Plymouth and South West Joint Local Plan Viability Study Final Report

On behalf of City Council

Project Ref: 33852/005 | Rev: AA | Date: February 2017

Office Address: 10 Queen Square, Bristol, BS1 4NT T: +44 (0)117 928 1560 E: [email protected] Plymouth & SW Devon JLP Viability Update Final Report

Document Control Sheet

Project Name: Plymouth Viability Partnering Project Ref: 33852 Report Title: Plymouth and South West Devon Joint Local Plan Viability Study Doc Ref: Draft Final Update Report Date: February 2017

Name Position Signature Date

Senior Associate Russell Porter / RP Prepared by: Economist / 08.02.17 Tom Marshall Consultant Planner TM Senior Associate Reviewed by: Russell Porter RP 08.02.17 Economist

Approved by: John Baker Partner JB 08.12.17

For and on behalf of Peter Brett Associates LLP

Peter Brett Associates LLP disclaims any responsibility to the Client and others in respect of any matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence within the terms of the Contract with the Client and generally in accordance with the appropriate ACE Agreement and taking account of the manpower, resources, investigations and testing devoted to it by agreement with the Client. This report is confidential to the Client and Peter Brett Associates LLP accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk.

© Peter Brett Associates LLP 2016

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Contents

1 Introduction ...... 1 1.1 The Study Scope ...... 1 1.2 Approach ...... 3 1.3 Consultation ...... 4 1.4 Report Structure ...... 5 2 National Policy Context ...... 6 2.1 National Framework ...... 6 2.2 Policy and Other Requirements ...... 14 2.3 Summary ...... 14 3 Local Policy Impacts on Viability ...... 17 3.1 Introduction ...... 17 3.2 Joint Local Plan Policies ...... 17 4 Local Residential Context ...... 25 4.1 Introduction ...... 25 4.2 Past Development Patterns ...... 25 4.3 Residential Market Sales Values ...... 28 5 Residential Viability Assumptions ...... 35 5.1 Introduction ...... 35 5.2 Residential Site Typologies ...... 35 5.3 Residential Values and Costs Assumptions ...... 39 5.4 Proposed Policy Costs ...... 42 5.5 Benchmark Land Value Assumptions ...... 45 6 Residential Sites Viability ...... 47 6.1 Introduction ...... 47 6.2 Is the Plan viable? ...... 47 6.3 Scope for CIL in Plymouth ...... 50 7 Scope for CIL from Older Persons Housing ...... 54 7.1 Introduction ...... 54 7.2 Defining Housing for Older People ...... 54 7.3 Assumptions for Further Testing ...... 54 7.4 Viability Results and Recommendations ...... 57 8 Scope for CIL from Non Residential uses ...... 58 8.1 Introduction ...... 58 8.2 Typologies Tested ...... 58 8.3 Non-Residential Values Assumptions ...... 59 8.4 Non-Residential Cost Assumptions ...... 61 8.5 Benchmark Land Values for Non-residential Uses ...... 63 8.6 Viability Results by Non-residential Use...... 64

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8.7 Recommendations for CIL ...... 65 9 Conclusions ...... 68 9.1 Testing of Local Plan Viability ...... 68 9.2 Recommendation for CIL Charging ...... 68

Figures

Figure 1.1 Approach to residual land value assessment for whole plan viability ...... 4 Figure 4.1 Residential completions 2006-2014 ...... 26 Figure 4.2 Types of developments ...... 26 Figure 4.3 Proportion of sites developed on brownfield land ...... 27 Figure 4.4 Residential development densities ...... 28 Figure 4.5 Trend in residential sales values in Plymouth ...... 29 Figure 4.6 Trend in residential sales values in ...... 29 Figure 4.7 Trend in residential sales values in West Devon ...... 29 Figure 4.8 Average sales values of new properties since Jan 2015...... 30 Figure 4.9 Projected increase in average second-hand values ...... 31 Figure 4.10 Spread of average prices for detached (left) and semidetached (right) houses ...... 32 Figure 4.11 Spread of average prices for terraced (left) and flats (right) houses ...... 32 Figure 4.12 Broad value areas in the Plymouth and Thriving Towns and Villages Policy Areas ...... 33 Figure 8.1 Non-residential headroom for each use in Plymouth ...... 66

Tables

Table 3.1 Viability Policy Matrix in the emerging JLP (as at February 2017) ...... 17 Table 4.1 Average per square metre values for residential units ...... 34 Table 5.1 Residential typologies tested for Plymouth (inc. value areas East and West) ...... 36 Table 5.2 Residential typologies tested for South West Devon value area ...... 37 Table 5.3 Tested mix of units ...... 37 Table 5.4 Tested average saleable floorspace by unit type ...... 38 Table 5.5 Tested average Open Market residential sales value, per sqm ...... 39 Table 5.6 Tested median build costs at Q3 2015 tender prices ...... 40 Table 5.7 Tested opening up costs on Greenfield sites ...... 41 Table 5.8 Tested site abnormal costs on Brownfield sites ...... 41 Table 5.9 Tested land purchase costs ...... 41 Table 5.10 Cost for meeting Building Regulation Access Standards ...... 43 Table 5.11 Assumed transfer values by Affordable Housing tenure ...... 44 Table 5.12 Benchmark land values for sites without planning ...... 46 Table 6.1 Residential viability headroom – Plymouth Policy Area ...... 48 Table 6.2 Residential viability headroom – Thriving Towns and Villages Area (South Hams) ...... 49 Table 6.3 Residential viability headroom – Thriving Towns and Villages Area (West Devon) ...... 49 Table 6.4 Residential development viability headroom – Plymouth Policy Area ...... 51 Table 6.5 Sensitivity at a range of affordable housing rates – Plymouth Policy Area ...... 51 Table 6.6 Sensitivity testing of the inclusion of Starter Homes – Plymouth Policy Area ...... 53 Table 7.1 Sales values for new retirement properties currently on the market (as of Dec 2016) ...... 55 Table 7.2 Sales values per square metre for each value area for Extra-care and Retirement homes . 56 Table 7.3 Maximum headroom for older person housing ...... 57 Table 8.1 Non-residential use typologies for testing ...... 58 Table 8.2 Tested non-residential rents and yields ...... 61 Table 8.3 Tested non-residential build costs at Q3 2015 ...... 62 Table 8.4 Other assumptions used ...... 63

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Table 8.5 Non-residential uses – land values ...... 63 Table 8.6 Non-residential viability headroom – B-class uses ...... 64 Table 8.7 Non-residential viability headroom – Retail uses ...... 65 Table 8.8 Non-residential viability headroom – Hotel ...... 65 Table 8.9 Non-residential viability headroom – Student Accommodation ...... 65 Table 8.10 Non-residential viability headroom – Care homes ...... 65 Table 8.11 Summary of Non-residential CIL recommendations in the Plymouth Policy Area ...... 67 Table 9.1 Recommended maximum CIL charges in the Plymouth Policy Area ...... 68

Appendices

Appendix A Example Appraisals Appendix B Developer Workshop Meeting Notes Appendix C New Build Properties sold since Jan 2015 Appendix D Research on Non-Residential Units

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1 Introduction

1.1 The Study Scope

1.1.1 Peter Brett Associates (PBA) have been commissioned by Plymouth City Council to provide high-level viability update advice relating to plan making in the Plymouth and South West Devon Joint Local Plan area. This has included undertaking high level viability assessments to provide the following outputs:

 A plan viability assessment of the Joint Local Plan (JLP) emerging policies; and

 Viability assessment of theoretical developments taking into account the JLP requirements and other costs, to inform potential revision of the adopted Community Infrastructure Levy (CIL) rates in Plymouth.

1.1.2 This report is an update of previous viability advice issued by PBA for Plymouth City Council in March 2016 (report titled ‘Plymouth Local Plan and CIL Viability Study’) to incorporate the South Hams and West Devon authorities as part of the newly emerging Joint Plan. As such, this update report should be read in conjunction with the previous report (hereon referred to as the PBA March 2016 report). Where any information or assumptions in the PBA March 2016 report has been updated in this report, the information/assumptions in the PBA March 2016 should no longer be relied on.

1.1.3 The main purpose of a plan viability (or PV) assessment is to provide evidence that the policy requirements in the Plan should not threaten the development viability of the Plan as a whole, in accordance with the National Planning Policy Framework (NPPF) paragraph 173. In assessing the Plan, this study will inform policy decisions based on the policy aspirations of achieving sustainable development and the realities of economic viability.

1.1.4 The report and the accompanying appraisals have been prepared in line with the Local Housing Delivery Group and chaired by Sir John Harman 'Viability Testing Local Plans' advice for planning practitioners, June 2012 (the Harman Report). The viability assessments have also been prepared in line with and the Royal Institute of Chartered Surveyors (RICS) valuation guidance. However, it is first and foremost a supporting document to inform the Local Plan evidence base and planning policy, in particular policy concerned with the planning, funding and delivery of infrastructure needed to support delivery of the plan.

1.1.5 It should therefore be noted that as per Professional Standards 1 of the RICS Valuation Standards – Global and UK Edition1, the advice expressly given in the preparation for, or during the course of negotiations or possible litigation does not form part of a formal “Red Book” valuation and should not be relied upon as such. No responsibility whatsoever is accepted to any third party who may seek to rely on the content of the report for such purposes.

1 RICS (January 2015) Valuation – Professional Standards, PS1 Compliance with standards and practice statements where a written valuation is provided

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Plymouth SHLAA Viability Assessment

1.1.6 In December 2015, PBA carried out a viability assessment of residential sites identified in the Plymouth Strategic Housing Land Availability Assessment (SHLAA). This included a viability assessment to provide evidence on the achievability of the 134 sites as potential housing land supply to underpin the emerging Local Plan. The assessment of sites was a high level viability exercise to provide a ‘snapshot in time’, to provide the most robust evidence available.

1.1.7 The SHLAA sites have been updated following consultations in July / August and November 2016 and a high level assessment, complete with cashflow analysis, is being carried out separately. This will cover the SHLAA sites in the three authority areas covered by the Plymouth Policy Area, and Thriving Towns and Villages Area. The results of the SHLAA Viability Assessment will be set out in a separate report (February 2017).

Defining the Joint Local Plan Area

1.1.8 Plymouth City Council, South Hams District Council and West Devon Borough Council are working together to produce a single JLP covering their geographic areas, which are referred to as the three individual districts or the “Plymouth Policy Area, and Thriving Towns and Villages Area”. The Plymouth Policy Area includes parts of South Hams but a CIL charge is currently applied within the Plymouth City Council boundary. This Plan will set out the overarching strategy for the area, setting out where development will take place, what areas should be protected, and how the area will change through to 2034.

1.1.9 The JLP brings together work that has already been carried out separately by the councils on the Plymouth Plan, South Ham’s ‘Our Plan’ and West Devon’s ‘Our Plan’. It will create single objective and policies whilst retaining the Council’s individual identities. The strategy and policies of the Plymouth Plan will therefore be carried forward into the Plymouth and South West Devon JLP and the same for the vision and themes in the South Hams and West Devon Our Plans. It is this geographic area, which is referred to as the “Plymouth Policy Area and Thriving Towns and Villages Area”, and the policies within the Plymouth Plan which this update study will consider in assessing the viability of the JLP.

Defining Local Plan Level Viability

1.1.10 The Harman Report defines local plan viability (on page 14) as follows:

'An individual development can be said to be viable if, after taking account of all costs, including central and local government policy and regulatory costs, and the cost and availability of development finance, the scheme provides a competitive return to the developer to ensure that development takes place, and generates a land value sufficient to persuade the land owner to sell the land for the development proposed.

At a Local Plan level, viability is very closely linked to the concept of deliverability. In the case of housing, a Local Plan can be said to be deliverable if sufficient sites are viable (as defined in the previous paragraph) to deliver the plan's housing requirement over the plan period.’

1.1.11 It should be noted that the approach to Local Plan level viability assessment does not require all sites in the plan to be viable. The Harman Report says that a site typologies approach (i.e. assessing a range of example development sites likely to come forward) to understanding plan viability is sensible. Whole plan viability:

'does not require a detailed viability appraisal of every site anticipated to come forward over the plan period… (p.11)

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[we suggest] rather it is to provide high level assurance that the policies within the plan are set in a way that is compatible with the likely economic viability of development needed to deliver the plan. (p.15)

A more proportionate and practical approach in which local authorities create and test a range of appropriate site typologies reflecting the mix of sites upon which the plan relies'. (p.11).

1.1.12 The Harman Report states that the role of the typologies testing is not required to provide a precise answer as to the viability of every development likely to take place during the plan period.

'No assessment could realistically provide this level of detail…rather, [the role of the typologies testing] is to provide high level assurance that the policies within the plan are set in a way that is compatible with the likely economic viability of development needed to deliver the plan.' (p.18)

1.1.13 Indeed, the report also acknowledges that a:

'plan-wide test will only ever provide evidence of policies being 'broadly viable’. The assumptions that need to be made in order to carry out a test at plan level mean that any specific development site may still present a range of challenges that render it unviable given the policies in the Local Plan, even if those policies have passed the viability test at the plan level. This is one reason why our advice advocates a 'viability cushion' to manage these risks.’ (p.18)

1.1.14 The report later suggests that once the typologies testing has been done:

'it may also help to include some tests of case study sites, based on more detailed examples of actual sites likely to come forward for development if this information is available'. (p.38)

1.1.15 The Harman Report points out the importance of minimising risk to the delivery of the plan. Risks can come from policy requirements that are either too high or too low. So, planning authorities must have regard to the risks of damaging plan delivery with excessive policy costs - but equally, they need to be aware of lowering standards to the point where the sustainable delivery of the plan is not possible. Good planning in this respect is about 'striking a balance' between the competing demands for policy and plan viability.

1.2 Approach

1.2.1 The PBA development viability model was used to test Plan delivery based on viability and to ascertain a potential for revising the CIL charge in Plymouth. This involved ‘high level’ testing of a number of hypothetical schemes that represent the future allocation of development land in the Joint Local Plan area.

1.2.2 The viability methodology applied is appropriate for whole plan and SHLAA analysis purposes but should not be taken as the de facto approach for every individual development proposal which will be subject to its own site opportunities and constraints.

1.2.3 The viability testing and study results are based on establishing a residual land value for different land uses relevant to different parts of the Joint Local Plan area. The approach takes the difference between development values and costs, and compares the 'residual value' (i.e. what is left over after the cost of building the site is deducted from the potential sales value of the completed site/buildings) with a benchmark/threshold land value (i.e. the value over and above the existing use value a landowner would accept to bring the site to market for development) to determine the balance that could be available to support policy costs such as affordable housing and infrastructure. This is a standard approach, which is

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advocated by the Harman Report. The broad method for residual land valuation is illustrated in the Figure 1.1.

Figure 1.1 Approach to residual land value assessment for whole plan viability

Less development costs – including build costs, fees, finance costs etc

Benchmark land value - to Balance - available to contribute Value of completed incentivise delivery and support towards policy requirements development scheme future policy requirements (can be + or -)

Less developer’s return (profit) – minimum profit acceptable in the market to undertake the scheme

1.2.4 The arithmetic of residual land value assessment is straightforward (PBA use a bespoke spreadsheet model for the assessments). However, the inputs to the calculation are hard to determine for a specific site (as demonstrated by the complexity of many S106 negotiations). The difficulties grow when making calculations that represent a typical or average site - which is what is required by CIL regulations for estimating appropriate CIL charges. Therefore, our viability assessments in this report are necessarily broad approximations, subject to a margin of uncertainty.

1.2.5 Examples of the residential and a non-residential site assessment sheets are set out in Appendix A.

1.3 Consultation

1.3.1 The Council arranged a number of viability workshop with the local development industry to enable us to test the assumptions contained within this report. These workshops took place in June 2015 and December 2016. Both workshops were attended by developers, agents and council officers with experience of the local development market.

1.3.2 Following each workshop, the Council circulated a meeting note around the attendees inviting further comment on the assumptions. Some further evidence to inform our assumptions was submitted, particularly relating to value areas, land values and Extra-care schemes, which have been taken account of in this report. However, most of the other assumptions presented at the time remain in absence of evidence being submitted. Copies of the meeting notes are included in Appendix B.

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1.4 Report Structure

1.4.1 The rest of this report is set out as follows:

 Chapter 2 sets out the policy and legal requirements relating to the Joint Local Plan viability, affordable housing and community infrastructure levy which the study assessment must comply with;

 Chapter 3 sets out the current policies informing the Joint Local Plan and their impact on viability;

 Chapter 4 outlines the planning and development context for residential schemes, which is forming the bulk of new floorspace coming forward over the plan period;

 Chapter 5 and 6 respectively describes the residential development scenarios to be tested and the viability assumptions, and then the test results;

 Chapter 7 does the same for older person housing;

 Chapter 8 and 9 does the same for non-residential development scenarios;

 Chapter 10 concludes on the viability of the Joint Local Plan policies and sets out recommendations for setting revised CIL charges in Plymouth

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2 National Policy Context

2.1 National Framework

2.1.1 The National Planning Policy Framework (NPPF) recognises that the ‘developer funding pot’ or residual value is finite and decisions on how this funding is distributed between affordable housing, infrastructure and other policy requirements have to be considered as a whole, they cannot be separated out.

2.1.2 The NPPF advises that cumulative effects of policy should not combine to render plans unviable:

‘Pursuing sustainable development requires careful attention to viability and costs in plan- making and decision-taking. Plans should be deliverable. Therefore, the sites and the scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable’. 2

2.1.3 With regard to non-residential development, the NPPF states that local planning authorities ‘…should have a clear understanding of business needs within the economic markets operating in and across their area. To achieve this, they should… understand their changing needs and identify and address barriers to investment, including a lack of housing, infrastructure or viability.’ 3

2.1.4 The NPPF does not state that all sites must be viable now in order to appear in the plan. Instead, the NPPF is concerned to ensure that the bulk of the development is not rendered unviable by unrealistic policy costs. It is important to recognise that economic viability will be subject to economic and market variations over the local plan timescale. In a free market, where development is largely undertaken by the private sector, the local planning authority can seek to provide suitable sites to meet the needs of sustainable development. It is not within the local planning authority's control to ensure delivery actually takes place; this will depend on the willingness of a developer to invest and a landowner to release the land. So in considering whether a site is deliverable now or developable in the future, we have taken account of the local context to help shape our viability assumptions.

Deliverability and Developability Considerations in the NPPF

2.1.5 The NPPF creates the two concepts of ‘deliverability’ (which applies to residential sites which are expected in years 1-5 of the plan) and ‘developability’ (which applies to year 6 of the plan onwards). The NPPF defines these two terms as follows:

To be deliverable, ‘…sites should be available now, offer a suitable location for development now, and be achievable, with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable.’ 4

2 DCLG (2012) National Planning Policy Framework (41, para 173) 3 Ibid (para 160) 4 Ibid (para 47, footnote 11 – note this study deals with the viability element only, the assessment of availability, suitability, and achievability is dealt with by the client team as part of the site selection process for the SHLAA and other site work.

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To be developable, sites expected from year 6 onwards should be able to demonstrate a ’…reasonable prospect that the site is available and could be viably developed at the point envisaged‘. 5

2.1.6 This study deals with the viability element only, because the assessment of suitability availability is dealt with by the Council as part of its site allocations and infrastructure planning.

2.1.7 The NPPF advises that a more flexible approach may be taken to the sites coming forward from year 6 onwards. These sites might not be viable now and might instead only become viable at a future point in time (e.g. when a lease for the land expires or future use values become attractive). This recognises the impact of economic cycles and variations in values and policy changes over time.

National Policy on Affordable Housing

2.1.8 In informing future policy on affordable housing, it is important to understand national policy on affordable housing. The NPPF states:

‘To deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities, local planning authorities should6:

 Plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes);

 Identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand; and

 Where they have identified that affordable housing is needed, set policies for meeting this need on site, unless off-site provision or a financial contribution of broadly equivalent value can be robustly justified (for example to improve or make more effective use of the existing housing stock) and the agreed approach contributes to the objective of creating mixed and balanced communities. Such policies should be sufficiently flexible to take account of changing market conditions over time’.7

2.1.9 The NPPF accepts that in some instances, off site provision or a financial contribution of a broadly equivalent value may contribute towards creating mixed and balanced communities.

2.1.10 Finally, the NPPF recognises that market conditions change over time, and so when setting long term policy on affordable housing, incorporating a degree of flexibility is sensible to reflect changing market circumstances.

Housing and Planning Act 2016

2.1.11 During the time of this study, the Housing and Planning Bill 2016 became law on 31 October 2016. This set out changes to the delivery of affordable housing in , as set out below:

‘The Secretary of State may by regulations provide that an English planning authority may only grant planning permission for a residential development of a specific description if the starter homes requirement is met.’

5 Ibid (para 47, footnote 12) 6 Ibid (para 50 and bullets) 7 Ibid (p13, para 50)

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‘The “starter homes requirement” means a requirement, specified in the regulations, relating to the provision of starter homes in England.’

Regulations under this section may, for example, provide that an England planning authority may grant planning permission only if a person has entered into a planning obligation to provide a certain number of starter homes or to pay a sum to be used by the authority for providing starter homes.’ 8

2.1.12 This indicated that there would be a requirement for starter homes set by Government which relates to each local authority in England. However, just as this report was being published, the Housing White Paper was published (7 February 2017) which dropped plans to impose a legal duty on councils to ensure provision of at least 20 per cent Starter Homes on all reasonably sized development sites. Instead, the Government has noted that local authorities will deliver Starter Homes as part of a mixed package of affordable housing that can respond to local needs and local markets. That is, the level of that starter home requirement is not known at present but the White Paper proposes to amend the NPPF to introduce a "clear policy expectation" that housing sites deliver a minimum of 10% affordable home ownership units, with local areas along with developers identifying an appropriate level of delivery of Starter Homes, alongside other affordable home ownership and rented tenures,

2.1.13 Consequently, the implications of the Housing and Planning Act remains unclear at the time of reporting, and does not provide any levels or thresholds relating to Starter Homes or density levels. However, the Council will need to be mindful of future changes in national planning policies or regulations which would impact on the viability of development and the overall Local Plan, which could be tested within the viability model as the detail will come within the secondary legislation and regulations. The Council should be aware that there could be potential impacts on viability testing from changes in national policy.

National Space Standards for Housing

2.1.14 Government published ‘Technical Housing Standards – Nationally Described Space Standard’ (NSS) in March 2015. This replaces the existing different space standards used by local authorities. It is not a building regulation and remains solely within the planning system as a new form of technical planning standard.

2.1.15 NSS deals with the internal space of new dwellings and sets out the requirement for Gross Internal Area (GIA). GIA is defined as the total floor space measured between the internal faces of perimeter walls. The standard is organised by number of bedrooms; number of bed spaces; number of storeys and provides an area for built-in storage. The minimum space standards shown in Table 1 in the Technical Standards Guide, as copied in Chapter 5 of this report which considers this in more detail.

2.1.16 NSS states that GIA ‘will not be adequate for wheelchair housing (Category 3 homes in Part M of the Building Regulations) where additional internal area is required to accommodate increased circulation and functionality to meet the needs of wheelchair households.’9

Part M Building Regulations

2.1.17 New requirements under the Part M Building Regulations 2010 were brought in at the same time, in October 2015. The main changes were replacing requirement M4 ‘Sanitary conveniences in dwellings’ with:

. M4(1) Category 1: Visitable dwellings

8 Housing and Planning Act 2016 (para 5(1) (4) (5)) 9 Para. 9, Technical Housing Standards, CLG (March 2015)

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. M4(2) Category 2: Accessible and adaptable dwellings . M4(3) Category 3: Wheelchair user dwellings. 2.1.18 The Approved Document Part M sets out detailed technical specifications relating to each of the categories 1 – 3. However, it does not provide any detail on the minimum internal floor areas.

Illustrative Technical Standards Developed by the Working Groups

2.1.19 In developing the Housing Standards Review Government undertook a detailed questionnaire and evidence base within the ‘Illustrative Technical Standards’ which were developed by the Working Groups. This Review looked at Accessibility Standards, which relates to Part M of the Building Regulations (Category 1, 2 and 3). This included overall gross internal floor areas for different dwelling type, for Category 1, 2 and 3. Therefore these measurements have been used to inform this study.

National Policy on Infrastructure

2.1.20 The NPPF requires local planning authorities to demonstrate that infrastructure will be available to support development:

‘It is equally important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up.’ 10

2.1.21 It is not necessary for local planning authorities to identify all future funding of infrastructure when preparing planning policy. The NPPF states that standards and policies in Local Plans should ‘facilitate development across the economic cycle,’ 11 suggesting that in some circumstances it may be reasonable for a local planning authority to argue that viability is likely to improve over time, that policy costs may be revised, that some infrastructure is not required immediately, and that mainstream funding levels may recover.

National Policy on Community Infrastructure Levy

2.1.22 The Community Infrastructure Levy (CIL) is a planning charge based on legislation that came into force on 6 April 2010. The levy allows local authorities in England and Wales to raise contributions from development to help pay for infrastructure that is needed to support planned development. Local authorities who wish to charge the levy must produce a draft charging schedule setting out CIL rates for their areas – which are to be expressed as pounds (£) per square metre, as CIL will be levied on the gross internal floorspace of the net additional liable development. Before it is approved by the Council, the draft charging schedule has to be tested by an independent examiner.

2.1.23 The requirements which a CIL charging schedule has to meet are set out in:

 The Planning Act 2008 as amended by the Localism Act 2011.

 The CIL Regulations 201012, as amended in 201113, 201214, 201315 and 201416.

10 DCLG (2012) National Planning Policy Framework (p42, para 177) 11 Ibid (p42, para 174) 12 http://www.legislation.gov.uk/ukdsi/2010/9780111492390/pdfs/ukdsi_9780111492390_en.pdf 13 http://www.legislation.gov.uk/ukdsi/2011/9780111506301/pdfs/ukdsi_9780111506301_en.pdf 14 http://www.legislation.gov.uk/uksi/2012/2975/pdfs/uksi_20122975_en.pdf 15 http://www.legislation.gov.uk/uksi/2013/982/pdfs/uksi_20130982_en.pdf 16 http://www.legislation.gov.uk/uksi/2014/385/pdfs/uksi_20140385_en.pdf

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 National Planning Practice Guidance on CIL (NPPG CIL).17

2.1.24 The 2014 CIL amendment Regulations have altered key aspects of setting the charge for charging authorities who publish a draft charging schedule for consultation. The key points from these various documents are summarised below.

Striking the appropriate balance

2.1.25 The revised Regulation 14 requires that a charging authority ‘strike an appropriate balance’ between:

 The desirability of funding from CIL (in whole or in part) the… cost of infrastructure required to support the development of its area; and

 The potential effects (taken as a whole) of the imposition of CIL on the economic viability of development across its area.

2.1.26 A key feature of the 2014 Regulations is to give legal effect to the requirement in this guidance for a charging authority to ‘show and explain…’ their approach at examination. This explanation is important and worth quoting at length:

‘The levy is expected to have a positive economic effect on development across a local plan area. When deciding the levy rates, an appropriate balance must be struck between additional investment to support development and the potential effect on the viability of developments.

This balance is at the center of the charge-setting process. In meeting the regulatory requirements (see Regulation 14(1)), charging authorities should be able to show and explain how their proposed levy rate (or rates) will contribute towards the implementation of their relevant plan and support development across their area.

As set out in the National Planning Policy Framework in England (paragraphs 173 – 177), the sites and the scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened. The same principle applies in Wales.’ 18

2.1.27 In other words, the ‘appropriate balance’ is the level of CIL which maximises the delivery of development and supporting infrastructure in the area. If the CIL charging rate is above this appropriate level, there will be less development than planned, because CIL will make too many potential developments unviable. Conversely, if the charging rates are below the appropriate level, development will also be compromised, because it will be constrained by insufficient infrastructure.

2.1.28 Achieving an appropriate balance is a matter of judgement. It is not surprising, therefore, that charging authorities are allowed some discretion in this matter. This has been reduced by the 2014 Regulations, but remains. For example, Regulation 14 requires that in setting levy rates, the Charging Authority (our underlining highlights the discretion):

‘…must strike an appropriate balance…’ i.e. it is recognised there is no one perfect balance;

‘Charging authorities need to demonstrate that their proposed levy rate or rates are informed by ‘appropriate available’ evidence and consistent with that evidence across their area as a whole.’

17 DCLG (February 2014) Community Infrastructure Levy Guidance and DCLG (June 2014) National Planning Practice Guidance: Community Infrastructure Levy (NPPG CIL) 18 DCLG (June 2014) NPPG CIL (para 009)

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‘A charging authority’s proposed rate or rates should be reasonable, given the available evidence, but there is no requirement for a proposed rate to exactly mirror the evidence …… There is room for some pragmatism.’ 19

2.1.29 Thus, the guidance sets the delivery of development firmly within the context of implementing the local plan. This is linked to the plan viability requirements of the NPPF, particularly paragraphs 173 and 174. This point is given emphasis throughout the guidance. For example, in guiding examiners, the guidance makes it clear that the independent examiner should establish that:

‘…evidence has been provided that shows the proposed rate (or rates) would not threaten delivery of the relevant Plan as a whole...’20

2.1.30 This also makes the point that viability is not simply a site specific issue but one for the plan as a whole.

2.1.31 The focus is on seeking to ensure that the CIL rate does not threaten the ability to develop viably the sites and scale of development identified in the local plan. Accordingly, when considering evidence, the guidance requires that charging authorities should:

‘…use an area based approach, involving a broad test of viability across their area’, supplemented by sampling ‘…an appropriate range of types of sites across its area…’ with the focus ‘...on strategic sites on which the relevant Plan relies and those sites where the impact of the levy on economic viability is likely to be most significant (such as brownfield sites).’ 21

2.1.32 This reinforces the message that charging rates do not need to be so low that CIL does not make any individual development schemes unviable (some schemes will be unviable with or without CIL). The levy may put some schemes at risk in this way, so long as, in striking an appropriate balance overall, it avoids threatening the ability to develop viably the sites and scale of development identified in the local plan.

Keeping clear of the ceiling

2.1.33 The guidance advises that CIL rates should not be set at the very margin of viability, partly in order that they may remain robust over time as circumstances change:

‘…if the evidence pointed to setting a charge right at the margins of viability………It would be appropriate to ensure that a ‘buffer’ or margin is included, so that the levy rate is able to support development when economic circumstances adjust.’22

2.1.34 We would add two further reasons for a cautious approach to rate-setting, which stops short of the margin of viability:

 Values and costs vary widely between individual sites and over time, in ways that cannot be fully captured by the viability calculations in the CIL evidence base; and

 A charge that aims to extract the absolute maximum would be strenuously opposed by landowners and developers, which would make CIL difficult to implement and put the overall development of the area at serious risk.

