Windfall Update
Technical Paper 2024
Index
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1.
Introduction
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3
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2.
Policy Context
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4
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3.
Analysis of Windfalls in the City of York
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5
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4.
Future Windfall Approach in the Local Plan
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15
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5.
Conclusions
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27
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Annexes
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30
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Annex 1: Windfall Trend
Analysis
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31
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1.1
In addition to our previous Windfall Allowance Technical Papers
that formed part of the evidence base to support the City of York
Local Plan through consultation and hearings held in 2022, this
paper updates our evidence to 1st April 2024 and
continues to support the justification for a windfall allowance
within the future housing land supply calculations.
1.2
Where appropriate, reference is made to our previous Technical
Papers to ensure this update is concise whilst it also aligns with
current national policy and guidance.
NPPF
Windfall Definition
2.1
As the City of York Local Plan is being examined under the
transitional arrangements set out in Annex 1 to the revised
National Planning Policy Framework, the policies in the previous
version of the framework published in 2012 will continue to apply,
as will any previous guidance which has been superseded since the
new framework was published in July 2018.
2.2
Paragraph 48 of the 2012 NPPF and revision note to the NPPG of
March 2014 provides clarity on the appropriateness in the use of
windfalls, whilst paragraphs 2.1 to 2.5 of the City of York Council
Local Plan Windfall Allowance Technical Paper (July 2016) expand on
these details. (See link below)
https://www.york.gov.uk/downloads/file/11252/windfall_allowance_technical_paper_2016
2.3
The Revised National Planning Policy Framework (NPPF) of December
2023 and National Planning Policy Guidance (NPPG) both provide
direction upon what constitutes a windfall and when it is
appropriate to include an allowance within the future housing
supply trajectory. It is confirmed in the Framework that a windfall
allowance can be made for windfall sites in housing supply
assumptions, subject to ‘compelling evidence that they will
provide a reliable source of supply’. It is further advised
that any allowance ‘should be realistic having regard to the
strategic housing land availability assessment, historic windfall
delivery rates and expected future trends’. For decision
making purposes the most recent versions of the NPPF and PPG
apply.
City
of York Windfall Definition
2.4
Consistent with our earlier technical papers’ windfall
definition we have excluded all previously identified sites from
our analysis and removed all historic garden infill sites. We have
included changes of use brought about through relaxed permitted
development rights (now made permanent), also known as ‘prior
approval’ sites along with completions resulting from
un-allocated off-campus privately managed student accommodation
completions. Both Brownfield and Greenfield unidentified windfall
sites are included within our calculations. A full explanation of
this definition is included in paragraphs 2.7 to 2.12 of our
earlier 2016 Technical Paper and can be viewed via the link
provided below.
https://www.york.gov.uk/downloads/file/11252/windfall_allowance_technical_paper_2016
Historic Windfall Delivery and Trends
Experienced in York’s Housing Market
3.1
Analysis of our historic housing completion figures indicates that
a considerable element of York’s housing supply has been
provided through un-identified windfall sites.
3.2
Table 1, below, shows that of the 6,921 net additional
homes
built in York during the last 10 years (2014-2024), a total of
3,185 homes have resulted from completions on windfall sites,
representing over 46% of all completions over that period.
3.3
Over the last 10 years completions through windfalls averaged over
318 net new homes per year, peaking at 650 in 2015/16, whilst just
123 homes were added to the housing stock in 2021/22. Nearly 79% of
all completions in 2020/21 were because of windfalls. However, just
under 24% of completions in 2017/18 were through windfalls. Out of
528 net housing completions last year (2023/24) 176 (33.33%) were
due to completions on windfall sites.
