Five year housing land supply report

Appendices

1. Introduction

1.1 This document sets out Wyre Forest District Council’s assessment of its housing land supply from 1 April 2026 to 31 March 2031.

1.2 Paragraph 78 of the December 2024 National Planning Policy Framework (NPPF) requires all local planning authorities to identify and update annually a supply of specific deliverable sites sufficient to provide at least five years’ worth of housing against their housing requirement as set out in adopted strategic policies. Where strategic policies are more than five years old, authorities must instead assess supply against their Local Housing Need (LHN), calculated using the standard method.

1.3 The December 2024 NPPF, together with the associated Housing Delivery Test (HDT) Rule Book, introduced a revised standard method for calculating LHN. If applied in Wyre Forest District, this would effectively double the Council’s annual housing need from 276 to 584 dwellings per annum.

1.4 However, the Government has set out transitional arrangements within the NPPF. These state that where an adopted spatial development strategy is less than five years old, the housing requirement within that plan will be used as the benchmark for assessing both housing delivery and five-year housing land supply. The Wyre Forest District Local Plan was adopted on 26 April 2022. Policy SP1 of the Wyre Forest Local Plan is strategic policy and sets out an average housing requirement of 276 dwellings per annum.

1.5 Accordingly, housing delivery will continue to be monitored against the adopted Local Plan requirement of an average of 276 dwellings per annum.

1.6 In addition, the provision of C2 accommodation has been factored into the 5 year supply calculation. The Wyre Forest Local Plan sets out that over the 20 year plan period, a total of 487 C2 bedspaces should be provided. Over a 5 year period, this equates to the provision of approximately 121.75 bedspaces.

1.7 The recent adoption of the Wyre Forest Local Plan therefore provides the Council with greater certainty over how housing delivery and supply will be measured for up to the next five years.

1.8 On this basis, the Council can currently demonstrate a 8.8 year supply of deliverable housing sites for the period 2026/27 to 2030/31, measured against the five-year requirement including the 5% buffer.

2. The Housing Requirement

2.1 Planning Practice Guidance (PPG) (Paragraph: 005 Reference ID: 68-005-20190722) requires the housing requirement figure set out in adopted strategic housing policies to be used when calculating the five year housing land supply. This applies only where the plan was adopted within the last five years or its strategic housing policies have been reviewed within the last five years and found not to need updating.

2.2 The Wyre Forest Local Plan was adopted on 26 April 2022. Policy SP.1 is strategic and sets out the housing requirement for the district, which is an average of 276 dwellings per annum. This figure has been used to calculate the five year housing land supply. In all other circumstances, the Local Housing Need figure must be used. The Local Housing Need is an unconstrained assessment of the minimum number of homes needed in an area. It must be calculated using the standard method, details of which are set out within the PPG (Paragraph: 004 Reference ID: 2a-004-2024121).

The housing land supply period

2.3 The period 1 April 2026 to 31 March 2031 is covered in this update of the five year housing land supply.

Housing Delivery Test and application of the NPPF buffer

2.4 Paragraph 78 of the NPPF sets out that the supply of specific deliverable sites should in addition include a buffer (moved forward from later in the plan period) of:

1. 5% to ensure choice and competition in the market for land; or
2. 20% where there has been significant under delivery of housing [Footnote 40: This will be measured against the Housing Delivery Test, where this indicates that delivery was below 85% of the housing requirement] over the previous three years, to improve the prospect of achieving the planned supply; or
3. 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 this 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.

2.5 The Government introduced the Housing Delivery Test (HDT) in 2018, with the first results of the HDT being published by the Secretary of State in November 2018. The HDT measures the net additional dwellings provided in a local authority area against the homes required, using national statistics and local authority data. The HDT provides a measure based on the preceding 3 financial years.

2.6 The current published HDT result relates to the ‘2023 measurement’ (published on 12 December 2024), and covers the period 2020/21, 2021/22 and 2022/23. For the 3-year period 2020/21-2022/23, Wyre Forest delivered 1140 dwellings against a requirement of 615, giving a score of 185%. Therefore, in line with paragraph 78a of the NPPF, a 5%buffer is required in addition to the housing requirement.

Over supply of past housing completions

2.7 PPG (Paragraph: 023 Reference ID: 68-032-20190722) allows the past over-supply of dwelling completions against the planned requirement to be used to offset any shortfalls against requirements from previous years. However, the PPG and NPPF are silent on whether over-supply can be set against future years

2.8 Since the beginning of the plan period (April 2016 until April 2026), there were 3043 dwellings completed, which when compared to the annual average dwelling requirement of 276 dwellings, results in a surplus of 283 dwellings.

3. Sources of Housing Supply

3.1 This section provides an explanation of the sources of land supply that form part of the monitoring of housing land supply position. Specific sites are set out in the accompanying schedules in Appendix 1. Monitoring data with a base date of 31 March 2025 was used.

