A feasibility study is conducted to consider the viability of a potential project, understand the possible challenges and assess the opportunities.
We discuss ideas and aspirations for the project with the client to understand what is needed. Initial designs and drawings of the project will then be created to provide an initial illustration that offer clients a great way to visualise their ideas and explore them further.
If you have a project in mind, whether it is a new build development on a recent plot of land you have acquired or extending your home then you may have already found yourself wondering whether the building project is possible or not?
In the early stages of any development project, a feasibility study is essential to determine the viability of a project and are very useful in helping to determine the options available for you. Establishing if a project is possible is perhaps one of the most common questions, we, are asked regularly. Common questions are:

  • How big of an extension can I build?
  • How many flats can I build?
  • How does the planning process work?
  • How much will it cost?
Here at HAD & CO we can offer the following at the feasibility stage:
·       Spatial arrangement of layouts to produce potential number of units
·       Photographic survey
·       Draft planning statement and start of Design & Access Statement
·       Submit basic site composition analysis to determine initial maximum density scheme
·       Set design criteria
·       Assessing any risks the proposal may have and what possible solutions can be considered
·       Submit Pre-Application to the Local Authority to gain their comments

 We charge £55 p/h for the feasibility stage, If you do have a potential project, we would love to hear from you! Please contact us to discuss your project and talk to us  about conducting a professional feasibility study.

Example without sketches (Previous study)
4 hrs 


Project Address Gynn Avenue, Blackpool, FY1 2LD 

Query Is the existing premises holiday let use lawful? 

Does it need planning permission to change the C3 use? 


Find information to assist with case 
Check relevant legislation 
Similar case studies 
Local Planning Policy (Blackpool Council) 
Issue conclusive thoughts

Blackpool planning policy 

Looking at Blackpool Council’s current planning policies including the Core Strategy and the Supplementary Planning Documents (SPD’s) we can attempt to determine the Council’s view on the existing premises as flats and/or holiday lets. The main policies to consider are quoted below, with the main parts highlighted. Policy CS23: Managing Holiday Bed Spaces 2 To achieve an economically viable level of quality holiday accommodation, the following approach will be adopted to manage a reduction in the oversupply of poor quality holiday bed-spaces: 1. Within the main holiday accommodation areas defined in the SPD: a. Existing holiday accommodation use will be safeguarded and new or refurbished holiday accommodation will be supported b. Change of use from holiday accommodation, or the loss of sites used, or last used, as holiday accommodation, will be resisted unless: i. Exceptional circumstances are demonstrated in accordance with the SPD, or ii. In relation to a promenade frontage, the proposal would provide high quality holiday accommodation alongside a supporting new residential offer. Such proposals would need to comply with the requirements of the SPD. 2. Outside the main holiday accommodation areas: a. Where existing holiday accommodation is viable its retention will be supported, including measures to improve the quality of accommodation b. Change of use from holiday accommodation to permanent residential use will be permitted where proposals provide high quality homes which comply with the Council’s standards for conversions or new build, and relate well in use, scale and appearance to neighbouring properties. Checking Blackpool Council’s Holiday Accommodation Areas SPD, the MH3 area (page 29) shows this property lies just outside the area boundary for this location as the majority of Gynn Avenue is included. The close proximity to the dedicated Holiday Accommodation Area should allow the Council to give it support to be used as Holiday Lets. Even without being within the zone, it can be shown to be viable and the planning history should also help show the precedence for the council to support the retention.

Policy CS21: Leisure and Business Tourism 1. In order to physically and economically regenerate Blackpool’s resort core and town centre, the focus will be on strengthening the resort’s appeal to attract new audiences year-round. This will be achieved by supporting: a. Proposals for new high-quality tourism attractions focused on the town centre and resort core, including major development opportunities which have the potential to become wider catalysts for regeneration to improve the visitor experience b. Proposals for new visitor accommodation focused on the town centre, resort core and defined holiday accommodation areas, unless exceptional circumstances justify a peripheral location outside these areas c. The improvement and enhancement of important existing tourist attractions d. The improvement of existing holiday accommodation and giving marginal, lower quality guesthouses the opportunity to convert to high quality residential accommodation outside the defined holiday accommodation areas. 3 Blackpool is one of the UK’s busiest areas dedicated to tourism and is reliant on the income from tourism to fund its economy. As such, the encouragement for new visitor attractions will coincide for the need for suitable holiday accommodation. The council plan for the development and future by writing planning policies to help shape this growth. The concentration on leisure and tourism is confirmation that this is what is anticipated for the coming years to help Blackpool strive so holiday lets will still be a requirement for the town. Although there isn’t anything specific on changing the use of existing flats or historical holiday homes back into holiday lets, or whether existing C3 uses can be used as holiday lets without needing a planning application; there are planning policies that show they will support such developments should an application be necessary.