Table
1: Historic Annual Windfall Completions
|
Year
|
Net
Dwelling Gain
|
Net
Windfall Completions
|
Windfalls as a %
of all Net Completions
|
|
2014-2015
|
507
|
182
|
35.90%
|
|
2015-2016
|
1121
|
650
|
57.98%
|
|
2016-2017
|
977
|
516
|
52.81%
|
|
2017-2018
|
1296
|
308
|
23.77%
|
|
2018-2019
|
449
|
260
|
57.91%
|
|
2019-2020
|
560
|
187
|
33.39%
|
|
2020-2021
|
622
|
490
|
78.78%
|
|
2021-2022
|
402
|
123
|
30.60%
|
|
2022-2023
|
459
|
293
|
63.83%
|
|
2023-2024
|
528
|
176
|
33.33%
|
|
2014-2024
|
6921
|
3185
|
46.02%
|
3.4
Graph 1 below shows how windfalls have generally mirrored overall
trends of housing completions over the last ten years reflecting
both periods of growth and recession. This has largely been true
other than during 2017/18 when significant levels of housing
development was carried out on allocated sites with 958
homes resulting from this source – none of which, by
definition, can be counted as windfalls.
Graph
1: Historic Housing Completions Compared to Windfall
Completions
3.5
In general, other Local Authorities use a larger threshold of
around 0.4 ha for site identification within their urban capacity
studies. City of York Council has adopted 0.2 ha as its threshold,
which recognises that the supply of housing from this type of site
has provided a significant contribution to past housing
completions.
3.6
Using the last ten-year monitoring period to estimate the future
supply of windfall delivery should ensure that neither an overly
optimistic nor pessimistic projection for windfalls will be
applied. As this document updates our previous technical papers
with the inclusion of our 2023/24 completions it reflects the most
recent market trends to ensure the most robust evidence base has
been used.
3.7
Historic housing windfall rates for the entirety of City of York
Council area have been recorded for several years and form a subset
of the housing completions figures that have appeared within our
Annual Monitoring Reports. The tables provided below show evidence
of historic windfall completions based on size of site and type and
have been compared against overall housing completion figures by
way of context.
3.8
All past completions that appear in the tables have been based
on;
·
Development Management housing consents – a record of
decisions on planning applications is updated monthly
·
Completions returns provided by our Building Control team
·
Site visits carried out on a 6 monthly basis to check
completions
·
Contact with applicants, developers, and agents at regular
intervals to confirm both completion and predicted completion
levels, and
·
Monitoring of extant consents, new permissions and inclusion of
development given lawful use through certificates of lawful
development (previously not included within housing returns).
·
Council tax records
3.9
Table 2 below provides details of the number of housing windfall
completions over the ten-year period from April 2014 to March 2024,
split by size and type. It should be noted that two of the main
contributors to net additions to the housing windfall supply over
that period came from conversions (inclusive of changes of use)
with 1,469 and from sites below 0.2 hectares (very small windfall
sites) with 512. These totals are significant in as much as they
fall outside the threshold used to identify potential housing
allocation sites in our emerging Local Plan and will not be
identified in future years.
3.12 This
analysis of previous windfalls is carried out using the following
categories;-
·
Very small windfalls – on sites less than 0.2
hectares
·
Small windfalls – on sites between 0.2 and 0.4
hectares
·
Medium windfalls – on sites between 0.4 and 1.0
hectares
·
Large windfalls – on sites over 1.0 hectares
·
Windfalls resulting from changes of use to residential
properties and conversions to existing residential units
Table
2: Historic Annual Windfall Completions Separated into Size and
Type
|
Year
|
Very
Small Windfalls (Net)
|
Small
Windfalls (Net)
|
Medium Windfalls
(Net)
|
Large
Windfalls (Net)
|
Conversions
(Net)
|
Total
(Net)
|
|
2014/2015
|
16
|
26
|
24
|
0
|
116
|
182
|
|
2015/2016
|
34
|
11
|
389
|
0
|
216
|
650
|
|
2016/2017
|
26
|
0
|
91
|
0
|
399
|
516
|
|
2017/2018
|
49
|
91
|
2
|
0
|
166
|
308
|
|
2018/2019
|
103
|
0
|
0
|
2
|
155
|
260
|
|
2019/2020
|
48
|
11
|
4
|
13
|
111
|
187
|
|
2020/2021
|
119
|
20
|
141
|
58
|
152
|
490
|
|
2021/2022
|
41
|
8
|
1
|
9
|
64
|
123
|
|
2022/2023
|
14
|
0
|
232
|
0
|
47
|
293
|
|
2023/2024
|
62
|
71
|
0
|
0
|
43
|
176
|
|
Totals
14-24
|
512
|
238
|
884
|
82
|
1469
|
3185
|
3.13
Both Table 2 and Graph 2 provide a complete picture of the overall
levels of windfall completions over the last ten years.
