Persimmon Homes, Taylor Wimpey & Wates Developments

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From: Steven Brown Sent: 27 March 2019 15:50 To: NewLocalPlan Subject: LOCAL PLAN PROPOSED MODIFICATIONS - REPRESENTATIONS ON BEHALF OF PERSIMMON HOMES LTD (NORTH LONDON), TAYLOR WIMPEY UK LTD AND WATES DEVELOPMENTS LTD Attachments: Response Form PTW.pdf; Reps - Pers TW Wates - 27 March 2019.pdf; Princes Risborough Viability Report full 250319.pdf

Sirs

I refer to the above consultation exercise and enclose a set of representations submitted on behalf of our clients, Persimmon Homes Ltd (North London), Taylor Wimpey UK Ltd and Wates Developments, comprising as follows:

 Completed response form  Set of representations dated 27 March 2019  Viability report

I trust the above is clear and look forward to hearing from you in due course.

Yours faithfully

Steven Brown BSc Hons DipTP MRTPI

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Wycombe District Local Plan Proposed Main Modifications (February - March 2019) Representation Form

The Wycombe District Local Plan was submitted for examination in public in March 2018. Hearings were held over the summer of 2018. The independent Local Plan inspector has identified various changes that she considers may need to be made to the Plan (known as “Proposed Main Modifications”) to make the Wycombe District Local Plan a “sound” plan.

We invite your comments, also known as representations, on these Proposed Main Modifications.

 Please quote the Proposed Main Modification you are commenting on (question 1 in part B).

 Please give your comments on the Proposed Main Modification and indicate any further changes to the Proposed Main Modifications that you feel are necessary (question 2 in part B).

 Comments will only be accepted for the Proposed Main Modifications. General comments about the content of the Local Plan not related to a Proposed Main Modification will not be accepted.

The deadline for responses to be received by the Council is 11:59 pm on Wednesday 27 March 2019.

Responses can be submitted:  online at www.wycombe.gov.uk/local-plan-modifications  by email to [email protected] (an automatic email response will confirm receipt)  or sent by post to: Planning Policy Team, Wycombe District Council, Queen Victoria Road, High Wycombe, Bucks, HP11 1BB

You can submit as many comments as you would like. Please complete a separate part B for each part of the plan on which you want to comment.

This form has two parts: - Part A – Your Details - Part B – Your comment(s). Please expand the comments table as appropriate

All comments received will be passed to the independent Local Plan Inspector for consideration.

PART A

1. Personal Details 2. Agent’s Details (if applicable) * If an agent is appointed, please complete only the Title, Name and Organisation boxes below but complete the full contact details of the agent in 2. Title Mr

First Name S

Last Name Brown

Job Title Planning Consultant (where relevant)

Organisation Woolf Bond Planning (where relevant)

Address

Postcode

Telephone

Email Address

3. Client Details If you are an agent representing a specific site interest, please fill in the details below.

Lan forming part of the Princes Risborough MEA, west of Longwick Road Site Interest

Persimmon Homes Ltd (North London), Taylor Wimpey UK Ltd Client’s Name and Wates Developments Ltd

4. Please tick this box if you wish to be notified of future stages of the Wycombe  District Local Plan

5. Please tick this box if you wish to receive our electronic Weekly Planning Bulletin which gives you updates on local and national Planning matters (you will need to supply an email address to receive this)

PART B – Comments on the Proposed Main Modifications– Please copy and use a separate sheet for each representation ______

Persimmon Homes Ltd (North London), Taylor Name or Organisation: Wimpey UK Ltd and Wates Developments Ltd

1. Which of the inspector’s Proposed Main Modifications does this response relate to?

PMM27, PMM28 and PMM29

Policy PR3 – Princes Risborough Area of Comprehensive Development; and Proposed Main Modification number Policy PR4 – The Main Expansion Area Development Framework

2. Please use this box to set out your comments on the Proposed Main Modification, setting out clearly if you support or object to the Proposed Main Modification and the reasons supporting your position.

If appropriate, please set out what further change(s) to the Proposed Main Modification you consider necessary. It will be helpful if you are able to put forward your suggested revised wording of any policy or text.

See Supporting Representation

(Please continue on a separate sheet/expand box if necessary)

Persimmon Homes Ltd (North London), Taylor Name or Organisation: Wimpey UK Ltd and Wates Developments Ltd

1. Which of the inspector’s Proposed Main Modifications does this response relate to?

PMM57 Proposed Main Modification number Policy DM22 – Housing Mix

See Supporting Representation

(Please continue on a separate sheet/expand box if necessary)

Persimmon Homes Ltd (North London), Taylor Name or Organisation: Wimpey UK Ltd and Wates Developments Ltd

1. Which of the inspector’s Proposed Main Modifications does this response relate to?

PMM59 Proposed Main Modification number Policy DM24 – Affordable Housing

2. Please use this box to set out your comments on the Proposed Main Modification, setting out clearly if you support or object to the proposed Main Modification and the reasons supporting your position.

See Supporting Representation

(Please continue on a separate sheet/expand box if necessary)

Persimmon Homes Ltd (North London), Taylor Name or Organisation: Wimpey UK Ltd and Wates Developments Ltd

1. Which of the inspector’s Proposed Main Modifications does this response relate to?

PMM71

Proposed Main Modification number Policy DM40 – Internal Space Standards

Policy DM41 – Optional Technical Standards

See Supporting Representation

(Please continue on a separate sheet/expand box if necessary)

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Our Ref: SB/7806

Email:

27th March 2019

Proposed Modifications Consultation Planning Policy Team Wycombe District Council, Queen Victoria Road High Wycombe, Bucks HP11 1BB

Dear Sirs

PROPOSED MODIFICATIONS TO THE WYCOMBE DISTRICT LOCAL PLAN

Representations on behalf of Persimmon Homes Ltd (North London), Taylor Wimpey UK Ltd and Wates Developments Ltd

INTRODUCTION: POSITION STATEMENT

Background

We refer to the above consultation and write on behalf of our clients, Persimmon Homes Ltd (North London), Taylor Wimpey UK Ltd and Wates Developments (“PTW”) Ltd setting out our comments upon certain of the proposed modifications in so far as they relate to matters of viability in relation to land under their control at Land south and west of Longwick Road, Princes Risborough which forms the part of the “Main Expansion Area” (“MEA”) allocated under Policy PR3.

These representations are prepared on a collaborative basis and represent the parties’ agreed position.

Context

As the Council will recall, we prepared Hearing Statements for and also attended the Examination in relation to Matter 3 (Housing) and Matter 8 (Princes Risborough); and whilst PTW have a strong belief in the principle of the plan-led system, it is frustrating that the proposed modifications fail to reflect the concerns expressed at the hearing sessions in relation to the viability of the proposed allocations, with particular emphasis on Princes Risborough. Moreover, the suggested changes make the MEA even less viable given the reduction in the number of dwellings (meaning the cost burden of developing the MEA is to be shared by fewer dwellings) and the change to the amount of affordable housing expected to be provided (48%).

As set out in the NPPF (2012) 1 Local Plans must be capable of delivering from the point at which they are adopted. This means scrutinising the policy wording to ensure the Plans are sound and that the allocations contained therein are capable of being delivered at the point envisaged. This is particularly the case in relation to the need for the Council to collate a robust evidence base to justify the imposition of certain policies and/or their wording so as not to over burden and/or stifle sustainable and appropriate development.

Whilst PTW continues to support the principle of the allocation of the MEA and is investing significant resources into bringing land under their control forward for development as expeditiously as possible, they nevertheless require a pragmatic approach to the application both the Princes Risborough (“PR”) and Development Management (“DM”) policies.

Despite the evidence presented at the hearing sessions, including that put forward by the Home Builders Federation (“HBF”), the proposed modifications simultaneously fail to adequately address our concerns whilst also exacerbating them, to the extent that the Local Plan cannot be said to be sound in relation to the requirements at paragraph 182 of the NPPF (2012) nor can it be said to be sufficiently flexible pursuant to the approach at paragraphs 14 (second bullet) and 21.