National Planning Legislation- class use and limits 

The existing court cases show that the actual definition and how uses are described in the Class Uses Order can assist in the argument for a C3 dwelling to be considered as a holiday let without needing planning permission. 

Conclusive final thoughts 

There is no legislative definition of a material change of use. As to whether your holiday-let flat would be considered as needing a material change of use it would be wholly down to how the council would view the situation. If the property is to be used as a like-for-like, i.e.: a home away from home, you could consider it is still classed as a C3 dwellinghouse. However, if the whole property is to be let out as a guest house, this is more likely to be classed as C1 which would need a change of use application. I would suggest the best way to clear up the issue is to consult the Local Authority Planning Department by way of a pre-app to formally check if you are in need of a planning application to change the use and also what use class this would be permitted as. The planning policies and guidance for Blackpool do seem more concerned with converting an existing holiday let into C3, and the Holiday Accommodation Area MH3 being so close is a positive sign. If you are confident your C3 flats can be let out as holiday lets without a change of use application, please check the rules on Council Tax/ Business rates and how long you can and cannot let the properties as holiday accommodation. Ideally, a property should only be let to families or those who constitute a pre-formed household group so that there will be no material change of use where the property was previously used as a family home.

Planning history 

83/0090 | Planning permission for use as five holiday lets and owner’s accommodation 01/8183 | Planning enforcement for HMO registration 13/8500 | Planning enforcement for holiday flats change of use to permanent accommodation 17/0812 | Certificate of Lawfulness for the existing use of the property as four self-contained flats and one non-selfcontained flat

Current class use

 The most recent planning application for the Lawful Development Certificate show the existing use of the property is “four self-contained flats and one non-self-contained flat”. This supersedes any previous uses and is considered the current existing use since no other application has been put in to change the use.

Case studies 

Various successful and unsuccessful appeals taken to the High Court have been documented online which argue their C3 use should extend to include the use as a holiday let after LPA’s and Planning Inspectorates have sided against this. They vary in judgement with concern over the ‘material use’ and whether this changes significantly from how the premises would be used as a traditional dwelling and also the actual definition of “dwelling house” and how one would perceive this. A quick recap and review of some cases: Moore v SSCLG and Suffolk Coastal District Council [2012] EWCA Civ 1202; [2013] JPL 192 The council issued enforcement as they believed the C3 dwelling was breaching planning by being let out as a holiday let. The Court took the Council’s side and refused the owner’s appeal. This was based on a large older building that had been coverted to a C3 dwelling which was then being used as a holiday let by renting out different rooms. The way in which the dwelling was being run as a business was determined that it was more of a “commercial leisure accommodation” than a private dwelling and hence required a change of use (sui generis). Blackpool Borough Council v Secretary of State for the Environment [1980] 40 P&CR 104 A four-bedroom town house was being used by the owner for part of the year and then rented out to family and friends when not in use. It was also empty for part of the year when the holiday season ends. The council believed the owner needed to change the use from C3 to holiday lets on a commercial basis. However the courts here sided with the appellant as it was proven that those who rented the property were actually using the premises as they would their own dwelling house, therefore the C3 use could stay. This was very dependent on the fact that the owner and their family also used the premises as a second home and the character of the existing house had not changed. Gravesham Borough Council v Secretary of State for the Environment (1982) P&CR 142 This case concluded that the C3 dwelling house use remains as a house, as long as it is used to facilitate those using it for private and domestic day-to-day living, regardless of the frequency of use or by whom. Ultimately, as there is little to no legislation on these matters, the council would have to determine on a case-bycase basis and weigh up the relevant matters whether they are of the opinion that a C3 property would need a change of use application. Things like the material changes, neighbour concerns and immediate surroundings would all be considered. In my opinion, 28 Gynn Avenue is in a well-suited location to be used as a holiday let and the close 4 proximity to the existing Holiday Home Area and planning history are all positives however this is only my view and the Council would need to be consulted to be sure. Pre-application advice can be obtained from Blackpool Council’s Planning Department to gain written confirmation as to whether the proposal would need a planning application with further advice as to what they would need in order to determine an application should one be necessary.