19 Ibid (para 019) 20 Ibid (para 038) 21 Ibid (para 019) 22 Ibid (para 019)

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Varying the CIL charge

2.1.35 CIL Regulations (Regulation 13) allows the charging authority to introduce charge variations by geographical zone in its area, by use of buildings, by scale of development (GIA of buildings or number of units) or a combination of these three factors. (It is worth noting that the phrase ‘use of buildings’ indicates something distinct from ‘land use’).23 As part of this, some rates may be set at zero. But variations must reflect differences in viability; they cannot be based on policy boundaries. Nor should differential rates be set by reference to the costs of infrastructure.

2.1.36 The guidance also points out that charging authorities should avoid ‘undue complexity’ when setting differential rates, and ‘...it is likely to be harder to ensure that more complex patterns of differential rates are state aid compliant.’ 24

2.1.37 Moreover, generally speaking, ‘Charging schedules with differential rates should not have a disproportionate impact on particular sectors or specialist forms of development’; otherwise the CIL may fall foul of state aid rules.25

2.1.38 It is worth noting, however, that the guidance gives an example which makes it clear that a strategic site can be regarded as a separate charging zone: ‘If the evidence shows that the area includes a zone, which could be a strategic site, which has low, very low or zero viability, the charging authority should consider setting a low or zero levy rate in that area.’ 26

Supporting evidence

2.1.39 The legislation requires a charging authority to use ‘appropriate available evidence' to inform their charging schedule27. The guidance expands on this, explaining that the available data ‘…is unlikely to be fully comprehensive’.28

2.1.40 These statements are important, because they indicate that the evidence supporting CIL charging rates should be proportionate, avoiding excessive detail. One implication of this is that we should not waste time and cost analysing types of development that will not have significant impacts, either on total CIL receipts or on the overall development of the area as set out in the local plan.

Chargeable floorspace

2.1.41 CIL will be payable on most buildings that people normally use and will be levied on the net additional new build floorspace created by any given development scheme. The following will not pay CIL:

 New build that replaces demolished existing floorspace that has been in use for six months in the last three years on the same site, even if the new floorspace belongs to a higher-value use than the old;

 Retained parts of buildings on the site that will not change their use, or have otherwise been in use for six months in the last three years;

23 The Regulations allow differentiation by “uses of development”. “Development” is specially defined for CIL to include only ‘buildings’, it does not have the wider ‘land use’ meaning from TCPA 1990, except where the reference is to development of the area. 24 DCLG (June 2014) NPPG CIL (para 021) 25 Ibid 26 Ibid 27 Planning Act 2008 Section 211 (7A) 28 DCLG (June 2014) NPPG CIL (para 019)

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 Development of buildings with floorspace less than 100 sqm (if not a new dwelling), by charities for charitable use, extensions to homes, homes by self-builders’ and social housing as defined in the regulations.

CIL, S106, S278 and the regulation 123 infrastructure list

2.1.42 The purpose of CIL is to enable the charging authority to carry out a wide range of infrastructure projects. CIL is not expected to pay for all infrastructure requirements but could make a significant contribution. However, development specific planning obligations (commonly known as S106) to make development acceptable will continue to be used alongside CIL. In order to ensure that planning obligations and CIL operate in a complementary way, CIL Regulations 122 and 123 place limits on the use of planning obligations.

2.1.43 To overcome potential for ‘double dipping’ (i.e. being charged twice for the same infrastructure by requiring the payment of CIL and S106), it is imperative that charging authorities are clear about the authority's infrastructure needs and what developers will be expected to pay for and through which route. The guidance expands this further in explaining how the list of infrastructure for funding by CIL, known as the Regulation 123 infrastructure list should be structured to account for generic projects and specific named projects).

2.1.44 The guidance states that ‘…it is good practice for charging authorities to also publish their draft (regulation 123) infrastructure lists and proposed policy for the scaling back of S106 agreements.’ This list now forms part of the ‘appropriate available evidence’ for consideration at the CIL examination. A draft infrastructure list should be available at the preliminary draft charging schedule phase.

2.1.45 The guidance identifies the need to assess past evidence on developer contributions, stating ‘…as background evidence, the charging authority should also provide information about the amount of funding collected in recent years through Section 106 agreements, and information on the extent to which affordable housing and other targets have been met’.

2.1.46 Whilst there are no pooling restrictions on the use of section 278 highway agreements, restrictions are in place to prevent “double dipping” i.e. the use of CIL and S278 to provide the same item of infrastructure.

What a CIL examiner will be looking for

2.1.47 According to the guidance, the independent examiner should check that:

 The charging authority has complied with the requirements set out in legislation;

 The 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.

2.1.48 The examiner must recommend that the draft charging schedule should be approved, rejected or approved with specific modifications.

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The Government’s review of CIL

2.1.49 Government is undertaking a review of CIL and has consulted with local authorities and others. A group appointed by Government first met in November 2015 to assess the extent to which CIL does or can provide an effective mechanism for funding infrastructure, as well as to recommend changes that would improve its operation in support of the government’s wider housing and growth objectives. This culminated in a report entitled ‘A New Approach to Developer Contributions’ being submitted to Government in October 2016.

2.1.50 After several delays, the outcomes of this review was published on 7th February 2017 alongside the Housing White, which was just as this report was also being published. In the White Paper the Government indicated that it continues to support the existing principle that developers are required to mitigate the impacts of development in their area to make it acceptable to the local community and pay for the cumulative impacts of development on the infrastructure of their area, secured via Section 106 planning obligations and via CIL.

2.1.51 In response to the Review report, the Government has indicated that it will examine the options for reforming the system of developer contributions including ensuring direct benefit for communities, and will respond to the independent review and make an announcement at the Autumn Budget 2017.

2.1.52 In addition to considering longer-term reform, the Government has indicated that it believes there is scope to make changes to Section 106 agreements in the short term to address practical issues in the operation of agreements raised by local planning authorities and developers.

2.1.53 In the absence of known changes, this report proceeds on the basis of current arrangements under the CIL Regulations.

2.2 Policy and Other Requirements

2.2.1 More broadly, the CIL guidance states that ‘Charging authorities should consider relevant national planning policy when drafting their charging schedules’29. Where consideration of development viability is concerned, the CIL guidance draws specific attention to paragraphs 173 to 177 of the NPPF and to paragraphs 162 and 177 of the NPPF in relation to infrastructure planning.

2.2.2 The only policy requirements which refer directly to CIL in the NPPF are set out at paragraph 175 of the NPPF, covering firstly, working up CIL alongside the plan making where practical; and secondly, placing control over a meaningful proportion of funds raised within neighbourhoods where development takes place. In urban areas, the Council retains the neighbourhood proportion to spend it on behalf of the neighbourhood. Whilst important considerations, these two points are outside the immediate remit of this study.

2.2.3 The NPPF requires Councils to ensure that they “do not load” policy costs onto development if it would hinder the site being developed. The key point is that policy costs will need to be balanced so as not to render a development unviable, but should still be considered sustainable.

2.3 Summary

Infrastructure summary

2.3.1 The infrastructure needed to support the plan over time will need to be planned and managed. Plans should be backed by a thought-through set of priorities and delivery sequencing that

29 Ibid (para 011)

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allows a clear narrative to be set out around how the plan will be delivered (including meeting the infrastructure requirements to enable delivery to take place).

2.3.2 This study confines itself to the question of development viability. It is for other elements of the evidence base to investigate the other ingredients in the definition of deliverability (i.e. location, infrastructure and prospects for development). Though the study will draw on infrastructure costs (prepared by the councils) to inform the impact on viability where relevant.

Affordable housing summary

The Housing and Planning Act

2.3.3 The Housing and Planning Act which became law at the end of October 2016, sets out that future Regulations will identify starter homes requirements for English planning authorities. This may have implications on future Local Plan affordable housing policies. At this stage, the requirements are unknown and the JLP will need to keep in mind any change in national policy. In the meantime, this report tests emerging proposed affordable housing policy.

Affordable housing exemption on 10 units and less

2.3.4 In November 2014, the Government introduced an exemption policy for small housebuilders (defined as developments of 10 dwellings or fewer) to exclude them from paying s106 and contribute to AH. Following a High Court ruling this was later quashed (West Berkshire District Council & Anr v The Secretary of State for Communities and Local Government, C1/2015/2559). However, in May 2016, the Government won a legal challenge against this, meaning that this threshold was to be upheld, and therefore the advice in this appraisal is based on smaller sites (10 units and fewer) being exempt from these contributions.

CIL summary

2.3.5 To meet legal requirements and satisfy an independent examiner, a CIL charging schedule published as a draft for consultation must strike an appropriate balance between the desirability of funding (in whole or in part) infrastructure needed to support the development and the potential effects (taken as a whole) of the imposition of CIL on the economic viability of development across its area.

2.3.6 This means that the net effect of the levy on total development across the area should be positive. CIL may reduce the overall amount of development by making certain schemes which are not plan priorities unviable. Conversely, it may increase the capacity for future development by funding infrastructure that would not otherwise be provided, which in turn supports development that otherwise would not happen. The law requires that the net outcome of these two impacts should be judged to be positive. This judgment is at the core of the charge-setting and examination process.

2.3.7 Legislation and guidance also set out that:

 Authorities should avoid setting charges at the margin of viability;

 CIL charging rates may vary across geographical zones, building uses, and by scale of development. But differential charging must be justified by differences in development viability, not by policy or by varying infrastructure costs; it should not introduce undue complexity; and it should have regard to State Aid rules;

 Charging rates should be informed by ‘appropriate available evidence’, which need not be ‘fully comprehensive’; and

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 Charging authorities should be clear and transparent about the use of different approaches to developers funding infrastructure and avoid ‘double dipping’.

2.3.8 While charging rates should be consistent with the evidence, they are not required to ‘mirror’ the evidence. In this, and other ways, charging authorities have discretion in setting charging rates.

2.3.9 The Government’s Housing White Paper 2017 has identified a need to speed up and simplify the planning obligation system, but what that might actually mean in practical terms will not be known until the Government’s Autumn’s Statement.

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3 Local Policy Impacts on Viability

3.1 Introduction

3.1.1 At the time of preparing this report, the Plymouth and South West Devon Joint Local Plan was still not published. Consequently, in identifying the implications of local policies on development viability in the Plymouth Policy Area and Thriving Towns and Villages Area, PBA has assessed the policies that may have a cost implication and hence an impact on viability that were being developed in the emerging Joint Local Plan. In addition, PBA have consulted with Plymouth City and South Hams and West Devon councils about any other polices, which are noted below.

3.1.2 The Plymouth and Thriving Towns and Villages policies have been assessed, firstly to determine whether there is likely to be a cost implication over and above that required by the market to deliver the defined development in the respective Policy Areas. For those policies where there will be or could be a cost implication, a broad assessment of the nature of that cost has been undertaken, including whether the cost is likely to be applied to the Policy Areas or is site specific, whether costs are related to specific timescales or apply for the entire life of the JLP and whether costs are likely to be incurred directly by the developer through on site or off site development, or via financial contributions made by the developer to other agencies or developers towards wider schemes within the Policy Areas.

3.2 Joint Local Plan Policies

3.2.1 Table 3.1 sets out the results of the policy review. Green indicates the policy has no cost/testing implication, amber indicates a slight impact, and red means that the policy would have some bearing on the viability of sites.

Emerging Joint Local Plan Policies

Table 3.1 Viability Policy Matrix in the emerging JLP (as at February 2017)

Does the policy Details of viability testing Emerging JLP policy have an impact implication for testing? Spatial Strategy No SPT1 Delivering sustainable development No SPT2 Sustainable linked neighbourhoods and sustainable rural No communities SPT3 Provision for new homes The policy sets out ambitions for types, and standards, for housing to be developed. The key policies in regards to sites of 11 units or more to provide at least 30% affordable housing. Size and tenure of affordable housing should reflect normal open Yes market housing. Providing a mix of housing sizes, types and tenures appropriate to neighbourhood. On housing schemes over 5 dwellings, provision is expected of 20% lifetime homes. On all new housing schemes over 25

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should provide at least 4 per cent of homes to meet full wheel chair user/adaptable standards. The Policy identifies the provision for 26,700 new homes over the plan period, of which at least 12,060 should be affordable. SPT4 Provision for employment Identifies the provision for Yes floorspace employment uses SPT5 Provision for shops Identifies the provision for retail Yes development SPT6 Spatial provision of retail and main town centre uses Yes Identifies the retail hierarchy SPT7 Working with neighbouring areas No SPT8 Strategic connectivity No SPT9 Strategic principles for transport planning and strategy No SPT10 Balanced transport strategy for growth and healthy sustainable No communities SPT11 Strategic approach to the natural environment No SPT12 Strategic infrastructure measures to deliver the spatial strategy No SPT13 European Protected Sites – mitigation of recreational impacts from No development Strategy for Plymouth Policy Area No PLY1 Enhancing Plymouth’s strategic role No PLY2 Unlocking Plymouths regional Identifies where growth will take Yes growth potential place PLY3 Utilising Plymouth’s regional economic assets No PLY4 Protecting and strengthening Devonport Naval Base and Dockyard’s No strategic role PLY5 Safeguarding Plymouth’s mineral No resources PLY6 Improving Plymouth’s City Centre No PLY7 Colin Campbell Court Identifies where development likely Yes to occur – viability will have to take this into account PLY8 Land at Royal Parade (between Yes Identifies where development likely Armada Way and Old Town Street) to occur – viability will have to take this into account PLY9 Mayflower Street East, City Centre Yes Identifies where development likely to occur – viability will have to take this into account PLY10 Cornwall Street East, City Centre Yes Identifies where development likely to occur – viability will have to take this into account PLY11 Cornwall Street West, City Centre Yes Identifies where development likely to occur – viability will have to take this into account PLY12 New George Street West, City Yes Identifies where development likely Centre to occur – viability will have to take this into account

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PLY13 Royal Assurance site, Armada Yes Identifies where development likely Way, City Centre to occur – viability will have to take this into account PLY14 Foot Anstey site, Derry’s Cross, Yes Identifies where development likely City Centre to occur – viability will have to take this into account PLY15 Civic Centre and Council House Yes Identifies where development likely site to occur – viability will have to take this into account PLY16 Railway Station Yes Identifies where development likely to occur – viability will have to take this into account PLY17 Plymouth University and No Plymouth College of Art PLY18 Plymouth History Centre and land No at Tavistock Place / Chapel Street PLY19 Central Park - Strategic Green No Space Site PLY20 Managing and enhancing No Plymouth’s waterfront PLY21 Supporting the visitor economy No PLY22 Cultural quarters No PLY23 Plymouth Fruit Sales, Sutton Identifies where development likely Road, Sutton Harbour Yes to occur – viability will have to take this into account PLY24 Sutton Road west, Sutton Yes Identifies where development likely Harbour to occur – viability will have to take this into account PLY25 Sugar House, Sutton Harbour Yes Identifies where development likely to occur – viability will have to take this into account PLY26 Sutton Harbour Fish Quay Yes Identifies where development likely to occur – viability will have to take this into account PLY27 Register office, Lockyer Street, Yes Identifies where development likely The Hoe to occur – viability will have to take this into account PLY28 Land north of Cliff Road, The Hoe Yes Identifies where development likely to occur – viability will have to take this into account PLY29 Millbay waterfront Yes Identifies where development likely to occur – viability will have to take this into account PLY30 Bath Street west Yes Identifies where development likely to occur – viability will have to take this into account PLY31 Bath Street east Yes Identifies where development likely to occur – viability will have to take this into account PLY32 Stonehouse Barracks Yes Identifies where development likely to occur – viability will have to take this into account PLY33 Oceansgate Yes Identifies where development likely to occur – viability will have to take this into account PLY34 Union Street Yes Identifies where development likely to occur – viability will have to take this into account PLY35 Drakes Island Yes Identifies where development likely to occur – viability will have to take this into account

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PLY36 Other site allocations in the Yes Identifies where development likely Growth Area to occur – viability will have to take this into account PLY37 Strategic infrastructure measures for the City Centre and Waterfront No Growth Area PLY38 Derriford commercial centre Yes Identifies where development likely to occur – viability will have to take this into account PLY39 Glacis Park, Derriford Yes Identifies where development likely to occur – viability will have to take this into account PLY40 Seaton Neighbourhood Yes Identifies where development likely to occur – viability will have to take this into account PLY41 Derriford Community Park No (Strategic Greenspace) PLY42 Plymouth Airport No PLY43 University of St Mark and St John No PLY44 Woolwell sustainable urban Identifies where development likely extension and community park Yes to occur – viability will have to take this into account PLY45 Plym Valley Strategic No Greenspace PLY46 Other site allocations in the Identifies where development likely Growth Area Yes to occur – viability will have to take this into account PLY47 Strategic infrastructure measures No for the Growth Area PLY48 Sherford new community Identifies where development likely Yes to occur – viability will have to take this into account PLY49 Sherford Community Park No

Strategic Greenspace PLY50 Saltram Meadow, Plymstock Yes Identifies where development likely to occur – viability will have to take this into account PLY51 Langage Yes Identifies where development likely to occur – viability will have to take this into account PLY52 Land at West Park Hill, Stoggy Yes Identifies where development likely Lane to occur – viability will have to take this into account PLY53 Land at former China Clay works Yes Identifies where development likely Coypool to occur – viability will have to take this into account PLY54 Saltram Countryside Park No PLY55 Hazeldene Quarry Minerals No

Safeguarding Area and buffer zone PLY56 Other site allocations in the Yes Identifies where development likely Growth Area to occur – viability will have to take this into account PLY57 Strategic infrastructure measures No

for the Growth Area PLY58 Site allocations in the south of Yes Identifies where development likely Plymouth to occur – viability will have to take this into account PLY59 Site allocations in the north of Yes Identifies where development likely Plymouth to occur – viability will have to take this into account

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PLY60 Site allocations in the east of Yes Identifies where development likely Plymouth (Plympton and Plymstock) to occur – viability will have to take this into account PLY61 Strategic infrastructure measures No Strategy for Thriving Towns and

Villages TTV1 Prioritising growth through a Yes Identifies where growth will take hierarchy of sustainable settlements place TTV2 Delivering Sustainable No

Development in the TTV policy area TTV3 Development in the countryside No TTV4 Residential extensions and No

replacement dwellings in the countryside TTV5 Strategic infrastructure measures No

for the Main Towns TTV6 Spatial priorities for development No

in Dartmouth TTV7 Land at Cotton Yes Identifies where development likely to occur – viability will have to take this into account TTV8 Land at Noss on Dart Yes Identifies where development likely to occur – viability will have to take this into account TTV9 Spatial priorities for development Yes Identifies where development likely in Ivybridge to occur – viability will have to take this into account TTV10 East of Ivybridge Yes Identifies where development likely to occur – viability will have to take this into account TTV11 Land at Filham Yes Identifies where development likely to occur – viability will have to take this into account TTV12 Land at Stibb Lane, Ivybridge Yes Identifies where development likely to occur – viability will have to take this into account TTV13 Other site allocations in the Yes Identifies where development likely Ivybridge area to occur – viability will have to take this into account TTV14 Spatial priorities for development No

in Kingsbridge TTV15 The Quayside, KIngsbridge Yes Identifies where development likely to occur – viability will have to take this into account TTV16 West of Belle Hill, Kingsbridge Yes Identifies where development likely to occur – viability will have to take this into account TTV17 Other site allocations in the Yes Identifies where development likely Kingsbridge area to occur – viability will have to take this into account TTV18 Spatial priorities for development No

in Okehampton TTV19 Land at Exeter Road, Yes Identifies where development likely Okehampton to occur – viability will have to take this into account TTV20 Land east of Okehampton Yes Identifies where development likely to occur – viability will have to take this into account TTV21 Spatial priorities for development No

in Tavistock TTV22 Callington Road, Tavistock Yes Identifies where development likely to occur – viability will have to take this into account

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TTV23 Plymouth Road, Tavistock Yes Identifies where development likely to occur – viability will have to take this into account TTV24 Other site allocations in the Yes Identifies where development likely Tavistock area to occur – viability will have to take this into account TTV25 Spatial priorities for development No

in Tavistock TTV26 Land at KEVICC Yes Identifies where development likely to occur – viability will have to take this into account TTV27 Land at Baltic Wharf Yes Identifies where development likely to occur – viability will have to take this into account TTV28 Other site allocations in the Yes Identifies where development likely Totnes area to occur – viability will have to take this into account TTV29 Site allocations in the Smaller Yes Identifies where development likely Towns and VIllages to occur – viability will have to take this into account TTV30 Empowering local residents to No create strong and sustainable communities Development Policies No DEV1 Protecting amenity and the No

environment DEV2 Air, water, soil, noise and land No DEV3 Sport and recreation No DEV4 Playing pitches No DEV5 Food growing and allotments No DEV6 Hot food takeaways in Plymouth No DEV7 Meeting local housing need in the Yes Identifies how housing need should Plymouth Policy Area be met DEV8 Meeting local housing need in the Yes Identifies how housing need should Thriving Towns and Villages Policy Area be met DEV9 Accessible housing Yes Identifies the accessible housing requirement DEV10 Delivering high quality housing Yes Identifies space and amenity standards DEV11 Houses in Multiple Occupation in No

the Plymouth Article 4 Direction Area DEV12 Purpose built student Yes Identifies student housing accommodation in the Plymouth Policy requirements Area DEV13 Consideration of traveller sites No DEV14 Maintaining a flexible mix of No

employment sites DEV15 Supporting the rural economy No DEV16 Providing retail and town centre Yes Identifies standards for retail uses in appropriate locations development DEV17 Promoting competitive town No

centres DEV18 Protecting local shops and No

services DEV19 Provisions for local employment No

and skills DEV20 Place shaping and the quality of No

the built environment DEV21 Conserving the historic No

environment

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DEV22 Development affecting the No

historic environment DEV23 Cornwall and West Devon Mining No

Landscape World Heritage Site DEV24 Landscape character No DEV25 Undeveloped coast No DEV26 Strategic Landscape Areas No

(Plymouth Policy Area) DEV27 Nationally protected landscapes No DEV28 Protecting and enhancing No

biodiversity and geological conservation DEV29 Green and play spaces No DEV30 Trees, woodlands and No

hedgerows DEV31 Specific provisions relating to No

transport DEV32 Meeting the community No

infrastructure needs of new homes DEV33 Waste management No DEV34 Delivering low carbon Yes Achieve regulated carbon emissions development levels of 20% less than that required to comply with Building Regulations. Connect to existing district energy networks or designed to be capable of connection. DEV35 Renewable and low carbon No

energy (including heat) DEV36 Community energy No DEV37 Managing flood risk No DEV38 Coastal Change Management No

Areas Delivery and Monitoring No DEL1 Approach to development delivery and viability, planning obligations and the No community infrastructure levy

The South West Devon Emerging Planning Policies

3.2.2 South Hams and West Devon council have identified their likely support for:

. An affordable housing requirement is anticipated but it is yet to be set. However, for the purpose of Plan testing, it was agreed by the council that the Plymouth requirement for 30% affordable housing would be suitable to test, although the council may seek to differ from this in due course. . The affordable housing threshold in South West Devon is assumed to start at 6 or more units where development is within Rural Parish areas. . The Housing Mix should be as follows (because this has recently been clarified through the Council’s Executive): - 35% - 1 and 2 bed dwellings - 35% - 3 bed dwellings - 30% - 4+ bed dwellings . Minimum National Space Standards in setting requirements for house sizes in their planning policies.

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. Lifetime Homes could be relevant in the rural areas, given the older age profile of population in these areas. However, the council have not yet identified what proportion of housing this would apply, but have suggested that it could be between 5-10% for Cat 2 standards (lifetime homes). With no readily prescribed proportions, PBA have applied the same proportions as those in Plymouth, which is a provision of 20% lifetime homes housing within schemes over 5 dwellings and at least 4 per cent of homes to meet Cat 3 standards (full wheel chair user/adaptable standards) within all new housing schemes over 25 dwellings is expected. . No sustainability uplift is expected to be made within planning policy beyond building regulations, however as a worst case scenario, PBA have tested schemes within South Hams and West Devon to meet a requirement for 20% carbon reduction below current building regulations, in line with the proposed policies in the Plymouth Plan. . Other site related mitigations are expected through S106 agreements, and for the purpose of testing, the council have suggested that an average sum of £2k per unit to be appropriate.

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4 Local Residential Context

4.1 Introduction

4.1.1 This chapter provides a brief summary of the residential development context and market conditions within the three authorities. This information is used to inform the residential testing assumptions presented in the following chapter. Non-residential assumptions based on market analysis are presented separately, in line with discussions about the testing assumptions, in Chapter 8.

4.1.2 A review of housing development patterns has been undertaken for the Plymouth Policy Area based on information obtained from the Plymouth Annual Monitoring Reports. Owing to an absence of recent annual monitoring reports in South Hams and West Devon, a review of the same information for the Thriving Towns and Villages Area is more limited, although it has been possible to note some of earlier patterns related to local residential activity.

4.2 Past Development Patterns

Size of development

4.2.1 Patterns of past development can often provide a guide to the likely patterns of future development.

4.2.2 Annual housing development in Plymouth was at a higher rate in the pre-recession years compared with post recession, achieving a peak of nearly 1,300 units in 2006/7. In 2014/15, just over 800 residential units were completed in Plymouth, which was nearly double that achieved the year before. Also, although not yet published, we are informed by the Council that completions in 2015/16 totalled just over 1,000 units.

4.2.3 The South Hams Housing Position Statement (March 2014) identifies that housing was being completed at rates around the 150 to 250 units per annum level between 2006/7 to 2012/13. The West Devon Five Year Housing Land Supply Statement (Jan 2015) identifies that housing was being completed at rates around the 70 to 500 units per annum, averaging at 250 per annum, between 2006/7 to 2013/14, with the higher rates in the first half of this period.

4.2.4 Figure 4.1 shows the delivery of dwellings in Plymouth (not including conversions, demolitions or student dwellings) according to Plymouth City Council’s Annual Monitoring Reports (AMRs). As shown by the red bars in Figure 4.1, the bulk of previous residential development has been achieved on sites with 10 or more units.

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Figure 4.1 Residential completions 2006-2014

1600 Small sites (9 and under dwellings) 1400 Larger sites (10 and over) 1200

1000

800 1289 600 898 400 636 770 503 609 457 465 200 417

0 57 67 31 34 50 83 49 25 41 2006/07 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15

Source: Plymouth City Council Annual Monitoring Reports

Type of units

4.2.5 The type of new units being developed is an important consideration used to inform our viability appraisals.

4.2.6 The Plymouth AMRs suggest that there was a clear preference for flatted development within Plymouth, but as shown in Figure 4.2, this trend has decreased in the recent period, from a high of 83% of all units in 2008/09 to a low of 20% in 2012/13. Conversely, the proportion of terraced housing appears to have increased in popularity over the same period.

Figure 4.2 Types of developments

100% 90% 20% 29% 80% 35% 36% 50% 70% 58% 72% 70% 60% 83% 50% 50% 37% 37% 40% 50% 29% 30% 32% 20% 22% 20% 30% 34% 22% 26% 10% 13% 15% 8% 8% 11% 0% 4% 2006/07 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15

Detached / Semi Terraced Flats

Source: Plymouth City Council Annual Monitoring Reports

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4.2.7 The latest South Hams AMR (2011/12) identifies that 2 and 3 bed sized properties account for some 38% and 36% of new build properties, followed next by 4+ bed properties at 20.5% of the total, and one beds with just 5.7%.

Type of land

4.2.8 It is important to consider the type of land where the bulk of future housing delivery is expected since this will have considerable impacts on development viability. According to the Plymouth Annual Monitoring Reports (AMRs) the vast majority of the dwellings developed are on previously developed land, as shown in Figure 4.3. Consequently, in testing future delivery assumptions it will be necessary to cover potential delivery costs associated with brownfield land, i.e. demolition and remediation of land.

4.2.9 The latest South Hams AMR (2011/12) identifies that brownfield sites have accounted for about half the housing completions between 2005/6 to 2011/12.

Figure 4.3 Proportion of sites developed on brownfield land

100% 9% 8% 4% 6% 4% 5% 6% 90% 20% 21% 80% 70% 60% 50% 91% 92% 96% 94% 96% 95% 94% 40% 80% 79% 30% 20% 10% 0% 2006/07 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15

Brownfield Garden Land or Greenfield land

Source: Plymouth City Council Annual Monitoring Report

Residential market densities

4.2.10 The Plymouth AMRs have measured the proportion of sites built at low, medium and high densities in recent years, which has been summarised in Figure 4.4. The bulk of development has achieved high densities of 50+ dwellings per hectare, hitting a peak of 97% in 2008/09. Since then, this has fallen to the bulk of new development achieving densities within the 30 to 50 dwellings per hectare range. The figure shows that development on the whole is at fairly high densities and potentially reflects the preference (albeit a falling preference) for flatted developments.

4.2.11 No similar monitoring data is available for the South Hams and West Devon area, although anecdotally we have been informed by the council that most developments are likely to be achieving somewhere between 30 and 40 units per hectare.

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Figure 4.4 Residential development densities

100% 12% 90% 80% 70% 56% 55% 70% 60% 79% 80% 76% 75% 64% 50% 97% 40% 30% 27% 38% 20% 25% 13% 15% 22% 21% 24% 10% 17% 8% 6% 7% 0% 5% 0%3% 2% 4% 2006/07 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15

less than 30 dwph between 30 and 50 dwph over 50 dwph

Source: Plymouth City Council Annual Monitoring Reports

4.3 Residential Market Sales Values

Sales values for all properties since January 2010

4.3.1 Using data of actual transactions since 2010 from the Land Registry, Figure 4.5 to 4.7 show the average sale price of residential units (new and existing) by comparable type (flats, detached, semidetached and terraced).

4.3.2 Figure 4.5, compared to figures 4.6 and 4.7, indicates that average sales values in Plymouth have tended to be lower than neighbouring West Devon and considerably lower than South Hams. Importantly, Figure 4.5 indicates that the average sale price for flats, semidetached and terraced have consistently been between £100,0000 to £200,000 in Plymouth, slightly higher within West Devon across the same period, whilst being consistently between £200,000 and £300,000 in South Hams.

4.3.3 It is unsurprising to discover that across the three figures that detached properties attract higher values. In Plymouth and West Devon, detached prices are followed by Semidetached, then terraced and then flats in terms of values. However, this pattern is less obvious in South Hams, where across the period values for flats, semidetached and terraced properties have been very similar.

4.3.4 Whilst notably lower than its neighbouring area, Plymouth has achieved the greatest growth in house prices since 2010, with a steady increase in average prices for all four residential types, and the increase in detached houses perhaps most prominent.

4.3.5 By contrast, the average prices have tended to fall in West Devon across the same period.

4.3.6 Sales values in South Hams have demonstrated greater monthly fluctuation, although this is partly explained by the smaller number of sales in this area. Values for detached homes appeared to dip in the middle of the period (early 2012) before returning to values similar to those seen at the start of the period. Values for flats, semidetached and terraced units in South Hams indicate a small increase over the period.

