Worthing Borough Council
COMMUNITY INFRASTRUCTURE LEVY (CIL)
CONSULTATION STATEMENT
JUNE 2014
Introduction
This document provides a record of the consultation undertaken by Worthing Borough Council in preparing the Community Infrastructure Levy (CIL). This includes a review of the consultation undertaken on both the Preliminary Draft Charging Schedule and the Draft Charging Schedule.
This consultation statement documents which bodies and persons were invited to make representations and how those bodies and persons were invited to make such representations.
This document should be read in association with the following:
Statement of Representations Procedure
Statement of Representations (Regulation 19)
Statement of Modifications
Consultation on the Preliminary Draft Charging Schedule
Worthing Borough Council invited representations on its Community Infrastructure Levy Preliminary Draft Charging Schedule for a six week period between 30th January 2013 and 13th March 2013.
Consultation Process
The consultation undertaken on the Preliminary Draft Charging Schedule (PDCS) involved the following:
The consultation documents and supporting evidence were made available to view on the Council’s website. All website links went live at 10.30am on 30th January 2013 and a new ‘tile’ covering the consultation was added to the homepage of the Council’s website. All documents were available here:
http://www.adur-worthing.gov.uk/planning-policy/infrastructure/
The Council’s Twitter and Facebook feeds were used to publicise the consultation – see Appendix 1a.
Hard copies of all relevant documents were available at the Council Offices and all of the libraries in the Borough – see Appendix 1b.
The Planning Policy Newsletter (Appendix 1c) was used to publicise the consultation. The Newsletter with covering email (Appendix 1d) or letter (Appendix 1e) was sent to all statutory consultees. In addition, the Council also contacted all subscribers to the Planning Policy Newsletter circulation list and all other interested parties or general consultees on the council’s database. This included a large number of developers, land-owners, local businesses and resident / interest groups. A list of all consultees contacted can be found in Appendix 1f.
Hard copies of the Newsletter were made available to pick up at Council offices and libraries.
An advertisement was placed in the Worthing Herald (31/01/13) – see Appendix 1g.
Representations
A total of 13 representations were received by the Council during the consultation. The level of detail set out in each response varied significantly and covered a range of issues. All comments were considered by officers and Members and where relevant they helped to inform a further round of testing. The outcome of this work was reported within the Revised Viability Assessment (October 2013) which in turn helped to inform the preparation of the Draft Charging Schedule. All comments made during the PDCS consultation, and the officer response to these, were made available to view on the Council's website (Appendix 1h).
Consultation on the Draft Charging Schedule
Worthing Borough Council invited representations on its Community Infrastructure Levy Draft Charging Schedule for a six week period between 6th Mach 2014 and 17th April 2014.
Consultation Process
The consultation undertaken on the Draft Charging Schedule (DCS) involved the following:
The consultation documents and supporting evidence were made available to view on the Council’s website. All website links went live on 4th March 2014. This included links from a number of pages including new tiles on the home page of the Council’s website. All documents were available here:
http://www.adur-worthing.gov.uk/planning-policy/infrastructure/
The Council’s Twitter and Facebook feeds were used to publicise the consultation both at the start and during the consultation – See Appendix 2a.
Hard copies of all relevant documents were available to the Council Offices and all of the libraries in the Borough – see Appendix 2b.
The Planning Policy Newsletter (Appendix 2c) was used to publicise the consultation. The Newsletter with covering email (Appendix 2d) or letter (Appendix 2e) was sent to all statutory consultees. In addition, the Council also contacted all those that responded to the Preliminary Draft consultation, subscribers to the Planning Policy Newsletter circulation list and all other interested parties on the council’s consultee database. This included a large number of developers, land-owners, local businesses and resident / interest groups. A list of all consultees contacted can be found in Appendix 2f.
Hard copies of the Newsletter were made available to pick up at Council offices and libraries.
An advertisement was placed in the Worthing Herald (13/03/14) – see Appendix 2g.
Representations
A total of 10 representations (and 4 additional acknowledgements) were received by the Council during the consultation. Full details of the responses received can be found within the Council’s Regulation 19(1)(b) Statement.
PART 1. PRELIMINARY DRAFT CHARGING SCHEDULE APPENDICES
Appendix 1a: Preliminary Draft Charging Schedule Social Media Summary
Figure 1. Facebook launch on 30th January 2013
Figure 2. Twitter launch on 30th January 2013
Appendix 1b: Preliminary Draft Charging Schedule Deposit Points for Documents and Newsletters
Worthing Borough Council
Worthing Town Hall, Portland House, Chapel Road, 44 Richmond Road, Worthing, Worthing, West Sussex, West Sussex, BN11 1HA BN11 1HS
Libraries
Worthing Library Goring Library Richmond Road Mulberry Lane Worthing Goring-by-Sea BN11 1HD Worthing BN12 4NR
Findon Valley Library Durrington Library Lime Tree Avenue Salvington Road Findon Valley Worthing Worthing BN13 2JD BN14 0DH
Broadwater Library Dominion Road Broadwater Worthing BN14 8JL
Appendix 1c: PDCS Planning Policy Newsletter
Figure 3. Winter 2013 Newsletter (Page 1)
Figure 4. Winter 2013 Newsletter (Page 2)
Appendix 1d: PDCS Newsletter Covering Email
Figure 5. Covering email sent to consultees for the PDCS Consultation
From: Ian Moody Sent: 30 January 2013 11:56 Subject: Worthing Planning Policy Newsletter - Community Infrastructure Levy
Attachments: CIL Newsletter January 2013.pdf
You have been sent this email as either a subscriber to the Worthing Planning Policy Newsletter or as someone who may have an interest in policy matters within the Borough, particularly the emerging Community Infrastructure Levy (CIL).
Worthing Borough Council is in the process of introducing a CIL to allow funds to be raised from developers to pay for infrastructure that is needed as a result of development. As part of this process a Preliminary Draft Charging Schedule has been prepared which sets out the potential charges across the Borough. This is the first stage in our consultation and the Council is keen to hear the views of all interested parties and stakeholders (closing date for comment is 13th March).
The latest version of the Planning Policy Newsletter (attached) provides more detail and links to the key documents. Please use the contact information supplied on the Newsletter to submit any comments or notify me of any changes to your contact details.
