LDF Thank You for the Opportunity to Comment. Surrey Heath Have No

LDF

From: Jane Ireland Sent: 13 April 2015 16:41 To: LDF Subject: RE: Publication of the Reigate & Banstead Community Infrastructure Levy Draft Charging Schedule

Thank you for the opportunity to comment. Surrey Heath have no comments on the CIL charging schedule. Regards Jane Ireland Planning Policy and Support Manager Policy and Conservation Surrey Heath Borough Council Knoll Road Camberley GU15 3HD (01276 707213) www.surreyheath.gov.uk Great Place l Great Community l Great Future

From: LDF [mailto:[email protected]] Sent: 13 April 2015 12:09 To: LDF Subject: Publication of the Reigate & Banstead Community Infrastructure Levy Draft Charging Schedule

Dear Sir/Madam

In accordance with Regulation 16 of the Community Infrastructure Levy Regulations 2010 (as amended), I am writing to inform you of publication of the Reigate and Banstead Infrastructure Levy (CIL) Draft Charging Schedule, and invite your comments on the document.

A copy of the CIL Draft Charging Schedule and Statement of Representations Procedure are attached to this email. These documents are also available to view on the Council’s website at www.reigate- banstead.gov.uk/cil, along with a range of relevant evidence and supporting documentation. Documents are also available for inspection at the Town Hall in Reigate and hard copies of all documents are available on request from 01737 276178 or [email protected].

You are encouraged to respond using the standard response form which is also available to download or on request using the details above. Responses must be submitted to the Council by 5pm, Tuesday 26 May 2015:  By email to: [email protected]; or  By post to: Planning Policy Team, Reigate & Banstead Borough Council, Town Hall, Castlefield Road, Reigate, Surrey, RH2 0SH.

Parties making representations may also request the right to be heard at examination or to be notified of future steps in the preparation of CIL should they wish.

If you have any queries about the content of the charging schedule or its preparation, or require any other assistance, please contact the Planning Policy Team on 01737 276178 or email LDF@reigate- banstead.gov.uk. 1

If you do not wish to take part in future consultations on the Community Infrastructure Levy or other planning policy documents, or receive any further updates on our new Local Plan, please contact the Planning Policy Team on the above details to request removal from our consultation database.

Yours faithfully,

Luci Mould Planning, Economic Prosperity and Parks Manager

Reigate & Banstead Borough Council Town Hall, Castlefield Road Reigate, Surrey RH2 0SH T: 01737 276000 W: www.reigate-banstead.gov.uk

Follow the Council on twitter.com/reigatebanstead Sign up for Borough e-news: www.reigate-banstead.gov.uk/enews

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Reigate & Banstead Borough Council

Reigate Town Hall, Castlefield Road, Reigate, Surrey RH2 0SH

Telephone : +44 (0)1737 276000

Website : http://www.reigate-banstead.gov.uk

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16 APRIL 2015

Planning Policy Team Reigate & Banstead Borough Council Town Hall Castlefield Road Reigate Surrey RH2 0SH Dear Sir/Madam

Re: Community Infrastructure Levy Draft Charging Schedule

Our Ref: LGW2920

Thank you for your email dated 13 April 2015, regarding the above mentioned document.

The draft charging schedule does not appear to have any implications for Aerodrome Safeguarding and therefore we have no further comments to make.

Thank you for giving us the opportunity to comment on this document.

Yours sincerely

Amanda Purdye, Aerodrome Safeguarding For and on behalf of Gatwick Airport Limited

Email: [email protected]

GATWICK AIRPORT LIMITED, DESTINATIONS PLACE, GATWICK AIRPORT, WEST SUSSEX, RH6 0NP www.gatwickairport.com Registered in England 1991018. Registered Office Destinations Place, Gatwick Airport, West Sussex, RH6 0NP LDF

From: Emma Pattison Sent: 17 April 2015 14:43 To: LDF Subject: RE: Publication of the Reigate & Banstead Community Infrastructure Levy Draft Charging Schedule OUR REF: TG General Attachments: PLANNING_plan.pdf

Dear Sirs,

Thank you for your email to GPSS, Government Pipelines and Storage Systems dated 13th April 2015 regarding the above. Please find attached a plan of our clients apparatus. We would ask that you contact us if any works are in the vicinity of the GPSS pipeline or alternatively go to www.linesearchbeforeudig.co.uk our free online enquiry service.

Kind regards

GPSS

Emma Pattison

For and on behalf of Fisher German LLP Download Outlook vCard

The Grange - 80 Tamworth Road - Ashby de la Zouch - Leicestershire - LE65 2BY

Emma Pattison

For and on behalf of Fisher German LLP 01530 410866 Download Outlook vCard

Enter The Rural Business Awards – Closing Date 7 August 2015. Sponsored By Fisher German. The Grange - 80 Tamworth Road - Ashby de la Zouch - Leicestershire - LE65 2BY

This e-mail message is confidential and for the use of the addressee only. If the message is received by anyone other than the addressee it must be deleted. Internet e-mails are not secure and Fisher German does not accept responsibility for changes made to the message. Fisher German LLP is a limited liability partnership. A list of members' names is available for inspection at the Market Harborough office. Registered Number: OC317554. SAVE PAPER - Please do not print this e-mail unless absolutely necessary.

1 517500 518100 518700 519300 519900 520500 521100 521700 522300 522900 523500 524100 524700 525300 525900 526500 527100 527700 528300 528900 529500 530100 530700 531300 531900 532500 533100 533700 534300 534900 163200 162800

162400 ± 162000

OVERVIEW WINDOW 161600 SCHEME:

161200 TITLE: 160800 160400 160000 159600 159200 158800

158400 T /G Legend

158000 GPSS

157600 Site centre coordinates: 526,160 - 156,431 157200 156800 FILE REF: 156400

156000 SCALE: 1:50,000 @ A3

155600 DATE: 16/04/2015

155200 Client:

154800 OPA Oil & Pipelines Agency 154400 TITLE: 154000 GPSS LOCATION PLAN EXTRACT

153600 OF PIPELINE T/G

153200 © Crown copyright and database rights 2014 Ordnance Survey Licence Number 152800 AL100005237 152400

THIS DRAWING IS PROTECTED BY COPYRIGHT. IT MAY NOT BE REPRODUCED IN ANY FORM OR

152000 BY ANY MEANS FOR ANY PURPOSE WITHOUT WRITTEN PERMISSION OF FISHER GERMAN LLP CHARTERED SURVEYORS 151600 151200 150800 150400 Fisher German LLP. The Grange 80 Tamworth Road, Ashby de la Zouch, Leicestershire, LE65 2BW 150000 Telephone 01530 412821 Fax: 01530 413896 149600 Date: 23 April 2015 Our ref: 150583

Ms Luci Mould Consultation Service Planning, Economic Prosperity & Parks Manager Hornbeam House Reigate & Banstead Borough Council Electra Way Town Hall Crewe Business Park Castlefield Road Crewe Reigate CW1 6GJ Surrey T: 0300 060 3900 RH2 0SH

Sent by E Mail only to:LDF@reigate- banstead.gov.ukmailto:LDF@reigate- banstead.gov.uk

Dear Ms Mould,

Re: Reigate and Banstead Community Infrastructure Levy Draft Charging Schedule

Thank you for your consultation on the above, which was received by Natural England on the 13 April 2015.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England has no specific comments to make on the draft Community Infrastructure Levy (CIL) Charges, however would like to make the following general comments, which we hope are helpful.

Natural England is not a service provider, nor do we have detailed knowledge of infrastructure requirements of the area concerned. However, we note that the National Planning Policy Framework (NPPF) Para 114 states “Local planning authorities should set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure.” We view CIL as playing an important role in delivering such a strategic approach.

As such we advise that the council gives careful consideration to how it intends to meet this aspect of the NPPF, and the role of the CIL in this. In the absence of a CIL approach to enhancing the natural environment, we would be concerned that the only enhancements to the natural environment would be ad hoc, and not deliver a strategic approach, and that as such the local plan may not be consistent with the NPPF.

Potential infrastructure requirements may include:

 Access to natural green-space.  Allotment provision.  Infrastructure identified in the local Rights of Way Improvement Plan.  Infrastructure identified by any Local Nature Partnerships and or BAP projects.  Infrastructure identified by any AONB management plans.  Infrastructure identified by any Green infrastructure strategies.

1  Other community aspirations or other green infrastructure projects (e.g. street tree planting).  Infrastructure identified to deliver climate change mitigation and adaptation.  Any infrastructure requirements needed to ensure that the Local Plan is Habitats Regulation Assessment compliant

We hope that you find this information useful. For any correspondence or queries relating to this consultation only, please contact David Hammond using the details given below. For all other correspondence, including in relation to forward planning consultations, please contact the address above or email [email protected].

We really value your feedback to help us improve the service we offer. We have attached a feedback form to this letter and welcome any comments you might have about our service.

Yours sincerely,

David Hammond Lead Advisor Thames Valley Team Sustainable Development & Regulation Tel: 0300 060 1373 Email: [email protected]

2 LDF

From: Ernest Amoako Sent: 27 April 2015 17:28 To: LDF Subject: Community Infrastructure Levy Draft Charging Schedule

Dear Sir/Madam

Thank you for giving Woking Borough Council the opportunity to comment on your Community Infrastructure Levy (CIL) Draft Charging Schedule. On this occasion I have nothing further to add. Please keep us informed of subsequent stages of your CIL process to adoption.

Thank you

Ernest Amoako Woking Borough Council

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Reigate & Banstead Borough Council

Community Infrastructure Levy (CIL): Draft Charging Schedule

April 2015

Representations Form

How to submit your comments

This response form has two parts:  Part A: Personal Details  Part B: Your Views  Part C: Participation and Notification

We would strongly encourage you to respond to the consultation by completing the questions set out in this form. Please complete PartsA, B and C to assist us in considering your views. You are encouraged to provide as much explanation as possible, and where relevant, attach any available evidence to support your position.

Forms must be returned to Reigate & Banstead Borough Council by 5pm on 26 May 2015

You can return your form:

By post to: Planning Policy Team, Reigate & Banstead Borough Council Town Hall, Castlefield Road, Reigate, Surrey, RH2 0SH.

By e-mail to: [email protected]

All duly made responses and representations will be considered by the Council and will be passed to the independent examiner as part of the examination procedure. We are happy to provide information in other languages, large print, braille or on audio tape. Please contact ouur Help Line on 01737 276000 if you would like this service.

Part A: Personal Details If an agent is appointed please complete only the Title, Name and Organisation boxes in (1) but complete the full contact details of the agent in (2).

(1) Personal Details (2) Agents Details (if relevant) Title Mr.

First name Stephen

Last name

Hanks Job title (if relevant) N/A

Organisation (if relevant) Nutfield Conservation Society

Address C/O 6, Braes Mead South Nutfield

Postcode RH1 4JR

Telephone No 01737 822516

Email address [email protected]

Page 1 Part B: Your Views

Draft Charging Schedule and Proposed Charges

(1) Do you have any comments to make on the proposed rates of CIL and the supporting viability evidence (set out in the CIL Revised Viability Assessment Report and Appendices)? Yes No No

If you have answered ‘yes’, please provide further explanation, Please set out any evidence available to support your views

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

(2) Do you have any comments to make on the charging zone maps set out in the Draft Charging Schedule?

Yes No No

If you have answered ‘yes’, please provide further explanation

(continue on a separate sheet/expand box if necessary) Page 1 Draft List of Relevant Infrastructure

(3) Do you have any comments to make on the draft list of relevant infrastructure?

Yes No No

If you have answered ‘yes’, please provide further explanation

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

Evidence Base

(4) Do you have any other comments to make on the evidence base and supporting documentation for the Draft Charging Schedule?

Yes No No

If you have answered ‘yes’, please provide further explanationPlease make clear which document (i.e. Infrastructure Delivery Plan) and if possible any specific passages or tables your views refer to, particularly if you are making comments on multiple documents. Please set out any evidence available to justify your views.

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

Page 2 Part C: Participation and Notification

Requesting the right to be heard at examination

(5) Organisations and individuals making representations may request the right to be heard by the examiner. Do you consider it necessary to participate at the oral part of the examination?

No, I do not wish to participate at No Yes, I wish to participate at the oral the oral examination examination

If you wish to participate at the oral examination, please outline why you consider this to be necessary

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

Please note: The examiner will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of any examination.

Requests to be notified

(6)Representations may also be accompanied by a request to be notified, at a specified address, of any of the following. Please indicate of which, if any, you wish to be notified.

(a) That the Draft Charging Schedule has been submitted to the Yes No No examiner in accordance with section 212 of the Planning Act 2008

(b) The publication of the recommendations of the examiner and the Yes Yes No reasons for those recommendations

Signature: Date: 29/04/15 Stephen Hanks

Page 3

Reigate & Banstead Borough Council

Community Infrastructure Levy (CIL): Draft Charging Schedule

April 2015

Representations Form

How to submit your comments

This response form has two parts:  Part A: Personal Details  Part B: Your Views  Part C: Participation and Notification

We would strongly encourage you to respond to the consultation by completing the questions set out in this form. Please complete Parts A, B and C to assist us in considering your views. You are encouraged to provide as much explanation as possible, and where relevant, attach any available evidence to support your position.

Forms must be returned to Reigate & Banstead Borough Council by 5pm on 26 May 2015

You can return your form:

By post to: Planning Policy Team, Reigate & Banstead Borough Council Town Hall, Castlefield Road, Reigate, Surrey, RH2 0SH.

By e-mail to: [email protected]

All duly made responses and representations will be considered by the Council and will be passed to the independent examiner as part of the examination procedure. We are happy to provide information in other languages, large print, braille or on audio tape. Please contact our Help Line on 01737 276000 if you would like this service.

Part A: Personal Details If an agent is appointed please complete only the Title, Name and Organisation boxes in (1) but complete the full contact details of the agent in (2).

(1) Personal Details (2) Agents Details (if relevant) Title Mrs

First name Cheryl

Last name Brunton

Job title (if relevant) Planning policy officer

Organisation (if relevant) Runnymede Borough Council

Address Civic Centre Station Road Addlestone KT15 2AH

Postcode

Telephone No

Email address [email protected]. uk

Page 1 Part B: Your Views

Draft Charging Schedule and Proposed Charges

(1) Do you have any comments to make on the proposed rates of CIL and the supporting viability evidence (set out in the CIL Revised Viability Assessment Report and Appendices)? Yes No x

If you have answered ‘yes’, please provide further explanation, Please set out any evidence available to support your views

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

(2) Do you have any comments to make on the charging zone maps set out in the Draft Charging Schedule?

Yes No x

If you have answered ‘yes’, please provide further explanation

(continue on a separate sheet/expand box if necessary) Page 1 Draft List of Relevant Infrastructure

(3) Do you have any comments to make on the draft list of relevant infrastructure?

Yes No x

If you have answered ‘yes’, please provide further explanation Is the reason why the specific exclusions are included on the list because the improvements are being funded through other means? Is it worth clarifying this?

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

Evidence Base

(4) Do you have any other comments to make on the evidence base and supporting documentation for the Draft Charging Schedule?

Yes No x

If you have answered ‘yes’, please provide further explanation Please make clear which document (i.e. Infrastructure Delivery Plan) and if possible any specific passages or tables your views refer to, particularly if you are making comments on multiple documents. Please set out any evidence available to justify your views. Is the September 2012 IDP available to view on the Council’s website as it does not appear to be available on the CIL web page?

Page 2

(continue on a separate sheet/expand box if necessary) Part C: Participation and Notification

Requesting the right to be heard at examination

(5) Organisations and individuals making representations may request the right to be heard by the examiner. Do you consider it necessary to participate at the oral part of the examination?

No, I do not wish to participate at x Yes, I wish to participate at the oral the oral examination examination

If you wish to participate at the oral examination, please outline why you consider this to be necessary

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

Please note: The examiner will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of any examination.

Requests to be notified

(6) Representations may also be accompanied by a request to be notified, at a specified address, of any of the following. Please indicate of which, if any, you wish to be notified.

(a) That the Draft Charging Schedule has been submitted to the Yes x No examiner in accordance with section 212 of the Planning Act 2008

(b) The publication of the recommendations of the examiner and the Yes x No reasons for those recommendations

Signature: Date: 30/4/15 Cheryl Brunton

Page 3

Page 4 LDF

From: Catherine Rose Sent: 05 May 2015 14:04 To: Billy Clements Subject: FW: PLANNING, ECONOMICS & LEVY CONSULTATION 5th May 2015

From: john.C [mailto:[email protected]] Sent: 05 May 2015 12:58 To: Catherine Rose Subject: PLANNING, ECONOMICS & LEVY CONSULTATION 5th May 2015

Hello Catherine,

Herewith our initial response to the matters associated with the Levy consultation.

Regards

John Chittenden for the Reigate Society Tpt committee.

This email has been checked for viruses by Avast antivirus software.

www.avast.com

MG -REPORT No. 69. A draft Document for discussion

PROTECTING THE PLANNING GREEN BELT

In protecting the Metropolitan Green Belt from further erosion it is recognized that an element of flexibility is required, but that the total area protected by the GREEN BELT - around large conurbations - should be maintained.

It is therefore proposed that LOCAL AUTHORITIES (LA) and others seeking to take Greenbelt land for development be required to provide replacement land from;-

A. Adjacent areas or Planning white land B. Brown field sites ( Restored )

In enforcing such a rule the Minister with the approval of Parliament may give guidance to others using similar objectives set out for the protection of common land in the COMMON ACT 2006;-

Section 16 (3) Replacement Land and Section 17 (3) Deregistration and Exchange ; Orders.

The objective of this proposal is to ;-

C. Maintain a Green belt for the long term benefit of the population. D. Reduce LA costs and expenditure on frequent and repetitive planning applications inquiries and appeals. E Simplify and reduce Government administration.

JOHN CHITTENDEN

MH - REPORT No. 70. The Reigate Society (RS) Tpt. Committee draft. may 2015.

PLANNING, ECONOMIC PROSPERITY & PARKS Reigate and Banstead Borough Infrastructure Levy Consultation.

1.0 LEP UPDATE -

1.1 Planned Housing & Population Growth;-

Mole Valley;- Housing requirement reduced and limited to brown field sites.with a plan to secure £125,000 for a Leatherhead upgrade.. New Homes 3766

Tandridge;- New homes 2500

Epsom & Ewell ‘’ 3620

Croydon ‘’ 27,000 Stated to be an important link between the LEP and London The deferred N/S bypass presents a problem and a bid for £559m has been made. Crawley ‘’ 7500

Horsham ‘’ 13000

Lewes There is concern about flood risk ‘’ 4500

Brightonn & Hove ‘’ 11300

Adur (Worthing) Many workers travel for employment ‘’ 4800

Arun ( Bognor Regis) ‘’ ‘’ 11500 There is concern about flood risk Chichester ‘’ 7388

Mid Sussex Many workers travel for employment ‘’ 11050

Reigate & banstead ‘’ 12500 Populatio;- 140,000 during (2012) predicted at 172,400 by 2032

The total estimate of new dwellings proposed within the LEP area is;- 120,424

Approximate population increase with an average of 2.59 occupancy = 311,900 extra persons There will be further population increases in adjacent LEP areas and within the Greater London Boroughs details of which are available elsewhere.

IT IS POSSIBLE THAT THIS POPULATION GROWTH WILL ADD TO THE DAILY THROUGH TRAFFIC FLOW WITHIN THE BOROUGHS OF REIGATE & BANSTEAD and CROYDON.

1.2 The Rowntree Foundation Report;- FLOODING & COASTAL MANAGEMENT;-

The Report forecasts a possible rise in the sea level during the period under review ;- 2020;- 5.7cm to 9.7cm; 2050;- 13.9cm to 21.8cm; 2080;- 24.4cm to 36.3cm. The combined effect of a storm with higher wind speeds and raised wave height can result in a local serge in estuary sea levels of 1m that could reach 1.5m. The relatively soft nature of sedimentary rock in Southern England is likely to result in rapid erosion, an increase in Littoral Drift with extra maintenance required at ports etc. The report also states that there is some complacency among those living on the coast in the belief that the Local Authority had responsibility for the shoreline management plan (SMP)and that flooding damage costs may be recoverable. The reason why this is important is that in the event of a storm water coastal inundation with damage to property residents will need alternative accommodation on higher ground within the LEP area. The South Downs Country Park has strict rules on planning development and alternative housing may have to be provided on higher land elsewhere similar problems may arise within the Thames and other estuaries.

2.0 LOCAL MATTERS;-

2.1 Following the presentation of RS Report No’s 1 and subsequent Reports and at meetings it was generally agreed that the main transport problem would be that of the through traffic flow. It is contended that many of the Boroughs through traffic routes, both classified and unclassified, are not up to current design standards and that bringing them up to standard would be both expensive, unpopular and therefore out of the question. Many of the traffic routes used are or have been reduced to single track by vehicle parking and some footways are obstructed making it necessary for pedestrians to use the carriageway. It may therefore be necessary to provide more off street parking as well as making provision elsewhere for Increasing through traffic flow.

2.2 Traffic Flow Problems that need to be addressed;- At a recent spot count at a daytime traffic queue it was found that at least 70% of the vehicles held and awaiting movement were commercial vehicles. This is important because the time wasted by those involved together with vehicle costs and fuel consumed amounts to an overall reduction in productivity. Nationally and locally declining productivity is an economic disaster as it is related to higher prices,less competitive services,the prospect of declining exports, with falling employment and incomes. It may be contended that vehicle engines should be switched off but this can prove difficult in diesel powered or slow moving vehicles. There is a further disadvantage in that fumes produced by slow moving traffic produce serious air pollution and health risk with costs to the community.

2.3 Road and Pedestrian Safety;- The measures to improve pedestrian and cycle safety are welcomed. But we all need to learn from the disaster of poor cycle safety in central London. Segregation of Vehicles,Cycles and Pedestrians should be the watch words in any SAFETY AUDIT. With such a large projected population increase the improved safety measures are bound to Inhibit traffic flow and alternative traffic routing should be considered or sought.

3.0 REGATE DEVELOPMENT PROPOSALS, TRAFFIC GROWTH & LEVY;-

3.1 Existing Bypass routes in use East of Redhill Town;- Redstone Hollow, Fullers wood lane, PHILANTHROPIC LANE, a single track Road with passing places, together with Hooley lane and St. Johns Road are currently used as a bypass to parts of Redhill. Now that the development proposals have been established for this area it is suggested that the roads listed above together with Hawthorne Way and Eastfield Rd be subjected to review and a safety audit to report on the overall impact of the projected through traffic flow on the Earlswood community and the need for vehicular access and parking at the local Railway Station. Traffic safety measures may also be necessary at the A25 cross roads formed at the junction of Fullers wood and Cormongers lane.

3.2 Bypass routes North & East of Redhill ;- Cormongers lane, Nutfield road, through Merstham, School Hill and the Water Colour development are currently used as part of the Eastern Bypass to Redhill to gain access to Merstham Railway Station, A23, Gatton Bottom, and A 217. The proposed Development on land enclosed between the London Brighton Rail line to the West, the M25 and the M23 and the Water filled Sand pits and Sewage works to the South presents an access problem that needs careful consideration with its effect on the Merstham community together with a safety audit and also a review of parking facilities at the Rail Station.

3.3 The A23 / M23 JUNCTION;- There has been much talk but no FUNDS for this proposal but if completed it may encourage and support the traffic growth on the routes listed above. The impact of this bypass traffic growth on local village communities may be serious without the introduction of alternative options. At present the expanding town and industrial area of Redhill has no satisfactory connection to the M23 Motorway and it is suggested that any connection North of Merstham is likely to be of little value because it is frequently blocked at the Motorway Junction with the A23 ( possibly because the Croydon A23 bypass has yet to be built ).

ALTERNATIVE JUNCTIONS WITH THE M23 need to be considered in conjunction with the social impact on the A25 village communities their antiquities and Conservation areas.

Option 1 Proposed at Hooley north of Merstham as mentioned above.

Option 2 A new Junction North of the A25,

Option3 A new Junction South of the A25;- This suggestion if implemented may have the benefit of reducing traffic flow on the A25 through Redhill and the Nutfield, Bletchingly & Godstone villages.

3.4 Bypass routes South and West of Reigate;- The existing traffic flow on the A217 is frequently held in a queue South of and within Reigate town, further delay occurs at the rail level crossing North of the Town where there is talk of improved train capacity and frequency. The building of 1500 homes North of Horley and the proposed homes South and West of the Woodhatch community will also have access to the A217.

It is also noted that the anticipated population growth within this Borough,Tandridge, Mole valley, Croydon, Epsom and Ewell,and Crawley is nearing 150,000 persons but this excludes the population growth of adjacent LEP’s and London Boroughs.

A 2044 Woodhatch Road;- This route may have some reserve capacity. However increased bypass traffic through Maple Road, the Woodhatch community area, Price’s Lane,Sand cross Lane, Park Lane and Park lane west (a potential cycle route) may need a review and given the attention of a SAFETY AUDIT. Options for a local Woodhatch bypass to Flanchford bridge South of the proposed housing development needs to be retained

4.0 REIGATE CENTER RELIEF ROAD;- (Scheme not agreed )

If the scheme is to proceed it may be necessary to accept the retention of;- Vehicle unloading bays for the Retail trade, customer short term parking and loading facilities,with a retained bus service route provided with stops for retail shoppers together with an exit for all traffic at the Western end of the High Street. Should this scheme be adopted then it may be possible to reduce vehicle wheel water spray damage to the lower courses of brick work on the Georgian Town Hall an at the same time reduce both air and noise pollution.