3.14
Graph 2 displays the fluctuations experienced in past windfall
supply. It shows that on sites over 0.2 ha significant variations
have taken place. By comparison sites below 0.2 ha and completions
resulting from changes of use and conversions to existing homes
vary less (other than in 2016/17 when 399 homes from conversions
and change of use were completed) and have provided a relatively
constant source of additional new homes over the monitoring
period.
3.15
Some of the more significant completions making up these variations
were carried out within the windfall categories resulted from the
following:
·
In 2015/16 a total of 389 homes were provided on medium sized
sites, these arising from the student accommodation completed at
the Old Yorkshire Evening Press Site, 76-86 Walmgate (361 homes)
and the retirement homes completed on the former Fox & Hounds,
Copmanthorpe (28 homes).
·
2015/16 also experienced significant levels of windfall completions
through changes of use. Holgate Villa (50) 3 Pioneer Business Park
(19) and Matmer House, Hull Road (14) being the three largest
contributers in this category.
·
In 2016/17 a total of 399 net new homes resulted from conversions
or changes of use and of this number 252 homes came about through
sites benefitting from ‘prior approval’. United House,
Piccadilly (119) Castle Chambers, 7-13 Clifford Street (25), the
William Birch & Sons Ltd former offices in Foss Place, Foss
Islands Road (24) were the largest contributors within this
category.
·
During 2016/17 61 student accommodation units resulted from the
change of use of 2-14 George Hudson Street.
·
In 2017/18, a total of 89 new student flats were competed at St
Lawrence WMC, 29-33 Lawrence Street on a small site (the scheme
also resulted in a total of 19 net new flats as part of the change
of use to the original structure)
·
2018/19 saw a rise in completions on sites of below 0.2 ha with 103
homes resulting from this source. Of this total 38 student flats
were completed at the former Herbert Todd & Son land at Percy
Lane, whilst a further 34 over 55’s homes have been
constructed at the former Oliver House site in Bishophill
Junior.
·
61 sites provided 155 homes resulting from changes of use and
conversion of residential properties during 2018/19. Of this total,
3 sites benefiting from prior approval (relaxed planning rules
allowing conversion of office buildings) resulted in 27 new
homes,
whilst the change of use to both Rowntree Wharf (25) and Former
London’s Toy Shop in Hawthorne Grove (10) made significant
contributions within this category.
·
During the 2019/20 monitoring year the largest contributions to
windfall completions resulted from the changes of use and
conversions category with a net total of 111 additional homes
delivered on 45 sites, the most significant development being 17
student flats at the Fleeting Arms, Gillygate. Whilst a further 48
net new homes were completed on sites below 0.2ha with 21 student
flats at the Coal Yard site in Mansfield Street and 14 dwellings at
the former Fire Station, 18 Clifford Street being the most
significant contributors to the housing supply within this
sub-set.
·
2020/21 saw the highest level of net completions on sites below 0.2
ha with 119 homes – the most significant contributors to this
number being 32 flats at 1 Redeness Street, a further 19 student
‘cluster’ flats at 11 Redeness Street, and 14 homes
each provided at the site to the rear of 33 Bootham, Thomas Dick
Ltd site on Hallfield Road and North Lodge re-development site on
Clifton Park Avenue.