Regards
Ian
Ian Moody - Principal Planning Officer | Planning Policy, Worthing Borough Council and Adur District Council Location: Adur Civic Centre - Room 221 Internal: 63009 | External: 01273 263009 | E-mail: [email protected]
Appendix 1e: PDCS Newsletter Covering Letter
Figure 6. Covering letter sent to consultees for the PDCS Consultation
Appendix 1f: PDCS List of Consultees
Below is a list of all consultees sent a newsletter and either a covering letter or email during the PDCS consultation. Note – this list does not include individuals / residents (including those that subscribe to the Planning Policy Newsletter).
Ability Housing Association Blue Sky Planning Ltd Adams Hendry Consulting Ltd Boots The Chemist Adur District Council Bovis Homes Affinity Sutton Boyer Planning Aid for Trade Brighton & Hove City Council Alliance Environment & Planning Ltd British Gas Plc AMEC Environment and Infrastructure British Horse Society UK Ltd (on behalf of National Grid) British Rail Property Board Amicus Horizon Housing Group British Telecom Angmering Parish Council Broadwater (Worthing) Community Anstone Properties Ltd Association Architectus Ltd Broadwater Residents Action Group Ardington Hotel Broadway Malyan Arun District Council Brunswick Hotel Avante Partnership Burlington Hotel Avid Development Ltd C G Spratt Aviva C.B.R.E B & S Ventures (Worthing) Limited Cable & Wireless B&W Group Ltd Campaign For Real Ale Ltd Banner Homes (Wessex) Ltd Cantium (Durrington) Ltd Barton Willmore Capella Holdings Batcheller Thacker Cellnet Becket Resident's Association Central Ward Residents Association Bellway Homes Central Worthing Residents' Blackrock UK Property Fund Association Bloomfields Ltd Central Worthing Resident's Blue Earth Web Solutions Association
Centrepoint Car Sales East Worthing Community Association CgMs Consulting ECE Planning Chatsworth Hotel EDF Energy Chichester District Council Elm Grove County First School Chloe Antiques English Heritage Chris Thomas Ltd Environment Agency Churches Together in Worthing Equiniti Churchill Retirement Living Ltd Factory Outlets City & Provincial Properties Plc Federation of Small Businesses Clapham Parish Council Ferring Parish Council Clifford Dann LLP FFT Planning Cliveden Homes Findon Parish Council Cluttons LLP Findon Valley Resident's Association Coal Authority Framptons Planning Consultants Colmi (UK) LLP Friends of Worthing Museum and Art Compass Travel Gallery Component Moulders Fusion Online Limited CPRE - Campaign to Protect Rural Fusion Online Ltd England (Sussex) Geoffrey Osborne Ltd Crawley Borough Council GL Hearn Crest Nicholson (South) Ltd GlaxoSmithKline Cushman & Wakefield Goring Chase Resident's Association David Wilson Homes South East Ltd DC Planning Limited Goring Residents Association Dearden Homes Ltd Gracemount Developments Ltd Designer Developments Ltd Guild Care Development Planning Partnership H G Scadgell Ltd Dialogue Hallam Land Management Ltd Dixon Searle Parnership (DSP) Hanson Capital Dome Trust Hargreaves Management Ltd Downlands Housing Association Heene Community Association DPDS Ltd Heyday Worthing Friendship Centre DTZ Royal Mail's Planning Advisors High Salvington Residents' Association East Worthing Action Group
High Street Tarring Resident's Lancing Parish Council Association Land & Brand New Homes LLP Highdown Copse Residents Lawson Planning Partnership Ltd Association Leith Planning Ltd Highways Agency Lemo Hillreed Developments Limited Lloyds TSB Registrars Ltd Hillreed Homes Marine Management Organisation Hillreed Residential Developments Marks & Spencer Plc Home Builders Federation Martin & Co Homes and Communities Agency Mccarthy & Stone Retirement Horizon Design Ltd Lifestyles Ltd Horsham District Council McLaren Clark Group Hot Dog Media Ltd MGM Assurance Hyde Housing / Chichester Diocesan Michael Cook Associates Ltd Housing Association (CDHA) Michael Jones & Co Hyde Martlet Michael Spurr Consulting Hyder Consulting Ltd Mid Sussex District Council ICENI Projects MONO Consultants Ltd Ilex Conservation Group Monsoon ITPS Mulberry Property Investment J Sainburys PLC Management Ltd Jeremy Silverthorne Jewellery Nathaniel Lichfield & Partners Ltd Jones Day National Car Parks Ltd Jones Lang LaSalle National Federation of Gypsy Liaison Jubilee Community Church National Grid Plant Protection Julian Dilkes Architecture National Trust (Southern Region) JW Stratton Ltd Natural England Kelsey Housing Association Natwest Bank Kier Homes Network Rail Kingston Parish Council NGPH Ltd Knightspur Homes Ltd NHS South East Coast Knightspur Homes Ltd Northbrook College Lambert Smith Hampton Northbrook College Lancashire Digital Technology Centre Oakfawn Properties Ltd
Orange Personal Communications Second Site Property Holdings Osborne Homes Secretary of State for Transport Palmer Business & Media Servite Houses Patching Parish Council Shafiques Paul and Company Showmens Guild of GB Peacock & Smith South Broadwater Resident's Persimmon Homes Association Peverel Management Services South Coast Nursing Home Phoenix Homes Ltd South Downs National Park Authority Planning Inspectorate South Downs Society Planning Perspectives Southern Powergen Southern Housing Group RAG Southern Water Raglan Housing Association Ltd Sport England Rapleys LLP St Barnabas Hospice Rapleys Llp Stagecoach (South) Red Square Developments Ltd Steeles of Worthing RF Financial Services Stewart Ross Associates Richard J Maile Town and City Stiles Harold Williams Planning Strutt & Parker Robert Dorin Chartered Surveyor Sussex Downs Conservation Board Robert Turley Associates Sussex Enterprise Roffey Homes Sussex Ornithological Society Roger Green Sound & Vision Sussex Police Rose Willmot Youth Centre Sussex Wildlife Trust Safran Homes Ltf Sustrans Sainsbury's Supermarkets Ltd Tarring Residents Association Sapphire Primary Care Developments Taylor Wimpey Save the Dome Terrance Higgins Trust South Saville Jones Architects Tesco Stores Ltd Saxon Weald Homes Ltd Tetlow King Planning Saywell International Ltd The Coal Authority Scotia Gas Network The Community House Scottish Power The Co-Operative Society
The Elim Church Worthing & Adur Chamber Of The Guinness Trust Commerce The Police and Crime Commissioner Worthing & Southlands NHS Trust for Sussex Worthing Access & Mobility Group The Village Estate Agency Worthing Arts Council Town & Country Planning Solutions Worthing Astronomical Society Transco Worthing Branch Disabilities Network Travelodge Worthing Churches Homeless Turley Associates Worthing College UE Associates Ltd Worthing Community Arts Council Viridian Housing Worthing Community Partnership Waitrose Worthing Council for Voluntary Service Waterstock Developments Ltd Worthing Council of Community West Durrington Consortium Associations West Sussex County Council Worthing First West Sussex Economic Partnership Worthing Friendship Centre West Sussex Fire & Rescue Service Worthing Herald West Sussex Gazette Worthing Homes Limited West Sussex Learning Partnership Worthing Islamic Cultural Centre West Sussex Local Access Forum Worthing Islamic Society West Sussex Primary Care Trust Worthing Liberal Democrats West Waddy ADP Worthing Methodist Church Western Sussex Hospitals Worthing MIND White Young & Green Worthing Society White Young Green Planning Worthing Society For The Blind Wilkinson Worthing Squares Dance Group Wilmington New Homes Ltd Worthing Town Centre Initiative Women's Aid Worthing Twinning Association Wood Frampton WYG Planning + Design - Persimmon Woolfbond Planning Homes Workability West Sussex Youth Council
