1. home and garden

Technical Paper No.5
Calculating a Windfall Allowance
April 2015
Technical Paper 5: Calculating a windfall allowance April 2015
Introduction
This technical paper is one of a series, prepared by the Council, to support preparation of its Local
Development Framework (LDF). The technical papers in the series currently comprise:
1. Defining the Coastal Change Management Area
2. Local Green Spaces
3. A Review of Built Up Area Boundaries
4. Influences on the Settlement Strategy
5. Calculating a Windfall Allowance
6. Interim Review of Local Landscape Designations and Important Local Countryside Gaps
This document supports the definition of an unidentified (windfall) allowance for residential sites for
use in meeting the Council’s agreed Local Plan housing target and its Strategic Housing Land
Availability Assessment. The paper draws upon the work of Shepway Borough Council whose
evidence for a windfall allowance was found robust for its adopted Core Strategy.
It was originally prepared to support the Council’s 2012/13 Strategic Housing Land Availability
Assessment (SHLAA), however the preparation of a revised SHLAA for 2013/14 presented the
opportunity to review the allowance reached in the first technical paper dated December 2012. In
particular, this technical paper update reviews the approach taken to the potential double counting
with SHLAA sites and the non-application of the windfall allowance in the five year supply. This is
in response to the generally conservative approach taken by the first paper.
The National Planning Policy Framework, March 2012
1. Paragraph 48 of the Framework states that:
‘Local planning authorities may make an allowance for windfall sites in the five-year supply if
they have compelling evidence that such sites have consistently become available in the local
area and will continue to provide a reliable source of supply. Any allowance should be realistic
having regard to the Strategic Housing Land Availability Assessment, historic windfall delivery
rates and expected future trends, and should not include residential gardens.’
2. ‘Windfalls’ are defined in the glossary to the Framework as:
‘Sites which have not been specifically identified as available in the Local Plan process. They
normally comprise previously-developed sites that have unexpectedly become available.’
3. This definition is largely a consistent one which has been well recognised over previous
Government guidance 1.
4. National guidance (NPPG) indicates that:
‘A windfall allowance may be justified in the five-year supply if a local planning authority has
compelling evidence as set out in paragraph 48 of the National Planning Policy Framework.
Local planning authorities have the ability to identify broad locations in years 6-15, which could
include a windfall allowance based on a geographical area (using the same criteria as set out
in paragraph 48 of the National Planning Policy Framework).’
5. The introduction in 2006 of Strategic Housing Land Availability Assessments (SHLAA) altered
the process for identifying housing sites and their availability, including the use of allowances
for windfall development. It is now necessary to assess the sites identified by the SHLAA to
1
The reference to ‘normally’ in respect of previously developed land is however new.
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Technical Paper 5: Calculating a windfall allowance April 2015
determine the contribution made by windfall sites, having regard to how suitable, available and
achievable past trends may be in terms of projecting into the future.
Quantifying windfalls – the past trends
6. Estimates traditionally examine past performance to justify their likely future contribution. The
NPPF supports this approach, but as a starting point. For example, past monitoring
information may not always be directly comparable and needs to be placed in context and its
future applicability reviewed.
Historic Context
7. A windfall allowance of 91 dwellings per year is included in the adopted Swale Borough Local
Plan 2008. Of this, 72 per year were expected from the Thames Gateway Planning Area
(Sittingbourne and the Isle of Sheppey), and 19 from the Faversham and the Rest of Swale
Planning Area.
Overview of delivery
8. Until 2010/11 Kent County Council monitored the level of windfall completions for all Kent
Districts. Table 10 (Appendix 1) shows the timespan for Swale between 1991 and 2013. A
‘mean’ average indicates that 143 dwellings per annum (dpa) have consistently come forward
over a long period of time, notwithstanding the effects of economic cycles 2.
9. In all but 3 years, windfall completions were at greater levels than the adopted Local Plan
windfall allowance; indicating (as was acknowledged by the Council at the time) that the
allowance had been a cautious one. There had been criticism by developers that the Council
had double counted the allowance with its Local Plan allocations because many had been
identified by an urban capacity study (UCS). That appears not to have been borne out by
table 10. This perhaps tells us two things: 1) levels of windfalls are difficult to predict; and 2)
despite efforts to identify and allocate sites, windfall sites still come forward.
10. For the most part, delivery of windfall completions has for 22 years been at levels in excess of
100 dpa and, for 14 of these, in excess of 130. There are some fluctuations, normally
explained by the corresponding number of overall completions. However, even for years,
such as 1995/96 and 2003/04, where there is not an obvious reason for the figures, an
identical mean average of 143 dpa remains.
11. Since 2007/08 (the commencement of the recession), windfall completions have reduced to a
mean average of 131 dpa, although since 2010/11, development on garden land has been
excluded from the completions. If this three-year period is considered, the mean average is
135 dpa, indicating that completions from ‘garden land’ were not especially significant.
Although the average overall levels of windfall completions have reduced, three of these years
have been in recession.