5.0 Summary of suggestions;-

That the Borough Council as the Planning Authority take the Lead in resolving some or all of the bypass problems listed using the levy and bid applications to the ministry (similar to Croydon) with the support of the LEP and SCC advised if necessary by Specialist Transport Consultants.

JOHN CHITTENDEN

For the Reigate Society Transport Committee

MI - REPORT No. 71. The Reigate Society (RS) Tpt. Committee draft. may 2015.

PLANNING, ECONOMIC PROSPERITY & PARKS; CONSULTATION;- R&B LEVY for SAFE PEDESTRIAN & CYCLE ROUTES TO SCHOOL, COLLEGE & RAIL STATIONS ;-

1.0 Proposed paths + cycle lane options;-

1.1 On WEST side of A217 Cockshot Hill ;- a path and cycle lane be provided on service roads,redundant quarry land, road verge, and Park footpath between Woodhatch and Reigate for the benefit and safety of the new population.

1.2 On Park Lane West (vehicles restricted to access only) and R of W, Nos.17,18 and 58 (for an easier Gradient), to the High Street, and the West side of London Road ( where land has been purchased ) and thence to schools, college and Rail Station. All as shown on the attached drawing.

1.3 On Lonesome Lane (vehicle restriction) from the Horley Development area to and through the Woodhatch development area to Park Lane West and route 1.2 above. This is proposed because fast and heavy traffic on the relatively narrow A217 with deep ditches is not safe for cyclists.

1.4 Other safe routes are possible and are shown including an off road cycle route from Woodhatch to the Hospital and a cycle route at Frenches Road. But noise and air pollution and safety problems at R of W, No.87 and at School Hill need other solutions for the new population within the proposed Merstham development areas.

JOHN CHITTENDEN For the RS Tpt committee

LDF

From: Claire Minter Sent: 19 May 2015 11:46 To: LDF Subject: FW: Publication of the Reigate & Banstead Community Infrastructure Levy Draft Charging Schedule Attachments: RBBC CIL Draft Charging Schedule.pdf; Statement of Representations and Availability.pdf

I can confirm that Salfords and Sidlow Parish Council discussed the CIL draft charging schedule at their Council meeting last night and have no further comment to make. Thanks, Claire

Clerk to Salfords and Sidlow Parish Council Salfords Village Hall 5 Honeycrock Lane Salfords Redhill, Surrey RH1 5DG

01737 780339 www.salfordsandsidlowpc.org.uk

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From: LDF [mailto:[email protected]] Sent: 13 April 2015 12:20 To: LDF Subject: Publication of the Reigate & Banstead Community Infrastructure Levy Draft Charging Schedule

Dear Sir/Madam

Parties making representations may also request the right to be heard at examination or to be notified of future steps in the preparation of CIL should they wish. 1

Yours faithfully,

Luci Mould Planning, Economic Prosperity and Parks Manager

Reigate & Banstead Borough Council Town Hall, Castlefield Road Reigate, Surrey RH2 0SH T: 01737 276000 W: www.reigate-banstead.gov.uk

Follow the Council on twitter.com/reigatebanstead Sign up for Borough e-news: www.reigate-banstead.gov.uk/enews

******************************************************************************

You should note that we cannot guarantee that this message or any attachment is virus free or has not been intercepted and amended.

The views of the author of this e-mail may not necessarily reflect those of the Authority.

Reigate & Banstead Borough Council

Reigate Town Hall, Castlefield Road, Reigate, Surrey RH2 0SH

Telephone : +44 (0)1737 276000

Website : http://www.reigate-banstead.gov.uk

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2 LDF

From: Barnes, Barbara Sent: 21 May 2015 09:30 To: LDF Cc: M25 Planning; growthandplanning Subject: Highways England Formal Response to the Publication of the Reigate & Banstead Community Infrastructure Levy Draft Charging Schedule

For the attention of: Luci Mould Planning, Economic Prosperity and Parks Manager

Dear Luci,

Thank you for email dated 14th May, 2015 inviting Highways England to comment on the Publication of the Reigate & Banstead Community Infrastructure Levy Draft Charging Schedule

Highways England has been appointed by the Secretary of State for Transport as Strategic Highway Company under the provisions of the Infrastructure Act 2015 and is the Highway Authority, Traffic Authority and Street Authority for the Strategic Road Network (SRN). The SRN is a critical national asset and as such works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.

Having reviewed the documents Highways England and have concluded that they have no comments.

Sent on behalf Janice Burgess (Asset Manager) Highways England

Barbara Barnes

Tel: +44 (0) 300 470 1027

Web: www.highwaysengland.co.uk

Highways England Company Limited | Registered Office: Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ | Registered in England and Wales No. 9346363

Safe roads, Reliable journeys, Informed travellers

______This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______

Planning Policy Team Our ref: SL/2011/108875/OR-03/PO1 Reigate & Banstead Borough Council Town Hall Your ref: Email Castlefield Road Reigate Date: 22 May 2015 Surrey, RH2 0SH

E: [email protected]

Dear Sir/Madam,

Reigate & Banstead Borough Council: Community Infrastructure Levy (CIL) Draft Charging Schedule consultation Thank you for consulting the Environment Agency on the above. We are pleased to note that flood risk management and river corridor enhancement are included in the draft infrastructure list of projects that will, or may be, wholly or partly funded by Community Infrastructure Levy. We welcome the Infrastructure Delivery Plan (IDP) Addendum detailed coverage of flood risk management and green infrastructure issues. We commend the council willingness to work closely with us to ensure that no development takes place within flood zones 2 and 3 to safeguard locations for potential flood storage.

The Environment Agency will continue working in conjunction with Surrey County Council and Reigate and Banstead Borough Council to develop flood alleviation schemes as part of the on-going flood risk management work underway across the Surrey County and clarify the responsibilities of different organisations involved in flood risk management.

Overall the Community Infrastructure Levy- Draft Charging Schedule appears to meet the statutory tests in accordance with Part 11 of the Planning Act 2008 (as amended) having complied with the requirements of the Act and the Community Infrastructure Levy regulations (as amended). It has also used appropriate available evidence to inform its preparation and has had regard to the Community Infrastructure Levy Guidance which sets out the main procedures local authorities need to follow when introducing and operating the community infrastructure levy.

Please do not hesitate to contact me should you wish to discuss this further.

Yours faithfully,

Charles Muriithi MRTPI Planning Specialist

Kent and South London Direct dial: 0203 263 8077 Direct e-mail: [email protected]

Environment Agency, Ergon House, Horseferry Road, London, SW1P 2AL 03708 506 506 [email protected] www.gov.uk/environment-agency

Reigate & Banstead Borough Council

Community Infrastructure Levy (CIL): Draft Charging Schedule

April 2015

Representations Form

How to submit your comments

This response form has two parts:  Part A: Personal Details  Part B: Your Views  Part C: Participation and Notification

We would strongly encourage you to respond to the consultation by completing the questions set out in this form. Please complete Parts A, B and C to assist us in considering your views. You are encouraged to provide as much explanation as possible, and where relevant, attach any available evidence to support your position.

Forms must be returned to Reigate & Banstead Borough Council by 5pm on 26 May 2015

You can return your form:

By post to: Planning Policy Team, Reigate & Banstead Borough Council Town Hall, Castlefield Road, Reigate, Surrey, RH2 0SH.

By e-mail to: [email protected]

All duly made responses and representations will be considered by the Council and will be passed to the independent examiner as part of the examination procedure. We are happy to provide information in other languages, large print, braille or on audio tape. Please contact our Help Line on 01737 276000 if you would like this service.

Part A: Personal Details If an agent is appointed please complete only the Title, Name and Organisation boxes in (1) but complete the full contact details of the agent in (2).

(1) Personal Details (2) Agents Details (if relevant) Title

Mr First name

Charles Last name

Muriithi Job title (if relevant) Planning Specialist Organisation (if relevant) Environment Agency Address

Environment Agency, Ergon House, Horseferry Road, London, SW1P 2AL

Postcode SW1P 2AL

Telephone No 0203 263 8077

Email address

charles.muriithi@environment- agency.gov.uk

Page 1 Part B: Your Views

Draft Charging Schedule and Proposed Charges

(1) Do you have any comments to make on the proposed rates of CIL and the supporting viability evidence (set out in the CIL Revised Viability Assessment Report and Appendices)? Yes No No

If you have answered ‘yes’, please provide further explanation, Please set out any evidence available to support your views

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

(2) Do you have any comments to make on the charging zone maps set out in the Draft Charging Schedule?

Yes No NO

If you have answered ‘yes’, please provide further explanation

(continue on a separate sheet/expand box if necessary) Page 1 Draft List of Relevant Infrastructure

(3) Do you have any comments to make on the draft list of relevant infrastructure?

Yes Yes No

If you have answered ‘yes’, please provide further explanation

We are pleased to note that flood risk management and river corridor enhancement is included in the draft infrastructure list of projects that will, or may be, wholly or partly funded by Community Infrastructure Levy.

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

Evidence Base

(4) Do you have any other comments to make on the evidence base and supporting documentation for the Draft Charging Schedule?

Yes Yes No

If you have answered ‘yes’, please provide further explanation Please make clear which document (i.e. Infrastructure Delivery Plan) and if possible any specific passages or tables your views refer to, particularly if you are making comments on multiple documents. Please set out any evidence available to justify your views.

We welcome the Infrastructure Delivery Plan (IDP) Addendum detailed coverage of flood risk management and green infrastructure issues. We commend the council willingness to work closely with us to ensure that no development takes place within flood zones 2 and 3 to safeguard locations for potential flood storage.

The Environment Agency will continue working in conjunction with Surrey County Council and Reigate and Banstead Borough Council to develop flood alleviation schemes as part of the on- going flood risk management work underway across the Surrey County and clarify the responsibilities of different organisations involved in flood risk management.

Page 2

(continue on a separate sheet/expand box if necessary) Part C: Participation and Notification

Requesting the right to be heard at examination

(5) Organisations and individuals making representations may request the right to be heard by the examiner. Do you consider it necessary to participate at the oral part of the examination?

No, I do not wish to participate at NO Yes, I wish to participate at the oral the oral examination examination

If you wish to participate at the oral examination, please outline why you consider this to be necessary

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

Please note: The examiner will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of any examination.

Requests to be notified

(6) Representations may also be accompanied by a request to be notified, at a specified address, of any of the following. Please indicate of which, if any, you wish to be notified.

(a) That the Draft Charging Schedule has been submitted to the Yes No examiner in accordance with section 212 of the Planning Act 2008

(b) The publication of the recommendations of the examiner and the Yes No reasons for those recommendations

Page 3 (c) The approval of the charging schedule by the charging authority Yes No

Signature: Date: 22/05/2015 Charles Muriithi

Page 4

?? May 2015 Reigate CIL Reps

Planning Policy Project Manager

David Wilson Sent by email to: [email protected] E: [email protected] DL: +44 (0) 1189520505 M: +44 (0) 7807 999431

Ground Floor, Hawker House 5-6 Napier Court Napier Road Reading RG1 8BW

savills.com

Dear Sir/Madam

REIGATE & BANSTEAD CIL –DRAFT CHARGING SCHEDULE CONSULTATION - COMMENTS ON BEHALF OF THAMES WATER

Thames Water Utilities Ltd (Thames Water) Property Services function is now being delivered by Savills (UK) Limited as Thames Water’s appointed supplier. Savills are therefore pleased to respond to the above consultation on behalf of Thames Water.

Thames Water are the statutory sewerage undertaker for the whole of the Borough and the statutory water undertaker for a very small area of the north west corner of the Borough and are hence a “specific consultation body” in accordance with the Town & Country Planning (Local Planning) Regulations 2012. We have the following comments on the CIL Draft Charging Schedule:

Thames Water provide essential water and wastewater infrastructure in order to support growth and deliver environmental improvements. That infrastructure provision can incorporate the provision of buildings such as a new sewage pumping station or a new sewage treatment building for example. The nature of such infrastructure buildings means that there is no impact on other forms of infrastructure requirements such as schools, open space and libraries. Thames Water therefore consider that water and wastewater infrastructure buildings should be exempt from payment of the Community Infrastructure Levy and this appears to be the case in the draft schedule where “All other development throughout the Borough” has a Nil charge which is supported by Thames Water.

The Council may however wish to consider using CIL contributions for enhancements to the sewerage network beyond that covered by the Water Industry Act and sewerage undertakers, for example by proving greater levels of protection for surface water flooding schemes. Sewerage undertakers are currently only funded to a circa 1:30 flood event.

We trust the above is satisfactory, but please do not hesitate to contact me if you have any queries.

Yours faithfully

David Wilson BA (Hons), BTP, MRTPI Associate Director Planning Error! AutoText entry not defined.Error! AutoText entry not defined. Offices and associates throughout the Americas, Europe, Asia Pacific, Africa and the Middle East.

Savills (UK) Limited. Chartered Surveyors. Regulated by RICS. A subsidiary of Savills plc. Registered in England No. 2605138. Registered office: 33 Margaret Street, London, W1G 0JD

Tel: 020 8541 9453

Email: [email protected]

Emailed to: [email protected]

Planning Policy Team Reigate and Banstead Borough Council Town Hall Environment & Castlefield Road Infrastructure Directorate Reigate Surrey Spatial Planning Team RH2 0SH Surrey County Council County Hall Kingston upon Thames KT1 2DN

26 May 2015

Dear Sir or Madam

Reigate & Banstead Community Infrastructure Levy Draft Charging Schedule

Thank you for consulting Surrey County Council on the Reigate & Banstead Community Infrastructure Levy Draft Charging Schedule. We have officer comments to make relating to developer contributions towards the provision of County Council infrastructure.

Paragraph 39 of the position statement states, “Improvements to, the expansion of, or the development of new schools and state-funded education facilities will be funded through CIL.” However it is mentioned elsewhere that there may be exceptional cases where planning obligations might be applied in addition to CIL. This sentence therefore needs to be amended to reflect the potential for developer contributions through S106 agreements.

Paragraph 40 sets out the scenarios where planning obligations may be sought rather than CIL contributions to partly fund provision. This seems to assume that development sites will not be of a sufficiently large scale, in themselves, to generate a pupil yield figure that would require a new school to meet the new demand from a single site. The Local Plan Core Strategy has identified broad areas search for urban extensions with the capacity for a maximum of just 700 homes and therefore single developments on a scale large enough to require a new school to serve their inhabitants are unlikely to come forward. However, in general terms, where the need for a school is not due to demographic change but is solely generated by a new development, we would expect the developer to entirely fund the new school required to serve the new development and ideally we would seek for the land to be provided as close to the development as possible. In addition we would seek contributions arising from large scale development via S106 agreements and not through CIL as this is likely to give certainty that a new school will be provided to support the new development. It would be useful if the principle that the developer is required to entirely fund the essential infrastructure where the need is solely generated by the new development through a planning obligation could be made explicit. The application of this principle is relevant to essential transport as well as to education provision.

It is understood that this principle which relates to planning obligations being made under Section 106 of the Town and Country Planning Act 1990 (as amended), would only apply where the legal tests set out in Regulation 122 and 123 of the Community Infrastructure Levy Regulations 2010 (as amended) are met.

Should you have any queries on this response, please contact Katharine Harrison.

Yours sincerely

Katharine Harrison Spatial Planning Team

Reigate & Banstead Borough Council

Community Infrastructure Levy (CIL): Draft Charging Schedule

April 2015

Representations Form

How to submit your comments

This response form has two parts: • Part A: Personal Details • Part B: Your Views • Part C: Participation and Notification

We would strongly encourage you to respond to the consultation by completing the questions set out in this form. Please complete Parts A, B and C to assist us in considering your views. You are encouraged to provide as much explanation as possible, and where relevant, attach any available evidence to support your position.

Forms must be returned to Reigate & Banstead Borough Council by 5pm on 26 May 2015

You can return your form:

By post to: Planning Policy Team, Reigate & Banstead Borough Council Town Hall, Castlefield Road, Reigate, Surrey, RH2 0SH.

By e-mail to: [email protected]

All duly made responses and representations will be considered by the Council and will be passed to the independent examiner as part of the examination procedure. We are happy to provide information in other languages, large print, braille or on audio tape. Please contact our Help Line on 01737 276000 if you would like this service.

Part A: Personal Details If an agent is appointed please complete only the Title, Name and Organisation boxes in (1) but complete the full contact details of the agent in (2).

(1) Personal Details (2) Agents Details (if relevant) Title Mr

First name Andrew

Last name Steen

Job title (if relevant) Associate Partner

Organisation (if relevant) White & Sons

Address 3 Massetts Road Horley

Postcode RH6 7PR

Telephone No 01293 824354

Email address [email protected]. uk

Page 1 Part B: Your Views

Draft Charging Schedule and Proposed Charges

(1) Do you have any comments to make on the proposed rates of CIL and the supporting viability evidence (set out in the CIL Revised Viability Assessment Report and Appendices)? Yes x No

If you have answered ‘yes’, please provide further explanation, Please set out any evidence available to support your views Our interest is limited to the residential charging of CIL, we have no comments on the charges for retail.

We support the provision of additional charge zones for this District following the previous consultation, particularly the new zones 1 and 3. The rates applying to these zones appear reasonable.

In addition, we would suggest that the conversion of empty rural buildings within the Urban Extension and rest of borough Charge Zone may also be unviable at the proposed £200 per square metre rate, since the existing use value of the building to be converted has not be taken into account within the accompanying viability assessment, which predominantly considers greenfield land. The Government did introduce new Permitted Development rights in April 2014, which allows, under specific circumstances, the conversion of agricultural buildings up to 450 sq metres to create a maximum of three dwellings. Consequently, applications to convert buildings last used for agriculture to residential dwellings are likely to increase in number over the forthcoming years.

There is concern at the level of charge for urban extensions that are yet to be allocated. It is agreed that the charge could be higher for these than urban developments, given that other costs will be lower. However, some (such as around Merstham and Horley) are in slightly lower value areas and so will be less viable than those in higher value areas such as south west Reigate. It is suggested that these should be subject of the same charge as the North West Sector of Horley, especially as some of the sites being promoted are separated from that allocation by no more than a road width and are effectively subject of the same viability considerations as the North West Sector.

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

(2) Do you have any comments to make on the charging zone maps set out in the Draft Charging Schedule?

Yes x No

If you have answered ‘yes’, please provide further explanation Please see above comment regarding Zone 5. It is suggested that the areas for potential allocations around Merstham and Horley should be incorporated into Zone 4. The boundaries for these could be:

Horley – boundaries to match those of the rural surrounds of Horley (i.e. not including any Green Belt); Merstham – all that to the south, east and north of Merstham up to the Borough boundary and M23/M25.

(continue on a separate sheet/expand box if necessary) Page 1 Draft List of Relevant Infrastructure

(3) Do you have any comments to make on the draft list of relevant infrastructure?

Yes No x

If you have answered ‘yes’, please provide further explanation

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

Evidence Base

(4) Do you have any other comments to make on the evidence base and supporting documentation for the Draft Charging Schedule?

Yes x No

If you have answered ‘yes’, please provide further explanation Please make clear which document (i.e. Infrastructure Delivery Plan) and if possible any specific passages or tables your views refer to, particularly if you are making comments on multiple documents. Please set out any evidence available to justify your views. See above comment regarding the viability of land in the North West Sector and that of other land surrounding Horley.

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

Page 2 Part C: Participation and Notification

Requesting the right to be heard at examination

(5) Organisations and individuals making representations may request the right to be heard by the examiner. Do you consider it necessary to participate at the oral part of the examination?

No, I do not wish to participate at the Yes, I wish to participate at the oral x oral examination examination

If you wish to participate at the oral examination, please outline why you consider this to be necessary To ensure our concerns are fully understood and considered.

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

Please note: The examiner will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of any examination.

Requests to be notified

(6) Representations may also be accompanied by a request to be notified, at a specified address, of any of the following. Please indicate of which, if any, you wish to be notified.

(a) That the Draft Charging Schedule has been submitted to the Yes x No examiner in accordance with section 212 of the Planning Act 2008

(b) The publication of the recommendations of the examiner and the Yes x No reasons for those recommendations

Signature: Date: 26 May 2015

Page 3

Reigate & Banstead Borough Council

Community Infrastructure Levy (CIL): Draft Charging Schedule

April 2015

Representations Form

How to submit your comments

This response form has two parts: • Part A: Personal Details • Part B: Your Views • Part C: Participation and Notification

We would strongly encourage you to respond to the consultation by completing the questions set out in this form. Please complete Parts A, B and C to assist us in considering your views. You are encouraged to provide as much explanation as possible, and where relevant, attach any available evidence to support your position.

Forms must be returned to Reigate & Banstead Borough Council by 5pm on 26 May 2015

You can return your form:

By post to: Planning Policy Team, Reigate & Banstead Borough Council Town Hall, Castlefield Road, Reigate, Surrey, RH2 0SH.

By e-mail to: [email protected]

All duly made responses and representations will be considered by the Council and will be passed to the independent examiner as part of the examination procedure. We are happy to provide information in other languages, large print, braille or on audio tape. Please contact our Help Line on 01737 276000 if you would like this service.

Part A: Personal Details If an agent is appointed please complete only the Title, Name and Organisation boxes in (1) but complete the full contact details of the agent in (2).

(1) Personal Details (2) Agents Details (if relevant) Title

Mr First name Brian

Last name Woods

Job title (if relevant) Managing Director

Organisation (if relevant) WS Planning & Architecture

Address Europe House, Bancroft Road, Reigate, Surrey

Postcode RH2 7RP

Telephone No 01737 225711

Email address [email protected]

Page 1 Part B: Your Views

Draft Charging Schedule and Proposed Charges

(1) Do you have any comments to make on the proposed rates of CIL and the supporting viability evidence (set out in the CIL Revised Viability Assessment Report and Appendices)? Yes √ No

If you have answered ‘yes’, please provide further explanation, Please set out any evidence available to support your views

Notwithstanding the proposed changes in the charging schedule, our concerns regarding the build cost assumptions made in the revised viability report still remain. Our clients generally build houses in the area defined as Zone 2 i.e. Reigate and settlements within the north of the Borough. The Council’s Viability Report states that development in these areas are windfall sites and as such “only a small allowance (50 dwellings per annum) from windfalls is relied upon in order to meet the housing target over the plan period”. On this basis therefore the Council are not expecting substantial amounts of funding to be raised through CIL in these particular areas and therefore the proposed charge of £180 per m² seems to be excessive and is significantly greater than proposed in the towns of Redhill and Horley.

In general houses within the Zone 2 charging area are more expensive than in other parts of the Borough and tend to comprise larger individually designed dwellings with a high specification and constructed at a much lower density. These dwellings are more expensive to construct than the build costs contained in the Viability Report. Individual clients have submitted details of actual built costs which have previously been sent to the Council. We have since received an additional comment from a client set out as follows:

“I’ve just priced 3 houses of around 2000 square feet and the gross cost is £182 per square foot or 1959 per square metre. This is with no abnormals. This is not the high end stuff we do which will be well over £200 per square foot, particularly in the north of the Borough.”

Our clients have also advised that the assumptions made in the report do not allow for costs relating to securing finance to build a development and the time periods for building have been under estimated. In addition the Viability Report makes an assumption that the build costs set out in Table 10 reduce for developments comprising 5 units and above and we are advised by our clients that this is not the case. On average build costs would not reduce significantly on schemes of 15 units and under.

Furthermore we note that a charge of £200 per m² is made for Green Belt sites. However there should be a lower charge for “pdl” sites in the Green belt as remedial measures clearly increase the cost of developing such sites.

Page 1

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

(2) Do you have any comments to make on the charging zone maps set out in the Draft Charging Schedule?

Yes √ No

If you have answered ‘yes’, please provide further explanation

The draft charging schedule maps are too small in scale and thus will lead to uncertainty as to the relevant charge. This could make a significant difference to our clients particularly at land assembly stage and in negotiations with landowners.

(continue on a separate sheet/expand box if necessary) Draft List of Relevant Infrastructure

(3) Do you have any comments to make on the draft list of relevant infrastructure?

Yes √ No

If you have answered ‘yes’, please provide further explanation

We have previously made comments on the length of the IDP and in particular the number of highway related projects. According to the IDP many of these projects state that they will be partially funded by CIL and then state that other funding is not available. Therefore there are serious doubts as to whether the schemes in the IDP are actually deliverable.

Our clients are also concerned about the potential for overlap and double counting between CIL and Section 106 payments for the provision of education and highways and transport. It is questioned why CIL is necessary to fund additional primary form of entry in the Banstead/Tadworth area when there is a surplus of capacity in this area of the Borough.

We would also reiterate our previous comments regarding the inclusion of super-fast broadband in the IDP. Page 2

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

Evidence Base

(4) Do you have any other comments to make on the evidence base and supporting documentation for the Draft Charging Schedule?

Yes √ No

If you have answered ‘yes’, please provide further explanation Please make clear which document (i.e. Infrastructure Delivery Plan) and if possible any specific passages or tables your views refer to, particularly if you are making comments on multiple documents. Please set out any evidence available to justify your views.

The evidence base gives unrealistically low building costs and this has been clearly set out in our client’s separate representations.

(continue on a separate sheet/expand box if necessary) Part C: Participation and Notification

Page 3 Requesting the right to be heard at examination

(5) Organisations and individuals making representations may request the right to be heard by the examiner. Do you consider it necessary to participate at the oral part of the examination?

No, I do not wish to participate at the Yes, I wish to participate at the oral √ oral examination examination

If you wish to participate at the oral examination, please outline why you consider this to be necessary

We represent a number of local house builders who over the years have make significant contribution to the Council’s housing land supply albeit on smaller windfall sites. Our clients have extensive local knowledge regarding land values and build costs on the Borough and it is important that this is imparted to the Inspector at the Examination.

We consider it necessary to attend the Examination to ensure that the evidence base has been properly tested and that the proposed charging levels are fair and made on the correct basis.

