Publication

The BLV should be re-assessed and justified by reference to the data provided at Appendix H of the Viability Assessment and, adopting appropriate methodology and bearing in mind the requirement for a reasonable incentive for land-owners to release land for development, should reach a more logical conclusion on BLV.

Benchmark Land Value (BLV)

1. BLV adopted has not been justified by reference to any evidence, collaborative process or appropriate methodology.

2. The data provided contradicts the Benchmark Land Value assesed.

3. The BLV adopted is 72% less than the last estimate of BLV provided by Hamson in 2017.

4. The BLV adopted is below the minimum return a reasonable landowner would accept.

5. As a consequence, land will not be brought forward for development which in turn will prevent the new plan meeting its objectives.

The net developable area for Typology 11 should be re-assessd.

Typology 11 - Unrealistic Gross to Net Areas Assumption

The Viability Assessment (VA) assumes a net to gross ration of 88% for Typology 11. This is not practical or feasible in reality. as demonstrated by a recent application of a similar sized site (2019/1370) which showed 49% net to gross ratio.

The VA assumes that all informal open space will be provided off-site. This is unlikely to be acceptable in reality.

There is no allowance made for infrastructure provision on large sites

The purpose of the Local Plan Viability is to assess the revenues that will be generated and that can only be reliably assessed using actual sales data.

Re-assess revenues using Land Registry data only.

Revenue Assumuptions Not Sound

From our own research of actual sales data, we consider the revenues adopted in the Viability Assessment (VA) to be excessive.

Revenues should be calculated using Land Registry sale price data, not asking prices.

Inaccurate revenues distort the outcome of the viability assessment and should be re-assessed.

Developer profit should be at 20% of GDV as set out in the interim viability study.

Developer Profit - No evidence provided for a reduction from 20% in the interim study to 17.5% in the final Viability Assessment (VA)

We consider this reduction to be arbitrary, un-evidenced and unjustified.

Build costs for flats should be based on the appropriate BCIS rate for flats, not an artificially adjusted figure sourced from the BCIS build costs of houses.

Build Costs - Apartments

The Viability Appraisal has an error in the calculation of build costs for apartments at para 199.