12. By dividing the KCC timespan in table 10 into two ten-year bands, the greatest frequency of
values (mode average) fall between the 110-149 dpa bands, with 137 dpa being the mean
average of the frequencies across these ranges.
13. It is necessary to arrive at a judgement as to the nature of past trends to make judgements
about their role into the future. From the above analysis, we see a range of values between
110 and 143 dpa. The majority of table 10 reflects the inclusion of garden land, however,
deriving past trends based upon the last three recession years of monitoring windfalls that do
2
Post completing this technical paper, data for the monitoring year 2013/14 became available. This showed 336 completions on
windfall sites, forming 60.7% of total completions – the highest since at least 1991. Large sites formed 137 of these and 67 were
small sites. None comprised sites identified by the SHLAA.
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Technical Paper 5: Calculating a windfall allowance April 2015
not include garden land is not considered sufficiently robust and the short term effects of
excluding them does not appear marked in any event.
14. To use an average based around the frequency of values (the mode) flattens out the natural
fluctuations that would otherwise occur through economic cycles and it is judged appropriate
to allow for such fluctuations.
15. In conclusion, the mean average across the 22-year period provides the best starting point for
a Swale windfall allowance - 143 dpa.
Garden land
16. With the NPPF now requiring the removal of garden land from any windfall allowance, table 1
shows the proportion of windfall completions comprising garden land between 2002/03 and
2012/13.
03/04
04/05
05/06
06/07
07/08
08/09
09/10
10/11
11/12
12/13
AVERAGE
/TOTAL
On
garden
land
Not on
garden
land
02/03
Table 1 KCC/SBC Time series of proportion of windfall completions on garden land 2002/3-2013
22
43
43
52
37
40
18
15
39
40
10
33
95
185
94
244
108
107
106
96
102
109
106
123
17. Table 1 indicates a mean average of 33 garden land completions per annum. There are two
alternative approaches to deducting garden land from the total windfall average:
a. Take 33 dwellings from the 143 dpa mean average to equal 110 dpa; or
b. Take actual completions from each year, re-calculating the mean average to 123 dpa.
18. If the frequency of the annual number of dwellings not on garden land is examined, of the 11
years, six are +/- 10 of 110, whilst none are +/- 10 of 123. Only 3 years are +/- 10 of 95 and
zero years are within +/- 10 of 244 (the lowest and highest figures in Table 2). It is concluded
that approach a. is the most appropriate i.e. a deduction of 33 dpa.
Conclusions on past trends
19. The levels of windfalls in Swale have stood up remarkably well through the 1990s and into the
21st Century. They have reflected the economic lows of the mid to late 1990s and the highs of
the early years of the 21st Century through to the current recession where they have stood up
very strongly. Levels will also have been influenced by previous Government efforts to boost
use of previously developed land and the developers and the planning system that have been
creative and flexible as a result. In recent years, windfall levels have remained robust in the
face of the post 2008 economic downturn and the ‘removal’ of the garden land element.
20. Despite no short-term impact of the loss of garden land from the windfall allowance, this cannot
be relied upon and it is appropriate to adopt a cautious approach with the starting point for
examining future trends being 110 dpa (i.e. the 22 year mean average windfall completions of
143 dpa less the 11 year mean average for completions on garden land at 33 dpa).
Quantifying windfalls – prospects for the future
21. This section considers whether the annual windfall average of 110 dwellings should be further
adjusted. There are three reasons why this might be needed, namely the:
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Technical Paper 5: Calculating a windfall allowance April 2015
a. continued availability, suitability and achievability of the supply (inc. changes in national
policy);
b. influence of the extant planning permissions; and
c. influence of sites identified by the Strategic Housing Land Availability Assessment.
A. The continued availability suitability and achievability of the supply
Small sites
22. One significant source of housing in Swale is its supply of small sites. It is a long-standing
practice within all Kent Districts and the County for a site capable of delivering up to 4
dwellings to comprise a small site. These sites are not identified in local plan calculations or
allocations. Table 2 shows the 11 year past trend of delivery in Swale on small relative to large
site windfalls.
Table 2 Proportion of windfall completions in Swale by size 2002/03 - 2012/13
Year
Small windfall
site completions
As % of all
windfalls
As % of all
completions
Large windfall
site completions
As % of all
windfalls
As % of all
completions
2012/13
69
59.5
23.7
47
40.5
16.2
2011/12
51
34.2
12.8
98
65.8
24.7
2010/11
58
41.1
13.4
83
58.9
19.2
2009/10
80
72.1
11.3
31
27.9
4.4
2008/09
65
52.5
13.2
59
47.5
11.9
2007/08
92
62.6
12.0
55
37.4
7.2
2006/07
85
58.5
10.2
60
41.5
7.2
2005/06
63
21.3
7.4
233
78.7
27.3
2004/05
73
53.3
19.5
64
46.7
17.1
2003/04
78
34.2
13.7
150
65.8
17.2
2002/03
86
73.5
15.1
31
26.5
8.3
Mean
average
66.7
44.6%
13.9%
82.8
48.8%
14.6%
23. In terms of total numbers of completions, large windfall site completions comprise a slightly
bigger part of both the total number of windfall completions and the total number of
completions overall. However, for seven of the 11 years small sites formed the greater
element of both overall windfall numbers and total completions. The contribution of large site
windfalls is swelled by occasional very large level of large windfall site completions (i.e.
