Deliverable five year housing land supply statement 1 April 202 4to 31 March 2029

1.0 Introduction

1.1 The National Planning Policy Framework 2023(NPPF), sets out the government’s planning policies for delivering a sufficient supply of homes. Paragraph 76states that local planning authorities are not required to identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing for decision making purposes if the following criteria are met: 

• a) their adopted plan is less than five years old
• b0 and b) that adopted plan identified at least a five year supply of specific, deliverable sites at the time that its examination concluded. 

1.2 Paragraph 77 goes on to state that in all other circumstances, local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide either a minimum of five years’ worth of housing, or a minimum of four years’ worth of housing if the provisions in paragraph 226 apply. The supply should be demonstrated against either the housing requirement set out in adopted strategic policies, or against the local housing need where the strategic policies are more than five years old. Where there has been significant under delivery of housing over the previous three years, the supply of specific deliverable sites should in addition include a buffer of 20% (moved forward from later in the plan period).

1.3 In Blackpool’s case, this statement sets out Blackpool’s deliverable five year housing land supply for the period 1 April 2024 to 31 March 2029 against the local housing need (standard method figure) as Blackpool’s strategic housing policy is more than five years old.

2.0 The five year housing requirement

2.1The Blackpool Local Plan Part 1: Core Strategy (Core Strategy) was adopted in January 2016 and sets out the housing requirement for Blackpool. Core Strategy Policy CS2 (Housing Provision) states that provision will be made for the delivery of 4,200 new homes in Blackpool between 2012 and 2027. Paragraph 5.20 of the supporting text sets out that this is a phased target equating to: 

• 250 dwellings per annum between 2012 to 2017 

• 280 dwellings per annum between 2017 to 2022 

• 310 dwellings per annum between 2022 to 2027 

This is an average of 280 dwellings per annum.

2.2 However, as the core strategy was adopted over five years ago (January 2016), paragraph 77 of NPPF is relevant. It states ‘supply should be demonstrated against either the housing requirement set out in adopted strategic policies, or against the local housing need (standard method) where the strategic policies are more than five years old’.

2.3 Blackpool’s local housing need calculated using the standard method (2024)with respect to the five year supply for the five year period 1 April 2024 to 31 March 2029 is 735 dwellings (147 per annum).

2.4 PPG states that the 5% buffer should be increased to 20% where there has been significant under delivery of housing over the previous 3 years, to improve the prospect of achieving the planned supply. PPG further explains that this is where delivery of housing taken as a whole over the previous 3 years, has fallen below 85% of the requirement, as set out in the last published housing delivery test results.

2.5 The 2023 housing delivery test results have not yet been made available. As a result, the 2022 housing delivery test results have been used in this paper to determine the buffer required when calculating the 5 year supply requirement.

2.6 The 2022 housing delivery test results indicate that Blackpool has significantly over-delivered against the number of homes required (see Table 1) so a 5% buffer is relevant.

Table 1: 2022 housing delivery test results

2.7 Therefore, for the purposes of the five year supply calculation for the period 2024 to 2029,the five year requirement incorporating a 5% buffer is calculated to be 772 dwellings, which is 154 dwellings per annum (Table 2).

Table2: Blackpool Five year supply housing requirement breakdown

3.0 The deliverable supply

3.1 The NPPF states that to be considered deliverable, sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years. 

3.2 The NPPF advises that sites which do not involve major development and have outline planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years. These deliverable sites are set out in table A of appendix 1.

3.3 Correspondence has been undertaken with developers on the largest sites with detailed planning permission in relation to build out rates and realistic delivery over the five year period.

3.4 In total, a deliverable supply of 659 new build dwellings on sites with detailed planning permission, or which do not involve major development and have outline planning permission, are identified in table A of appendix 1. For the purposes of this assessment, sites with reserved matters approval are considered to have detailed permission, because the permissions can now be implemented and in some cases the sites are under construction.

3.5 In addition there are 92 dwellings that have detailed planning permission in the form of conversions and changes of use as part of major schemes (10 dwellings or more), which are identified in table B of appendix 1. There are also 67 dwellings that have detailed planning permission in the form of conversions and changes of use as part of minor schemes (9 or fewer dwellings), which are identified in table C of appendix 1.

3.6 The NPPF advises that where a site has outline permission for major development, has been allocated in a development plan, has a grant of permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within five years. 

3.8T he housing site allocations in the Blackpool Local Plan Part 2: Site Allocations and Development Management Policies are considered to be deliverable over the five year period. These sites equate to 367 dwellings and are listed in table D of appendix 1.

3.9 The NPPF allows local planning authorities to make an allowance for windfall sites as part of their anticipated supply, if there is compelling evidence that they will provide a reliable source of supply. The issue of windfall housing provision was considered by the Blackpool core strategy inspector (paragraph 42 of the inspector’s report). He notes that the majority of windfall site developments in Blackpool are anticipated to be conversions (notably of hotels and guest houses) in the inner areas and that the council is encouraging such schemes in appropriate circumstances as part of its regeneration strategy. He considered that there was compelling evidence that windfalls will continue to provide a reliable source of housing land supply during the plan period. This is reflected in core strategy policy CS2, which identifies windfall housing as one of the three sources of housing provision in Blackpool.

3.10 Looking specifically at conversions, table 3 below provides up to date information about this type of windfall development. It shows that from 2012-2024, 1,427 dwellings were completed on windfall sites through conversions/changes of use 

Table 3: Windfall housing completions

Conversions/changes of use: Permitted and CLDE/CLUP/CPA

*It should be noted that these figures have been affected by the Covid-19 pandemic

3.11 Table 3 shows that the most consistent source of windfall completions has been conversions/changes of use on small sites (sites of 9 dwellings or less). This includes dwellings provided through permitted conversions, prior approvals for change of use and lawful development certificates. An average of 98 dwellings per year have been provided through these sources. 

3.12 This source of supply is expected to continue because core strategy policy CS23 allows more hotels and guest houses to change to residential uses than previous policy approaches. In addition, in 2015 the council established Blackpool Housing Company, which acquires poor quality existing homes and redundant buildings, such as former holiday accommodation and remodels them into quality affordable homes for rent. They have a development programme which aims to deliver between 80 and 100 quality homes per year. Although not all of these homes will be net additions to the stock, this work will further boost the supply of dwellings created through conversions and changes of use.

3.13 Conversions/changes of use on larger sites (sites of over 9 dwellings) also come forward (at an average of 21 per year since 2012), but the figures can be unduly influenced by larger schemes which come forward on an irregular basis (such as the scheme for 66 apartments that is currently under construction at 647-651 New South Promenade). New build windfall sites also tend to come forward, but not on a consistent basis.

3.14 Therefore, taking account of completion evidence it is considered appropriate to use a windfall allowance of 98 dwellings per year based upon conversions/changes of use on small sites of 9 units or less, which have consistently delivered housing over the plan period. Any new build windfall sites or major conversions/changes of use that come forward will be in addition to the windfall allowance.

3.15 At 31 March 2024 there were 67 dwellings permitted in conversions/change of use schemes on small sites. To avoid double counting, these permitted dwellings are incorporated into the windfall allowance. Table 4 sets out the deliverable housing supply.

Table 4: Deliverable housing supply

3.16 The five year target incorporating a 5% buffer is calculated to be 772 dwellings. A supply of 1608 dwellings has been identified. This equates to around a 10.44 year deliverable housing supply. Therefore, the council can currently demonstrate a five year deliverable housing supply, in accordance with the requirements of the NPPF. 

Appendix 1: Deliverable housing sites

Table A: New build sites with detailed permission at 1 April 2024