Appendix 1g: Press Advert in Worthing Herald for PDCS Consultation
Figure 7. Scanned Image of Press Advert (31st January 2013)
Figure 8. Text for Press Advert in Worthing Herald
Appendix 1h: Summary of Consultation Representations and Officer Response for PDCS Consultation
Worthing CIL - Preliminary Draft Charging Schedule
Summary of Consultation Responses Jan 30th – March 13th
001 Katie Dodds (Tanner & Tiley -Planning Consultants) Officer Response
On behalf of – Retirement Housing Group
Imposition of CIL on specialist accommodation for older people will have Evidence has demonstrated that developments falling within Use Class C2 would disproportionate impact on viability compared with general needs housing. be zero rated and would not be liable for CIL. This form of housing should be treated differently when CIL is applied. Accommodation for older people, whether falling within Classes C2 or C3 of Additional testing has been undertaken with regards to specialist accommodation the Use Classes Order should be differentiated for general needs housing for older people. Ultimately, evidence dictates whether this form of housing scheme when CIL is applied. should be treated differently and the outcome is that there is no reason to consider a separate CIL category for specialist elderly housing in Worthing. This work is reported within the revised Viability Assessment – Oct 2013 and Land Value Appraisal Study (Supplementary Report) Nov 2013. These help to inform the preparation of the Draft Charging Schedule.
(In addition - see the Council’s response to Representation 10)
002 Jo Hutchinson (Resident and member of Worthing Arts Officer Response Council, Twinning Association and Friends of Worthing Museum + Gallery)
Not in favour of the introduction of CIL. Builders and developers have CIL remains the Government’s preferred vehicle for collecting contributions to already invested heavily in residential properties that have failed to sell. mitigate the impacts of development and, as such, all local planning authorities Recent flooding has resulted in building delays. An additional cost will are encouraged to adopt CIL as quickly as possible. In doing so the Council must increase the price of properties, including retail. ensure that the ‘appropriate balance’ is struck so that the majority of key schemes remain viable.
003 Gareth Giles Officer Response
South Downs National Park Authority
Notes that (as set out in the PDCS) the Park Authority is the charging Noted. The South Downs National Park Authority has been, and will be, consulted authority for CIL in the identified areas and that they will set their own charge at every appropriate stage. Similarly, WBC will be consulted when the Park for the area in 2014/15. Supports the Worthing PDCS and will continue its Authority advance work on CIL for the Park area that will include areas within cooperation with the Council. In particular, further growth in Worthing will Worthing Borough. increase usage of the Park and so discussions on cross-boundary infrastructure funding will be welcome.
004 Catherine McLeod Officer Response
Environment Agency
Supportive of CIL and are satisfied it can go some way to supplement other Noted. The Environment Agency has been, and will be, consulted at every funding streams in providing new infrastructure to support local growth. appropriate stage and the Teville Stream Restoration Project is currently being Schemes for Green Infrastructure such as the Teville Stream Restoration considered as part of the Infrastructure Funding Gap Review work being Project provide opportunities to deliver ecological enhancements and progressed to inform the setting of CIL. improve access for new and existing communities. We hope to continue to work with you as you develop your CIL further.
005 Alex Medhurst Officer Response
Medhurst Chartered Surveyors
Challenge the proposed CIL charge of £30 m2 for new industrial development Full residual appraisals will be available to view on the Council’s website prior to as there is no residual appraisal or sensitivity analysis that justifies this the publication of the Draft Charging Schedule for consultation. conclusion. Unable to identify why this recommendation has been made and this should be explored before Examination. Unaware of another authority There are examples of other LPAs (e.g. Newark & Sherwood DC) that do charge who has deemed it viable in this economic climate to make a charge for CIL on industrial development. It is important to note though, that the rates industrial development and this includes a review of some much more proposed for Worthing will be informed by evidence rather than through any economically successful areas. precedent being set across the country.
Following additional testing, and as reported in the revised Viability Appraisal (Oct 2013) and Land Value Appraisal Study (Supplementary Report) Nov 2013, local evidence now indicates negative viability for industrial uses on brownfield sites.
As such, it is not proposed that a levy will be charged on industrial uses (see Draft Charging Schedule).
006 Nicki Faulkener Officer / NCS Response
Arun District Council
A fixed rate for residential uses could result in the level of affordable housing The setting of the proposed rates for Worthing has sought to achieve an delivered being reduced due to viability considerations, especially in low appropriate balance between the desirability of funding infrastructure from the levy value areas. and the potential effects of the levy on economic viability of development across
the borough. The residential viability tests used to inform the setting of the PDCS documents are not up to date as they do not make reference to the latest CIL amendment regulations or CIL Guidance 2012. proposed rates have incorporated the Council’s affordable housing requirements (proportion and mix). Retail rate of £150 sqm is quite high in comparison to the rates of other authorities in the South East especially when considering the recent lack of activity in this sector. Unclear whether the ‘roadside retail unit’ classification used in the assumptions, is the most representative of the types of units The Council’s PDCS (Jan 13) did not make reference to the CIL Guidance (Dec planned for Union Place, a new retail heart in the town. Rate may require 2013) given the timescales involved when preparing the documentation. further consideration given that VA highlights the need to be cautious due to However, it should be noted that the publication of the Dec 2012 guidance did not the lack of activity in the sector. include any changes that would have necessitated any delay to the PDCS stage. All documentation to support the Council’s Draft Charging Schedule will take into account the requirements of all relevant guidance / legislation.
