Item8Appendix3ValuationReportAffordableHousingLandValuationsandCommutedSumPayments

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 Appendix 3 14/05/2021

AGENDA ITEM 8

APPENDIX 3

VALU­ATION REPORT FOR CNPA: AFFORD­ABLE HOUS­ING LAND VALU­ATIONS AND COM­MUTED SUM PAYMENTS

Valu­ation Office Agency

DVS Prop­erty Specialists

Valu­ation Report for Cairngorms Nation­al Park Author­ity: Afford­able Hous­ing Land Valu­ations and Com­muted Sum Payments

Stra­tegic Set­tle­ment GRANT­OWN-ON-SPEY A9 to Inverness Inter­me­di­ate Set­tle­ment Rur­al Set­tle­ment Stra­tegic Plan­ning Consent/​New Set­tle­ment A939 to Forres A95 to Aber­lour Glen­liv­et Crom­dale Dul­nain Bridge Carr-Bridge Nethy Bridge Tomin­toul Boat of Garten. AVIEMOREAN CAMAS MÒR Glen­more Kin­craig KIN­GUSSIE Inver­druie & Insh Coylumbridge NEW­TON­MORE Lag­gan A86 to Spean Bridge Dal­whin­nie Calv­ine, Bru­ar & Pit­agow­an 45% AFFORD­ABLE Brae­mar HOUS­ING REQUIRE­MENT Strath­don A944 to Alford Din­net BAL­LATER A93 to Aboyne Angus Glens Glen­shee née Blair Atholl Kil­liecrankie A9 to Perth A93 to Blair­gowrie The VOA is an Exec­ut­ive Agency of HM Rev­en­ue and Customs

Report for: Dan Har­ris Cairngorms Nation­al Park Authority

Pre­pared by: Kate Paton MRICS Seni­or Sur­vey­or RICS Registered Valu­er DVS

Tel: 03000 506234

kate.​paton@​voa.​gov.​uk

Case Num­ber: 1749005

Cli­ent Ref­er­ence: CNP7603

Date: 13 Novem­ber 2020

dis­ab­il­ity con­fid­ent EMPLOYER

Cli­ent Ref: CNP7603 VOA Ref: 1749005 Date: 13 Novem­ber 2020

Con­tents

DVS Prop­erty Specialists

Exec­ut­ive Sum­mary. 1

1. Intro­duc­tion 3

2. Valu­ation Para­met­ers 3

3. Prop­erty Inform­a­tion 7

4. Valu­ation. 18

5. Gen­er­al Inform­a­tion .32

6. Appen­dices .34 6.1 Map 34 6.2 Brief. .35

Cli­ent Ref: CNP7603 VOA Ref: 1749005 DVS Prop­erty Spe­cial­ists Date: 13 Novem­ber 2020

Exec­ut­ive Summary

1.1 Descrip­tion

Cairngorms Nation­al Park Author­ity (CNPA) have com­mis­sioned research to determ­ine at what level a com­muted sum, defined as a ​‘fin­an­cial con­tri­bu­tion to afford­able hous­ing’ should be set for each of the Loc­al Author­ity areas in the Nation­al Park area and for the Nation­al Park as a whole, for devel­op­ments under 4 units.

1.2 Loc­a­tion

The com­muted pay­ment policy is to apply to the CNPA area.

1.3 Ten­ure

Owner’s her­it­able interest with vacant possession.

1.4 Valu­ation Date

13 Novem­ber 2020

1.5 Meth­od­o­logy and Basis of Valuation

The meth­od­o­logy used to arrive at the level of developer con­tri­bu­tion is taken as being the dif­fer­ence between the value of land for afford­able hous­ing and the mar­ket value of the land for private res­id­en­tial development,

Although my advice will not con­sti­tute a form­al valu­ation, it will gen­er­ally accord with the concept of Mar­ket Value, which is defined at VPS 4, para 4 as:

‘The estim­ated amount for which an asset or liab­il­ity should exchange on the valu­ation date between a will­ing buy­er and a will­ing seller in an arm’s length trans­ac­tion after prop­er mar­ket­ing and where the parties had each acted know­ledge­ably, prudently and without compulsion.’

