1.0 Introduction
1.1 The National Planning Policy Framework 2024 (NPPF), sets out the Government’s planning policies for delivering a sufficient supply of homes.
1.2 Paragraph 78 states that Local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirement set out in adopted strategic policies, or against their local housing need where the strategic policies are more than five years old.
1.3 The supply of specific deliverable sites should in addition include a buffer of: a) 5% to ensure choice and competition in the market for land; or b) 20% where there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned supply; or c) From 1 July 2026, for the purposes of decision-making only, 20% where a local planning authority has a housing requirement adopted in the last five years examined against a previous version of the Framework , and whose annual average housing requirement is 80% or less of the most up to date local housing need figure calculated using the standard method set out in national planning practice guidance.
1.4 In Blackpool’s case, this statement sets out Blackpool’s deliverable five year housing land supply for the period 1st April 2025 – 31st March 2030 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
2.1 The 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 - 2017
- 280 dwellings per annum between 2017 - 2022
- 310 dwellings per annum between 2022 - 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 (2025) with respect to the five year supply for the five year period 1st April 2025 to 31st March 2030 is 2935 dwellings (587 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 are the latest to be made available. Therefore, the 2023 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 2023 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: 2023 Housing delivery test results
.
No. of homes
required | Total no. of
homes required | No. of homes
delivered | Total number of
homes delivered | Housing Delivery Test:
2020 Measurement |
|---|
| 2020-21 | 2021-22 | 2022-23 | 2020-21 | 2021-22 | 2022-23 |
|---|
| 81 |
130 |
132 |
343 |
161 |
267 |
233 |
858 |
250% |
2.7 Therefore, for the purposes of the five year supply calculation for the period 2025- 2030, the five year requirement incorporating a 5% buffer is calculated to be 3082 dwellings, which is 616 dwellings per annum (Table 2).
Table 2: Blackpool five year supply housing requirement breakdown
.
| Ref | Description | Number |
|---|
| A |
Local housing need calculated using the standard method 2025 – 2030 |
2935 |
| B |
5% buffer (5% of 2935) |
147 |
| C |
Five year requirement incorporating buffer (A + B) |
3082 |
| D |
Annual requirement for next five years (C/5) |
616 |
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 473 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 48 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 55 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.
3.8 The 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 351 dwellings and are listed in Table D of Appendix 1.7
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 2012-2025, 1,500 dwellings were completed on windfall sites through conversions/changes of use
Table 3: Windfall housing completion
.
| Year | Conversions / Changes of Use:Permitted & CLDE/CLUP/CPA |
|---|
| Small sites | Major sites | Total |
|---|
| 2012/13 |
99 |
24 |
123 |
| 2013/14 |
129 |
22 |
151 |
| 2014/15 |
148 |
31 |
179 |
| 2015/16 |
149 |
12 |
161 |
| 2016/17 |
95 |
16 |
111 |
| 2017/18 |
117 |
10 |
127 |
| 2018/19 |
115 |
14 |
129 |
| 2019/20 |
153
|
31 |
184 |
| 2020/21* |
50 |
11 |
61 |
| 2021/22 |
39 |
40 |
79 |
| 2022/23 |
71 |
39 |
110 |
| 2023/24 |
12 |
0 |
12 |
| 2024/25 |
46 |
27 |
73 |
| Total |
1223 |
277 |
1500 |
* 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 94 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 has recently been completed 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 94 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 2025 there were 55 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
.
| Source of supply | Number of dwellings |
|---|
| New build sites that do not involve major development and have outline planning permission and sites with detailed planning permission |
473 |
| Major conversions and changes of use with detailed planning permission |
48 |
| Minor conversions and changes of use with detailed planning permission |
55 |
| Windfall allowance for minor conversions and changes of use (470 minus 55 dwellings with permission) |
145 |
| Other deliverable sites |
351 |
| Total |
1306 |
3.16 The five year target incorporating a 5% buffer is calculated to be 3082 dwellings. A supply of 1306 dwellings has been identified. This equates to around a 2.1 year deliverable housing supply. Therefore, the council is not able to 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 2025
.