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Figure 4.5 Trend in residential sales values in Plymouth

£600,000 £500,000 £400,000 £300,000 £200,000 £100,000

£0

Jul-10 Jul-11 Jul-12 Jul-13 Jul-14 Jul-15

Jan-10 Jan-11 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16

Oct-10 Oct-11 Oct-12 Oct-13 Oct-14 Oct-15

Apr-11 Apr-10 Apr-12 Apr-13 Apr-14 Apr-15 Apr-16

Plymouth Detached Plymouth Flat Plymouth Semi Plymouth Terraced

Source: Land Registry

Figure 4.6 Trend in residential sales values in South Hams

£600,000 £500,000 £400,000 £300,000 £200,000 £100,000

£0

Jul-10 Jul-11 Jul-12 Jul-13 Jul-14 Jul-15

Jan-10 Jan-11 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16

Oct-10 Oct-11 Oct-12 Oct-13 Oct-14 Oct-15

Apr-10 Apr-11 Apr-12 Apr-13 Apr-14 Apr-15 Apr-16

South Hams Detached South Hams Flat South Hams Semi South Hams Terraced

Source: Land Registry Figure 4.7 Trend in residential sales values in West Devon

£600,000 £500,000 £400,000 £300,000 £200,000 £100,000

£0

Jul-10 Jul-13 Jul-11 Jul-12 Jul-14 Jul-15

Jan-10 Jan-11 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16

Oct-10 Oct-11 Oct-12 Oct-13 Oct-14 Oct-15

Apr-10 Apr-11 Apr-12 Apr-13 Apr-14 Apr-15 Apr-16

West Devon Detached West Devon Flat West Devon Semi West Devon Terraced

Source: Land Registry

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Sales values for new properties since 2015

4.3.7 Figure 4.8 shows transactional data for new properties sold since January 2015 from the Land Registry.

4.3.8 Land Registry data identifies that detached houses sold for approximately £325,000 in Plymouth and West Devon, and £380,000 in South Hams district. In Plymouth, semi- detached, terraced houses and flats have tended to sell for a similar amount (£200,000). These types of units have sold for notably higher in South Hams, particularly terraced housing. In West Devon, semi-detached properties and terraced properties have sold for approximately £185,000 and £175,000, respectively most likely reflecting the locations as well as the type of units sold, for example flats being close to town centres and/or coastal areas with a premium.

4.3.9 Figure 4.8 also indicates that the price of new flats in West Devon is low compared to the other locations because of the absence of coastal views; however this might also be explained by the small number of new flats sold since 2015.

Figure 4.8 Average sales values of new properties since Jan 2015.

£450,000 £400,000 £350,000 £300,000 £250,000 £200,000 £150,000 £100,000 £50,000 £0 Plymouth South Hams West Devon Average for 3 areas

Detached Flat Semi Terraced

Source: Land Registry

Future sales values

4.3.10 Looking forward in Figure 4.9, the latest projections of second-hand house prices prepared by Savills in their Residential Property Focus (Issue 1 2016), shows that the South West region, is expected to grow at a high rate relative to many other regions, both in terms of 1 year and 5 year forecasts. Savills estimate an annual growth rate of 6% in 2016 (compared to the national average of 5%) with values forecast to rise by almost 20% over the next 5 years (national average of 17%).

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Figure 4.9 Projected increase in average second-hand values

25.0% 5 year forecasted change in average second hand values (2016 to 2020) Annual forecasted change in average second hand values (2016)

20.0%

15.0%

10.0%

5.0%

0.0% UK London South South East of East West North North Yorks & Wales Scotland East West England Midlands Midlands East West Humber

Source: Savills World Research (2016), Residential Property Focus 2016 Issue 1

Sales values by postcode sector

4.3.11 Land Registry data of transactions by post code sector locations within the Plymouth Policy Area, and Thriving Towns and Villages Area are summarised for comparable unit types (detached, semidetached, terraced and flats sales) in Figures 4.10 and 4.11. Postcodes with lighter shading refer to areas where values are lower compared with darker areas where the average is higher. The results are presented separately for each dwelling type, so that the data is not skewed by an over representation of a particular type.

4.3.12 This exercise is important in regards to local plan testing or identifying a scope for CIL as clearly defined locations where there are significantly different sales values could necessitate a requirement for different policies or CIL rates. Guidance states that “Charging authorities can set differential rates for different geographical zones provided that those zones are defined by reference to the economic viability of development within them.”30

4.3.13 For the Plymouth Policy Area, the heatmaps indicates two clear points. Firstly, values in postcodes in or near the city centre, particularly along the coastal front, appear higher than most other locations in the authority area. Secondly, there appears a noticeable east-west divide with values in the west of the authority area (such as Camel’s Head, Weston Mill and Ernesettle neighbourhoods) having lower values than those towards the east.

30 DCLG (2016) Community Infrastructure Levy Guidance (para 34)

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Figure 4.10 Spread of average prices for detached (left) and semidetached (right) houses

Source: Land Registry data Figure 4.11 Spread of average prices for terraced (left) and flats (right) houses

Source: Land Registry data

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4.3.14 In South Hams there are clear differences in values in postcodes in the southern half of the district. Property prices for each unit type in Salcombe and Dartmouth are consistently higher than in locations towards the north, such as Ivybridge.

4.3.15 In West Devon, there is also a north south divide. The heat maps show higher values in the South around Tavistock compared to locations in the North around Okehampton.

4.3.16 From this PBA are able to form broad value areas shown in Figure 4.12.

Figure 4.12 Broad value areas in the Plymouth and Thriving Towns and Villages Policy Areas

Source: PBA Research using Land Registry

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4.3.17 These will provide the basis to constructing site typologies by value areas in the following section. In addition, PBA understand that it is expected that there would likely be considerable flatted development in waterfront locations within the Plymouth East value area. The value areas used for high level testing are therefore shown in Figure 4.11 below and are categorised as:

. Plymouth West . Plymouth East . South Hams - South . South Hams - North . West Devon - North . West Devon - South

Sales values per square metre

4.3.18 It is worth stating that the analysis so far is based on the full average prices achieved for residential units. Whilst this analysis is very useful it only tells part of the context. Land registry data is useful in providing the average sales value of a property, but does not adequately take into consideration the size of the property. For instance, it would be reasonable to assume that, all things being equal, larger properties attract higher values than smaller ones. It is also reasonable to assume that property sizes are likely to be larger, in general, in rural areas compared to their urban counterparts. Therefore, it is important to gain an understanding of likely sales values per square metre values.

4.3.19 By using Land Registry data of new properties, and by obtaining the corresponding floorspace data for each property from their Energy Performance Certificate, it is possible to derive an achieved per square metre sales value. PBA have analysed a sample of over 700 new build transactions that have taken place since 2015 in Appendix B. For West Devon, because of a smaller sample data, PBA have used data since 2014. The averages of these values for houses (owing to a low variation by housing type) and flats (which tend to have a significant differential from houses) are separated into the coloured geography bands shown in Figure 4.11 and summarised in Table 4.1 below.

Table 4.1 Average per square metre values for residential units

House Flat

Plymouth - West £2,351 Sample size too small Plymouth - East £2,465 £2,783 South Hams - North £2,409 Sample size too small South Hams - South £2,882 £2,860 West Devon - North £2,129 £1,847 West Devon - South £2,477 £2,555 Source: PBA Research using Land Registry data and EPC records

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5 Residential Viability Assumptions

5.1 Introduction

5.1.1 It is not always possible to get a perfect fit between a site, the site profile and cost/revenue categories but we have attempted a best fit in the spirit of the Harman Report. For this, the viability testing requires a series of assumptions about site typologies, the site coverage and floorspace mix to generate an overall sales turnover and value of land, which along with viability assumptions are discussed here for residential testing in turn.

5.1.2 Note that the viability testing assumptions relate to whole plan purposes and not specific site viability assessments.

5.2 Residential Site Typologies

5.2.1 This section identifies a suitable list of typologies (i.e. hypothetical developments), that are likely to reflect sites and schemes being brought forward in the plan period within the Plymouth Policy Area and Thriving Towns and Villages in South Hams and West Devon. PBA’s approach to identifying site typologies is informed by NPPG CIL guidance (2014), which suggests that:

‘…a charging authority should directly sample an appropriate range of types of sites across its area, in order to supplement existing data. This will require support from local developers. The exercise should focus on strategic sites on which the relevant Plan relies, and those sites where the impact of the levy on economic viability is likely to be most significant (such as brownfield sites). The sampling should reflect a selection of the different types of sites included in the relevant Plan, and should be consistent with viability assessment undertaken as part of plan-making.’31

5.2.2 The Harman Report states that the role of the typologies testing is not required to provide a precise answer as to the viability of every development likely to take place during the plan period:

‘No assessment could realistically provide this level of detail…rather, [the role of the typologies testing] is to provide high level assurance that the policies within the plan are set in a way that is compatible with the likely economic viability of development needed to deliver the plan.’32

5.2.3 Indeed the Report also acknowledges that a:

‘…plan-wide test will only ever provide evidence of policies being ‘broadly viable.’ The assumptions that need to be made in order to carry out a test at plan level mean that any specific development site may still present a range of challenges that render it unviable given the policies in the Local Plan, even if those policies have passed the viability test at the plan level. This is one reason why our advice advocates a ‘viability cushion’ to manage these risks.33

31 DCLG CIL Guidance 2014 page 16. 32 Local Housing Delivery Group (2012), op cit (para 15) 33 Ibid (para 18)

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5.2.4 Taking this guidance into consideration, the starting point is understanding where, and at what scale, development is likely to take place. As a starting point, PBA have utilised the findings in the PBA March 2016 report for identifying suitable typologies within the Plymouth JLP area. This set out a range of typologies from 1 unit to 400 units. For this study PBA have used a similar set of site typologies as a basis for the testing. The typologies used in PBA’s appraisals are set out in Tables 5.1, 5.2 and 5.3. In addition, the separate testing of actual sites identified through the Plymouth, South Hams and West Devon SHLAAs have been undertaken on the same basis, but reported under separate cover (see Chapter 1).

Site coverage and area

5.2.5 For establishing housing land values, assumptions about the likely number of units and saleable floorspace of the dwellings are required for generating a sales turnover. Total turnover is dramatically increased by greater coverage. But housing needs to be serviced by roads for instance, and for larger developments, land is required for public open space, strategic landscaping, community buildings, employment and possibly schools.

5.2.6 The gross area of the site allows for the provision of non-residential land uses normally associated with larger sites which generally support no direct revenue to the development. Also residential land values are normally traded and reported on a per net hectare basis, since it is only this area which delivers a saleable return and is therefore valued. Consequently, the viability assessments identify the likely net developable area to identify its value and to compare this with net developable land values benchmark.

5.2.7 For the residential typologies, the net developable areas have been derived based on discussions with the Councils and the wider development industry, and examples from elsewhere, including the SHLAA. The starting point to estimating site area is based on widely accepted English Partnerships Urban Capacity Guide, but this results in a slab approach where larger sites crossing a size threshold can generate lowers yields than those sites just under the threshold. Therefore, a ‘progressive’ rate of change formula based on local intelligence (a range of actual developments around the Plymouth area) is applied, which avoids the pitfalls of the slab approach34. The gross to net ratios used are shown in Tables 5.1 and 5.2.

Table 5.1 Residential typologies tested for Plymouth (inc. value areas East and West)

Typology Land type Gross Area Net Area No of Density (ha) (Ha) units (dph)

1 unit Brownfield 0.02 0.02 1 40 6 units Brownfield 0.15 0.15 6 40 10 units Brownfield 0.25 0.25 10 40 11 units Brownfield 0.28 0.28 11 40 25 units Brownfield 0.63 0.63 25 40 50 units Brownfield 1.28 1.25 50 40 100 units Greenfield 2.72 2.50 100 40 400 units Greenfield 13.93 10.00 400 40

34 The old rate was a "slab approach" where higher net to gross ratios were incremented and applied to the whole site area, which means there would be sudden drops in developable land as the gross land rose above the next threshold. The new approach is "progressive" and ratio decreases are applied between land size thresholds only. This means the ratio decreases are no longer applied to the whole site. It is easier to think how this works in comparison to income tax system.

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Table 5.2 Residential typologies tested for South West Devon value area

Typology Land type Gross Area Net Area No of Density (ha) (Ha) units (dph)

1 unit Brownfield 0.03 0.03 1 35 6 units Brownfield 0.17 0.17 6 35 10 units Brownfield 0.29 0.29 10 35 11 units Brownfield 0.31 0.31 11 35 25 units Brownfield 0.71 0.71 25 35 50 units Brownfield 1.48 1.43 50 35 100 units Greenfield 3.18 2.86 100 35 400 units Greenfield 16.23 11.43 400 35

5.2.8 PBA understand that the density of development is likely to differ between locations and applies the councils’ estimates of the number of dwellings per net hectare for each site. This identifies a density of 40 dwellings per hectare for typologies in Plymouth, and at 150 dwellings per hectare for typologies in Plymouth waterfront locations. Typologies in South Hams and West Devon are assumed at 35 dwellings per hectare.

Developing site profile categories

5.2.9 PBA’s appraisals are based on four dwelling types: 1/2 bedroom flats, 2 bedroom houses, 3 bedroom houses and 4+ bedroom houses. Each typology is based on a mix of these dwelling types and are based on feedback from each local authority. For open market units, PBA have based on the mix set out in Table 5.3. Note however, that for flatted typologies have been based on 100% 1-2 bed flats whilst for housing typologies these are shared, based on the mix of 2 bed, 3 bed and 4+ bed houses as shown in Table 5.3.

5.2.10 A similar approach is adopted for the mix of affordable units, which has again been informed through discussion with each local authority based on expectations of need for each unit as identified in Chapter 3. This is also set out in Table 5.3.

Table 5.3 Tested mix of units

1 bed 2 bed 3 bed 4+ bed

Open Market Mix

Plymouth 20% 30% 30% 20% South Hams 15% 20% 35% 30% West Devon 15% 20% 35% 30% Affordable housing mix Plymouth 20% 30% 30% 20% South Hams 20% 40% 30% 10% West Devon 20% 40% 30% 10%

Source: Discussions with PCC, WDDC and SHDC officers

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Size of units

5.2.11 All three authorities are considering a specific Planning policy for achieving the minimum National Space Standards for property size. Since the space standards cover a wide range of sizes according to differing numbers of bedrooms, numbers of storeys, and numbers of residing persons, PBA have sought an average based on the sizes set out in Table 1 of the National Space Standards Guide which is copied below to derive the size averages in Table 5.4 for testing development viability in the Plymouth Policy Area, and Thriving Towns and Villages Area. For flatted developments, Table 5.4 shows the net area for estimating values and an additional 15% is added to this for additional space related to circulation space such as stairwells, etc.

Table 1 - Minimum gross internal floor areas and storage (m2)

Number of Number of bed 1 storey 2 storey 3 storey bedrooms (b) spaces (persons) dwellings dwellings dwellings

1 39 1b 2 50 58 3 61 70 2b 4 70 79 4 74 84 90 5 86 93 99 3b 6 95 102 108 5 90 97 103 6 99 106 112 7 108 115 121 4b 8 117 124 130 6 103 110 116 7 112 119 125 5b 8 121 128 134 7 116 123 129 6b 8 125 132 138

Table 5.4 Tested average saleable floorspace by unit type

Average minimum NSS Size (sqm) 1-2 bed Flats 55 2 bed houses 75 3 bed houses 93 4+ bed houses 117

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5.3 Residential Values and Costs Assumptions

Sales values

5.3.1 Current residential revenues and other viability variables are obtained from a range of sources, including:

. Land Registry matched with EPC records, as considered in a Chapter 4, provides a wealth of transactional data for a local area for new and second hand properties35; . Property websites, such as Rightmove, provide a snapshot of values of properties currently on the market, including new build and the floorspace of new build which is used to derive a sales value per square metre; and . Direct research with developers and agents operating in the area. 5.3.2 Based on these sources of information, and the analysis set out in Chapter 4, the assumed sales values per square metre are shown in Table 5.5. These are used for testing open market units in the viability assessment.

Table 5.5 Tested average Open Market residential sales value, per sqm

Value area Houses Flats

Plymouth - West £2,350 £2,500 Plymouth - East £2,500 £2,800 South Hams - North £2,400 £2,600 South Hams - South £2,900 £2,900 West Devon - North £2,150 £1,850 West Devon - South £2,450 £2,550

5.3.3 To corroborate these values, PBA carried out various consultations with the development industry, not least via discussions at the Stakeholder Workshop in December 2016. This provided invaluable information about the various elements of the local housing market including likely sales values per square metre, which were in line with the information presented in Table 5.5.

Build costs

5.3.4 Residential build costs are based on actual tender prices for new builds in the market place over a 15-year period from the Build Cost Information Service (BCIS), which is published by the Royal Institution of Chartered Surveyors (RICS). The data is derived from the median third quarter 2015 prices, which is the most recent data (at the time of the report) that reflects actual construction data as opposed to later figures that are based on estimated figures. While this is not the current forecast projection, the build costs period is more likely to be a comparable time frame to match the sales data, which is collected from the start of 201536 to the end of 2016 if we assume that the average will be close to sales sometime around 2015 prices

5.3.5 The tender price data reflects an average figure between costs taken for Plymouth, South Hams and West Devon (using BCIS tender price adjustments), and is therefore rebased to

35 Using average new build values for the past two years and floorspace from the Energy Performance Certificate to ascertain an average sales value per square metre. 36 Start of 2014 in West Devon to achieve a robust sample.

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show costs relevant to the local area. The build costs used for high level testing are shown in Table 5.6.

5.3.6 Volume and regional house builders are able to operate within the median cost figures comfortably, especially given that they are likely to achieve significant economies of scale in the purchase of materials and the use of labour. Many smaller and medium sized developers of houses are usually unable to attain the same economies, so their construction costs may be higher as shown in Table 5.6, which reflects the higher costs for schemes with 3 or less houses (taken from BCIS) and for 4-14 houses (taken as a mid-point between the larger and small schemes).

Table 5.6 Tested median build costs at Q3 2015 tender prices

Private Build Costs Cost per sqm Flats / Apartments £1,131 Houses (small house builder 3 and under) £1,181 Houses (medium house builder 4 to 14) £1,062 Houses (large house builder 15 and above) £942 Source: PBA derived from BCIS 5.3.7 The BCIS build costs are exclusive of external works, fees, contingencies, VAT and finance charges, plus other revenue costs. These additional costs are discussed below.

Other development costs

External works

5.3.8 This input incorporates all additional costs associated with the site curtilage of the built area. These include circulation space in flatted areas and garden space with housing units; incidental landscaping costs including trees and hedges, soft and hard landscaping; estate roads and connections to the strategic infrastructure such as sewers and utilities.

5.3.9 The external works variable had been set at a rate of 10% of build cost.

Professional fees

5.3.10 This input incorporates all professional fees associated with the build, including fees for planning, designs, surveying, project managing, at 8% of build cost plus externals.

Contingency

5.3.11 It is normal to build in contingency based on the risk associated with each site and has been calculated based on industry standards. It is generously applied at 4% of build cost plus externals since the above assumed costs may be lower or higher when they are realised.

Opening up costs

5.3.12 On large sites there is a need to allow for opening costs such site service installations or enhancements and strategic infrastructure such as drainage, strategic landscaping and public open space, etc. The following assumptions in Table 5.7 are used based on the number of units per scheme to identify scale of site infrastructure.

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Table 5.7 Tested opening up costs on Greenfield sites

No. of units per scheme Cost per unit Sites of 35 and under £0 Sites between 36 and 199 units £5,000 Sites between 200 and 499 units £10,000 Sites of 500 units and over £17,000

Brownfield site costs

5.3.13 Developing brownfield sites represent different risk and costs. All sites identified in the Local Plan are brownfield sites, and these costs can vary significantly depending on the site's specific characteristics. To reflect additional costs associated with residential site development on brownfield sites such as site clearance and remediation, an additional site cost, as in Table 5.8, is added onto to Brownfield site costs. This cost has been informed by examples from elsewhere and an HCA37 guide.

Table 5.8 Tested site abnormal costs on Brownfield sites

Brownfield site (abnormal) costs Per net hectare

Brownfield (e.g. industrial/retail/car park/storage uses) £300,000 Mixed (e.g. part developed and part open space) £150,000

Land purchase costs

5.3.14 The land value needs to reflect additional purchase cost assumptions, shown in Table 5.9. These are based on surveying costs and legal costs to a developer in the acquisition of land and the development process, which we have established from discussions with developers and agents, and are also reflected in the Harman Report (2012) as industry standard rates.

Table 5.9 Tested land purchase costs

Land purchase costs Rate Unit

Surveyor's fees 1.00% land value Legal fees 0.75% land value Stamp Duty Land Tax HMRC rate land value

5.3.15 A Stamp Duty Land Tax is payable by a developer when acquiring development land. This factor has been recognised and applied to the residual valuation as percentage cost based on the HM Customs & Revenue variable rates against the residual land value.

37 HCA, ‘Guidance on dereliction, demolition and remediation costs’ (March 2015)

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Sales fees

5.3.16 The Gross Development Value (GDV) on open market housing units need to reflect additional sales cost assumptions relating to the disposing of the completed residential units. This will include legal, agents and marketing fees at the rate of 3% of the open market unit GDV, which is based on industry accepted scales established from discussions with developers and agents.

Developer profit

5.3.17 The developer's profit is the expected and reasonable level of return that a private developer would expect to achieve from a specific development scheme. PBA assume a profit of 20% of open market residential sales value. This also allows for internal central overheads.

5.3.18 For the affordable housing element, because they will have some, albeit lower, risks to the developer, PBA assume a lower 6% profit margin of affordable housing transfer value for the private house builders. This is on a nil grant basis.

Finance

5.3.19 Each appraisal in this viability assessment calculates the interaction of costs and values, subject to a monthly cashflow based using a finance cost of 6% per annum. This is used to account for the cost of borrowing and the risk associated with the current economic climate and the near term outlook and associated implications for the housing market. This is a typical rate which is being applied to residential schemes similar to those being tested.

5.4 Proposed Policy Costs

5.4.1 In the policy testing we assess the impact of different policies, including S106, affordable housing and access standards.

S106 costs (excluding affordable housing)

5.4.2 PBA understand that the JLP councils are likely to continue to seek S106 costs from developments for site mitigations and contribution to planning policies. From discussions with each of the local authorities, a figure of £2,000 per unit has been assumed to be appropriate on the basis that a CIL would be collected for payment towards wider strategic infrastructure costs in Plymouth

Community Infrastructure Levy

5.4.3 Plymouth City Council has a formally adopted CIL charge in place. Accounting for indexing, currently this is £37 per CIL Liable square metre, which is applied to the relevant Plymouth sites in the viability assessment.

Policies regarding housing standards

5.4.4 It is understood that all councils are considering policies requiring new development to meet certain housing criteria, as in the Joint Local Plan emerging policies Dev9 Accessible Housing, DEV10 Delivering High Quality Housing and DEV34 Low Carbon Development. It has been assumed that the Category 1 dwelling sizes, as described in national government’s Illustrative Technical Standards (2013), led to the finalised NSS adopted minimum space standards. For the purposes of the study, the percentage increase from Cat 1 to Cat 2; and then from Cat 1 to Cat 3 was taken from the draft Illustrative figures. The percentage increases were then applied to the NSS to provide space standards for dwellings built to Cat 2 and 3.

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5.4.5 To assess the impact on viability, there is a need to identify the extra costs that might burden future sites in meeting requirements for accessible homes, i.e. Category M2 (Accessible and adaptable buildings) and/or Category M3 (wheelchair user dwellings). To do this PBA reviewed the DCLG Housing Standards Review Cost Impacts (Sept 2014) report for M2 (Cat 2) and M3 (Cat 3) and in total the additional average costs for upgrading a NSS home are summarised in Table 5.10.38

5.4.6 However, since it has been policy in Plymouth for 20% of new dwellings developed to be Lifetime Homes standard under Core Strategy Target 10.4, and similarly in West Devon and South Hams under their previous plan policies, it is likely that the extra-over cost associated with Cat 2 properties will already be included in the BCIS build costs that are rebased to Plymouth, South Hams and West Devon tender prices using the BCIS location index. Therefore, no extra cost for Cat 2 properties are assumed to occur beyond the increase in cost related to the additional floorspace size of Cat 2 units.

Table 5.10 Cost for meeting Building Regulation Access Standards

Category type Cost Unit Cat 2 £521* per house

Cat 2 £924* per flat

Cat 3 £22,694 per house

Cat 3 £7,906 per flat

*These costs are not separately identified in the PBA model because they are assumed to be within the BCIS build costs.

Policies regarding Sustainable Design and Construction

5.4.7 Similar to the previous section, PBA understand that the joint Councils are seeking to pursue policies requiring a commitment to sustainable design. Policy DEV34 of the emerging Joint Local Plan focuses on the issue of reducing regulated CO2 emissions by 20% through sustainable construction. Within the context of producing this report, no specific costs are able to be identified for this. But given that the required policy CO2 reductions would be similar to achieving the abandoned Code for Sustainable Homes Level 4, a 2.5% extra-over build costs (discussed above) is assumed to apply in meeting this policy. This assumption has been informed by a Davis Langdon report (Sept 2013) which assessed the Extra over capital costs per dwelling for CSH4 may be between £2k to £3k on BCIS building costs to 2010 Building Regulations standards, which is somewhere around 2.5% of average build costs.

38 In December 2015, PBA carried out a viability assessment of national government minimum space standards. This included a review of 20 sites across Plymouth with planning permission to provide evidence on the achievability of the new minimum house standards to underpin the merging Local Plan. The assessment of sites was a high level viability assessment which assessed the current viability of schemes with planning permission, using ‘as built’ sizes of dwellings, and compared the viability using the same schemes using the new minimum national space standards and proposed local policy access standards.

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Policy regarding Affordable Housing

5.4.8 One of the most significant items of S106 sought from residential development sites is affordable housing. PBA have been asked to test Affordable Housing policy options delivered at a 30% Affordable Housing rate in the Plymouth Policy Area and Thriving Towns and Villages Area. However, it should be noted that South Hams and West Devon councils may still include a higher rate for the latter area based on viability.

5.4.9 PBA have also been asked to test the implications of the Starter Homes initiative on affordable housing delivery. PBA understand that an affordable housing threshold should be applied to developments of 11 units and more in the Plymouth Policy Area and 6 units or more in the Thriving Towns and Villages area.

5.4.10 In the absence of a policy covering a required affordable housing tenure, based on recent delivery informed by PCC’s housing team, the following assumptions are applied to the affordable housing units:

. 1/3 social rented . 1/3 affordable rent; and . 1/3 intermediate/shared ownership. 5.4.11 The appraisal assumes that affordable housing will command a transfer value to a Registered Provider at lower than market rates. For the Plymouth area, the values have been informed by evidence of recent deals, the Planning Obligations and Affordable Housing Supplementary Planning Document 2nd Review values (Sept 2014), a PHDP Register Provider survey (Sept 2015) and discussion with the Council’s housing team. For South Hams and West Devon, the appraisal assumes that affordable housing will command a transfer value to a Registered Provider at lower than market rates. The testing assumes the values set out in Table 5.11, which from discussions with Registered Providers, would reflect the current market under the Government introduced ‘Rent Review’ mechanism announced in July 2015.

Table 5.11 Assumed transfer values by Affordable Housing tenure

House Flat (Plymouth Transfer value (Plymouth only) only) Social rent – all areas £849 £1,049 40% Affordable rent £1,117 £1,117 50% Intermediate/shared ownership 65% Starter Homes* 80% *subject to a cap of £250,000 per unit

Impact of introducing Starter Homes

5.4.12 PBA have been asked to sensitivity test the impact of the introduction of Starter Homes and the impact that the initiative is likely to have on the recommendation for policy and CIL rates. Although full details are yet to be confirmed by Government, the purpose is to provide a high- level sensitivity testing for suggesting CIL rates based on Starter Homes being defined as affordable housing.

5.4.13 Before testing the impact of the Starter Homes initiative it is worth clarifying some of the assumptions used to test these units. A key change in policy is an assumed requirement for 20% Starter Homes (on sites of 11 and above) replacing some of the affordable housing element.

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5.4.14 For the purposes of this testing, PBA have applied the same sizes for open market units to Starter Homes and included S106 (of £2,000 per unit) to remain consistent with the analysis in the previous section.

5.4.15 Finally, it is currently unclear as to how the development industry will consider its profit on Starter Homes. Affordable units often carry a much lower expectation of profit than open market units, due in part to the lower risks involved in disposing of these units. It is unclear as to whether there will be similar expectations for Starter Homes. For this report an expectation of 10% of the gross development value of Starter Homes is assumed.

5.5 Benchmark Land Value Assumptions

5.5.1 To assess viability, the residual value generated by a scheme is compared with a benchmark (sometimes referred to as a threshold) land value, which reflects ‘a competitive return for a landowner’ (as stated in Harman). The difference between the benchmark land value and the residual land value is used for estimating financial headroom.

5.5.2 PBA assume a benchmark land value in our viability assessments, that would be sufficiently below the market rate for clean residential land to allow for possible on-costs, like meeting planning requirements and possibly site preparation costs discussed earlier. These on-costs would normally be expected to come off the clean land value price.

5.5.3 The starting point was to consider the land values in the PBA March 2016 report, which were informed by a review of viability evidence of sites currently on the market, a review of submitted viability appraisal by applicants, published data on land values and discussions with stakeholders. The approach followed a top down approach of current market value of serviced plots and bottom up approach of existing use values without benefit of permission of allocation for residential use. At the time these figures were considered an acceptable benchmark for what could be considered as a reasonable return to a willing landowner and developer, in line with the approach set out in the NPPF/NPPG and Harman guidance.

5.5.4 For the scope of this exercise, viability-led appraisals have been created, however for policy purposes these standard appraisals are assumed as being planning led. This accords with national planning guidance which advises that the “land or site value should reflect policy requirements, planning obligation requirements, and where applicable the CIL.”39

5.5.5 In determining the benchmark land value, evidence of known land transactions within the Plymouth Policy Area, and Thriving Towns and Villages Area has been collected by the councils. Land sale agreements are not widely available and data has been sourced from records held by three local agents as well as transactions where the local authority has been the landowner. In collecting this information, note has been made of the planning obligations attached to the land, the planning policies in effect at the time of consent and the specific terms of the deal whether unconditional, option agreement or promotion agreements.

5.5.6 To determine the value of the unconsented land, transactions have been risk-adjusted back to the unconsented value in line with RICS guidance note GN 94/2012, Financial Viability in Planning. The open market consented land transactions have been discounted to between 40% and 85% of their value to reflect the specific risk and terms of each individual transaction.

5.5.7 These adjustments have given an assumed benchmark land value for unconsented development land on a net hectare basis as set out in Table 5.12 and which could be considered as an appropriate benchmark for policy level viability testing.

