UPDATE TO FIVE YEAR LAND SUPPLY AT 1ST APRIL 2021 WYRE FOREST DISTRICT COUNCIL Contents Page 1 Introduction Justification for applying a windfall allowance 3 Prior Notification Completions 6 Applying a Lapse Rate 9 Contribution of C2 Accommodation to Housing Supply 10 Five-year land supply calculations Tables Page 2 Table 1 Completions on non-allocated (windfall) sites since 2011 3 Table 2 Residential Completions Via Prior Notification Process 6 Table 3 Lapse rates in Wyre Forest District for large and small sites 2002-2020 8 Table 4 Details of Large site lapses 10 Scenario 1 11 Scenario 2 Scenario 3 12 Scenario 4 Scenario 5 13 Scenario 6 Scenario 7 14 Scenario 8 15 Scenario 9 Appendix 1 Details of Windfall Completions Appendix 2 C3 Housing Trajectory at 1st April 2021 Appendix 3 C2 Bedspaces Trajectory 2016-36 Update to five-year housing land supply at 1st April 2021 Introduction 1.1 Following the hearing session for Matter 7, the Council has been requested to put together a note setting out the compelling evidence for the use of a windfall allowance, details of prior approvals and their implementation, justification for the application of a lapse rate and further information on C2 developments in Wyre Forest District. A revised calculation of the five-year housing land supply at 1st April 2021 has then been made. 1.2 As set out previously, the Council is looking to fix its housing land supply through the Local Plan process until 31st October 2022 and would therefore wish to apply a 10% buffer. However, the Council is aware that the recent Housing Delivery Test result (January 2021) of 84% now means that a 20% buffer should be applied. (ID:68-010-20190722) For this reason, the estimated five-year supply at 1st April 2021 will be calculated with both a 10% and a 20% buffer. For the purposes of this calculation, it is also assumed that the proposed Local Plan allocations will all be taken forward. Justification for applying a windfall allowance 2.1 Table 10 of document ED10 (Five-year Housing Land Supply Report at April 1st 2020) sets out details of windfall completions on site of under 10 dwellings completed in the District since 2008. However, these sites are windfalls on previously developed sites as NPPF 2012 defined them and excludes development on gardens and barn conversions. Sites included in the Housing and Economic Land Availability Assessment were also excluded from this initial calculation. However, the latest NPPF 2018 and updated 2019 now defines windfalls sites as those that are not allocated in a local plan. Therefore, to give a more robust picture of recent development, a detailed analysis of all completions on non-allocated sites whether brownfield or greenfield has now been undertaken. This has resulted in a much higher number of windfalls. 2.2 Table 1 of this report shows the breakdown of windfall completions by year, type of site and size of site. Please note that this replaces the data shown at Table 10 in ED10. Further details of these windfall sites completions can be found at Appendix 1 to this report. 1 Table 1 Completions on non-allocated (windfall) sites since 2011 11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21 0-5 dws 26 38 54 47 50 75 45 36 43 33 6-9 dws 14 19 14 41 22 17 25 63 53 19 Total <10 40 57 68 78 72 92 70 99 96 52 dws Total 145 128 180 212 117 107 95 111 96 52 windfalls Number of 0 0 0 47 12 15 12 34 9 9 prior approvals included Brownfield 84% 73% 84% 90% 93% 84% 86% 95% 93% 75% Greenfield 16% 27% 16% 10% 7% 16% 14% 5% 7% 25% Total gross 235 227 382 462 235 271 165 187 201 240 completions 2.3 As the Local Plan proposes to allocate mainly sites over 10 dwellings, such sites have been excluded from the analysis. The table shows that windfalls have continued to make an important contribution to the housing supply alongside allocated sites. Since the start of the plan period in 2016, small site windfalls (<10 dwellings) have averaged 82 per year. Since 2013, the prior approval notification procedure has been available for the conversion of buildings to residential uses. Further details of these approvals can be found in this report at Table 2. This process has led to a marked increase in the supply of small flats especially in Kidderminster town centre where vacant offices have been converted into studio apartments by the private rented sector. These prior approval completions are included in the windfall totals. It should be noted though, that several of the schemes implemented within Kidderminster town centre have been much larger than 10 units. 