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

Please note: The examiner will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of any examination.

Requests to be notified

(6) Representations may also be accompanied by a request to be notified, at a specified address, of any of the following. Please indicate of which, if any, you wish to be notified.

(a) That the Draft Charging Schedule has been submitted to the Yes √ No examiner in accordance with section 212 of the Planning Act 2008

(b) The publication of the recommendations of the examiner and the Yes √ No reasons for those recommendations

Signature: Date: 26/05/2015

Page 4

Page 5 our ref: TD/Q50547 your ref: email: [email protected] date: 26 May 2015

Planning Policy Team Reigate & Banstead Borough Council Town Hall, Castlefield Road Reigate Surrey

RH2 0SH

By Email

Dear Sir/Madam,

REIGATE AND BANSTEAD BOROUGH COUNCIL: COMMUNITY INFRASTRUCTURE LEVY DRAFT CHARGING SCHEDULE

I am writing on behalf of Berkeley to respond to your consultation on the Reigate and Banstead Council's Draft Charging Schedule (DCS).

Berkeley has an interest in land to the east of Redhill which forms part of a Sustainable Urban Extension (SUE) identified in the Council’s Core Strategy (2014). Berkeley is, therefore, keen to ensure that the introduction of the Community Infrastructure Levy (CIL) achieves its intended objective of supporting housing growth by ensuring the delivery of necessary infrastructure.

We responded previously in January 2015 to the consultation on the Preliminary Draft Charging Schedule (PDCS) (copy attached) and would request that the Council and Examiner read our two representations in conjunction as most of our previous points remain relevant.

We welcome the additional work that the Council has undertaken and the reduction in the proposed CIL rate in Charge Zone 5. However, we remain concerned that the approach still does not properly assess the infrastructure needs and requirements or viability of the proposed Sustainable Urban Extensions (SUEs) and, as such, does not justify the residential rate proposed for these locations.

The attached consultation form sets out our response in detail but we thought it would be useful to briefly summarise our key concerns here:

 The SUEs are critical to the delivery of the Council’s Development Plan and should, therefore, be assessed as strategic sites;

 The current assessments in the Viability Study for SUEs are for 150 and 300 dwelling generic developments. The Core Strategy, however, suggests that SUEs are likely to deliver between 500 to 700 homes;

 While it is anticipated that the SUEs will be delivered through several individual sites, their likely cumulative infrastructure requirements need to be assessed and confirmed. The Council, however, has not undertaken any detailed infrastructure planning work for the SUEs. Therefore, the assumptions about residual S106 and other costs are not based on evidence, and, given that the Council recognises that planning obligations are likely to be higher for developments of over 500 homes, this could significantly understate the likely residual s106 obligations relevant to the SUEs;

 The cost assumptions set out in the Revised Viability Assessment Report for the Urban Extension to the North West of Horley (which is based on actual evidence) include Section 106 obligations that are £4,000 higher per dwelling than the cost allowance for the SUEs. Furthermore, the total cost of ‘opening up’, Section 106 and Associated Infrastructure is £7,000 higher for North West of Horley. If applied to the SUEs, this level of cost would reduce the amount ‘available’ for CIL by up to £100 per square metre for a 3 bedroom house;

 The currently proposed approach to Section 106 and the Regulation 123 list does not provide any confidence that Section 106 obligations would be scaled back for the SUEs as it allows Section 106 contributions to continue to be required for all items on individual sites and provides no evidence of when and where such obligations would be required. Given the uncertainty over infrastructure requirements and the potential for them to disproportionately affect specific sites, we are of the view that the Council should confirm its intention to allow ‘in-kind’ provision of land and/or infrastructure in appropriate circumstances.

We noted previously that the Council was due to publish its preferred options public consultation draft ‘Development Management Policies’ (DMP) document which would identify specific sites within the SUE broad locations identified in the Core Strategy. This will allow a proper assessment of obligations for these sites. In the meantime, it is our view that the Council should take a precautionary approach and set a lower CIL rate of £120 per sqm for the SUEs based on the evidence from the actual development at North West of Horley.

Berkeley is keen to continue to engage in the CIL charge setting process and would be happy to discuss any of these points further with the Council and its advisers.

If you require any further information, please do not hesitate to contact me.

Yours faithfully,

Tom Dobson Director cc. Jonathan Lambert - Berkeley

Reigate & Banstead Borough Council

Community Infrastructure Levy (CIL): Draft Charging Schedule

April 2015

Representations Form

How to submit your comments

This response form has two parts:  Part A: Personal Details  Part B: Your Views  Part C: Participation and Notification

We would strongly encourage you to respond to the consultation by completing the questions set out in this form. Please complete Parts A, B and C to assist us in considering your views. You are encouraged to provide as much explanation as possible, and where relevant, attach any available evidence to support your position.

Forms must be returned to Reigate & Banstead Borough Council by 5pm on 26 May 2015

You can return your form:

By post to: Planning Policy Team, Reigate & Banstead Borough Council Town Hall, Castlefield Road, Reigate, Surrey, RH2 0SH.

By e-mail to: [email protected]

All duly made responses and representations will be considered by the Council and will be passed to the independent examiner as part of the examination procedure. We are happy to provide information in other languages, large print, braille or on audio tape. Please contact our Help Line on 01737 276000 if you would like this service.

Part A: Personal Details If an agent is appointed please complete only the Title, Name and Organisation boxes in (1) but complete the full contact details of the agent in (2).

(1) Personal Details (2) Agents Details (if relevant) Title Mr.

First name Thomas

Last name Dobson

Job title Director (if relevant)

Organisation Quod (if relevant)

Address Ingeni Building 17 Broadwick Street London

Postcode W1F 0AX

Telephone No 020 3597 1025

Email address [email protected]

Page 1 Part B: Your Views

Draft Charging Schedule and Proposed Charges

(1) Do you have any comments to make on the proposed rates of CIL and the supporting viability evidence (set out in the CIL Revised Viability Assessment Report and Appendices)? Yes X No

If you have answered ‘yes’, please provide further explanation, Please set out any evidence available to support your views We responded to the previous consultation on the Preliminary Draft Charging Schedule (PDCS) on behalf of Berkeley. This response, together with its covering letter, should be read alongside those representations most of which remain relevant.

Our response was focussed principally on the Sustainable Urban Extensions (SUEs) proposed in the Reigate and Banstead Core Strategy (Policy CS6 (3)). We noted previously that the viability assessment undertaken by the Council did not address the specific viability issues of these broad locations, which are necessary to secure the delivery of the Local Plan (Core Strategy).

Whilst we welcome the additional work that the Council has undertaken in relation to its Viability Assessment, and the reduction in proposed CIL rates for SUEs from £240 to £200, we remain concerned that this rate continues to put the viability of such developments at risk and that the Viability Assessment does not use appropriate available evidence on which to draw its conclusions in relation to these sites.

To re-iterate our point from previous representations, the Core Strategy (Policy CS6 (3)) identifies that the Council will need to allocate land for urban extensions. The Core Strategy identifies the need for new homes to be provided as urban extensions in the following broad locations: to the East of Redhill and East of Merstham (within which Berkeley has a land interest), and to the South and South West of Reigate (with 500-700 homes in each location).

In contrast, the Council’s Viability Assessment tests only two typologies for Urban Extensions – for 150 and 300 homes – and this remains unchanged in the new Viability Assessment. This approach is justified within the Viability Assessment on the grounds that the urban extensions will most likely be developed through a number of sites rather than a single large development of 500-700 homes.

The approach which has been taken in relation to this issue is important as the Council has previously accepted that it is larger developments of 500 homes or more that are likely to have higher on-site planning obligations as they have to pay for strategic items such as roads or schools. This is also acknowledged in the Position Statement on the use of CIL and Section 106 Agreements (March 2015). The Table on pages 6 and 7 of that document identifies a list of potential planning requirements and to which type of developments they may continue to apply. It shows that all of them may apply to “‘Strategic Scale Housing Developments Such as Urban Extensions”. This includes expensive items of infrastructure such as schools and roads.

The Council acknowledges in its Updated Infrastructure Delivery Plan Addendum (March 2015) that site specific infrastructure needs for SUEs are likely to arise (paragraph 1.4) but these cannot be confirmed until site specific proposals are developed.

Instead of a properly costed approach, the Viability Assessment states that it applies a £10,000 per dwelling Section 106 assumption for SUEs. This compares to £14,300 which is assumed in the

Page 1 Viability Assessment for the actual Urban Extension at North West of Horley, which the Council suggests is based on a detailed assessment of actual infrastructure requirements and costs.

In fact, the actual appraisals allow an uplift of £7,000 per dwelling for the combined costs of external and enabling works, abnormals, link roads and Section 106 for the land North West of Horley compared to the two SUEs considered as part of an appendix to the Viability Study (pages 50 to 52). If the additional £7,000 per dwelling cost were applied to the Sustainable Urban Extensions it would reduce the amount ‘available’ for CIL by up to £100 per sqm for market dwellings depending on the dwelling mix.

The Council’s background evidence document of recent section 106 contributions (March 2015) also suggests that the Council may be understating the residual impact of Section 106 for SUEs. This notes that current charges (outside of the Horley Tariff area) are £14,777 for a 100sqm 3 bedroom house. This is what the Council is currently charging.

It should be noted that the statutory tests for planning obligations have been in force since April 2010 and, therefore, the Council believes that these obligations would meet those tests. This would continue to be the case after CIL has been introduced with the only constraints being what is included on the Council’s Draft List of Relevant Infrastructure and restrictions on pooling. This would be likely to limit the use of such an approach on smaller sites, but for larger sites such as SUEs, we are of the view that this amount provides a reasonable benchmark for what the Council is likely to require as evidenced by the assumptions made for the North West of Horley appraisal.

On the basis of previous experience in Horley and of other Councils’ approaches to planning for the SUEs, in practice Reigate and Banstead Council is likely to require the sites within an SUE area to meet the ‘cumulative’ impacts of their development (e.g. schools and roads) and this will increase the likely level of obligations above those assumed for ‘standalone’ 150 or 300 unit developments in the Viability Assessment.

To off-set this increase in Section 106 costs, the Council needs to apply a higher assumed Section 106 requirement for such sites in the Viability Assessment and reduce the proposed CIL rate for SUEs to at least the £180 per sqm level it has proposed for North West of Horley and probably lower to the £120 per sqm that we recommended in our previous representations.

If on the other hand, the Council intends to use CIL funding to fund the delivery of infrastructure to address the cumulative impacts of more than one urban extension site, then it should confirm this in its Draft Infrastructure List and Position Statement on the use of CIL and Section 106 funding.

In this respect, we note that the Council’s own sensitivity testing, at Table 17 of the Revised Viability report suggests that minor changes to assumptions, including those on Section 106 would push the SUE developments to the margins of viability. We also note that Table 15 incorrectly states that, using the Council’s methodology, the ‘surplus available for CIL’ from a 300 unit SUE is £312 per sqm when in fact it is £280 per sqm as stated elsewhere in the document.

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

Page 2

(2) Do you have any comments to make on the charging zone maps set out in the Draft Charging Schedule?

Yes X No

If you have answered ‘yes’, please provide further explanation

The revised Charging Zones map continues to show a single Urban Extension at North West of Horley and a Rest of the Borough Charge Zone. The Council justifies this approach on the basis that the SUEs currently comprise broad areas of search rather than specific sites. If the Council wished to reduce the CIL rate for SUEs it could identify the broad areas on the map and retain a higher rate for the Rest of the Borough area.

(continue on a separate sheet/expand box if necessary) Draft List of Relevant Infrastructure

(3) Do you have any comments to make on the draft list of relevant infrastructure?

Yes X No

If you have answered ‘yes’, please provide further explanation The Draft List of Relevant Infrastructure provides a useful ‘general’ basis for understanding the likely types of obligations that will or may be funded by CIL and those for which Section 106 obligations will continue to be required.

The Draft List of Relevant Infrastructure and the other background infrastructure planning work does not however provide any level of certainty in relation to the SUEs. As the document is currently drafted, the Council may require any of the obligations for an SUE site, in addition to CIL, without having provided any proper evidence at examination stage as to what the cost of such obligations will be.

As we noted in our response to the PDCS consultation, the NPPG CIL Guidance (Paragraph: 097 Reference ID: 25-097-20140612) states that:

“Where the regulation 123 list includes a generic type of infrastructure (such as ‘education’ or transport’), section 106 contributions should not be sought on any specific projects in that category. Site specific contributions should only be sought where this can be justified with reference to the underpinning evidence in infrastructure planning which was made publically available at the charging schedule examination.”

At present we are of the view that no such information has been provided in relation to SUEs and that it needs to be available to enable developers and landowners in those potential locations to understand likely obligations and respond to this consultation effectively. Without such evidence we do not believe that the Council has provided appropriate available evidence to set the proposed CIL charge for SUEs.

(continue on a separate sheet/expand box if necessary) Page 3

Evidence Base

(4) Do you have any other comments to make on the evidence base and supporting documentation for the Draft Charging Schedule?

Yes X No

If you have answered ‘yes’, please provide further explanation Please make clear which document (i.e. Infrastructure Delivery Plan) and if possible any specific passages or tables your views refer to, particularly if you are making comments on multiple documents. Please set out any evidence available to justify your views.

The Community Infrastructure Levy Explanatory Document (April 2015) refers (at the bottom of Page 8 and top of Page 9) to Discretionary Reliefs. Although not an issue for the Examination we would re-iterate our view that the Council should allow for such reliefs, particularly that for Exceptional Circumstances.

The potential for in-kind contributions of infrastructure or land (allowed under Regulations 73 and 73a of the CIL regulations) does not appear to be mentioned either in the Explanatory Document or Position Statement on the use of CIL and Section 106 agreements. As we noted in our response to the PDCS, given the likely on-site requirements in SUEs which may meet strategic needs beyond that particular site, it is essential that the Council confirms that it will consider the use of such contributions towards CIL liabilities.

(continue on a separate sheet/expand box if necessary) Part C: Participation and Notification

Requesting the right to be heard at examination

(5) Organisations and individuals making representations may request the right to be heard by the examiner. Do you consider it necessary to participate at the oral part of the examination?

No, I do not wish to participate at the Yes, I wish to participate at the oral x oral examination examination

If you wish to participate at the oral examination, please outline why you consider this to be necessary

Our response to this consultation has asked the Council to provide further evidence in a number of areas. If the Council produces such information, or if the Examiner raises specific questions in relation to these issues, we would like to reserve a right to appear at a hearing if one should be held.

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

Please note: The examiner will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of any examination.

Requests to be notified

(6) Representations may also be accompanied by a request to be notified, at a specified address, of any of the following. Please indicate of which, if any, you wish to be notified.

Page 4

(a) That the Draft Charging Schedule has been submitted to the Yes X No examiner in accordance with section 212 of the Planning Act 2008

(b) The publication of the recommendations of the examiner and the Yes X No reasons for those recommendations

Signature: Date:

26 May 2015

Page 5 our ref: TD/Q50547 your ref: email: [email protected] date: 12 January 2015

LDF Team, Reigate & Banstead Borough Council Town Hall, Castlefield Road, Reigate, Surrey, RH2 0SH

Dear Sir/Madam,

REIGATE AND BANSTEAD DISTRICT COUNCIL: COMMUNITY INFRASTRUCTURE LEVY PRELIMINARY DRAFT CHARGING SCHEDULE

I am writing on behalf of Berkeley to respond to your consultation on the Council's Preliminary Draft Charging Schedule (PDCS).

Berkeley has an interest in land to the east of Redhill which forms part of a Sustainable Urban Extension identified in the Council’s Core Strategy. They are therefore keen to ensure that the introduction of the Community Infrastructure Levy (CIL) achieves its intended objective of supporting housing growth by supporting the delivery of necessary infrastructure.

Berkeley welcomes the comprehensive set of documents which the Council has produced to support this consultation, and particularly on the early guidance on the likely future approach to S106 and the draft Regulation 123 list.

We are however concerned that the approach currently does not properly assess the infrastructure needs and requirements or viability of the proposed Sustainable Urban Extensions and as such does not justify the higher residential rate proposed for these locations.

The attached form sets out our response in detail but we thought it would be useful to briefly summarise our key concerns here:

 The Sustainable Urban Extensions (SUEs) are critical to the delivery of the plan and should therefore be assessed as strategic sites;

 The current assessments in the Viability Study for SUEs are for 150 and 300 dwelling generic developments, however the Core Strategy suggests that they are likely to be in the range of 500 to 700 homes.

 While it is likely that the SUEs will be delivered through several individual sites their likely cumulative infrastructure requirements need to be assessed and confirmed;

 The Council has not undertaken any detailed infrastructure planning work for the SUEs and therefore the assumptions about residual S106 and other costs are not based on evidence, and, given that the Council recognises that planning obligations are likely to be higher for developments of over 500 homes this could significantly understate the likely residual s106 obligations relevant to the SUEs which are identified in the Core Strategy for 500 – 700 dwellings;

 The proposed CIL rates for SUEs would imply a contribution of £24,000 CIL per typical private 3 bed house, along with assumed £20,000 ‘opening up’ and residual Section 106 requirements. This compares to £14,777 on the basis of the current ‘tariff’. This is a very significant uplift and is not justified by the published evidence. On the basis of the evidence currently available we are of the view that the proposed CIL rate should be akin to that of the urban areas (ie. £120/sqm);

 The currently proposed approach to Section 106 and the Regulation 123 list does not provide any confidence that Section 106 obligations would be limited even to this level for the SUEs, as it allows Section 106 contributions to continue to be required for all items on individual sites and provides no evidence of when and where such obligations would be required. Given the uncertainty over infrastructure requirements and the potential for them to disproportionately affect specific sites we are of the view that the Council should confirm its intention to allow ‘in kind’ provision of land and/or infrastructure in appropriate circumstances.

We are aware that the Council will shortly (Autumn 2015) be publishing its preferred options public consultation draft ‘Development Management Policies’ (DMP) document. This document will allocate sites based on the SUE broad locations identified in the Core Strategy. We would request that as part of that process the Council consider the approach to infrastructure delivery for the SUEs in the necessary level of detail to allow the need for, and appropriate level of, any CIL charge to be determined in line with the regulations and guidance.

Berkeley is keen to continue to engage in the Charge Setting process and would be happy to discuss any of these points further with the Council and its advisers.

If you require any further information please do not hesitate to contact me.

Yours faithfully,

Tom Dobson Director cc. Jonathan Lambert - Berkeley

Reigate & Banstead Borough Council

Community Infrastructure Levy (CIL): Preliminary Draft Charging Schedule

November 2014

Representations Form

How to submit your comments

This response form has two parts:  Part A: Personal Details  Part B: Your Views

We would strongly encourage you to respond to the consultation by completing the questions set out in this form. Please complete both Part A and Part B to assist us in considering your views. You are encouraged to provide as much explanation as possible, and where relevant, attach any available evidence to support your position.

Forms must be returned to Reigate & Banstead Borough Council by 5pm on Monday 12 January 2015

You can return your form:

By post to: LDF Team, Reigate & Banstead Borough Council Town Hall, Castlefield Road, Reigate, Surrey, RH2 0SH.

By e-mail to: [email protected]

All duly made responses and representations will be considered by the Council in the preparation of its final Draft Charging Schedule. We are happy to provide information in other languages, large print, braille or on audio tape. Please contact our Help Line on 01737 276000 if you would like this service.

Part A: Personal Details If an agent is appointed please complete only the Title, Name and Organisation boxes in (1) but complete the full contact details of the agent in (2).

(1) Personal Details (2) Agents Details (if relevant) Title Mr.

First name Thomas

Last name Dobson

Job title Director (if relevant)

Organisation Quod (if relevant)

Address Ingeni Building 17 Broadwick Street London

Postcode W1F 0AX

Telephone No 020 3597 1025

Email address [email protected]

Page 1 Part B: Your Views

Infrastructure Needs and Funding Gap

(1) Do you agree that the infrastructure needs and funding gap analysis demonstrates that there is justification for introducing a Community Infrastructure Levy in Reigate & Banstead? Yes No X

If you have answered ‘no’, please provide further explanation As noted in our covering letter this response is focussed principally on the Sustainable Urban Extensions (SUEs) proposed in the Reigate and Banstead Core Strategy 2014 (Policy CS6 (3)). We note that the Core Strategy assumes that such sites will come forward later in the plan period and are therefore currently identified as ‘Broad Locations’. The Sustainability Assessment Addendum Report (2012) which underpinned their allocation within the Plan did not undertake any detailed assessment of Infrastructure Requirements, nor did the Infrastructure Delivery Plan (2012) on which the Council is basing its evidence for the CIL examination.

We will demonstrate, below, that in the absence of such an analysis the assumptions contained in the CIL Viability Assessment (October 2014) in relation to obligations for on-site infrastructure (paragraphs 4.53 to 4.59) are not based on appropriate available evidence and cannot therefore justify a specific (and higher) CIL charge for Strategic Urban Extensions.

We note that the Council will shortly (Autumn 2015) be publishing its preferred options public consultation draft ‘Development Management Policies’ (DMP) document which will allocate specific sites within the SUE Broad Locations. We would request that as part of that process the Council consider the approach to infrastructure delivery for such sites in appropriate detail to allow the need for, and appropriate level of, any CIL charge to be determined in line with the regulations and guidance.

Charge Setting and Proposed Charging Rates

(2) Do you agree with: (a) The scope and range of schemes tested in the CIL Yes No X Viability Assessment?

(b) The methodology and assumptions adopted in the Yes No X study?

If you have answered ‘no’ to either of the above, please provide further explanation of how you feel the study should be revised and include any relevant evidence to support your views Regulation 14 of the CIL Regulations requires local authorities to strike a balance between the need for investment to support development and the impacts on the viability of that development.

In producing viability evidence:

The focus should be in particular on strategic sites on which the relevant Plan relies and those sites (such as brownfield sites) where the impact of the levy is likely to be most significant. (PPG: Reference ID: 25-019-20140612) The Council recognises the need for the assessment of strategic sites and includes three typologies which it regards as reflecting those included in the Core Strategy (2014). These are Land North West of Horley (1,510 homes), a 150 home Urban Extension and a 300 home Urban Extension. Page 1

The Core Strategy 2014 (Policy CS6 (3)) identifies that the Council will allocate land for urban extensions in three locations: adjoining Horley, East of Redhill and East of Merstham, and South and South West of Reigate. The policy itself does not include numbers of homes, but the supporting text (paragraph 6.2.8) identifies up to 200 homes for Horley and up to 500 to 700 new homes in each of the other two locations. These SUEs are clearly sites on which the relevant plan relies as confirmed by the Inspector’s Report into the Reigate and Banstead Core Strategy (January 2014) which required modifications to strengthen policies on these sites in order for the plan to be found Sound (MM2, MM9 and MM10).

The report goes on to confirm (at paragraph 63) that the top end of the range for SUEs (700 homes) would be likely to be required to deliver the Council’s overall housing target. Even then the Council would be delivering below objectively assessed need and is encouraged to maximise provision from these sources (paragraph 69).

Given these plan imperatives the Council should in our view a) be testing appropriate site typologies for Sustainable Urban Extensions and b) act with caution in setting CIL rates given the critical importance of these sites for the delivery of the Local Plan (Core Strategy).

We therefore question the choice of typologies for the SUEs in the Council’s CIL Viability Appraisal (150 home urban extension and 300 home urban extension), which should at least test the 500 home and 700 home options. The Council itself notes, in the Position Statement on the use of CIL and Section 106 agreements (2014), at paragraph 40, that it is developments exceeding 500 units which are most likely to have significant remaining on site non-CIL infrastructure requirements.

Whilst it is likely that the SUEs will be comprised of several smaller sites, possibly of between 150 and 300 dwellings, it remains the case that the cumulative impacts of such developments may require strategic on site infrastructure to be provided to serve the SUE. The Council’s viability testing of strategic site typologies of 150 and 300 dwellings has not had regard to the potential strategic on site infrastructure requirements arising from the SUEs.

In assessing its smaller SUE typologies the Council’s Viability Study makes a number of assumptions about likely development costs. These include assumptions of £10,000 per dwelling for ‘opening up costs’, and £10,000 per dwelling for residual Section 106 requirements. These assumptions do not appear to be based on any evidence and, as we note above, the Council has yet to undertake any infrastructure assessment for the SUE sites. Based on the experience of Quod and Berkeley, is it is likely that the assessment of the actual infrastructure needs of the SUEs will demonstrate that the broad and unsubstantiated allowance made in the viability appraisal of £10,000 per dwelling for ‘opening up costs’, and £10,000 per dwelling for residual Section 106 requirements is inadequate and that in fact such costs are significantly in excess of the allowances made.

It is noted that it is anticipated that such sites will come forward later in the Plan Period, and that the Council may consider that it will not have the necessary evidence to set specific rates until the DMP is produced and specific sites are allocated.

Nevertheless evidence was presented to the Core Strategy examination that the Council’s dependence on urban housing site supply in the early stages of the plan could put delivery at risk. The Inspector advised the Council in his report not to be complacent with regard to supply (paragraph 69) and it is possible that the SUEs may be required earlier if other sites are not delivered. The Council will be aware that once a CIL Charging Schedule is adopted it remains in place until a Council chooses to withdraw or replace it, regardless of actual impacts on viability.

Page 2 The Council therefore needs to ensure that it takes a prudent approach to the SUE sites now and ensures that they will be deliverable over the plan period. If the Council wishes to set a site specific rate for these sites it should be on the basis only of viability, based on appropriate evidence and the testing of relevant strategic site typologies of 500 and 700 dwellings. At present we are of the view that the Council has not produced appropriate evidence to support its variation in rates.