2003/04 and 2005/06).
24. Levels of small site completions are generally consistent year on year and the supply over the
period appears robust with little to suggest any long term decline in their supply. Whilst
numbers have been lower in the last three years, these have been during a period of
recession. Although the loss of garden land appears to have been most keenly felt on small
sites, table 2 shows that small site completions have never dropped below 50, with the
greatest frequency of completions falling within the 60-89 dpa range. Taking the final three
years that consider the exclusion of garden land, provides a mean average of 59 dpa. Whilst
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Technical Paper 5: Calculating a windfall allowance April 2015
this is a relatively short period to consider, it would not be considered safe to rely on the longer
term mean average as it is this source of windfall where the exclusion of garden is likely to be
most keenly felt.
25. Whilst any source of windfall site cannot be extrapolated indefinitely, small sites are significant
in terms of their consistency, despite the Borough being arguably more dependent upon
national house-builders. This consistency suggests that smaller sites are likely to have less
exposure to nation-wide fluctuations in demand. For example, with viability an issue with
national house builders since 2007/08, small site completions have only been marginally
affected, with completions even taking place within neighbourhoods in Swale forming part of
the 20% most deprived in England 3 wards. Even in the low point year of 2012/13 44
completions were recorded in nearly all these wards 4.
Large windfall sites
26. Whilst table 2 examined the levels of completions from large sites, table 3 indicates the
frequency that they occurred since 2007/08 within size bands represented by the number of
dwelling proposed. Table 3 shows the focus of this activity on sites below 15 units with the
majority below 10 units.
Table 3 Number of windfall sites in Swale 2007/08-2012/13 by dwelling number proposed
Unit range
5
6-10
11-15
16-20
21-25
26-30
31-35
36-40
41-45
46-50
51-55
56-60
61-65
2007/082012/13
14
27
14
0
2
1
1
0
0
1
1
0
1
27. As a comparison, table 4 shows the frequency of identified SHLAA sites, focusing on
previously developed sites. This is because some parties argue that such sites may have
previously been regarded as windfalls (see table 12 in Appendix 1). This indicates the
greatest frequency of sites falling below 20 units with the majority of these below 15 units.
Table 4 Number of SHLAA possible windfall sites in Swale 2007/08-2012/13 by dwelling number proposed
Unit range
2007/082012/13
5-10
11-15
16-20
21-25
26-30
31-35
36-40
41-45
46-50
51-60
61-70
71-80
81+
3
8
2
2
2
0
2
0
0
3
0
1
2
Type of windfalls
28. Table 5 shows the previous use of land that delivered windfall sites in Swale since 2007/08. It
shows a strong delivery across a range of use types with conversions and the redevelopment
of business sites as the two key sources, followed by those from residential buildings. The
relatively high contribution from green field sites refers mostly to infill plots not within
residential curtilages.
Table 5 Source of windfall completions 2007/08-2012/13 by previous use of land
Year
Change of
use,
5
conversion
Greenfield
6
land
Business,
industrial
or other
Car
parking
3
Residential
buildings
Institutional
land
Other
8
Index of Multiple Deprivation 2010, CLG.
After finalising this report, windfall completions for 2013/14 became available which showed windfall completions outperforming those for allocated large sites where building by national house builders remains sluggish or stalled.
5
Includes the conversion of existing non-residential buildings, intensification of residential units in existing buildings.
6
Comprises land of rural and urban character, agricultural buildings, restored minerals/waste and ‘other’ – does not include
garden land.
4
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Technical Paper 5: Calculating a windfall allowance April 2015
commercial
7
use
2007/082012/13
243
264
180
22
156
1
25
29. In terms of applicability in the future, these results are positive. Firstly, the supply of windfalls
since 2007/08 has drawn from a wide range of sources and is not dependent on a narrow form
of development. Secondly, the supply draws largely upon sources that are unlikely to cease in
their suitability, availability and achievability into the foreseeable future given economic and
demographic shifts. A possible exception might have been the green field land category
where the supply might be regarded as finite. However, further analysis of the category
suggests a wide range of sources. Whilst infill plots might conceivably be finite, they make up
a relatively small (6%) proportion of the category.
Location of windfalls
30. It is appropriate to consider the distribution of housing sites in the Borough in order to consider
whether changes in settlement strategy policy could lead to changes in the supply 9. By
combining individual wards to make up the areas in Table 7, the distribution of windfall
completions and all SHLAA sites can be compared. Urban locations provide some 67% of
total windfall completions 2007/08–2011/12, with SHLAA sites 81%. The settlement strategy
of the existing and emerging Local Plans is relatively unchanged and suggests a likely
continuing positive response to future applications for windfall sites.