39 NPPG 2014 (“Viability and decision taking” paragraph 023)

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Table 5.12 Benchmark land values for sites without planning

Value area Per net hectare

Plymouth - East £650,000

Plymouth - West £450,000

South Hams – North £470,000

South Hams - South £495,000

West Devon – North £350,000

West Devon – South £390,000

5.5.8 It is important to appreciate that assumptions on benchmark land values can only be broad approximations subject to a wide margin of uncertainty. This uncertainty is considered when drawing conclusions and recommendations from this study. They are not used to identify a value or price for the land. They are values to compare against in terms of a site being deliverable. As noted in Chapter 1, the viability methodology applied is appropriate for whole plan analysis purposes but should not be taken as the de facto approach for every individual development proposal which will be subject to its own site opportunities and constraints.

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6 Residential Sites Viability

6.1 Introduction

6.1.1 This Chapter sets out the viability assessments of emerging Joint Local Plan policies to identify and assess their burden on future development within the Plymouth Policy Area and Thriving Towns and Villages Area, and the potential for changing the residential CIL charges in Plymouth.

6.1.2 This is based on running viability appraisals to provide a summary of the potential surplus headroom residing in each typology, defined as the difference between value and all costs, including the cost of the land, associated with each typology. PBA display the residential viability results in the following tables using a 'traffic light' system, as follows:

. Green colour means that the development is viable with financial headroom that could be used for CIL. . Amber is marginal in that they fall within a 20% range (i.e. 10% above or below) around the benchmark land value. . Red colour means it is unviable. 6.1.3 The analysis considers viability in each of the value areas, and considers an affordable CIL rate based on the broad typologies. To recap, the testing includes the following policy considerations:

. 30% Affordable housing policy . £2,000 per unit contribution for s106 . £37 per CIL Liable Sqm (current rate for Plymouth typologies only) . Sustainable design of 2.5% . Policy 15: CAT 3 Houses and Flats 6.1.4 An example residential viability appraisal is included in Appendix A.

6.2 Is the Plan viable?

Plymouth

6.2.1 Table 6.1 provides a summary of the viability assessment and identifies the potential surplus financial headroom per CIL liable square metre of development above the level required to deliver the tested site typologies in Plymouth.

6.2.2 Looking across the generic typologies it can be concluded that the emerging JLP policies could be accommodated in the majority of the typologies. It is worth pointing out that although not all sites are likely to be able to meet the requirements of the plan, the nature of testing the emerging JLP policies is to provide a high level assessment of viability and that the broad assumptions will not match the reality of each development in every instance. PBA acknowledge that these known sites may have characteristics, such as density, costs, values, size and splits of units, etc, that may differ from the broad approximations used in the assessment appraisals. A good example for this is housing mix. In Plymouth, this is particularly relevant to the 11 unit sites which are just moving into the Affordable Housing threshold, where in reality sites may seek to deliver more housing to improve the return or reduce the number of houses below the threshold to avoid the burden of policy on viability. This means that, where sites are seen in this testing as unviable, there is scope through minor tweaking in the development which could enable its delivery.

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Table 6.1 Residential viability headroom – Plymouth Policy Area

ID Typology Value area Viable?

1 1 unit Plymouth - West Marginal 2 6 units Plymouth - West Viable 3 10 units Plymouth - West Viable 4 11 units Plymouth - West Unviable 5 25 units Plymouth - West Viable 6 50 units Plymouth - West Viable 7 100 units Plymouth - West Viable 8 400 units Plymouth - West Viable 9 1 unit Plymouth - East Viable 10 6 units Plymouth - East Viable 11 10 units Plymouth - East Viable 12 11 units Plymouth - East Marginal 13 25 units Plymouth - East Viable 14 50 units Plymouth - East Viable 15 100 units Plymouth - East Viable 16 400 units Plymouth - East Viable

Thriving Towns and Villages

6.2.3 For South Hams, the viability testing identified headrooms for the typology of sites in Table 6.2 indicates a clear difference between sites north and south of the district. The north show plan viability for small sites as being marginal at the affordable housing rate of 30%.

6.2.4 Similarly, for West Devon, the viability testing identified headroom for the typology of sites in in Table 6.3 again indicates a clear difference between sites north and south of the district. The affordable housing rate of 30% is viable across all typologies in the south section of West Devon. It is only at the small sites, of 11 and under units, that viability is notably weaker. This may therefore necessitate, that in some instances, the Council may wish to compromise on certain requirements in order to assist delivery, for instance housing mix, density or other site characteristics that could have small, beneficial impacts on viability.

6.2.5 The conclusion from this assessment is that, on the whole, it is considered that the policies in the emerging Joint Local Plan are appropriate.

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Table 6.2 Residential viability headroom – Thriving Towns and Villages Area (South Hams)

ID Typology Value area Viable?

17 1 unit South Hams - North Viable 18 6 units South Hams - North Marginal 19 10 units South Hams - North Marginal 20 11 units South Hams - North Marginal 21 25 units South Hams - North Viable 22 50 units South Hams - North Viable 23 100 units South Hams - North Viable 24 400 units South Hams - North Viable 25 1 unit South Hams - South Viable 26 6 units South Hams - South Viable 27 10 units South Hams - South Viable 28 11 units South Hams - South Viable 29 25 units South Hams - South Viable 30 50 units South Hams - South Viable 31 100 units South Hams - South Viable 32 400 units South Hams - South Viable

Table 6.3 Residential viability headroom – Thriving Towns and Villages Area (West Devon)

ID Typology Value area Viable?

33 1 unit West Devon - South Viable 34 6 units West Devon - South Viable 35 10 units West Devon - South Viable 36 11 units West Devon - South Viable 37 25 units West Devon - South Viable 38 50 units West Devon - South Viable 39 100 units West Devon - South Viable 40 400 units West Devon - South Viable 41 1 unit West Devon - North Unviable 42 6 units West Devon - North Unviable

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ID Typology Value area Viable?

43 10 units West Devon - North Unviable 44 11 units West Devon - North Unviable 45 25 units West Devon - North Viable 46 50 units West Devon - North Marginal 47 100 units West Devon - North Viable 48 400 units West Devon - North Marginal

6.3 Scope for CIL in Plymouth

6.3.1 PBA have also been asked to assess the scope for changing the CIL charge within Plymouth. The following section is based on the same assumptions in the previous section. The exception to this is that the CIL rate for the below analysis has been assumed as zero. The headroom set out in Table 6.4 therefore indicates the total value per sqm residing in a scheme after all other policy costs have been considered, and could be considered as the maximum that could be used for a CIL until the scheme becomes unviable.

6.3.2 The analysis in this section provides an indication of the headroom, in a similar fashion to the previous section, but expressed as a figure indicating the headroom per CIL liable floorspace (i.e. for open market uses only because affordable housing floorspace is exempt). Rather than applying the maximum headroom rates consistent with viability shown by PBA’s testing, reasonable common sense indicates that charging rates should be lower than this ‘ceiling’ or margin or viability of what the average development can afford. Therefore, based on the potential headrooms for CIL shown in Table 6.4, there is scope to increase CIL from the current indexed rate of £37 per sqm.

6.3.3 Since the headroom is not significantly different depending on whether the site is in the east or west value area, it is recommended that a single charge of up to about £100 per sqm would be affordable by the bulk of sites within the Plymouth Plan Policy Area. Alternatively, a rate of up to about £90 in the East and £120 in the West could be appropriate to maximise the return and reducing the impact on some sites not being able to afford the charge.

6.3.4 Based on analysis of headroom for setting CIL rates within the generic typologies of developments within the Plymouth, the following rates can be recommended:

. Plymouth - East = £90 per sqm . Plymouth - West = £120 per sqm 6.3.5 These recommendations for CIL charging are based on meeting full council policy requirements as set out in the emerging JLP, which from PBA’s testing would suggest that the majority of sites are able to comfortably meet the additional CIL that would be imposed with a few exceptions (such as those units just crossing policy thresholds). In the majority of sites, at the recommended rates for CIL, it can be expected that there would be a substantial financial

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cushion left within schemes (more than 30% of the total average headroom across the tested typologies) for potential unknown cost increases and/or lower sales values.

Table 6.4 Residential development viability headroom – Plymouth Policy Area

Additional CIL Liable ID Typology Value area Headroom

1 £42 1 unit Plymouth - West 2 £187 6 units Plymouth - West 3 £185 10 units Plymouth - West 4 -£23 11 units Plymouth - West 5 £174 25 units Plymouth - West 6 £159 50 units Plymouth - West 7 £194 100 units Plymouth - West 8 £124 400 units Plymouth - West 9 £94 1 unit Plymouth - East 10 £238 6 units Plymouth - East 11 £233 10 units Plymouth - East 12 £21 11 units Plymouth - East 13 £213 25 units Plymouth - East 14 £198 50 units Plymouth - East 15 £232 100 units Plymouth - East 16 £160 400 units Plymouth - East

6.3.6 The Council’s decisions on increasing the charging rates will depend on two main factors: the amount of risk it is prepared to accept and its policy priorities. To inform this, further policy sensitivity testing is presented in the next section.

Sensitivity testing - Affordable housing percentages

6.3.7 To inform Plymouth City Council’s decision making PBA have included the following sensitivity test. The first appraises the typologies, using the same assumptions, except varying the affordable housing policy.

6.3.8 Table 6.5 shows the CIL Liable headroom at a range of affordable housing provision between 20% and 40%, demonstrating a trade-off between affordable housing provision and seeking a higher rate of CIL. Broadly speaking, the testing demonstrates that a reduction in the affordable housing percentage to 20% provides scope for seeking an extra £30 - £40 per square metre in CIL.

Table 6.5 Sensitivity at a range of affordable housing rates – Plymouth Policy Area

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ID Typology Value area CIL Liable CIL Liable CIL Liable CIL Liable CIL Liable Headroom Headroom Headroom Headroom Headroom @ 20% AH @ 25% AH @ 30% AH @ 35% AH @ 40% AH

1 1 unit Plymouth - West £42 £42 £42 £42 £42 2 Plymouth - West 6 units £187 £187 £187 £187 £187 3 Plymouth - West 10 units £185 £185 £185 £185 £185 4 Plymouth - West 11 units £64 £24 -£23 -£78 -£141 5 Plymouth - West 25 units £234 £206 £174 £138 £95 6 Plymouth - West 50 units £220 £192 £159 £121 £77 7 Plymouth - West 100 units £251 £224 £194 £159 £118 8 Plymouth - West 400 units £189 £159 £124 £84 £38 9 1 unit Plymouth - East £94 £94 £94 £94 £94 10 Plymouth - East 6 units £238 £238 £238 £238 £238 11 Plymouth - East 10 units £233 £233 £233 £233 £233 12 Plymouth - East 11 units £110 £69 £21 -£34 -£100 13 Plymouth - East 25 units £276 £247 £213 £175 £129 14 Plymouth - East 50 units £263 £232 £198 £158 £111 15 Plymouth - East 100 units £292 £264 £232 £195 £151 16 Plymouth - East 400 units £228 £196 £160 £118 £69

Sensitivity testing - Impact of Starter Homes

6.3.9 The second sensitivity testing models the inclusion of Starter Homes. Before testing the impact of the Starter Homes initiative it is worth clarifying some of the assumptions used to test these units. Starter Homes have been defined in guidance40 as homes set at discount of 80% of the open market value. This has been included in the testing. PBA have also ensured that these units are capped at a price of £250,000 as is also stated in the guidance41. It is also assumed that Starter Homes apply to developments of 11 units or more.

6.3.10 It is not yet known if Starter Homes would be exempt from S106 obligations. For the purposes of this testing, PBA have included s106 (of £2,000 per unit) to remain consistent with the analysis in the previous section. It is also understood that the Government has established a design advisory panel to provide guidance regarding appropriate sizes for Starter Homes. The results of this have not been provided, and to maintain consistency with the previous section the same sizes for open market and affordable housing units has been tested.

6.3.11 Finally, it is currently unclear as to how the development industry will consider its profit on Starter Homes. Affordable units often carry a much lower expectation of profit than open market units, due in part to the lower risks involved in disposing of these units. It is unclear as

40 Housing and Planning Act 2016 (Para 2 (1)) 41 Ibid (Para 2 (1))

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to whether there will be similar expectations for Starter Homes. For this testing PBA have adopted an expectation of 10%.

6.3.12 In terms of testing the impact of including Starter Homes, PBA have been asked to test the following scenarios:

. 30% Affordable housing provision: - 20% Starter Homes & 10% Affordable Homes (split 50% Shared Ownership and 50% Affordable Rent) . 35% Affordable housing provision: - 20% Starter Homes & 15% Affordable Homes (split 50% Shared Ownership and 50% Affordable Rent) . 40% Affordable housing provision: - 20% Starter Homes & 20% Affordable Homes (split 50% Shared Ownership and 50% Affordable Rent) 6.3.13 The results are shown in Tables 6.6. The conclusion of this testing indicates that the CIL rates set out in the previous section would remain applicable if Starter Homes were introduced in Plymouth.

Table 6.6 Sensitivity testing of the inclusion of Starter Homes – Plymouth Policy Area

CIL Liable CIL Liable CIL Liable Headroom @ Headroom @ Headroom @ ID Typology Value area 20% SH 20% SH 20% SH & 10% AH & 15% AH & 20% AH

1 1 unit Plymouth - West £42 £42 £42 2 Plymouth - West 6 units £187 £187 £187 3 Plymouth - West 10 units £185 £185 £185 4 Plymouth - West 11 units £156 £127 £93 5 Plymouth - West 25 units £347 £333 £318 6 Plymouth - West 50 units £331 £316 £299 7 Plymouth - West 100 units £365 £353 £339 8 Plymouth - West 400 units £291 £274 £254 9 1 unit Plymouth - East £94 £94 £94 10 Plymouth - East 6 units £238 £238 £238 11 Plymouth - East 10 units £233 £233 £233 12 Plymouth - East 11 units £216 £189 £157 13 Plymouth - East 25 units £405 £393 £378 14 Plymouth - East 50 units £389 £375 £359 15 Plymouth - East 100 units £422 £411 £398 16 Plymouth - East 400 units £346 £329 £310

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7 Scope for CIL from Older Persons Housing

7.1 Introduction

7.1.1 This part of this report tests a number of assumptions regarding the impact of CIL on retirement dwellings, namely Retirement homes and Extra care schemes. It is also worth noting that care homes are also tested in PBA’s appraisal, however these are discussed in the non-residential section of this report (see Chapters 8 and 9).

7.2 Defining Housing for Older People

7.2.1 In terms of viability testing we consider three types of retirement schemes as defined below:

. Retirement homes – also known as sheltered housing, these are defined as groups of dwellings, often flats and bungalows, that provide independent, self-contained homes. We consider that in addition to this, there will likely be some element of communal facilities, such as a lounge or warden. A service charge will be in place to cover the normal ongoing costs but also incur additional costs to upkeep communal facilities as described. . Extra care – also known as assisted living by the private sector. It is provided across a range of tenures (owner occupied, rented, shared ownership/equity). This is housing with care whereby people live independently in their own flats but have access to 24-hour care and support. These are defined as schemes designed for an elderly population that may require further assistance with certain aspects of their day to day life. Arrangements for care provision vary between care provided according to eligible assessed need by the local authority and people purchasing privately who may not have such a high level of need which is on site and is purchased according to need. For private sector developments the care facilities are normally part of a care package with additional fees to pay for the service and facilities, which are on top of normal service charges and the cost of purchasing the property. The schemes will often have their own staff and may provide one or more meals per day. We consider these as schemes that will likely have a greater proportion of communal space than retirement homes and a likely to be built to standards likely to suit an older population, i.e. wheelchair access, better designed bathroom facilities. . Care homes – residential or nursing homes where 24-hour personal care and/or nursing care are provided together with all meals. People occupy under a licence arrangement. As discussed these are tested with the non-residential section of the report and therefore are discussed in greater detail in Chapter 8.

7.3 Assumptions for Further Testing

7.3.1 The assumptions used for Retirement homes and Extra care are as summarised below, with all other assumptions not listed below remaining the same as the original report.

. Scheme sizes - We have tested a Retirement home scheme based on similar schemes and an Extra care scheme based on a gross area of 0.5 hectares. . The Retirement scheme is based on a total of 60 dwellings and the Extra care scheme is tested at 55 dwellings. This provides a figure of approximately 110 dwellings per hectare for Retirement homes and 100 dwellings per hectare for Extra care homes, which are in line with the Three Dragons and Retirement Housing Groups’ briefing note42 regarding appropriate densities.

42 “A briefing note on viability prepared for Retirement Housing Group by Three Dragons”, Three Dragons, May 2013.

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. Size of units - In terms of net internal area of the units, we have used sizes of 60 for Retirement homes and 71 for Extra care schemes. This is again informed by Three Dragon’s guidance regarding appropriate sizes for 1 and 2 bed properties and based on a 60:40 split between the two. . PBA have assumed that Retirement homes and Extra care schemes have an allocation of floorspace considered as non-chargeable functions and communal space. Again, PBA have followed Three Dragons guidance of 25% for Retirement properties and 35% for Extra care schemes. PBA have therefore assumed that the net floorspace per unit for Retirement properties is 80 sqm and 109 sqm for Extra care units. . Build Costs - In terms of build costs PBA have used figures supplied by BCIS. PBA have used a figure of £1,245 per sqm for retirement properties and £1,290 for extra care. . Sales value per square metre – To test the viability of retirement homes and Extra-care homes PBA have analysed schemes from various developments within or around the Plymouth Policy Area, and Thriving Towns and Villages Area which are summarised in Table 7.1. The table indicates that sales values for new properties could be considered as in the region of £2,900. Table 7.1 Sales values for new retirement properties currently on the market (as of Dec 2016)

Location Value Area No of Sales Value Size Sales Bedrooms (per Value sqm) (per sqm)

Flat 56, Station Road, Plympton Plymouth 2 £280,000 70 £4,000 Hillside Court, Plymouth Plymouth 2 £275,000 71 £3,873 , Plymouth Plymouth 2 £235,000 87 £2,701 Station Road, Plympton, Plymouth Plymouth 2 £170,000 68 £2,500 Hermitage Court, Plymouth, Plymouth 2 £169,950 60.5 £2,809 Station Road, Central Plympton Plymouth 1 £165,000 50 £3,300 Hermitage Court, Plymouth, Plymouth 2 £150,000 68.1 £2,203 Highbridge Court, 96-100 Ridgeway Plymouth 1 £150,000 60 £2,500 Ridgeway, Plympton Plymouth 2 £140,000 50 £2,800 Wesley Court, Plymouth Plymouth 1 £140,000 48 £2,917 Horn Cross Road, Plymstock Plymouth 1 £135,000 48 £2,813 Wesley Court, Plymouth Plymouth 1 £130,000 45 £2,889 Western Road, Ivybridge South Hams 2 £165,000 64.5 £2,558 Newton Hill, Newton Ferrers South Hams 1 £135,000 60 £2,250 Bishops Court, Newton Ferrers South Hams 1 £135,000 58 £2,328 The Manor House, Totnes South Hams 2 £240,000 55.4 £4,332 Source: Commercial websites such as Rightmove and Zoopla

7.3.2 To supplement this, PBA have sense checked this data against the RHG Guidance, which suggests that, as a guide, sales prices for 1 bed retirement homes should be in the region of 75% of the price of existing three bed semi-detached properties in that location, with 2 bed retirement properties equal to the full value of a three bed semi-detached house.

7.3.3 Table 7.2 shows the average sales value of a semidetached property for transactions since January 2015 in each of the 6 value areas identified in the previous chapters on residential viability. Applying the same 60:40 weighting between 1 bed and 2 bed dwellings to Three

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Dragons guidance, this suggests that retirement housing should be considered in the region of 85% of the total value. In terms of Extra care properties, PBA have again followed Three Dragons guidance and have applied a 25% uplift on Retirement homes to calculate a value for Extra care schemes. Using the floorspace assumption, Table 6.2 also sets out a sales value per square metre figure based on these calculations (which has been rounded to the nearest £50).

7.3.4 These figures, though broadly similar to the transactional results shown in Table 7.1, offer a greater indication of the difference between broad value areas. The figures for retirement homes and Extra-care set out in Table 7.2 shall be used within the appraisal.

Table 7.2 Sales values per square metre for each value area for Extra-care and Retirement homes

Value Area Average Typical value Retirement Typical value for Extracare Price of a for a £ per sqm an Extracare £ per sqm Semi- retirement unit (based on detached home (based +25% of a on 85% of a retirement semi- home) detached)

Plymouth - East £199,592 £169,653 £2,850 £212,067 £3,000 Plymouth - West £169,039 £143,683 £2,400 £179,604 £2,550

. Land Values – PBA have tested the both Retirement homes and Extra-care homes using the same for each broad value area, as set out in a previous chapter. . Brownfield – PBA have assumed that these developments are likely to occur on brownfield land, based on an understanding that there is a preference for these types of developments to be in close proximity to town or city centres and related amenities. Therefore, PBA have assumed an extra cost of £300,000 per net hectare for brownfield development, which includes payments for remediation and demolition etc. . Policy costs – Both retirement and Extra-care properties have been appraised at the same policy costs identified in a previous chapter. These include: - A contribution to s106 of £2,000 per unit - An allowance for Sustainable design as set out in Policy 25 'Reducing carbon emissions and adapting to climate change.' - Policy 15 'Meeting local housing needs’

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7.4 Viability Results and Recommendations

7.4.1 PBA have tested the retirement and extra care schemes across the broad value areas. The results of the testing are summarised in the Table 7.3, which identifies that a CIL rate would not be viable on either retirement or extra-care units across the majority of value areas. It is therefore recommended that retirement and extra-care properties are zero rated in terms of a Community Infrastructure Levy in Plymouth.

Table 7.3 Maximum headroom for older person housing

Retirement units CIL Headroom Extracare units CIL Headroom

Plymouth - East -£410 -£642 Plymouth - West -£691 -£871

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8 Scope for CIL from Non Residential uses

8.1 Introduction

8.1.1 Similar to the appraisals for residential schemes, PBA test for non-residential development hypothetical schemes that might be planned or delivered over the Joint Local Plan period. Viability testing on a typical basis has been adopted since it is not possible to consider viability on a site-specific basis at this stage because actual site-specific costs and values have yet to be established. Such detail will evolve over the plan period.43

8.1.2 Non-residential viability testing requires a series of assumptions about site typologies based on different use types, along with site coverage, rents and yields to generate an overall sales turnover and value of land, which along with viability assumptions are discussed here for non- residential testing.

8.2 Typologies Tested

8.2.1 For the purpose of testing plan policies and for a change in the rate of CIL in Plymouth, the typologies shown in Table 8.1 are to be tested. These have been agreed with the councils and through the stakeholder workshop. It is important to consider the density of development proposed. Table 8.2 sets out the assumed site net developable area for each development type with plot ratios to derive floorspace estimates.

Table 8.1 Non-residential use typologies for testing

Site Use Site (ha) GIA (sqm) NIA (sqm) coverage

1: Town centre office 0.10 150% 1,500 1,350 2: Business park 0.31 80% 2,500 2,375 3: Industrial / warehouse 0.38 40% 1,500 1,425 4: Small local convenience 0.03 90% 280 266 5: Smaller supermarket 0.17 60% 1,000 800 6: Supermarket 0.63 40% 2,500 1,875 7: Retail warehouse 0.50 40% 2,000 1,400 8: Town centre retail 0.02 100% 200 190 9: Hotel (60 beds) 0.30 50% 1,500 1,200 10: Student accommodation (200 bed) 0.20 270% 5,430 3,800 11: Care home (30 bed) 0.25 80% 2,000 1,400

43 Site-specific testing for non-residential uses would be considering detail on purely speculative / assumed scenarios, producing results that would be of little use for a study for strategic consideration.

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8.3 Non-Residential Values Assumptions

Establishing gross development value (GDV)

8.3.1 In establishing the GDV for non-residential uses for the variety of development types, this report has considered historical comparable evidence for new values on a local, regional and national scale based on the work to inform the PBA March 2016 report, updated data using CoStar44 covering the whole of the Plymouth Policy Area, and Thriving Towns and Villages Area, and further workshop with developers.

8.3.2 The accompanying evidence for rent any yield data that has helped inform the values for non- residential uses can be found in Appendix D.

Town centre offices and business parks

8.3.3 Consultation with local agents to inform the PBA March 2016 report revealed that the office market is not particularly strong at the moment. Consultees expressed a view that while there are a number vacant offices within the town centres, Plymouth in particular, the supply of good quality office stock is fairly rare. Leasing activity, throughout the three authorities, shows a sporadic picture with little activity in 2012, significant highs in 2013 and then little activity in the current market. Comparing the three authorities, Plymouth is the preferred destination for town centre development. For business park type developments, prominent locations include locations along the A38 and also Okehampton which has strong strategic links to Exeter and the M5.

8.3.4 According to data from the commercial property information service, CoStar, vacancy rates for office units in Plymouth have fallen from 10% in 2012 to approximately 6% at the time of the report. Since 2012, the average asking rent has remained at a similar amount between £108 to £118 per sqm (£10 and £11 per sqft). Analysis of the office market indicates that yields could be considered to achieve between 8% and 10%. In terms of office units, whilst transactional data is fairly patchy, there does not appear to be significant difference between South Hams and West Devon. The average rent has been around £86 sqm (£8 per sqft) with yields of 8%.

Industrial units

8.3.5 PBA have appraised industrial and warehouse space as a single use, covering use classes B1c (light industrial), B2 (general industrial) and B8 (warehousing and distribution). It is understood that demand for industrial units could increase in Plymouth and South West Devon as the region continues to capitalise on certain sectors that it has shown a recent competitive advantage, such as marine technology.

8.3.6 An audit of transactional data from CoStar and of properties currently on the market suggests that rental values could be considered between £50 and £60 per sqm. Yields, whilst varying considerably based on quality of unit, are just under 9%.

44 CoStar is an industry reliable commercial property data source that tracks space becoming available to it being let or sold covering for more than 400,000 UK commercial property buildings. CoStar gathers and updates its data on an ongoing basis with over 8,000 sources, and has developed a state of the art research centre dedicated to monitoring the market.

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Retail uses

8.3.7 Plymouth City Centre has an extensive range of retail offer. Town centre comparison units are focused around Drake Circus which include a number of large, nationally known retailers. Outside of the centre there are a number of retail parks, many of which situated on the Devon Express way such as the Errill and Coypool Retail park. South Hams and West Devon has a more limited retail offer, with town centre retail located along high streets in the main centres of Kingsbridge, Totnes and Okehampton.

8.3.8 The general view from consultation was that rental values for town centre retail units in Plymouth, have fallen since 2011, from around £180 per sqm to £150 per sqm. Over the same period yields have varied, but could be considered as around 8.5%. Retail rates in South Hams appear very similar to that of Plymouth, and are currently considered as £155 per sqm with yields around 8%. Transactional data for West Devon indicates retail rates of around £160 per square foot with yields between 7%-8%.

8.3.9 PBA have surveyed a number of retail parks in the area including Coypool, Crownhill and the Friary retail park. From a sample of recent transactions, it was seen that rental values ranged between £105 to £210 per sqm and yields also around 8%.

8.3.10 Convenience retail operates in a slightly different market to comparison retailing. While both have been influenced by the increasing popularity of online shopping, the convenience sector continues to undergo significant structural change brought through by an increasingly competitive market and a fundamental change in the way customers shop. This has had key implications in the type of units that are being developed, as seen by the increasing prominence of budget retailers (such as Aldi and Lidl) and smaller format stores.

8.3.11 For smaller convenience stores PBA were instructed of two deals, for a Sainsbury’s and a Tesco in the local area, which both achieved a rental value of approximately £130 and yields of 5.75% and 5.5%. For larger scale supermarkets, PBA understand that a 2,320 sqm Tesco, that was built relatively recently, was transacted with a rental rate of £194 per sqm and a yield of 5%.

Hotels, student accommodation and care homes

8.3.12 Transactional data and responses from consultees in regards to hotel, student accommodation and care home development are relatively less abundant. Where possible, PBA endeavour to use local data however where this is not possible, transactional data and research from a wider location is sought.

8.3.13 For Hotel development, PBA understand that a 63 bed Premier Inn in Plymouth, was leased for £122 per sqm, or £6,800 per room and achieved a yield of 4.46%, however from consultation it is understood that this yield is considered fairly low.

8.3.14 For Student accommodation, research conducted by Knight Frank45 noted that 2015 was a “record year” for the student accommodation investment market. Knight Frank provides evidence to demonstrate that yields for regional student accommodation has fallen from 6.5% on 2009 to between 5.5% and 6% in December 2015. Similarly, the most recent Student Accommodation report by Savills46 confirms these figures indicating yields between 5.5% and 6% in prime regional locations, such as Plymouth.

8.3.15 Based on research in the Plymouth market, shown in Appendix D, the average weekly rent is £138 per week for student accommodation, and with an assumption that rent is paid for 45

45 Knight Frank research (2015), Student Market review 46 Savills World Research (2016), Spotlight UK Student Housing 2016

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weeks (as student accommodation is rarely occupied for the full year) and allowing for management costs (assumed at 35%), this equates to a figure in the region of £4,030 per bed.

8.3.16 Finally, for Care homes, research also by Knight Frank47 indicated that care homes in the South West area achieved values of around £11,000 per bed space. In a similar research document, also by Knight Frank48, it was suggested that prime Care homes traded at yields of between 5% and 6% yield, with secondary quality assets trading at 7.5% to 8%.

Summary of rents and yields used for high level testing

8.3.17 Finally, the following Table 8.2 illustrates the values established for a variety of non-residential uses, expressed in square metres of net rentable floorspace.

Table 8.2 Tested non-residential rents and yields

Use Rents (per sqm) Yield

1: City/town centre office £160 8.0%

2: Business park £150 8.0%

3: Industrial / warehouse £70 9.0%

4: Small local convenience £150 6.0%

5: Smaller supermarket £175 5.5%

6: Supermarket £190 5.5%

7: Retail warehouse £180 8.0%

8: City centre retail £160 8.5%

9: Hotel (60 beds) £180 6.5%

10: Student accommodation (200 unit) £4,030 per bed 5.75%

11: Care home (60 bed) £11,000 per bed 8.0% Source: PBA research

8.4 Non-Residential Cost Assumptions

Build costs

8.4.1 Build cost inputs have been established from the RICS Build Cost Information Service (BCIS) at values set at the time of this study (current build cost values). The build costs adopted are based on the BCIS median values, rebased to an average across Plymouth, South Hams and West Devon prices at 2015 Q3 rate at the following values shown in Table 8.3.