Importantly, the provisions at paragraph 21 of the NPPF (2012) sets out a clear and unambiguous approach to the expectations set out in planning policies, stating as follows:

“Investment in business should not be over-burdened by the combined requirements of planning policy expectations. Planning policies should recognise and seek to address potential barriers to investment…”

This approach is expanded upon in the wording set out at paragraph 173, which states in full as follows:

“Pursuing sustainable development requires careful attention to viability and costs in plan-making and decision-taking. Plans should be deliverable. Therefore, the sites and the scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened. To ensure viability, the costs of any requirements likely to be applied to development, such as

1 Based upon the transitional arrangements at paragraph 214 of the NPPF(2019) the Local Plan was examined on the basis of the policies in the previous NPPF(2012) 2

requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable.” (Our emphasis)

Given the importance of this paragraph in seeking to ensure that Local Plans are deliverable, we have emphasized this by our underlining. Set against this background, and in this context, it is unfortunate that the concerns we expressed at the hearing sessions in relation to viability have seemingly gone unheeded.

The text set out at paragraph 173 of the NPPF (2012) distills our concerns with the Local plan as drafted; and the proposed modifications have failed to allay our fears.

The NPPF makes it clear that Local Plans should be deliverable and that sites should not be subject to such scale of obligations and policy burdens that would impact upon and/or threaten their viability.

PTW acknowledges that the District Council has undertaken work to ascertain the cost of some individual items as detailed in the Infrastructure Delivery Plan (“IDP”), and to some degree assessed whether some items can be delivered. However, we remain concerned as to the impact of the cumulative policy and infrastructure burdens placed upon certain of the allocations (particularly at Princes Risborough) which calls into question the evidence base in relation to inter alia, viability methodology, infrastructure costings and whether the full spectrum of obligations has been assessed together.

It is considered that a number of the generic ‘CP’ and ‘DM’ policies all have significant cost implications2 and, in turn, when assessed cumulatively, raise serious questions over the deliverability of certain of the allocated sites. Moreover, Wycombe District Council has not produced a robust evidence case to justify need and therefore conflict with national policy.

In addition to the above, it is concerning to note that the vast amount of site specific infrastructure items which have been indicatively costed and set out in the IDP (2017) total approximately £95.5 million. This does not include a high number of other items where the costs have yet to be concluded (including in relation to possible ransom payments). As a result, the infrastructure burden can be assumed to be significantly higher.

The NPPF states that where the viability of a development is called into question, Local Planning Authorities should look to be flexible in applying policy requirements wherever possible. We do not consider that policies with the Plan are flexible enough to adhere to this requirement. Most policies contain prescriptive and rigid obligations with no room for negotiation and nor do they result in viable allocations.

Objections to the Proposed Modifications

For the reasons previously expressed, and reiterated below, the MEA at Princes Risborough is simply not viable on the basis of the proposed policy burden in so far as it relates to the wording of policies DM22, DM24, DM40 and DM41.

2 For example Policy CP 12 – Climate Change, DM33 – Managing Carbon Emissions, DM34 – Delivering Green Infrastructure, DM40 – Internal Space Standards, DM41 – Optional Technical Standards.

On the basis of the foregoing, PTW maintain their objections to the soundness of the Local Plan for the following reasons:

 The Plan is not justified having regard to the overall approach to policies PR3, PR4, PR6, PR7, PR8 and PR17, such that it cannot be said to provide the most appropriate strategy when considered against the reasonable alternatives. This is particularly the case in relation to the Council’s viability assumptions at paragraph 5.3.224 of the Submission Local Plan which suggests that the required package of infrastructure works at the MEA is to be funded by the developers and that it is affordable and provides a competitive return. The policies should be revised in order to assist in bringing the MEA forward, which matters and suggested changes were addressed in our Matter 8 Statement.

 The Plan is not justified having regard to the approach to certain of the Development Management policies (DM22, DM24, DM40 and DM41) which have significant cost implications and will adversely impact upon the viability of schemes3. We addressed these points in our Statements for Matter 3 and 8. A further viability appraisal is appended to this consultation response upon the proposed modifications (see below).

 The Plan is not consistent with national policy due to the constraints imposed upon housing delivery at Princes Risborough resulting from the onerous policy requirements.

In order for the Local Plan to provide an appropriate basis for the planning of the District to 2033, PTW identify a need for a further round of hearings in order to consider the implications arising from the imposition of the aforementioned polices, including in particular the suggested imposition of a 48% affordable housing requirement – which is simply not justified by the evidence base.

(i) Amend the wording of the Princes Risborough policies to reflect viability concerns and to provide a flexible approach to ensuring delivery of housing during the plan period; and

(ii) Amend the wording of policy DM22 to provide greater flexibility in relation to the provision of self-build plots

(iii) Amend DM24 with reference to a target of 30% affordable housing based upon the total number of net additional dwellings to be provided (see accompanying Viability Report)

(iv) Delete policy DM40 on the basis that it is not justified.

(v) Amend policy DM41 in order to provide for a more flexibility approach to the imposition of the standards.

The above changes are necessary in order to satisfy the tests of soundness at paragraph 182 of the NPPF (2012).

3 For Persimmon Homes this includes land controlled by the Company at Terriers Farm, High Wycombe (Policy HW7). 4

Summary of Representations

Our comments upon the proposed modifications are accompanied by the following particulars:

 Completed Response Form

 Viability Report for Land at Princes Risborough (March 2019)

Our clients’ representations upon the proposed modifications may be summarised as relating to the following:

Proposed Modification Policy No.

PMM27 Policy PR3 – Princes Risborough Area of Comprehensive Development; and PMM28 Policy PR4 – The Main Expansion Area Development PMM29 Framework

PMM57 Policy DM22 – Housing Mix

PMM59 Policy DM24 – Affordable Housing

PMM71 Policy DM40 – Internal Space Standards

Policy DM41 – Optional Technical Standards

The content of the remainder of our representations is set out as follows:

 PMM27, PMM28 and PMM29 – page 6

 PMM57 – page 8

 PMM59 – page 11

 PMM71 – page 14

 Summary - page 19

PMM27, PMM28, PMM29

Policies PR3 and PR4 – Princes Risborough

Objection

Viability

We object to the reduction on the number of dwellings expected to come forward at the Princes Risborough MEA during the plan period.

The viability modelling submitted at Appendix C to our Matter 8 Statement was based upon an equitable financial contribution from landowners/developers based upon the 2,460 dwellings proposed at that time.

The reduction in the total number of dwellings to be delivered at the MEA from 2,460 to 2,300 will have implications in relation to the infrastructure burden to be shared amongst fewer dwellings. It is not clear whether the implication of this reduction in relation to the viability of the wider MEA has been assessed by the Council.

At the Hearings the Council set out its commitment to work positively with land owners and developers within the MEA. This commitment to joint working has since been reiterated by the Council, which approach is welcome and we look forward to working with officers on a collaborative basis in developing a high quality residential environment at Princes Risborough.

As to matters of viability, it is our understanding is that officers are currently working on the preparation of more detailed guidance which is to be informed by further modelling work. Accordingly, and pursuant to our concerns about the viability of the MEA in light of the overall policy burden, we are of the view that Inspector should hold a further hearing session(s) to consider matters. It is vital for the delivery of the Plan, and in seeking to satisfy the tests of soundness at paragraph 182 of the NPPF (2012) that the MEA is demonstrated to be viable and thus deliverable.

By holding a further hearing, this enables viability matters to be considered in a transparent manner, on the basis of up to date modelling and viability information which can then inform the final policy wording to be included in the relevant policies including, but not limited to, DM24, DM40, DM41 and the PR policies).

Approach to Planning Applications within the MEA

We note and support the qualification proposed by the inclusion of new text at paragraph 5.3.16 of the Local Plan (PMM28 refers) which confirms that the Council expects separate planning applications to be brought forward on individual land parcels within the MEA; and that such applications will need to demonstrate how they will ensure a comprehensive approach to the wider MEA.

This reflects the approach taken in the Statement of Common Ground prepared for the Local Plan Examination between Persimmon, Wates and Taylor Wimpey where paragraph 6.6 states that the MEA should be designed and brought forward on a comprehensive and non-prejudicial fashion. This represents a fundamental component part of the strategy for the town that runs through the new Local Plan.

PTW is committed to working with the Council on a collaborative basis to ensure that proposals for the development of the land parcels within the PREA should be designed in a non-prejudicial fashion, with roads up to the boundaries in order to ensure there are no ransom situations that could otherwise restrict delivery.

Primary School Provision

We are of the view that the approach advocated in relation to the proposed location of two new primary schools within the MEA is too prescriptive.