The rate proposed for retail development has been informed by evidence collected at the local level and is set well within the margins of viability. The property tested was based on a roadside retail unit since this type has been more common than others in recent years and as such, it provides the most robust data. However, as suggested in this representation, this form of development does not perhaps relate particularly well to the units envisaged as part of Worthing’s proposed retail heart. As such, further testing has been undertaken and outcomes are reported within the Revised Viability Appraisal (Oct 2013) and Land Value Appraisal Study (Supplementary Report) Nov 2013.
007 Francesca Barker Officer Response
Natural England
NPPF Para 114 states “LPAs should set out a strategic approach in their CIL Regulations do not provide an exhaustive definition of infrastructure and, as Local Plans, planning positively for the creation, protection, enhancement such, it falls to each charging authority to determine what is to be deemed and management of networks of biodiversity and green infrastructure.” In the ‘infrastructure’ in its area. For Worthing, the definition is broad but would certainly absence of a CIL approach we would be concerned that the only natural include biodiversity and green infrastructure. As such, these would be considered environment enhancements would be ad hoc, and not deliver a strategic approach, and that as such the local plan may not be consistent with the when the Council reviews infrastructure needs and, as an example, the Teville NPPF. Potential infrastructure requirements may include: access to natural Stream Restoration Project is currently being considered as part of the greenspace; allotments; RoW improvements; green infrastructure projects; Infrastructure Funding Gap Review work being progressed to inform the setting of and infrastructure identified to deliver climate change mitigation and CIL. Where appropriate, projects of this type can be added to the Council’s adaptation. Regulation 123 list which will set out the infrastructure projects in the Borough that are intended to be funded wholly or partly through the levy. Furthermore, following proportionate consultation, the Council is able to bring forward a replacement Regulation 123 list at any time once the levy has come into force.
008 Ed Kemsley – Peacock & Smith Ltd (& Aspinall Verdi Ltd chartered Officer / NCS Response surveyors)
On behalf of the Morrison Supermarkets
Morrisons strongly object to the proposed CIL rates (£150 sqm) for retail development. The viability appraisals which demonstrate the viability margin and Whilst the work undertaken to date has been substantial, it makes several optimistic upon which the recommended rates are based will be published at assumptions, lacks clear rationale for these assumptions and is missing the Draft Charging Schedule stage. The appraisal inputs are based on a development appraisals to allow analysis. The presentation of separate reports suggests valuation study undertaken by HEB Chartered surveyors and cost a piecemeal approach that lacks a consistent rationale. Suggested charges will be an assessment undertaken by Gleeds. The assumptions upon which the unrealistic financial burden and will have an adverse impact on the viability of retail viability assessment are considered sound and reflective of industry development, investment and jobs. A balance hasn’t been found between infrastructure standard practice. funding and viability. The store size sample tested is not aimed to reflect any particular food CIL rate for retail of £150 psm requires review - despite the major discounting of the retail operators target unit size. It is aimed to represent a median proposed maximum rates these rates are extremely optimistic and the report and its example to allow for the range of supermarkets from local centre associated values are not evidenced. 1000sqm stores to major out of town 8-10000sqm superstores.
To address concerns: 1. The full development appraisals need to be provided; 2. All It is accepted that many brownfield sites have ‘abnormal costs’ assumptions relating costs values need to be made explicit and be clearly evidenced. 3. associated with them but these may be considered ‘site defects’ which The level of developers’ profit should be increased. 4. Recommend a revised approach need to be addressed in order to bring the site into developable state to the generic one size scheme, which doesn’t accurately reflect actual store sizes. and achieve a retail land value. As such they are discounted for the Additional costs for larger schemes need to be taken into account. purpose of the viability appraisal.
Land Value Appraisal Study All the commercial viability appraisals assume that development will be undertaken by developers and let/sold to operators. The food retail Concur that the approach of using ‘real world’ market comparable transactions * construction cost rates and sales values are based on shell Appraisals have been based on 3,000 sqm units at a rent of £150 sqm rent @ 6% specification and do not include fit out costs undertaken by the yield. No explanation has been given as to why this size (which is relatively small) contractor under separate contract or by the operator. has been selected. Most foodstore operators would have larger formats (5-6000 sqm) and would have additional costs. * The appraisals are not based purely on landowners aspiration - the Report is silent on the land value for retail uses. It is therefore not clear what benchmark land value thresholds are based on a methodology which ‘threshold’ has been incorporated into the models. Information is needed to be clear and transparent. reflects a reasonable return to the landowner as required by the NPPF. This is fully explained in the methodology section of the viability report.
Construction Cost Study The specific requirement to factor in residual S106, as required by the April 2013 CIL Guidance is being considered at Draft Charging Some allowance should be included for demolitions and abnormals particularly as Schedule stage at which point a draft Regulation 123 list will also be Worthing is substantially urban and developments are likely to occur on brownfield published. sites.* Highways works outside the boundary of the site have been excluded – this is The profit return, which reflects the reduced risk from a likely pre-sale unrealistic for most supermarket development and an allowance should be made. or pre-let is considered to represent a reasonable developers return in Construction cost figures (median - £610 sqm) appear to be very low. For example, context with the guidance contained in the NPPF. the mean BCIS figure (adjusted for the South East) for supermarkets (1,000 -7,000 sqm) is £1,110 sqm. It is unfortunate that the basis of construction costs is not clear.
CIL Viability Assessment (some comments are duplicated above*)
Agree in principle with the methodology adopted. However, residual appraisals are only appropriate so long as the underlying assumptions are robust enough to validate the results. The evidence base and appraisals should be published. Maximum rates aren’t based on evidenced information as required by guidance. Work presented lacks transparency as development appraisals aren’t provided. It is not clear which construction costs from the range provided have been used. Heb report doesn’t make recommendations as to retail land values and therefore the threshold land values adopted in the NCS appraisals are not transparent. Heb report does make reference to store size, rent and yield, but it is not clear whether these figures have been carried through to the NCS appraisals. Concur that market value benchmarking is preferred approach to land valuation. Landowners have not fully discounted the value of their land following credit crunch. In the case of retail developments, landowners are likely to hold out for the highest value and are unlikely to accept a reduction in their land value for CIL. Interrelationship of CIL and site specific S106 is critical to the commercial viability of larger projects. Preparation of Reg 123 list needs to be clearly defined and site specific planning obligations should be included in the appraisal model in order to avoid ‘double dipping’. A 17.5% return is too low. Developers profit level for retail foodstore option should be increased to 25% due to: site assembly risk; holding costs; funding costs; and planning costs and risks.