(3) Do you agree that, in general, the proposed charging rates strike an appropriate balance between helping to fund infrastructure and the potential effects of CIL on the economic viability of development and overall delivery of Local Plan development needs?

Yes No X

If you have answered ‘no’, please provide further explanation including identifying where you feel the proposed charges deviate from the evidence The PDCS proposes a CIL rate of £120/sqm within the Urban Charge Zone and £240/sqm in the Urban Extension and Rest of Borough Charge Zone.

As we have noted above we do not believe that the Council has provided evidence to justify the higher rate for SUEs and that this will materially impact on the delivery of the Local Plan housing requirement as these sites are critical to the soundness of and delivery of the Local Plan (Core Strategy).

On the basis of its assessment the Council concludes that the SUEs can support a higher rate of CIL than either Urban Sites or the Land North West of Horley. For an indicative 3 bedroom private house this would equate to £24,000 per dwelling, in addition to the £20,000 per dwelling cost for ‘opening up’, and Section 106 obligations. This compares to the current Planning Infrastructure Contributions charge of £14,777 (CIL Background Evidence of recent Section 106 Contributions and Affordable Housing (2014) Table 1). This is a very significant uplift in total likely obligations.

In the case of the SUEs the Council has not provided the infrastructure evidence base to enable it to judge a balance between viability and infrastructure delivery as it has not determined what infrastructure needs to be delivered and how it will be funded, and has not tested the relevant strategic site typologies. On the basis of the current evidence we would suggest that a single rate of £120 be adopted for both the Urban Area (as currently proposed) and the SUEs.

(4) Do you agree that setting charges 30% below the maximum viable rates reflects a reasonable ‘buffer’ or margin in response to the requirements of the Practice Guidance?

Yes No X

If you have answered ‘no’, please provide further explanation In our view such ‘buffers’ or ‘margins’ are more appropriate for dealing with the large numbers of smaller sites in a CIL viability assessment and are usually somewhere between 25% and 50%.

The purpose of assessing strategic sites however is to take a more fine grained view and to understand the likely costs and values sufficient to demonstrate broad deliverability at the plan making level. This will require site specific judgement and should not be subject to such a broad brush approach. (continue on a separate sheet/expand box if necessary)

Page 3 Residential Charges

(5) Do you consider that the: (a) Proposed residential charges are suitably informed Yes No X by the evidence of viability?

(b) Geographic zones defined in the charging schedule Yes No X are appropriate?

(d) Proposal to apply a nil rate to care homes is Yes n/a No n/a justified?

Please provide further explanation below – particularly if you have answered ‘no’ to any of the questions above - making clear which specific point your comments refer to (i.e. (a), (b) etc.). Please provide supporting evidence where available. As we have noted above the Council’s approach to setting CIL rates for SUEs is not based on an appropriate methodology and therefore there is no basis for which the Council to set the proposed variable rates. The rates are neither justified in the basis of viability arising from the size of development (because it has not assessed 500 and 700 home examples), nor by location.

Retail Charges

(6) Do you consider that the: (a) Proposed retail charge is suitably informed by the Yes n/a No n/a evidence of viability?

(b) Proposal to apply a nil rate to all retail other than Yes n/a No n/a convenience retail uses is justified?

Charges for other uses

(7) Do you consider that the proposal to apply a nil rate to office, industrial and all other forms of development is justified and consistent with the evidence of viability?

Yes x No

Page 4

Please provide further explanation below – particularly if you have answered ‘no’ to the question above. Please provide supporting evidence where available.

)

Implementation

(8) Do you consider that the draft statement on the proposed approach to the complementary use of CIL and section 106 agreements: (a) Is consistent with the overall intentions of the Yes No X Regulations and Practice Guidance?

(b) Is fair, transparent and would be effective in avoiding Yes No X actual or perceived ‘double dipping’?

If you have answered ‘no’, please provide further explanation We welcome the Council’s commitment to seek to scale back Section 106 and other obligations in line with the NPPG guidance on CIL. We also welcome early publication of the Draft Position Statement and Draft List of Relevant Infrastructure, which allow an informed response to be made.

We remain very concerned however about the uncertainty relating to likely future planning obligations in relation to the SUEs. The Council’s Position Statement, as noted above, states that significant residual infrastructure costs are only likely to apply to developments of over 500 homes (paragraph 40), but has not undertaken the necessary infrastructure planning work to demonstrate what those infrastructure requirements are likely to be for the SUEs, which the Core Strategy identifies for 500-700 homes. It is probable that the residual Section 106 cost on the SUE sites will be significantly in excess of the £10,000 per unit allowed for in the Council’s Viability Assessment.

The NPPG CIL Guidance (Paragraph: 097 Reference ID: 25-097-20140612) states clearly that:

“Where the regulation 123 list includes a generic type of infrastructure (such as ‘education’ or ‘transport’), section 106 contributions should not be sought on any specific projects in that category. Site-specific contributions should only be sought where this can be justified with reference to the underpinning evidence on infrastructure planning which was made publicly available at the charging schedule examination.”

The Draft list of relevant infrastructure (Regulation 123 list) is clearly not consistent with this guidance as it allows for exclusions for all of the generic items whilst not, in the case of SUEs at least, providing the evidence on infrastructure planning to identify those situations where it is likely to the exclusions will occur.

This means that the developers of the SUE sites can have little confidence in the assumptions set out in the Viability Assessment on residual Section 106 as they could be required to provide any of Page 5 the types of infrastructure set out in the regulation 123 list. It is therefore essential that the list of relevant infrastructure is amended once the infrastructure needs of the SUE sites have been properly assessed to identify any exclusions that we be applied to the SUE sites so that the impact of these exclusions on the viability of these sites can be properly assessed. In this context, and with the potential for strategic requirements to fall disproportionately on specific sites and for residual Section 106 costs to be significantly higher than the £10,000 per dwelling allowed for in the Viability Assessment, it is essential that the Council confirms that it will accept payment in kind through land or infrastructure provision (under Regulations 73 and 73a of the CIL regulations 2010 as amended) in appropriate circumstances.

(9) Do you have any views on the draft list of relevant infrastructure (Regulation 123 list)? Yes x No

If you have answered ‘yes’, please provide further explanation

Please see Section 9 above. This is inextricably linked with the approach to future Section 106 contributions. Although neither point is an issue for the Examination in itself, in our view the approach proposed does not allow interested parties or the examiner to determine whether the appropriate balance has been struck as required by the regulations.

(10) Do you consider that the Council should offer discretionary relief: (a) For development by a charity where the profits will Yes X No be used for charitable purposes?

(b) For housing developed specifically for discounted Yes X No market sale?

Please provide further explanation below – particularly if you have answered ‘yes’ to the any of the questions above Given the generic nature of CIL viability assessment and the ongoing uncertainties in relation to any specific site it is our view that the Council should seek to retain the maximum flexibility in relation to the implementation of CIL.

(11) Do you consider that: (a) The Council should introduce a local instalments Yes X No policy?

(b) The initial suggested payment phasing is a Yes X No reasonable approach?

Please provide further explanation below We welcome the Council’s suggested payment phasing and regard the approach set out in Table 3 of the Explanatory Document as a reasonable one. We would question whether the proposed negotiated approach to instalments on any £1 million plus CIL liable developments is consistent Page 6 with CIL regulation 69b (2) which requires the policy to include the time from the commencement of development of first and subsequent instalments to be included. We would suggest instead the Council includes specific timings for potential instalments.

(12) Do you have any further comments? No

Signature: Date: 12/01/2015

Page 7 LDF

From: Tom Ormesher Sent: 26 May 2015 15:58 To: LDF Subject: Draft CIL Charging Schedule

Dear Reigate and Banstead Borough Council, Thank you for inviting comment on the draft CIL charging schedule. Agricultural developments place no or in a few cases a very limited extra burden upon infrastructure. The CIL is essentially a levy on the enhanced value of development land. There is no enhanced land value with agricultural development and therefore the CIL would have to be paid from farm revenue budgets; placing a burden on agricultural development. We recognise and welcome that most farm development will fall within the “all other development” category and would therefore be zero rated. The development of housing for essential farm workers is however as much an integral part of farm infrastructure as (say) a new dairy unit or machinery storage shed. Residential accommodation is often essential for the safe and effective running of the farm and is developed at substantial cost to the farm business without the opportunity to realise any capital gain, particularly where the use of such development is restricted by an Agricultural Occupancy Condition. Within the context of the draft charging schedule however farmworkers accommodation is likely to fall within the highest CIL banding category of £200 per square metre. We consider this as a rather punitive charge, particularly where such housing is often brought forward in the absence of any otherwise available affordable housing. We note from the explanatory documents that it is possible to register for a CIL exemption “where a) the development will be used or occupied for charitable purposes, b) for affordable housing and c) for self‐build residential extensions or self‐build new dwellings.”; however we feel that it would be entirely consistent for an additional exemption to specifically cover rural workers accommodation, such as those permitted under Policy Ho23 of the Reigate and Banstead Local Plan 2005 or its successor policies. We would therefore recommend that an additional exemption is included within the explanatory document. I hope that you find our contribution to the consultation helpful, and that the views of the farming sector are taken into account when drafting the schedule for examination. If you require further information or clarificationy of an of the points raised in this response please do not hesitate to contact me at the NFU South East Regional Office. We look forward to seeing the next version of this document. With kind regards Tom

Tom Ormesher Regional Environment & Land Use Adviser

NFU South East Region Unit 8 Rotherbrook Court Bedford Road Petersfield Hampshire GU32 3QG

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Reigate & Banstead Borough Council

Community Infrastructure Levy (CIL): Draft Charging Schedule

April 2015

Representations Form

How to submit your comments

This response form has two parts:  Part A: Personal Details  Part B: Your Views  Part C: Participation and Notification

We would strongly encourage you to respond to the consultation by completing the questions set out in this form. Please complete Parts A, B and C to assist us in considering your views. You are encouraged to provide as much explanation as possible, and where relevant, attach any available evidence to support your position.

Forms must be returned to Reigate & Banstead Borough Council by 5pm on 26 May 2015

You can return your form:

By post to: Planning Policy Team, Reigate & Banstead Borough Council Town Hall, Castlefield Road, Reigate, Surrey, RH2 0SH.

By e-mail to: [email protected]

All duly made responses and representations will be considered by the Council and will be passed to the independent examiner as part of the examination procedure. We are happy to provide information in other languages, large print, braille or on audio tape. Please contact our Help Line on 01737 276000 if you would like this service.

Part A: Personal Details If an agent is appointed please complete only the Title, Name and Organisation boxes in (1) but complete the full contact details of the agent in (2).

(1) Personal Details (2) Agents Details (if relevant) Title MR

First name ROBERT

Last name STEELE

Job title (if relevant) SENIOR PLANNER

Organisation SAVILLS (UK) LTD (if relevant) Address SAVILLS, 2 CHARLOTTE PLACE, SOUTHAMPTON

Postcode SO14 0TB

Telephone No 02380 713900

Email address [email protected]

Page 1 Part B: Your Views

Draft Charging Schedule and Proposed Charges

(1) Do you have any comments to make on the proposed rates of CIL and the supporting viability evidence (set out in the CIL Revised Viability Assessment Report and Appendices)? Yes X No

If you have answered ‘yes’, please provide further explanation, Please set out any evidence available to support your views

See attached.

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

(2) Do you have any comments to make on the charging zone maps set out in the Draft Charging Schedule?

Yes No X

If you have answered ‘yes’, please provide further explanation

(continue on a separate sheet/expand box if necessary) Page 1 Draft List of Relevant Infrastructure

(3) Do you have any comments to make on the draft list of relevant infrastructure?

Yes X No

If you have answered ‘yes’, please provide further explanation

See attached.

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

Evidence Base

(4) Do you have any other comments to make on the evidence base and supporting documentation for the Draft Charging Schedule?

Yes X No

If you have answered ‘yes’, please provide further explanation Please make clear which document (i.e. Infrastructure Delivery Plan) and if possible any specific passages or tables your views refer to, particularly if you are making comments on multiple documents. Please set out any evidence available to justify your views.

See attached.

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

Page 2 Part C: Participation and Notification

Requesting the right to be heard at examination

(5) Organisations and individuals making representations may request the right to be heard by the examiner. Do you consider it necessary to participate at the oral part of the examination?

No, I do not wish to participate at Yes, I wish to participate at the oral X the oral examination examination

If you wish to participate at the oral examination, please outline why you consider this to be necessary

The representation contains supporting evidence and it will be necessary to discuss this with the Examiner and provide clarification where necessary. The representation is on behalf of a number of house builders which have significant land interests within the Borough and so it is appropriate that they are represented at the hearing.

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

Please note: The examiner will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of any examination.

Requests to be notified

(6) Representations may also be accompanied by a request to be notified, at a specified address, of any of the following. Please indicate of which, if any, you wish to be notified.

(a) That the Draft Charging Schedule has been submitted to the Yes X No examiner in accordance with section 212 of the Planning Act 2008

(b) The publication of the recommendations of the examiner and the Yes X No reasons for those recommendations

Signature: Date: 26/05/15 Robert Steele

Page 3

Consortium of house builders May 2015

r Reigate and Banstead Borough Council Community Infrastructure Levy Draft Charging Schedule (DCS)

Consultation response on behalf of a consortium of house builders

savills.co.uk Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

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Consortium of house builders May 2015 1 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Contents

Executive Summary 3 1. Introduction 5 2. Summary of National Policy and Legal Context 8 3. Planning Overview and Housing Delivery 12 4. Viability Appraisal 19 5. Effective Operation of CIL 34 6. Conclusion 37 Appendix 1: List of Documentation 39 Appendix 2: CIL Getting it Right, Savills 41 Appendix 3: Developer Profit, Savills 43 Appendix 4: LPAs adopting or proposing £Nil CIL Rates 45 Appendix 5: Savills, ARGUS Development Appraisals 47

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Consortium of house builders May 2015 2 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Executive Summary

This representation has been prepared by Savills (UK) Limited (hereafter “Savills”) on behalf of Crest Nicholson, Miller Homes, Taylor Wimpey, Thakeham Homes and Persimmon (hereafter “the Consortium”). It is made in respect of Reigate and Banstead Borough Council’s (RBBC) Draft Charging Schedule (DCS) for the Community Infrastructure Levy (CIL). This follows representations made, outlining similar points on the Preliminary Draft Charging Schedule (PDCS).

The CIL Guidance contained within the Planning Practice Guidance (PPG) is clear on the narrow focus of the CIL Examination process permitted by the Regulations:

“The Examiner should establish that:

• The charging authority has complied with the required procedures set out in part 11 of the Planning Act 2008 and the CIL Regulations; • The charging authority’s draft charging schedule is supported by background documents containing appropriate available evidence; • The proposed rate or rates are informed by and consistent with, the evidence on economic viability across the charging authority’s area; and • Evidence has been provided that shows the proposed rate (or rates) would not threaten delivery of the relevant Plan as a whole”1

This representation explores whether RBBC has presented appropriate evidence, come to reasonable conclusions and is able to demonstrate that it “strikes an appropriate balance” in accordance with Regulation 12(1) of the CIL Regulations.

As outlined, Savills on behalf of the consortium has previously made representations to RBBC’s consultation on its Preliminary Draft Charging Schedule (PDCS) and provided some advice on the key aspects of formulating CIL rates, as set out in the Savills document “CIL: Getting it Right” (Appendix 2).

The purpose of this representation is to:

• consider whether the charging schedule as drafted would render the development required to meet the Council’s housing target unviable and undeliverable in the context of a historically fragile five year housing supply position; and • challenge a selection of the assumptions adopted by the Council in its viability appraisals.

We welcome that RBBC has undertaken a fine-grain viability appraisal of one of the proposed strategic allocations (land NW of Horley), recognising that sites delivering large scale developments come with high mitigation and enabling costs, which can have a dramatic impact on the amount of CIL which can be afforded. This is lacking however for the proposed Sustainable Urban Extensions (SUEs), which are a key component of the housing land supply (6-15 years), as indicated by Core Strategy policy (adopted July 2014), and clear intent for a future Green Belt review. Other Councils have adopted a £nil rate of CIL for their strategic sites, as it offers the greatest flexibility to use Section 106 to fund infrastructure and mitigate site impact.

1 Paragraph 038, Reference ID 25-038-20140612, PPG CIL Guidance September 2014

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Savills and the Consortium have concerns with the general approach taken by RBBC in proposing its residential CIL rates and these were previously highlighted in the PDCS representation dated January 2015. The concerns included:

Unviable rates for Greenfield strategic land – the rates were considered to risk rendering a significant proportion of the future housing supply across the Borough undeliverable (for example North West Horley and the presently Green Belt Sustainable SUEs as proposed in the Core Strategy).

Appraisal Assumptions – Benchmark land values, net:gross development area and profit were questioned.

Housing Delivery – An unviable CIL rate poses a risk of reducing housing delivery, which in turn will affect the level of CIL receipts collected. The reliance on North West Horley and the SUEs to maintain a five year housing land supply and deliver the Core Strategy, and therefore the need for an appropriate CIL rate must be recognised by RBBC.

Housing Supply – In January 2015 the consortium noted the Borough’s marginal land supply position and the need for a Green Belt release in the near future (a draft Site Allocations/ Development Management DPD is due in the Autumn). A viability buffer of 40% was advocated for the viability appraisals to reflect the existing risk to the housing supply and to ensure the delivery of infrastructure and community facilities required to support the enhanced level of growth across the Borough.

Charging Zones – In recognition that the exact location of the SUEs was not known (rather broad areas as indicated by the Core Strategy Key Diagram), the consortium called for rates to be set on the basis of the scale of development.

RBBC has made some changes to the Charging Schedule following the PDCS consultation stage in January 2015, including reducing the Urban Extension and rest of the Borough zone (now called Zone 5) from £240 to £200 psm. However, the concerns raised by the Consortium for that previous stage are still relevant and explored further in this representation. The rate of CIL for North West Horley and the SUEs (potentially defined by scale of development) should be reduced to £Nil and £50 psm respectively.

As a result we do not believe that the Council has demonstrated that the proposed rates for the SUEs and North West Horley are viable and will not threaten the delivery of the Core Strategy.

The structure of this document is as follows:

Section 1.0 gives an introduction to the representation Section 2.0 gives planning and legal background Section 3.0 outlines specific points about the available evidence bases Section 4.0 provides scrutiny of the available viability evidence Section 5.0 outlines the position of the Consortium in respect of the effective operation of CIL Section 6.0 provides conclusions.

Where relevant this representation provides comment on the supporting evidence/ existing guidance and also makes reference to policy documents, a list of which can be found at Appendix 1.

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1. Introduction

1.1 This representation has been prepared by Savills on behalf of a consortium of house builders consisting of Crest Nicholson, Miller Homes, Taylor Wimpey, Thakeham Homes and Persimmon (hereafter “the Consortium”).

1.2 The Consortium has a significant land interest within the Borough. Crest Nicholson, Taylor Wimpey and Persimmon have interests on land at North West Horley, which benefits from outline planning permission (granted 2 December 2014, reference P/04/02120 for 1,510 dwellings), though this does not guarantee that the site will not be subject to future planning permissions, which post implementation of CIL will be liable for the Levy.

1.3 Miller Homes and Thakeham Homes have interests on land which may become a Sustainable Urban Extension (SUE), to the south west of Reigate, as indicated by the Core Strategy Key Diagram, and required by the 6-15 year housing trajectory. The Core Strategy was adopted in July 2014, and thus is a recent plan.

1.4 This representation has been submitted to influence the emerging Community Infrastructure Levy (CIL) Charging Schedule and our comments relate to the proposed rates for residential development. The lack of reference to other parts of the evidence base cannot be taken as agreement with them and we reserve the right to make further comments upon the evidence base at the Examination stage, or at future revised stage where necessary. For the avoidance of doubt, the Consortium requests the right to be heard at the Examination.

1.5 The objective of this representation is not to oppose CIL; it merely seeks to ensure that viable rates based on the evidence and a collective interest to delivery of well planned, viable and feasible development in the Borough are adopted.

Draft Charging Schedule

1.6 RBBC has proposed the following residential CIL rates:

Residential Zones Proposed CIL Rate (£ psm) Zone 1 £20 Redhill and Horley Town Centre Zone 2 £140 Reigate and North of the Borough Zone 3 £80 Rest of the urban area Zone 4 £180 North West Horley Zone 5 £200 Rest of the Borough Source: Reigate and Banstead Borough Council

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Previous Representation to PDCS January 2015

1.7 In January 2015 the Consortium responded to RBBC’s Preliminary Draft Charging Schedule (PDCS). The PDCS was prepared following the adoption of the Council’s Core Strategy in July 2014 and the evidence included viability appraisals relating to the North West Horley allocation and proposed SUEs.

1.8 Despite the apparent fine grained viability testing by the Council of the strategically important Greenfield developments set out in the Core Strategy, there were some key areas of concern for the Consortium and it was concluded that the viability of the planned development would be severely compromised by the CIL rates proposed. The concerns included:

a. The use of incorrect assumptions - such as profit, build costs and abnormal and benchmark land values. b. The failure to recognise the marginal five year supply of housing – as an unviable CIL rate would result in a reduced housing delivery; impacting the number of CIL receipts collected; to the detriment of infrastructure delivery. c. Not setting a CIL rate in relation to scale of development – this would differentiate SUEs from the rest of the Borough zone, and together with a viable CIL rate would ensure the delivery of the sites when necessary. d. Not including a 40% viability buffer – in recognition of the marginal land supply in the Borough and the likelihood of the SUEs needing to come forward sooner in the plan period.

1.9 It is disappointing to see that these concerns are not addressed in detail by RBBC in its latest DCS. The current rates proposed will threaten the delivery of the SUEs, which, as later described, will become more pertinent to the delivery of housing planned in the Core Strategy. In addition, given the scale of the North West Horley allocation and despite it having planning permission, it is possible that amendments requiring planning permission will be sought on the site, triggering the levy in the future, which creates unnecessary complexity. At the rate proposed, the viability of that development and the delivery of infrastructure would be severely compromised.

1.10 It is noted that RBBC has not adequately tested 500 or 700 unit typologies, to reflect the planned housing land supply. This is a key shortcoming of the CIL evidence base. This is necessary to account for the substantial uplift proposed with CIL, in comparison to the previous Section 106 tariff regime, and also so that further evidence may be obtained/ tested in respect of the potential SUEs.

1.11 Comparably speaking, the housing market in the Borough is moderate by wider South East standards. A high CIL rate, together with high site mitigation and affordable housing requirements, will put a strain on the viability of development and harm delivery of new homes to meet the Borough’s priorities.

1.12 The Council’s Core Strategy sets out the proposed strategy for 460 dwellings per annum (dpa) between 2012 - 2027, based on the objectively assessed housing needs for the Borough and region. Whilst the Core Strategy proposes an “urban areas first” approach, it recognises that opportunities within the urban area are likely to become more limited during the life of the plan. The consequences of this are already apparent in RBBC’s delivery forecasts. Delivery from the SUEs is inevitable as outlined in the housing trajectory (years 6-15), and there is an immediate reliance on key sites such as NW Horley.

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1.13 The National Planning Policy Framework (NPPF) requires Councils to boost significantly the supply of housing, and identify annually a supply of housing sufficient to provide five years worth of housing against its housing requirements2. Reigate and Banstead’s five year supply as of 2013-2014 is marginal and it is likely that the SUEs will need to come forward in order to meet the needs and priorities of the area. As such, the on-going delivery of housing must not be curtailed by an unviable CIL rate.

2 Paragraph 47, NPPF

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Consortium of house builders May 2015 8 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

2. Summary of National Policy and Legal Context

2.1 In respect of the preparation of Charging Schedules and supporting documentation, it is important to have regard to the Government policy, guidance and law. This includes:

• National Planning Policy Framework (NPPF) • Part 11 of the Planning Act 2008; Community Infrastructure Levy Regulations 2010 (as amended) • Planning Practice Guidance (PPG) CIL Guidance 2014 (as amended)

National Planning Policy Framework (NPPF)

2.2 It is important that the preparation of CIL is in the spirit of the NPPF, notably that it is delivery-focused and “positively prepared”3.

2.3 The NPPF outlines 12 principles for both plan making and decision taking, notably that planning should “proactively drive and support sustainable economic growth”4. Plan making should “take account of market signals such as land prices and housing affordability” and that “the Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth”5.

2.4 Furthermore, the NPPF refers to the “cumulative impacts”6 of standards and policies relating to the economic impact of these policies (such as affordable housing) and that these should not put the implementation of the Plan at serious risk. Existing policy requirements should therefore be considered when assessing the impact of CIL on development viability.

2.5 The NPPF calls for local authorities to boost significantly the supply of housing7. It requires local authorities to:

• meet the full, objectively assessed needs for housing, including identifying key sites; • identify deliverable sites to provide five years worth of supply and developable sites further ahead; • provide a housing trajectory for the plan period describing how the five year supply is to be maintained.

2.6 The NPPF expressly states that CIL “should support and incentivise new development”8. To comply with this policy, CIL Charging Schedules must be demonstrated to have positive effects on development and have regard to an up-to-date Local Plan. The absence of adverse effects on the economic viability of development, whether serious or otherwise, is not enough to justify CIL proposals. Charging Authorities have a positive duty when it comes to setting CIL rates and formulating their approach on the application of CIL.

3 Ibid, Paragraph 182, March 2012 4 Ibid, Criterion 3, March 2012 5 Ibid, Paragraph 19, March 2012 6 Ibid, Paragraph 174, March 2012 7 Ibid, Paragraph 47, March 2012 8 Ibid, Paragraph 175, March 2012

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Planning Act 2008 (as amended)

2.7 Section 205 (2) of Part 11 of the 2008 Act (as amended by the Localism Act 2011) states that:

“In making the regulations the Secretary of State shall aim to ensure that the overall purpose of CIL is to ensure that costs incurred in supporting the development of an area can be funded wholly or partly by owners or developers of land in a way that does not make development of the area economically unviable.”