1.6 Spe­cial Assumptions

The valu­ations are for notion­al house plots for the erec­tion of a four apartment/​three bed­room detached house with­in each of the Loc­al Author­ity Areas with­in the Nation­al Park and a valu­ation for the Nation­al Park as a whole as shown on the Bound­ary Map at Appendix 2.

LDG21a (16.09.20) Private and Con­fid­en­tial Page 1

Cli­ent Ref: CNP7603 VOA Ref: 1749005 DVS Prop­erty Spe­cial­ists Date: 13 Novem­ber 2020

1.7 Mar­ket Value

The opin­ion of Mar­ket Value of the owner’s her­it­able interest with vacant pos­ses­sion of the notion­al house plots and the res­ult­ant com­muted sums are as follows:

LA area	Afford­able Hous­ing Plot value	Private Hous­ing Plot Value	Com­muted Payment
Aber­deen­shire	£0	£32,500	£32,500
Angus	£0	£16,000	£16,000
High­land	£0	£18,500	£18,500
Moray	£0	£17,000	£17,000
Perth and Kinross	£0	£30,000	£30,000
CNPA (aver­age of 5 LA)	£0	£23,000	£23,000

1.8 Remarks

The land val­ues for the unres­tric­ted plots are based on the assump­tions stated with­in the report, spe­cif­ic sites with abnor­mal costs relat­ing to infra­struc­ture, site con­di­tions or plan­ning oblig­a­tions could well pro­duce dif­fer­ent plot val­ues. Sim­il­arly if the char­ac­ter­ist­ics of the notion­al unit were to change, then high­er or lower val­ues could be generated.

As the hypo­thet­ic­al site could be loc­ated any­where with­in the radi­us of the Loc­al Author­ity areas as shown, val­ues in real­ity would likely vary with­in each area and there would likely be some ​‘blur­ring’ at the bor­ders of the author­ity areas.

LDG21a (16.09.20) Private and Con­fid­en­tial Page 2

Cli­ent Ref: CNP7603 VOA Ref: 1749005 DVS Prop­erty Spe­cial­ists Date: 13 Novem­ber 2020

1. Intro­duc­tion

I refer to your ori­gin­al enquiry dated 11 Feb­ru­ary 2020 and sub­sequent email exchanges and my email of 19 March 2020, which included my fee quote. The case was put on hold for a num­ber of weeks as a res­ult of the Cov­id-19 pan­dem­ic, how­ever you advised CNPA still required the advice in an email dated 14 August 2020 and I was able to con­firm the fee quote was still val­id. A pur­chase order num­ber was received on 2 Septem­ber and the case was taken on.

I also refer you to my Terms of Engage­ment dated 3 Septem­ber 2020.

I have car­ried out the valu­ations and I am pleased to report to you as follows.

1. Valu­ation Parameters

2.1 Iden­ti­fic­a­tion of Client

The valu­ation advice is pre­pared for CNPA.

2.2 Pur­pose of Valuation

It is under­stood that you require the valu­ation advice in order to assess at what level a com­muted sum, which is defined as a ​“fin­an­cial con­tri­bu­tion to afford­able hous­ing” should be set for each of the Loc­al Author­ity area in the Nation­al Park area and the Nation­al Park as a whole, for devel­op­ments under 4 units.

2.3 Sub­ject of the Valuation

The valu­ations are for notion­al house plots for the erec­tion of a four apartment/​three bed­room detached house with­in a devel­op­ment of around ten houses in each of the five Loc­al Author­ity Areas with­in CNPA, and also valu­ations for the CNPA area as a whole (as shown on the Map at Appendix 2 and the maps of the Hous­ing Mar­ket Areas in Sec­tion 3.1)

2.4 Date of Valuation

The date of valu­ation is 13 Novem­ber 2020.

Please note that val­ues change over time and that a valu­ation giv­en on a par­tic­u­lar date may not be val­id on an earli­er or later date.

2.5 Con­firm­a­tion of Standards

The valu­ation has been pre­pared in accord­ance with the pro­fes­sion­al stand­ards of the Roy­al Insti­tu­tion of Chartered Sur­vey­ors: RICS Valu­ation – Glob­al Stand­ards and RICS UK Nation­al Sup­ple­ment, com­monly known togeth­er as the Red Book.