As proposed to be amended, the wording at PMM29 states that one primary school is to be located in the southern part of the Expansion Area, west of Longwick Road and one located near the local centre (page 61 of the proposed modifications document refers).

Neither of the planning applications submitted by Halsbury Homes for up to 150 and 500 homes respectively on land at Park Mill Farm, Princes Risborough provide land for a school. This is despite the Concept Plan at Figure 26 of the Submission Local Plan showing a school in that location.

However, the application submitted by Bloor Homes for up to 360 dwellings on land east of Longwick Road (LPA ref: 18/06916/OUTEA) does include land for a primary school – which is proposed to be provide on land to the south of Alscot.

On this basis, the logical location for the second primary school will be on land to the north of Alscot; which location should be reflected in the wording at PMM29 (Pg61 of the Proposed Modifications consultation document refers).

Proposed Amendment

Our principal concerns relate to the viability of the land parcels within the MEA on the basis of the viability modelling we have undertaken. In short, the approach to the MEA cannot said to be justified on the basis of the imposition of a 48% affordable housing target.

We also propose an amendment to the indicative school location as shown on the Concept Plan at Figure 26 of the Local Plan. This should refer to the school sites being provided to the north and south of Alscot.

We expand upon our concerns in response to Policy DM24 below.

**********

PMM57

Policy DM22 – Housing Mix

Objection

In so far as the Plan is intended to cover the long-term period to 2033, we are generally supportive of the flexibility afforded by part (1) of the policy. However, we strongly object to the imposition of a requirement at (2) for all proposals in excess of 100 dwellings to include at least 5% of the proposed dwelling numbers as self-build plots.

Whilst the self-build register may have 194 people who have registered an expression of interest with regard to self-build further evidence is required to be provided in order to assess the number of these that are realistically able to achieve this aspiration.

The Council needs to demonstrate and justify that there is an existing demand for such development in the Borough. Paragraph 8.69 of HEDNA states:

“In May 2012 a Self-Build Portal run by the National Custom and Self Build Association (NCaSBA) was launched. Figure 133 shows the current registrations from groups and individuals looking for land in the HMA on the ‘Need-a-Plot’ section of the portal. Whilst there is clearly some interest in self-build across the area (around twenty groups or individuals in July 2016), this represents only a very limited number of people and an exceptionally small proportion of the overall housing need identified each year.”

The above indicates that the self-build demand is particularly limited.

Consideration also needs to be given to the effect of self-build housing on the deliverability of strategic sites including ability to subsidise obligations and infrastructure. In addition, there are also practical issues with consistency of design (which may contrast with WDC’s approach to seeking a high standard of design in all new development) and logistics with multiple trades wanting to be on site at the same time for each individual plot.

Where plots are not sold it is important that the Council’s policy is clear as to when these revert to the developer. At present this policy makes no such commitment.

Overall, we do not consider that the requirement for developments of 100+ dwellings to provide self-build plots to be either justified or consistent with the approach set out in the PPG.

The PPG (at ID 57-025-201760728) helpfully sets out the approach to be applied in assessing options for the provision of self-build homes:

“How can relevant authorities increase the number of planning permissions which are suitable for self-build and custom housebuilding?

Relevant authorities should consider how they can best support self-build and custom housebuilding in their area. This could include:

 developing policies in their Local Plan for self-build and custom housebuilding4;

 using their own land if available and suitable for self-build and custom housebuilding and marketing it to those on the register;

 engaging with landowners who own sites that are suitable for housing and encouraging them to consider self-build and custom housebuilding and facilitating access to those on the register where the landowner is interested; and

 working with custom build developers to maximise opportunities for self-build and custom housebuilding.”

There is no suggestion that Councils should use prescriptive policies that require developers to provide plots for self-build.

Moreover, and as to the evidence base:

(i) Paragraph 8.69 of the HEDNA confirms that the demand for self-build plots is particularly small; and

(ii) Para 9.12 of the Housing Topic Paper (TP3) merely establishes that there are 194 expressions of interest.

This does not translate into the 5% policy requirement.

Given the fragility of the delivery trajectory for the provision of new dwellings across the plan period, the delivery assumptions for the identified sites could be further impacted by the imposition of a requirement for 5% self–build homes.

The policy should be revised in order to require a smaller quantum of dwelling plots for sale to self-builders. The policy should also provide for greater clarity as to how the policy is to work in practice.

Proposed Amendment

We suggest that the policy should state that if a plot remains unsold within 6 months of it being offered on the open market it should revert back to the developer to be delivered as part of the overall scheme.

The policy should be revised in order to require a smaller quantum of dwelling plots for sale to self-builders, reflecting the evidence base. The policy should also provide for greater clarity as to how the policy is to work in practice.

4 This does not excuse the requirement for the policy to be evidence-based 9

We suggest the following wording:

i. To support prospective self-builders, on sites of more than 200 dwellings, developers will be encouraged to supply 1% of dwelling plots for sale to self- builders, having regard to the need identified on the Council’s Self-Build and Custom Build Register.

ii. Planning permissions should include conditions requiring self-build developments to be completed within 3 years of a self-builder purchasing a plot.

iii. Where plots have been made available and marketed appropriately for at least 6 months and have not sold out, the plot(s) will revert to the developer.

**********

PMM59

Policy DM24 – Affordable Housing

Objection

General

Whilst we support the change to the means of calculating the amount of affordable housing to be provided as part of development schemes on the basis of the total number of net additional dwellings to be provided on qualifying sites, we object to the imposition of a 48% affordable housing target.

It is an arbitrary requirement and contradicts the Council’s own evidence which states that a figure of 23%5 is justified.

The Council suggests that the justification for such a target is articulated in the Viability Assessment Briefing Note prepared by Adams Integra for Wycombe District Council (Action Point 3.10) (August 2018) and which is accessible via the Examination pages of the Council’s website6. We have obtained and reviewed the document and cannot see where it is demonstrated that the assessment has taken account of all viability matters.

PMM59 cannot be said to be sound in relation to the requirements at paragraph 182 of the NPPF (2012) in so far as it is not justified, effective or consistent with national policy. The should be expected to undertake further testing of the imposition of 48% affordable housing against updated development costs, including in relation to the overall policy burden.

Our Position

Our position is summarised as follows:

1. The imposition of a 48% affordable housing target is not justified by the evidence base.

2. The imposition of a 48% affordable housing requirement is demonstrably unviable.

3. As a matter of principle, converting an affordable housing requirement based upon 40% GIA equates to approximately 44% not the 48% suggested by the Council.

4. As demonstrated in the accompanying Viability Report, the imposition of a 30% affordable housing target to be met at Princes Risborough would be viable and would ensure delivery.

The detailed viability modelling submitted at Appendix C to our Matter 8 Statement set out our position in relation to our viability concerns at the Princes Risborough MEA. PTW has since re-worked the cost burden along with the Council’s imposition of a 48%

5 As confirmed at paragraph 14.2 of the Council’s Matter 3 Statement and as set out at paragraph 5.4 of the Housing Topic Paper (TP2), based upon the OAN figures in the HEDNA Addendum (September 2017) the affordable housing need figure for Wycombe District is 23%. 6 https://www.wycombe.gov.uk/uploads/public/documents/Planning/New-local-plan/Local-plan- examination-2018/EXAM2-Action-Point-3.10-Wycombe-DC-viability-assessment-briefing-note.pdf

11 affordable housing target. Details are set out in the accompanying Viability Report (March 2019).

How the Council seek to demonstrate a requirement for 48% by dwelling numbers has not yet been fully explained. There is no clear paper trail to demonstrate how the Council arrived at the 48% figure. Regardless, and in any event, the imposition of such a requirement is not viable for the reasons set out in the accompanying Viability Report.

Commentary

Policy CP4 makes provision for a total of 10,925 dwellings to be met within Wycombe District during the Plan period, relying upon Aylesbury Vale District Council (“AVDC”) to accommodate unmet housing needs totalling 2,275 dwellings.

As confirmed at paragraph 5.14 of the Housing Topic Paper, a percentage of the 2,275 dwellings to be met within AVDC will be affordable and will thus contribute to meeting Wycombe’s affordable need.

Applying AVDC’s 25% affordable housing requirement to the 2,275 dwellings to be met within AVDC would provide for 569 dwellings.

If this quantum were subtracted from the total 3,100 affordable housing need for Wycombe, the residual to be met would be 2,531 affordable dwellings (3,100 – 569).