·
A further 152 homes were created in 2020/21 through conversion and
change of use – the largest of which were carried out at
Ryedale House (77) and Shepherd Engineering Services, Mill Mount
(22)
·
232 student ‘cluster’ flats were complete in 2022/23 at
Frederick House, Fulford Road – this site falling into the
medium windfall category.
·
14 homes were provided on very small sites, whist 47 were completed
through changes of use and conversions during the 2022/23
monitoring period – both totals representing the lowest
within their categories over the last 10 years reflecting the
market conditions affecting the house building industry post
covid.
·
19 net additional student ‘cluster’ flats at Aubrey
House, Foss Islands Road together with 9 new flats at 11 The
Crescent and 7 new homes at the Former Glen Garage, Heworth helped
contribute towards a total of 62 net new homes on sites below 0.2
ha in the 2023/24 monitoring period.
·
During the same period 71 homes were completed on small sites all
coming from the Former Vacant Site, Eboracum Way (62) and Former
George Chapman (York) Ltd site at 86 Heworth Green (9).
3.16
Sites over 0.2 ha are shown to display more significant and varied
levels of annual completions and greater ranges within the totals
making any future trends more difficult to predict.
3.17 A
further breakdown of the windfall completion figures, as displayed
in Table 3 below, highlights that over 62% of all windfall
completions during the past 10 years took place either on very
small sites below 0.2 ha or through changes of use to residential
properties and conversion of existing homes. Neither of this type
of site is likely to be picked up in housing land assessments and
is, therefore, more appropriate for use in potential future
windfall projections.
Table
3: Breakdown of Windfall Completions by Size and Type
|
Size/Type of
Windfall
|
Ten
Year Total
|
Ten
Year Mean Average
|
Windfall Types as
a % of Total Windfalls
|
|
Very Small
Windfalls (< 0.2 ha)
|
512
|
51.2
|
16.08%
|
|
Small Windfalls
(0.2 – 0.4 ha)
|
238
|
23.8
|
7.47%
|
|
Medium Windfalls
(0.4 – 1.0 ha)
|
884
|
88.4
|
27.76%
|
|
Large Windfalls
(> 1.0 ha)
|
82
|
8.2
|
2.57%
|
|
Conversions/Changes
of Use
|
1469
|
146.9
|
46.12%
|
|
Totals
|
3185
|
318.5
|
100.00%
|
3.18
Graphs 3 and 4 below show a representation of the last 10 years of
windfall sites of less than 0.2 ha and conversions and changes of
use. Both graphs display the range between the highest and lowest
completion years.
3.19 For
sites below 0.2ha housing completions reached 119 during 2020/21,
the highest level achieved within this category over the ten-year
monitoring period. Other than for monitoring years 2018/19 and
2020/21 completions from this type of site have generally remained
stable over the 10-year analysis period.
3.20 The
low figure of 14 homes achieved during the 2022/23 in the below
0.2ha category was out of character with typical completion levels
and was almost certainly the result of labour, material shortages
and changed working practices that affected the house building
industry during the post covid period.
3.21
Completions through change of use and conversions of existing
properties increased significantly in 2015/16 when over 200 new
homes were created and almost 400 further homes coming from this
category in 2016/17. This spike in delivery can be associated with
the relaxation of permitted development rights introduced by
central government in 2013. These ‘prior approval’
sites have become a continued source of supply following the
relaxation of rights that have not only been made permanent but
also expanded upon. Since 2017/18 there has been a drop in
completions from this source. However, 306 net new homes have been
provided in this category over the last four years despite the
impact Covid-19 has had on working practices and continues to
provide a significant supply of homes within the authority
area.
Graph
3: Very Small Windfall Site Completions
Graph
4: Conversion & Changes of Use Windfall Site
Completions
Calculating
an Appropriate Windfall Allowance
4.1
Several factors need to be considered before determining a
realistic housing windfall allowance. The following issues are
highlighted within this part of the paper before setting our
proposed approach to windfall projections. These include:
·
An
appropriate timescale for historic windfall evidence
·
The
threshold and type of windfall to be included.