009 Ben Cheal Officer / NCS Response
Roffey Homes
Roffey Homes are a Worthing based developer of new build apartments. Generally CIL will replace some or all S106 contributions and so current standards support the principle of CIL but a key balance must be found to ensure that may not be relevant in the future. Nevertheless the future impact of contributions do not end up stifling development. residual S106 payments will be considered at Draft Charging Schedule stage. Proposed collection of CIL should be made easier for developments of apartments, where financing and cash flow requirements make the early payment It is agreed that greenfield land will be able to support higher levels of of CIL a lot harder. CIL as the existing use value is generally lower than brownfield land and It is reasonable to apply the current standards on collection of S106 contributions therefore the uplift in value generated by planning permission, from which for apartments. the potential to yield CIL is generated, is greater. This is borne out by the Conclusions with regard to residential brownfield development (particularly viability assessment results. apartments), are flawed. Main concern on Land Value report is that greenfield land (£15k/ha) has a Additional valuation evidence will be made available at Draft Charging significantly lower existing value than brownfield land (£1m - £3m/ha). How has this been reasonably factored into the VA, as the CIL rates in the table are very Schedule stage and at CIL Examination close together. The greenfield viability rates should be amended to suit this lower existing land value. If planning permission is achieved to change the use to It is acknowledged that the residential to residential category is slightly residential, then this type of land will be able to support significant CIL misleading – it should state ‘residual’ category in that this test represents contributions without materially affecting the incentivised uplift in value necessary the maximum potential land value – subtracting all development costs to tempt the existing landowner to sell. from total sales value but without factoring in any policy cost impacts CIL on existing greenfield use should be re-assessed and should be well over from development plan policy (affordable housing, S106 etc). These £500 sqm. Such an approach will support the setting of lower rates on brownfield residual values are really used just to generate the greenfield and land, where CIL at £100 sqm is more than likely to kill much of the future speculative development, particularly on apartments. brownfield benchmarks. Any application of policy cost impact will produce Market evidence should be made available. a negative viability margin and this column of results may be discounted It is abundantly clear from the evidence that residential apartment developments for the purpose of the assessment. This will be addressed at Draft of any sort will struggle with the application of CIL. Charging Schedule stage. Revenue projections are flawed as this includes a significant proportion of apartments which the evidence has shown are not viable for CIL. Additional research in response to concerns over the viability of For high rise residential developments to only realistic opportunity areas are in apartment development in Worthing will be undertaken. Further testing residential to residential locations. However, as these have the highest land will be locally specific and outcomes will be reported within the Revised values they are the least likely to support CIL. Viability Appraisal (Oct 2013) and Land Value Appraisal Study All of the high rise apartments ever built are in the ‘medium value’ areas but the (Supplementary Report) Nov 2013. medium value residential to residential viability appraisal figure is minus £1045
therefore making schemes unviable. 20% is the normal developer profit for housing development for apartments 25% is required to secure funding. The two bed apartments size in the appraisals (66sqm) should be increased to 76 sqm. VA states that “the results demonstrate that most brownfield and greenfield development is viable and can stand CIL but that CIL may threaten the viability of some forms of residential development on recycled urban land”. However, we have copied the VA results table and this clearly shows that 24 out of the 45 residential situations are unable to sustain a CIL rate of £100 per SQM, and a further 5 are on the margin of economic viability. So it is reasonable to suggest that two thirds of residential developments are likely to be unviable with this rate of CIL being charged. PDCS states that the “CIL rates are set significantly within the identified viability margins……. In addition the proposed rates are balanced and set against the context of Worthing where there is a clear and over-arching aim to deliver regeneration across the Borough”. It is the brownfield and regeneration areas that are most likely to deliver new residential housing. Half of the Core Strategy Areas of Change (key regeneration sites) with residential elements are for high rise apartments which the evidence suggests cannot sustain CIL. Other brownfield sites have high existing land values and require a reasonable uplift to tempt owners to sell. As such, we believe that how CIL is applied will materially affect development on brownfield land – which is where most development in Worthing is likely to occur. Out of the 15 ‘residential to residential’ examples in the VA, 11 are shown to be unable to support any CIL and the remaining 4 can only just support CIL, not allowing for any site abnormal costs. The £100 sqm rate would only allow a tiny uplift when viewed against industrial or greenfield areas. Taking account of CIL Guidance 2012 and supported by our evidence we believe that the charging of one flat rate will have a negative impact on development. We contend that the majority of the delivery of the Plan is unlikely to occur, because most of the development is likely to occur on brownfield land or strategic regeneration sites which are most likely to be unable to support CIL. The Borough should review their CIL rate for brownfield development land types and set it at differential rates to suit the type of development and location. The Council say that all eligible sites will be charged CIL and that in very rare circumstances will discretionary relief be given. However elsewhere they say that only developments that are shown to be viable will be charged CIL and that on
developments where charging CIL will make them unviable, a zero rate shall be applied. The wording is ambiguous and a clear statement of policy is needed. It should be made clear how to deal with sites where charging CIL will make the scheme unviable. Bearing in mind the figures that have been presented in the VA it would be more reasonable to: - State specific regeneration sites where CIL will not be charged and review this annually - On brownfield locations where the assessments show that future development is unable to support full or partial CIL, state that these developments will have CIL determined by means of a VA provided by the developer, which must then be independently checked by the District Valuer.
Note – the above is a summary of the respondent’s recommendations and conclusions – their full representation (19 pages) can be viewed separately.