| Application number | Address | Total capacity (net) | Dwellings left to be built (at 1 April 2025) | Deliverable dwellings over 5 year period | Comments |
|---|
| 17/0095 |
Land at Moss House Road |
422 |
280 |
36 |
Dwellings under construction |
| 21/1062 |
Land at 8 Norbreck Road, FY5 1RP |
35 |
35 |
35 |
Site with detailed permission |
| 21/0904 |
Land to the rear of former Hawes Side Library, Hawes Side Lane |
8 |
8 |
8 |
Site with detailed permission |
| 19/0679 |
Land to the rear of Ma Kelly’s. 44-46 Queen’s Promenade, FY2 9RW |
20 |
20 |
20 |
Site with detailed permission |
| 22/0422 |
45-47 Bond Street, FY4 1BW |
2 |
2 |
2 |
Site with detailed permission |
| 22/0440 |
Princess Street, Blundell Street, Rigby Road & Tyldesley Road |
88 |
48 |
48 |
Dwellings under construction |
| 22/0254 |
24 Low Moor Road, FY2 0PG |
5 |
5 |
5 |
Site with detailed permission |
| 22/0499 |
6 Whinney Heys Road, FY3 8NP |
1 |
1 |
1 |
Site with detailed permission |
| 20/0794 |
Land at Ryscar Way |
51 |
29 |
29 |
Site under construction |
| 23/0248 |
Land at 58 Common Edge Road, FY4 5AU |
4 |
4 |
4 |
Site with detailed permission |
| 21/1078 |
6-8 Carlin Gate, FY2 9QX |
3 |
3 |
3 |
Site with detailed permission |
| 23/0359 |
Land at Bridge House Road |
4 |
4 |
4 |
Site with detailed permission |
| 24/0004 |
67 Chepstow Road (Former GP Housing Office |
2 |
2 |
2 |
Site with detailed permission |
| 22/0670 |
Former Bispham High School, Bispham Road |
200 |
200 |
200 |
Site under construction |
| 22/0571 |
19 Mossom Lane |
1 |
1 |
1 |
Site with detailed permission |
| 24/0034 |
49 Moss House Road, FY4 5JF |
1 |
1 |
1 |
Site with detailed permission |
| 24/0180 |
Former Baguleys Centre, FY4 5HE |
1 |
1 |
1 |
Site with detailed permission |
| 22/0168 |
611-613 New South Promenade, FY4 1NJ |
40 |
40 |
40 |
Site with detailed permission |
| 24/0379 |
Whitegate Manor, Whitegate Drive, FY3 9JL |
25 |
25 |
25 |
Site with detailed permission |
| 25/0003 |
338 Central Drive, FY1 6LF |
1 |
1 |
1 |
Site with detailed permission |
| 22/0713 |
Land at Lytham Road and Moon Avenue, FY1 6DZ |
7 |
7 |
7 |
Site with detailed permission |
| N/A |
Total |
N/A |
N/A |
473 |
N/A |
Table B: Major conversion/change of use schemes with detailed permission at 1 April 2025
.
| Application number | Address | Total capacity (net) | Dwellings left to be built (at 1 April 2025) | Deliverable dwellings over 5 year period | Comments |
|---|
| 17/0859 |
98A Park Road |
10 |
10 |
10 |
Under construction |
| 18/0856 |
396-402 Promenade |
13 |
13 |
13 |
Under construction |
| 21/0974 |
580-582 Lytham Road |
10 |
10 |
10 |
Detailed Permission |
| 21/0386 |
6-8 Harrow Place |
15 |
15 |
15 |
Detailed Permission |
| N/A |
Major conversions total |
48 |
48 |
48 |
|
Table C: Minor conversion/change of use schemes with detailed permission at 1 April 2025
.