·
Trend
analysis and the appropriate trend timescale to be used to ensure
market conditions are reflected appropriately.
·
When
windfalls should appear in the housing trajectory
·
What
level of windfalls should be applied to future housing projections
·
Should discount
rates be applied to future windfall allowances, and
·
What
risks are there in including windfalls within a future housing land
supply?
Timescale
Used to Provide Historic Windfall Evidence
4.2
The timescale for analysing historic windfall completions has been
considered and following a review of other local authority windfall
papers, the use of the last ten years' figures is considered to be
most appropriate, particularly as this period includes a wide range
of market conditions.
4.3
Longer periods of historic completions records have been used in
some authority windfall completions analysis whilst less reference
shorter historic records. The advantage of using a 10-year trend
ensures that the full cycle of market conditions that have taken
place during that time should ensure that neither an overly
optimistic nor pessimistic projection for windfalls will be
applied. A rolling 10-year windfall trend incorporated annually
within the housing trajectory will ensure that any upturn or
decrease in supply will be accounted for within future windfall
allowances. By using a longer historic record this fluctuation
could be lost within a larger dataset.
Threshold
and Type of Windfall to be Included
4.4
Research reveals that other planning authorities have set varying
thresholds when considering what type of windfall site should be
included within any allowance in future years. These have broadly
been based on either capacity (potential number of homes that have
been developed on individual sites, often set at 10 or more
dwellings) or simply a size of site threshold.
4.5
City of York Council does not view a capacity threshold as
providing the most meaningful approach to identifying sites. Site
location tends to influence the number of acceptable homes
appropriate for each site, and individual site constraints may
affect overall capacity. Over time this could result in similar
sites being included within the figures or excluded elsewhere
dependant on the location and changing market circumstances. These
characteristics are difficult to monitor and can provide unbalanced
evidence.
4.6
A size threshold, often of around 0.4 ha, has been used in several
authority areas in analysing past windfall performance. This aligns
with their SHLAA thresholds used in identifying potential future
allocations.
4.7
Preference in York is for a size threshold of 0.2 ha throughout the
authority area in our analysis of windfalls, and this accords with
that set within the ‘call for sites’ to support the
Local Plan. Although we have recorded windfalls above the 0.2 ha
threshold, we do not intend to project forward an allowance for
this type of site within the future housing supply for a variety of
reasons:
·
The monitoring period covers a time in which we did not have a
formally adopted development plan in place. Therefore, sites of
this nature have not previously been identified as allocations.
With a comprehensive Local Plan that includes identified site
allocations for the full trajectory period and regular SHLAAs
planned over the future years we expect to capture these sites as
allocations rather than as windfall sites.
·
As can be seen from the graphs showing past delivery of this type
of site, evidence reveals that the supply of housing from these
sites is less predictable in the delivery of housing and projecting
forward these rates could prove to be unreliable.
4.8
Changes of use and conversions of existing residential dwellings
have delivered a steady and reliable source of housing in York
throughout the monitoring period, even during recessionary and post
pandemic times. This supply is likely to continue because of the
announcement that the temporary measures introduced in 2013 to
relax the permitted development rights, relating to the conversion
of offices to residential use, have now been made permanent and
recently expanded upon. As consented conversions of this type are
already included within the unimplemented housing permissions and
therefore accounted for within the housing trajectory, no increase
in the rate of this type of windfall is proposed. However, future
monitoring will take account of any variations and appropriate
allowances will be made accordingly throughout the plan
period.
Windfall
Trend Analysis
4.9
A relatively simple method for estimating a general trend in a set
of data is to add a linear trend line to a chart. A trend line
shows results within a chart, but it doesn't connect each data
point precisely as a line chart does. A trend line takes account of
all the data meaning that minor exceptions or statistical anomalies
will not distort the output. In some circumstances the use of a
trend line is an aid in forecasting future figures.