2.8 Examiners are required in particular to have regard to the matters listed in Section 211(2) and 211(4). This requires examiners to consider whether the relevant charging authority has had regard to the following matters:

• actual and expected costs of infrastructure; • matters specific by the CIL Regulations relating to the economic viability of development; • other actual and expected sources of funding for infrastructure; and • actual or expected administrative expenses in connection with CIL.

2.9 Regulation 14 of the CIL Regulations (as amended) expands on these requirements, explaining that charging authorities must, when striking an appropriate balance, have regard to:

• the desirability of funding from CIL (in whole or in part), the actual and expected estimated total cost of infrastructure required to support the development of its area, taking into account other actual and expected sources of funding; and • the potential effects (taken as a whole) of the imposition of CIL on the economic viability of development across its area.

2.10 The Examiner will need to determine whether appropriate evidence on infrastructure needs and development viability has been presented by the Council.

Planning Practice Guidance (PPG)

2.11 Relevant to CIL, the PPG (2014) states:

• Charging schedules should be consistent with, and support the implementation of, up-to-date relevant Plans9. • The need for balance (as per Regulation 1410). • The need for “appropriate available evidence to inform the Draft Charging Schedule” (as per Schedule 211(7)(a) of the 2008 Act11.

2.12 The policy direction from central government is very much towards facilitating development. This policy imperative should have a major material bearing on the CIL rates. This applies to the evidence to support the balance reached between the desirability of funding infrastructure through CIL and the potential effects on economic viability of development across that area.

9 Paragraph 10, Reference ID: 25-010-20140612, PPG CIL Guidance 2014 10 CIL Regulations 2010 (as amended)

11 Paragraph 19, Reference ID: 25-019-20140612, PPG CIL Guidance 2014

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2.13 The Guidance states that it is up to charging authorities to decide how much potential development they are willing to put at risk through CIL (the “appropriate balance”). Clearly this judgement needs to consider the wider planning priorities. Furthermore, the CIL Guidance outlines that CIL receipts are not expected to pay for all infrastructure but a “significant contribution”12. The overall approach and rate of CIL will have to pay attention to the development plan and intended delivery.

2.14 The Guidance also states that charging authorities may adopt differential rates in relation to:

• geographical zones within the charging authority’s boundary • types of development; and/or • scales of development13

2.15 It explains that where a particular type or scale of development has low, very low or zero viability, the charging authority should consider setting low or zero rates for that type of development. The opportunity to define a CIL rate by development scale is important in this instance.

2.16 On 28 November 2014, the PPG was updated to include the recent content of the ministerial statement by Brandon Lewis, about the minimum thresholds required to trigger the need for affordable housing and tariff based contributions. The Government position is that contributions for affordable housing and tariff style planning obligations should not be sought from developments of 10-units or less.

2.17 This guidance must be reflected in RBBC’s viability appraisals.

12 Paragraph 95, Reference ID 25-095-20140612, PPG CIL Guidance 2014 13 Paragraph 21, Reference ID 25-021-20140612, PPG CIL Guidance 2014

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Consortium of house builders May 2015 12 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

3. Planning Overview and Housing Delivery

The Development Plan

3.1 The Development Plan for RBBC includes:

• The ‘saved’ policies of the Borough Local Plan 2005 • Core Strategy adopted 2014.

3.2 Policy CS13 of the Core Strategy plans for 6,900 homes to be delivered between 2012-2027. The Council’s aim is to prioritise urban area locations for development of 5,800 homes, although they do recognise that opportunities are likely to become limited during the life time of the plan.

3.3 Two new neighbourhoods were proposed to the north of Horley. The North East Sector is close to completion and the North West Sector, controlled by some of the Consortium members, has outline planning permission for up to 1,510 homes (04/02120/OUT).

3.4 Policy CS6 of the Core Strategy also allocates broad areas for development beyond the urban area, including:

a. Countryside beyond the Green Belt adjoining the urban area of Horley b. East of Redhill and East of Merstham c. South and South West of Reigate

3.5 It is therefore important that the emerging CIL and evidence base factors the likely type of development coming forward in line with the housing delivery strategy.

Housing Delivery

3.6 Analysis of viability results should always be considered in the context of the relevant Development Plan and the identified housing supply. In LPAs, where there has been a historic under-delivery of housing (both private and affordable), or a marginal five year housing land supply, as is presently the case in RBBC, greater attention needs to be paid to the proposed CIL rates as, if they are set at unviable levels, the planned delivery plan in the Development Plan will be put at risk.

3.7 The introduction of CIL represents an additional obligation and therefore must be assessed holistically to establish the cumulative impact of CIL and existing planning obligations, to ensure that the delivery of development would not be threatened by the introduction of CIL. Savills has therefore reviewed the identified housing supply for the Borough, to determine whether the proposed CIL rates could threaten the delivery of the development during the Plan period.

3.8 In addition to this, the CIL guidance confirms that LPAs must have an “up-to-date” development strategy for the area in which they propose to charge CIL. It states that a Charging Authority must be able to demonstrate how the proposed levy rates will contribute towards the implementation of the Local Plan.

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3.9 Since 2009 the annual housing completions have generally slowed and decreased as shown in Table 3.1, with some instances where completions have been below target.

Table 3.1: Housing Delivery in Reigate and Banstead 2006 - 2014 Year Total Completions Target Completions % Difference 2006-2007 607 500 21% 2007-2008 602 500 20% 2008-2009 836 500 67% 2009-2010 654 500 30% 2010-2011 439 500 -12% 2011-2012 455 500 -9% 2012-2013 469 460 +2% 2013-2014 433 460 -6% Source: RBBC Annual Monitoring Reports, Various.

3.10 This evidence demonstrates that the housing delivery within the Borough is fragile and as stated in the Council’s Housing Delivery Monitor 2014, the five year supply is at 5.52 years. It is therefore conceivable that a CIL rate which is set too high would weaken the delivery of housing threatening the maintenance of a five year supply.

3.11 At the proposed levels the DCS would result in higher CIL rates for the urban extension sites, which may come forward to meet the needs of the Borough to help maintain a five year supply. The proposal to subject the broad areas for the urban extensions to a “rest of the Borough” rate is of concern.

3.12 The Council’s justification for not setting specific rates for urban extensions is set out at paragraph 5.25 of the Revised Viability Assessment Report. The reason appears to be that because the sites have yet to be allocated, it is not possible to define a charging zone.

3.13 However the Council could set rates on the basis of scale and it is considered that there is a strong argument for differential rates on this basis. Either way, RBBC must adequately test the potential development coming forward in these sites, which will have cumulative infrastructure burdens (500 or 700 dwellings).

3.14 The larger the scale of development the higher the enabling, mitigation and development costs reducing the overall “pot” left for CIL. This is recognised by RBBC in principle in the Revised Viability Assessment Report. Section 4 of this Representation explores this in more detail.

The Duty to Co-operate – Sub Regional Dynamics

3.15 The Duty to Co-operate is relevant to the preparation of CIL charging schedules and whilst the Duty does not apply specifically to the CIL process, it is a fundamental requirement of Local Plan making and hence planning policy, which clearly is intrinsic on CIL (notably owing to the tests of CIL examinations). The requirements for the Duty are outlined in the NPPF14

14 Paragraphs 178 - 181, NPPF

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3.16 LPAs are subsequently required to take a strategic approach to local planning. It is therefore entirely relevant to view RBBC’s proposed CIL within its local context.

3.17 As can be seen in Figure 3.2, the Borough has relatively moderate sale values compared to its neighbours, with Mole Valley to the West and Tandridge to the East showing higher values across a wider area. Reigate and Banstead is characterised by relatively broad divergence in values, between higher value north (surrounds of Banstead), to a lower value south (around Horley). The Council should recognise the relatively moderate sale values compared to the rest of the sub-region in setting the CIL rates, as the affordability of CIL and the “trade-off” with affordable housing and other planning policies will be directly impacted by the values which can be achieved.

Figure 3.2: Sale Values within the sub- region (land East of Angmering shown)

3.18 We have also outlined the emerging and adopted CIL rates in surrounding LPAs (Table 3.3), which demonstrates that the highest CIL rate proposed in RBBC (£200 psm) is significantly higher than those in neighbouring LPAs. Given the average sale value in RBBC and divergence of values within the Borough, this is concerning and raises the question of whether the proposed rates will meet the teststs set out in the statutory guidance.

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Table 3.3: Comparison of RBBC CIL Rates with Neighbouring Authorities

Local Authority Current CIL Stage Average Sales Values Max. Residential CIL RBBC comparison £psf (UQ) rate (£200psm) Crawley PDCS £270 £100 +£100 Tandridge Adopted £355 £120 +£80 Epsom & Ewell Adopted £427 £125 +£75 Elmbridge Adopted £514 £125 +£75 Sutton Adopted £386 £120 +£80 Croydon Adopted £349 £120 +£80 AVERAGE £383 £118 +£82 Reigate and Banstead DCS £376 £200 0 Source: Savills Analysis (May 2015)

3.19 This analysis clearly demonstrates that the CIL rates proposed by RBBC are higher than those proposed locally. The following is worth particular note:

Maximum CIL Rates: RBBC is proposing a higher residential CIL rate than all of the neighbouring authorities listed above.

Sale Values: Average sales values are higher in a number of RBBC’s neighbouring LPAs. It is therefore concerning that the maximum CIL rate proposed is £82 more than the average maximum CIL rate across these authorities (£118 psm).

Implemented CILs: Those CIL rates that have been through examination and subsequently adopted are considerably lower than those proposed in RBBC.

3.20 Savills therefore asks that the Council considers the proposed CIL rates in light of the analysis above.

The Present Approach to Section 106

3.21 The Consortium notes the present approach to Section 106 is outlined in various guidance, notably the Surrey-wide Planning Infrastructure Contributions approach, which seeks tariff based contributions in order of £7,700 for a one bedroom flat to around £22,000 for a five bedroom house. Taking the proposed levy for Zone 5 (£200 psm) as an example, it is clear to see from the table below that the proposed charge represents a significant uplift in contributions compared to the existing situation. This is pertinent for the potential SUE sites where option agreements have already been made on the basis of the existing Section 106 tariff regime. A significant increase in costs will risk jeopardising the delivery of those sites.

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Table 3.4: Comparison of CIL (£200 psm) to current S106 Tariff House Size per sqm Current Rest of Borough S106 tariff CIL Charge (£200 psm) 1 bed flat 50 £7,712 £10,000 2bed flat 70 £10,363 £14,000 2 bed house 85 £10,363 £17,000 3 bed house 100 £14,777 £20,000 4 bed house 130 £16,838 £26,000 5 + bed house 160 £21,958 £32,000

Affordable housing/ S106: 10 or less unit schemes threshold

3.22 The effect of the Government’s guidance on small scale typologies is worthy of consideration. Whilst the likely CIL rate may increase for small scale schemes (as no affordable housing would be secured meaning more in the “pot”), the Consortium is keen that the “fair share” principle applies for CIL and that adequate funding is obtained for all sources, including smaller schemes to deliver the infrastructure needed. As previously mentioned, the CIL Regulations permit the differentiation of CIL rates by scale.

Consortium of house builders May 2015 17 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

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Consortium of house builders May 2015 18 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

4. Viability Appraisal

4.1 Through analysing the Reigate & Banstead CIL Revised Viability Assessment Report, dated March 2015 (herein termed the Viability Report), we have split our response in respect of the viability assessment into three parts:

Part 1 - Summary of RBBC Appraisal Inputs Part 2 - Assessment of Appraisal Inputs Part 3 - Savills Assumptions and Appraisals

4.2 The viability assessments are based on a series of residual valuation scenarios that model the gross development value achievable from different uses, in different areas within the local authority area and discounts development costs, interest costs and developer profit.

4.3 The RBBC Appraisal has tested 14 typologies ranging from 1 unit to 1,510 units, in addition two locations of specific modelling have been undertaken:

• Scenario 1 - 1 unit • Scenario 8 - 20 units (flats) • Scenario 2 - 3 units • Scenario 9 - 25 units • Scenario 3 - 7 units • Scenario 10 - 50 units (flats) • Scenario 4 - 10 units (flats) • Scenario 11 - 100 units (flats) • Scenario 5 - 10 units • Scenario 12 - 300 units (Strategic) • Scenario 6 - 14 units • Scenario 13 - 150 units (Strategic) • Scenario 7 - 15 units • Scenario 14 - 1,510 units (Strategic)

4.4 No modelling of 500 or 700 dwelling strategic site has been taken with regard to the potential cumulative costs arising from SUE development. As outlined, differential rates of between £20 - £200 psmetre have been proposed.

Part 1 - Summary of RBBC Appraisal Inputs

4.5 We summarise in Table 4.1 the RBBC Appraisal viability assumptions and highlight the areas of agreement and concern.

Table 4.1 - Opinion on RBBC Appraisal viability assumptions/inputs.

Viability Appraisal RBBC Adopted General Assumptions Consortium Opinion Assumptions

Values Open Market Value Value Level 1 Value level 2 Value level 3 Value level 4 Agree in principle.

(OMV) £3,300/sqm £3,400/sqm £3,600/sqm £4,000/sqm Redhill and Redhill, Horley, Merstham, Banstead, Horley (town Earlswood, Woodhatch, Chipstead, centre) Tadworth, Kingswood, Reigate 1 bed flat £165,000 £170,000 £180,000 £200,000 2 bed flat £231,000 £238,000 £252,000 £280,000 2 bed house £280,500 £289,000 £306,000 £340,000 3 bed house £330,000 £340,000 £360,000 £400,000 4 bed house £445,500 £459,000 £486,000 £540,000

Consortium of house builders May 2015 19 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Viability Appraisal RBBC Adopted General Assumptions Consortium Opinion Assumptions

5 bed house £561,000 £578,000 £612,000 £680,000

Affordable Housing For rented units, OMV has been discounted by 55% and for intermediate (i.e. Agree in principle. shared ownership) units; a 35% discount has been applied. Value

Densities Per Hectare Housing >10 units: 30 dph Agree in principle. 10+ units: 35 dph Flats >25 units: 90 dph Agree in principle. 25+ units: 125 dph Urban Extensions 24 dph Agree in principle.

Dwelling Sizes (sq.m) Open Market Housing Dwelling type Size m2 Agree in principle. 1 bed flat 50 2 bed flat 70 2 bed house 85 3 bed house 100 4 bed house 135 5 bed house 170 10% allowance is made for schemes of up to 25 flats. For larger schemes, additional cores are often required and therefore an allowance of 12.5% is made. Affordable Housing Unknown Unknown Acquisition Costs Purchaser’s Costs Legal fees are assumed to be 0.75% of GDV and agents fees are assumed to be a further 1.0% of GDV. Stamp Duty Land Tax Prevailing standard rates Agree in principle. Construction Costs Build Costs (£/m2 ) Type £ /m2 Externals £ /m2 Externals Housing schemes under 5 units £1,300 10% Disagree Agree in – principle. Housing schemes 5 or more units £1,080 10% reference Agree in Part 2 for principle. Urban extensions and Horley NW £1,080 12.5% (+ £10k further Agree in per plot) detail. principle. Flatted schemes under 50 units £1,260 7.5% Agree in principle. Flatted schemes of 50 or more units £1,310 10% Agree in principle.

Infrastructure / Opening An additional per plot allowance of £10,000 (over and above the 12.5% allowance Agree in principle. for landscaping etc.) is also factored into urban extensions and Horley North West Costs Sector

Abnormals No abnormal costs incorporated. Disagree – reference Part 2 for further detail. Building Regulation / 4% cost inflation has been included Agree in principle.

sustainability Contingency General at 5%. Larger complex schemes at 7.5% Agree in principle. Professional Fees Standard 10% Larger complex schemes at 12.5% Agree in principle. Section 106

Consortium of house builders May 2015 20 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Viability Appraisal RBBC Adopted General Assumptions Consortium Opinion Assumptions

Affordable Housing 15 net dwellings or 10 to 14 net dwellings 1 to 9 net dwellings provide Agree in principle. more at 30% provide a contribution a contribution equivalent to equivalent to 20% 10% Mix: 40:60 between rented and intermediate S106 Financial Urban residential Urban extension schemes North West Sector at Disagree – reference at £1,000 per unit at £10,000 per unit £14,300 per unit Contribution (per unit) Part 2 for further detail. Section 278 Financial Contribution Nil – assumed included in above contribution. Disagree – reference Part 2 for further detail. Profit Developer Profit 20% of GDV for Residential. 6% of GDV from Affordable Housing. Disagree – reference Part 2 for further detail. Timescales Pre-construction period 3 months Disagree – reference Part 2 for further detail Build Rate (units per Houses 4 units per month (after an initial 6 month period for sub-structure and other site preparation/landscaping works) month) Flats 6 units per month Sales Rate (units per 4 units per month (reservations/sales commence six months into the construction period) / North West Sector scheme at 6.5 units per month per outlet month) 1 unit scheme 3 months 7 months 0 months

3 unit scheme 7 unit scheme 6 months 8 months 10 flat scheme 10 unit scheme 9 months 14 unit scheme 10 months 15 unit scheme 20 flat scheme 25 unit scheme 13 months 50 flat scheme 9 months 15 months 4 months 100 flat scheme 23 months 8 months

150 12 months 29 months 9 months 300 12 months 60 months 9 months Horley North West 14 months 125 months 12 months Affordable Sales Unknown Clarification required

distribution Finance Debit Rate 6.5% Agree in principle.

Consortium of house builders May 2015 21 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Viability Appraisal RBBC Adopted General Assumptions Consortium Opinion Assumptions

Sales Fees All fees and marketing Agency Fees 1.25%. An additional flat rate allowance of £500 per unit is made for Disagree – reference local marketing material and a further £1,000 per unit is included for legal costs. Part 2 for further detail.

Part 2 - Assessment of Appraisal Inputs

4.6 As stated, there are a number of assumptions made by RBBC that cause concern. We have explored these points further and made reference to evidence where appropriate. The key areas of concern are as follows:

‘Up-to-date’ Evidence

4.7 It is fundamental that the appraisals are run with assumptions reflective of the current market to ensure that the rates are set at viable levels. The Consortium is therefore concerned that the Viability Report will be relying on data that has not been updated for some time and is some cases indexation has been used to estimate market movements. As such the Consortium feels it is fundamental that the CIL rates are formulated on up-to-date evidence rather than estimates and forecasted data, namely in relation to benchmark land value.

Typologies

4.8 RBBC tested 14 residential typologies in total, with 3 specific strategic sites modelled. The Consortium welcomes the testing of strategic sites, but feels this is insufficient as it does not test a large enough Sustainable Urban Extension (SUE) site, as originally stated within our Representations to the PDCS consultation (Page 14 paragraph 2.24). We have accordingly undertaken our own appraisal at 600 units (reference Part 3) to reflect the scale of development expected in the Core Strategy for SUEs (500-700 homes)

Gross to Net Land Take

4.9 Strategic sites will be required to provide public open space and recreation space that will reduce the net developable area. These additional land uses are a necessary part of any planning permission and contribute towards the acceptability of the scheme from the Council’s perspective. These factors must be considered appropriately to ensure the viability of Greenfield sites is not jeopardised.

4.10 It is important to note in respect of large scale sites such as land at North West Horley and other SUEs that development proposals are likely to change over time, flexing densities and therefore changing the gross to net ratio. In addition sites may be subject to a number of planning permissions throughout the development period, meaning that post the implementation of CIL they would be liable for the levy.

Consortium of house builders May 2015 22 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Scale of Development

4.11 The Consortium asks that RBBC would look to set a differential rate, by scale of development, in order to differentiate between other rural areas and the potential location / areas of the SUEs. This would allow for a greater level of flexibility and avoid the potential for sites to be captured by an unviable level of CIL in later phases of development.

4.12 This method has been adopted by other Local Authorities, who have addressed strategic sites via either a reduced or £ zero CIL rate to reflect the site-specific infrastructure delivery, and hence ability to secure said infrastructure via planning condition / Section 106 Agreement (see Appendix 4 for the LPAs which have adopted or are proposing £Nil rates). This reduces complexity and the Regulatory burden.

Benchmark Land Values (BLVs)

4.13 RBBC has modelled against a range of separate BLVs which are as follows:

Urban Residential Developments • High Density residential / mixed use - £3.6m (VP 1&2), £4.275m (VP 3) and £4.95 (VP 4) • Conventional housing - £3.15m (VP 1 & 2), £3.6m (VP 3) and £4.05m (VP 4).

Urban Extension Schemes and Horley North West Sector • £800,000 per net developable hectare.

4.14 To inform these BLVs, RBBC has sought to find examples of recent land transactions locally. They highlight that “There is some limited available information regarding greenfield land transactions” (Paragraph 88, Page 32 - Revised Viability Assessment Report – Appendices).

4.15 In respect of Urban Extension Schemes, the BLV used is £800,000 per net hectare which RBBC consider to be appropriate and have sighted only three transactions; a Greenfield (Green Belt) site with no formal allocation, a large strategic allocated site and a very small Greenfield (Green Belt) site with no formal allocation. Other than the second comparable, these are small sites, which would inherently achieve a higher land value than a true large scale strategic site. In addition it is important to factor in the planning position of Greenfield comparables, as the largest uplifts in value come at the point of allocation and obtaining planning. Meaning that an unallocated site in the Green Belt, in the market would be purchased at a discount for risk, therefore meaning the value is at the lower range of values for strategic Greenfield sites.

4.16 Savills has undertaken research on land transactions within the locality. For large strategic sites with a net developable area of circa 30-40%, research indicates that land has been purchased in excess of £1 million per net developable area. For commercial sensitivity reasons we cannot provide further detail, however the example show a considerable uplift over the adopted BLV and proves that a BLV of £800,000 per net developable hectare sits at the bottom end of the range currently being achieved for Greenfield sites.

Consortium of house builders May 2015 23 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Section 106/ 278

4.17 RBBC has allowed a cost of £1,000 per unit for urban residential schemes, £10,000 per unit for urban extensions and £14,300 for the North West Sector. In principle we believe these figures are reasonable to capture S106 related costs, however the level of estimated Section 106 contributions for the smaller typologies does not reflect the true costs associated with Section 278 works. Section 278 contributions typically cover traffic calming measures, provision and improvement of junctions and improvement of facilities for pedestrians and cyclists.

4.18 In addition for strategic site typologies we would highlight that £10,000 per unit would considered on the lower end of the range and £15,000 per unit would be more reflective of market conditions.

4.19 As stated within the Viability Report, “No account has been taken in the core appraisals of the recent Ministerial Statement by Brandon Lewis and changes to Planning Practice Guidance which indicate that affordable housing contributions should not be sought from sites of 10 units or less”. (Page 35 Paragraph 4.81)

4.20 The Consortium disagrees with this approach and are keen to see that the ‘fair share’ principle applies for CIL, and that adequate funding is obtained from all source to deliver the required infrastructure.

Build Costs

4.21 The levels of build costs applied within the Viability Report are of concern to the Consortium, because build costs have been steadily increasing over the past 24 months, as a result of rising material and labour costs. The impact of this is highlighted in Table 4.2 below, which shows the movement since the RBBC figures were adopted.

Table 4.2 – Movement in BCIS Build Costs RBBC May 2015 Movement

(£/m2) (£/m2) %

Development Type Housing schemes under £1,300 £1,330 + 2.28 5 units Housing schemes 5 or £1,080 £1,108 + 2.55 more units Urban extensions and £1,080 £1,170 + 8 Horley NW Flatted schemes under £1,260 £1,277 + 1.34 50 units Flatted schemes of 50 or £1,310 £1,330 + 1.51 more units Total Average 3.13% Movement Source: Savills (RBBC figures rebase date unknown. Utilised the same methodology as stated within Table 10 of the Viability Report)

4.22 This indicates an average increase of 3.13% in build costs for houses and flats. It is therefore imperative that RBBC updates their Viability Report and Appraisals to reflect current build cost estimates. It should also be highlighted that as the build costs link to a number of other inputs; an incorrect base build costs risks a significant underestimation of the true costs of development.

Consortium of house builders May 2015 24 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

4.23 It is important to note that it is unclear as the date of the BCIS rebase RBBC has used and therefore the date their build cost estimate has been adopted. As build costs are a moving factor it is essential that an element of ‘buffer’ is included (not to be confused with contingency or the build cost inflation for sustainability), as this approach would ‘future proof’ the build costs reducing the risk of underestimating the adopted build cost.

4.24 Looking in more detail as to the methodology used, in the instance of housing schemes under five units, RBBC have taken an average of 2 and 3 storey estate housing and then added an additional 20%. Although this is a practical approach, small unit schemes have more in common with the BCIS figures relating to ‘one off’ housing detached (3 units or less). We would therefore recommend a more realistic level would be between the one off figure of £1,685 psm (May 2015) and the current £1,108 psm (average of 2 and 3 storey estate housing) level, say £1,400 psm.

Professional Fees

4.25 The Consortium welcomes the changes in respect of professional fees, with an allowance of 12.5% for strategic sites, over a standard of 10%.

Abnormal Costs

4.26 As stated within the Viability Report “...some brownfield sites may encounter higher levels of ‘abnormal’ costs associated with decontamination, remediation or demolition. However, in order to provide a strategic rather than site specific overview of general viability across the borough, it is necessary to apply a set of reasonable generic assumptions rather than attempting to introduce complex refinements.” (page 24 paragraph 4.22). Whilst it is appreciated that abnormals are likely to vary significantly on a site by site basis, higher contingencies should be allowed for in the modelling to account for issues such as contamination and other unforeseen development costs that, when compounded with the cost of CIL and on site infrastructure requirements/ Section 106 contributions, could render the development unviable.