| Application number | Address | Dwellings left to be completed (at 1 April 2025) | Deliverable dwellings over 5 year period |
|---|
| 21/0372 |
14 Shaftesbury Avenue |
1 |
1 |
| 21/0643 or 22/0001 |
174 Queens Promenade |
1 |
1 |
| 22/0194 |
20 Charles Street |
1 |
1 |
| 21/0369 |
1 Chapel Street |
6 |
6 |
| 21/0955 |
97 Lytham Road |
1 |
1 |
| 21/0388 |
22 Whitegate Drive |
3 |
3 |
| 22/0629 |
156 Lytham Road |
2 |
2 |
| 22/0703 |
29-31 Cookson Street |
1 |
1 |
| 22/0673 |
14 Coop Street |
3 |
3 |
| 23/0080 |
68 Church Street |
1 |
1 |
| 23/0222 |
9 Reads Avenue |
1 |
1 |
| 23/0100 |
156 Lytham Road |
1 |
1 |
| 22/0763 |
12 Holmfield Road |
3 |
3 |
| 21/0636 |
4-8 Edward Street |
3 |
3 |
| 22/0358 |
128 Palatine Road |
1 |
1 |
| 23/0615 |
61 Bond Street |
1 |
1 |
| 23/0531 |
61 Bolton Street |
1 |
1 |
| 23/0416 |
2-3 Lansdowne Place |
6 |
6 |
| 23/0867 |
299 Church Street |
1 |
1 |
| 23/0819 |
1 Cliff Place |
1 |
1 |
| 22/0283 |
27-29 Yorkshire Street |
2 |
2 |
| 24/0087 |
10 Warley Road |
1 |
1 |
| 24/0058 |
99 Reads Avenue |
1 |
1 |
| 24/0168 |
187 Lytham Road |
1 |
1 |
| 24/0124 |
4B crummock Place |
1 |
1 |
| 24/0239 |
97 Bispham Road |
1 |
1 |
| 24/0217 |
28 Northfield Avenue |
1 |
1 |
| 22/0467 |
12 Holmfield Road |
1 |
1 |
| 24/0302 |
16-18 Talbot Road |
2 |
2 |
| 24/0483 |
57 Aintree Road |
1 |
1 |
| 24/0411 |
22 Dean Street |
1 |
1 |
| 23/0228 |
106-108 Lytham Road |
1 |
1 |
| 24/0611 |
195 Dickson Road |
1 |
1 |
| 23/0890 |
78 Holmfield Road |
1 |
1 |
| 24/0594 |
53 Whitegate Drive |
1 |
1 |
| N/A |
Total |
55 |
55 |
Table D: Other deliverable sites
.
| Address | Application number | Deliverable dwellings over 5 year period | Comments |
|---|
| Land at the Enterprise Zone (Jepson Way) |
- |
57 |
Housing allocation in the Blackpool Local Plan Part 2. |
| Land at the end of Bromley Close |
- |
12 |
Housing allocation in the Blackpool Local Plan Part 2. |
| Land rear of 307-339 Warley Road |
- |
14 |
Housing allocation in the Blackpool Local Plan Part 2. |
| 190-194 Promenade, Blackpool |
- |
15 |
Housing allocation in the Blackpool Local Plan Part 2. |
| Blackpool Council Offices, South King Street |
- |
47 |
Housing allocation in the Blackpool Local Plan Part 2. |
| Car Park, Bethesda Road |
- |
13 |
Housing allocation in the Blackpool Local Plan Part 2. |
| Land to the rear of 69-85 Kipling Drive |
- |
14 |
Housing allocation in the Blackpool Local Plan Part 2. |
| Land at Rough Heys Lane |
- |
27 |
Housing allocation in the Blackpool Local Plan Part 2. |
| Land at 50 Bispham Road |
- |
12 |
Housing allocation in the Blackpool Local Plan Part 2. |
| 41 Bispham Road and land to the rear of 39-41 Bispham Road |
- |
16 |
Housing allocation in the Blackpool Local Plan Part 2. |
| 7-11 Alfred Street |
- |
14 |
Housing allocation in the Blackpool Local Plan Part 2. |
| 9-15 Brun Grove (Blackpool Trim Shops) |
- |
10 |
Housing allocation in the Blackpool Local Plan Part 2. |
| Waterloo Road Methodist Church, Waterloo Road |
- |
12 |
Housing allocation in the Blackpool Local Plan Part 2. |
| 585-593 New South Promenade and 1 Wimbourne Place |
- |
88 |
Housing allocation in the Blackpool Local Plan Part 2. |
| Total |
|
351 |
|