Windfall Update Technical Paper 2024
Index
1. Introduction |
3 |
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2. Policy Context |
4 |
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3. Analysis of Windfalls in the City of York |
5 |
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4. Future Windfall Approach in the Local Plan |
15 |
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5. Conclusions |
27 |
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Annexes |
30 |
Annex 1: Windfall Trend Analysis
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31 |
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https://www.york.gov.uk/downloads/file/11252/windfall_allowance_technical_paper_2016
https://www.york.gov.uk/downloads/file/11252/windfall_allowance_technical_paper_2016
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% |
Graph 1: Historic Housing Completions Compared to Windfall Completions
· 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
3.12 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 |
Graph 2: Illustration of Historic Annual Windfall Completions by Size and Type
· 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[3], 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).
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% |
Graph 3: Very Small Windfall Site Completions
Graph 4: Conversion & Changes of Use Windfall Site Completions
Calculating an Appropriate Windfall Allowance
· 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
Threshold and Type of Windfall to be Included
· 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.
Windfall Trend Analysis
Graph 5: Net Windfall Completions 2014-2024
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
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 |
Windfall Allowance in Years 1-5 of the Housing Trajectory
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% |
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.
5.1 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.
Annex 1
Full Windfall Trend Analysis
Brownfield Land Windfalls (2014-2024)
Very Small Windfalls (Net) |
Small Windfalls (Net) |
Medium Windfalls (Net) |
Large Windfalls (Net) |
Conversions/ Changes of Use (Net) |
Total (Net) |
|
2014/2015 |
15 |
26 |
0 |
0 |
110 |
151 |
2015/2016 |
33 |
10 |
389 |
0 |
212 |
644 |
2016/2017 |
19 |
0 |
91 |
0 |
383 |
493 |
2017/2018 |
34 |
89 |
0 |
0 |
160 |
283 |
2018/2019 |
95 |
0 |
0 |
0 |
151 |
246 |
2019/2020 |
41 |
5 |
2 |
13 |
109 |
170 |
2020/2021 |
118 |
3 |
130 |
58 |
149 |
458 |
2021/2022 |
41 |
1 |
1 |
6 |
60 |
109 |
2022/2023 |
14 |
0 |
232 |
0 |
46 |
292 |
2023/2024 |
60 |
71 |
0 |
0 |
40 |
171 |
Totals 14-24 |
470 |
205 |
845 |
77 |
1420 |
3017 |
Greenfield Land Windfalls (2014-2024)
Year |
Very Small Windfalls (Net) |
Small Windfalls (Net) |
Medium Windfalls (Net) |
Large Windfalls (Net) |
Conversions/ Changes of Use (Net) |
Total (Net) |
2014/2015 |
1 |
0 |
24 |
0 |
6 |
31 |
2015/2016 |
1 |
1 |
0 |
0 |
4 |
6 |
2016/2017 |
7 |
0 |
0 |
0 |
16 |
23 |
2017/2018 |
15 |
2 |
2 |
0 |
6 |
25 |
2018/2019 |
8 |
0 |
0 |
2 |
4 |
14 |
2019/2020 |
7 |
6 |
2 |
0 |
2 |
17 |
2020/2021 |
1 |
17 |
11 |
0 |
3 |
32 |
2021/2022 |
0 |
7 |
0 |
3 |
4 |
14 |
2022/2023 |
0 |
0 |
0 |
0 |
1 |
1 |
2023/2024 |
2 |
0 |
0 |
0 |
3 |
5 |
Totals 14-24 |
42 |
33 |
39 |
5 |
49 |
168 |
Combined Brownfield and Greenfield Windfalls (2014-2024)
Year |
Very Small Windfalls (Net) |
Small Windfalls (Net) |
Medium Windfalls (Net) |
Large Windfalls (Net) |
Conversions/ Changes of Use (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 |
[1] For the purposes of this paper, we have excluded equivalent homes provided through communal establishments such as care homes and on campus student accommodation that are based upon bedspaces and calculated using a national ratio based upon census results.
[2] The most significant allocated sites providing homes during 2017/18 were St Joseph’s Convent, Lawrence Street (526) Hungate (195) Former Terry’s Factory Site Bishopthorpe Road (88) and Former Grain Stores Water Lane (82)
[3] Stonebow House, Diocese House (Aviator Court) and British Red Cross (Marsden Park) saw 13, 10 and 4 completions respectively during the monitoring period.