3.2 The Council considers that the sites which form part of the five year housing land supply are deliverable (as defined by the Glossary to the NPPF), and that there is clear evidence and a realistic prospect that housing completions will begin within five years. Many of the sites were also the subject of extensive discussions as part of the Local Plan Review examination process.

The meaning of deliverable

3.3 The meaning of 'deliverable’ is set out within the Glossary of the NPPF. This states: “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. In particular:

1. Sites which do not involve major development and have 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 (for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans).
2. Where a site has outline planning 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.”

3.4 For all sites with detailed planning permission (full or reserved matters) and small sites (sites delivering less than 10 dwellings) with outline planning permission which fall under Part a) of the definition, the NPPF is clear that these should be assessed as being deliverable until permission expires, unless there is specific evidence to the contrary. Without such specific evidence, a decision taker should not reach another conclusion.

3.5 For large sites (site delivering 10 or more dwellings) with outline planning permission or allocated sites in the adopted development plan without planning permission, specific evidence is required that there is a realistic prospect of dwellings being delivered within the five year period. It should be noted that the need for specific evidence falls under the umbrella of a 'realistic prospect', carrying no greater evidential burden.

3.6 The PPG provides additional guidance (PPG, Paragraph 007, Reference ID: 68-007-20190722) on deliverability stating that evidence may include:

• Current planning status– for example, on larger scale sites with outline or hybrid permission how much progress has been made towards approving reserved matters, or whether these link to a planning performance agreement that sets out the timescale for approval of reserved matters applications and discharge of conditions;
• Firm progress being made towards the submission of an application–for example, a written agreement between the local planning authority and the site developer(s) which confirms the developers’ delivery intentions and anticipated start and build-out rates;
• Firm progress with site assessment work; or
• Clear relevant information about site viability, ownership constraints or infrastructure provision, such as successful participation in bids for large-scale infrastructure funding or other similar projects.

Local Plan Strategic Site Allocations

3.7 Residential site allocations are identified within the adopted Wyre Forest Local Plan (2016-2036), including both strategic and non strategic housing allocations, which are intended to contribute towards meeting the district’s housing requirement over the plan period.

3.8 The Local Plan includes a number of strategic site allocations which are expected to deliver a significant proportion of the district’s future housing growth. These sites are generally large scale urban extension developments located adjacent to the district’s main settlements and are intended to deliver comprehensive and sustainable development supported by associated infrastructure, green infrastructure, public open space and transport improvements.

3.9 Due to the scale and complexity of these sites, delivery is anticipated to take place over a number of years and across multiple phases. Several strategic allocations are progressing through the planning process, with ongoing engagement taking place between the council, site promoters, developers and infrastructure providers to support delivery.

Local Plan Non-Strategic Site Allocations

3.10 In addition to the strategic allocations, the Local Plan identifies a range of non-strategic residential allocations across the district. These sites vary in size and character and include both greenfield and previously developed land opportunities within and adjacent to existing settlements. A number of these allocations have already secured planning permission or are subject to active pre-application discussions and are therefore expected to make an important contribution to housing delivery within the five year period.

3.11 The Council has undertaken a detailed assessment of allocated sites to determine their anticipated delivery within the five year housing land supply period. In respect of sites without full planning permission, the council has adopted a cautious and evidence based approach, taking account of factors including site-specific constraints, infrastructure requirements, lead in times, developer intentions and anticipated build out rates. Only sites where there is clear evidence that housing completions are likely to come forward within the five year period have been included as deliverable within this report.

Neighbourhood Development Plan Allocations

3.12 In addition to the allocations identified within the adopted Wyre Forest Local Plan, a number of residential site allocations are also identified through made Neighbourhood Development Plans (NDPs) within the district. At the time of writing this report, the adopted Neighbourhood Development Plans in Wyre Forest comprise the Chaddesley Corbett Neighbourhood Plan (2022-2036) and the Churchill and Blakedown Neighbourhood Plan (2016-2026). The allocations within these plans form part of the statutory development plan for the district and contribute towards meeting local housing needs and supporting sustainable growth within their respective parish areas.

3.13 Neighbourhood Development Plan allocations are generally smaller-scale sites located within or adjacent to existing settlements and have been identified through locally-led plan making processes, including public consultation, independent examination and local referendum.

3.14 As with other allocated sites included within this report, the council has applied a cautious and evidence-based approach when assessing the likely contribution of Neighbourhood Development Plan allocations towards the five year housing land supply. Consideration has been given to factors such as planning status, site constraints, infrastructure requirements, lead in times, and developer intentions. Only those sites where there is sufficient evidence to demonstrate a realistic prospect of delivery within the five year period have been included as deliverable within the housing land supply calculation.

Non-allocated sites for 10 or more dwellings with planning permission

3.15 The Five year housing land supply also includes a number of non-allocated residential sites which have secured permission for 10 or more dwellings. These sites contribute towards housing deliver where they are considered deliverable in accordance with the definition set out within the National Planning Policy Framework (NPPF).