4.27 RBBC states in paragraph 5.4 (page 37) of the Viability Report that no allowance has been made for existing floorspace from either a demolition cost angle or a “netting off” from CIL liabilities side. The Consortium feels this is an under estimation of costs, as not all existing structures will be capable of ‘saving’ on CIL liability and abnormals do not just cover the cost of demolition. In addition, abnormal costs can be high even on Greenfield sites, and are not included within opening-up costs or a contingency.

4.28 The Consortium would ask that abnormal costs are included within all scenarios and not just within strategic sites where these have already been estimated.

Developers Profit

4.29 RBBC has chosen to adopt a profit margin of 20% on Gross Development Value (GDV) for the private housing and 6% on GDV for the affordable housing, reflecting a blended rate in the region of 17.5% on GDV within their appraisals. We would like to make it clear the minimum profit margin that lending institutions are currently prepared to accept, on residential development, is 20% on GDV and therefore the blended profit rate adopted by RBBC is below the minimum level required by national house builders.

Consortium of house builders May 2015 25 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

4.30 The NPPF states that to ensure viability, developments should provide competitive returns to a willing land owner and willing developer. A competitive return to a developer is one that provides a sufficient return for the developer to continue a successful business through the economic cycle, taking account of the risk profile of the business. We are therefore concerned that RBBC’s assumption is too low and does not take account of the minimum returns required by shareholders of quoted Plc house builders.

4.31 We have attached a report on competitive developer return (Appendix 3), which provides evidence on the minimum profit margins required by Plc house builders. The key focus is the distinction between gross (site level) margin and net operating margin. A point discussed in the Harman Report, which suggests that “overheads for house-building typically lie in the range of 5%-10% of gross development value”. This is particularly relevant for large Greenfield sites and regeneration areas, where large up-front costs have an impact on a developer’s required Return on Capital Employed (ROCE), as a higher margin is required to reflect the higher risk. This is new evidence, provided to counter previous Examiners decisions on profit, which were made in the absence of any evidence on this matter.

4.32 Taking this into account, we would therefore ask that a minimum profit level of 20% on GDV (blended) plus 25% ROCE across all tenures, subject to consideration of the risk profile of the scheme, is adopted in the viability testing.

Sales and Marketing Fees

4.33 The Consortium believes that the assumption of 1.25% on GDV for agency sales fees is inline with market expectations and sits within the range of 1.25% to 1.5%. On the other hand the Consortium disagrees with the provision of only £500 per unit for marketing costs and £1,000 per unit for legal costs. Marketing cost would normally be seen between 0.5% and 1% of GDV with legal fees being around 0.35% of GDV.

4.34 It is felt this is an under estimation of sales costs and should be increased inline with market expectations, to reflect true costs.

Viability Buffer

4.35 The CIL Guidance highlights the importance of a charging authority recognising the need for an appropriate balance when determining CIL rates. We have therefore sought to incorporate a viability buffer of 40% to reflect the risk attached to setting CIL rates at the edge of viability.

4.36 RBBC have utilised a series of sensitivity tests to flex the inputs, adjusting for a change in; sales values, build costs, S106 costs and gross to net developable area. Although this is a logical method, it is quite specific and does not factor other important inputs/assumptions like finance rates and build programme timing, all of which have a huge effect on development viability. The use of a blanket ‘buffer’ captures all the inputs/assumptions and better ensures that rates are not set at or too close to viable levels.

Consortium of house builders May 2015 26 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

General Appraisal Assumptions

Development Programme / Timing

4.37 The timing assumptions adopted by RBBC are consider reasonable in the most part and sit within the range of build and sales rates. The Consortium do however disagree with the 6 month delay after the start of the build period before sales begin.

4.38 This assumption is quite reasonable for smaller scale developments, but for strategic sites the time period isn’t sufficient . Our experience would point towards a 12 month delay between the start of build and sales to be more inline with market norms. It is recognised that there has been a separate provision for pre-construction works, however this should not be confused with the structural/foundation works associated with the building of units. It is in fact a period for infrastructure, site remediation, transport improvements and site preparation, to name but a few.

Discrepancies

4.39 To accurately mirror the typology appraisals within the Viability Report, Savills has analysed the appraisal/cash-flow summaries and found a few anomalies. It is particularly important to note that it has been extremely difficult to breakdown the larger site typology appraisals, as only cash-flow summaries were provided.

4.40 It would appear that sales fees on a number of the typologies appear to have captured both private and affordable sales, which would over estimate the total fees cost.

4.41 In addition it has proven very difficult to accurately assess the total floor-space and chargeable floor-space of the larger typologies as this information was not provided within the summaries. Table 15 of the Viability Report does state these areas, however from our own calculations these would seem to differ from the standard size assumptions. It is also worth noting that the surplus available for CIL psm figures in Table 15 are in contradiction to the ‘goal seek’ value found within the typology appraisals and there would appear to be some mistakes within the table. We have sought clarification from RBBC and have been informed that there are a number of errors within Table 15. The Consortium would request further clarification on the above points.

4.42 Lastly, there are a number of inputs within the RBBC appraisals, which require further clarification such as; the affordable housing transfer costs, building costs fee and lump some payment structures. The Consortium would appreciate clarification on these areas.

Overall

4.43 The Consortium consider that whilst the general methodology of utilising residual appraisals within the Viability Assessments is in line with industry practice, the report provided by the Council contains some assumptions which are concerning the Consortium, which may undermine the validity of the evidence that is being relied upon to justify the proposed CIL rates. As a result, the Consortium cannot agree to some of the points that have been raised by the report and feels that the rates set have not been based upon a robust evidence base, where it can be concluded that development will not be put at serious risk.

Consortium of house builders May 2015 27 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

4.44 Our clients therefore request that certain elements of the evidence be revised and made readily available, as summarised by the list below:

• Incorporation of a reasonable developers profit; • Incorporation of abnormal costs on large scale sites; • Full detailed appraisals assumptions for each typology; • Inclusion of site specific S106 costs for large scale sites; and • Evidence of an appropriate viability buffer.

Part 3 - Savills Assumptions and Appraisals

4.45 Given the concerns set out in Part 2, Savills has created a base appraisal to mirror the inputs by RBBC in the North West Horley appraisal and a further Sustainable Urban Extension Appraisal of 600 units.

4.46 Savills has sought to reproduce appraisals produced by RBBC, however there are a number of issues preventing us from doing so accurately. The appraisals have been constructed using Homes and Community Agency’s DAT model rather than industry recognised software, this has meant there are limitations to the level of accuracy that can be achieved.

4.47 We have been able to reproduce RBBC’s 1,510 unit typology appraisals, as close as possible, using our own ARGUS Developer appraisal software and have incorporated the assumptions set out in Tables 4.4 & 4.5 below. We have also created a 600 unit SUE typology extrapolating RBBC assumptions (from the 300 unit typology). We have sought to produce two specific typologies because we feel this is representative of proposed housing supply and demonstrates a good cross section of typologies.

4.48 We would highlight that our Base Appraisals are not site specific, and have been created for the purposes of general testing only, based on RBBC’s Appraisal assumptions. Our Base Appraisals are therefore not reflective of any specific site in the Borough.

Savills North West Horley Appraisal

Table 4.3 – Savills Base Appraisal Results RLV (inc CIL at Net Site Area (Ha) RLV per net RBBC BLV RLV at or £256) hectare above BLV RBBC Appraisal £44,640,000 55.9 £798,568 £800,000 No Savills Appraisal £48,985,414 55.9 £876,304 £800,000 Yes

4.49 It is apparent from Table 4.3 above that the Savills appraisal does not reach a similar level of Residual Land Value, even with the use of the same assumptions provided within the Viability Report. As stated within Part 2 there is a requirement for clarification a number of points and these elements have meant it is extremely difficult to replicate the RBBC Appraisal. This is in part due to what appears to be a number of errors and the fact only a cash flow was provided as part of the Viability Report Appendices Document.

Consortium of house builders May 2015 28 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

4.50 Given the concerns set out above, we have produced a set of alternative viability appraisals in order to demonstrate the impact of the underestimation of the following on the calculation of the maximum CIL rate:

1) Construction and Sales Timing; 2) Developer’s Profit; 3) Section 106 Allowance for Site Specific Costs; and 4) Build Costs. 5) Sales and marketing Fees

Table 4.4 – Alternative Viability Appraisal Assumptions for North West Horley Typology

Viability Appraisal RBBC Adopted Assumptions for North West Horley Typology Consortium Opinion Assumptions Values Open Market Value Value Level 1 Value level 2 Value level 3 Value level 4 Agree in principle.

Affordable Housing For rented units, OMV has been discounted by 55% and for intermediate (i.e. Agree in principle. shared ownership) units; a 35% discount has been applied. Value

Densities Per Hectare Housing >10 units: 30 dph Agree in principle. 10+ units: 35 dph Flats >25 units: 90 dph Agree in principle. 25+ units: 125 dph Urban Extensions 24 dph Agree in principle.

Consortium of house builders May 2015 29 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Viability Appraisal RBBC Adopted Assumptions for North West Horley Typology Consortium Opinion Assumptions Stamp Duty Land Tax Prevailing standard rates Agree in principle. Construction Costs Build Costs (£/m2 ) Type £ /m2 Externals £ /m2 Externals Urban extensions and Horley NW £1,080 12.5% (+ £10k £1,170 Agree in per plot) principle.

Abnormals £1,400,000 (Oil Pipeline) Agree in principle, but require further clarification Building Regulation / 4% cost inflation has been included Agree in principle.

sustainability Contingency Larger complex schemes at 7.5% Agree in principle. Professional Fees Larger complex schemes at 12.5% Agree in principle. Section 106 Affordable Housing 15 net dwellings or more at 30% Agree in principle.

Mix: 40:60 between rented and intermediate S106 Financial North West Sector at £14,300 per unit Agree in principle. Contribution (per unit) Section 278 Financial Contribution Nil – assumed included in above contribution. Agree in principle. Profit Developer Profit 20% of GDV for Residential. 6% of GDV from Affordable Housing. 20% on GDV blended. Timescales Pre-construction period 14 months Agree in principle. Build Rate (units per 4 units per month month)

Sales Rate (units per 6.5 units per month per outlet month)

Principle Post-construction Construction Horley North West 125 months 12 months Agree in principle. Increase sales commencement to 12 months. Affordable Sales Unknown Assimilate ‘golden brick’ method distribution

Finance Debit Rate 6.5% Agree in principle.

Consortium of house builders May 2015 30 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Viability Appraisal RBBC Adopted Assumptions for North West Horley Typology Consortium Opinion Assumptions

Sales Fees All fees and marketing Agency Fees 1.25%. An additional flat rate allowance of £500 per unit is made for Disagree – 1% local marketing material and a further £1,000 per unit is included for legal costs. Marketing. 0.35% Legal

Table 4.5 – Alternative Viability Appraisal Assumptions for 600 Unit Base Typology

Viability Appraisal RBBC Adopted General Assumptions Consortium Opinion Assumptions

Values Open Market Value Value Level 1 Value level 2 Value level 3 Value level 4 Agree in principle.

Affordable Housing For rented units, OMV has been discounted by 55% and for intermediate (i.e. Agree in principle. shared ownership) units; a 35% discount has been applied. Value

Densities Per Hectare Housing >10 units: 30 dph Agree in principle. 10+ units: 35 dph Flats >25 units: 90 dph Agree in principle. 25+ units: 125 dph Urban Extensions 24 dph Agree in principle.

Consortium of house builders May 2015 31 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Viability Appraisal RBBC Adopted General Assumptions Consortium Opinion Assumptions

Construction Costs Build Costs (£/m2 ) Type £ /m2 Externals £ /m2 Externals Urban extensions and Horley NW £1,080 12.5% (+ £10k 1,170 Agree in per plot) principle.

Abnormals No abnormal costs incorporated. Agree in principle, but require further clarification Building Regulation / 4% cost inflation has been included Agree in principle.

Mix: 40:60 between rented and intermediate S106 Financial Urban extension schemes at £10,000 per unit Disagree – Higher end

Contribution (per unit) of the range more appropriate at £15,000 per unit Section 278 Financial Contribution Nil – assumed included in above contribution. Agree in principle. Require further clarification. Profit Developer Profit 20% of GDV for Residential. 6% of GDV from Affordable Housing. 20% on GDV blended. Timescales Pre-construction period 12 months Agree in principle. Increase sales commencement to 12 months.

Build Rate (units per 4 units per month (after an initial 6 month period for sub-structure and other site preparation/landscaping works) month) Sales Rate (units per 4 units per month month)

Affordable Sales Unknown Assimilate ‘golden brick’ method distribution Finance Debit Rate 6.5% Agree in principle.

Consortium of house builders May 2015 32 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Viability Appraisal RBBC Adopted General Assumptions Consortium Opinion Assumptions

Table 4.6 – Alternative Maximum CIL Rates

Charging Net Site Max. CIL CIL Chargeable Private GIA per 40% Proposed Typology RLV (£/ha) BLV (£/ha) Max. CIL Zone Area (Ha) Capacity Floor Space HA (Sq M) Buffer CIL Rate

North West Horley - 4 55.9 £876,304 £800,000 £76,304 130,515 2,335 £33 £20 £180 R&BBC Assumptions North West Horley - Savills 4 55.9 £827,147 £800,000 £27,147 130,515 2,335 £12 £7 £180 Assumptions 600 Unit Typology - R&BBC 5 25 £1,384,422 £800,000 £584,422 51,690 2,068 £283 £170 £200 Assumptions 600 Unit Typology - Savills 5 25 £952,492 £800,000 £152,492 51,690 2,068 £74 £44 £200 Assumptions Source: Savills

4.51 The results in Table 4.6 demonstrates that only the 600 base (SUE) appraisal remains above the proposed CIL rates. Once a 40% viability buffer is factored in, even that typology also falls short of reaching the proposed CIL rate. When market facing assumptions are applied in the case of the ‘Savills Assumptions’ appraisals, it is clear the proposed CIL rate is far above the maximum CIL margin (£74 psm) and when the buffer is applied on top, the level of viability reduces even further to £44 psm.

4.52 A 40% viability buffer is necessary to reflect the already existing risk to the housing supply and to ensure the delivery of infrastructure to support the level of growth across the Borough. If there is not sufficient headroom applied to the CIL rate the risk to housing delivery is adverse.

4.53 This analysis illustrates that the proposed CIL rates are unviable and do not adequately incorporate a viability buffer. The rates are subsequently being proposed above the margin of viability. We would therefore advise that the Council reviews its viability evidence and resulting CIL rates for the strategic sites, to ensure that they are not set at the margins of viability.

4.54 Based on our analysis above we would recommend that a rate of £50 psm is applied to all of the SUE / Strategic Sites and a £ zero rate is applied to the North West Horley Site to ensure the delivery of these sites, which are essential for the housing delivery of RBBC. It is important to note that we feel the BLV is set at the lower range of values, according to anecdotal evidence. Accordingly, this would mean that if the current BLV was to increase, this would only reduce the level of surplus available for CIL.

Consortium of house builders May 2015 33 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

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Consortium of house builders May 2015 34 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

5. Effective Operation of CIL

5.1 Despite the narrow scope of the Examination, we urge the Council to make clear at the earliest opportunity, the supporting documentation needed to operate CIL and to make it available for consultation. Practically, this needs to be done as soon as possible, so that participants and stakeholders are able to comment on the effective operation of CIL. Whilst this supporting information is not tested at Examination, this information is critical to allow for the successful implementation of CIL and to demonstrate that the CIL has been prepared positively and supports sustainable development.

5.2 The documentation should include:

• Guidance on how to calculate the relevant chargeable development/ level of CIL • Guidance on liability to pay CIL/ Appeals process • Policy for payments by instalments • Approach to payments in kind • Guidance on relief from CIL and a policy on exceptional circumstances for relief from CIL

5.3 Further comments on a selection of there points is provided.

Relief

5.4 With regard to Discretionary Relief and Exceptional Circumstances Relief, we note that RBBC has not set any of these policies out in their DCS.

5.5 Savills does not consider there to be any detriment arising from the Council making available such reliefs within policies as part of its Charging Schedule, as the Council will still retain control over the application of the policies. There are strict tests surrounding the availability and applicability of Exceptional Circumstances Relief. It would therefore only be applicable to those schemes that can justify the need for it and meet those strict tests.

5.6 The consortium therefore considers it imperative that RBBC makes both Discretionary and Exceptional Circumstances Relief available from the adoption of CIL. We would therefore ask that relief is included in the Charging Schedule and that the intended approach to doing so is outlined at the Draft Charging Schedule consultation stage.

Instalments Policy

5.7 The consortium is concerned that RBBC has not published an Instalments Policy, as it is important that the timing of delivery of development is considered to ensure that the CIL does not put unnecessary pressure on cash flow and viability.

5.8 Savills therefore recommends the following thresholds as a starting point:

Consortium of house builders May 2015 35 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Table 5.1: Recommended Instalments Policy

CIL Liability Number of Instalments Payments

Up to £25,000 1 Full payment within 120 days of commencement

£25,001 - £100,000 2 120 days after commencement 50% 240 days after commencement 50% £100,001 - £250,000 3 120 days after commencement 20% 240 days after commencement 40% 360 days after commencement 40%

£250,001 - £500,000 4 120 days after commencement 10% 240 days after commencement 30% 540 days after commencement 40% 720 days after commencement 20% Greater than £500,001 4 120 days after commencement 10% 360 days after commencement 30% 720 days after commencement 40% 900 days after commencement 20%

Consortium of house builders May 2015 36 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

6. Conclusion

6.1 This representation has been prepared by Savills on behalf of a consortium of house builders including Crest Nicholson, Miller Homes, Persimmon, Taylor Wimpey and Thakeham Homes (“the Consortium”). As set out at the start of this representation there are four key tests the charging schedule must pass at Examination:

i. The charging authority has complied with the required procedures set out in part 11 of the Planning Act 2008 and the CIL Regulations; ii. The charging authority’s draft charging schedule is supported by background documents containing appropriate available evidence; iii. The proposed rate or rates are informed by and consistent with, the evidence on economic viability across the charging authority’s area; and iv. Evidence has been provided that shows the proposed rate (or rates) would not threaten delivery of the relevant Plan as a whole

6.2 Overall, RBBC has made some changes to the Charging Schedule following the PDCS consultation stage in January 2015, including reducing the Urban Extension and rest of the Borough zone (now called Zone 5) from £240 to £200 psm. However the concerns raised by the Consortium for that previous stage are still relevant and explored further in this representation.

6.3 Based on the appraisals undertaken by Savills, as set out in Section 4, the rate of CIL for NW Horley and the SUEs (potentially defined by scale of development) should be reduced to £NIL and £50 psm respectively to ensure the delivery of housing in accordance with the Core Strategy.

6.4 Savills strongly recommends that a lower rate of CIL is proposed for development of over 200 dwellings (defined by scale), in order to encompass sites which will become necessary to meet the Council’s housing needs, such as the urban extensions planned in the Core Strategy under Policy CS6. These sites would be rendered unviable if they are subjected to rates of £200 psm currently proposed for Zone 5 based on the present Regulation 123 List. Savills has submitted evidence to demonstrate this. The Zone 5 ‘standard rate’ across the Borough is also particularly surprising, given the rate of CIL in the context of other neighbouring Authorities, and the divergence in values across the Borough (as recognised by the Borough’s own evidence of four different value points).

6.5 RBBC has also not tested 500 or 700 unit typologies to reflect the planned housing land supply, a key shortcoming of the CIL evidence base. This is necessary to account for the substantial uplift proposed with CIL, in comparison to the previous Section 106 tariff regime, and also so that further evidence may be obtained/ tested in respect of the potential SUEs. RBBC already knows a reasonable amount of information about the likely SUE sites following the Core Strategy preparation process. In addition, the Council’s through its preparation of the Development Management Policies Document (which will allocate SUE sites) should consider appropriate infrastructure delivery and provide detail as to how it relates to the proposed CIL rate in accordance with the Regulations and guidance.

Consortium of house builders May 2015 37 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

6.6 In respect of NW Horley, the site benefits from planning permission for circa 1,510 dwellings. The permission was accompanied by a Section 106 agreement, recently signed and thus was in accordance with CIL Regulations 122/123. The various planning obligations were therefore ‘site specific’ and/or necessary to make the development acceptable in planning terms. RBBC proposes a CIL rate of £180 psm for NW Horley, in addition to a ‘residual’ level of Section 106, reduced via the effect of the proposed Regulation 123 List. The proposed imposition of a relatively high CIL rate on the major strategic site in RBBC runs contrary to a number of other examples nationally of low or £Nil CIL rates for strategic sites (numbering 30 plus – see Appendix 4). There are good reasons for this, not simply viability, but reduced planning complexity in respect of the potential for future amendments to planning permission(s), and avoidance of CIL charges.

6.7 Therefore, the consortium has concerns relating to the CIL rates proposed and the assumptions used in the viability models as highlighted in Section 4. In assessing the Council’s evidence, Savills has recreated as closely as possible, the Council’s appraisal model, and whilst many of the inputs used by the Council are reasonable, a number of the fundamental assumptions are challenged, including profit on GDV, build and abnormal costs. In addition, further evidence is required for the Consortium to be satisfied that an assumption of £10,000 per unit in Section 106 for SUE sites is credible.

6.8 The consortium remains open to a meeting with the Council to discuss the approach taken and to discuss common ground in advance of the Examination. Ideally, the consortium would like RBBC to consider a re-consultation of the DCS.

6.9 For the avoidance of doubt, the Consortium requests the right to be heard at the Examination.

Consortium of house builders May 2015 38 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Appendix 1: List of Documentation

General

Community Infrastructure Levy Guidance, DCLG (2014), Planning Practice Guidance Website Community Infrastructure Levy Regulation (2010) (as amended) National Planning Policy Framework, DCLG (March 2012) Planning Act (2208) (as amended) CIL – Getting it Right, Savills (UK) Ltd (January 2014) Developer Profit, Savills (UK) Ltd (October 2014)

Reigate and Banstead Borough Council

Borough Local Plan – Saved policies (April 2005) Core Strategy (July 2014) Reigate and Banstead Borough Council Draft Charging Schedule (March 2015) Reigate and Banstead Borough Council Draft List of Relevant Infrastructure (March 2015) Reigate and Banstead Borough Council Draft Position Statement on the use of CIL and other developer contributions (March 2015) Reigate and Banstead Borough Council CIL Revised Viability Assessment – Main Report (March 2015) Reigate and Banstead Borough Council CIL Revised Viability Assessment – Appendices (March 2015) Reigate and Banstead Borough Council Infrastructure Delivery Plan Addendum (March 2015) Reigate and Banstead Borough Council Background Evidence on Section 106 and Affordable Housing (October 2014)

Consortium of house builders May 2015 39 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Consortium of house builders May 2015 40 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Appendix 2: CIL - Getting it right, Savills

Consortium of house builders May 2015 41 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Consortium of house builders May 2015 42

A report from Savills Research, sponsored by the Home Builders Federation

CIL – Getting it right January 2014

A nation of renters? Examining the opportunities and challenges facing the private rented sector in the UK

Setting Community Infrastructure Levy Rates to Support the Construction of More New Homes

■ For local planning policies to be ■ These are important markets, in ■ The capacity to pay CIL varies viable, there is a three way trade-off which 85% of residential development widely, according to local policy on between the costs of CIL, Section 106 outside London takes place. At sales Section 106 payments. Even with funding of infrastructure and affordable values of £225 per sq.ft., in order for scaled back Section 106 policy, the housing policy, with the costs of there to be enough ‘in the pot’ for CIL cost of Section 106 infrastructure is local standards and the move to zero and Section 106 combined to be paid unlikely to be less than £3,000 per carbon being additional costs to be at £10,000 per plot, affordable housing plot on large greenfield sites and it factored into the trade-off. policy would need to have been set at can often amount to significantly 10%. This is the trade-off that needs more than £10,000 per plot. ■ Based on generic assumptions and to be recognised when Local Plans are before local specifics, the capacity tested for their viability. ■ Viability testing of CIL cannot be to pay CIL and Section 106 on large robust if there is no clarity on Section greenfield sites equates to between ■ In stronger markets, there is more 106 policy. From the other end of the 20% and 30% of unserviced land capacity to fund infrastructure via CIL lens, a zero CIL rate for strategic sites value in many markets. However, this and Section 106. At a sales value of offers the greatest flexibility to use capacity falls away towards zero where £300 per sq.ft., with a 30% affordable Section 106 to fund infrastructure and affordable housing policies apply at housing policy, there is enough 'in the mitigate site impact, subject to the higher percentages in excess of 30%, pot' for CIL and Section 106 to be paid restrictions in the revised regulations. and at lower percentages in markets in at £15,000 per plot. However, this falls which potential sales values for volume away to around £10,000 per plot if sales are below £250 per sq.ft. affordable housing policy is set at 40%. savills.co.uk/research 01 CIL – Getting it Right

Consistency is key What is the benchmark? CIL is designed to contribute ■ towards the funding of local The benchmark is based on the residual development appraisal of infrastructure, to facilitate sustainable a large greenfield site, with generic assumptions relating to significant development. This is clearly a variables. It gives a starting point for review of policy viability, before desirable outcome, provided the levy examination of local specifics. is set at a level that does not threaten the viability of the development plan. How much CIL can Our objective in this report is to be paid? "It is rarely, if ever, seek more consistency in the rate The National Planning Policy setting process, with particular Framework requires that local the case that the regard to viability assessment, as planning policies should be tested the majority of authorities move for their viability, such that: pot of money is towards implementation of CIL charging schedules. It is written “The sites and the scale of large enough to with our experience of advising and development identified in the plan fund all policies" representing members of the Home should not be subject to such a scale Builders Federation on appropriate of obligations and policy burdens that rate setting at a local level across their ability to be developed viably The most crucial assumption in England and Wales. is threatened. To ensure viability, the policy testing process is the the costs of any requirements likely benchmark level of land value Within this report, we review the rates to be applied to development, such required to provide a competitive at which CIL is being set by charging as requirements for affordable return to land owners, across the authorities across the country for housing, standards, infrastructure types of site that make up the the residential development of contributions or other requirements housing land supply in the charging large greenfield sites, as these are should, when taking account of the authority (usually the local authority such an important part of national normal cost of development and area). This should be set at a level housing land supply. Alongside this, mitigation, provide competitive which includes a ‘viability cushion’, we present a new benchmark for returns to a willing land owner and as recommended in the Local the capacity to pay CIL and Section willing developer to enable the Housing Delivery Group guidance 106 on such sites, based on a broad development to be deliverable.” on the viability testing of local plans. view on development economics, (para 173) When testing the viability of CIL, this local market strength and affordable reflects the government guidance housing policy. The costs of CIL and planning that CIL should not be set at the obligations are paid out of land margins of viability. This is particularly This paints a picture of the diverse value, as long as there is sufficient important for CIL, which is a fixed approach that charging authorities value remaining for the land to come charge with no flexibility for variance, are taking to the rate setting process. forward for development (benchmark should individual sites be unviable. The result is wide variation in how land value). If the residual value authorities are striking the balance remaining (after deduction of all The viability test will establish the between fund raising and economic costs from total revenues) is too low, pot of money that is available from viability, in order to facilitate the scale then the land is not economically development, to fund policies. It is of development outlined in their viable to develop, as shown in Graph rarely, if ever, the case that the pot Local Plans. 1 below. of money is large enough to fund all policies, as the cost of delivering infrastructure is so substantial. If graph 1 viability testing of the Local Plan and Cumulative impact of policy on financial viability CIL is carried out concurrently, then the local authority can choose which policies take precedence.