The anticipated supply of affordable housing is explained at pages 59 to 60 and Appendix 10 of the HELAA and totals 3,065 affordable dwellings which is 534 dwellings in excess of the residual affordable housing requirement to be met within Wycombe District.

Paragraph 154 on page 59 states that the housing supply has been assessed in order to estimate approximately how much affordable housing may come forward during the plan period. The supply figures are summarised in Table 25 on Pg59, whilst Appendix 10 provides the detailed site schedules.

In carrying out the detailed site assessment in Appendix 10, the Council applies an indicative % to the qualifying sites. Importantly, this is not based on bed spaces but rather the overall number of dwellings e.g. for the Princes Risborough Expansion Area Appendix 10 shows a figure of 664.8 affordable dwellings at 40%7.

As per the worked example at paragraph 3.11 of the Council’s Princes Risborough Expansion Viability Report (Sept 2017), the requirement to provide 40% of the total floorspace as affordable equates to an affordable housing requirement of 45% of the total number of dwellings. Whilst it is an onerous and disproportionate requirement, and one that fails to take account of all viability considerations at paragraph 173 of the NPPF (2012) (see above) it further demonstrates the arbitrary approach adopted by the Council in relation to their suggestion that 40% of floorspace translates to a requirement for 48% of the total number of dwellings. Their own evidence proves that not to be the case.

The detailed viability modelling submitted in support of our Matter 8 Statement (Appendix C to that Statement refers).

7 Based upon a total supply of 1,662 dwellings within the plan period. 12

Details relating to the viability modelling undertaken by Persimmon Homes are set out at paragraphs 2.27 to 2.53 of our Matter 8 Statement and conclude that the scheme is not viable at the level of affordable housing that was sought in the Submission Local Plan (40% of bed spaces).

PTW has since re-worked the cost burden derived from the application of the space standards set out in Policy DM40 and DM41 along with the Council’s imposition of a 48% affordable housing target. Details are set out in the accompanying Viability Report (March 2019).

The Viability Report prepared on behalf of PTW concludes as follows:

 With a requirement to deliver the Princes Risborough allocation in accordance with the draft local plan policies the scheme will only deliver £35,000 per gross acre as a return to the owners. This not an acceptable return to the land owners and falls way short of the comparable evidence on benchmark land values used in adjoining local authority areas.

 The viability scenarios presented to the Examination provide clear, unambiguous and demonstrable evidence that the imposition of a 48% affordable housing requirement cannot be said to be justified and will result in owners and developers being unable to bring sites forward for development.

 Informed by the foregoing, the imposition of a 30% affordable housing requirement (on the basis of net additional dwelling numbers (on qualifying sites)) would represent a viable and deliverable target. This would accord with the guidance set out in the NPPF and supporting Planning Practice Guidance.

The Viability Report provides clear, unambiguous and demonstrable evidence that the imposition of a 48% affordable housing target is simply not viable and cannot be said to be justified. It will simply result in developers being unable to bring sites forward for development.

However, and as demonstrated, the imposition of a 30% affordable housing target at Princes Risborough would be viable. In addition, this would also ensure the delivery of the requisite amount of affordable dwellings given the 23% figure identified in the HEDNA and the fact that an element of Wycombe’s affordable housing need will be met by allocations in AVDC.

Proposed Amendment

On the basis of the foregoing, informed by our submissions at the Local Plan hearing sessions, we are of the view that the affordable housing requirement to be met at Princes Risborough should be set at a maximum of 30%. This level of provision has been arrived at following a thorough viability appraisal; and which shows the Council’s viability modeling to be erroneous in relation to the various assumptions that have been applied.

The 30% affordable housing target to be met at Princes Risborough will ensure the MEA remains a deliverable allocation.

In order to satisfy the tests of soundness at paragraph 182 of the NPPF (2012), Policy DM24 should be amended in order to include reference to a specific target requirement for the provision of 30% affordable housing at the Princes Risborough MEA.

**********

PMM71

Policy DM40 – Internal Space Standards; and Policy DM41 – Optional Technical Standards

Policy DM40 – Internal Space Standards: Objection

The PPG (ID 56-002-20160519 refers) sets out the tests to be applied in assessing whether there is a need and justification for a policy requiring the application of the national space standards, stating as follows:

What optional technical housing standards can local planning authorities set?

Local planning authorities have the option to set additional technical requirements exceeding the minimum standards required by Building Regulations in respect of access and water, and an optional nationally described space standard. Local planning authorities will need to gather evidence to determine whether there is a need for additional standards in their area, and justify setting appropriate policies in their Local Plans.

Mandatory Building Regulations covering the physical security of new dwellings came into force on 1 October 2015 and planning authorities should no longer seek to impose any additional requirements for security of individual dwellings through plan policies, though designing for security of site layout remains a valid planning consideration.

Evident form the above is that the national standards are not mandatory. Importantly, they need to be justified by an appropriate evidence base.

1. The PPG (ID: 56-020-20150327) adds:

How should local planning authorities establish a need for internal space standards?

Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas:

 need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.

 viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.

 timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.

In relation to the adopted development plan for Wycombe District, the Core Strategy does not contain any minimum space standards and the Council has produced no evidence that this has given rise to poor standards of housing accommodation, nor – contrary to the PPG - has it evidenced a particular need.

The justification for the imposition of the internal space standards was considered in the Inspector’s Report on the Examination of the Canterbury City Council Local Plan published in June 2017.

Paragraph 232 of that Report states as follows:

“The Council’s suggested modifications to Policy DBE7 and Table D3 would require the application of the nationally described residential internal space standards. These would replace the local standards in the submission LP. The Council’s case is based largely on national evidence. However, the Government has decided that the national standards should not be mandatory. The Council indicates that currently most planning applications conform to these standards in any event. While the evidence base should be proportionate, the specific requirement in the WMs to establish a clearly evidenced need in order to apply the optional standards has not been met. As such, the deletion of the standards in MM127, MM128 and MM129 is necessary for consistency with national policy.”

The Inspector’s conclusion was translated into the final policy wording in the adopted Canterbury Local Plan (July 2017) and an extract is set out below.

We endorse this approach as a pragmatic solution to planning for suitably sized accommodation to meet all housing needs during the plan period, without applying a prescribed standard that is not supported by local evidence of need.

The Canterbury approach allows flexibility and is being consistent with the Framework.

A ‘one size fits all’ policy with stated thresholds is unlikely to be effective for all schemes and areas. This position is echoed in The Housing White Paper (March 2017) which states that the Government is concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households.

The portfolio of house types offered by Persimmon Homes includes a range of smaller dwellings in order to make home ownership more affordable to the market.

Appendix 3 to our Matter 3 Statement illustrates that by adopting the prescriptive standards, the cost of starter homes increases significantly. This has the adverse effect of starter homes driving unaffordability rather than addressing it and helping people to get their first home.

Using the figures contained in Appendix 3 to our Matter 3 Statement, the application of the Nationally Described Space Standards (“NDSS”) would increase the sales value of a 2-bed 4 person home of 60sqm from £336,000 in Princes Risborough (based upon a sales price of £5,600psqm) to £442,000 on the basis of a 79sqm property (the minimum size for a 2-bed 4 person dwelling). Self-evidently, this reduces the type of property than can be offered on the open market.

As evidenced in this example, imposition of the NDSS would simply serve to drive unaffordability.

Proposed Amendment

We endorse the approach adopted in the Canterbury Local Plan which provides for flexibility, without the mandatory imposition of the NDDS.

**********

Policy DM41 – Optional Technical Standards: Objection

Objection

There is no proposed modification to this policy, which is a cause for concern given the compelling evidence that was presented on this matter at the hearing.

The starting position is the approach set out in the PPG (ID 56-007-20150327 refers) which indicates that it is for the LPA to set out how it intends to demonstrate the need for such dwellings. This is subject to a number of assessment criteria and states as follows:

“What evidence should local planning authorities use to demonstrate a need to set higher accessibility, adaptability and wheelchair housing standards?

Based on their housing needs assessment and other available datasets it will be for local planning authorities to set out how they intend to approach demonstrating the need for Requirement M4(2) (accessible and adaptable dwellings), and/or M4(3) (wheelchair user dwellings), of the Building Regulations. There is a wide range of published official statistics and factors which local planning authorities can consider and take into account, including:

 the likely future need for housing for older and disabled people (including wheelchair user dwellings).  size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes, sheltered homes or care homes).  the accessibility and adaptability of existing housing stock.  how needs vary across different housing tenures.  the overall impact on viability.