2.4 The 10-year average for completions on small windfall sites of less than 10 dwellings is 72, whereas if only sites of 5 or fewer dwellings are included, this decreases to 45 dwellings. It is proposed to use 72 dwellings as the windfall allowance. Calculations of the 5-year housing land supply 2021-26 will also show the effect of only 75% or 50% of estimated windfalls coming forward in the future, that is 54 or 36 dwellings per annum. For the purposes of the 5YHLS calculations, the windfall allowance will not be applied to the first 3 years. This is because it is assumed that all windfall sites likely to be completed in the first 3 years will have already been through the planning process and would therefore result in double counting. As this windfall figure is based on actual completions and not approvals no lapse rate will be applied. A further discussion on lapse rates can be found at paragraph 4.1. 2 2.5 As discussed at the hearing sessions, the proposed allocations do include a small number of sites of less than 10 dwellings in the villages – a site at Wilden for 2 dwellings, a site in Upper Arley parish for 2 dwellings and 2 small sites in Caunsall for 3 and 4 dwellings and a site for 6 in Chaddesley Corbett. There is also an allocation for 10 dwellings in Upper Arley which may be too constrained to take this number of dwellings. These locations are in areas ‘washed over’ by Green Belt and it is possible that they may be able to come forward as windfalls rather than requiring allocation through the Local Plan. There is also an allocation for 3 dwellings on a garden plot in Kidderminster. Thus, the Council proposes to base its windfall allowance on the average number of windfall completions on sites under 10 dwellings. 2.6 The Council considers that small site residential windfalls will continue to come forward in the future in the form of small infill sites as envisaged under Policy 18B, together with conversions of former offices and agricultural buildings and sub-divisions of larger dwellings. Developments under Policy 18B will include garden infill sites subject to the design criteria set out in policy. As at 01/04/2021 there were 195 dwellings on windfall sites under construction with a further 244 on sites not yet started. Other than the 39 flat conversions at Towers Buildings in Kidderminster, those dwellings under construction were all on sites of less than 10 dwellings. This shows that windfalls are continuing to provide a substantial supply of dwellings and are expected to carry on doing so during the Plan period. The Council believes that a figure of 72 windfalls per annum going forward is justified by the evidence. This windfall allowance will not include large sites (the threshold for which is 10 or more dwellings). Prior Notification Completions 3.1 The introduction of the Prior Notification route for certain types of conversion to residential use in May 2013 has had a significant impact on the housing supply, particularly in Kidderminster Town Centre. Table 2 lists residential completions via this process with total completions for each financial year shown in bold. Codes for the parishes can be found in Appendix 1. Table 2 Residential Completions Via Prior Notification Process Application Address Parish Decision Expiry Description Number Year number Date Date of completed dwellings 13/3023/PN Oxford House & K 15/10/13 30/05/16 Change of use 28 14/15 Worcester House from offices 13/3033/PN 99 Coventry Street K 02/12/13 30/05/16 Change of use 11 14/15 from offices 13/3040/PN 29a Worcester K 14/01/14 14/01/17 Change of use 2 14/15 Street from offices 14/3073/PN Units A & B Oxford K 22/12/14 22/12/17 Change of use 2 14/15 House from offices 3 Application Address Parish Decision Expiry Description Number Year number Date Date of completed dwellings 14/3074/PN Units D & E Oxford K 22/12/14 22/12/17 Change of use 2 14/15 House from retail 14/3075/PN Worcester House K 22/12/14 22/12/17 Change of use 2 14/15 from retail 47 14/3035 94-98 B 15/07/14 30/05/16 Change of use 8 15/16 Kidderminster from offices Road 14/3040/PN Hundred Acre Br 15/09/14 15/09/17 Conversion of 2 15/16 Farm agricultural building 14/3029/PN r/o 46 George K 22/07/14 22/07/17 Change of use 2 15/16 Street from offices 12 15/3082/PN Station Yard, CB 26/01/16 26/01/19 Change of use 2 16/17 Blakedown from office 14/3023/PN 25-26 High Street K 05/06/14 05/06/17 Change of use 3 16/17 from office 14/3022/PN 25-26 High Street K 17/06/18 17/06/17 Change of use 3 16/17 from hairdressers 15/3036/PN 29 Worcester K 15/07/15 15/07/18 Change of use 2 16/17 Street from office 14/3069/PN Brockstone House, Ri 24/12/14 24/12/17 Change of use 1 16/17 Netherton Lane from Dunley agricultural 14/3059/PN Old Library Vale S 14/11/14 14/11/17 Conversion to 3 16/17 Road dwellings 14/3048/PN Blakeshall Farm, W 16/09/14 16/09/17 Change of use 1 16/17 Wolverley from agricultural 15 14/3052/PN Common Farm CB 03/11/14 03/11/17 Change of use 2 17/18 Barn, Crown Lane, of agricultural