Table 6 General locations of windfalls and SHLAA sites across Swale 2007/08 - 2011/12
Broad Area
Windfall total (%
share) 10
SHLAA
identified sites
(% share) 11
Faversham urban
10.9
19.0
Sittingbourne urban
31.5
39.7
Sheppey urban
25.0
22.4
Sheppey rural
2.2
3.5
Swale rural
30.4
15.5
Conclusions
31. The analysis in this section serves to underpin small sites as a very robust source of
development where previous data can be considered to be still fully relevant going forward.
From the traditional sources of windfall supply, there is no evidence that points to a reduction
in the supply of small or large sites and none to suggest this will not continue. Small sites are
especially robust and can be expected to be at least at 59 dpa (see para. 24). Although less
static in their supply, the number of large sites is not diminishing and their sources appear
8
Includes new build/conversion for other uses and ‘other’ category e.g. new build plus conversion.
Includes redevelopment of existing commercial premises.
9
SBC data has been used as KCC data cannot give ward breakdown. This means that there are variances between the data
presented in Table 1 and that used to compile Table 7. There is confidence in this data as it is able to demonstrate the relative
differences between the areas.
10
May not add to 100% due to rounding.
11
Not including extant planning permissions.
7
6
Technical Paper 5: Calculating a windfall allowance April 2015
likely to continue. Both sources will be aided by expectations that national initiatives to
increase housing will result in increased sources. Structural economic changes, notably a
decline in traditional manufacturing, are likely to ensure that the supply of sites on former
industrial land will continue, at least for the time being. Just one source that could have been
expected to be finite – garden land – has been removed from the definition of windfall land.
32. These matters strongly indicate the continuing suitability and availability of sites. Whilst
viability issues may affect achievability in the short term, there is no counter evidence to
suggest that they will not continue to be achieved in the medium to long terms; indeed there is
strong evidence that developers of smaller sites are less affected by viability issues.
33. In conclusion, there seems every reason to assume that with the in-built discount for garden
land small sites will continue to be available, suitable and achievable against the NPPF.
B. The influence of extant planning permissions
34. Extant planning permissions are those yet to be counted as complete. Not all future
completions from this source are from windfall sources. By examining extant planning
permissions from windfall sources from 2012/13 (table 11 Appendix 1), the number exceeds
those expected from the estimated 110 dpa figure derived in para. 20. Given this, there is a
strong case for not including any windfall allowance within years 1-5.
35. This technical paper update has considered whether there should be any change to this
position. The expected number of completions from extant planning permissions was
examined for the immediate 5 year period (as of 2012/13), as with past provision, this data too
found expected levels of completions well above the 110 dpa figure from para. 20. This
further supports conclusion that it would not be appropriate to apply a windfall allowance to the
first 5 years. However, the same data is another indicator of the overall conservative nature of
the allowance in total.
C. The influence of identified SHLAA sites
36. The starting point is the definition of a windfall site provided by the NPPF: - ‘Sites which have
not been specifically identified as available in the Local Plan process. They normally comprise
previously-developed sites that have unexpectedly become available.’
37. SHLAA sites are identified for potential inclusion as allocations within the Local Plan. They
are put forward by landowners and/or developers and judged as suitable, available and
achievable. They are known sites, whereas windfalls, by contrast, are unknown and
unexpected up to the point of permission being granted. There is therefore a persuasive
argument that there is no double counting between windfall sites and SHLAA previously
developed sites. The December 2014 technical paper nevertheless considered that as some
SHLAA sites would have similar characteristics to those traditionally described as windfall;
there was a theoretical risk of double counting, especially within urban areas. As a result, it
concluded that a cautious approach to minimise at least the theoretical risk of double counting
should be deployed.
38. This matter has been reconsidered. The fact that all the SHLAA sites have been submitted by
willing landowners, there is strength in the argument that they cannot be a windfall. Given the
evidence of cautiousness already present within the 110 dpa allowance figure, a further
discount is considered to be unnecessarily over-cautious.
Discounting to form the windfall allowance
39. Combining the influences of garden land and extant planning permissions, table 8 summarises
the deductions necessary from the original mean annual average windfall allowance of 143
dwellings. Where deductions lead to a minus figure, the total for the year is recorded as zero.
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Technical Paper 5: Calculating a windfall allowance April 2015
Table 7 Total discounting of windfall sites to form allowance.
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
ALL
Period
13/14
14/15
15/16
16/17
17/18
18/19
19/20
20/21
21/22
22/23
23/24
24/25
25/26
26/27
27/28
28/29
29/30
30/31
Total
143
143
143
143
143
143
143
143
143
143
143
143
143
143
143
143
143
143
2574
33
33
33
33
33
33
33
33
33
33
33
33
33
33
33
33
33
33
594
Past trend
mean
(Table 1)
Garden
land
PPs
105
149
135
158
158
0
0
0
0
0
0
0
0
0
0
0
0
0
746
Year 1-5
discount
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Total
0
0
0
0
0
110
110
110
110
110
110
110
110
110
110
110
110
110
1,320
‘Converting’ the windfall allowance to the identification of broad locations
40. Expressing the windfall contribution from a series of broad locations is considered to be in
accordance with the National Planning Policy Guidance (para.24). It can be justified because
there is to be no change to the overall spatial strategy of development that is likely to lead to a
change in policy toward windfall applications. Given the certainty of the future supply from the
same areas, the overall provision of 1,320 dwellings 2013/14-2030/31 (table 7) can be
apportioned and split across the areas identified in table 6. These areas can be combined to
create two broad locations comprising the urban and rural areas in table 8.