To assist local planning authorities in appraising this data the government has produced a summary data sheet. This sets out in one place useful data and sources of further information which planning authorities can draw from to inform their assessments. It will reduce the time needed for undertaking the assessment and thereby avoid replicating some elements of the work.”

Again, the standards are not mandatory and it is wholly inappropriate in our view to suggest that all new homes are to be built to M4(2) (accessible and adaptable dwellings), and/or M4(3) (wheelchair user dwellings).

Importantly, the SHMA does not point to a need for 100% of dwellings to be built to tis standard. As such, the approach cannot be said to be justified.

In relation to M4(2), the difficulty with the imposition of wording requiring all new dwellings to achieve the standard is firstly the increase footprint and build cost for each dwelling; and secondly the costs associated with step free access to all dwellings, including flatted blocks.

Unless step-free access can be provided to each flat, the upper floors would not comply with M4(2). Provision of a lift in these blocks would be the only theoretical way we can see to satisfy the standard for the upper floor flats. However, lifts are expensive and there needs to be several flats served by each lift in order to make its maintenance viable. For small blocks the service charges which would end up being imposed on occupants to support a lift would be punitive. Flatted blocks large enough to spread the cost of lifts may not be appropriate for all sites, including Princes Risborough.

Paragraph 010 ID: 56-010-20150327 of the PPG deals with this consideration and makes it clear that “in setting policies requiring M4(2) and M4(3) compliant dwellings, local planning authorities will need to assess whether this has an impact on non-lift serviced multi-storey development in their local housing mix. Where step-free access in this type of development is not viable, neither of the Optional Requirements in Part M should be applied.”

Overall, we are of the view that the lack of flexibility in terms of the policy wording will adversely impact upon site delivery.

Proposed Amendment

The policy wording should be reworded along the following lines:

“The Council will therefore encourage all new homes to be built to the higher optional Building Regulations standard M4 (2) Accessible and Adaptable Dwellings and will apply it as a planning condition to development where viability is not compromised. The requirement to provide affordable dwellings constructed to Building Regulation Standard M4(3) Category 3: Wheelchair Accessible Standards, will be dependent on identified need at the time a planning application is submitted and the suitability of the site”

**********

SUMMARY

We trust the above comments are of assistance in relation to the amendments necessary in order to satisfy the tests of soundness set out at paragraph 182 of the NPPF (2012).

For the reasons stated, we are of the view that there is a need for the Inspector to explore the obligations and policy burden set out in the Plan in relation to scheme viability and therefore delivery of the Plan as a whole, which can only sensibly and rationally take place in the form of a further hearing session(s). This is particularly the case in the context of the suggested imposition of 48% affordable housing (DM24) along with the implications arising from policies DM40 and DM41.

We welcome the opportunity to continue dialogue with the Council in relation to the ongoing approach to the development of the Land south and west of Longwick Road, Princes Risborough, as well as in relation to the form of suggested modifications to the development management policies generally.

We also welcome the opportunity to explore the aforementioned matters including the deliverability of the allocations at Princes Risborough, at a resumed hearing session which will enable the Inspector to fully explore the implications arising from the proposed policy burden.

Yours faithfully,

Steven Brown BSc Hons DipTP MRTPI

Enc

P E R S I M M O N H OMES

Viability Report For Land at Princes Risborough

On behalf of Persimmon Homes, Taylor Wimpey and Wates Developments Ltd

Viability Report Details

Date of Report: 25 March 2019

Purpose of Report: Viability Report to consider 48% affordable

Report Prepared by: David Huggett of Persimmon Homes Regional Strategic Land Director & Chartered Town Planner Persimmon House, Vanwall Business Park, 2 Vanwall Business Road, Maidenhead, SL6 4UB

Telephone: 01628 502800 Email: [email protected]

HEAD OFFICE HEAD OFFICE HEAD OFFICE WATES PERSIMMON HOMES T W

Persimmon Homes North London is a trading division of Persimmon Homes Limited Registered in England No. 4108747. A subsidiary of Persimmon plc

CONTENTS

1.0 Introduction 2.0 Proposed Policy Modification 3.0 Proposed Selling Prices 4.0 Construction Costs 5.0 Infrastructure Costs 6.0 Section 106 Costs and CIL 7.0 Landowners Expectations 8.0 Persimmon/TaylorWimpey/Wates requested policy amendments 9.0 Conclusion

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APPENDICES

A Greenfield Appraisal for 48% affordable by dwelling numbers with NDSS and M4 (2) / M4 (3) B Greenfield Appraisal for 30% affordable by dwelling numbers with M4 (2) on affordable only C Housing Mix Calculation

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1.0 Introduction

1.1 This viability report has been prepared by Persimmon Homes, Taylor Wimpey and Wates Developments Ltd as a response Wycombe District Council’s consultation upon the Proposed Main Modifications to the Wycombe District Local Plan (submission version).

1.2 The viability has been prepared to assess the financial consequence of Action Point 3.10 where the Inspector has asked the local planning authority to redraft Policy DM24 with reference to dwelling numbers and not gross internal floor space and to set out in a note what effect this change would have on delivery, percentages and existing evidence.

1.3 This document seeks to ensure that the policy modifications proposed by Wycombe Council are set at a level that is realistic and that will not undermine deliverability of the Major Expansion Area (“MEA”) at Princes Risborough.

1.4 This viability is an update of the models presented to the Examination in August 2018 that were included at Appendix C to our Matter 8 Statement.

1.5 Our viability assessment concludes that the imposition of a 48% affordable housing target is not supported by the evidence and nor would it be viable. This conclusion equally applies to the delivery of the MEA at Princes Risborough and in relation to the delivery of ‘other’ housing allocations controlled by the parties1.

2.0 Proposed Modification

2.1 The Council has set out in Proposed Main Modification 59 its amendments to policy DM24 on Affordable Housing.

2.2 The Council has recommended that it will require on all developments for 10 or more dwellings or more than 1,000 sqm of residential floor space to provide on site housing of at least 48% of the total number of units on sites that were greenfield or were last used for Class B business or similar sui generis employment generating uses or 35% of the total number of units on all other sites.

2.3 The justification given is that the previous draft policy requirement for affordable housing to be delivered at 40% of gross internal floor area translates to 48% by dwelling numbers.

2.4 A table using information from the Buckinghamshire HEDNA Addendum Report dated September 2017 is attached at Appendix C and an analysis of the required mix of private and affordable dwellings concludes that the relevant proportion to be adopted using HEDNA evidence would be 44% by dwelling numbers. How the Council seek to demonstrate a requirement for 48% by dwelling numbers has not yet been fully explained.

2.5 The mix of houses incorporated within the attached viability appraisal follows the details set out in the Buckinghamshire HEDNA dated 2016. This identifies the housing need to be for market

1 For Persimmon Homes, this includes land controlled by the Company at Terriers Farm, High Wycombe (Policy HW7).

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dwellings with 3 or 4 bedrooms and for affordable homes the report identifies that the greatest need is for smaller 2 and 3 bed houses.

2.6 The mix of dwellings in the attached viabiltiy is:

Private Dwelling Mix Alnwick 2 bed terrace 12.69% - HEDNA 12.78% - Wycombe Viability 15% Hanbury 3 bed semi / terrace 30.40% - HEDNA 30.4% - Wycombe Viability 24% Chedworth 4 bed detached 20.50% - HEDNA 21.06% - Wycombe Viability 26% Clayton 3 bed detached 21.30% - HEDNA 21.8% - Wycombe Viability 24% Corfe 5 bed detached 6.80% - HEDNA 6.89% - Wycombe Viability 0% Flat 1 bed 4.56% - HEDNA 3.64% - Wycombe Viability 4% Flat 2 bed 3.65% - HEDNA 3.51% - Wycombe Viability 7% Total 100%

Affordable Dwelling Mix Flat 1 bed 12% - HEDNA 5.98% - Wycombe Proposed Modification 12% 2 bed 43% - HEDNA 38.58% - Wycombe Proposed Modification 43% 3 bed 35% - HEDNA 43.16% - Wycombe Proposed Modification 35% 4 bed 10% - HEDNA 5.58% - Wycombe Proposed Modification 10% Total 100%

3.0 Proposed Selling Prices

3.1 The dwellings within the viability are built to achieve the Nationally Described Space Standards (NDSS) as required by policy DM40 and are based on the selling prices used in the August 2018 models.