Legislation: Class use C “The Town and Country Planning (Use Classes) Order 1987 (Amendment) (England) Order 2010 SCHEDULE PART C Class C1. Hotels and hostels Use as a hotel, boarding or guest house or as a hostel where, in each case, no significant element of care is provided. Class C2. Residential institutions Use for the provision of residential accommodation and care to people in need of care (other than a use within class C3 (dwelling houses)). Use as a hospital or nursing home. Use as a residential school, college or training centre. Class C2A. Secure residential institutions Use for the provision of secure residential accommodation, including use as a prison, young offenders institution, detention centre, secure training centre, custody centre, short-term holding centre, secure hospital, secure local authority accommodation or use as military barracks. Class C3. Dwellinghouses Use as a dwellinghouse (whether or not as a sole or main residence) by— (a)a single person or by people to be regarded as forming a single household; (b)not more than six residents living together as a single household where care is provided for residents; or (c)not more than six residents living together as a single household where no care is provided to residents (other than a use within Class C4). Interpretation of Class C3 5 For the purposes of Class C3(a) “single household” shall be construed in accordance with section 258 of the Housing Act 2004(2). Class C4. Houses in multiple occupation Use of a dwellinghouse by not more than six residents as a “house in multiple occupation”. Interpretation of Class C4 For the purposes of Class C4 a “house in multiple occupation” does not include a converted block of flats to which section 257 of the Housing Act 2004 applies but otherwise has the same meaning as in section 254 of the Housing Act 2004.

Legislation: Housing Act “Single Household” Section 258 of The Housing Act 2004 258 HMOs: persons not forming a single household (1)This section sets out when persons are to be regarded as not forming a single household for the purposes of section 254. (2)Persons are to be regarded as not forming a single household unless— (a)they are all members of the same family, or (b)their circumstances are circumstances of a description specified for the purposes of this section in regulations made by the appropriate national authority. (3)For the purposes of subsection (2)(a) a person is a member of the same family as another person if— (a)those persons are married to [F1, or civil partners of, each other or live together as if they were a married couple or civil partners]; (b)one of them is a relative of the other; or (c)one of them is, or is a relative of, one member of a couple and the other is a relative of the other member of the couple. (4)For those purposes— (a)a “couple” means two persons who F2... fall within subsection (3)(a); (b)“relative” means parent, grandparent, child, grandchild, brother, sister, uncle, aunt, nephew, niece or cousin; (c)a relationship of the half-blood shall be treated as a relationship of the whole blood; and (d)the stepchild of a person shall be treated as his child. (5)Regulations under subsection (2)(b) may, in particular, secure that a group of persons are to be regarded as forming a single household only where (as the regulations may require) each member of the group has a prescribed relationship, or at least one of a number of prescribed relationships, to any one or more of the others. (6)In subsection (5) “prescribed relationship” means any relationship of a description specified in the regulations. 6 The legislation states the use of a C3 dwelling house is for the use a single household. The Housing Act then goes on to explain what is meant by a single household. Using this legislation, it could be argued that each flat being rented out separately as a holiday let could only be used by a single household therefore falling under the class use C3. Holiday let flats for 28 Gynn Avenue would need to be considered on an individual basis whereby only 1-2 people can let the individual flat and use it as a “dwelling house”. If the whole house was let at once, this could be more of a C1 use due to the variety of self-contained units and the possibility of those renting would not fall under the definition of a single household. PLEASE NOTE: There are further limits on how long you can rent as a holiday let and a limit as to how long one person/party can let a property- this is more of a council tax/ business rates issue rather than planning so the relevant authorities at the Council will need to be notified/ contacted.