Table 8 Broad locations for windfall sites
Broad Area
Source
Windfall total
The urban areas of Sittingbourne,
Faversham, Sheerness,
Queenborough, Halfway and Minster.
From within defined built up area boundaries
and in locations otherwise permitted by the
National Planning Policy Framework.
884
Within the villages and the wider rural
area.
From within defined built up area boundaries
and in locations otherwise permitted by the
National Planning Policy Framework.
436
TOTAL
1,320
Overall Conclusions: Compliance with National Planning Policy Framework and Guidance
41. This section considers whether the approach taken is compliant with current national policy
and guidance.
42. There is strong evidence that windfall sites have consistently come forward in Swale across a
variety of economic and planning environments. This is demonstrated by the evidence of past
trends. Even after garden land is deducted, this paper has demonstrated that average annual
windfall completions should be something in the order of 110 dpa.
43. Data is extremely robust in respect of small sites, which has shown them consistently
delivering over 60 dpa. This data is relevant to future proposals as SHLAA identified sites
feature no sites under five units. Additionally and looking forward, evidence from the source of
windfall completions suggests every reason to assume a continuing supply from small sites.
44. It is also relevant to consider larger sites. Windfall sites larger than 5 units have featured in
every year since 2002/03 (and earlier), providing an absolute minimum of 31 units per annum,
although their contribution has varied considerably year on year. This supply has not
diminished (proportionately or aggregately) and, unlike extant planning permissions, the risk of
double counting from identified SHLAA sites is small. Larger sites can and will continue to
come forward from nearly all the traditional sources, whilst Government initiatives will continue
to provide for new sources.
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Technical Paper 5: Calculating a windfall allowance April 2015
45. The analysis of housing land sources suggests that certain elements of the supply should be
discounted. Firstly, excluding any allowance from garden land reduces the supply, whilst
extant permissions remove the allowance in years 1-5.
46. After the discounts highlighted, the average past trend windfall allowance of 143 dpa
produces an plan period windfall allowance of 1,320 units - an average of 110 dpa.
Against a draft Local Plan target of 10,800, this represents just 12.2% of the total, less than
the long term past trend average contribution that has only twice in 22 years been less than
15% of the total of annual completions. It is acknowledged that this might be regarded by
some as too cautious an approach, however, such caution is advisable until the effects of
changes in national policy and the local economy can be monitored.
47. With no overall change in the spatial strategy from past trends, it is reasonable to split any
final allowance across broad locations and using the proportions of past trends is an
appropriate way to achieve this. It confirms the likely continued dominance of the urban
areas, although the contribution of rural areas of nearly a third is significant.
48. It can be concluded that there is strong evidence to suggest that windfall completions will
continue to be suitable, available and achievable in terms of the NPPF/G. Table 9 shows how
the requirements of NPPF paragraph 48 have been met.
Table 9 Meeting the requirements of NPPF para. 48
National criterion
Comment
Sites have consistently become available in the local See table 10 setting out windfall delivery since 1991
area and will continue to provide a reliable source of and table 7 justifying the amount of windfall
allowance.
supply having regard to…
… the Strategic Housing Land Availability
Assessment…
See table 6 and paras. 35-36 highlighting the
SHLAA as a key evidence base document in
identifying non-windfall sites.
… historic windfall delivery rates…
See table 10 setting out windfall delivery since 1991
with reference to the windfall allowance set for the
adopted Swale Borough Local Plan 2008 in paras.
7-9.
… and expected future trends,
See tables 2 & 5. No evidence of a decline in
sources of supply, whilst the proposed development
strategy and national initiatives are likely to ensure
that windfalls will continue to comprise a significant
part of delivery.
SHLAA guidance suggests to include:
•
•
pattern of development
market conditions
… and should not include residential gardens.
Gardens are not included in the allowance. This
paper has isolated this contribution from the
allowance (see table 7).
‘A windfall allowance may be justified in the five-year
supply if a local planning authority has compelling
evidence as set out in paragraph 48 of the National
Planning Policy Framework. Local planning
authorities have the ability to identify broad locations
in years 6-15, which could include a windfall
allowance based on a geographical area (using the
same criteria as set out in paragraph 48 of the
National Planning Policy Framework).’
The guidance overlooks the potential for double
counting in the first 5 years. Table 7 excludes this
possibility as a cautious approach.
There is evidence to enable the windfall allowance
to be isolated to broad geographical locations as set
out in tables 6 & 8.
