Demystifying viability The local authority experience Dominick Mennie, Deputy Team Leader (Plan Making)

SETTING THE SCENE

Welcome to Croydon Croydon

Welcome to Croydon

Developing Croydon Small schemeMedium scheme

Developing Croydon Smaller schemeMedium scheme

Developing Croydon

BrownfieldGreenfield

Developing Croydon

Planning Croydon

50% affordable housing Minimum 15% affordable on-site Commuted sum for affordable housing on all minor residential schemes Mayor of London space standards Code Level 4 for all new build homes Eco Homes Very Good for all change of use to residential BREEAM Excellent for all new build non- residential The Croydon Local Plan: Strategic Policies BREEAM Very Good for all change of use to non- residential

Croydon’s Community Infrastructure Levy Development type Croydon Metropolitan Centre Rest of borough ResidentialNil£120 per m 2 Business£120 per m 2 Nil InstitutionsNil All other uses£120 per m 2

VIABILITY TESTING THE CROYDON LOCAL PLAN: STRATEGIC POLICIES

Viability testing the Plan

Affordable Housing Viability Assessment Only as good as the numbers that go into it S.106/CIL? Local build costs? Appraisal model? Do stakeholders agree?

Choosing sites to test

Setting an affordable housing target from the viability evidence

Facilitating development across the economic cycle

Sustainability requirements of non-residential buildings Costs can be reduced if sustainability is built in at the design stage - strong policies don’t necessarily increase costs…

CONSIDERING VIABILITY OF OUR CIL CHARGING SCHEDULE

If you do CIL on its own… You can use different consultants…

CIL viability is not the same as the infrastructure funding gap Infrastructure funding gap not relevant to viability

What we did do about viability testing CIL Existing viability work Sustainability Affordable housing

Choosing sites to test

But not just residential so…

And later on we thought that…

A question for you… What was the difference between the sites we tested for CIL and the typical Croydon developments? Answer?

We didn’t test the viability of…

The end result

Our (then) draft CIL rates

THE EXAMINATIONS

A tale of two examinations The Local Plan Community Infrastructure Levy

The Croydon Local Plan: Strategic Policies Examination

What the inspector asked Minimum affordable housing Geographical variations Impact on housing numbers

The evidence we presented Housing SourceViableNot Viable SHLAA sites with planning permission 1,090n/a SHLAA sites without permission 1,1751,053 Windfall sites2,5401,107 Under construction656n/a Non self-contained homes 910No affordable requirement Empty homes returned to use 200No affordable requirement Sites in Croydon Opportunity Area 4,685Flexible policy to ensure viability of key regeneration area. Total11,2562,160

What the inspector concluded “Undoubtedly the affordable housing policies are complex but they are an attempt by the Council to meet the considerable demand for affordable housing is met while ensuring that the required level of affordable housing remains economically viable in changing market conditions.”

The Draft CIL Charging Schedule Examination

What the examiner asked Site sample Assumptions Planning for the future Geographical variations Risk to development

The challenges at the examination

What the examiner concluded “While it may be that the viability of certain marginal schemes would be adversely affected, the evidence is that Draft Charging Schedule would not put the overall development of the area at serious risk.”

Benefits of back-to-back examinations Cost to the councilEfficiency

IMPLEMENTATION

Croydon Local Plan: Strategic Policies Educating others Don’t forget practical issues

Community Infrastructure Levy Collecting authority Liable Party Developer/ Land owner) Submit Notice of Chargeable Development Submit Assumption of Liability Notice Receive Assumption of Liability Notice and acknowledge Issue Liability Notice Receive Liability Notice (consider appeal) Submit Commencement Notice minimum (1 day before commencement) Receive Commencement Notice and acknowledge Issue Demand Notice Receive Demand Notice Commencement development and start making payments Receive payments and issue receipts for each one received Receive Notice of Chargeable Development Planning Application Grant planning permission Determine the deemed commencement date Submission of relief forms / Instalment policy engaged

Community Infrastructure Levy Regulation vagueness Regulation processes

And the developers? Largely supportive Like certainty Dislike CIL => S.106

LESSONS LEARNT

What we would do differently Test even smaller developments Update policy Manage consultants better! More sites???

And what we would not change Project team approach IDP ready in advance Use of consultants

Concluding thoughts

Thank you for listening