010 Ziyad Thomas (The Planning Bureau) Officer / NCS Response
On behalf of the McCarthy & Stone
NPPF states that planning system should deliver housing based on current and Additional testing of specialist elderly accommodation will be undertaken future demographic trends and that the needs of different groups such as old and reported within the revised Viability Assessment (Oct 2013) and people are addressed. Land Value Appraisal Study (Supplementary Report) Nov 2013. This Worthing’s demographic profile is projected to age - particularly ‘frail’ elderly (75+). work, in turn, will inform the preparation of the Draft Charging Schedule. CS Policy 8 addresses the need to deliver a wide choice of homes to meet the needs of the community – including the needs of an aging population. Proposed CIL rate should not threaten the delivery of the Plan (e.g. CS8). Whilst the desire to keep the charging rate simple (single rate for residential) is It is considered the estimates for communal/non-saleable floorspace are understandable the broad inclusion of retirement housing within general exaggerated. Typical sheltered accommodation includes a small ‘residential’ fails to acknowledge the specific issues associated with specialist residents lounge and wardens apartment but this is not considered to accommodation. VA did not include a development scenario for sheltered housing. represent 30% of the floorspace. This is also balanced by the premium Specialist housing often provides communal areas for resident at an additional cost in sales value over standard apartments attached to this type of to developer. Typically an open market flat provides 16% non-saleable floorspace development. whereas this is 30% for sheltered housing and 40% for extra care. This places the providers of specialist accommodation at a disadvantage in land acquisition. There is a much longer sales period for retirement housing which, as a result,
typical sales and marketing fees are in excess of 6% GDV. Extra Care is defined within Class C2 use which is zero rated for CIL in Properties can only be sold on the completion of the development and the the Worthing PDCS. establishment of all communal facilities and staff. Service charge monies are subsidised and ‘Empty Property Costs’ are approximately £100k. Any apartment scheme can only be sold on completion of the The VA does not consider the build costs of flatted sheltered housing schemes. development and therefore, in this regard, there is no reason to make Specialist accommodation for the elderly is in the region of 5% more expensive to special allowance for sheltered housing. construct than apartments and 15-20% more than estate housing. An allowance should be made for payment by instalments. Suggest that part It is considered that any perceived additional construction cost for payment on first occupation would be fair and that payment is then phased sheltered housing is likely to be more than offset by the premium in sales depending on occupation levels. (It is acknowledged that instalment policy does not form part of the charging schedule or Examination). value but this will be considered through additional viability testing.
An instalment policy will be considered at Draft Charging Schedule stage. Summary It is acknowledged that certain specialist forms of elderly Given the projected need for older person’s accommodation it is vital that the potential accommodation, particularly those offering care in Class C2 use, may not shortcomings of providing a uniform rate for all residential developments are be viable and this is recognised in the PDCS. However in the same way recognised. Additional costs associated with the construction and maintenance of sheltered housing has been classified in C3 use and deemed appropriate sheltered schemes, coupled with slower sales rates, show that the financial viability of to make affordable housing contributions it should similarly be considered such developments are more finely balanced than those of houses and flats. As such, in any CIL system. a bespoke rate should be prepared for sheltered housing and specialist accommodation, or, the levy should be restricted to the saleable areas of these forms of development.
011 Lucy Seymour-Bowdery Officer Response
West Sussex County Council (Officer comments)
WSCC has been working with WBC to identify infrastructure requirements to support WBC will continue to work with the County Council and their services to development and a draft Strategic Infrastructure Package has been prepared to identify and prioritise infrastructure requirements needed to support enable the provision of County Council services to meet the needs of new development. development. This has informed the Infrastructure Funding Gap Review. The County Council will continue to support this evidence based approach. It is imperative that appropriate governance procedures are in place and finalised by the time that Worthing has CIL in place. Governance will No mechanism for prioritising infrastructure needs across different public services need to incorporate partnership working with many services and currently exists. WSCC would like to work with WBC to see a robust mechanism and providers, none more so than the County Council given the ‘two-tier’ appropriate governance arrangements established to oversee the prioritisation of system that prevails in Worthing. Discussions relating to the most
infrastructure across different services. appropriate form of governance arrangements will continue alongside the progression of Worthing’s CIL. An infrastructure funding deficit of £20m has been identified, however education infrastructure schemes are currently absent. Further work will need to be undertaken WSCC has helped to inform the Infrastructure Funding Gap Review to determine which schemes could be funded by the CIL, but it is expected that the which has sought to identify infrastructure schemes that are potentially cost of providing education infrastructure is likely to form a significant proportion of the eligible for CIL funding. The County Council will continue to be involved infrastructure required to support new development. Library infrastructure is currently in this process and the drafting of the Regulation 123 list (and any absent from the Infrastructure Funding Deficit and it is likely that additional library subsequent review of that list). infrastructure will be identified in the future. The current entry for a new library at West Durrington will need to be investigated further. Consideration should also be given to the inclusion of the costs of storage for archiving archaeological finds in connection with development proposals.
Assumption has been made that 50% of the cost of the behaviour change programme will be available through the Local Transport Plan. At this stage this is considered to be a sensible working assumption. Further work is required to determine the contribution for schemes where there are links to growth.
012 Melys Pritchett – Savills Officer / NCS Response
On behalf of Home Builders Federations and Members
Viability Appraisal Assumptions Professional fees are at 8% of construction costs.
Professional fees used in the viability appraisals of 4.5% are far too low. Consideration of the impact of residual S106 contributions is being given Concerned about the scale of S106 contributions, which will be sought alongside at Draft Charging Schedule stage in accordance with the new CIL the proposed CIL, will render the delivery of sites difficult. Greater clarity is needed Guidance, April 2013. Evidence of historic S106 contributions to guide regarding the items which will be funded through site specific S106 agreements. future allowances will also be prepared as part of this work. CIL Guidance requires WBC to prepare information on the amounts raised in recent years through S106 agreements and the extent to which targets have been met. Approximately 25% of CIL eligible residential development is projected in This information should be produced in advance of the DCS consultation. the low value sub-market area. The low value viability results The VA does not appear to include any allowance for S106 contributions. demonstrate that only apartment development is not CIL viable. From
historic delivery rates and future projections it is anticipated that Interpretation and Application of the Viability Appraisal Results apartments will make up approximately 20% of overall supply so the proposed CIL rate would only threaten 5% of the overall delivery of
The VA justifies multiple charging rates across three residential zones. However, in Worthing’s housing in the low value sub-market area. It should also be choosing to set a single rate, based upon the ‘medium’ value scenario, instead of recognised that new housing is likely to generate sales values that three rates the evidence has failed to clearly show that the single rate will not exceed historic ‘median’ sales value evidence from a low sub-market jeopardise the delivery of housing in low value areas. WBC must prove that the rate area. This will be considered as the revised Viability Assessment is proposed would not put at risk the delivery of the Plan as a whole. prepared. Site specific circumstances will vary and as such it is best practice to apply a viability ‘cushion’ when setting CIL and not set the rate up to the margin of viability. It is accepted that many sites have ‘abnormal costs’ associated with them VA states that abnormal costs have not been included within the appraisals. They should therefore be taken into account when setting CIL through the reduction of the but these may be considered ‘site defects’ which need to be addressed in proposed rate below the maximum. order to bring the site into developable state and achieve a retail land value. As such they are discounted for the purpose of the viability appraisal. CIL Regulation 122 – Double Counting The VA does build in a viability cushion and does not set rates at the full The Charging Schedule should be clear that ‘double counting’ of S106 and CIL is extent of the viability margin that has been identified. not permitted by law and the key tests of Reg 122 should be outlined within the supporting documentation. A draft Regulation 123 list will be prepared at Draft Charging Schedule It is likely that only site specific or immediately adjacent measures will continue to stage to clarify the position and future relationship between S106 and be funded by S106. CIL. Furthermore, to help explain the future approach, the Council will Request that the Draft Reg 123 list of infrastructure is provided for comment at the publish a draft Developer Contributions SPD for consideration alongside earliest opportunity. the Draft Charging Schedule.