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Technical Paper 5: Calculating a windfall allowance April 2015
49. It can be noted that any windfall estimate is a judgement on the weight to be attached to
different sources of land or information and entails consideration of future uncertainties that
may ultimately be subjective. This research has considered a wide range of past, present and
future factors and examined the size, source and location of windfall sites. It has highlighted
the consistency and relevance of the volume of housing supply from windfall sites given the
scope of windfalls set out in the NPPF. Under these circumstances, it is judged that the final
windfall allowance is, at the present time, as robust as the evidence allows it to be.
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Technical Paper 5: Calculating a windfall allowance April 2015
Appendix 1
AVERAGE /
TOTAL
12/13
11/12
10/11
09/10
08/09
07/08
06/07
05/06
04/05
03/04
02/03
01/02
00/01
99/00
98/99
97/98
96/97
95/96
94/95
93/94
92/93
91/92
Table 10 KCC/SBC Time series of windfall completions 1991-2013
Windfall
comps
136
199
176
125
58
64
89
137
119
154
182
117
228
137
296
145
147
124
111
141
149
116
143
All
comps
439
407
432
308
511
293
321
705
576
654
659
568
570
375
854
835
767
494
709
433
397
291
527.2
Windfall
as % of
All
31.0
48.9
40.7
40.6
11.4
21.8
27.7
19.4
20.7
23.5
27.6
20.6
40.0
36.5
34.7
17.4
19.2
25.1
15.7
32.6
37.5
39.9
28.8
st
Table 11 Extant planning permission on windfall sites as of 1 April 2013.
Ref
06/0231
06/1448
07/1248
08/1124
09/0733
09/0911
09/1032
09/1201
10/0050
10/0104
10/0157
10/0367
10/0420
10/0487
Address
Seaview, Land adj The Retreat, Bell Farm Lane
Conyer Brickworks, Conyer
36-37 St Johns Road
153 London Road
Ewell Farmhouse, Graveney Road
Duke of Clarence Trading Estate, Blue Town
Land adj 78 Charlotte Street
Land between 32/37 High Street
Land r/o Seager Road
Land R/O 26 London Road
Capri, corner of Cliff Drive and Sea Approach
Land adj Rookery Nook
Woody's, Wood Street
2 Park Road
Settlement
Minster
Teynham
Faversham
Sittingbourne
Graveney & Goodnestone
Sheerness
Sittingbourne
Sheerness
Sheerness
Newington
Warden
Minster
Sheerness
Sittingbourne
11
Yield
1
24
1
26
1
11
1
13
35
2
2
2
7
4
Technical Paper 5: Calculating a windfall allowance April 2015
Ref
10/0517
10/0653
10/0732
10/0777
10/0840
10/0948
10/0977
10/0980
10/0996
10/1022
10/1032
10/1067
10/1071
10/1288
10/1302
10/1354
10/1367
10/1369
10/1379
10/1388
10/1505
10/1553
10/1598
11/0225
11/0262
11/0293
11/0328
11/0429
11/0516
Address
Plot adj 120 Scarborough Drive
1-3 High Street
46 High Street
Co Op Store, Forbes Road
Former A2 Tyres Depot, Cowper Road
Wilmar, Warden Road
Land at Kings Road
138 The Street
39 Stone Street
Land at 140 Park Road
The Old Dairy, Halfway Road
13 Neptune Terrace
Pett Dane Cottage, Stalisfield Road
68/70 Ospringe Street
Land adj 5 Harold Road
76 East Street
Swale Martial Arts Club, Sports Centre, East Street
83 Drake Avenue
Land behind Dai-Mon, Princes Avenue
142-144 London Road
126 London Road
Land adj 20 Adelaide Gardens
Copton Manor Barns, Salters Lane
Land at Rear of 244 London Road
Land r/o 35 the Broadway
55 William Street
7/7A Market Street / 1/1a Court Street
The Cabin, Almshouse Road
Village Hall, Ferry Rd
Settlement
Minster
Sittingbourne
Eastchurch
Faversham
Sittingbourne
Eastchurch
Minster
Boughton
Faversham
Sittingbourne
Sheerness
Sheerness
Eastling
Faversham
Sittingbourne
Sittingbourne
Sittingbourne
Minster
Minster
Sittingbourne
Sittingbourne
Sheerness
Sheldwich
Sittingbourne
Sheerness
Sittingbourne
Faversham
Throwley
Iwade
12
Yield
1
4
2
6
5
1
2
2
4
3
14
3
1
5
1
4
3
1
1
7
6
1
1
1
4
4
3
1
10
Technical Paper 5: Calculating a windfall allowance April 2015
Ref
11/0606
11/0617
11/0635