LDG21a (08.20) Private and Con­fid­en­tial Page 3

Cli­ent Ref: CNP7603 VOA Ref: 1749005 DVS Prop­erty Spe­cial­ists Date: 13 Novem­ber 2020

2.6 Com­pli­ance with the RICS pro­fes­sion­al stand­ards and valu­ation prac­tice state­ments gives assur­ance also of com­pli­ance with the Inter­na­tion­al Valu­ations Stand­ards (IVS).

Meas­ure­ments stated are in accord­ance with the RICS Pro­fes­sion­al State­ment ​‘RICS Prop­erty Meas­ure­ment’ (2^nd Edi­tion) and, where rel­ev­ant, the RICS Code of Meas­ur­ing Prac­tice (6^th Edition).

As spe­cific­ally reques­ted by you, the res­id­en­tial prop­erty has been repor­ted upon using a meas­ure­ment stand­ard oth­er than IPMS, and spe­cific­ally Gross Intern­al Area (GIA) has been used. Such a meas­ure­ment is an agreed depar­ture from ​‘RICS Prop­erty Meas­ure­ment (2^nd Edition)’.

2.7 Agreed Depar­tures from the RICS Pro­fes­sion­al Standards

As spe­cific­ally reques­ted by you, and as cap­tured above with explan­a­tion, cer­tain prop­erty has been repor­ted upon using a meas­ure­ment stand­ard oth­er than IPMS.

2.8 Basis of Value

Although my advice will not con­sti­tute a form­al valu­ation, it will gen­er­ally accord with the concept of Mar­ket Value, which is defined at VPS 4, para 4 as:

The basis of value adop­ted is Mar­ket Value which is defined at VPS 4, para 4 as:

‘The estim­ated amount for which an asset or liab­il­ity should exchange on the valu­ation date between a will­ing buy­er and a will­ing seller in an arm’s length trans­ac­tion after prop­er mar­ket­ing and where the parties had each acted know­ledge­ably, prudently and without compulsion.’

2.9 Spe­cial Assumptions

The fol­low­ing agreed spe­cial assump­tions have been applied:

The valu­ations are for notion­al house plots and the fol­low­ing assump­tions have been applied:

• The house plots are for the erec­tion of a stand­ard new build four apartment/​three bed­room detached house of approx­im­ately 96m² GIA.
• It should be assumed that it has private garden grounds, off-street park­ing but no garage.
• The plot will be ready for devel­op­ment with ser­vices loc­ated close by, which is in line with sec­tion 22 of PAN 2/2010 Afford­able Hous­ing and Hous­ing Land Audits, which states the com­muted sum should be of ​‘a value equi­val­ent to the cost of provid­ing the amount of ser­viced land required by the policy’.

2.10 Nature and Source of Inform­a­tion Relied Upon

In addi­tion to rely­ing upon VOA held records and inform­a­tion, I have assumed that all inform­a­tion provided by, or on behalf of you, in con­nec­tion with this instruc­tion is cor­rect without fur­ther veri­fic­a­tion – for example, details of ten­ure, ten­an­cies, plan­ning con­sents, etc.

LDG21a (16.09.20) Private and Con­fid­en­tial Page 4

Cli­ent Ref: CNP7603 VOA Ref: 1749005 DVS Prop­erty Spe­cial­ists Date: 13 Novem­ber 2020

My advice is depend­ent upon the accur­acy of this inform­a­tion and should it prove to be incor­rect or inad­equate, the accur­acy of my valu­ation may be affected.

You provided a Brief out­lining the approach, meth­od­o­logy expec­ted and back­ground inform­a­tion along with your instruc­tions (copied in Appendix 6.2).

The valu­ation meth­od­o­logy is out­lined below in sec­tion 4 with ref­er­ence to the Scot­tish Gov­ern­ment PAN2/2010, More Homes Divi­sion Guid­ance Notes ²⁰²⁰⁄₀₂ and the guid­ance notes issued by the RICS, in par­tic­u­lar ​‘Valu­ation of Land for Afford­able Hous­ing Scot­land’ GN100/2013, VIP 12 ​‘Valu­ation of Devel­op­ment Land’ and RICS ​“Valu­ation of Devel­op­ment Prop­erty” Octo­ber 2019.