47 Knight Frank research (2015), 2015 Care Homes Trading Performance Review 48 Knight Frank research (2015), Healthcare Capital Markets 2015

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Table 8.3 Tested non-residential build costs at Q3 2015

Use Cost per sqm

1: City/town centre office £1,307

2: Business park £1,247

3: Industrial / warehouse £701

4: Small local convenience £1,116

5: Smaller supermarket £1,269

6: Supermarket £1,422

7: Retail warehouse £645

8: City/town centre retail £1,082

9: Hotel (60 beds) £1,535

10: Student accommodation (200 unit) £1,471

11: Care home (60 bed) £1,301 Source: BCIS

Other development assumptions

8.4.2 Table 8.4 sets out the other development assumptions that we have used in the assessment. The majority of the assumptions remain identical to those used in the PBA March 2016 report. Developer contributions also have an impact on the viability of a project, but rather than including a specific figure within the appraisal, PBA consider whether the buffer at the final stage of the appraisal is appropriate.

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Table 8.4 Other assumptions used

Cost Description % used in appraisal

Externals These covers external build costs for site preparation and includes items such as internal access roads, car parking, 15% of build costs landscaping, drainage, utilities and services within the site. Professional fees Professional fees are based upon accepted industry 10% of build costs. standards. Contingency Contingency is based upon the risk associated with each site. 4% of construction cost. Sale costs This is an allowance for legal, surveyor and marketing fees 3% of gross development and based on industry accepted scales. value Finance costs Based upon the likely cost of development finance we have 7% of negative cashflow used current market rates of interest. Profit Gross development profit (including central overheads). 20% of total development costs Professional fees on This input represents the fees associated with the lands 1% for surveyors and 0.75% land purchase purchase and are based upon the following industry for legal costs of the residual standards. land value Stamp duty A Stamp Duty Land Tax is payable by a developer when Standard variable rates set out acquiring development land. by HMRC depending on size of the residual land value

8.5 Benchmark Land Values for Non-residential Uses

8.5.1 After systematically removing the various costs and variables detailed above, the result is the residual land value (RLV). To ascertain the likelihood of delivery and the risk associated with development viability, the resulting RLVs are measured against a benchmark land value that a landowner would reasonably be expected to sell/release their land for development. This is normally based on an existing use value (EUV) of the land plus an uplift.

8.5.2 Setting a benchmark at which a landowner is prepared to sell to enable a consideration of viability can be a complex process. There are a wide range of site specific variables which affect land sales (e.g. position of the landowner – are they requiring a quick sale or is it a long term land investment?). However, for a strategic study, where the land values on future individual sites are unknown, a pragmatic approach is required.

8.5.3 PBA have consulted a number of sources in order to determine what could be a suitable value in which a landowner could reasonably be willing to sell the land for. For instance, PBA have reviewed websites such as CoStar, confidential appraisals held by the local councils and websites of local land agents to gain an approximate sales value. The benchmark values are given in Table 8.5.

Table 8.5 Non-residential uses – land values

Type of Land Date sold Location Value

Commercial land 2015 Plymouth £995,661

Commercial land 2015 Plymouth £844,967

Industrial land On sale now Plymouth £427,327*

Residential land On sale now West Devon £1,647,955*

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Type of Land Date sold Location Value

Commercial land 2012 Plymouth £947,224

Commercial land 2009 South Hams £825,592

Commercial land 2015 South Hams £469,306

Commercial land 2012 Plymouth £353,056

Commercial land 2014 Plymouth £221,737

*denotes asking price

8.5.4 PBA have consulted a number of sources in order to determine what could be a suitable value in which a landowner could reasonably be willing to sell the land for. For instance, PBA have reviewed websites such as CoStar, confidential appraisals held by the local councils and websites of local land agents to gain an approximate sales value. The benchmark values are given in Table 8.6.

8.6 Viability Results by Non-residential Use

8.6.1 This section sets out the assessment of non-residential development viability and also summarises the effect on viability of changes in values and costs, and how this might have an impact on the level of developer contribution. The results tables in this chapter summarise the detailed assessments, and represent the residual value per square metres after values and costs, including land have been calculated. An example appraisal is included in Appendix A.

8.6.2 It is important to note that the analysis considers development that might be built for subsequent sale or rent to a commercial tenant. However, there will also be development that is undertaken for specific commercial operators either as owners or pre-lets.

B-class uses

8.6.3 Consistent with findings from analysis of other locations in England and Wales outside of major cities, commercial B-class development remains relatively unviable. The typologies associated with B-class uses: town centre offices, business parks, industrial units and warehouses, have low rental values, and as such were unable to generate sufficient value in any locations in Plymouth to justify introducing a CIL charge.

Table 8.6 Non-residential viability headroom – B-class uses

1: Town 2: Business 3: Industrial / Centre Office Park Warehouse

B class uses -£319 -£350 -£439

Retail

8.6.4 In terms of retail typologies there is a clear difference in viability between retail uses compared to other uses such as office units. The testing shows that there is sufficient viability to levy a CIL rate in Plymouth on all uses with the exception of city/town centre retail units where high land values and build costs associated with the town centre location significantly restrict viability. Retail warehouses, in particular, show significant scope for affording a CIL charge.

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Table 8.7 Non-residential viability headroom – Retail uses

4: Small local 5: Smaller 6: Supermarket 7: Retail 8: Town convenience supermarket warehouse centre retail Retail uses £277 £496 £321 £561 -£86

Hotel development

8.6.5 PBA’s testing identifies that the hotel market within Plymouth does not realise sufficient residual value to warrant a positive levy charge.

Table 8.8 Non-residential viability headroom – Hotel

9: Hotel Hotel -£28

Student accommodation

8.6.6 The testing of student accommodation identifies that there is a small scope to charge a levy. The evidence suggests that Plymouth could continue to pursue the CIL charge currently adopted. PBA would recommend a CIL rate of up to £70 per sqm could be seen as appropriate.

Table 8.9 Non-residential viability headroom – Student Accommodation

10: Student

accommodation Student £125 accommodation

Care homes

8.6.7 Finally, the viability assessment indicates that care homes continue to struggle within the three authorities in viability terms. These developments often have considerably high build costs, and coupled with relatively low development values, fail to generate a headroom in which to charge a levy.

Table 8.10 Non-residential viability headroom – Care homes

11: Care homes Care homes -£150

8.7 Recommendations for CIL

8.7.1 Figure 8.1 summarises the headroom for each typology for Plymouth that was shown in the previous analysis.

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Figure 8.1 Non-residential headroom for each use in Plymouth

8.7.2 The previous section illustrates the maximum headroom available to charge CIL from each scheme. As discussed there is scope to charge CIL for the four retail typologies (Smaller Supermarkets, Supermarkets, Retail Warehouses and Small local convenience stores).

8.7.3 Plymouth City Council currently has a CIL charge for certain non-residential uses. According to the adopted charging schedule retail development that is above 1,000 square metres is expected to contribute £100 per square metre and Purpose built student accommodation is expected to provide £60 per square metre.

8.7.4 From this testing, it is suggested that there is scope for the retail CIL rate to be increased from £100 per square metre to up to £200 per square metre. This rate could be deemed as appropriate for all areas within Plymouth. The existing CIL charge for retail development is for development over 1,000 square metres. PBA’s testing indicates that this requirement could be relaxed, and could apply regardless of size. However, the testing indicates that town centre retail development is still unable to generate scope for a charge. PBA would therefore recommend that the levy applies to retail development outside of the defined town boundaries (as it is considered more probable that supermarkets, retail warehouses etc.) would be located outside of these locations).

8.7.5 The testing indicates that the existing CIL charge for student accommodation in Plymouth remains applicable and could be increased to £80 across all areas of Plymouth. In summary, PBA suggest the following as set out in Table 8.11.

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Table 8.11 Summary of Non-residential CIL recommendations in the Plymouth Policy Area

Land use CIL rate (per sqm)

Retail floorspace outside of defined town centres Up to £200 Retail floorspace inside defined town centres Zero rated Student Accommodation in the Plymouth Policy Area Up to £80 All other forms of non-residential floorspace Zero rated

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9 Conclusions

9.1 Testing of Local Plan Viability

9.1.1 The final stage of this viability assessment is to draw broad conclusions on whether the Joint Local Plan (JLP) is deliverable in terms of viability. A key finding of this report is that viability varies across the JLP area. The testing shows that, overall, the plan policies set out in the emerging Joint Local Plan policies are viable across the majority of typologies. Where the assessment has identified that viability is comparatively weaker, for instance on small sites in the north of West Devon, there may be a need for compromise on certain policy requirements (for instance the mix of units, policy contribution, etc) to ensure delivery.

9.1.2 However, the overall assessment of the policy requirements within the Plymouth Policy Area and Thriving Towns and Villages Area considers that the emerging JLP policies would not adversely affect the delivery of residential and non-residential development in most parts of the Plymouth Policy Area and Thriving Towns and Villages Area.

9.2 Recommendation for CIL Charging

9.2.1 Secondly, the assessment is able to draw conclusions for the level of Community infrastructure levy (CIL) able to be sought in Plymouth.

9.2.2 It should be noted however that the suggested CIL rates for Plymouth are based on the current CIL arrangements in place at the time of this report. As stated at Chapter 2 of this report, the Government has indicated in the Housing White Paper 2017 that it will be examining the options for reforming the system of developer contributions and will respond to the independent review of CIL and make an announcement concerning any changes at the Autumn Budget Statement 2017. Ultimately, decisions regarding CIL are at the discretion of the local authority who may, or may not, choose to await further instruction by the Government before making any change to the current CIL arrangements that are in place.

9.2.3 However, based on analysis of headroom for setting CIL rates within the generic typologies of developments within Plymouth, it is considered that the following rates set out in the Table 9.1 would be achievable.

Table 9.1 Recommended maximum CIL charges in the Plymouth Policy Area

Use Recommended CIL rate (per sqm) Residential uses in Plymouth - East £90 Residential uses in Plymouth - West £120 Floorspace for retirement or extracare properties £0

Retail floorspace in the outside of defined town centres £200 Retail floorspace inside defined town centres £0 Student Accommodation £80 All other forms of non-residential floorspace £0

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Appendix A Example Appraisals

Residential

1 unit City Of Plymouth - West 1 Units

ITEM Residual Value Technical Checks: Net area (ha) 0.02 Brownfield CITY OF PLYMOUTH - WEST £468,451 per net ha Sqm/ha 3,543 Stamp Duty Commercial land Dwgs/ha 40 Units/pa 1 Private Affordable Starter Homes Social rent Affordable rentIntermediate GDV=Total costs - Nr of units 1.00 0.00 0.00 0.00 0.00 0.00

1.0 Development Value

1.1 Private units No. of units Size sq.m Total sq.m £psm Total Value 1.1.1 Flats (NIA) 0.00 55 0 £2,500 £0 1.1.2 2 bed house 0.50 75 37 £2,350 £87,538 1.1.3 3 bed house 0.30 93 28 £2,350 £65,565 1.1.4 4+ bed house 0.20 117 23 £2,350 £55,042 1.0 89

1.5 Starter Homes No. of units Size sq.m Total sq.m £psm Total Value 1.5.1 Flats (NIA) 0.00 55 0 £2,000 £0 1.5.2 2 bed house 0.00 75 0 £1,880 £0 1.5.3 3 bed house 0.00 93 0 £1,880 £0 1.5.4 4+ bed house 0.00 117 0 £1,880 £0

1.2 Social rent No. of units Size sq.m Total sq.m £psm Total Value 1.2.1 Flats (NIA) 0.00 55 0 £1,049 £0 1.2.2 2 bed house 0.00 75 0 £849 £0 1.2.3 3 bed house 0.00 93 0 £849 £0 1.2.4 4+ bed house 0.00 117 0 £849 £0 - -

1.3 Affordable rent No. of units Size sq.m Total sq.m £psm Total Value 1.3.1 Flats (NIA) 0.00 55 0 £1,105 £0 1.3.2 2 bed house 0.00 75 0 £1,105 £0 1.3.3 3 bed house 0.00 93 0 £1,105 £0 1.3.4 4+ bed house 0.00 117 0 £1,105 £0 - -

1.4 Intermediate No. of units Size sq.m Total sq.m £psm Total Value 1.4.1 Flats (NIA) 0.00 55 0 £1,625 £0 1.4.2 2 bed house 0.00 75 0 £1,528 £0 1.4.3 3 bed house 0.00 93 0 £1,528 £0 1.4.4 4+ bed house 0.00 117 0 £1,528 £0 - - - -

Gross Development value £208,145

2.0 Developer's Profit

2.1 Private units 20.0% on OM GDV £41,629

2.1 Starter Home 10.0% on Starter Home value £0

2.2 Affordable units 6% on AH transfer values £0.00

Total Developer's Profit £41,629

3.0 Development Costs 3.1 Sale cost

3.1.1 Private units only 3.00% on OM GDV £6,244

£6,244 3.2 Build Costs

3.2.1 Private units No. of units Size sq.m Total sq.m Cost per sq.m Total Costs 3.2.1.1 Flats (GIA) 0.00 63 0 £1,131 £0 3.2.1.2 2 bed house 0.50 75 37 £1,181 £44,009 3.2.1.3 3 bed house 0.30 93 28 £1,181 £32,962 3.2.1.4 4+ bed house 0.20 117 23 £1,181 £27,672 1 89

3.2.2 Affordable units No. of units Size sq.m Total sq.m Cost per sq.m Total Costs 3.2.2.1 Flats (GIA) 0.00 63 0 £1,131 £0 3.2.2.2 2 bed house 0.00 75 0 £1,181 £0 3.2.2.3 3 bed house 0.00 93 0 £1,181 £0 3.2.2.4 4+ bed house 0.00 117 0 £1,181 £0 - - 3.2.3 Extra-over BR2013 £0 per unit £0

Total build costs 1 £104,643 3.3 Extra over construction costs

3.3.1 Externals 10% extra-over on build cost £10,464

3.3.2 Site abnormals (remediation/demolition) £300,000 per net ha £7,500

3.3.3 Site opening up costs £0 per unit £0

Total extra over construction costs £17,964 3.4 Professional Fees

3.4.1 on build costs (incl: externals) 8% £9,209

Total professional fees £9,209 3.5 Contingency

3.5.1 on build costs (incl: externals) 4% £4,604

Total contingency £4,604 3.6 Developer contributions

3.6.1 Policy 15: Cat 3 houses £22,694 per unit £0

3.6.2 Policy 15: Cat 3 flats £7,906 per unit £0

3.6.3 CIL £37 per sqm £3,277

3.6.4 S106/S278/AH contribution £2,000 per unit £2,000

3.6.5 Sustainable design 2.50% build cost £2,616

Total developer contributions £7,893

TOTAL DEVELOPMENT COSTS £150,558

4.0 Site Acquisition

4.1 Net site value (residual land value) £11,711

£0 4.2 Stamp Duty £0

4.3 Purchaser costs 1.75% on land costs £205

Total site costs £11,916

TOTAL PROJECT COSTS [EXCLUDING INTEREST] £204,103

TOTAL INCOME - TOTAL COSTS [EXCLUDING INTEREST] £4,042

5.0 Finance Costs APR PCM 5.1 Finance 6.00% on net costs 0.487% -£4,042

TOTAL PROJECT COSTS [INCLUDING INTEREST] £208,145

This appraisal has been prepared by Peter Brett Associates for the Council. The appraisal has been prepared in line with the RICS valuation guidance. The purpose of the appraisal is to inform the Council about the impact of planning policy has on viability at a strategic level. This appraisal is not a formal 'Red Book' (RICS Valuation – Professional Standards January 2014) valuation and should not be relied upon as such.

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Non-residential

1: Town centre office

ITEM Residual value Net Site Area 0.10 -£3,780,076.68 per ha

1.0 Development Value

No. of units Size sq.m Rent Yield Value per unit Capital Value 1.1 1: Town centre office 1 1350 160 8.00% £2,700,000 £2,700,000.00

Rent free period Adjusted for rent free No. of months 0 £2,700,000

Total development value £2,700,000 2.0 Development Cost

2.1 Site Acquisition

2.1.1 Site value (residual land value) -£378,008

Purchaser costs £0

-£378,007.67 2.2 Build Costs

No. of units Size sq.m Cost per sq.m Total Costs 2.2.1 1: Town centre office 1 1,500 £1,307 £1,960,500

£1,960,500

2.3 Externals

2.3.1 external works as a percentage of build costs 15.0% £294,075

£294,075 2.4 Professional Fees

2.4.1 as percentage of build costs & externals 10% £225,458

£225,458

2.5 Total construction costs £2,480,033

3.0 Contingency

3.1.1 as a percentage of total construction costs 4% £99,201.30

£99,201 3.1 CIL

3.1.1 £0 £0.00

£0

TOTAL DEVELOPMENT COSTS (including land payment) £2,201,226 4.0 Developers' Profit Rate 4.1 as percentage of total development costs 20% £440,245.23

£440,245

TOTAL PROJECT COSTS [EXCLUDING INTEREST] £2,641,471

TOTAL INCOME - TOTAL COSTS [EXCLUDING INTEREST] £58,529

5.00 Finance Costs APR PCM 7.00% 0.565% -£58,529

TOTAL PROJECT COSTS [INCLUDING INTEREST] £2,700,000

This appraisal has been prepared by Peter Brett Associates on behalf of the Council. The appraisal has been prepared in line with the RICS valuation guidance. The purpose of the appraisal is to inform Council as to the impact of planning policy has on viability at a strategic borough level. This appraisal is not a formal 'Red Book' (RICS Valuation – Professional Standards January 2014) valuation and should not be relied upon as such.

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Appendix B Developer Workshop Meeting Notes

Circulated Minutes from the June 2015 Workshop

Meeting Title: Plymouth City Council – Development industry viability workshop Attendees: Graham Divine – RIBA; Craig Francis – Spectrum Housing Group; Mark Copleston – Atwell Martin; Duncan Tilney – Bond Dickinson; Andrew Herridge – Herridge Property Consulting; Gareth Pinwell – Ashfords; William Lean – William Lean Commercial Property and Development; Peter Welsh – Currie and Brown; Liz Dunster – PCC; Ian Potts – Architects Design Group; Alex Hugo – Barratt Homes; Peter Coates – CPRE; Craig Robinson – Rent Plus; Nick Carter – PCC; Grant Jackson – PCC; Lionel Shelley – PCC; Simon Pickstone (SP) – PCC; Chris Rorstad – Redrow Homes; Mark Felgate (MF) - PBA; Russell Porter (RP) - PBA

Date of Meeting: 1st June 2015

PLEASE NOTE THAT THESE MINUTES SHOULD BE READ IN CONJUNCTION WITH THE SLIDES PRESENTED AT THE WORKSHOP

Subject Actions

1. Introduction

SP introduced the workshop and explained how it fitted with the preparation of the Plymouth Plan 2. Purpose of the Workshop

MF explained that the role of the workshop was to find out about local experience of CIL and the approach to testing viability in Plymouth. MF explained that PBA is looking at viability in terms of the SHELAA sites, a whole plan viability test and any revisions to CIL. 3. Experience of CIL ALL - If anyone would like to comment in MF asked the workshop attendees about their experience of CIL being in more detail regarding place for exactly two years within Plymouth. how CIL works for Plymouth, the City Feedback was generally positive about CIL within Plymouth. Council is welcoming of any feedback to help improve the process.

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Process – for those who had experienced it, the process is considered clear and better than other authorities just starting to operate CIL. CIL has PCC have helped with timing and reduced duration of S106 negotiations. subsequently noted that there is a Impact – The adopted rates did not represent a major step change in mandatory annual overall developer contributions, therefore in Plymouth they have not had a requirement on them major impact on the decision making on whether to bring forward a site – to report CIL spend but it was noted that in other areas where CIL represented a big change, over the year which the impact has been greater. they are doing. The latest monitoring can Plymouth have been consistent with the overall requests for S106 and be accessed here… CIL, both pre and post CIL, helping inform the appropriate price level for http://www.plymouth.g land. However it was noted that S106 requirements have started to creep ov.uk/homepage/envir up over past couple of years, plus the element of unpredictability onmentandplanning/pl associated with S106 negotiations remains. anning/makingaplanni ngapp/planningobspro Use in land deals – as CIL rates are known they are being factored into gressreports.htm land deals and having certainty is helpful. CIL spending – feedback suggested

Future changes - it was generally considered that the current rates were reasonable. But if larger strategic sites are proposed then a different approach to allow developer control over key infrastructure needed to help sell a development. In particular a lower or zero CIL rate with an expectation of greater S106 may work better because it was felt that CIL would provide less certainty of delivery.

4. Sites to be tested ALL – if you have any further suggestions MF explained that, whilst the first stage of work will test the SHELAA sites, regarding the and that strategic sites and policies would be discussed and tested with typologies to be used the Council, there is a need for further discussion and agreement by in testing viability, stakeholders at this workshop regarding the appropriate development please let us know. If typologies for testing the impact of CIL. not then we will assume the list Residential – MF explained that the typologies shown in a slide (copied suggested here is below) were those used for the last CIL study. appropriate.

Typology of sites - residential

• CIL evidence previously tested • 1 unit • 5 units • 14 units • 15 units • 50 units • 200 units • 4 Townhouse units on the waterfront • 50 unit flatted scheme on the waterfront

• At different ‘value areas’

Peter Brett Associates LLP

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There was general agreement that these broadly reflected development types but that perhaps a typology between 50 and 200 (possibly a 75 and 100) should be incorporated.

It was also noted that various thresholds should be sensitivity tested and therefore development sizes either side of thresholds should be considered. In particular the government s106 (incl: affordable housing) threshold of 11 units and the Council’s proposed policy threshold for wheelchair accessible homes on schemes with 25+ units.

It was agreed that ‘Older Person’ housing accommodation should be tested separately – i.e. extra care, retirement/sheltered and care homes, although the latter would be more appropriately tested as a non-residential use.

It was generally agreed that there was a ‘hot spot’ value area for residential development along the coastal front, and therefore a specific look at the waterfront should be undertaken.

Non-residential – as with residential, MF explained that the typologies shown in the slides (copied below) were drawn from the previous CIL work.

Typology of sites – non residential

• CIL evidence previously tested • Student accommodation • Care homes • Hotels • Cinemas • All retail <1,000 sqm • (66 sqm, 279 sqm, 5019 sqm district & 446 sqm city centre) • Food stores >1000 sqm • (8364 sqm, 2323 sqm, 1000 sqm, 5019 sqm) • Office – in and out of centre • Industrial

Peter Brett Associates LLP

There was disagreement about the suggested typologies although it was considered unnecessary to test for cinema developments since these are unlikely to come forward in the future.

It was also suggested that the retail testing should separately look at A3 land use type developments, while the other retail tests could be condensed to focus on what was more likely to come forward – i.e. small local convenience stores around the Sunday trading threshold, small supermarkets of the size of lidl/aldi and medium to large supermarkets because of known interest for these types of stores plus the local plan has previously supported these in specified locations.

Hotels should be continued to be tested but may split to allow for differences between business budget and higher end units.

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5. Approach

RP explained the approach to viability testing using the slide copied below.

No comments were made, so it assumed that the approach is acceptable.

Typology of sites – non residential

• CIL evidence previously tested • Student accommodation • Care homes • Hotels • Cinemas • All retail <1,000 sqm • (66 sqm, 279 sqm, 5019 sqm district & 446 sqm city centre) • Food stores >1000 sqm • (8364 sqm, 2323 sqm, 1000 sqm, 5019 sqm) • Office – in and out of centre • Industrial

Peter Brett Associates LLP

6. Residential sales value ALL – please provide any comments on the RP set out the recent average sale prices of residential properties across values and whether Plymouth by Lower Super Output Areas (statistical neighbourhood areas you think they are which typically include between 400 to 1,200 households). (Slide copied broadly correct. We below) will assume they are unless told otherwise – please provide Residential – average sales values (houses) evidence if you want them altered.

Peter Brett Associates LLP

RP reported that the broad pattern of sales values was similar to previous SHLAA viability testing work. The lowest value bands tended to

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be clustered in the West and highest in the East, but with a higher band in the middle.

RP explained that the 2013 SHLAA sites are also included on the maps scaled to their size, to show how potential future development patterns tie in with value areas. This shows that most of the future supply is in the medium to higher value areas.

RP then set out the values on a per sqm/sqft basis for houses and flats, along with a separate slide showing each neighbourhood allocated a different value area. (Both slides copied below)

Residential – tested sales values

• Mix of values across Plymouth • Possible to band into five value zones:

House (per Flat (per House (per Flat (per Value area sqm) sqm) sqft) sqft) Value 1 £2,850 £3,150 £265 £293 Value 2 £2,500 £2,800 £232 £260 Value 3 £2,250 £2,250 £209 £209 Value 4 £2,050 £2,050 £190 £190 Value 5 £1,850 £1,800 £172 £167

Peter Brett Associates LLP

Residential - value areas

Neighbourhood area Value area Neighbourhood area Value area 31. Glenholt Value 1 03. Devonport Value 4 40. Elburton & Dunstone Value 1 04. Stoke Value 4 01. City Centre Value 2 11. Ham Value 4 23. Peverell Value 2 12. North Prospect Value 4 24. Hartley & Mannamead Value 2 15. Honicknowle Value 4 27. Derriford Value 2 16. Efford Value 4 29. Southway Value 2 32. Estover Value 2 17. Lipson & Laira Value 4 34. Eggbuckland Value 2 18. Mount Gould Value 4 35. Woodford Value 2 21. Beacon Park & Pennycross Value 4 36. Colebrook & Newnham Value 2 25. Higher Compton Value 4 39. Plympton St Maurice Value 2 26. Manadon Value 4 41. Plymstock Value 2 05. Morice Town Value 5 43. Turnchapel, Hooe & Oreston Value 2 06. Ford Value 5 02. Stonehouse Value 3 07. Keyham Value 5 20. Mutley & Greenbank Value 3 08. Barne Barton Value 5 22. Leignham and Mainstone Value 3 09. St.Budeaux Value 5 28. Tamerton Foliot Value 3 10. Kings Tamerton & Weston Mill Value 5 30. Widewell Value 3 13. Ernesettle Value 5 33. Crownhill Value 3 14. Whitleigh Value 5 37. Chaddlewood Value 3 19. East End Value 5 38. Yealmpstone Value 3 42. Goosewell Value 3

Peter Brett Associates LLP

Workshop attendees did not disagree with the values presented at the workshop.

7. Residential land values RP - to review land values with planning

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RP set out the previous land values assumptions used to inform the and preparation costs SHLAA viability work, in the slide copied below. added in.

ALL – any further Residential – land values information on land values will be helpful.

• Previous work used pre site preparation and pre planning estimated benchmark values:

Value zone Per net ha Waterfront hotspots £1,000,000 High value areas £900,000 Mid value areas £500,000 Low value areas £350,000

• Are these reasonable? City variance? • Does this reflect the previously constrained land market?

Peter Brett Associates LLP

There was discussion about what the values were reflecting in terms of the sites planning and preparation stage. RP explained that the values were for purchasing sites pre planning and pre site preparation for an alternative residential use. Developers in the room stated that they normally think of land value with planning (i.e. sales contracts will be subject to obtaining planning therefore the price offered will be for land with consent) and so found it difficult to reconcile the values shown with their land purchases.

In broad terms, comments were made by participants that values have risen since the previous viability testing was undertaken in 2013, but that they have dropped down again. Generally it was felt that the figures may need to be slightly higher.

It was suggested that Land Registry data could be used but RP explained that whilst this can sometimes indicate a price it is difficult to understand the basis of the deal and what has or has not been included in the reported sums.

8. Residential unit mix and type ALL – if you have any further comments on RP set out the proportion of flats and housing that was to be applied to unit sizes please let us sites, based on the number of units envisaged. (Slide copied below) know, with supporting evidence if they should be altered.

RP to reconsider market housing sizes.

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Residential - floorspace areas

• Type of units is important because this informs overall revenue • We use a formula for identifying unit types based on the following broad site area ratios

Units per ha Apartments Houses < 35 0% 100.0% < 70 10% 90.0% < 100 40% 60.0% < 150 70% 30.0% >= 150 100% 0%

Peter Brett Associates LLP

No comments were given about this.

RP also set out the sizes of market units that were proposed to be tested, along with the sizes for affordable houses based on the mid-point Plymouth Planning Obligation SPD standards. (Slide copied below)

Residential - floorspace areas

• Floorspace size is important because this informs overall revenue • For private houses we use the average size standards • For AH, we use the average sizes based on the PO SPD Review 2

Private Affordable Unit type units (sqm) units (sqm) Flats (NIA) 55 52 Flats (GIA) 63 60 2 bed house 74 74 3 bed house 86 84 4+ bed house 115 115

Peter Brett Associates LLP

General the feedback was that not all housebuilders build at specific sizes, so the figures shown as an average across all developers were considered reasonable.

IT was also commented that, with the exception of high-end market houses, typical market units would normally be built smaller than the reported.

It was indicated that normally a developer would achieve anywhere between 4,000 to 16,000 sqm per net developable hectare of land in Plymouth.

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Another developer suggested that the average 3 bed house was just over 1,000 sqft (i.e. 93 sqm), while their best-selling new houses were 840 sqft (72 sqm) 3 bed houses.

It was suggested that the market for town houses was not very strong because the value was disproportionate to the build cost and size of these units, except in the city centre where space is very restricted.

It was reported by one Registered Provider that the highest demand (need) for affordable housing was for one and two bed units.

9. Residential build out rates

RP explained that the model uses a formula to calculate build out rates based on experience of schemes elsewhere. Using the model formula, RP presented some examples of different scheme sizes and their assumed build out rates in the slide copied below.

Residential – build out rates

• The testing uses a cash-flow • We assume sales lapse build timescales by 6 months • We use a formula for building timescales based on the following rates

Nr units Nr build years Units p.a. 1 1.0 1 10 1.3 8 50 1.8 27 200 2.8 71 500 4.3 118 1,500 7.2 209

Peter Brett Associates LLP

Feedback suggested that anything up to 200 units would be delivered by a single developer with one outlet and that in Plymouth this would be at a maximum rate of 50-55 per annum. If there are two outlets within the scheme, then the sales rate per outlet reduces to about 1.75 of the sales rate on a one outlet scheme.

Also it was generally agreed that large housebuilders would only take on sites of 50 plus units, with 2 years or more of saleable space.

It was also suggested by developers in the room that they would be agreeable to consortium approaches over 200 dwellings, but the preference was to develop on their own, and for this reason it would be very rare for there to be many consortium sites in Plymouth.

10. Small residential developers PBA/PCC – to explore if there was a problem There was discussion stating that many smaller house builders have with a lack of smaller disappeared from the market in recent years, which will have affected developers operating delivery on some smaller sites. This occurred mostly because of access in Plymouth with

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to finance, but also because smaller developers were less able to regard to reviewing the negotiate S106, including the provision of affordable housing. However, it viability testing was also contradictorily commented that smaller developers are still assumptions on building inner city apartments. smaller developments.