11/0652
11/0676
11/0689
11/0809
11/0821
11/0827
11/0906
11/0970
11/1017
11/1026
11/1071
11/1086
11/1087
11/1100
11/1167
11/1234
11/1249
11/1373
11/1418
11/1493
11/1581
11/1609
11/1616
11/1624
12/0023
12/0090
Address
13 Market Place
67 West Street
175 Wards Hill Road
Land adj Longview
Toachim House, South Rd
1 High Street
Jetty Cott, Jetty Road
39 Abbeyfields
89 The Broadway
Ex. Working Men’s Club, High Street
Latchmere, Park Avenue
9 Drake Avenue
183 Ufton Lane
Harps Farm, Thistle Hill way
8 Hawthorn Avenue
Land adj 32 Ferry View
Thistle Hill Way
115 West Street
Blocks 1b & 2a, Eurocentre, Whitstable Rd
Land off Lower Rd, Teynham
65 West Street
1 Shurland Avenue
Cookham-Shaw, Maidstone Rd, Danaway
Former Windmill PH, Canterbury Rd
35 The Street
Land adj 27 Waverley Ave
Transit Works, Power Station Rd
76 Bradfield Avenue
Adj Queenborough Society Club, North Rd
Settlement
Faversham
Sittingbourne
Minster
Boughton
Faversham
Sheerness
Warden
Faversham
Minster
Newington
Leysdown
Minster
Sittingbourne
Minster
Sheerness
Queenborough
Minster
Faversham
Faversham
Teynham
Sittingbourne
Leysdown
Borden
Faversham
Boughton
Minster
Minster
Teynham
Queenborough
13
Yield
2
2
2
1
2
7
2
1
1
12
4
2
1
3
1
3
3
2
8
12
2
1
1
2
1
1
46
9
4
Technical Paper 5: Calculating a windfall allowance April 2015
Ref
12/0117
12/0164
12/0172
12/0181
12/0199
12/0240
12/0272
12/0288
12/0299
12/0312
12/0385
12/0386
12/0439
12/0514
12/0526
12/0558
12/0637
12/0657
12/0668
12/0690
12/0758
12/0760
12/0787
12/0833
12/0867
12/0902
12/0935
12/0936
12/1017
Address
Former Garden Hotel, 169 The Street
Adjacent to 95 The Broadway
Sunfield, Lower Rd
Land adj Lower Champion Court, Newnham Valley, Newnham
r/o Mill House, Throwley Forstall
Rochester Lodge, Preston Hall Gardens
20 Filer Rd
27 Halfway Rd
90 Minster Road
2 Roman Rd
9, 11 & 13 Murston Rd
R/O 9, 11 and 13 Murston Road
Bedfont House, Holywell Lane
46 Parsonage Chase
St Ann’s Cross Coach House, 87 South Rd
1A Saxon Road
62 High Street
The Barn, Gibbens Farm, The Street
22-24 Orchard Way
1-3 Hope Street
Ambleside, Ennerdale
Adj 1 Western Aven, Halfway
Land r/o 44 High Street
Cedar House, Lewson Street
Land adj 157 Peregrine Drive
1 & 2 Rhode Common Cottages
Lime House, Burley Rd
129 Shortlands Rd
Orchard View, Chequers Hill
14
Settlement
Boughton
Minster
Minster
Newnham
Throwley
Warden
Sheerness
Sheerness
Sheppey
Faversham
Sittingbourne
Sittingbourne
Upchurch
Minster
Faversham
Faversham
Newington
Bredgar
Eastchurch
Sheerness
Faversham
Sheerness
Eastchurch
Norton
Sittingbourne
Dunkirk
Sittingbourne
Sittingbourne
Doddington
Yield
10
2
1
1
1
1
3
1
1
1
6
4
5
1
1
4
4
1
2
2
14
2
2
1
1
2
2
1
2
Technical Paper 5: Calculating a windfall allowance April 2015
Ref
12/1034
12/1054
12/1057
12/1096
12/1122
12/1166
12/1188
12/1225
12/1226
12/1275
12/1332
12/1363
12/1407
12/1421
12/1446
12/1467
12/1543
12/1568
12/1580
12/1596
12/1610
13/0009
13/0066
13/0103
13/0118
13/0123
03/0279
03/1252
03/1308
Address
7 High Street
Plot 3, Land adj Bayfield, Painters Forstall
R/o 1 London Rd
Land adj 69 Barton Hill Drive
Land adj The New Bothy, Lynsted Lane
53A West Street
Wyllie Court, Attlee Way
118 Prince Charles Avenue
Plot jnc. of Thomas Rd & Cowper Rd
Barbara Crest, Norman Rd
Land adj The Meadows
42 High Street
r/o 118 Ospringe Road
Victoria Working Men’s Club, Broadway
Land between 118-120 Manor Road
47 Bayford Road
2 Frederick Street
4 Trinity Road
202 High Street
Land at Rook Lane
152-154 Station Road
11 Shurland Avenue
The Burrows, Swanley Farm, Warden Road
Red Shed Site, Lower Road
Land opposite Stumble Inn, St Pauls Street
34 Goodnestone Road
Gunpowder Works Bysingwood Road
Land adjoining 2 Haysel
R/O 58-60 High Street
Settlement
Minster
Ospringe
Sittingbourne
Minster
Lynsted
Sittingbourne
Sittingbourne