4.0 Construction Costs

4.1 This viability is based on the information presented to the Examination in August 2018. House construction costs are taken from the BCIS Average Building Prices (1st Quarter 2015 Estimates) which have been indexed to May 2017. The costs being used are: Flats (£131 per sq ft), Terraced 2 storey houses (£113 per sq ft) and detached houses (£120 per sq ft).

4.2 An allowance of £20,000 per dwelling has been included for External Works which includes site clearance and the construction of estate roads, on site foul and surface water drainage systems and the provision of normal connection fees for services including gas, water, electricity and fibre.

4.3 Costs have also been added for providing the enhanced accessibility requirements to deliver M4 (2) and M4 (3) as set out in the local plan policy DM41. The costs for each dwelling type have been extracted from the Councils Viability Report dated March 2017.

4.4 An allowance of £6,000 has been made for provision of garages on 3, 4 and 5 bed private dwellings and the cost has been taken from the Councils Viability Report dated March 2017.

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4.5 The attached viability assessment is based on the assumption that NDSS sized house types are used in accordance with local plan draft policy DM40.

5.0 Infrastructure Costs

5.1 The cost assumptions for providing the necessary infrastructure to serve the proposed allocation is the same as that presented to the Examination in August 2018. This includes the cost of providing the larger non frontage roads, roundabouts and other internal highway features, surface and foul drainage including pump stations, balancing ponds and on site attenuation, landscaping, Green Infrastructure, play areas and public open space, level changes, capping layers, and the servicing of the primary school site. Based on experience of similar projects undertaken by Persimmon and Taylor Wimpey we have used an allowance of £375,000 per net developable acre.

5.2 This generates a total allowance of £59,000,000 to build out the allocation.

6.0 Section 106 Costs and CIL

6.1 The costs for the S106 and for CIL are the same as those presented to the Examination in August 2018. Within the appraisal an allowance of £84,865,000 has been made to cover the anticipated S106 contributions which have been set out in Appendix 4 of the Princes Risborough Expansion Area Summary – Infrastructure Delivery Plan dated September 2017. The details are:

Railway £3,465,000 Footbridge Extension £2,000,000 Relief Road £49,000,000 Bus Subsidy £1,100,000 Footway / Cycleway £3,000,000 Town Centre Traffic Management £5,000,000 Primary Education £14,300,000 Community Facilities £1,000,000 Open Space £6,000,000

Third Party Land Acquisition £4,395,000 Part 1 Compensation Claims £1,736,000

6.2 In addition to the costs for delivering S106 obligations an allowance has been made for CIL at a rate of £181.47 per sq metre.

7.0 Landowners Expectations

7.1 This report which has been prepared to demonstrate the financial impact which Proposed Modification 59 will have on the viability of the allocation concludes that a policy compliant scheme for 2,357 dwelling which delivers 48% affordable housing will deliver a EUV+ of £34,921 per gross

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acre. The assumptions are based on a proposed development which complies with policies DM24, DM40 and DM41.

7.2 In August 2018 the viability prepared in appendix B of my report concluded that the scheme would deliver a EUV+ of £60,911 per gross acre.

7.3 The impact of Proposed Modification 59 is to reduce the EUV+ by £25,990 per gross acre which is a reduction of 43%. The change in policy to deliver 48% affordable by dwelling numbers creates an additional cost burden where no reasonable landowner who owns land in Princes Risborough would be persuaded to sell.

7.4 Since the close of the Hearings Persimmon Homes, Taylor Wimpey and Wates Developments have attempted to begin a dialogue with Wycombe Council to consider the impact of policy on the viability of the allocation but to date no meeting or discussion has been forthcoming. The consequence is that we continue to challenge many of the basic assumptions through this further consultation.

7.5 The evidence presented to the Examination in August 2018 recommended that a benchmark land value for land in Princes Risborough should be about £200,000 per gross acre.

7.6 This was based on the comparable evidence from authorities in Stevenage (£175,000 per gross acre), the 8 Hertfordshire local authorities as set out by Lambert Smith Hampton in its 2012 report (£194,000 per gross acre) and Aylesbury Vale (between £170,000 and £208,000 per gross acre).

8.0 Persimmon / Taylor Wimpey / Wates requested policy amendments

8.1 The policy amendment being suggested by Wycombe Council to vary policy DM24 to deliver 48% affordable by dwelling numbers has a negative impact on the benchmark land value. The amendment whilst increasing the number of affordable dwellings from 1,042 to 1,136 decreases the benchmark land value to £12,431,000 which equates to a value per gross acre of £34,921.

8.2 The amendment to policy DM24 still does not consider the conflict with the HEDNA which confirms that affordable housing should be delivered at 23%.

8.3 A viability assessment was prepared for the Examination which sought to understand the impact that a reduction in the level of affordable housing will have on EUV+. A viability which delivers affordable housing at 35% by dwelling numbers provides a land value of £196,591 per gross acre. This viability also allows the affordable dwellings to be constructed to achieve M4 (2) which is part of the Councils enhanced accessibility standards set out in policy DM41. Constructing 30% of affordable dwellings which equates to 247 dwellings to a full wheelchair accessible standard appears illogical when no demand has been indentified.

8.4 A final viability assessment was prepared to show the impact on EUV+ when the affordable element is further reduced to 30% by dwelling numbers and delivered to M4 (2). The effect is to increase EUV+ to £227,888 per gross acre.

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9.0 Conclusion

9.1 The attached viability prepared by Taylor Wimpey, Persimmon and Wates Developments has concluded that the Proposed Modifications being requested by Wycombe Council to policy DM24 has a negative impact on viability, to the extent it is unviable.

9.2 With a requirement to deliver the Princes Risborough allocation in accordance with the draft local plan policies the scheme will only deliver £35,000 per gross acre as a return to the owners. This not an acceptable return to the land owners and falls way short of the comparable evidence on benchmark land values used in adjoining local authority areas.

9.3 The viability scenarios presented to the Examination provide clear, unambiguous and demonstrable evidence that the imposition of a 48% affordable housing requirement cannot be said to be justified and will result in owners and developers being unable to bring sites forward for development.

9.4 Informed by the foregoing, the imposition of a 30% affordable housing requirement (on the basis of net additional dwelling numbers (on qualifying sites)) would represent a viable and deliverable target. This would accord with the guidance set out in the NPPF and supporting Planning Practice Guidance.

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"Technical housing standards – nationally described space standard" Buckinghamshire HEDNA Addendum (gov.uk) ref. in Policy Report September 2017 (table 123) DM40 Market Housing HEDNA split HEDNA split HEDNA split Number of Min. GIA (m2) Total GIA based @ 40% actual (no. of units) of full Mkt @76.52%1 persons (p) on HEDNA (m2) affordable nos. (%) Mkt (%) (D*G) (m2) (cals at bottom) 1 bed flat 300 3.0% 2.3% 1p 39 89 67 2 2+ bed flat 350 3.5% 2.7% 3p 61 162 123 2 2 bed house 760 7.5% 5.8% 4p 70 403 305 4 3 bed house 5,770 57.1% 43.7% 4p 84 3,672 2,781 33 4 bed house 2,330 23.1% 17.7% 5p 97 1,712 1,297 13 5+ bed house 590 5.8% 4.5% 6p 110 492 372 3 total 10,100 100.0% 76.5% 6,530 4,946 58 1 based on 10,100 market units as a percentage of all units (13,200)

Affordable Rent HEDNA HEDNA split HEDNA split Number of Min. GIA (m2) Total GIA based @ 40% actual split (no. of of full Mkt @19.69%2 persons (p) on HEDNA (m2) affordable nos. units) (%) Mkt (%) (D*G) (m2)

1 bed flat 330 13% 2.50% 1p 39 97 188 5 2+ bed flat 420 16% 3.18% 3p 61 194 373 6 2 bed house 520 20% 3.94% 3p 70 276 531 8 3 bed house 950 37% 7.19% 4p 84 604 1,163 14 4+ bed house 380 15% 2.88% 5p 97 279 537 6 total 2,600 100% 19.69% 1,451 2,792 38 2 based on 2,600 affordable rent units as a percentage of all units (13,200)

Intermediate HEDNA HEDNA split HEDNA split Number of Min. GIA (m2) Total GIA based @ 40% actual split (no. of of full Mkt @0.037%3 persons (p) on HEDNA (m2) affordable nos. units) (%) Mkt (%) (D*G) (m2)