4.10
When applying a trend line to overall windfall completions carried
out between 2014 and 2024 the overall linear trend indicates a
decline in completions over the monitoring period (see Graph 5
below).
Graph
5: Net Windfall Completions 2014-2024
4.11
When we consider trend analysis of specific windfall rates, we have
included records for both the whole ten-year monitoring period
together with trends over the shorter term i.e. the last five
years. In so doing we hope to pick up on any shorter-term
fluctuations being experienced within the housing market to confirm
that appropriate estimations are being applied to projected
windfall delivery.
4.12
Further evidence shows that, for the two windfall types we deem
appropriate for inclusion within our projected future housing
supply, the following characteristics are apparent.
4.13
Graphs 6 and 7 reveal that in terms of very small windfalls (sites
below 0.2 ha) the ten-year trend is one of improving numbers, with
over 284 homes being built within this category over the last five
monitoring years helping to set the trend (see paragraph 3.18
earlier in this paper for details). A fall in the trend of
completions from this source has taken place over the last 5 years
which is understandable considering the impact the pandemic has had
on the housing development industry since 2020.
4.14
Conversions and changes of use completions (see Graphs 8 and 9)
indicate a decreasing trend over the longer term. This decline has
been replicated over the shorter 5-year period and almost certainly
has resulted from the impact of the pandemic and the wider
materials and labour shortages experienced nationally. With the
‘prior approval’ regulations now being made permanent
and expanded further during the last couple of years this source of
future housing supply is anticipated to provide healthy levels of
future housing completions when the market corrects itself after
the effects of adverse market conditions during the post covid
years.
Graph
6: Net Very Small Windfall Completions 2014-2024 (Sites
<0.2ha)
Graph
7: Net Very Small Windfall Completions 2019-2024 (Sites
<0.2ha)
Graph
8: Net Conversions and Changes of Use Windfall Completions
2014-2024
Graph
9: Net Conversions and Changes of Use Windfall Completions
2019-2024
4.15 The
following tables provide details of the trends associated with the
different types of windfalls over both the longer ten year and
shorter five-year historic monitoring periods.
Table
4: Combined Brownfield & Greenfield Windfall Completion
Trends
|
Type
of Windfall
|
10
Year Trend
|
5
Year Trend
|
|
Very
Small Sites (<0.2 ha)
|
ñ
|
ò
|
|
Small
Sites (0.2 to 0.4 ha)
|
ñ
|
ñ
|
|
Medium
Sites (0.4 to 1.0 ha)
|
ò
|
ñ
|
|
Large
Sites (>1.0 ha)
|
ñ
|
ò
|
|
Conversions
and Changes of Use
|
ò
|
ò
|
|
All
Brownfield/Greenfield Windfalls
|
ò
|
ò
|
Key
|
Decrease
|
ò
|
|
No Significant
Change
|
ó
|
|
Increase
|
ñ
|
The following
tables (5 and 6) provide a breakdown of the preceding table’s
trends according to their type, whether greenfield or
brownfield
Table
5: Brownfield Windfall Completion Trends
|
Type
of Windfall
|
10
Year Trend
|
5
Year Trend
|
|
Very
Small Sites (<0.2 ha)
|
ñ
|
ò
|
|
Small
Sites (0.2 to 0.4 ha)
|
ó
|
ñ
|
|
Medium
Sites (0.4 to 1.0 ha)
|
ò
|
ñ
|
|
Large
Sites (>1.0 ha)
|
ñ
|
ò
|
|
Conversions
and Changes of Use
|
ò
|
ò
|
|
All
Brownfield Windfalls
|
ò
|
ò
|
Table
6: Greenfield Windfall Completion Trends
|
Type
of Windfall
|
10 Year
Trend
|
5 Year
Trend
|
|
Very
Small Sites (<0.2 ha)
|
ò
|
ò
|
|
Small
Sites (0.2 to 0.4 ha)
|
ñ
|
ò
|
|
Medium
Sites (0.4 to 1.0 ha)
|
ò
|
ò
|
|
Large
Sites (>1.0 ha)
|
N/A
|
N/A
|
|
Conversions
and Changes of Use
|
ò
|
ó
|
|
All
Brownfield Windfalls
|
ò
|
ò
|
4.16 Our
monitoring shows that an upward trend in supply on very small,
small, and large sites has been experienced over a 10-year
monitoring period. However, over the shorter 5-year period most of
the categories show a decline in supply. This reflects the impacts
that the pandemic and material shortages have had during the
shorter term on the house building industry.