It was also pointed out that having ‘cliff edge’ thresholds may put off PBA/PCC – to make smaller developers in particular, example of affordable housing at 30% for sure that all policy 11 units but zero for 10 or the requirement for lifetime home/more thresholds are tested accessible units for schemes over 25 were cited. and that options are considered as to best It was suggested smaller developers achieve different build costs, profit, approach to ‘cliff edge’ build out rates to the larger developers in Plymouth and therefore there policies. should be a different approach to testing smaller developments, with different assumptions used for build costs, profit, build out rates etc. 11. Residential build costs

RP set out the build costs in the slide copied below and confirmed that these were based on BCIS median averages, rebased to Plymouth and Q2 2015. and that small developments related to three units and under.

Residential – build costs

• Using BCIS data • Based on Q2 2014 data rebased to Plymouth • Assume Q2 2014 values meet 2013 building regs

Scheme type £/GIFA sqm £/GIFA sqft Estate housing £1,095 £102 (large developments) Housing £1,151 £107 (small developments) Flat £967 £90

Peter Brett Associates LLP

Feedback suggested that in the past BCIS costs have been a bit higher than the volume house builders would pay, however it was also stated that this gap has narrowed considerably over the last couple of years and therefore the general consensus was that the presented BCIS costs were about right.

12. Residential site development costs All – if you have any further comments on RP explained that an allowance is made for extra costs of development on these site brownfield land and for opening up costs to bring in services etc. on development cost greenfield sites, proportionate to the size of development. (Slide copied assumptions please below) inform the team, with evidence.

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Residential – extra over land costs

• Site abnormal costs: • Brownfield areas of sites incur additional demolition and/or remediation costs • Brownfield site: £200k gross ha (£80k/gross acre) • Mixed site: £100k gross ha (£40k/gross acre)

• Site opening up costs: • Large Greenfield sites have very high physical infrastructure set up costs, reducing achievable land values. • Small (40-200 dwellings): £5,000 per unit • Medium (200-500 dwellings): £10,000 per unit • Large (500+ dwellings): £17,000 per unit • We will seek information on opening costs for the strategic sites

Peter Brett Associates LLP

There was further discussion around ‘definitions/language’ used, for example, ‘site abnormals’ should be ‘site demolition and remediation’.

It was pointed out that there were some location-specific problems such as Arsenic, Radon and topography constraints in Plymouth which affected the greenfield sites. RP suggested that if such problems were common then these should be reflected in the purchase price paid for the affected land, which might therefore achieve a lower land value than those presented in the earlier slides. But if sites are purchased without knowledge of these risks (i.e. without undertaking detailed surveys), then it was accepted that the risks would need to be reflected when applying the extra-over land remediation costs, and this would need to be factored into the viability model.

13. Residential other development costs PBA/PCC to consider approach to profit RP presented and explained the range of other cost assumptions in the appraisal in the slide copied below.

Residential – other development costs

• Externals = 10% of build costs • Professional fees = 8% of build costs (incl; externals) • Finance = 6% of cash-flow net revenue/costs • Marketing fees = 3% of GDV • Contingency = 4% of build costs

• Developer return (incl o/hs) - 20% of development costs

Peter Brett Associates LLP

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Whilst there little comment on most of these, such as professional fees being higher for smaller developers, there was a discussion about profit. In particular it was considered by all in the room that profit should be calculated in respect of GDV and not cost because residential prices change quickly, and that this is how house building development generally operates.

It was considered by most participants that a figure of 20% of overall GDV was about right, although sometimes this would vary both above and below depending on the risk of the development coming forward and then speed of future sales. However, PCC commented that this was high compared with figures that have obtained from open book viability appraisal over the past couple of years, which have generally ranged between 15% to 23% on GDV.

14. Residential development obligations PBA/PCC to review recent applications to RP confirmed that a range of affordable housing percentages, tenures and test appropriate S106 transfer rates would be tested and that further consultation with RPs and rates. housing at PCC would take place. (Slide copied below)

Residential – policy variables

• Affordable housing • Test at different rates • Starting with policy at 30% • Test AH tenures: • 60% social/affordable rented • 40% intermediate (e.g. shared ownership product) • Transfer values: • Social rented – values based on PO SPD Review 2 • Affordable rented: 45% OMV • Intermediate (shared ownership product): 50% OMV

• Development obligations • Start with likely S106/278 contributions • Based on experience and information provided by the Council • CIL at varying amounts by iteration

Peter Brett Associates LLP

In terms of ‘other S106’, RP pointed out that the previous SHLAA viability tested this to be around £2500 per dwellings. Comments around the room were that previously this was about right but that PCC had started to ask for more on recent applications.

15. Non Residential values All – these figures were not discussed in RP set out value assumptions for testing non-residential schemes, as detail so welcome copied in the slide below. further thoughts once you have had chance to review in more detail. If you are recommending changes please provide evidence.

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Non-residential – sales values Typology Rent (sqm) Yield Rent free period (mths)

1: Town centre office £150 7.0% 3

2: Business park £160 7.0% 3

3: Industrial / warehouse £65 7.0% 3

4: Small supermarket £185 5.5% 0

5: Supermarket £210 5.0% 0

6: Retail warehouse £250 7.5% 3

7: Town centre retail £215 6.5% 3 Capital value of 8: Hotel (60 beds) £52,000 per room 6.0% 3

9: Small local convenience £140 6.0% 3 Rent of £5,000 per 10: Care home annum per room 7.0% 3 Capital value of 11: Student accommodation £48,000 per room 7.0% 3

Peter Brett Associates LLP

Feedback suggested that:

 Rental levels for town centre offices looked too high

 Yields were too low for employment and retail uses o possibly more likely to be around 9% for industrial uses.

 Retail should include A3 uses separately.

 Hotel units should be tested at 100 bed schemes

 Land values a bit light for employment uses

16. Non-residential land values

RP asked stakeholders to comment on a slide (copied below) of land values that informed the previous CIL evidence work to see if there were changes. Non-residential – land values

Land type – existing use Per net ha

1: Town centre office £175,000

2: Business park £175,000

3: Industrial / warehouse £175,000

4: Small supermarket £1,250,000

5: Supermarket £1,250,000

6: Retail warehouse £550,000

7: Town centre retail £1,250,000

8: Hotel (60 beds) £500,000

9: Small local convenience £1,250,000

10: Care home £600,000

11: Student Accommodation £600,000 Peter Brett Associates LLP

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Comments were made that the land for supermarkets may have reduced in value because of recent profit warnings and selling off sites by the major operators.

One commercial agent commented that the retail warehouse land values looked low, and so did the business park office land values which would normally come forward as serviced sites.

The value of student accommodation land also looked on the lower side.

17. Non-residential costs All – these figures were not discussed in RP presented buiuld cost assumptions were taken from BCIS rebased to detail so welcome Plymouth, and explained the range of other cost assumptions, which were further thoughts once presented in the two slides below. you have had chance to review in more detail. If you are Non-residential - build costs recommending Typology Build cost £/GIFA sqm changes please provide evidence. 1: Town centre office £1,329 2: Business park £1,150 3: Industrial / warehouse £611 4: Small supermarket £1,220 5: Supermarket £1,365 6: Retail warehouse £599 7: Town centre retail £789 8: Hotel (60 beds) £1,460 9: Small local convenience £1,075 10: Care home £1,205 11: Student Accommodation £1,378

Peter Brett Associates LLP

Non-residential – other dvpm’t costs

• Add on external works = 10% • Project/design team fees = 10% of build costs • Contingency = 4% of construction costs • Marketing, legal and sales = 3.5% of GDV • Finance – using a monthly cash-flow = 7% (APR) • Developer return = 20% of costs incl: overheads • Professional fees on land purchase = 1.75% (+ SDLP)

• Development obligations • Start with likely S106/278 contributions based on experience and information provided by the Council • CIL at varying amounts by iteration

• Anything else? Peter Brett Associates LLP

No further comments were made.

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18. Conclusion All – these are the contacts for further RP concluded the session and thanked everyone for their time and discussion or sending explained that the notes of the meeting and the presentation would be any notes and/or circulated for further comment. RP also emphasised the need to back up evidence to inform the comments with evidence and to send them to PBA using the contacts work. details presented in the slide copied below.

Lastly…

• Any questions or further thoughts • More discussion…

• Mark Felgate – [email protected] • Russell Porter – [email protected]

Peter Brett Associates LLP

19. AOB:

Please could everybody review the accompanying Panel List and confirm their desire to participate in future work or not. Please send completed forms to [email protected]. Thank you.

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Circulated Minutes from the Panel meeting on the 6th December 2016 at The Civic Centre, Plymouth

This note accompanies the presentation given by Peter Brett Associates (PBA) on the 6th of December. The presentation slides are attached to this note. The presentation was split into a morning and afternoon session. The morning session set out the intended methodology and evidence regarding the assumptions that had been formed in relation to the viability work currently being undertaken by PBA. The afternoon session looked at some early results in applying the method and assumptions to the SHLAA sites

The purpose of the presentation, and indeed of this note, is to set out proposed viability assumptions and to invite thoughts about the nature of the local residential and commercial uses market within the Plymouth and South West Devon Joint Local Plan (JLP) area. PBA would like to thank you for the comments received so far, and should anyone like to provide further considerations within the next 7 days, we are contactable by email ([email protected] & [email protected]).

It should be noted that the viability methodology applied is appropriate for whole plan analysis and SHLAA purposes but should not be taken as the de facto approach for every individual development proposal which will be subject to its own site opportunities and constraints.

This note summarises a number of the key points raised on the day.

a. Grant Jackson (GJ) from Plymouth City Council introduced the day, and then gave context regarding the progress of the JLP, its timetable and the reasons behind conducting a joint local plan. GJ noted the importance of the workshop for the JLP authorities, and PBA, to gain a further understanding on delivery and assumptions.

b. Russell Porter (RP) of Peter Brett Associates (PBA) introduced the study and PBA’s role as viability consultants to the council. In the accompanying slides 3 to 5, RP discussed the method used in the study, the residual land value method and the legislative background that underpins the study and its approach to assessing viability.

c. RP then set out research regarding the past level of development, particularly regarding Plymouth that is shown in slides 6 to 13. In summary, RP noted that:

i. The majority of delivery was from larger sites (defined as 10 and over). GJ commented further that most recent figures for the 2014/15 period (not shown on slide) had shown a notable increase in delivery. ii. A large portion of the delivery over the past decade has been delivered through brownfield sites. A point that was confirmed by the council, attributed in part due to large flatted citing examples of 2007/08 and 2008/09. iii. The rationale for the typologies that PBA intends to test. RP responded to a question that retirement homes reflect the definitions for sheltered accommodation, whilst extra-care units are similar to assisted living which includes additional warden care. RP also confirmed to a question that the quantum of dwellings shown in the far right hand column of slide 8 refers to the total number of dwelling and not just the open market units. iv. A post meeting comment relating to Extra-care units was received which PBA is to consider. The noted commented reflected ‘In respect of the ‘Extra Care typology’ it is McCarthy & Stone’s experience that a scheme of this type would not be feasible at 30 units. Residents of Extra Care developments pay a service charge to cover the cost of the enhanced facilities and staffing. The more residents, the lower the service charge. A

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minimum of 50 units is needed to provide a service charge that is affordable to potential purchasers.’ i. Slides 9 to 11 discussed assumptions regarding density. RP noted that delivery in the area has been fairly high density, increasing between 2000 to a peak of 97% of development being above 50dph in 2008/09, before falling somewhat in recent years. Since 2003 consistently less than 10% of sites has been developed at under 30 dph. One attendee noted that high density developments at the minimum sizes could perpetuate smaller development in the future. Otherwise, there was little comment regarding the density assumptions shown in the presentation.

ii. Slide 12 sets out the mix of residential housing (detached, semi, terraced and flats) in Plymouth and the mix used in testing in slide 13 to indicate that the appraisal would be based on broad housing requirements as informed by JLP officer advice. It was asked whether PBA had considered who the houses were being sold to and whether there was a consideration of second home buyers in the typologies. RP responded to say that the council would be considering this separately through the SHMA, and that while there could be some premium placed on second home purchases, at present there was no information to support undertaking any further analysis for the purposes of undertaking high level assessments of sites and the JLP.

iii. Development assumptions on housing sizes, as presented in Slide 14 is based on the government prescribed minimum national space standards by taking an average figure within each category under flats, 2 bed, 3 bed and 4 bed properties.

iv. Slide 15 shows the assumed gross to net developable land ratios. RP explained that estimating the net developable land area from the gross site area uses a default formula for size thresholds based on real examples and past guidance. So that as sites more than 0.75ha become bigger the proportion of net developable area becomes smaller to account for requirements like open space. The formula is applied progressively. There was little comment as to the appropriateness of the approach or size trigger assumptions in general, however some comments suggested that these ratios may vary by location given flood risk issues and topography.

v. Slide 16 presented current thinking regarding appropriate benchmark land values, noting that transactional land value data is rarely available. This slide generated the most discussion in the room. RP stated that these reflect values that could be expected by the landowner when all other costs are considered separately (for instance remediation, gaining planning permission, policy costs such as AH etc). There was a mix of feelings about local land values, with some suggesting that they are not high enough while others suggesting that the assumed values are too high, with particular concern given to the Plymouth Waterfront rates and West Devon. It was noted that land values in the South Hams hotspots around Salcombe, Dartmouth and potentially Totnes could be higher. Owing to the dearth of strong evidence about appropriate benchmark land values, RP welcomed further comment to help determine appropriate land values for policy testing and suggested that more work will be undertaken to consider the evidence for benchmark land values. A post meeting comment was received:

vi. RP presented assumptions for brownfield land costs and opening up costs. There were no questions or responses regarding whether or not these were appropriate.

vii. Tom Marshall (TM) from PBA then presented four ‘heatmaps’ to discuss where there may be obvious value differences between large areas. From discussions in the room it appeared that the value areas were fairly acceptable, however it was deemed that greater banding of values could be useful to show a more a finer grain approach particularly for high value areas like Salcombe. It was also commented that there could be significantly differentials in value areas within West Devon. PBA agreed to give this further thought.

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viii. TM also presented the methodology involved in gaining sales value data. One attendee suggested that the values did not correlate with the land values presented in Slide 16 (discussed above). Another commentated that there are steep variations across South Hams. A number of attendees expressed a wish to look into this in more detail and provide evidence after the event. A post meeting comment from West Devon Council was received, which notes: ‘observations from the panel meeting were that there are 2 distinct areas within West Devon in terms of North (Okehampton) and South (Tavistock). The values for these areas vary quite considerably. It is also worth noting that there has been very little new accommodation within the south of the borough but the north of the areas have had considerable development. I was concerned that these figures were somewhat skewed towards the northern end of the borough. A similar scenario plays out with the ‘honey pot’ areas of the South Hams in terms of Salcombe and the coastal areas there. There has been some development in Salcombe but there is very little change from a few million quid!’ PBA will be reviewing the West Devon sales values (and land prices) data in more detail to identify any skews in the data and/or patterns of variation.

ix. RP then discussed Build costs used in the appraisal, which were taken from BCIS. A discussion regarding the closeness of BCIS figures to actual cost pricing, and an acknowledgement of irregularities of forecast data. No significant opposition of BCIS as a tool for providing build costs.

x. RP set out assumptions regarding externals, professional fees, finance, marketing fees and contingency. One respondent felt that finance fees could be lower than 6%, though there was an acknowledgement that 6% is often seen as ‘the norm’ for these studies. Conversely, it was suggested by one respondent that profit was too low (at 20%) and should be much higher (25%). This was debated amongst the attendees with one respondent suggesting that in many cases in Plymouth 20% can be considered as too generous. RP indicated that 20% was a figure that was widely used for high level viability testing.

xi. RP then discussed assumptions regarding affordable housing. It was noted that the threshold is lower in South Hams and West Devon (5 and lower) than Plymouth (10 and lower) which would need to be considered in the viability results. It was also commented that Social rented was not particularly popular, however an attendee form Plymouth Housing team confirmed that there was still a need for this tenure.

xii. RP discussed other policy variables. S106 at £2,000 per dwelling was discussed and it was advised that this can be substantially higher in some larger developments, though there was an understanding that this was in places currently without a CIL charge. PBA have requested that South Hams and West Devon send through further information regarding average s106 receipts.

xiii. RP discussed assumptions for CIL. It was acknowledged that CIL had been in place in Plymouth for a couple of years and therefore the CIL rate would need to be indexed up to reflect the latest All in Tender Price change from BCIS.

xiv. RP presented information on build out rates. The Council had previously circulated a note about their estimates of local build out rates that had informed the presented rates. No comments or alternative rates/lead-in times were put forward by panel members.

xv. RP gave a broad overview of the non-residential assumptions. Attendees were invited to review the assumptions for these and provide comments. RP closed Session 1 of the presentation.

Afternoon Session

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xvi. Following a break RP then introduced the viability results from an initial test of SHLAA sites. RP set out that the study covered the three authorities using the assumptions set out in the morning session.

When discussing the results, it was commented and agreed that the affordable housing thresholds in South Hams/West Devon needed to reflect the current policy positions of 6 or more units in rural parishes rather than the assumed 11 or more units.

xvii. Similarly, it was commented that the tested CIL rate would need indexing to show the current charging rates (currently around £37 for residential; £72 for student; £121 for retail). It was also noted that some of the sites may have been duplicated because they had been reported by both Plymouth and South Hams/West Devon authorities.

xviii. RP presented the viable, non-viable and marginally viable sites on a geographical map, which demonstrated that unviable and marginally viable sites were generally scattered, and therefore it was difficult to note exact geographical patterns (where it could be said development particularly struggles, etc).

xix. RP then ran through all of the sites that were deemed as marginal (defined as having a residual land value plus or minus 10% of the benchmark land value). In this exercise, RP discussed site characteristics with the attendees to ascertain what was impacting on the delivery of these sites. Comments about this included:

• Benchmark land value assumptions to be too high, at least in certain locations. For example, one site was in a greenfield area and therefore the benchmark land value would be close to an agricultural land value plus uplift.

• Sites just meeting the affordable threshold (i.e. 11, 12 and 13 unit sites). In reality it was suggested that these sites would come forward with fewer units to be just under threshold, built with higher densities to mitigate the policy cost of providing for affordable housing.

• Some sites identified had issues regarding flood risk and/or contamination

xx. Finally, RP discussed the viability outcomes of three strategic sites that are identified as being important to future housing delivery. The initial testing indicated that these strategic sites would be deliverable. Whilst there was an acknowledgment that the headroom was relatively high, it was considered that higher s106 costs could be required on them relative to the assumed tested rate of £2k per unit.

xxi. One attendee had asked as to how commercial uses as part of mixed use development are to be considered in the assessment. It was discussed that the model only appraises the residential element of the scheme for the purposes of identifying achievability of housing delivery. It was further commented by another attendee that this would mask the true viability of sites such as Derriford where there is a significant element of commercial floorspace.

xxii. GJ closed the workshop and encouraged attendees to submit any further comments or evidence by the 14th December so that the work could be finalised.

xxiii. RP re-affirmed the request for further comments with suitable evidence to support suggested changes to the viability assumptions. All comments/evidence received two weeks post the panel workshop have been included in the above points. Other than any actions to be taken regarding the points raised and noted above, it is taken that the assumptions for policy level viability testing are agreed.

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Appendix C New Build Properties sold since Jan 2015

Sourced from the Land Registry and matched with EPC data

Plymouth

Location Postcode Type date £ per sqm Broad Value area

Ashbrook Street PL9 7FH Semi August 2015 £1,949 Plymouth - East Ashbrook Street PL9 7FH Semi March 2015 £2,025 Plymouth - East Ashbrook Street PL9 7FH Terraced August 2015 £1,949 Plymouth - East Barton Road PL9 9RQ Terraced September 2015 £2,935 Plymouth - East Barton Road PL9 9RQ Terraced July 2015 £3,377 Plymouth - East Barton Road PL9 9RQ Terraced June 2015 £3,247 Plymouth - East Barton Road PL9 9RQ Terraced June 2015 £2,963 Plymouth - East Barton Road PL9 9RQ Terraced June 2015 £3,104 Plymouth - East Barton Road PL9 9RQ Terraced June 2015 £2,778 Plymouth - East Barton Road PL9 9RQ Terraced June 2015 £2,593 Plymouth - East Barton Road PL9 9RQ Terraced June 2015 £2,641 Plymouth - East Blandford Road PL3 6JD Terraced January 2016 £2,372 Plymouth - East Blandford Road PL3 6JD Terraced December 2015 £2,238 Plymouth - East Blandford Road PL3 6JD Terraced December 2015 £2,238 Plymouth - East Blandford Road PL3 6JD Terraced November 2015 £2,280 Plymouth - East Blandford Road PL3 6JD Terraced November 2015 £2,388 Plymouth - East Blandford Road PL3 6JD Terraced November 2015 £2,271 Plymouth - East Blandford Road PL3 6JD Terraced October 2015 £1,803 Plymouth - East Blandford Road PL3 6JD Terraced October 2015 £2,322 Plymouth - East Blandford Road PL3 6JD Terraced September 2015 £1,803 Plymouth - East Blandford Road PL3 6JD Terraced August 2015 £1,803 Plymouth - East Blandford Road PL3 6JD Terraced July 2015 £2,627 Plymouth - East Boston Close PL9 7NR Detached February 2016 £2,301 Plymouth - East Boston Close PL9 7NR Detached December 2015 £2,500 Plymouth - East Boston Close PL9 7NR Detached October 2015 £2,578 Plymouth - East Boston Close PL9 7NR Detached September 2015 £2,556 Plymouth - East Boston Close PL9 7NR Detached August 2015 £2,734 Plymouth - East Boston Close PL9 7NR Detached August 2015 £2,742 Plymouth - East Boston Close PL9 7NR Detached August 2015 £2,734 Plymouth - East Boston Close PL9 7NR Detached July 2015 £2,481 Plymouth - East Boston Close PL9 7NR Detached July 2015 £2,730 Plymouth - East Boston Close PL9 7NR Detached June 2015 £3,828 Plymouth - East Boston Close PL9 7NR Detached June 2015 £2,451 Plymouth - East Boston Close PL9 7NR Detached May 2015 £2,593 Plymouth - East

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Boston Close PL9 7NR Detached April 2015 £2,811 Plymouth - East Boston Close PL9 7NR Detached April 2015 £2,157 Plymouth - East Boston Close PL9 7NR Detached January 2015 £2,362 Plymouth - East Boston Close PL9 7NR Semi January 2016 £2,664 Plymouth - East Boston Close PL9 7NR Semi November 2015 £3,125 Plymouth - East Boston Close PL9 7NR Semi November 2015 £3,047 Plymouth - East Boston Close PL9 7NR Semi November 2015 £2,628 Plymouth - East Boston Close PL9 7NR Semi November 2015 £2,633 Plymouth - East Boston Close PL9 7NR Semi October 2015 £2,667 Plymouth - East Boston Close PL9 7NR Semi October 2015 £2,464 Plymouth - East Boston Close PL9 7NR Semi September 2015 £2,611 Plymouth - East Boston Close PL9 7NR Semi September 2015 £2,383 Plymouth - East Boston Close PL9 7NR Semi July 2015 £2,333 Plymouth - East Boston Close PL9 7NR Semi April 2015 £2,418 Plymouth - East Boston Close PL9 7NR Semi April 2015 £2,426 Plymouth - East Boston Close PL9 7NR Terraced June 2015 £2,658 Plymouth - East Boston Close PL9 7NR Terraced March 2015 £2,532 Plymouth - East Boston Close PL9 7NR Terraced March 2015 £2,658 Plymouth - East Boston Close PL9 7NR Terraced February 2015 £2,848 Plymouth - East Bridgelands Close PL5 1FA Detached July 2015 £2,500 Plymouth - West Bridgelands Close PL5 1FA Detached February 2015 £2,500 Plymouth - West Broxton Drive PL9 7FG Terraced May 2015 £2,361 Plymouth - East Causeway View PL9 9FQ Detached January 2016 £2,419 Plymouth - East Causeway View PL9 9FQ Detached December 2015 £2,438 Plymouth - East Causeway View PL9 9FQ Detached September 2015 £2,500 Plymouth - East Causeway View PL9 9FQ Detached September 2015 £2,541 Plymouth - East Causeway View PL9 9FQ Detached September 2015 £2,517 Plymouth - East Causeway View PL9 9FQ Detached September 2015 £2,594 Plymouth - East Causeway View PL9 9FQ Detached May 2015 £2,705 Plymouth - East Causeway View PL9 9FQ Detached February 2015 £2,465 Plymouth - East Centenary Road PL1 4SY Semi July 2015 £2,323 Plymouth - East Centenary Road PL1 4SY Semi July 2015 £2,282 Plymouth - East Centenary Road PL1 4SY Terraced December 2015 £2,405 Plymouth - East Centenary Road PL1 4SY Terraced October 2015 £2,343 Plymouth - East Cookworthy Road PL2 2LH Semi January 2015 £2,151 Plymouth - West Curtis Street PL1 4BP Terraced April 2015 £1,634 Plymouth - East Discovery Road PL1 4SJ Terraced November 2015 £2,372 Plymouth - East Discovery Road PL1 4SJ Terraced November 2015 £2,462 Plymouth - East Discovery Road PL1 4SJ Terraced October 2015 £2,179 Plymouth - East Discovery Road PL1 4SJ Terraced October 2015 £2,179 Plymouth - East Discovery Road PL1 4SJ Terraced October 2015 £2,179 Plymouth - East Discovery Road PL1 4SJ Terraced October 2015 £2,126 Plymouth - East Discovery Road PL1 4SJ Terraced October 2015 £2,333 Plymouth - East

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Fin Street PL1 3FF Terraced December 2015 £2,120 Plymouth - East Fin Street PL1 3FF Terraced September 2015 £2,260 Plymouth - East Fin Street PL1 3FF Terraced May 2015 £2,087 Plymouth - East Fin Street PL1 3FF Terraced May 2015 £2,196 Plymouth - East Flagstaff Walk PL1 4SH Terraced November 2015 £2,427 Plymouth - East Foliot Road PL2 2RZ Semi May 2015 £1,745 Plymouth - West Foliot Road PL2 2RZ Terraced June 2015 £2,103 Plymouth - West Foliot Road PL2 2RZ Terraced June 2015 £1,716 Plymouth - West Foliot Road PL2 2RZ Terraced May 2015 £1,667 Plymouth - West Foliot Road PL2 2RZ Terraced May 2015 £1,745 Plymouth - West Foliot Road PL2 2RZ Terraced May 2015 £1,765 Plymouth - West Foliot Road PL2 2RZ Terraced March 2015 £1,667 Plymouth - West Foliot Road PL2 2RZ Terraced March 2015 £2,132 Plymouth - West Foliot Road PL2 2RZ Terraced March 2015 £1,764 Plymouth - West Fore Street PL1 4FZ Terraced May 2015 £1,802 Plymouth - East Grassendale Avenue PL2 2SN Detached November 2015 £2,303 Plymouth - West Grassendale Avenue PL2 2SN Detached November 2015 £2,273 Plymouth - West Grassendale Avenue PL2 2SN Semi December 2015 £2,254 Plymouth - West Grassendale Avenue PL2 2SN Semi December 2015 £2,408 Plymouth - West Grassendale Avenue PL2 2SN Semi November 2015 £2,395 Plymouth - West Grassendale Avenue PL2 2SN Semi November 2015 £1,980 Plymouth - West Grassendale Avenue PL2 2SN Semi September 2015 £2,396 Plymouth - West Grassendale Avenue PL2 2SN Semi September 2015 £2,388 Plymouth - West Grassendale Avenue PL2 2SN Semi September 2015 £2,263 Plymouth - West Grassendale Avenue PL2 2SN Semi July 2015 £1,942 Plymouth - West Grassendale Avenue PL2 2SN Semi July 2015 £1,893 Plymouth - West Grassendale Avenue PL2 2SN Semi June 2015 £2,103 Plymouth - West Grassendale Avenue PL2 2SN Semi May 2015 £1,942 Plymouth - West Grassendale Avenue PL2 2SN Semi March 2015 £2,357 Plymouth - West Grassendale Avenue PL2 2SN Semi March 2015 £1,553 Plymouth - West Grassendale Avenue PL2 2SN Terraced November 2015 £2,259 Plymouth - West Grassendale Avenue PL2 2SN Terraced October 2015 £2,246 Plymouth - West Grassendale Avenue PL2 2SN Terraced October 2015 £2,239 Plymouth - West Grassendale Avenue PL2 2SN Terraced July 2015 £2,336 Plymouth - West Grassendale Avenue PL2 2SN Terraced June 2015 £2,408 Plymouth - West Grassendale Avenue PL2 2SN Terraced June 2015 £2,388 Plymouth - West Grassendale Avenue PL2 2SN Terraced March 2015 £2,357 Plymouth - West Hangar Lane PL6 8DW Semi March 2015 £2,284 Plymouth - East Hangar Lane PL6 8DW Semi March 2015 £3,026 Plymouth - East Hangar Lane PL6 8DW Semi March 2015 £2,644 Plymouth - East Harlyn Drive PL2 3EQ Semi May 2015 £2,271 Plymouth - West Harlyn Drive PL2 3EQ Terraced August 2015 £2,167 Plymouth - West Harlyn Drive PL2 3EQ Terraced June 2015 £2,176 Plymouth - West

