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Changes to Planning Policy guidance on affordable housing are long overdue. Guidance note PPG3 was last updated in 2000, a move that supposedly "put in place policies [to] radically alter the way in which we build homes in this country," as deputy prime minister John Prescott said at the time. However, although affordable housing was purportedly one of the central tenets of the update, the supporting guidance remained unaltered.

More changes are proposed now: paragraphs 9-20, paragraph 71 and annex B of the guidance are likely to go, replaced with 17 new paragraphs; and a guide on planning and affordable housing will effectively replace Circular 6/98, complementing existing good practice on local housing needs assessment.

There is an important point of principle here. Planning and circular guidance carry more weight than good practice advice, which is neither an expression of government policy nor subject to consultation. It is true that the consultation paper on the changes includes a series of proposed headings for topics to be included in the good practice guide, but these give little clue as to its contents. Largely, these will reflect the professional judgment of the consultants commissioned to prepare it.

Undoubtedly, some of the contents of the circular, particularly those concerned with section 106 planning gain agreements, will sit more comfortably within good practice advice. However, there are serious reservations over some of the information likely to be removed from policy guidance.

Although Circular 6/98 is flawed, it does contain guidance that should be retained:

• broad parameters for carrying out local housing needs assessments
  
• targets for affordable housing in development plans
  
• site size thresholds for negotiating affordable housing
  
• site-specific information.

These matters are too important to be relegated to mere advice. They should be retained, encapsulated within a brief additional annex to the planning guidance.

The good news
There are some welcome policy changes included in the guidance, however. For example, it recognises that strategic housing needs assessment is as important as the equivalent in local housing management, a fundamental point to achieving integrated regional planning and housing strategies.

Welcome though some of the proposals are, they are hardly sufficient to generate a significant increase in affordable housing delivery

The greater flexibility to fix site size thresholds in a manner appropriate to local circumstances rather than to a centralised standard is also good news, as is the reduction in this national norm from 25 homes to 15.

The guidance's recognition that tenure may be material in some circumstances is useful, although it is odd that housing minister Keith Hill has referred to the need for "mixed tenure developments if we are to get truly thriving communities", as this statement goes further than the actual proposals.

But, welcome though some of the proposed changes are, they are hardly sufficient to generate a significant increase in affordable housing delivery, unless accompanied by a major increase in public expenditure.

In particular, the reduction in site size thresholds may not yield a proportionate increase in output, because small brownfield sites are likely to prove more difficult than larger greenfield sites, on which provision can be achieved more easily.

Additionally, the abolition of the rural exceptions scheme is likely to hinder delivery in such areas (HT 17 October, page 34).

The proposals' relationship to the current review of planning obligations is also unclear. Green paper documents on planning refer to affordable housing as "a fundamental component of sustainable development". What will ultimately prove crucial is the priority accorded to affordable housing, relative to other competing planning obligations.