4.17
Notably the type of windfall sites we intend to project forward
within our housing trajectory such as those below 0.2ha show an
upward delivery trend over the long term and a decrease in supply
over the last five years, whilst completion levels through changes
of use and conversions remain relatively high, even though falling
over the previous 5-year monitoring period. This evidence has been
used to project forward a mean average of past performance within
these categories of windfall sites within the housing
trajectory.
4.18 For
a complete record of windfall trends separated into Greenfield and
Brownfield sites and the full range of categories analysed over the
last five and ten-year periods see Annex 2 of this document.
Windfall
Allowance in Years 1-5 of the Housing Trajectory
4.19 Our
unimplemented housing consents records reveal that from a total of
8,719 homes with consent there were 1,273 net additional homes with
extant consent on 1st April 2024 on sites regarded as
windfalls (see Table 7). Of this total 554 had gained consent on
sites of less than 0.2 ha or could result from changes of use or
conversions to existing dwellings. Further scrutiny of the data
shows that within this number 131 net homes have approval as a
result of ‘prior approval’, whilst a further 336 are
student cluster flats that have gained approval on previously
unidentified sites. All this evidence indicates that a continued
supply of homes built on consented windfall sites should be
maintained within the short term.
Table 7: Potential
Windfall Sites with Extant Consent on 1st April
2024
|
Size/Type of
Windfall
|
Brownfield
Sites
|
Greenfield
Sites
|
Total
BF +GF Sites
|
Windfall Types as
a % of Total Windfalls
|
|
Very Small
Windfalls (< 0.2 ha)
|
220
|
11
|
231
|
18.15%
|
|
Small Windfalls
(0.2 – 0.4 ha)
|
187
|
2
|
189
|
14.85%
|
|
Medium Windfalls
(0.4 – 1.0 ha)
|
151
|
1
|
152
|
11.94%
|
|
Large Windfalls
(> 1.0 ha)
|
77
|
301
|
378
|
29.69%
|
|
Conversions/Changes
of Use
|
289
|
34
|
323
|
25.37%
|
|
Totals
|
924
|
349
|
1273
|
100.00%
|
4.20 We
do not consider it to be appropriate to include a windfall
allowance within the first three years of the housing trajectory.
This will provide an appropriate time scale for any applications on
sites which would ultimately result in windfall completions to go
through the development process. This timescale also allows for
completions of windfalls with extant consent to be built out at
reasonable lead in times and, therefore, avoid double
counting..
4.21
Phasing in a windfall allowance will provide more certainty in the
early part of the trajectory and will avoid double counting. The
estimation of housing supply will, therefore, be based on known
consented development and anticipated delivery schedules provided
by applicants/developers rather than relying on unidentified
windfall sites providing homes in the early part of the Plan.
4.22
Consideration has also been given to an approach whereby windfalls
were only to be accounted for beyond the first 5 years of the
trajectory. Whilst this method would avoid any potential double
counting and only rely on extant consents and identified draft
allocations for completions in the 5-year housing supply, it would
represent a very cautious view of windfall projections. Trend
analysis shows that a significant supply of windfall completions
within the categories to be projected forward has been evidenced in
both the longer and short term.
4.23
Further, with the relaxed permitted development rights now made
permanent and expanded upon around two years ago, and the consent
analysis indicating that this type of development continues to come
forward, it is highly likely that windfalls will continue to
contribute significant levels of new housing in future years.