However, if introduction of a CIL Residual land value charging schedule follows the Local Viable policies Benchmark Plan, then the policies in the Plan (All revenues land value less all costs Unviable policies must be costed fully in the testing of including finance CIL. This includes affordable housing and return to developer) policy, Section 106 funding for infrastructure, any local standards that Residual land value go beyond national standards and the additional known policy costs of Cost of CIL, Section 106, affordable housing and local standards moving towards zero carbon by 2016. In this case, CIL may be ‘crowded Source: Savills Research out’ by the cost of other policies.

02 January 2014

How does viability vary authorities need to work together to at lower affordable housing policies across markets? find ways of bringing sites forward, of 10% and 20% in higher value To take a view on the viability of using policy flexibility and whatever markets are greyed out in the tables, policies across the country, we have public investment in infrastructure as such policies are unlikely to apply developed a model for the viability that can be made available. in these areas. of large greenfield sites in different strength markets. The output is a Even in mid-priced markets there This is all based on generic benchmark amount available to is a viability squeeze. For instance, assumptions relating to significant pay CIL, Section 106 infrastructure at sales values of £225 per sq.ft., variables, such as the proportion funding and the cost of local policies, in order for there to be enough ‘in of the site that is developable, the taking account of affordable housing the pot’ for CIL and Section 106 costs of site infrastructure and local policy. It gives a starting point for combined to be paid at £10,000 per land values. The specifics of the local review of policy viability, before plot, affordable housing policy should market may differ from these generic examination of local specifics. be set at 10%. assumptions.

Table 1 shows the benchmark In stronger markets, there is more If there is evidence of Section 106 amount per plot, as an average capacity to fund policies. At a sales payments having been agreed and across all tenures. This varies value of £300 per sq.ft., with a 30% paid at higher levels, then the specific significantly, according to sales affordable housing policy, there is circumstances of these sites should value and affordable housing policy, enough in the pot for CIL and Section be understood, to test whether they with little or no level of CIL being 106 to be paid at £15,000 per plot. are representative of the economics viable in lower value markets, where However, this falls away to around of the bulk of the land supply pipeline sales values are at £175 per sq.ft. In £10,000 per plot if affordable housing in the district. these markets, developers and local policy is set at 40%. Viable amounts

Table 1 Amount available for CIL and S.106 (£ per plot, all tenures)

Sales value per sq.ft. Affordable Housing % 350 325 300 275 250 225 200 175 150 0% 45,800 39,400 33,000 26,600 20,200 13,800 7,400 1,000 0

10% 38,300 32,700 27,100 21,500 15,900 10,200 4,600 0 0

20% 30,900 26,000 21,200 16,400 11,500 6,700 1,800 0 0

30% 23,400 19,400 15,300 11,300 7,200 3,100 0 0 0

40% 16,000 12,700 9,500 6,200 2,900 0 0 0 0

50% 8,600 6,100 3,600 1,100 0 0 0 0 0

Source: Savills Research

savills.co.uk/research 03 CIL – Getting it Right

Table 2 Amount available for CIL and S.106 as % of unserviced land value

Sales value per sq.ft. Affordable Housing % 350 325 300 275 250 225 200 175 150

0% 37% 37% 36% 35% 34% 31% 26% 8% 0%

10% 35% 35% 34% 33% 31% 28% 20% 0% 0%

20% 33% 32% 31% 30% 27% 22% 11% 0% 0%

30% 30% 29% 27% 25% 21% 14% 0% 0% 0%

40% 25% 23% 21% 18% 11% 0% 0% 0% 0%

50% 17% 15% 11% 5% 0% 0% 0% 0% 0%

Source: Savills Research

Land Value Capacity in Graph 2. Outside London, 85% fund infrastructure from planning Expressing the benchmark as a of development is in these markets. obligations and levies in markets proportion of land value gives a Clearly, development does take place where sales values are less than useful perspective on the capacity to in these mid- to lower-value markets, £250 per sq.ft. Many of the country’s pay CIL and Section 106. In higher generally on smaller sites that are less allocated greenfield sites are located value markets, the capacity to make expensive to develop. Sales values on in these markets, so other sources of the combined payment is between these smaller sites are not constrained infrastructure funding will be required 20% and 30% of unserviced land by the competitive sales environment here. It also indicates that allocation value at 30% affordable housing, but found on larger sites, so their viability of more large greenfield sites in higher this falls away towards zero at higher can be supported by sales values that value markets would release more affordable housing policies in excess are higher than those achievable on capacity to fund infrastructure from of 30%, particularly in markets where the larger sites. obligations and levies. sales values are below £300 per sq.ft. (Table 2). What is at issue here is the urgent The Three Way Trade-Off need to bring forward large sites in Section 106 payments are varying This is important, as more than areas where unmet housing need is considerably in the emerging CIL 70% of residential development is greatest, as national housing need world, depending on whether local in markets where new build sales cannot be met without development of policy is to scale back Section 106 value potential for volume sales is no such sites. The analysis demonstrates alongside CIL, or whether significant more than £250 per sq.ft, as shown there is only a limited potential to site specific infrastructure will continue to be funded via Section GRAPH 2 106. Some authorities have stated Housing completions in England, by volume new build sales that Section 106 on large sites will be scaled back to amounts in the value potential order of £3,000 per plot, to cover ■ Out of London ■ London the amounts typically payable for 30,000 smaller scale road and pedestrian connections, play parks and

25,000 community buildings.

In other cases, major items of 20,000 transport and education infrastructure will be funded via Section 106 on 15,000 the large greenfield sites. At the East Cambridgeshire examination, a higher figure of £10,000 per plot was used 10,000 as an assumption, but funding of such items of major infrastructure can 5,000 exceed £15,000 per plot.

Housing Completions (Apr 2012 - Mar 2013) 0 Whether Section 106 payments Up to 150 150-175 175-200 200-225 225-250 250-275 275-300 300-325 325-350 More are nearer £3,000 or £15,000 per than 350 New build sales value potential for volume sales (£ per sq.ft.) plot has a dramatic impact on the amount of CIL that is payable within Source: Savills Research Note: London sales values are shown for context only, as these are not relevant to the values achievable on greenfield sites our benchmark amount, as shown in

04 January 2014

Table 3 Amount available for CIL – assuming £3,000 S.106 per plot (all tenures)

Sales value per sq.ft. Affordable Housing % 350 325 300 275 250 225 200 175 150 0% 420 360 300 230 170 110 40 0 0 10% 390 330 270 200 140 80 20 0 0 20% 350 280 230 170 110 50 0 0 0 £ per sq.m. of 30% 290 230 170 120 60 0 0 0 0 market housing 40% 210 160 110 50 0 0 0 0 0 50% 110 60 10 0 0 0 0 0 0

0% 11% 10% 9% 8% 6% 5% 2% 0% 0% 10% 10% 9% 8% 7% 5% 3% 1% 0% 0% 20% 9% 8% 7% 6% 4% 2% 0% 0% 0% % of sales value 30% 8% 7% 5% 4% 2% 0% 0% 0% 0% 40% 6% 5% 3% 2% 0% 0% 0% 0% 0% 50% 3% 2% 0% 0% 0% 0% 0% 0% 0%

Source: Savills Research

Table 4 Amount available for CIL – assuming £15,000 S.106 per plot (all tenures)

Affordable Sales value per sq.ft. Housing % 350 325 300 275 250 225 200 175 150 0% 300 240 180 110 50 0 0 0 0 10% 260 190 130 70 10 0 0 0 0 20% 200 140 80 20 0 0 0 0 0 £ per sq.m. of 30% 120 60 0 0 0 0 0 0 0 market housing 40% 20 0 0 0 0 0 0 0 0 50% 0 0 0 0 0 0 0 0 0

0% 8% 7% 6% 4% 2% 0% 0% 0% 0% 10% 7% 5% 4% 2% 0% 0% 0% 0% 0% 20% 5% 4% 2% 1% 0% 0% 0% 0% 0% % of sales value 30% 3% 2% 0% 0% 0% 0% 0% 0% 0% 40% 1% 0% 0% 0% 0% 0% 0% 0% 0% 50% 0% 0% 0% 0% 0% 0% 0% 0% 0%

Source: Savills Research

Tables 3 and 4. At the scaled back At higher levels of Section 106 on what is funded via each level of Section 106 of £3,000 per of £15,000 per plot (Table 4), the mechanism during the rate plot (Table 3), the viable level of CIL capacity to pay CIL in addition is setting process. reaches £170 per sq.m. (around 5% much lower, falling away to zero in of sales value) in higher value sales most markets, other than the higher As such, the so-called ‘Regulation markets of £300 per sq.ft., at an value markets in which sales values 123 list’ of infrastructure is now part affordable housing policy of 30%. exceed £300 per sq.ft. of the evidence base required during the rate setting process, although However, at the 40% affordable The revised CIL Guidance recognises it is regrettable that the proposed housing policy that often applies in the need for clarity on the interaction requirements for formal consultation such markets, this is squeezed to between CIL and Section 106, by on any subsequent changes to this £110 per sq.m. formalising the need to be explicit list have not been introduced.

savills.co.uk/research 05 CIL – Getting it Right

Appraisal assumptions Table 5 The benchmark is the result of a Assumptions summary residual development appraisal, adopting a standard set of Net Dev Area (% gross area) 50% assumptions which are shown in Interest rate 6.5% Table 5. Amongst these, the appraisal should allow for a competitive return Marketing (% of sales) 3% to the developer. We use 20% margin Professional fees (% of build costs) 12% on gross development value across Additional build cost to 2013 Building Regulations (£ per dwelling) 1,000 all tenures, in line with evidence that this is a minimum requirement across Infrastructure (£ per dwelling) 20,000 the cycle. Density (dwellings per acre) 14.2 The allowance for on-site infrastructure, at £20,000 per plot, is in Dwelling size (sq.ft.) 1,030 the middle of the range of £17,000 to Coverage (sq.ft. per net dev acre) 14,600 £23,000 per plot outlined in the Local Developer profit on all GDV 20% Housing Delivery Group guidance. (excluding marketing and finance, to cover overheads)

The proportion of the site that is Sales value (£ per sq.ft) 300 250 200 developable varies widely. We Affordable value as % of market value 43% 48% 55% have assumed 50% of the site is Build cost (£ per sq.ft) 97 91 86 developable for residential use, but this is often lower and can be as low Land value benchmark inc. buffer (£000 per gross acre) 290 190 95 as 30%, in which case the amount available to pay CIL and Section 106 These are generic assumptions for larger sites with a capacity of more than 500 homes. Local specifics will vary. On smaller sites, costs of infrastructure may be lower but benchmark land values are likely to be higher. will be lower than the CIL benchmark presented here. both minimum land value and market The Local Housing Delivery Group Land Value and land value, as shown in Graph 3. guidance recommends that evidence Viability Buffer of minimum land values in option It is crucial to set a benchmark land Minimum land value represents agreements is used as a reference value to represent a competitive the lower end of land owners’ point for setting a benchmark land return to land owners, such that the expectations of realisable value. value, subject to addition of a viability local land supply will continue to It is a feature of option agreements cushion, to include consideration come forward for development. between land owners and of the costs and risks involved in developers, representing the promoting land through the planning Our benchmark appraisal uses a minimum value at which land will system. benchmark land value that includes be released by the land owner to a viability cushion. This has regard to the developer. Market land value is, by definition, the value at which land will trade freely GRAPH 3 in the current system. If benchmark Land value benchmarks and risks to delivery land value is set at the lowest end of the range between minimum and market land values, then high risks of Establishing the Benchmark Land Value Market Value non-delivery will be introduced into the of serviced land development market.

Accordingly, we set the viability cushion at 50% of the gap between Market Value minimum land value and the market of unserviced land

Y value of unserviced land (before R considering deductions for CIL and Section 106). Benchmark Land Value Reflecting competitive returns to the landowner To avoid setting CIL at "It is crucial to set ISK TO DELIVE

the margins of viability R Minimum Land Value a benchmark land Agreed in option agreements Adjusted to include premium to value to represent incentivise landowner to release land a competitive return Agricultural Land Value

Source: Savills Research to landowners"

06 January 2014

Variation in approach to 5). This is partly because there are The Winchester headroom is a rate setting at local level fewer authorities within this group consequence of a zero rating of We have compared adopted and with relatively low sales values, which large greenfield sites for CIL, mindful emerging CILs with our benchmark, continue to hold back the viability of the benefits of creating flexibility in charging authorities where large of larger sites. for the Section 106 payment. greenfield sites form part of the housing land supply. However, of these areas with CIL at The contrast with the unviably examination, few have the headroom high level of CIL proposed in It can be seen in Graph 4 that many to pay a substantial amount of Section Mid Sussex is stark. The same implemented CILs have been set at 106 in addition to CIL. Winchester is patterns have emerged amongst a level in excess of our benchmark, the exception, where there is likely to CILs at the draft (see Graph 6 indicating a threat to delivery of the be headroom for Section 106 to be overleaf) and preliminary draft authority’s development plan. paid at around £10,000 per plot. charging schedule stages.

If this is the case, having taken account of local specifics, then the GRAPH 4 charging authority will have failed to CIL and S.106 benchmark for large greenfield sites: demonstrate that they have struck Implemented CILs an appropriate balance between the ■ CIL — Viable CIL & S.106 combined at AH policy desirability of funding from CIL and --- Viable CIL & S.106 at 20% AH --- Viable CIL & S.106 at 10% AH its effects on the economic viability 35,000 of development across the whole area, as now required by the latest 30,000 amendments to the regulations. 25,000

Some of these early adopters did 20,000 not appraise affordable housing policy at the full requirement that is 15,000 shown in the chart. Following current 10,000 practice at examination, an authority would now have to formally adopt a all tenures) £ per plot (across 5,000 lower affordable housing requirement in order to set CIL at these levels. 0 Newark & South Preston Shrop- Hunting- Norwich Broadland East Mid Exeter Fareham Oxford Graph 4 shows the increased Sher- Ribble (30%) shire donshire (33%) (40%) Cam- Devon (35%) (40%) (50%) headroom for CIL and Section 106 wood (30%) (33%) (40%) bridge- (35%) (30%) shire that is created by adopting a lower (30%) affordable housing requirement of Charging authorities + affordable housing policy either 10% or 20%. Lower sales value Higher sales value Source: Savills Research (using Hometrack sales value data) In the one case where the benchmark sits above CIL in the chart, there is GRAPH 5 headroom for Section 106 in addition to CIL. In the case of Oxford, there is CIL and S.106 benchmark for large greenfield sites: likely to be headroom for Section 106 CILs at or post Examination to be paid at around £6,000 per plot ■ CIL — Viable CIL & S.106 combined at AH policy in addition to CIL, according to the --- Viable CIL & S.106 at 20% AH --- Viable CIL & S.106 at 10% AH benchmark. 35,000

30,000 Charging authorities should be explicit about their policy intention on 25,000 additional Section 106 when setting CIL rates. As noted above, such 20,000 payments can be substantial on a large greenfield site, to mitigate the 15,000 impact of development of that site. The need for clarity on this point has 10,000 been emphasised by the forthcoming all tenures) £ per plot (across 5,000 changes to the CIL Regulations. 0 The charging schedules that are at Swindon Sedge- South Bedford Teign- West East Chelms- West Mid Winchester (30%) moor Norfolk (30%) bridge Dorset Devon ford Berkshire Sussex (40%) the examination stage (including (30%) (33%) (30%) (35%) (25%) (35%) (40%) (30%) those examined but not implemented) Charging authorities + affordable housing policy include fewer authorities where little or no CIL is viable at the adopted Lower sales value Higher sales value affordable housing policy (Graph Source: Savills Research (using Hometrack sales value data)

savills.co.uk/research 07 CIL – Getting it Right January 2014

GRAPH 6 CIL and S.106 benchmark for large greenfield sites: "This exercise has revealed Draft CILs ■ CIL — Viable CIL & S.106 combined at AH policy inconsistencies in the way in --- Viable CIL & S.106 at 20% AH --- Viable CIL & S.106 at 10% AH 35,000 which setting of CIL viability 30,000 is being approached across 25,000 the country" 20,000 In these areas, affordable housing policy 15,000 has been set at too high a level in mid- 10,000 to lower-value markets for there to be any headroom for either CIL or Section £ per plot (across all tenures) £ per plot (across 5,000 106. Whilst some authorities with draft schedules, such as Cambridge, have 0 Lincoln West North Gedling Col- Harro- Wealden Bracknell Cam- headroom for Section 106, others have (25%) Lindsey Kesteven (30%) chester gate (35%) Forest bridge proposed unviably high level of CIL. In (25%) (25%) (35%) (50%) (25%) (40%) the case of Bracknell Forest, the 25% Charging authorities + affordable housing policy affordable housing policy gives some Lower sales value Higher sales value room for CIL, compared with other Source: Savills Research (using Hometrack sales value data) authorities at 40% affordable housing. However, the proposed rate is unviably high, given the substanstial items of GRAPH 7 infrastructure that will be funded by Progress on CIL implementation (England & Wales) Section 106, in addition to CIL. Number of local authorities 0 20 40 60 80 100 120 More consistency needed Implemented This benchmarking exercise has revealed 9% Done inconsistencies in the way in which setting Submitted for examination/ examination closed of CIL viability is being approached across the country. So far, only 31 CILs have Draft consultation 37% been implemented, with a further 34 at In process Preliminary draft consultation examination (Graph 7). A large proportion (27%) of authorities are either at draft or Preparing evidence/ Charging schedule preliminary draft consultation and a further

35% 35% are engaged in the process at an

Engaged Committed but not started earlier stage, so there remains scope for

Not yet committed greater consistency in rate setting. Our intention is to seek such consistency in 19% Not pursuing the rate setting process, as the majority of Not engaged authorities move towards implementation Source: Savills Research (as at 20 January 2014) of CIL charging schedules. 

Please contact us for further information Savills Research & Consultancy

Jim Ward Melys Pritchett Lizzie Cullum UK Development UK Development UK Development 020 7409 8841 020 3107 5454 01223 347 291 [email protected] [email protected] [email protected] Twitter: @melysep

08 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Appendix 3: Developer Profit, Savills

Consortium of house builders May 2015 43 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Consortium of house builders May 2015 44 Home Builders Federation October 2014

Developer Profit

Competitive Return to a Willing Developer

savills.co.uk

Developer Profit

Competitive Return to a Willing Developer

Introduction

1.2 Savills is representing HBF members and other house builders and landowners nationwide on emerging CIL Charging Schedules, to scrutinise the available evidence, notably in respect of infrastructure provision and the testing of viability against both the emerging planning policy requirements and the identified housing land supply. We are therefore well placed to observe trends in the emerging viability work and subsequent CIL examinations.

1.3 The purpose of this Briefing Note is to present the evidence of what represents a competitive return to a willing developer.

October 2014 1

Developer Profit

Competitive Return to a Willing Developer

Developer’s Profit

2.1 The NPPF states that to ensure viability developments should provide competitive returns to a willing land owner and willing developer1. A competitive return to a developer is one that provides a sufficient return for the developer to continue a successful business through the economic cycle, taking account of the risk profile of the business. The most readily available market evidence of a competitive return is the return required by the shareholders of the quoted Plc housebuilders, noting that the Top 10 House Builders accounted for 45% of completions in England 2012/132.

2.2 Shareholders are principally institutional investors - pension funds, insurance companies and private equity funds. They have a wide range of companies and sectors to choose from, including retail, housebuilding, mining, transport, energy and telecommunications, all with different risk and return profiles. If shareholders’ hurdle rates are not achieved then they will invest in other sectors, reducing the development capacity of the housebuilding sector.

2.3 The key measures are Operating Margin and Return on Capital Employed (ROCE). For a development to be viable, both measures need to meet acceptable target levels. ROCE and Internal Rate of Return (IRR) are closely related; IRR is the projected compound annual rate of return on capital employed across the life of the scheme, compared with ROCE which is the return on capital employed in any one year.

2.4 The operating margins (based on Earnings or Profit before Interest and Tax) of the Plc housebuilders are shown in Figure 1. The average margin has recovered from a low of 4.3% in 2009 to 14.6% in 2013. Within this, Berkeley has maintained a margin of between 15% and 20% throughout the cycle, as has Crest Nicholson since 2010. All other housebuilders are rebuilding margins towards that level. As examples:

o in August 2013 Persimmon stated that it had reached its target margin of 15-17% of revenue, 18 months ahead of plan; and

o in July 2014 Taylor Wimpey announced targets for the 2015-17 period of an average 20% operating margin and a return on net operating assets of 20% per annum.

2.5 It is important to distinguish between gross (site level) margin and the net operating margin reported in house builder accounts. This is discussed in the Harman Report, which suggests that “Overheads for house-building typically lie in the range of 5% - 10% of gross development value, with only the very largest developers operating near the lower end of the scale”3.

1 NPPF, Communities and Local Government. Para 173. March 2012 2 Facts & Statistics, House Building Statistics, HBF, August 2014 3 Viability Testing Local Plans, Chaired by Sir John Harman, June 2012

October 2014 2

Developer Profit

Competitive Return to a Willing Developer

Figure 1 - Net Operating Margins 2006 - 2013

Source: Savills

2.6 JP Morgan analysis4 of Plc housebuilder performance for the financial years 2012 and 2013 indicates that the average overheads of housebuilders (the difference between Gross Margin and Earnings Before Interest and Tax) were 6.4% and 6.0% of revenue respectively, averaging 6.2%.

2.7 Therefore a target operating margin of 15% to 20% of revenue equates to a target gross margin of 21% to 26% of gross development value. Barratt stated in its 2012 annual report (and in its July 2014 trading update) that its minimum hurdle rates for land acquisition are 20% gross margin and 25% ROCE.

2.8 Both operating margin and gross margin are quoted before deduction of the cost of paying interest on debt, which has averaged 1.2% of GDV over the 2013 and 2013 financial years. Therefore the hurdle rate of gross margin after deduction of the cost of debt is 20-25% of gross development value.

4 UK Housebuilding, Europe Equity Research. J.P. Morgan. September 2013

October 2014 3

Developer Profit

Competitive Return to a Willing Developer

2.9 This is the basis of the developer margin hurdle rate that is applicable to site level development appraisals of Residual Land Value, in which the cost of debt is included separately as a cost. More specifically, this is the average hurdle rate across all sites developed by the housebuilder during any one year. Around this average, there will be a range of site specific development risk and therefore a range of site level hurdle rates for developer margin. Smaller lower density sites are inherently less capital intensive and less risky than costlier larger sites and higher density sites, so for smaller lower density sites the hurdle rate will be below the corporate average and for larger complex sites and higher density sites it will be above the corporate level average.

2.10 This is particularly relevant for large Greenfield sites and regeneration areas, where large up- front costs have an impact on a developer’s required Return on Capital Employed (ROCE), as a higher margin is required to reflect the higher risk. In these instances, the profit margin and ROCE become much more important as highlighted by the Harman Report – “Developments of large flatted blocks on previously used land in urban areas with high cash requirements will demand significantly higher levels of profit to achieve an acceptable ROCE than developments of a more standard, less cash intensive nature on virgin ground. Likewise, projects with significant up-front infrastructure may also require higher levels of profit to generate an acceptable ROCE.”5

Figure 2 - Developer’s Profit Breakdown

Source: Savills

2.11 A minimum developer margin of 20% of Gross Development Value was supported by the appeal decisions relating to The Manor, Shinfield6 and Lydney7. It has also been included in Maldon District Council’s supporting viability work produced by HDH Planning & Development who are currently preparing supporting viability evidence for 24 Local Authorities8.