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Harlyn Drive PL2 3EQ Terraced June 2015 £2,200 Plymouth - West Harlyn Drive PL2 3EQ Terraced May 2015 £2,139 Plymouth - West Harlyn Drive PL2 3EQ Terraced April 2015 £2,268 Plymouth - West Harlyn Drive PL2 3EQ Terraced April 2015 £2,277 Plymouth - West Harlyn Drive PL2 3EQ Terraced March 2015 £2,277 Plymouth - West Harlyn Drive PL2 3EQ Terraced March 2015 £2,321 Plymouth - West Jetstream Way PL6 8ED Detached October 2015 £2,474 Plymouth - East Jetstream Way PL6 8ED Detached September 2015 £2,578 Plymouth - East Jetstream Way PL6 8ED Detached August 2015 £2,426 Plymouth - East Jetstream Way PL6 8ED Detached April 2015 £2,471 Plymouth - East Kernow Gate PL5 1FB Semi January 2016 £2,308 Plymouth - West Kernow Gate PL5 1FB Semi December 2015 £2,128 Plymouth - West Kernow Gate PL5 1FB Semi December 2015 £2,272 Plymouth - West Kernow Gate PL5 1FB Semi June 2015 £2,432 Plymouth - West Kernow Gate PL5 1FB Semi May 2015 £2,000 Plymouth - West Kernow Gate PL5 1FB Semi March 2015 £2,432 Plymouth - West Killerton Lane PL9 7GA Semi September 2015 £2,613 Plymouth - East Limeburners Road PL9 9FL Terraced May 2015 £2,308 Plymouth - East Limeburners Road PL9 9FL Terraced March 2015 £2,404 Plymouth - East Limeburners Road PL9 9FL Terraced March 2015 £2,404 Plymouth - East Linhay Lane PL9 7FL Terraced April 2015 £2,130 Plymouth - East Linhay Lane PL9 7FL Terraced February 2015 £2,241 Plymouth - East Lord Morley Way PL9 8AF Detached June 2015 £2,778 Plymouth - East Lord Morley Way PL9 8AF Detached April 2015 £2,876 Plymouth - East Lord Morley Way PL9 8AF Detached April 2015 £2,576 Plymouth - East Lord Morley Way PL9 8AF Detached March 2015 £2,863 Plymouth - East Lord Morley Way PL9 8AF Detached March 2015 £2,784 Plymouth - East Lord Morley Way PL9 8AF Detached February 2015 £2,911 Plymouth - East Lord Morley Way PL9 8AF Semi September 2015 £2,712 Plymouth - East Marazion Way PL2 3FD Terraced September 2015 £2,578 Plymouth - West Marazion Way PL2 3FD Terraced September 2015 £2,703 Plymouth - West Marazion Way PL2 3FD Terraced August 2015 £2,703 Plymouth - West Marazion Way PL2 3FD Terraced July 2015 £2,469 Plymouth - West Marazion Way PL2 3FD Terraced June 2015 £2,407 Plymouth - West Marazion Way PL2 3FD Terraced June 2015 £2,346 Plymouth - West Marazion Way PL2 3FD Terraced June 2015 £2,407 Plymouth - West Marazion Way PL2 3FD Terraced June 2015 £2,703 Plymouth - West Marazion Way PL2 3FD Terraced June 2015 £2,407 Plymouth - West Marazion Way PL2 3FD Terraced June 2015 £2,346 Plymouth - West Marazion Way PL2 3FD Terraced June 2015 £2,656 Plymouth - West Marazion Way PL2 3FD Terraced June 2015 £2,432 Plymouth - West Maritime Square PL1 4SW Terraced June 2015 £2,173 Plymouth - East Market Road PL7 1QW Terraced November 2015 £1,691 Plymouth - East

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Market Road PL7 1QW Terraced October 2015 £1,768 Plymouth - East Mildren Way PL1 4GF Terraced May 2015 £2,145 Plymouth - East Mildren Way PL1 4GF Terraced May 2015 £2,101 Plymouth - East Millennium Street PL2 3EE Detached November 2015 £2,745 Plymouth - West Millennium Street PL2 3EE Detached October 2015 £2,566 Plymouth - West Millennium Street PL2 3EE Detached October 2015 £2,725 Plymouth - West Millennium Street PL2 3EE Detached October 2015 £2,704 Plymouth - West Millennium Street PL2 3EE Detached October 2015 £2,824 Plymouth - West Millennium Street PL2 3EE Detached June 2015 £2,500 Plymouth - West Millennium Street PL2 3EE Detached June 2015 £2,519 Plymouth - West Millennium Street PL2 3EE Detached June 2015 £2,591 Plymouth - West Millennium Street PL2 3EE Detached June 2015 £2,625 Plymouth - West Millennium Street PL2 3EE Detached June 2015 £2,625 Plymouth - West Millennium Street PL2 3EE Detached June 2015 £2,708 Plymouth - West Millennium Street PL2 3EE Detached June 2015 £2,600 Plymouth - West Millennium Street PL2 3EE Detached May 2015 £2,708 Plymouth - West Millennium Street PL2 3EE Detached May 2015 £2,591 Plymouth - West Millennium Street PL2 3EE Detached May 2015 £2,636 Plymouth - West Millennium Street PL2 3EE Detached April 2015 £2,673 Plymouth - West Millennium Street PL2 3EE Detached April 2015 £2,636 Plymouth - West Millennium Street PL2 3EE Detached February 2015 £2,510 Plymouth - West Millennium Street PL2 3EE Detached February 2015 £2,455 Plymouth - West Millennium Street PL2 3EE Detached February 2015 £2,455 Plymouth - West Millennium Street PL2 3EE Semi June 2015 £2,746 Plymouth - West Millennium Street PL2 3EE Semi April 2015 £2,697 Plymouth - West Millennium Street PL2 3EE Semi April 2015 £2,697 Plymouth - West Millennium Street PL2 3EE Semi March 2015 £2,697 Plymouth - West Millennium Street PL2 3EE Semi March 2015 £2,584 Plymouth - West Millennium Street PL2 3EE Terraced November 2015 £2,789 Plymouth - West Millennium Street PL2 3EE Terraced November 2015 £2,606 Plymouth - West Millennium Street PL2 3EE Terraced November 2015 £3,014 Plymouth - West Millennium Street PL2 3EE Terraced October 2015 £2,606 Plymouth - West Millennium Street PL2 3EE Terraced June 2015 £2,746 Plymouth - West Millennium Street PL2 3EE Terraced June 2015 £2,606 Plymouth - West Millennium Street PL2 3EE Terraced June 2015 £2,562 Plymouth - West Murhill Lane PL9 7FN Detached April 2015 £2,932 Plymouth - East Murhill Lane PL9 7FN Detached March 2015 £2,951 Plymouth - East Murhill Lane PL9 7FN Detached February 2015 £3,086 Plymouth - East Murhill Lane PL9 7FN Semi May 2015 £2,824 Plymouth - East Murhill Lane PL9 7FN Semi February 2015 £2,915 Plymouth - East Outcrop Road PL9 9FR Detached June 2015 £2,587 Plymouth - East Outcrop Road PL9 9FR Detached June 2015 £2,541 Plymouth - East Park Avenue PL1 4TB Terraced November 2015 £2,225 Plymouth - East

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Pennycross Close PL2 3EF Terraced December 2015 £2,083 Plymouth - West Pennycross Close PL2 3EF Terraced June 2015 £2,346 Plymouth - West Pennycross Close PL2 3EF Terraced June 2015 £2,064 Plymouth - West Perryfield Place PL9 7FT Terraced June 2015 £2,840 Plymouth - East Phelps Road PL1 4GH Semi April 2015 £1,622 Plymouth - East Phelps Road PL1 4GH Semi March 2015 £1,613 Plymouth - East Pine Gardens PL3 4FG Detached December 2015 £2,774 Plymouth - East Pine Gardens PL3 4FG Detached October 2015 £2,868 Plymouth - East Pine Gardens PL3 4FG Detached September 2015 £2,917 Plymouth - East Pine Gardens PL3 4FG Detached August 2015 £3,134 Plymouth - East Pine Gardens PL3 4FG Detached August 2015 £3,082 Plymouth - East Pine Gardens PL3 4FG Detached July 2015 £3,082 Plymouth - East Pine Gardens PL3 4FG Detached June 2015 £2,885 Plymouth - East Pine Gardens PL3 4FG Detached June 2015 £2,857 Plymouth - East Piper Street PL6 8DS Detached June 2015 £2,385 Plymouth - East Piper Street PL6 8DS Detached April 2015 £2,431 Plymouth - East Piper Street PL6 8DS Detached April 2015 £2,500 Plymouth - East Piper Street PL6 8DS Detached March 2015 £2,536 Plymouth - East Piper Street PL6 8DJ Semi May 2015 £1,750 Plymouth - East Piper Street PL6 8DS Terraced January 2015 £2,750 Plymouth - East Plymview Close PL3 6AL Detached July 2015 £2,262 Plymouth - East Plymview Close PL3 6AL Detached June 2015 £2,537 Plymouth - East Plymview Close PL3 6AL Semi December 2015 £2,373 Plymouth - East Plymview Close PL3 6AL Semi October 2015 £2,661 Plymouth - East Plymview Close PL3 6AL Semi June 2015 £2,012 Plymouth - East Plymview Close PL3 6AL Terraced December 2015 £2,409 Plymouth - East Plymview Close PL3 6AL Terraced December 2015 £2,542 Plymouth - East Plymview Close PL3 6AL Terraced October 2015 £2,542 Plymouth - East Radar Road PL6 8DU Terraced December 2015 £3,406 Plymouth - East Radar Road PL6 8DU Terraced December 2015 £2,891 Plymouth - East Radar Road PL6 8DU Terraced December 2015 £2,260 Plymouth - East Radar Road PL6 8DU Terraced December 2015 £2,968 Plymouth - East Radar Road PL6 8DU Terraced November 2015 £2,859 Plymouth - East Radar Road PL6 8DU Terraced November 2015 £2,178 Plymouth - East Radar Road PL6 8DU Terraced October 2015 £2,297 Plymouth - East Radar Road PL6 8DU Terraced October 2015 £2,905 Plymouth - East Radar Road PL6 8DU Terraced October 2015 £2,889 Plymouth - East Radar Road PL6 8DU Terraced October 2015 £2,859 Plymouth - East Radar Road PL6 8DU Terraced September 2015 £2,889 Plymouth - East Radar Road PL6 8DU Terraced September 2015 £3,261 Plymouth - East Radar Road PL6 8DU Terraced September 2015 £3,333 Plymouth - East Radar Road PL6 8DU Terraced August 2015 £2,904 Plymouth - East Radar Road PL6 8DU Terraced August 2015 £2,844 Plymouth - East

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Radar Road PL6 8DU Terraced August 2015 £2,889 Plymouth - East Radar Road PL6 8DU Terraced July 2015 £2,859 Plymouth - East Radar Road PL6 8DU Terraced January 2015 £3,116 Plymouth - East Reflections Road PL9 9FT Detached August 2015 £2,378 Plymouth - East Reflections Road PL9 9FT Detached June 2015 £2,483 Plymouth - East Reflections Road PL9 9FT Detached June 2015 £2,483 Plymouth - East Reflections Road PL9 9FT Detached April 2015 £2,377 Plymouth - East Runway Road PL6 8DT Terraced January 2016 £1,856 Plymouth - East Runway Road PL6 8DT Terraced January 2016 £1,856 Plymouth - East Runway Road PL6 8DT Terraced December 2015 £2,051 Plymouth - East Sourton Square PL9 7FR Detached March 2015 £2,407 Plymouth - East St Aubyn Road PL1 4TE Terraced June 2015 £2,273 Plymouth - East St Aubyn Road PL1 4TE Terraced June 2015 £2,266 Plymouth - East St Aubyn Road PL1 4TE Terraced June 2015 £2,343 Plymouth - East St Aubyn Street PL1 4GW Terraced September 2015 £1,595 Plymouth - East St Aubyn Street PL1 4GW Terraced September 2015 £1,595 Plymouth - East St Aubyn Street PL1 4GW Terraced September 2015 £1,595 Plymouth - East St Aubyn Street PL1 4GW Terraced August 2015 £2,145 Plymouth - East St Aubyn Street PL1 4GW Terraced August 2015 £2,173 Plymouth - East St Aubyn Street PL1 4GW Terraced August 2015 £1,552 Plymouth - East St Aubyn Street PL1 4GW Terraced June 2015 £1,541 Plymouth - East St Aubyn Street PL1 4GW Terraced June 2015 £1,505 Plymouth - East St Aubyn Street PL1 4GW Terraced June 2015 £1,514 Plymouth - East St Aubyn Street PL1 4GW Terraced June 2015 £1,514 Plymouth - East Trelawney Lane PL3 4FD Detached March 2016 £2,051 Plymouth - East Unity Park PL3 6PN Detached October 2015 £2,330 Plymouth - East Unity Park PL3 6PN Detached September 2015 £2,509 Plymouth - East Unity Park PL3 6PN Detached September 2015 £2,330 Plymouth - East Unity Park PL3 6PN Detached June 2015 £2,573 Plymouth - East Unity Park PL3 6PN Detached June 2015 £2,330 Plymouth - East Unity Park PL3 6NW Detached June 2015 £2,529 Plymouth - East Unity Park PL3 6PN Detached June 2015 £2,636 Plymouth - East Unity Park PL3 6PN Semi October 2015 £2,686 Plymouth - East Unity Park PL3 6PN Semi October 2015 £2,731 Plymouth - East Unity Park PL3 6PN Semi January 2015 £2,602 Plymouth - East Unity Park PL3 6PN Terraced June 2015 £2,130 Plymouth - East Unity Park PL3 6PN Terraced June 2015 £2,061 Plymouth - East Unity Park PL3 6PN Terraced June 2015 £2,071 Plymouth - East Unity Park PL3 6PN Terraced June 2015 £2,081 Plymouth - East Unity Park PL3 6NW Terraced April 2015 £2,605 Plymouth - East Unity Park PL3 6PN Terraced March 2015 £2,686 Plymouth - East Unity Park PL3 6PN Terraced February 2015 £2,083 Plymouth - East Unity Park PL3 6NW Terraced February 2015 £2,632 Plymouth - East

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Upland Drive PL6 6BE Detached July 2015 £2,500 Plymouth - West Verden Close PL3 4BT Detached January 2015 £1,894 Plymouth - East Vixen Way PL2 2QW Detached March 2015 £2,272 Plymouth - West Vixen Way PL2 2QW Detached March 2015 £2,242 Plymouth - West Vixen Way PL2 2QW Terraced August 2015 £2,358 Plymouth - West Vixen Way PL2 2QW Terraced August 2015 £2,418 Plymouth - West Vixen Way PL2 2QW Terraced August 2015 £2,418 Plymouth - West Watercolour Way PL9 9FN Detached February 2016 £1,677 Plymouth - East Watercolour Way PL9 9FU Detached September 2015 £2,378 Plymouth - East Watercolour Way PL9 9FU Detached June 2015 £2,552 Plymouth - East Watercolour Way PL9 9FU Detached June 2015 £2,439 Plymouth - East Watercolour Way PL9 9FU Detached June 2015 £2,483 Plymouth - East Watercolour Way PL9 9FU Detached March 2015 £2,955 Plymouth - East Watercolour Way PL9 9FU Semi March 2015 £2,426 Plymouth - East Watercolour Way PL9 9FU Terraced April 2015 £2,987 Plymouth - East Watercolour Way PL9 9FU Terraced March 2015 £2,922 Plymouth - East Watercolour Way PL9 9FU Terraced March 2015 £3,052 Plymouth - East Westleigh Way PL9 7FZ Semi August 2015 £2,640 Plymouth - East Westleigh Way PL9 7FZ Semi August 2015 £2,738 Plymouth - East Westleigh Way PL9 7FZ Semi August 2015 £2,875 Plymouth - East Westleigh Way PL9 7FZ Semi July 2015 £2,640 Plymouth - East Westleigh Way PL9 7FZ Semi July 2015 £3,254 Plymouth - East Westleigh Way PL9 7FZ Semi July 2015 £2,640 Plymouth - East Westleigh Way PL9 7FS Semi May 2015 £3,233 Plymouth - East Westleigh Way PL9 7FS Semi May 2015 £3,095 Plymouth - East Westleigh Way PL9 7FS Semi April 2015 £3,034 Plymouth - East Westleigh Way PL9 7FS Semi March 2015 £3,267 Plymouth - East Westleigh Way PL9 7FS Semi February 2015 £2,818 Plymouth - East Westleigh Way PL9 7FS Semi January 2015 £2,905 Plymouth - East Whitleigh Villas PL5 3BH Detached April 2015 £4,041 Plymouth - West Woodville Road PL2 2SG Semi November 2015 £2,264 Plymouth - West Woodville Road PL2 2SG Semi September 2015 £1,971 Plymouth - West Woodville Road PL2 2SG Semi August 2015 £1,844 Plymouth - West Woodville Road PL2 2SG Semi July 2015 £1,823 Plymouth - West Woodville Road PL2 2SG Semi July 2015 £1,854 Plymouth - West Woodville Road PL2 2SG Semi June 2015 £1,854 Plymouth - West Chapel Street PL1 4DU Flat September 2015 £2,141 Plymouth - East Craigie Drive PL1 3FX Flat February 2016 £2,011 Plymouth - East Craigie Drive PL1 3FX Flat January 2016 £2,034 Plymouth - East Craigie Drive PL1 3FZ Flat October 2015 £2,202 Plymouth - East Craigie Drive PL1 3GB Flat September 2015 £2,184 Plymouth - East Craigie Drive PL1 3GB Flat July 2015 £2,172 Plymouth - East Craigie Drive PL1 3GB Flat July 2015 £1,929 Plymouth - East

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Craigie Drive PL1 3GB Flat June 2015 £2,381 Plymouth - East Craigie Drive PL1 3FZ Flat June 2015 £1,322 Plymouth - East Craigie Drive PL1 3GB Flat April 2015 £2,071 Plymouth - East Craigie Drive PL1 3GB Flat March 2015 £2,298 Plymouth - East Craigie Drive PL1 3FX Flat January 2015 £2,612 Plymouth - East Discovery Road PL1 4SJ Flat April 2015 £2,564 Plymouth - East Discovery Road PL1 4SJ Flat March 2015 £2,746 Plymouth - East Discovery Road PL1 4SJ Flat March 2015 £2,759 Plymouth - East Discovery Road PL1 4SJ Flat March 2015 £2,845 Plymouth - East Discovery Road PL1 4SJ Flat March 2015 £2,500 Plymouth - East Discovery Road PL1 4SJ Flat March 2015 £2,759 Plymouth - East Durnford Street PL1 3QR Flat March 2016 £5,380 Plymouth - East Durnford Street PL1 3QR Flat March 2016 £5,306 Plymouth - East Durnford Street PL1 3QR Flat February 2016 £5,652 Plymouth - East Durnford Street PL1 3QR Flat February 2016 £4,532 Plymouth - East Durnford Street PL1 3QR Flat February 2016 £4,786 Plymouth - East Durnford Street PL1 3QR Flat February 2016 £5,321 Plymouth - East Durnford Street PL1 3QR Flat January 2016 £4,756 Plymouth - East Durnford Street PL1 3QR Flat January 2016 £5,241 Plymouth - East Durnford Street PL1 3QR Flat January 2016 £5,430 Plymouth - East Durnford Street PL1 3QR Flat January 2016 £4,502 Plymouth - East Durnford Street PL1 3EU Flat April 2015 £1,848 Plymouth - East Durnford Street PL1 3EU Flat April 2015 £1,762 Plymouth - East Durnford Street PL1 3EU Flat March 2015 £1,701 Plymouth - East Elliot Street PL1 2BE Flat April 2015 £2,766 Plymouth - East Elliot Street PL1 2BE Flat March 2015 £1,849 Plymouth - East Fin Street PL1 3FF Flat December 2015 £3,571 Plymouth - East Fin Street PL1 3FF Flat December 2015 £3,214 Plymouth - East Fin Street PL1 3FF Flat December 2015 £3,472 Plymouth - East Fin Street PL1 3FF Flat November 2015 £2,200 Plymouth - East Fin Street PL1 3FF Flat November 2015 £3,030 Plymouth - East Fin Street PL1 3FF Flat November 2015 £2,030 Plymouth - East Fin Street PL1 3FF Flat October 2015 £3,529 Plymouth - East Fin Street PL1 3FF Flat October 2015 £2,694 Plymouth - East Fin Street PL1 3FF Flat October 2015 £2,823 Plymouth - East Fin Street PL1 3FF Flat September 2015 £3,154 Plymouth - East Fin Street PL1 3FF Flat September 2015 £2,729 Plymouth - East Fin Street PL1 3FF Flat September 2015 £3,600 Plymouth - East Fin Street PL1 3FF Flat August 2015 £3,066 Plymouth - East Fin Street PL1 3FF Flat August 2015 £3,177 Plymouth - East Fin Street PL1 3FF Flat August 2015 £2,806 Plymouth - East Fin Street PL1 3FF Flat July 2015 £2,823 Plymouth - East Fin Street PL1 3FF Flat July 2015 £3,857 Plymouth - East

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Fin Street PL1 3FF Flat July 2015 £3,583 Plymouth - East Fin Street PL1 3FF Flat June 2015 £2,846 Plymouth - East Fin Street PL1 3FF Flat June 2015 £3,211 Plymouth - East Fin Street PL1 3FF Flat May 2015 £2,243 Plymouth - East Fin Street PL1 3FF Flat May 2015 £3,043 Plymouth - East Fin Street PL1 3FF Flat May 2015 £3,110 Plymouth - East Fin Street PL1 3FF Flat May 2015 £3,243 Plymouth - East Fin Street PL1 3FF Flat May 2015 £2,839 Plymouth - East Fin Street PL1 3FF Flat May 2015 £3,294 Plymouth - East Fin Street PL1 3FF Flat May 2015 £2,300 Plymouth - East Fin Street PL1 3FF Flat May 2015 £2,793 Plymouth - East Fin Street PL1 3FF Flat May 2015 £3,663 Plymouth - East Fin Street PL1 3FF Flat May 2015 £2,047 Plymouth - East Fin Street PL1 3FF Flat May 2015 £3,750 Plymouth - East Fin Street PL1 3FF Flat May 2015 £3,578 Plymouth - East Fin Street PL1 3FF Flat April 2015 £3,221 Plymouth - East Fin Street PL1 3FF Flat April 2015 £3,465 Plymouth - East Fin Street PL1 3FF Flat April 2015 £3,779 Plymouth - East Fin Street PL1 3FF Flat April 2015 £3,133 Plymouth - East Fin Street PL1 3FF Flat April 2015 £3,569 Plymouth - East Fin Street PL1 3FF Flat April 2015 £2,047 Plymouth - East Fin Street PL1 3FF Flat April 2015 £2,720 Plymouth - East Fin Street PL1 3FF Flat April 2015 £3,897 Plymouth - East Fin Street PL1 3FF Flat April 2015 £3,275 Plymouth - East Fin Street PL1 3FF Flat April 2015 £3,066 Plymouth - East Fin Street PL1 3FF Flat April 2015 £3,603 Plymouth - East Fin Street PL1 3FF Flat April 2015 £3,364 Plymouth - East Fin Street PL1 3FF Flat April 2015 £2,735 Plymouth - East George Place PL1 3FJ Flat October 2015 £2,489 Plymouth - East George Place PL1 3FJ Flat September 2015 £2,499 Plymouth - East George Place PL1 3FJ Flat June 2015 £2,750 Plymouth - East George Place PL1 3FJ Flat June 2015 £2,444 Plymouth - East Holland Road PL9 9BN Flat November 2015 £3,102 Plymouth - East Maritime Square PL1 4SW Flat January 2016 £3,703 Plymouth - East Maritime Square PL1 4SW Flat December 2015 £3,791 Plymouth - East Maritime Square PL1 4SW Flat October 2015 £3,804 Plymouth - East Maritime Square PL1 4SW Flat September 2015 £3,982 Plymouth - East Maritime Square PL1 4SW Flat July 2015 £3,511 Plymouth - East Maritime Square PL1 4SW Flat January 2015 £3,464 Plymouth - East Mildren Way PL1 4GF Flat March 2015 £2,016 Plymouth - East Mildren Way PL1 4GF Flat January 2015 £2,208 Plymouth - East Mildren Way PL1 4GF Flat January 2015 £1,910 Plymouth - East Mildren Way PL1 4GF Flat January 2015 £2,030 Plymouth - East

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Mildren Way PL1 4GF Flat January 2015 £2,078 Plymouth - East Murhill Lane PL9 7FN Flat February 2015 £2,562 Plymouth - East Regent Street PL4 8AR Flat June 2015 £2,280 Plymouth - East Regent Street PL4 8AR Flat June 2015 £2,375 Plymouth - East Regent Street PL4 8AR Flat June 2015 £2,111 Plymouth - East Seymour Road PL3 5AS Flat January 2015 £1,899 Plymouth - East The Crescent PL1 3FG Flat November 2015 £3,170 Plymouth - East The Crescent PL1 3FH Flat July 2015 £2,042 Plymouth - East The Crescent PL1 3FG Flat July 2015 £2,069 Plymouth - East The Crescent PL1 3FH Flat July 2015 £1,768 Plymouth - East The Crescent PL1 3FG Flat July 2015 £1,875 Plymouth - East The Crescent PL1 3FH Flat July 2015 £1,791 Plymouth - East The Crescent PL1 3FH Flat June 2015 £1,820 Plymouth - East The Crescent PL1 3FG Flat June 2015 £2,060 Plymouth - East The Crescent PL1 3FG Flat June 2015 £1,746 Plymouth - East The Crescent PL1 3FH Flat June 2015 £2,142 Plymouth - East The Crescent PL1 3FH Flat June 2015 £2,647 Plymouth - East The Crescent PL1 3FH Flat May 2015 £1,989 Plymouth - East The Crescent PL1 3FH Flat April 2015 £2,635 Plymouth - East The Crescent PL1 3FH Flat April 2015 £1,589 Plymouth - East The Crescent PL1 3FH Flat April 2015 £2,022 Plymouth - East The Crescent PL1 3FG Flat March 2015 £2,517 Plymouth - East The Crescent PL1 3FH Flat March 2015 £1,689 Plymouth - East The Crescent PL1 3FH Flat March 2015 £1,688 Plymouth - East The Crescent PL1 3FH Flat February 2015 £2,412 Plymouth - East Trinity Street PL1 3FT Flat October 2015 £1,929 Plymouth - East Trinity Street PL1 3FT Flat June 2015 £2,889 Plymouth - East Trinity Street PL1 3FT Flat March 2015 £1,969 Plymouth - East Trinity Street PL1 3FT Flat March 2015 £2,047 Plymouth - East Trinity Street PL1 3FT Flat January 2015 £2,243 Plymouth - East Willoughby Way PL1 3GA Flat May 2015 £2,402 Plymouth - East Willoughby Way PL1 3GA Flat April 2015 £2,402 Plymouth - East

South Hams

Location Postcode Type Date £ Per Sqm Broad Value Area

Pinwill Crescent PL21 9FS Detached April 2015 £2,984 South Hams - North Pinwill Crescent PL21 9FS Detached March 2015 £2,942 South Hams - North Pinwill Crescent PL21 9FS Detached June 2015 £2,713 South Hams - North Pinwill Crescent PL21 9FS Detached May 2015 £2,984 South Hams - North Orchard Road PL8 2FE Detached March 2015 £2,233 South Hams - North Orchard Road PL8 2FE Detached June 2015 £2,752 South Hams - North

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Orchard Road PL8 2FE Detached January 2015 £2,857 South Hams - North Orchard Road PL8 2FE Detached December 2015 £2,787 South Hams - North Orchard Road PL8 2FE Detached June 2015 £2,564 South Hams - North Orchard Road PL8 2FE Detached July 2015 £2,635 South Hams - North Orchard Road PL8 2FE Detached June 2015 £2,367 South Hams - North Orchard Road PL8 2FE Detached October 2015 £2,939 South Hams - North Orchard Road PL8 2FE Detached September 2015 £2,674 South Hams - North Brook Mead PL8 2FF Detached June 2015 £2,127 South Hams - North Bramley Close PL8 2FG Semi April 2015 £3,053 South Hams - North Bramley Close PL8 2FG Semi May 2015 £3,086 South Hams - North Bumble Walk PL8 2FH Detached August 2015 £2,344 South Hams - North Bumble Walk PL8 2FH Detached August 2015 £2,303 South Hams - North Gardeners Lane PL8 2PJ Detached January 2015 £2,209 South Hams - North Tappers Lane PL8 2PL Terraced June 2015 £2,787 South Hams - North Tappers Lane PL8 2PL Terraced June 2015 £2,772 South Hams - North Tappers Lane PL8 2PL Detached August 2015 £2,061 South Hams - North Tappers Lane PL8 2PL Terraced March 2015 £1,595 South Hams - North Tappers Lane PL8 2PL Terraced March 2015 £1,573 South Hams - North Tappers Lane PL8 2PL Terraced March 2015 £1,666 South Hams - North Tappers Lane PL8 2PL Semi May 2015 £1,729 South Hams - North Tappers Lane PL8 2PL Semi March 2015 £1,729 South Hams - North Tappers Lane PL8 2PL Detached September 2015 £2,280 South Hams - North Tappers Lane PL8 2PL Detached December 2015 £2,121 South Hams - North Tappers Lane PL8 2PL Detached March 2015 £2,406 South Hams - North Barton Brake PL9 0BJ Semi October 2015 £1,709 South Hams - South Barton Brake PL9 0BJ Detached August 2015 £2,743 South Hams - South Barton Brake PL9 0BJ Terraced December 2015 £2,045 South Hams - South Barton Brake PL9 0BJ Detached December 2015 £2,813 South Hams - South Barton Brake PL9 0BJ Detached October 2015 £2,674 South Hams - South Barton Brake PL9 0BJ Detached October 2015 £2,625 South Hams - South Barton Brake PL9 0BJ Detached December 2015 £2,597 South Hams - South Barton Brake PL9 0BJ Semi September 2015 £3,000 South Hams - South Barton Brake PL9 0BJ Detached November 2015 £2,619 South Hams - South Barton Brake PL9 0BJ Detached December 2015 £2,674 South Hams - South Barton Brake PL9 0BJ Detached November 2015 £2,822 South Hams - South Barton Brake PL9 0BJ Semi December 2015 £1,819 South Hams - South Barton Brake PL9 0BJ Semi October 2015 £1,985 South Hams - South Barton Brake PL9 0BJ Detached December 2015 £2,708 South Hams - South Barton Brake PL9 0BJ Detached December 2015 £2,813 South Hams - South Barton Brake PL9 0BJ Detached December 2015 £2,538 South Hams - South Barton Brake PL9 0BJ Semi December 2015 £3,125 South Hams - South Barton Brake PL9 0BJ Semi September 2015 £3,000 South Hams - South Barton Brake PL9 0BJ Semi December 2015 £3,125 South Hams - South