Flexible Operation of CIL The request for supporting documentation to support the flexible Although not tested at Examination WBC should provide the supporting documentation needed to operate CIL and to make it available for input/comment. operation of CIL is noted and it is the Council’s intention is to address Documentation should include: these issues prior to CIL adoption. - guidance on how to calculate the relevant ‘chargeable development’; - guidance on liability to pay CIL; - policy for payments by instalments (suggested approach provided); - approach to payments in kind (recommended by HBF); The viability assessments will be published at Draft Charging Schedule - and guidance on relief from CIL and a policy on exceptional circumstances stage. for relief from CIL. Regular monitoring is key to ensuring that CIL does not stifle development in the right locations - WBC should have a clearly defined and open review mechanism. The VA does build in a viability cushion and does not set rates at the full extent of the viability margin that has been identified, accepting that
Land Value Benchmarking generic appraisals cannot account for all development circumstances.
VA takes an alternative approach to land value benchmarking than that commonly It is intended that the Council’s advisors, NCS, will meet with Savills to used for CIL. The application of both the Harman Guidance and the NPPF to the agree common ground on methodology and assumptions where possible benchmarking process is supported and we welcome this pragmatic approach. prior to the CIL Examination. Request access to the supporting viability appraisals that have been produced by WBC’s advisors, for the more detailed consideration of the Consortium members. Concerned that WBC has selected to charge a rate at the margins of viability, allowing no flexibility for site specific circumstances of viability or the additional costs of S106 contributions or abnormal costs. The Consortium is open to meeting WBC and its advisors to discuss the approach taken and the adjustments required to ensure that the rate proposed does not put at risk the delivery of the Plan.
013 Peter French – WYG Officer Response
On behalf of Sainsbury’s Supermarkets Ltd
The VA notes that retail development is capable of collecting CIL rates of between - See the Council’s response to representation 8. £169 and £927 and notes that there are a number of factors to warrant a lower CIL rate for retail development - including land owners expecting significant premiums in order to release sites for development. Although this is one justification, there is no evidenced calculation to show that the charge is more suitable than £100; £50 or £0. £150 per square metre is a rate which appears to have been reached arbitrarily. The rate should be fully justified and backed by evidence - Reg 6 (b) (ii).
PART 2. DRAFT CHARGING SCHEDULE APPENDICES
Appendix 2a - Draft Charging Schedule Social Media Summary
Figure 9. Facebook Launch on 6th March 2014
Figure 10. Facebook Midpoint Reminder on 27th March 2013
Figure 11. Twitter Launch
Figure 12. Twitter Newsletter Launch
Figure 13. Twitter Midpoint Reminder
Figure 14. Twitter Final Reminder
Appendix 2b: Draft Charging Schedule Deposit Points for Documents and Newsletters
Worthing Borough Council
Worthing Town Hall, Portland House, Chapel Road, 44 Richmond Road, Worthing, Worthing, West Sussex, West Sussex, BN11 1HA BN11 1HS
Libraries
Worthing Library Goring Library Richmond Road Mulberry Lane Worthing Goring-by-Sea BN11 1HD Worthing BN12 4NR
Findon Valley Library Durrington Library Lime Tree Avenue Salvington Road Findon Valley Worthing Worthing BN13 2JD BN14 0DH
Broadwater Library Dominion Road Broadwater Worthing BN14 8JL
Appendix 2c - Draft Charging Schedule Planning Policy Newsletter
Figure 15. March 2014 Newsletter (Page 1)
Figure 16. March 2014 Newsletter (Page 2)
Appendix 2d: DCS Newsletter Covering Email
Figure 17. Covering email sent to consultees for DCS Consultation
Appendix 2e: DCS Newsletter Covering Letter
Figure 18. Covering letter sent to consultees for DCS Consultation
Appendix 2f: Consultee List for DCS Consultation
Below is a list of all consultees sent newsletter and covering letter or email during the DCS consultation. Note – this list does not include individuals / residents (including those that subscribe to the Planning Policy Newsletter).