Sittingbourne
Sittingbourne
Eastchurch
Sittingbourne
Eastchurch
Faversham
Sheerness
Queenborough
Sittingbourne
Sittingbourne
Sheerness
Sheerness
Bobbing
Teynham
Leysdown
Eastchurch
Teynham
Sittingbourne
Sittingbourne
Faversham
Sittingbourne
Newington
15
Yield
6
1
2
1
1
1
51
2
2
1
6
2
1
2
3
5
6
1
2
5
3
3
1
9
1
2
1
1
1
Technical Paper 5: Calculating a windfall allowance April 2015
Ref
04/0253
05/0967
06/0150
06/0763
06/1364
07/1192
07/1311
08/0458
09/0079
09/0972
09/1000
09/1108
10/0458
10/0584
10/0664
10/0908
11/0237
11/0295
11/0306
11/0651
11/0921
11/0940
11/0960
11/1482
11/1497
11/1586
12/0100
12/0102
12/0183
Address
Land adj. Helig, Queenborough Drive
Former Hernhill school, Church Hill
Provender, Provender Lane
Former Vic Working Men's Club, Broadway
Farmyard at Belvedere Farm, Dargate Rd, Hernhill
Land adj 'The Plough', Plough Rd, Minster
Green Farm Barn, Stalisfield Green
85 London Rd
Forge Orchard, Staple Street
Eden Top, Sheppey Way
Site at 131A Minster Road
R/O Sondes Arms Public House
Marshlands Farm, Lower Road
3 Shurland Avenue
Land adj to Beachside, Seaview Gardens
Chapel Farm, Hillside Road
1 Kingsborough Cott, Eastchurch Road
r/o 79 East Street
Beggars Roost, 27 Sixth Avenue
Land r/o 39 Seathorpe Avenue
South of Barbery Farm, Provender Lane
Underfield, Wellbrook Farmhouse, South Street
Fmr British Queen Car Park, Chequers Rd
Faversham Foundry, Seager Road
Sandbanks Farm, Perrywood
2-4 South Road
Land adj 32 Woodland Drive
414 Minster Rd
Land north of Plantation Lodge, School Lane
Settlement
Minster
Hernhill
Norton
Sheerness
Hernhill
Minster
Stalisfield
Sittingbourne
Hernhill
Bobbing
Sheppey
Selling
Minster
Leysdown
Warden
Stalisfield
Eastchurch
Sittingbourne
Eastchurch
Minster
Norton
Boughton
Minster
Faversham
Selling
Faversham
Minster
Minster
Iwade
16
Yield
1
1
1
24
1
1
1
1
1
1
1
5
1
1
1
1
2
3
1
1
1
1
3
49
1
1
1
2
1
Technical Paper 5: Calculating a windfall allowance April 2015
Ref
12/0266
12/0889
12/1492
12/1529
11/1624
TOTAL
Address
1-31 Rushenden Court, Rushenden Rd
Forge House/Barrow House, The Street
124 Chalkwell Road
Victoria Hotel, 103-109 Alma Road
Transit Works, Power Station Rd
Settlement
Queenborough
Borden
Sittingbourne
Sheerness
Minster
Yield
8
4
2
5
46
746
Table 12 SHLAA (Local Plan allocations) identified 'windfall' sites with sites <15 units highlighted.
Ref
SW/005
SW/034
SW/039
SW/076
SW/112
SW/113
SW/114
SW/120
SW/122
SW/140
SW/169
SW/191
SW/203
SW/209
SW/212
SW/220
SW/310
SW/312
SW/318
SW/353/354
Site Name
The Foundry
Weston Works, Brent Hill/Brent Road
Shellness Road/Park Avenue
Lydbrook Close
St Bartholomew’s Primary School, Atlee Way
St Thomas’s Primary School, Atlee Way
Halfway Houses Primary School, Southdown Road
Iwade Fruit & Produce, The Street
Iwade Village Centre II, The Street
Parsonage Farm, School Lane
HBC Engineering, Power Station Road
Faversham Police Station, Church Road
Land at Ordnance Wharf, Flood Lane
Land at Preston Skreens, Minster Road
Bysingwood Primary School, Hazelbrouck
152 Staplehurst Road
Freesia, Grovehurst Road
35 High Street, Milton Regis
Land at Manor Road
Standard Quay/Fentiman's Yard
Settlement
Queenborough
Faversham
Leysdown
Sittingbourne
Sittingbourne
Sittingbourne
Minster
Iwade
Iwade
Newington
Minster
Faversham
Faversham
Minster
Faversham
Sittingbourne
Sittingbourne
Sittingbourne
Queenborough
Faversham
17
Yield
37
40
10
60
29
22
60
30
12
14
87
12
11
24
15
72
15
15
6
11
Technical Paper 5: Calculating a windfall allowance April 2015
SW/356
SW/359
SW/374
SW/424
SW/442
South East Coast Oil Services
Standard House
Orbital Staplehurst Road
Swan Quay (various sites), Belvedere Road
Watermark, Staplehurst Road
Faversham
Faversham
Sittingbourne
Faversham
Sittingbourne
18
16
5
60
20
219
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