1 bed flat 60 12% 0.44% 1p 39 17 33 1 2+ bed flat 110 22% 0.81% 3p 61 50 96 2 2 bed house 120 24% 0.89% 3p 70 62 120 2 3 bed house 180 36% 1.33% 4p 84 112 215 3 4+ bed house 30 6% 0.22% 5p 97 22 41 0 total 500 100% 3.70% 263 505 7 3 based on 500 intermediate units as a percentage of all units (13,200)

Summary Total GIA based @ 40% actual on HEDNA (m2) affordable nos. (D*G) (m2) affordable combined 3,100 1,713 685 45 whole site 13,200 8,243 3,297 103 affordable percentage based on no. of units 43.7% ABNORMAL COSTS BUILD UP Date 08-Aug-18

SITE NAME Princes Risborough Acres 158 56

Description Total Cost

Infrastructure Costs 158 acres x £375,000 per acre £59,250,000 Abnormal Foundations Underbuild Retaining Walls Screen Walls Enhanced External Materials Off Site Surface Water Drainage Systems Off Site Foul Water Drainage Systems Surface Water Attenuation - balancing ponds Open Space - LAPS , LEAPS Landscaping Non Frontage Estate Roads & Sewers Private Drives Ecology mitigation and aboricultural works Service diversion and reinforcement

S 106 Costs

Railway £3,465,000 Footbridge Extension £2,000,000 Relief Road £49,000,000 Bus Subsidy £1,100,000 Footway / Cycleway £3,000,000 Traffic Deterent Measures £5,000,000 Primary Education £14,300,000 Community Facilities £1,000,000 Open Space £6,000,000

Third Party Land Acquisition £4,395,000 Part 1 Compensation Claims £1,736,000

CIL Payment £181.47 x 140,791m2 £25,549,404

£175,795,404 1,108,700 per ac PERSIMMON HOMES WEST YORKSHIRE - COST TRANSACTION REPORT

DESCRIPTION DATE AMOUNT (£)

Option Fee

Total £0 Sellers Legal and Agent Fees

Bungalow SDLT

Total £0 Planning Application

Persimmon Costs to Date Costs for S106 Agreement

Total £0 Appeal Costs

Technical Consultant Fees

Transport Work

Landscape

Ecology

Engineering / Feasibility Design

Public Consultation

Local Plan Representations

Other

Total £0 EXTERNAL COSTS BUILD UP Date: 08-Aug-18

SITE NAME: Princes Risborough Acres 158.56

Description Quantity Unit CostperUnit TotalCost - External Works 2,357.0 plot 20,000.00 47,140,000 Estate Roads - Private Drives - Foul & Surface Water draninage system - Services - gas, water, electricity - Surface Water attenuation on plot - Site Clearance

- M4 (2) Additional Costs - PD House 883.00 - PD Flat 1,068.00 - AH House 617.0 1,646.00 1,015,582 AH Flat 90.0 2,327.00 209,430 - M4 (3) Additional Costs - PD House 20% 16,658.00 - PD Flat 20% 10,926.00 - AH House 30% 26,405.00 - AH Flat 30% 15,691.00 - - - Garages 1,304.0 6,000.00 7,824,000 - - -

------

- - - - -

SITE TOTALS 56,189,012 354,371 per ac PLOT & UNIT BUILD COST CALCULATION SHEET Date: 08-Aug-18

SITE NAME: Princes Risborough

FULL PLOT CONSTRUCTION Housetype Sq Ft No Cost per Sq ft Unit Cost Total Cost Alnwick EP 648 210 113.0 73,224 15,377,040 Hanbury 761 501 113.0 85,993 43,082,493 Chedworth DC 1,220 340 120.0 146,400 49,776,000 Clayton CnrDC 999 351 120.0 119,880 42,077,880 Corfe DC 1,414 112 120.0 169,680 19,004,160 Flat 1 bed 520 76 131.0 68,120 5,177,120 Flat 2 bed 580 60 131.0 75,980 4,558,800 ------TOTAL 1650 179,053,493

AFFORDABLE PLOTS CONSTRUCTION Housetype Sq Ft No Cost per Sq ft Unit Cost Total Cost Flat 1 bed 520 42 131.0 68,120 2,861,040 Flat 2 bed 580 48 131.0 75,980 3,647,040 2 bed 761 274 113.0 85,993 23,562,082 3 bed 875 304 113.0 98,875 30,058,000 4 bed 1220 39 120.0 146,400 5,709,600 ------TOTAL 707 65,837,762

SITE TOTALS 2,357 244,891,255 REVENUE CALCULATION SHEET 08-Aug-18

SITE NAME: Princes Risborough

FULL PLOT CONSTRUCTION SALES REVENUE Housetype Sq Ft No Revenue £ Sq Ft Total Revenue Total Sq ft Alnwick EP 648 210 340,000 524.7 71,400,000 136,080 Hanbury 761 501 375,000 492.8 187,875,000 381,261 Chedworth DC 1,220 340 515,000 422.1 175,100,000 414,800 Clayton CnrDC 999 351 425,000 425.4 149,175,000 350,649 Corfe DC 1,414 112 565,000 399.6 63,280,000 158,368 Flat 1 bed 520 76 210,000 403.8 15,960,000 39,520 Flat 2 bed 580 60 285,000 491.4 17,100,000 34,800 ------TOTAL 1650 679,890,000 1,515,478

AFFORDABLE PLOTS SALES REVENUE Housetype Sq Ft No Revenue £ Sq Ft Total Revenue Total Sq ft - - Flat 1 bed 520 42 116,480 224.00 4,892,160.00 21,840 Flat 2 bed 580 48 129,920 224.00 6,236,160.00 27,840 2 bed 761 274 170,464 224.00 46,707,136.00 208,514 3 bed 875 304 196,000 224.00 59,584,000.00 266,000 4 bed 1220 39 273,280 224.00 10,657,920.00 47,580 ------TOTAL 707 128,077,376.00 571,774

SITE TOTALS 2357 807,967,376 2,087,252 GREENFIELD RESIDUAL SITE APPRAISAL MODEL Date 08-Aug-18

SITE NAME Princes Risborough SITE ACREAGE 158 56 Nett Acres

1 TOTAL REVENUE (imported from Revenue Calculation Sheet)

FULL PLOT CONSTRUCTION SALES REVENUE Private Revenue 679,890,000 449 psf Affordable Revenue 128,077,376 224 psf

TOTAL REVENUE 807,967,376 387 psf

LESS

PLOT & UNIT BUILD COSTS (detail on Plot & Unit Calculation Sheet)

FULL PLOT CONSTRUCTION 179,053,493 AFFORDABLE PLOTS CONSTRUCTION 65,837,762

TOTAL PLOT & UNIT BUILD COSTS 244,891,255 117 psf

EXTERNAL WORKS (detail on External Costs Sheet) 56,189,012 27 psf

PRELIMINARIES (Site Overheads) of Plot & Unit Build, External Works Costs - - psf

ABNORMAL DEVELOPMENT COSTS 175,795,404 84 psf

TOTAL BUILD COSTS 476,875,671 228 psf

BUILD COST CONTINGENCY @ 5.00% 23,843,784

TOTAL BUILD COST + CONTINGENCY 500,719,455 240 psf

MAINTENANCE (Customer Care) 1000 per plot 2,357,000 1 psf

SALES & MARKETING BUDGET 3.50% of Sales Revenue (excluding Affordable) 23,796,150 11 psf

PROFESSIONAL FEES 10.00% of Build Cost (Plot & Unit, Externals) 30,108,027 14 psf

2 TOTAL DEVELOPMENT COSTS 556,980,631 267 psf

3 FINANCE COSTS Build Finance @ 6.50% 15,498,459 7 psf (based upon 50% of Total Build Cost before Contingency)

4 GROSS PROFIT (including Group & Office Overheads) N.B. Expressed as a Percentage of Sales Revenue for each Category

PRIVATE REVENUE MARGIN @ 20.00% 135,978,000 AFFORDABLE MARGIN @ 6.00% 7,684,643

TOTAL GROSS PROFIT 143,662,643 69 psf

TOTAL DEDUCTIONS (Items 2 + 3 + 4) 716,141,733

LAND RESIDUAL VALUE 91,825,643

Less

Legal Fees 0 50% 459,128 Land Finance @ 6 50% 5,968,667 Stamp Duty 5 00% 4,269,892