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Barton Brake PL9 0BJ Detached December 2015 £2,639 South Hams - South Barton Brake PL9 0BJ Detached December 2015 £2,639 South Hams - South Barton Brake PL9 0BJ Detached December 2015 £2,813 South Hams - South Barton Brake PL9 0BJ Detached September 2015 £2,673 South Hams - South Barton Brake PL9 0BJ Detached October 2015 £2,813 South Hams - South Barton Brake PL9 0BJ Terraced November 2015 £1,985 South Hams - South 0 TQ10 9JT Semi March 2015 £1,176 SOUTH HAMS - NORTH 0 TQ6 0LH Semi September 2015 £3,519 SOUTH HAMS - SOUTH 0 TQ7 2EW Terraced January 2015 £2,757 SOUTH HAMS - SOUTH Eastacoombes Way TQ7 3DH Terraced June 2015 £2,806 South Hams - South Eastacoombes Way TQ7 3DH Semi September 2015 £2,520 South Hams - South Eastacoombes Way TQ7 3DH Semi October 2015 £2,560 South Hams - South Eastacoombes Way TQ7 3DH Terraced June 2015 £2,723 South Hams - South Eastacoombes Way TQ7 3DH Semi October 2015 £2,921 South Hams - South Eastacoombes Way TQ7 3DH Terraced June 2015 £2,874 South Hams - South Chestnut Way TQ7 4BT Detached June 2015 £2,760 South Hams - South Chestnut Way TQ7 4BT Detached August 2015 £2,699 South Hams - South Chestnut Way TQ7 4BT Detached June 2015 £2,884 South Hams - South Chestnut Way TQ7 4BT Detached September 2015 £2,748 South Hams - South Chestnut Way TQ7 4BT Detached June 2015 £2,822 South Hams - South Chestnut Way TQ7 4BT Detached June 2015 £2,974 South Hams - South Chestnut Way TQ7 4BT Detached August 2015 £2,875 South Hams - South Harveys Walk TQ7 4BU Detached November 2015 £2,743 South Hams - South Harveys Walk TQ7 4BU Detached March 2015 £2,956 South Hams - South Harveys Walk TQ7 4BU Detached May 2015 £2,836 South Hams - South Harveys Walk TQ7 4BU Detached May 2015 £2,777 South Hams - South Harveys Walk TQ7 4BU Detached June 2015 £2,812 South Hams - South Harveys Walk TQ7 4BU Semi February 2015 £3,113 South Hams - South Harveys Walk TQ7 4BU Detached May 2015 £2,672 South Hams - South Harveys Walk TQ7 4BU Detached March 2015 £2,801 South Hams - South Beechwood Park TQ7 4BY Detached June 2015 £2,938 South Hams - South Beechwood Park TQ7 4BY Terraced February 2015 £2,218 South Hams - South Beechwood Park TQ7 4BY Terraced May 2015 £2,778 South Hams - South Beechwood Park TQ7 4BY Semi October 2015 £2,771 South Hams - South Grenville Road TQ8 8BJ Terraced August 2015 £5,205 South Hams - South Herbert Road TQ8 8HR Terraced August 2015 £4,713 South Hams - South Home Reach Avenue TQ9 5FS Semi September 2015 £3,235 South Hams - South Home Reach Avenue TQ9 5FS Semi October 2015 £3,045 South Hams - South Home Reach Avenue TQ9 5FS Semi October 2015 £3,045 South Hams - South Home Reach Avenue TQ9 5FS Semi December 2015 £3,073 South Hams - South Home Reach Avenue TQ9 5FS Terraced February 2016 £2,917 South Hams - South Home Reach Avenue TQ9 5FS Detached April 2016 £2,883 South Hams - South Home Reach Avenue TQ9 5FS Semi December 2015 £3,243 South Hams - South

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Home Reach Avenue TQ9 5FS Detached December 2015 £3,072 South Hams - South Home Reach Avenue TQ9 5FS Detached December 2015 £2,875 South Hams - South Home Reach Avenue TQ9 5FS Semi December 2015 £3,235 South Hams - South Home Reach Avenue TQ9 5FS Semi April 2016 £3,294 South Hams - South Home Reach Avenue TQ9 5FS Semi December 2015 £3,235 South Hams - South Home Reach Avenue TQ9 5FS Semi February 2016 £3,308 South Hams - South Home Reach Avenue TQ9 5FS Semi December 2015 £3,294 South Hams - South Home Reach Avenue TQ9 5FS Semi February 2016 £3,235 South Hams - South Home Reach Avenue TQ9 5FS Semi November 2015 £2,700 South Hams - South Home Reach Avenue TQ9 5FS Semi June 2015 £3,045 South Hams - South Home Reach Avenue TQ9 5FS Semi November 2015 £2,700 South Hams - South Home Reach Avenue TQ9 5FS Semi July 2015 £2,989 South Hams - South Home Reach Avenue TQ9 5FS Semi November 2015 £3,142 South Hams - South Home Reach Avenue TQ9 5FS Semi October 2015 £3,308 South Hams - South Home Reach Avenue TQ9 5FS Semi December 2015 £3,114 South Hams - South Longstem Drive TQ9 6FS Detached October 2015 £3,660 South Hams - South Longstem Drive TQ9 6FS Semi October 2015 £3,316 South Hams - South Longstem Drive TQ9 6FS Semi February 2016 £3,158 South Hams - South Longstem Drive TQ9 6FS Detached January 2016 £3,217 South Hams - South Longstem Drive TQ9 6FS Semi November 2015 £3,434 South Hams - South Tremlett Grove TQ9 6FU Terraced October 2015 £2,931 South Hams - South Tremlett Grove TQ9 6FU Detached December 2015 £3,470 South Hams - South Tremlett Grove TQ9 6FU Terraced October 2015 £2,874 South Hams - South Tremlett Grove TQ9 6FU Semi July 2015 £2,931 South Hams - South Tremlett Grove TQ9 6FU Terraced July 2015 £2,931 South Hams - South Tremlett Grove TQ9 6FU Terraced January 2016 £3,247 South Hams - South Tremlett Grove TQ9 6FU Terraced June 2015 £3,560 South Hams - South Tremlett Grove TQ9 6FU Detached May 2015 £3,554 South Hams - South Tremlett Grove TQ9 6FU Terraced August 2015 £2,984 South Hams - South Tremlett Grove TQ9 6FU Terraced August 2015 £2,969 South Hams - South Tremlett Grove TQ9 6FU Terraced January 2016 £1,277 South Hams - South Tremlett Grove TQ9 6FU Terraced August 2015 £3,047 South Hams - South Shinners Bridge TQ9 6JA Terraced May 2015 £3,063 South Hams - South Cottages The Fallapit Estate TQ9 7AT Terraced July 2015 £1,905 South Hams - South Elderflower Barn TQ9 7ES Semi September 2015 £3,411 South Hams - South Hernaford Barns TQ9 7HY Terraced March 2015 £1,991 South Hams - South Hernaford Barns TQ9 7HY Terraced January 2015 £2,702 South Hams - South Crocadon Meadows TQ9 7LH Semi June 2015 £2,970 South Hams - South Harbertonford Mill TQ9 7RS Terraced October 2015 £3,351 South Hams - South Victoria Road TQ6 9DF Flat May 2015 £4,417 South Hams - South Longstem Drive TQ9 6FS Flat December 2015 £1,817 South Hams - South Tremlett Grove TQ9 6FU Flat August 2015 £2,816 South Hams - South The Fallapit Estate TQ9 7AT Flat June 2015 £2,262 South Hams - South

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West Devon

£ Per Location Postcode Type Date Broad Value Area Sqm

Broom Park Ex20 1ft Terraced September 2015 £2,122 West Devon - North Broom Park Ex20 1ft Semi November 2015 £2,193 West Devon - North Broom Park Ex20 1ft Semi December 2015 £2,193 West Devon - North Broom Park Ex20 1ft Detached November 2015 £2,161 West Devon - North Broom Park Ex20 1ft Semi November 2015 £2,426 West Devon - North Broom Park Ex20 1ft Semi November 2015 £2,346 West Devon - North Broom Park Ex20 1ft Semi November 2015 £2,205 West Devon - North Broom Park Ex20 1ft Semi November 2015 £2,229 West Devon - North Broom Park Ex20 1ft Semi December 2015 £2,205 West Devon - North Broom Park Ex20 1ft Semi December 2015 £2,169 West Devon - North Broom Park Ex20 1ft Semi December 2015 £2,204 West Devon - North Broom Park Ex20 1ft Semi February 2016 £2,229 West Devon - North Broom Park Ex20 1ft Semi February 2016 £2,168 West Devon - North Broom Park Ex20 1ft Semi February 2016 £2,228 West Devon - North Broom Park Ex20 1ft Semi March 2016 £2,264 West Devon - North Link Road Ex20 1fu Terraced February 2015 £1,959 West Devon - North Link Road Ex20 1fu Terraced January 2015 £1,793 West Devon - North Link Road Ex20 1fu Terraced September 2015 £2,068 West Devon - North Link Road Ex20 1fu Terraced August 2015 £2,095 West Devon - North Link Road Ex20 1fu Terraced August 2015 £2,123 West Devon - North Link Road Ex20 1fu Terraced February 2015 £1,959 West Devon - North Broom Park Ex20 1fw Semi December 2015 £2,284 West Devon - North Broom Park Ex20 1fw Semi December 2015 £2,352 West Devon - North Broom Park Ex20 1fw Semi September 2015 £2,275 West Devon - North Broom Park Ex20 1fw Detached February 2016 £2,133 West Devon - North Broom Park Ex20 1fw Semi June 2015 £2,182 West Devon - North Broom Park Ex20 1fw Semi June 2015 £2,195 West Devon - North Summering Close Ex20 1fx Semi February 2015 £2,171 West Devon - North Summering Close Ex20 1fx Semi March 2015 £2,143 West Devon - North Summering Close Ex20 1fx Semi February 2015 £2,200 West Devon - North Summering Close Ex20 1fx Semi March 2015 £2,176 West Devon - North Summering Close Ex20 1fx Semi March 2015 £2,128 West Devon - North Summering Close Ex20 1fx Detached April 2015 £2,113 West Devon - North Summering Close Ex20 1fx Semi June 2015 £1,951 West Devon - North Summering Close Ex20 1fx Semi June 2015 £2,134 West Devon - North Summering Close Ex20 1fx Semi September 2015 £2,062 West Devon - North Summering Close Ex20 1fy Semi March 2015 £2,108 West Devon - North

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Summering Close Ex20 1fy Semi February 2015 £2,169 West Devon - North Summering Close Ex20 1fy Detached June 2015 £2,122 West Devon - North Summering Close Ex20 1fy Terraced March 2015 £2,140 West Devon - North Summering Close Ex20 1fy Terraced March 2015 £2,200 West Devon - North Summering Close Ex20 1fy Terraced June 2015 £2,140 West Devon - North Summering Close Ex20 1fy Terraced June 2015 £2,043 West Devon - North Summering Close Ex20 1fy Terraced June 2015 £2,022 West Devon - North Summering Close Ex20 1fy Terraced June 2015 £2,022 West Devon - North Summering Close Ex20 1fy Terraced July 2015 £2,222 West Devon - North Summering Close Ex20 1fy Terraced July 2015 £2,211 West Devon - North Summering Close Ex20 1fy Terraced July 2015 £2,222 West Devon - North Crediton Road Ex20 1ly Terraced February 2016 £2,238 West Devon - North Crediton Road Ex20 1ly Terraced February 2016 £2,238 West Devon - North Summering Walk Ex20 1us Detached September 2015 £2,481 West Devon - North Cottles View Ex20 2fn Semi November 2015 £2,452 West Devon - North Livaton Ex20 2rb Detached June 2015 £1,567 West Devon - North Livaton Ex20 2rb Semi March 2015 £2,139 West Devon - North 0 EX20 Detached September 2015 £1,960 West Devon - North 4BX Gorbutt Gardens Pl19 9ah Detached March 2015 £3,400 West Devon - South Gorbutt Gardens Pl19 9ah Detached June 2015 £3,524 West Devon - South Philpott Lane Pl19 9fb Detached May 2015 £3,167 West Devon - South Drakes Park Pl20 7dy Semi July 2015 £2,940 West Devon - South Kellands Lane Ex20 1fs Semi May 2014 £2,012 West Devon - North Kellands Lane Ex20 1fs Semi May 2014 £2,073 West Devon - North Kellands Lane Ex20 1fs Semi May 2014 £2,043 West Devon - North Kellands Lane Ex20 1fs Semi February 2014 £2,165 West Devon - North Summering Close Ex20 1fx Semi June 2014 £2,228 West Devon - North Summering Close Ex20 1fx Semi December 2014 £2,285 West Devon - North Summering Close Ex20 1fx Semi October 2014 £2,285 West Devon - North Summering Close Ex20 1fx Semi November 2014 £2,229 West Devon - North Summering Close Ex20 1fx Semi December 2014 £2,071 West Devon - North Summering Close Ex20 1fx Semi December 2014 £2,071 West Devon - North Summering Close Ex20 1fx Semi September 2014 £2,168 West Devon - North Summering Close Ex20 1fy Semi June 2014 £2,108 West Devon - North Summering Close Ex20 1fy Semi June 2014 £2,168 West Devon - North Summering Close Ex20 1fy Semi September 2014 £2,084 West Devon - North Summering Close Ex20 1fy Semi October 2014 £2,168 West Devon - North Summering Close Ex20 1fy Semi April 2014 £2,108 West Devon - North Summering Close Ex20 1fy Semi December 2014 £1,964 West Devon - North Summering Close Ex20 1fy Semi December 2014 £2,198 West Devon - North Summering Close Ex20 1fy Detached December 2014 £2,350 West Devon - North Summering Close Ex20 1fy Semi April 2014 £2,096 West Devon - North Summering Close Ex20 1fy Semi August 2014 £2,084 West Devon - North

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Little Marsh Road Ex20 1ga Semi August 2014 £2,073 West Devon - North Little Marsh Road Ex20 1ga Semi June 2014 £2,024 West Devon - North Little Marsh Road Ex20 1ga Terraced August 2014 £2,220 West Devon - North Little Marsh Road Ex20 1ga Terraced May 2014 £2,279 West Devon - North Little Marsh Road Ex20 1ga Terraced April 2014 £2,042 West Devon - North Little Marsh Road Ex20 1ga Terraced February 2014 £2,042 West Devon - North Little Marsh Road Ex20 1ga Semi June 2014 £2,168 West Devon - North Little Marsh Road Ex20 1ga Semi July 2014 £2,048 West Devon - North Little Marsh Road Ex20 1ga Semi September 2014 £2,000 West Devon - North Little Marsh Road Ex20 1ga Semi June 2014 £2,156 West Devon - North Little Marsh Road Ex20 1ga Semi September 2014 £2,000 West Devon - North Little Marsh Road Ex20 1ga Semi June 2014 £2,145 West Devon - North Little Marsh Road Ex20 1ga Semi September 2014 £2,060 West Devon - North Hillside Drive Ex20 1un Detached June 2014 £2,027 West Devon - North Quant Park Pl19 0jq Terraced September 2014 £2,328 West Devon - South Philpott Lane Pl19 9fb Detached March 2014 £1,500 West Devon - South Marshall Road Pl19 9fg Detached July 2014 £2,689 West Devon - South Marshall Road Pl19 9fg Detached June 2014 £2,764 West Devon - South Marshall Road Pl19 9fg Detached October 2014 £2,713 West Devon - South Marshall Road Pl19 9fg Detached August 2014 £2,827 West Devon - South Stoneycliffe Place Pl20 6fg Detached November 2014 £1,541 West Devon - South Stoneycliffe Place Pl20 6fg Semi October 2014 £1,487 West Devon - South Harrowbeer Mews Pl20 6we Terraced July 2014 £2,522 West Devon - South Harrowbeer Mews Pl20 6we Terraced June 2014 £2,502 West Devon - South Harrowbeer Mews Pl20 6we Terraced May 2014 £2,473 West Devon - South Harrowbeer Mews Pl20 6we Terraced February 2014 £2,473 West Devon - South Fore Street Pl20 7ab Detached April 2014 £1,980 West Devon - South Fore Street Pl20 7ab Detached May 2014 £2,025 West Devon - South Fairplace Ex20 1dn Flat November 2015 £1,600 West Devon - North Fairplace Ex20 1dn Flat November 2015 £1,818 West Devon - North Fairplace Ex20 1dn Flat February 2015 £1,571 West Devon - North Fairplace Ex20 1dn Flat May 2015 £1,957 West Devon - North Fairplace Ex20 1dn Flat April 2015 £1,724 West Devon - North Fairplace Ex20 1dn Flat April 2015 £2,195 West Devon - North Fairplace Ex20 1dn Flat April 2015 £2,206 West Devon - North Sparrows Row Ex20 1fd Flat February 2015 £1,563 West Devon - North Sparrows Row Ex20 1fd Flat June 2015 £1,625 West Devon - North Sparrows Row Ex20 1fd Flat June 2015 £1,552 West Devon - North Broom Park Ex20 1ft Flat January 2016 £2,161 West Devon - North Broom Park Ex20 1ft Flat April 2016 £2,202 West Devon - North Link Road Ex20 1fu Flat October 2015 £2,023 West Devon - North Abbey Court Pl19 0ap Flat July 2015 £1,902 West Devon - South Parkwood Road Pl19 0hp Flat March 2015 £3,828 West Devon - South

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The Beeches Pl20 6fe Flat March 2015 £1,905 West Devon - South The Beeches Pl20 6fe Flat August 2015 £1,905 West Devon - South The Crescent Pl20 7ps Flat July 2015 £2,556 West Devon - South The Beeches Pl20 6fe Flat November 2014 £1,905 West Devon - South Harrowbeer Mews Pl20 6we Flat May 2014 £2,740 West Devon - South Harrowbeer Mews Pl20 6we Flat August 2014 £3,269 West Devon - South Harrowbeer Mews Pl20 6we Flat May 2014 £2,826 West Devon - South The Crescent Pl20 7ps Flat January 2014 £2,895 West Devon - South

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Appendix D Research on Non-Residential Units

Research on Retail – rents and yields

Rent (per Asking Rent (per Size Type Scheme Size (Sq.ft) sqm per Yield annum) (Sqm) annum) Convenience SPAR, Old Liara Rd £16,750 1,105 103 £163.16 8.50% Convenience Sainsburys, Mutley Plains £101,000 8,778 816 £123.85 5.75% Convenience Tesco Express, Wolsely Rd £60,000 5,059 470 £127.66 5.50% Convenience Co-op Exeter Rd 4.58% Supermarket Tesco Plymouth Rd £449,568 24,976 2,320 £193.75 5.00% Retail Park Coypool Retail Park £379,000 38,575 3,584 £105.76 9.40% Retail Park Friary Retail Park £225000 15,000 1,394 £161.00 9.50% Retail Park Plymouth Rd £66,955 3433 319 £209.93 7.61% Retail Park Laira Bridge Retail Park 7.25% Retail Park B&Q, Coypool Retail Park 6.90% Retail Park Crownhill Retail Park 6.80% Local centre , Plymouth 9.33% Local centre Fore St, Kingsbridge £11,879 684 64 £186.94 8.75% Local centre Morshead Rd £10,300 436 41 £254.29 8.49% Local centre Wolseley Rd £27,800 2,527 235 £118.42 8.16% Local centre Mutley plain, Plymouth 6.58% Local centre Brook St, Tavistock £45,000 3,705 344 £130.74 6.54% Town centre Retail Fore St, Ivybridge 9.20% Town centre Retail New George St £36,000 4,032 375 £96.11 9.15% Town centre Retail New George St 8.50% Town centre Retail New George St £104,600 4,098 381 £274.75 8.00% Town centre Retail High St Totnes £10,750 829 77 £139.58 7.60% Town centre Retail West, St Tavistock 7.51% Town centre Retail New George St 7.50% Town centre Retail Beaumont Rd 7.00% Town centre Retail Fore St, Kingsbridge £8,000 743 69 £115.90 6.67% Town centre Retail Fairfax Pl, Dartmouth £24,000 329 31 £785.21 6.36% Town centre Retail Derry’s Cross 6.13% Town centre Retail Duke St, Tavistock 6.00% Town centre Retail Fore St, Kingsbridge £11,879 351 33 £364.29 5.57% Drake Circus Shopping Town centre Retail £130,000 1,473 137 £949.97 5.87% Centre

Wider Research on Supermarkets

Store Operator Location Rent (sqm) Yield New Date store Morrisons South Shields £137 5.25% N Jun-10

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Store Operator Location Rent (sqm) Yield New Date store Sainsburys Truro 4.65% N Nov-11 Waitrose Crewkerne £238 5% N Dec-15 Morrisons Burnham On Sea 5% N June-13 Tesco Tavistock £194 5% N Aug-15 Sainsburys Torpoint £146 6.75% N Jan-15 Waitrose Rickmansworth £211 4% N Oct-10 M&S Simply Food Maldon £197 5.58% N Jun-08 Waitrose Hornchurch, London £186 4.43% N Unknown Sainsbury’s Tooting £253 4.50% Y Mar-11 Tesco Welling High St, Bexley £232 4.75% Y Nov-10 Waitrose Clerkenwell, London £226 4.20% Y Nov-09 ASDA Bangor £204 5% Y Jun-11 Tesco Extra Coventry £168 4.11% N Unknown Waitrose Crowborough £192 5.04% N Unknown Tesco Metro London N7 £193 5.25% N Unknown Sainsbury’s Londonderry £167 5.36% N Unknown Waitrose Wantage £172 4.50% N Unknown Tesco Wembley £317 5.50% Y Sep-12 Tesco Congleton - 4.90% Y Jun-12 Tesco Glastonbury - 4.50% Y Apr-12 Tesco St Ives - 4.90% Y Jan-12 Tesco Tiptree £236 4.90% Y Jan-12 Tesco Cross Point, Coventry - 4.57% Y Sep-11 Tesco Keynsham - 4.96% Y Aug-11 Tesco Ruthin £161 4.96% Y Aug-11 Tesco Welling - 5% Y Jul-11 Tesco Cardiff - 4.50% N Feb-11 Tesco Investment Chatteris - 5% Y Sep-12 Tesco Investment Gosport £215 5% Y Apr-12 Tesco Investment Corby £215 4.60% Y Oct-11 Tesco Investment Welling High St, Bexley £232 4.75% Y Jun-11 Sainsbury’s Putney £273 4% N Current Tesco Perth £212 4.35% N Aug-13 Sainsbury’s Sale £242 4.10% N Aug-13 Sainsbury’s Hythe £226 4.10% Y Aug-03 Sainsbury’s Ashford £248 4.10% Y Aug-13

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Store Operator Location Rent (sqm) Yield New Date store Morrisons Milton Keynes £242 4.25% Y Jul-13 Morrisons Edgware Road, London £286 4.60% Y Jan-13 Sainsbury’s Harrow Manor Way, £237 4.50% Y Jan-13 London Sainsbury’s March £194 4.76% N Jul-13 Morrisons Aldershot £224 4.25% Y Apr-13 Sainsbury’s Hayes £331 4.19% Y Apr-13 Tesco Oldham £181 5.28% N Current ASDA Torquay £248 N Nov - 11

Wider Research on Smaller Supermarkets (rents)

Broad Location Tenant Achieved Transaction rent per date sqm Cheshire Aldi Stores Ltd £137 2013 West Midlands Aldi Ltd £147 2013 Merseyside Aldi £152 2011 London Lidl Ltd £161 2008 West Midlands Iceland Foods Plc £161 2008 Nottinghamshire ALDI, Inc. £171 2006 Suffolk ALDI, Inc. £175 2013 Cheshire Aldi Stores Ltd £191 2009 Essex Lidl Ltd £191 2008 London Lidl Ltd £279 2010 Essex Tesco £137 2012 Torbay Iceland Foods Plc £310 2008 Essex Tesco £136 2011

Wider Research on Smaller Supermarkets (yields)

Broad Location Tenant Yield Transaction Date Lancashire Aldi Stores Ltd 6.25 2009 Not Disclosed Lidl Ltd, 6.5 2010 Co Durham Lidl UK Properties GmbH, 7.46 2010 Middlesex Lidl Ltd 4.15 2009 London Lidl (UK) GMBH 5.5 2006 Staffordshire n/a 5.2 2005

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West Glamorgan Lidl Ltd 5.76 2005 Avon n/a 5.75 2005

Research on Town Centre Offices

Scheme Location Size Rent (p.a.) (sqm) per sqm

12a Mayors Ave Dartmouth 550 £281.80 Central Ct Ivybridge 476 £84.82 Cranmere Rd West Devon 3874 £94.51 Millbay Rd Plymouth 4412 £106.78 Millbay Rd Plymouth 619 £154.25 Millbay Rd Plymouth 899 £119.69 Millbay Rd Plymouth 4412 £107.75 Millbay Rd Plymouth 1313 £118.40 Millbay Rd Plymouth 852 £118.40 Millbay Rd Plymouth 551 £112.38 Coburg House, Plympton Plymouth 212 £139.00 Lynher Building Plymouth 114 £168.00 North Hill Plymouth 118 £148.00 Prideaux Court Plymouth 153 £113.00 Lockyer St Plymouth 96 £141.00 Tamar House Plymouth 2947 £113.66 Island St Salcombe 355 £151.56 Fore St, Ivybridge South Hams 48 £110.00 West Street, Tavistock South Hams 23 £130.00 Drake Rd Tavistock 1723 £106.24 Kilworthy Hl Tavistock 1500 £107.64

Research on Business Park Offices

Scheme Location Size Rent (p.a.) (sqm) per sqm

12 William Prance Rd Plymouth 1718 £98.71 61 Longbridge Rd Plymouth 1470 £64.58 61 Longbridge Rd Plymouth 1470 £64.58 41 Estover Close Plymouth 4540 £82.15 Forresters Business Park Plymouth 1836 £107.64 Endeavor House, Parkway court Plymouth 314 £99.00 Follot House Plymouth 258 £118.00 Darklake view, Estover Plymouth 662 £30.00 Envoy House Plymouth 137 £118.00

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Argosy House Plymouth 118 £106.00 Brooklands Plymouth 103 £117.00 Plymouth International Medical Plymouth 1329 £140.55 Endurance House Plymouth 618 £126.66 Beaumont House Plymouth 1052 £95.09 Ash House, Canal Way South Hams 543 £96.00 Langage Business Park South Hams 140 £121.00 Modbury House, Ivybridge South Hams 127 £133.00 Langage Office Campus South Hams 5582 £169.74 Crelake Industrial estate, Tavistock West Devon 293 £72.00

Research on Town centre office and business park yields

Type Scheme Yield (%)

Business Park Plymouth International Medical 8.61%

Business Park Endurance House 8.50% Business Park Langage Office Campus 7.75% Town Centre Tamar House 9.55% Town Centre Beaumont House 7.50%

Research on Industrial Units – Rents & Yields

Scheme Asking Rent (per Size Size (Sqm) Rent (per Yield annum) (Sq.ft) sqm per annum)

Faraday Business Park £18,000 2,891 269 £67.02 12.33% Billacombe Rd £84,000 7,660 712 £118.04 10.55% Drake Mill Business Park £189,400 84,936 7,891 £24.00 10.50% Phoenix Business Park £165,940 41,010 3,810 £43.55 8.88% St Modwen Way £298,000 66,221 6,152 £48.44 8.66%

Lee Mill Industrial estate £26,000 4,948 460 £56.56 8.55%

Hannaford’s Landing 7.75% Langage Science Park £257,500 59,736 5,550 £46.40 7.60%

Research on Student Accommodation

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Net rent £/per £/per down to Total Beds bed per Capitlised Plymouth Provider bed per allow for Beds (nr) wk, Wks/yr value p.a. mngmt 2015/16 costs

43 £135 41 £5,535 35% £2,524,323 43 £147 41 £6,027 35% £2,748,707 Discovery PU/Unite 214 43 £135 51 £6,885 35% £3,140,011 Heights 43 £155 41 £6,355 35% £2,898,297 43 £155 51 £7,905 35% £3,605,198 100 £91 40 £3,640 35% £3,878,689 Gilwell PU 200 100 £93 40 £3,720 35% £3,963,934 52 £135 41 £5,535 35% £3,086,594 Mary PU 157 52 £139 41 £5,699 35% £3,178,049 Newman 52 £147 41 £6,027 35% £3,360,958 59 134 40 £5,360 35% £3,384,049 59 141 40 £5,640 35% £3,560,828 Pilgrim PU 237 59 146 40 £5,840 35% £3,687,098 59 155 40 £6,200 35% £3,914,385 110 £135 40 £5,400 35% £6,310,328 Francis Drake PU 329 110 £147 40 £5,880 35% £6,871,246 110 £155 40 £6,200 35% £7,245,191 136 £134 40 £5,360 35% £7,767,607 Radnor PU 408 136 £146 40 £5,840 35% £8,463,213 136 £155 40 £6,200 35% £8,984,918 143 £98 40 £3,920 35% £5,987,104 Robbins PU 430 143 £103 40 £4,120 35% £6,292,568 143 £124 40 £4,960 35% £7,575,519 Alexandra PU/Unite 246 246 £121 43 £5,203 35% £13,638,684 Works Towers Central Park Lettings & 205 205 £127 44 £5,588 35% £12,206,574 Towers Manageme nt

45 £140 44 £6,160 35% £2,931,891 Frobisher PU 134 House 45 £145 44 £6,380 35% £3,036,601 45 £160 44 £7,040 35% £3,350,732

St Teresa 54 £110 43 £4,730 35% £2,721,689 PU/Unite 108 House 54 £146 43 £6,278 35% £3,612,423

St Thomas 114 £126 43 £5,418 35% £6,552,671 PU/Unite 227 Court 114 £144 43 £6,192 35% £7,488,767 Prodigy 130 £125 44 £5,500 35% £7,589,549 Astor House 518 Living 130 £137 44 £6,028 35% £8,318,146

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Net rent £/per £/per down to Total Beds bed per Capitlised Plymouth Provider bed per allow for Beds (nr) wk, Wks/yr value p.a. mngmt 2015/16 costs

130 £146 44 £6,424 35% £8,864,593 130 £151 44 £6,644 35% £9,168,175

4 £118 48 £5,664 35% £256,505 Student The Square Rooms 4 17 4 £128 48 £6,144 35% £278,243 Plymouth 4 £126 48 £6,048 35% £273,895 4 £149 48 £7,152 35% £323,892

6 £114 48 £5,472 35% £335,272 Student The Cube Rooms 4 23 6 £118 48 £5,664 35% £347,036 Plymouth 6 £120 48 £5,760 35% £352,918 6 £117 48 £5,616 35% £344,095

Metro 6 £85 48 £4,080 35% £246,361 The Mutley Student 17 Tavern Accommoda tion 6 £90 48 £4,320 35% £260,852 6 £128 48 £6,144 35% £370,990 14 £129 51 £6,579 35% £1,001,487 14 £159 51 £8,109 35% £1,234,391 14 £165 51 £8,415 35% £1,280,972 Central Point Unite 100 14 £169 51 £8,619 35% £1,312,026 14 £134 51 £6,834 35% £1,040,304 14 £138 51 £7,038 35% £1,071,358 14 £149 51 £7,599 35% £1,156,756 13 £125 44 £5,500 35% £761,885 Primo 13 £135 44 £5,940 35% £822,836 The Court Property 65 13 £145 44 £6,380 35% £883,787 House Developme nts 13 £155 44 £6,820 35% £944,738 13 £160 44 £7,040 35% £975,213 St Augustine's Collegiate 89 89 £250 51 £12,750 35% £12,091,598 House AC 35 £141 43 £6,063 35% £2,228,898 35 £146 43 £6,278 35% £2,307,937 35 £155 43 £6,665 35% £2,450,207 The Old Dairy Victorial 35 £160 43 £6,880 35% £2,529,246 (brand new 276 Hall for 2017/18) 35 £135 51 £6,885 35% £2,531,084 35 £140 51 £7,140 35% £2,624,828 35 £153 51 £7,803 35% £2,868,562 35 £158 51 £8,058 35% £2,962,306 Average 200 200 £138 45 £6,195 35% £13,203,462

J:\33852 Plymouth Viability Partnering\Reporting\003 Local Plan Viability Report\Plymouth & SW Devon JLP Viability Report.docx Plymouth & SW Devon JLP Viability Update Final Report

J:\33852 Plymouth Viability Partnering\Reporting\003 Local Plan Viability Report\Plymouth & SW Devon JLP Viability Report.docx