3.16 Non allocated sites typically comprise windfall developments, redevelopment opportunities and other sustainable sites which have come forward through the development management process outside of the formal plan allocation process. These sites vary in scale and character and include both previously developed land and greenfield sites located within or adjacent to existing settlements.

3.17 The inclusion of non-allocated sites within the housing land supply reflects the council’s continued ability to support sustainable residential development opportunities beyond those specifically identified through the development plan. Many of these sites have benefited from active developer interest and in some cases, construction has already commenced on site.

Non-allocated sites for less than 10 dwellings with planning permission

3.18 The five year housing land supply also includes a number of non-allocated small sites with planning permission for fewer than 10 dwellings. Whilst individually, these sites make a relatively modest contribution to housing delivery, collectively they represent and important component of the district’s overall housing supply and provide flexibility and variety within the housing market.

3.19 Small non-allocated sites typically arise through windfall development opportunities, including infill development, redevelopment of previously developed land, conversions, changes of use and small-scale residential schemes within existing settlements. These sites are generally delivered more quickly than larger strategic developments due to their scale, reduced infrastructure requirements and shorter lead-in times.

3.20 The inclusion of small sites within the housing land supply reflects historic delivery trends within Wyre Forest District, where smaller developments have consistently contributed towards annual housing completions. These sites already benefit from full planning permission, and in some cases, development has already commenced or is nearing completion.

3.21 The council has assessed all non-allocated sites with planning permission on an individual basis, taking account of factors including planning status, commencement on site, site constraints, developer intentions and anticipated build-out rates. Where outline planning permission has been granted, the council has considered the likelihood and timing of reserved matters approval and subsequent delivery. Only sites where there is clear evidence that housing completions are realistically expected within the five year period have been included within the deliverable housing supply.

Sites for less than 10 dwellings with prior approvals

3.22 The five year housing land supply also includes a number of small sites for fewer than 10 dwellings which have secured prior approval. These developments typically comprise the conversion or change of use of existing buildings to residential use and form an additional source of housing supply within the district.

3.23 Prior approval schemes are generally associated with the redevelopment or reuse of existing buildings, including former offices, agricultural buildings, and other commercial premises. Such developments can make an important contribution towards housing delivery by bringing underutilised buildings back into active use and supporting the efficient use of land within existing settlements and rural areas where appropriate.

3.24 Due to their relatively small scale and the streamlined nature of the prior approval process, these sites are often capable of being delivered within shorter timescales when compared to larger residential developments. Many schemes involve limited site preparation and infrastructure requirements, allowing development to proceed relatively quickly following approval.

3.25 The council has assessed small prior approval sites on an individual basis, taking account factors including the status of approval, evidence of implementation, site specific constraints and anticipated delivery timescales. Only those sites where there is a realistic prospect of completion within the five year period have been included within the deliverable housing supply.

Residential Institutions (Use Class C2) Accommodation

3.26 The five year housing land supply also includes relevant residential institution accommodation falling within use class C2 of the Town and Country Planning (Use Classes) Order 1987 (as amended). Use Class C2 includes residential accommodation such as care homes, nursing homes and other forms of accommodation where personal care is provided to residents.

3.27 National planning policy and guidance recognise that housing needs should be assessed across a range of accommodation types, including housing for older persons and those requiring care or support. The NPPF states that the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies, including older persons and those with disabilities. In addition, Planning Practice Guidance (PPG) confirms that communal accommodation, including residential institutions within Use Class C2, may be counted towards housing supply where it releases accommodation into the wider housing market (Paragraph: 026, Reference ID: 68-035-20190722). The Housing Delivery Test Rule Book was updated on 12 December 2024, and the council must now apply a ratio of 1.9 to convert bed spaces to a dwelling equivalent within the five year housing land supply.

3.28 The Wyre Forest Local Plan sets out that over the 20 year plan period, a total of 487 C2 bedspaces should be provided. Over a 5 year period, this equates to the provision of approximately 121.75 bedspaces, and when applying a dwelling equivalent of 1.9, this equates to 64 dwellings. The additional 64 dwellings have been factored into the 5-year requirement.

3.29 The Council has assessed relevant C2 schemes on an individual basis, taking account of planning status, delivery prospects and the likely level of self-contained or communal accommodation proposed. Only those schemes considered deliverable within the five year period have been included within the housing land supply position.

2. The Five Year Housing Land Supply

Total deliverable housing supply for the period 1 April 2026 until 31 March 2031.

Housing Land Supply Position

4.1 The Council can currently demonstrate a 8.8 year supply of deliverable housing sites for the period 1 April 2026 to 31 March 2031, measured against the five year requirement including the 5% buffer and C2 accommodation requirement.

4.2 It is important to note the housing land supply position is always a snapshot in time, and subject to change. This is due to various factors that include the planning status of sites, delivery rates, market conditions, and changes to national and local policy

[Note1] Total deliverable supply includes minus 48 demolitions at Dunclent flats