NETT LAND VALUE 81,127,955

Less discount Applicable - Option Fee - Legal & Surveyors Fees - Application Fees - Professional and Technical Fees (inc. appeal costs) -

LAND PAYMENT 81,127,955

Nett Land Value per Acre 511,655 Nett Land Value per Acre (after Deductions) 511,655 Nett Land Value per Unit (after Deductions) 34,420 Coverage Per Net Acre 13,164 Greenfield (INCLUD NG affordable) Total 256,923,359 Gross Land Value per Acre Per Acre 227,888 GREENFIELD RESIDUAL SITE APPRAISAL MODEL Date 13-Aug-18

SITE NAME Princes Risborough policy compliant SITE ACREAGE 158 56 Nett Acres

1 TOTAL REVENUE (imported from Revenue Calculation Sheet)

FULL PLOT CONSTRUCTION SALES REVENUE Private Revenue 518,870,000 420 psf Affordable Revenue 209,317,500 210 psf

TOTAL REVENUE 728,187,500 326 psf

LESS

PLOT & UNIT BUILD COSTS (detail on Plot & Unit Calculation Sheet)

FULL PLOT CONSTRUCTION 145,865,930 AFFORDABLE PLOTS CONSTRUCTION 115,213,988

TOTAL PLOT & UNIT BUILD COSTS 261,079,918 117 psf

EXTERNAL WORKS (detail on External Costs Sheet) 69,282,338 31 psf

PRELIMINARIES (Site Overheads) of Plot & Unit Build, External Works Costs - - psf

ABNORMAL DEVELOPMENT COSTS 172,390,330 77 psf

TOTAL BUILD COSTS 502,752,586 225 psf

BUILD COST CONTINGENCY @ 5.00% 25,137,629

TOTAL BUILD COST + CONTINGENCY 527,890,215 236 psf

MAINTENANCE (Customer Care) 1000 per plot 2,357,000 1 psf

SALES & MARKETING BUDGET 3.50% of Sales Revenue (excluding Affordable) 18,160,450 8 psf

PROFESSIONAL FEES 10.00% of Build Cost (Plot & Unit, Externals) 33,036,226 15 psf

2 TOTAL DEVELOPMENT COSTS 581,443,891 260 psf

3 FINANCE COSTS Build Finance @ 6.50% 16,339,459 7 psf (based upon 50% of Total Build Cost before Contingency)

4 GROSS PROFIT (including Group & Office Overheads) N.B. Expressed as a Percentage of Sales Revenue for each Category

PRIVATE REVENUE MARGIN @ 20.00% 103,774,000 AFFORDABLE MARGIN @ 6.00% 12,559,050

TOTAL GROSS PROFIT 116,333,050 52 psf

TOTAL DEDUCTIONS (Items 2 + 3 + 4) 714,116,400

LAND RESIDUAL VALUE 14,071,100

Less

Legal Fees 0 50% 70,356 Land Finance @ 6 50% 914,622 Stamp Duty 5 00% 654,306

NETT LAND VALUE 12,431,817

Less discount Applicable - Option Fee - Legal & Surveyors Fees - Application Fees - Professional and Technical Fees (inc. appeal costs) -

LAND PAYMENT 12,431,817

Nett Land Value per Acre 78,404 Nett Land Value per Acre (after Deductions) 78,404 Nett Land Value per Unit (after Deductions) 5,274 Coverage Per Net Acre 14,079 Greenfield (INCLUD NG affordable) Total 184,822,147 Gross Land Value per Acre Per Acre 34,921 REVENUE CALCULATION SHEET 13-Aug-18

SITE NAME: Princes Risborough policy compliant

FULL PLOT CONSTRUCTION SALES REVENUE Housetype Sq Ft No Revenue £ Sq Ft Total Revenue Total Sq ft Alnwick EP 850 133 350,000 411.8 46,550,000 113,050 Hanbury 904 362 395,000 436.9 142,990,000 327,248 Chedworth DC 1,237 264 515,000 416.3 135,960,000 326,568 Clayton CnrDC 1,001 280 425,000 424.6 119,000,000 280,280 Corfe DC 1,414 90 565,000 399.6 50,850,000 127,260 Flat 1 bed 538 55 210,000 390.3 11,550,000 29,590 Flat 2 bed 753 42 285,000 378.5 11,970,000 31,626 ------TOTAL 1226 518,870,000 1,235,622

AFFORDABLE PLOTS SALES REVENUE Housetype Sq Ft No Revenue £ Sq Ft Total Revenue Total Sq ft - - Flat 1 bed 538 136 112,980 210.00 15,365,280.00 73,168 Flat 2 bed 738 158,130 214.27 - - 2 bed 850 454 178,500 210.00 81,039,000.00 385,900 3 bed 904 395 189,840 210.00 74,986,800.00 357,080 4 bed 1237 146 259,770 210.00 37,926,420.00 180,602 ------TOTAL 1131 209,317,500.00 996,750

SITE TOTALS 2357 728,187,500 2,232,372 PLOT & UNIT BUILD COST CALCULATION SHEET Date: 13-Aug-18

SITE NAME: Princes Risborough policy compliant

FULL PLOT CONSTRUCTION Housetype Sq Ft No Cost per Sq ft Unit Cost Total Cost Alnwick EP 850 133 113.0 96,050 12,774,650 Hanbury 904 362 113.0 102,152 36,979,024 Chedworth DC 1,237 264 120.0 148,440 39,188,160 Clayton CnrDC 1,001 280 120.0 120,120 33,633,600 Corfe DC 1,414 90 120.0 169,680 15,271,200 Flat 1 bed 538 55 131.0 70,478 3,876,290 Flat 2 bed 753 42 131.0 98,643 4,143,006 ------TOTAL 1226 145,865,930

AFFORDABLE PLOTS CONSTRUCTION Housetype Sq Ft No Cost per Sq ft Unit Cost Total Cost Flat 1 bed 538 136 131.0 70,478 9,585,008 Flat 2 bed 738 0 131.0 96,678 - 2 bed 850 454 113.0 96,050 43,606,700 3 bed 904 395 113.0 102,152 40,350,040 4 bed 1,237 146 120.0 148,440 21,672,240 ------TOTAL 1131 115,213,988

SITE TOTALS 2,357 261,079,918 EXTERNAL COSTS BUILD UP Date: 13-Aug-18

SITE NAME: Princes Risborough policy compliant Acres 158.56

- M4 (2) Additional Costs - PD House 1,207.0 883.00 1,065,781 PD Flat 108.0 1,068.00 115,344 AH House 995.0 1,646.00 1,637,770 AH Flat 136.0 2,327.00 316,472 - M4 (3) Additional Costs - PD House 20% 241.0 16,658.00 4,014,578 PD Flat 20% 22.0 10,926.00 240,372 AH House 30% 298.0 26,405.00 7,868,690 AH Flat 30% 41.0 15,691.00 643,331 15,902,338 - - Garages 1,040.0 6,000.00 6,240,000 - - -

------

- - - - -

SITE TOTALS 69,282,338 436,947 per ac ABNORMAL COSTS BUILD UP Date 13-Aug-18

SITE NAME Princes Risborough policy compliant Acres 158 56

Description Total Cost

Infrastructure Costs 158 acres x £375,000 per acre £59,250,000 Abnormal Foundations Underbuild Retaining Walls Screen Walls Enhanced External Materials Off Site Surface Water Drainage Systems Off Site Foul Water Drainage Systems Surface Water Attenuation - balancing ponds Open Space - LAPS , LEAPS Landscaping Estate Roads & Sewers Private Drives Ecology mitigation and aboricultural works Service diversion and reinforcement

S 106 Costs

Third Party Land Acquisition £4,395,000 Part 1 Compensation Claims £1,736,000

CIL Payment £181.47 x 122,027m2 £22,144,330

£172,390,330 1,087,225 per ac PERSIMMON HOMES WEST YORKSHIRE - COST TRANSACTION REPORT

DESCRIPTION DATE AMOUNT (£)

Option Fee

Total £0 Sellers Legal and Agent Fees

Bungalow SDLT

Total £0 Planning Application

Persimmon Costs to Date Costs for S106 Agreement

Total £0 Appeal Costs

Technical Consultant Fees

Transport Work

Landscape

Ecology

Engineering / Feasibility Design

Public Consultation

Local Plan Representations

Other

Total £0