Stage C Evidence Base

Comment

Representation ID: 23189

Received: 27/04/2020

Respondent: Persimmon Homes (Anglia)

Number of people: 4

Agent: Bidwells

Viability Inputs
127. Revenues are overstated and unsubstantiated.
128. Discounts to affordable rent tenure are too low and do not reflect registered provider bids in the current market.
129. Build costs adopted are below BCIS median rates. No explanation or rationale is provided for this.
130. Build costs make no allowance for Part L of the 2020 Building Regulations nor for
regulations M49”) and M4(3).
131. The allowance for Site and Infrastructure works is likely to prove inadequate for most schemes. This allowance should not include the cost of garages which are a build cost.
132. Benchmark land values have been reduced by 30% from the 2017 Hamson report without any reference to data, reasoning or justification. The levels adopted are likely to prevent land coming forward for development.
133. The outcome of using the inputs chosen in the interim study produces appraisals that
very significantly over-state viability.

Typologies
134. We have focussed only on Typology 9 in this report. We make no comment about any other typologies.
135. A Typology for large (1,000 unit plus) schemes should be provided accounting for the specific infrastructure and community facilities these sites are expected to provide.
136. Without this typology, the study cannot be considered complete.

Appraisals
137. Based on our review of Typology 9 only, we consider the methodology adopted in the preparation of the appraisals to be sound.
138. We cannot calculate the interest charges to match those used in the interim study, but this is not unusual when comparing viabilities.

General
139. We are concerned that the instructions to the consultant that prepared the interim study are not made clear in the report. We are also concerned that there may be a conflict of interest that has not been declared.
140. Both issues undermine the veracity of the report and its conclusions, especially when combined with the consistent adoption of inputs that improve viability.
141. We are especially concerned at the lack of background data, reasoning and justification for many of the inputs to the interim study.

142. We therefore conclude that the NPS Interim Viability Study does not provide a reliable, robust or accurate assessment of viability for the purposes of the emerging GNLP