5 Viability Testing Local Plans, p46, Chaired by Sir John Harman, June 2012 6 Ref: APP/X0360/A/12/2179141, 8 January 2013 7 Ref: APP/P165/Q/14/2215840, 3 September 2014 8 Local Plan & CIL Viability Study – Post Consultation Update (November 2013)

October 2014 4

Developer Profit

Competitive Return to a Willing Developer

2.12 The evidence in this paper indicates that the minimum profit level used within viability testing should be a blended rate of 20% on Gross Development Value plus 25% ROCE across all tenures, subject to consideration of the risk profile of the scheme. The reference to ROCE is particularly important on large capital intensive schemes. In these cases the relevant hurdle rate for site specific appraisal is an Internal Rate of Return of at least 25%.

2.13 A number of viability consultants argue that a different profit level should be applied to private and affordable housing. If this is the case, then the blended margin across all tenure should equate to the hurdle rate referred to above. As an indication, a developer’s blended profit margin on site of 20% of Gross Development Value could be a combination of Affordable Housing at an 8% margin on cost and Market Housing at a 23% margin on Gross Development Value.

2.14 It is increasingly common for developers to purchase land prior to securing an offer from Registered Providers who are subject to more market risk from the current affordable housing regime than in previous systems of funding. There is subsequently a risk associated with the affordable housing, in addition to increased holding and finance costs.

October 2014 5

Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Appendix 4: LPAs adopting or proposing £Nil CIL Rates

Consortium of house builders May 2015 45 Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Consortium of house builders May 2015 46 Emerging CIL Rates - List of LPAs with £0 psm CIL Rates

Table 1 - Site Specific CIL Rates Table 2 - Area CIL Rates No. Local Authority CIL Stage Sites No. Local Authority CIL Stage Comments 1 Hertsmere 1 Elstree Way Corridor 1 Caerphilly 1 Low viability areas 2 Surrey Heath 1 Princess Royal Barracks 2 Chorley 1 Applies to apartments 3 Waveney 1 Lake Lothing flood zone, Sustainable Urban Neighbourhood & Kirkley Waterfront 3 Croydon 1 Metropolitan Centre Strategic Allocations (North Winchester, Whitley and West of Waterlooville) and 4 Winchester 1 4 Merthyr Tydfil 1 Mid & Lower Valleys South Hampshire Urban Areas 5 Poole 1 Poole Power Station site 5 Newark and Sherwood 1 Mansfield fringe and ollerton 6 Hackney 1 Woodberry Down Regeneration Area 6 Plymouth 1 Linked to "Zone of opportunity for Tall Buildings", residential institutions. 7 Kensington & Chelsea 1 Earl's Court Regen to also include Kensal strategic site. 7 Preston 1 Applies to apartments 8 Swindon 1 Swindon's new communities 8 Rhondda Cynon Taff 1 Low value area Nil rate for all dev i Tower Hamlets within the boundaries ofBishopsgate Goods Yard, 9 Tower Hamlets 1 9 South Ribble 1 Applies to apartments Wood Wharf, Westferry Printsworks and London Dock 10 Watford 1 Major Developed Areas 10 Taunton Deane 1 Taunton Town Centre and within Wellington 11 Peterborough 1 Strategic Sites (More than 500 units) 11 Trafford 1 Apartments only in cold and moderate zones 12 Chesterfield 2 Staveley Corridor (Birmington North, Barrow Hill & New Whittington) 12 Wandsworth 1 Roehampton Charging Area 13 County Durham 2 Housing market renewal areas (HMR) 13 West Lancashire 1 Zone B (Skelmersdale & Up Holland) and Zone A apartments 14 Gosport 2 Rowner redevelopment area 14 Bracknell Forest 1 Central Bracknall 15 Solihull 2 North Solihull Regeneration Area 15 Eastbourne 1 Brownfield Low Value Land Zone 1 - schemes of 15 or more units to which Policy HO3 Affordable Housing 16 South Lakeland 2 Kendal & Ulverston Canal Head regeneration areas 16 Spelthorne 1 applies 17 Suffolk Coastal 2 Adastral Park 17 Three Rivers 1 Area C Low Value areas 4, 5, 6 & 7, SUEs and Birmingham Municipal Housing Trust 18 Eastleigh 2 Central Eastleigh Urban Area and 'Strategic Extensions' 18 Birmingham 2 developments. 19 LB Hammersmith & Fulham 2 White City East, Earls Court & West Kensington Opportunity Area 19 Cannock Chase 2 Specialist Retirement Housing 20 Maldon 2 North of Heybridge & North of Holloway Road 20 Dudley 2 Zone 1 (low value) 21 South Cambridgeshire 2 Strategic sites in Local Plan 21 Gedling 2 Zone 1 Strategic sites over 600 units, includes Cribbs Patchway and East of Harry Stoke New 22 South Gloucestershire 2 22 Sheffield 2 North East neighbourhoods 23 Babergh 2 Chilton Woods, Sudbury & strategic broad locations for growth 23 West Dorset 2 Essential rural workers' dwellings 24 East Hampshire 2 Whitehill and Bordon eco town 24 Worthing 2 Excluding Low value residential areas 25 Mid Suffolk 2 Chilton Leys, Ashes Farm and Farriers Road – Stowmarket 25 Bolton 3 Affordable Housing Strategic sites - Whitenap, Hoe Lane, Park Farm, George Yard/Black Sawn Yard, Picket 26 Test Valley 2 26 Wakefield 3 Low value areas Piece and Picket Twenty extension land 27 Basingstoke and Deane 3 Manydown (zone 1) 27 Lichfield 3 Apartments excluded from CIL 1-5 units for all areas. Sheltered and extra care housing in lower value areas and 28 Bournemouth 3 Development outside the Town Centre AAP Area 28 West Oxfordshire 3 extra care housing in medium value areas. 29 Hart 3 Blackwater 29 Cornwall 4 Zone H3 (multiple areas) 30 Leicester 3 Strategic regeneration area 30 Dover 4 Aylesham 31 Mid Devon 3 Strategic sites 31 Newcastle under Lyme 4 Zone 1 (very low) 32 Shepway 3 Strategic Development Sites and Key Development Sites (Zone A) 32 Newcastle Upon Tyne 4 Outside Zones A & B (low value) 33 Torbay 3 Brownfield sites 15+ units and greenfield sites 11+ units (6+ units in AONB) 33 North Somerset 4 Weston Town Centre and gateway 34 Vale of White Horse 3 Crab Hill and Monks Farm 34 Stoke on Trent 4 Zone 1 (very low). 35 South Oxfordshire 3 Didcot: North East and Ladygrove East site, Wallingford site B 35 Wychavon 4 Droitwich, Evesham & Pershore 36 Stroud 4 Stroud Valley area and strategic sites 36 Malvern Hills 4 Malvern, Upton upon Severn & Tenbury Wells 37 Herefordshire 4 Leominster SUE 37 Stockton-on-Tees 4 Low value areas 38 Monmouthshire 4 Sudbrook Paper Mill strategic site. 38 Oldham 4 Low value areas

KEY 1 - Implemented 2 - At Examination 3 - Draft Charging Schedule 4 - Preliminary Draft Charging Schedule

Correct as of 6th May 2015

Reigate and Banstead Council CIL DCS C onsultation response on behalf of a consortium of house builders

Appendix 5: Savills, ARGUS Development Appraisals

Consortium of house builders May 2015 47

Savills (UK) Ltd

Development Appraisal

North West Horley - 1,510 unit strategic site.

Base Appraisal

Report Date: 26 May 2015 APPRAISAL SUMMARY SAVILLS (UK) LTD North West Horley - 1,510 unit strategic site. Base Appraisal

Summary Appraisal for Merged Phases 1 2

Currency in £

REVENUE Sales Valuation Units m² Rate m² Unit Price Gross Sales Private Sales - 1,055 units 1 130,515.00 3,400.00 443,751,000 443,751,000 Ground rent 1 0.00 0.00 1,218,462 1,218,462 Commercial 1 2,280.00 1,643.98 3,748,273 3,748,273 Affordable Rent - 181 units 1 14,770.00 1,530.00 22,598,100 22,598,100 Affordable Inter - 274 units 1 22,250.00 2,210.00 49,172,500 49,172,500 Totals 5 169,815.00 520,488,335

NET REALISATION 520,488,335

OUTLAY

ACQUISITION COSTS Residualised Price 53,650,003 Residualised Price (Negative land) (4,664,589) Stamp Duty 4.00% 2,146,000 Agent Fee 1.00% 536,500 Legal Fee 0.75% 402,375 Town Planning 249,660 52,319,949 CONSTRUCTION COSTS Construction m² Rate m² Cost Private Sales - 1,055 units 130,515.00 m² 1,080.00 pm² 140,956,200 Commercial 2,280.00 m² 1,079.94 pm² 2,462,268 Affordable Rent - 181 units 14,779.00 m² 1,080.00 pm² 15,961,320 Affordable Inter - 274 units 22,265.00 m² 1,080.00 pm² 24,046,200 Totals 169,839.00 m² 183,425,988 183,425,988

Contingency 7.50% 13,756,949 Opening up costs 15,100,000 Landscaping 22,928,248 S106 21,600,000 CIL 130,515.00 m² 256.00 pm² 33,411,840 106,797,037 Other Construction Sustainability cost inflation 5,638,248 Sustainability cost inflation 1,600,300 7,238,548

PROFESSIONAL FEES Professional 12.50% 22,928,248 22,928,248 MARKETING & LETTING Marketing 527,500 Intermediate Housing Sales/Markeing 477,444 1,004,944 DISPOSAL FEES Sales Agent Fee 1.25% 5,546,887 Sales Legal Fee 1,510,000 7,056,887

Additional Costs Arrangement Fee 500,000 Abnormals - Oil Pipeline 1,400,000 Commercial Outgoings 3,586,246 Cost of sale to RP 477,444 RP Purchase Costs 4,304,953 10,268,643 FINANCE

File: Appraisal\North West Horley.wcfx ARGUS Developer Version: 6.00.008 Date: 26/05/2015 APPRAISAL SUMMARY SAVILLS (UK) LTD North West Horley - 1,510 unit strategic site. Base Appraisal Debit Rate 6.500% Credit Rate 0.000% (Nominal) Total Finance Cost 32,890,429

TOTAL COSTS 423,930,674

PROFIT 96,557,661

Performance Measures Profit on Cost% 22.78% Profit on GDV% 18.55% Profit on NDV% 18.55%

IRR 13.52%

Profit Erosion (finance rate 6.500%) 3 yrs 2 mths

File: Appraisal\North West Horley.wcfx ARGUS Developer Version: 6.00.008 Date: 26/05/2015 Savills (UK) Ltd

Development Appraisal

North West Horley - 1,510 unit strategic site.

Savills Assumptions

Report Date: 26 May 2015 APPRAISAL SUMMARY SAVILLS (UK) LTD North West Horley - 1,510 unit strategic site. Savills Assumptions

Summary Appraisal for Merged Phases 1 2

Currency in £

NET REALISATION 520,488,335

OUTLAY

ACQUISITION COSTS Residualised Price 65,581,199 Residualised Price (Negative land) (19,343,685) Stamp Duty 4.00% 2,623,248 Agent Fee 1.00% 655,812 Legal Fee 0.75% 491,859 Town Planning 249,660 50,258,093 CONSTRUCTION COSTS Construction m² Rate m² Cost Private Sales - 1,055 units 130,515.00 m² 1,170.00 pm² 152,702,550 Commercial 2,280.00 m² 1,170.00 pm² 2,667,600 Affordable Rent - 181 units 14,779.00 m² 1,170.00 pm² 17,291,430 Affordable Inter - 274 units 22,265.00 m² 1,170.00 pm² 26,050,050 Totals 169,839.00 m² 198,711,630 198,711,630

Contingency 7.50% 14,903,372 Opening up costs 15,100,000 Landscaping 22,928,248 S106 21,600,000 74,531,620 Other Construction Sustainability cost inflation 6,108,102 Sustainability cost inflation 1,840,363 7,948,465

PROFESSIONAL FEES Professional 12.50% 24,838,954 24,838,954 MARKETING & LETTING Marketing 1.00% 4,437,510 Intermediate Housing Sales/Markeing 477,444 4,914,954 DISPOSAL FEES Sales Agent Fee 1.25% 5,546,887 Sales Legal Fee 0.35% 1,553,128 Sales Legal Fee 455,000 7,555,016

Additional Costs Arrangement Fee 500,000 Abnormals - Oil Pipeline 1,400,000 Commercial Outgoings 3,586,246 Cost of sale to RP 477,444 RP Purchase Costs 4,304,953 10,268,643 FINANCE

File: Appraisal\North West Horley - Savills assumptions.wcfx ARGUS Developer Version: 6.00.008 Date: 26/05/2015 Savills (UK) Ltd

Development Appraisal

600 Unit Typology

Base Appraisal

Report Date: 26 May 2015 APPRAISAL SUMMARY SAVILLS (UK) LTD 600 Unit Typology Base Appraisal

Summary Appraisal for Phase 1

Currency in £

REVENUE Sales Valuation Units m² Rate m² Unit Price Gross Sales Private - 420 units 1 51,690.00 3,400.00 175,746,000 175,746,000 Affordable rent - 36 units 1 2,955.00 1,530.00 4,521,150 4,521,150 Affordable inter - 54 units 1 4,395.00 2,210.00 9,712,950 9,712,950 Ground rent 1 0.00 0.00 480,000 480,000 Totals 4 59,040.00 190,460,100

NET REALISATION 190,460,100

OUTLAY

ACQUISITION COSTS Residualised Price (25.00 Ha 1,384,422.40 pHect) 34,610,560 Stamp Duty 4.00% 1,384,422 Agent Fee 1.00% 346,106 Legal Fee 0.75% 259,579 Town Planning 932,600 37,533,267 CONSTRUCTION COSTS Construction m² Rate m² Cost Private - 420 units 51,690.00 m² 1,080.00 pm² 55,825,200 Affordable rent - 36 units 2,970.00 m² 1,080.00 pm² 3,207,600 Affordable inter - 54 units 4,410.00 m² 1,080.00 pm² 4,762,800 Totals 59,070.00 m² 63,795,600 63,795,600

Contingency 7.50% 4,784,670 S106 6,000,000 10,784,670 Other Construction Landscaping / Externals 12.50% 7,974,450 Opening-up Costs 6,000,000 Various items 6,000,000 Abnormals 625,000 Developers Costs of sale to RP 190,824 RP Purchase Costs 1,720,596 Sustainability cost inflation - 4% 2,551,824 25,062,694

PROFESSIONAL FEES Professional Fees 12.50% 7,974,450 7,974,450 MARKETING & LETTING Marketing 300,000 300,000 DISPOSAL FEES Sales Agent Fee 1.25% 2,196,825 Sales Legal Fee 600,000 2,796,825

Additional Costs Arrangement Fee 440,000 Intermediate sales & marketing 190,824 Commercial outgoings 1,346,918 1,977,742 FINANCE Debit Rate 6.500% Credit Rate 0.000% (Nominal) Land 10,799,669 Construction 1,068,783 Total Finance Cost 11,868,453

File: Appraisal\600 Unit Base Appraisal.wcfx ARGUS Developer Version: 6.00.008 Date: 26/05/2015 APPRAISAL SUMMARY SAVILLS (UK) LTD 600 Unit Typology Base Appraisal

TOTAL COSTS 162,093,701

PROFIT 28,366,399

Performance Measures Profit on Cost% 17.50% Profit on GDV% 14.89% Profit on NDV% 14.89%

IRR 14.94%

Profit Erosion (finance rate 6.500%) 2 yrs 6 mths

File: Appraisal\600 Unit Base Appraisal.wcfx ARGUS Developer Version: 6.00.008 Date: 26/05/2015 APPRAISAL SUMMARY SAVILLS (UK) LTD North West Horley - 1,510 unit strategic site. Savills Assumptions Debit Rate 6.500% Credit Rate 0.000% (Nominal) Total Finance Cost 14,283,845

TOTAL COSTS 393,311,221

PROFIT 127,177,114

Performance Measures Profit on Cost% 32.34% Profit on GDV% 24.43% Profit on NDV% 24.43%

IRR 19.62%

Profit Erosion (finance rate 6.500%) 4 yrs 4 mths

File: Appraisal\North West Horley - Savills assumptions.wcfx ARGUS Developer Version: 6.00.008 Date: 26/05/2015 Savills (UK) Ltd

Development Appraisal

600 Unit Base Appraisal

Savills Assumptions

Report Date: 26 May 2015 APPRAISAL SUMMARY SAVILLS (UK) LTD 600 Unit Base Appraisal Savills Assumptions

Summary Appraisal for Phase 1

Currency in £

NET REALISATION 190,460,100

OUTLAY

ACQUISITION COSTS Residualised Price (25.00 Ha 952,491.85 pHect) 23,812,296 Stamp Duty 4.00% 952,492 Agent Fee 1.00% 238,123 Legal Fee 0.75% 178,592 Town Planning 932,600 26,114,103 CONSTRUCTION COSTS Construction m² Rate m² Cost Private - 420 units 51,690.00 m² 1,170.00 pm² 60,477,300 Affordable rent - 36 units 2,970.00 m² 1,170.00 pm² 3,474,900 Affordable inter - 54 units 4,410.00 m² 1,170.00 pm² 5,159,700 Totals 59,070.00 m² 69,111,900 69,111,900

Contingency 7.50% 5,183,392 S106 - £15k per unit 9,000,000 14,183,392 Other Construction Landscaping / Externals 12.50% 8,638,987 Opening-up Costs 6,000,000 Various items 6,000,000 Abnormals 625,000 Developers Costs of sale to RP 190,824 RP Purchase Costs 1,720,596 Sustainability Cost Inflation - 4% 2,764,476 25,939,883

PROFESSIONAL FEES Professional Fees 12.50% 8,638,987 8,638,987 MARKETING & LETTING Marketing 1.00% 1,757,460 1,757,460 DISPOSAL FEES Sales Agent Fee 1.25% 2,196,825 Sales Legal Fee 0.35% 664,930 2,861,755

Additional Costs Arrangement Fee 440,000

File: E:\GUDV\CONSULTANCY\Consultancy 2015\Reigate and Banstead - CIL\Appraisal\600 Unit Base Appraisal - Savills Assumptions.wcfx ARGUS Developer Version: 6.00.008 Date: 26/05/2015 APPRAISAL SUMMARY SAVILLS (UK) LTD 600 Unit Base Appraisal Savills Assumptions Intermediate sales & marketing 190,824 Commercial outgoings 1,346,918 1,977,742 FINANCE Debit Rate 6.500% Credit Rate 0.000% (Nominal) Land 6,924,659 Construction 1,206,852 Total Finance Cost 8,131,511

TOTAL COSTS 158,716,735

PROFIT 31,743,365

Performance Measures Profit on Cost% 20.00% Profit on GDV% 16.67% Profit on NDV% 16.67%

IRR 18.91%

Profit Erosion (finance rate 6.500%) 2 yrs 10 mths

File: E:\GUDV\CONSULTANCY\Consultancy 2015\Reigate and Banstead - CIL\Appraisal\600 Unit Base Appraisal - Savills Assumptions.wcfx ARGUS Developer Version: 6.00.008 Date: 26/05/2015

Reigate & Banstead Borough Council

Community Infrastructure Levy (CIL): Draft Charging Schedule

April 2015

Representations Form

How to submit your comments

This response form has two parts:  Part A: Personal Details  Part B: Your Views  Part C: Participation and Notification

We would strongly encourage you to respond to the consultation by completing the questions set out in this form. Please complete Parts A, B and C to assist us in considering your views. You are encouraged to provide as much explanation as possible, and where relevant, attach any available evidence to support your position.

Forms must be returned to Reigate & Banstead Borough Council by 5pm on 26 May 2015

You can return your form:

By post to: Planning Policy Team, Reigate & Banstead Borough Council Town Hall, Castlefield Road, Reigate, Surrey, RH2 0SH.

By e-mail to: [email protected]

Part A: Personal Details If an agent is appointed please complete only the Title, Name and Organisation boxes in (1) but complete the full contact details of the agent in (2).

(1) Personal Details (2) Agents Details (if relevant) Title Mrs

First name Vicky

Last name Aston

Job title (if relevant) Planning Manager

Organisation (if relevant) Sport England

Address National Sports Centre, near Marlow, Buckinghamshire

Postcode SL7 1RR

Telephone No 020 7273 1912

Email address [email protected]

Page 1 Part B: Your Views

Draft Charging Schedule and Proposed Charges

(1) Do you have any comments to make on the proposed rates of CIL and the supporting viability evidence (set out in the CIL Revised Viability Assessment Report and Appendices)? Yes No NO

If you have answered ‘yes’, please provide further explanation, Please set out any evidence available to support your views

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

(2) Do you have any comments to make on the charging zone maps set out in the Draft Charging Schedule?

Yes No NO

If you have answered ‘yes’, please provide further explanation

(continue on a separate sheet/expand box if necessary) Page 1 Draft List of Relevant Infrastructure

(3) Do you have any comments to make on the draft list of relevant infrastructure?

Yes YES No

If you have answered ‘yes’, please provide further explanation

Sport England supports the Council’s intention, through the Draft Infrastructure List, to continue to secure Section 106 contributions towards indoor and outdoor sports facilities to mitigate the impact of new development.

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

Evidence Base

(4) Do you have any other comments to make on the evidence base and supporting documentation for the Draft Charging Schedule?

Yes No NO

If you have answered ‘yes’, please provide further explanation Please make clear which document (i.e. Infrastructure Delivery Plan) and if possible any specific passages or tables your views refer to, particularly if you are making comments on multiple documents. Please set out any evidence available to justify your views.

Page 2 (continue on a separate sheet/expand box if necessary) Part C: Participation and Notification

Requesting the right to be heard at examination

(5) Organisations and individuals making representations may request the right to be heard by the examiner. Do you consider it necessary to participate at the oral part of the examination?

No, I do not wish to participate at X Yes, I wish to participate at the oral the oral examination examination

If you wish to participate at the oral examination, please outline why you consider this to be necessary

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

Please note: The examiner will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of any examination.

Requests to be notified

(6) Representations may also be accompanied by a request to be notified, at a specified address, of any of the following. Please indicate of which, if any, you wish to be notified.

(a) That the Draft Charging Schedule has been submitted to the Yes No X examiner in accordance with section 212 of the Planning Act 2008

(b) The publication of the recommendations of the examiner and the Yes No X reasons for those recommendations

Signature: Date: 28/05/2015

Page 3

Reigate & Banstead Borough Council

Community Infrastructure Levy (CIL): Draft Charging Schedule

April 2015

Representations Form

How to submit your comments

This response form has two parts:  Part A: Personal Details  Part B: Your Views  Part C: Participation and Notification

We would strongly encourage you to respond to the consultation by completing the questions set out in this form. Please complete Parts A, B and C to assist us in considering your views. You are encouraged to provide as much explanation as possible, and where relevant, attach any available evidence to support your position.

Forms must be returned to Reigate & Banstead Borough Council by 5pm on 26 May 2015

You can return your form:

By post to: Planning Policy Team, Reigate & Banstead Borough Council Town Hall, Castlefield Road, Reigate, Surrey, RH2 0SH.

By e-mail to: [email protected]

All duly made responses and representations will be considered by the Council and will be passed to the independent examiner as part of the examination procedure. We are happy to provide information in other languages, large print, braille or on audio tape. Please contact our Help Line on 01737 276000 if you would like this service.

Part A: Personal Details If an agent is appointed please complete only the Title, Name and Organisation boxes in (1) but complete the full contact details of the agent in (2).

(1) Personal Details (2) Agents Details (if relevant) Title Mrs

First name Minnie

Last name Ngaluafe

Job title Community Infrastructure Officer (if relevant) Organisation Tandridge District council (if relevant) Address The Council Offices Station Road East Oxted, Surrey

Postcode RH8 0BT

Telephone No 01883 732880

Email address [email protected]

Page 1 Part B: Your Views

Draft Charging Schedule and Proposed Charges

(1) Do you have any comments to make on the proposed rates of CIL and the supporting viability evidence (set out in the CIL Revised Viability Assessment Report and Appendices)? Yes No No

If you have answered ‘yes’, please provide further explanation, Please set out any evidence available to support your views

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

(2) Do you have any comments to make on the charging zone maps set out in the Draft Charging Schedule?

Yes No No

If you have answered ‘yes’, please provide further explanation

(continue on a separate sheet/expand box if necessary) Page 1 Draft List of Relevant Infrastructure

(3) Do you have any comments to make on the draft list of relevant infrastructure?

Yes No No

If you have answered ‘yes’, please provide further explanation

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

Evidence Base

(4) Do you have any other comments to make on the evidence base and supporting documentation for the Draft Charging Schedule?

Yes No No

If you have answered ‘yes’, please provide further explanation Please make clear which document (i.e. Infrastructure Delivery Plan) and if possible any specific passages or tables your views refer to, particularly if you are making comments on multiple documents. Please set out any evidence available to justify your views.

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

Page 2 Part C: Participation and Notification

Requesting the right to be heard at examination

(5) Organisations and individuals making representations may request the right to be heard by the examiner. Do you consider it necessary to participate at the oral part of the examination?

No, I do not wish to participate at No Yes, I wish to participate at the oral the oral examination examination

If you wish to participate at the oral examination, please outline why you consider this to be necessary

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

Please note: The examiner will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of any examination.

Requests to be notified

(6) Representations may also be accompanied by a request to be notified, at a specified address, of any of the following. Please indicate of which, if any, you wish to be notified.

(a) That the Draft Charging Schedule has been submitted to the Yes Yes No examiner in accordance with section 212 of the Planning Act 2008

(b) The publication of the recommendations of the examiner and the Yes Yes No reasons for those recommendations

Signature: Date: 20/05/2015 M Ngaluafe

Page 3