Ability Housing Association Barton Willmore
Adams Hendry Consulting Ltd Batcheller Thacker
Adur District Council Becket Resident's Association
Affinity Sutton Bellway Homes
Aid for Trade Blackrock UK Property Fund
Alliance Environment & Planning Ltd Bloomfields Ltd
Alliance Environment & Planning Ltd Blue Earth Web Solutions
AMEC Environment and Infrastructure Blue Sky Planning Ltd UK Ltd (on behalf of National Grid) Boots The Chemist Amicus Horizon Housing Group Bovis Homes Angmering Parish Council Boyer Planning Anstone Properties Ltd Brighton & Hove City Council Architectus Ltd British Gas Plc Ardington Hotel British Horse Society Arun District Council British Railways Property Board Avante Partnership British Telecom Avid Development Ltd Broadwater (Worthing) Community Aviva Association
B & S Ventures (Worthing) Limited Broadwater Residents Action Group
B&W Group Broadway Malyan
B&W Group Ltd Brunswick Hotel
Banner Homes (Wessex) Ltd Burlington Hotel
C G Spratt Colmi (UK) LLP
C.B.R.E Compass Travel
Cable & Wireless Component Moulders
Campaign For Real Ale Ltd CPRE - Campaign to Protect Rural England (Sussex) Cantium (Durrington) Ltd Crawley Borough Council Cantium Developments Crawley Borough Council Capella Holdings Crest Nicholson (South) Ltd Cellnet Cushman & Wakefield Central Ward Residents Association David Wilson Homes South East Central Worthing Residents' Association DC Planning Limited
Centrepoint Car Sales Dearden Homes Ltd
CgMs Consulting Designer Developments Ltd
Chatsworth Hotel Dialogue
Chichester District Council Dixon Searle Parnership (DSP)
Chichester District Council Dome Trust
Chloe Antiques DPDS Ltd
Chris Thomas Ltd DTZ Royal Mail's Planning Advisors
Churches Together in Worthing East Worthing Action Group
Churchill Retirement Living Ltd East Worthing Community Association
City & Provincial Properties Plc ECE Planning
Clapham Parish Council EDF Energy
Clifford Dann LLP EDF Energy
Cluttons LLP Elm Grove County First School
Cluttons LLP English Heritage
Coal Authority Environment Agency
Coast 2 Capital Local Enterprise Environment Agency Partnership
Equiniti Heron Homes
Factory Outlets Heyday Worthing Friendship Centre
Federation of Small Businesses High Salvington Residents' Association
Federation of Small Businesses High Salvington Residents' Association
Ferring Parish Council High Street Tarring Resident's Association FFT Planning Highdown Copse Residents Findon Parish Council Association Framptons Planning Consultants Highways Agency Friends of Worthing Museum and Art Hillreed Developments Limited Gallery Hillreed Homes Fusion Online Limited Hillreed Residential Developments Fusion Online Ltd Home Builders Federation Fusion Online Ltd Homes and Communities Agency Geoffrey Osborne Ltd Horizon Design Ltd GL Hearn Horsham District Council GlaxoSmithkline Hot Dog Media Ltd Gleeson Strategy Land Howard Sharp Goring Chase Resident's Association Ltd Hyde Housing / Chichester Diocesan Housing Association (CDHA) Goring Residents Association Hyde Martlet Goring Resident's Association Hyder Consulting Ltd Gracemount Developments Ltd ICENI Projects Guild Care Ilex Conservation Group H G Scadgell Ltd Ilex Conservation Group Hallam Land Management Ltd Ilex Conservation Group Hanson Capital ITPS Hargreaves Management Ltd J Sainburys PLC Heene Community Association
Jones Day MGM Assurance
Jones Lang LaSalle Michael Cook Associates Ltd
Jubilee Community Church Michael Jones & Co
Julian Dilkes Architecture Michael Spurr Consulting
JW Stratton Ltd Mid Sussex District Council
Kelsey Housing Association MONO Consultants Ltd
Kier Homes Monsoon
Kingston Parish Council Mulberry Property Investment Management Ltd Kingston Parish Council Nathaniel Lichfield & Partners Ltd Knightspur Homes Ltd National Car Parks Ltd Knightspur Homes Ltd National Federation of Gypsy Liaison Lambert Smith Hampton National Grid Plant Protection Lancashire Digital Technology Centre National Grid Property Lancing Parish Council National Grid Property Land & Brand New Homes LLP National Trust (Southern Region) Lawson Planning Partnership Ltd Natural England Leith Planning Ltd Natwest Bank Lemo Network Rail Lloyds TSB Registrars Ltd NHS South East Coast Local Nature Partnership Northbrook College Marine Management Organisation Oakfawn Properties Ltd Marine Management Organisation Orange Personal Communications Marks & Spencer Plc Osborne Homes Martin & Co Palmer Business & Media McCarthy & Stone Retirement Lifestyles Ltd Patching Parish Council
McLaren Clark Group Paul and Company
Peacock & Smith Scotia Gas Network
Persimmon Homes Secretary of State for Transport
Persimmon Homes Servite Houses
Peverel Management Services Servite Houses
Phoenix Homes Ltd Shafiques
Planning Inspectorate Showmens Guild of GB
Powergen South Coast Nursing Home
RAG South Downs National Park Authority
Raglan Housing Association Ltd South Downs National Park Authority
Rapleys LLP South Downs Society
Rapleys LLP South Downs Society
Rapleys Llp Southern
Rapleys Llp Southern Housing Group
Red Square Developments Ltd Southern Water
RF Financial Services Southern Water
Richard J Maile Town and City Southern Water Planning Sport England Robert Turley Associates Sport England Roffey Homes Sport England Roger Green Sound & Vision St Barnabas Hospice Rose Willmot Youth Centre Stagecoach (South) Sainsbury's Supermarkets Ltd Steeles of Worthing Sapphire Primary Care Developments Stewart Ross Associates Save the Dome Stiles Harold Williams Saville Jones Architects Stiles Harold Williams Saxon Weald Homes Ltd Strutt & Parker Saywell International Ltd Strutt & Parker
Sussex Enterprise Turley Associates
Sussex Enterprise UE Associates Ltd
Sussex Ornithological Society Viridian Housing
Sussex Ornithological Society Waitrose
Sussex Police Waterstock Developments Ltd
Sussex Police West Durrington Consortium
Sussex Wildlife Trust West Sussex County Council
Sussex Wildlife Trust West Sussex County Council
Sussex Wildlife Trust West Sussex Fire & Rescue Service
Sussex Wildlife Trust West Sussex Gazette
Sustrans West Sussex Learning Partnership
Tarring Residents Association West Sussex Local Access Forum
Taylor Wimpey West Sussex Local Access Forum
Terrance Higgins Trust South West Sussex Primary Care Trust
Tesco Stores Ltd West Waddy ADP
Tetlow King Planning Western Sussex Hospitals
The Coal Authority White Young & Green
The Co-Operative Society White Young Green Planning
The Elim Church Wilmington New Homes Ltd
The Guinness Trust Women's Aid
The Police and Crime Commissioner Woolfbond Planning for Sussex Workability West Sussex The Village Estate Agency Worthing & Adur Chamber Of Town & Country Planning Solutions Commerce
Transco Worthing & Southlands NHS Trust
Travelodge Worthing & Southlands NHS Trust
Turley Associates Worthing Access & Mobility Group
Worthing Arts Council Worthing Homes Limited
Worthing Astronomical Society Worthing Islamic Cultural Centre
Worthing Branch Disabilities Network Worthing Islamic Society
Worthing Churches Homeless Worthing Liberal Democrats
Worthing College Worthing Methodist Church
Worthing Community Arts Council Worthing MIND
Worthing Community Partnership Worthing Society
Worthing Council for Voluntary Service Worthing Society
Worthing Council of Community Worthing Society For The Blind Associations Worthing Squares Dance Group Worthing First Worthing Town Centre Initiative Worthing Friendship Centre Worthing Twinning Association Worthing Herald Youth Council
Appendix 2g: Press Advert in Worthing Herald for DCS Consultation
Figure 19. Scanned Image of Press Advert f (Thursday 13th March 2014)
Figure 20. Text for Worthing Press Advert