The
Level of Windfalls to be included in Future Housing
Projections
4.30 In
taking a proportionate approach to identifying land for development
in the emerging Local Plan only sites above 0.2ha have been
identified as draft allocations. To ensure that we properly
understand the potential for development on very small sites below
this allocation threshold an assessment of the trends in the
historicrate of windfall
delivery along with changes of use and conversions has been carried
out.
4.31 It
should be noted that this monitoring period covers a time in which
York had no adopted development plan and, therefore, continued high
levels of windfall supply are unlikely to be maintained over the
plan period, especially in the case of larger windfall sites above
0.2 ha (the threshold used for the allocation of sites). This is
important to note because the NPPF requires not just compelling
evidence of historic windfall rates but also evidence of expected
future trends to justify the use of a windfall allowance within
housing supply.
4.32 During
the last 10 years housing supply from net windfall sites, by far
the largest proportion derives from conversions/change of use and
from very small windfalls (sites below 0.2ha). These totals are
significant in as much as they fall outside the threshold used to
identify potential housing sites in the Local Plan and therefore
will not otherwise be identified in future years. By including a
qualified allowance for this type of windfall within the housing
supply this would ensure that an appropriate estimate of future
windfall supply is included within the housing trajectory. The
figure for windfalls proposed to be projected forward is 198
dwellings per annum which is effectively a mean average for these
two categories of windfalls calculated over a 10-year period. (See
Table 8, below, for details)
Table
8: Projection of Windfall Sites <0.2 ha and Change of Use and
Conversions
|
Average Windfall
Completions on Very Small Sites (< 0.2 ha)
|
51
|
|
Average Windfall
Completions Resulting from Change of Use/Conversion
|
147
|
|
Mean Average
Projected Annual Windfall Rate
|
198
|
Applying Discount Rates to the Future Windfall
Allowance
4.33
A discount rate can be applied to both the delivery of identified
consented sites and housing allocations to allow for uncertainty
within the market. This discount rate is typically around 10% based
on evidence of past housing delivery of consented sites and
comparison with other local authority non-delivery rates.
Alternatively, an additional allowance in housing supply can be
made. A discount rate for the future supply of housing from
windfall sites (i.e. as yet unidentified windfalls without the
benefit of consent) has been considered especially in the case of
small sites below 0.2 ha. This acknowledges that the capacity of
unidentified sites to accommodate future windfall development is
finite within a constrained urban area.
4.34
A constant and significant delivery of homes resulting from changes
of use from offices is currently being experienced largely a result
of relaxed permitted development rights. Whilst this source of
supply is finite and may reduce over time it is too early to
predict such an outcome bearing in mind that we continue to
experience completions resulting from the legislative
change.
4.35
However, because of our analysis of delivery trends (see Section 3)
indicating marginally significant levels of changes of use and
conversion of existing properties over the last 10 years and
increasing levels of housing resulting from sites below 0.2
hectares, the discounting of projected windfalls for these reasons
is not deemed appropriate at this time.
4.36
Should planning policy change in future years this approach may be
reconsidered and potentially a discount rate applied at that
time.
5
Conclusions
5.1
Several factors have been considered in determining a realistic
housing windfall allowance. The following sets out our
intended approach:
·
Timescale for historic windfall evidence
Use
of selected completions from the last 10 years ensures that the
full cycle of market conditions that have taken place during that
time are considered. See paragraphs 4.2 and 4.3.
·
Threshold and type of windfall to be included
Very
small sites (below 0.2ha) and change of use/conversions will be
monitored as the basis for our projections. See paras 4.4 to
4.9.
·
When to introduce windfalls into the housing trajectory
To avoid double counting
and allow time for sites to continue through the development
process, windfalls will be included from year 4. See paras
4.21 to 4.29.
·
What level of windfalls should be included in the housing
trajectory
A figure of 198 dwellings
per annum provides an appropriate level reflecting past development
trends. See paras 4.30 and 4.32.
·
Discounts
We
do not intend to apply a discount to windfall projections.
See para 4.33 to 4.36.