I have also had regard to the Loc­al Plans and Sup­ple­ment­ary Plan­ning Guid­ance pub­lished on the inter­net by the rel­ev­ant Loc­al Authorities.

In under­tak­ing my research I have also used prop­erty mar­ket­ing web­sites such as TSPC, ASPC, Right­move and loc­al Estate Agents websites.

2.11 Date of Inspection

The valu­ation reflects notion­al house plots and no inspec­tions were undertaken.

2.12 Extent of Invest­ig­a­tions, Sur­vey Restric­tions and Assumptions

An assump­tion in this con­text is a lim­it­a­tion on the extent of the invest­ig­a­tions or enquir­ies under­taken by the valu­er. The fol­low­ing agreed assump­tions have been applied in respect of your instruc­tion, reflect­ing restric­tions to the extent of our investigations.

• As agreed with you, no inspec­tion of the prop­erty was under­taken and the advice and valu­ation has been pre­pared on a ​‘desk-top basis’; i.e. it is provided on the basis of ​‘restric­ted information’.

• No detailed site sur­vey, build­ing sur­vey or inspec­tion of covered, unex­posed or inac­cess­ible parts of the prop­erty was under­taken. The Valu­er has had regard to the appar­ent state of repair and con­di­tion, and assumed that inspec­tion of those parts not inspec­ted would neither reveal defects nor cause mater­i­al alter­a­tion to the valu­ation, unless aware of indic­a­tion to the con­trary. The build­ing ser­vices have not been tested and it is assumed that they are in work­ing order and free from defect. No respons­ib­il­ity can there­fore be accep­ted for iden­ti­fic­a­tion or noti­fic­a­tion of prop­erty or ser­vices’ defects that would only be appar­ent fol­low­ing such a detailed sur­vey, test­ing or inspection.

• It has been assumed that good title can be shown and that the prop­erty is not sub­ject to any unusu­al or oner­ous restric­tions, encum­brances or outgoings.

LDG21a (16.09.20) Private and Con­fid­en­tial Page 5

Cli­ent Ref: CNP7603 VOA Ref: 1749005 Date: 13 Novem­ber 2020 DVS Prop­erty Specialists

• It has been assumed that the prop­erty and its value are unaf­fected by any stat­utory notice or pro­pos­al or by any mat­ters that would be revealed by a loc­al search and replies to the usu­al enquir­ies, and that neither the con­struc­tion of the prop­erty nor its con­di­tion, use or inten­ded use was, is or will be unlaw­ful or in breach of any covenant.

• Valu­ations include that plant that is usu­ally con­sidered to be an integ­ral part of the build­ing or struc­ture and essen­tial for its effect­ive use (for example build­ing ser­vices install­a­tions), but exclude all machinery and busi­ness assets that com­prise pro­cess plant, machinery and equip­ment unless oth­er­wise stated and required.

• It has been assumed that no dele­ter­i­ous or haz­ard­ous mater­i­als or tech­niques were used in the con­struc­tion of the prop­erty or have since been incor­por­ated. How­ever where an inspec­tion was made and obvi­ous signs of such mater­i­als or tech­niques were observed, this will be drawn to your atten­tion and cap­tured in this report.

• No access audit has been under­taken to ascer­tain com­pli­ance with the Equal­ity Act 2010 and it has been assumed that the premises are com­pli­ant unless stated oth­er­wise in this report.

• No envir­on­ment­al assess­ment of the prop­erty (includ­ing its site) and neigh­bour­ing prop­er­ties has been provided to or by the VOA, nor is the VOA instruc­ted to arrange con­sult­ants to invest­ig­ate any mat­ters with regard to flood­ing, con­tam­in­a­tion or the pres­ence of radon gas or oth­er haz­ard­ous sub­stances. No search of con­tam­in­ated land registers has been made.

How­ever, where an inspec­tion was made and obvi­ous signs of con­tam­in­a­tion or oth­er adverse envir­on­ment­al impact were vis­ible this will have been advised to you, fur­ther instruc­tions reques­ted and the obser­va­tions cap­tured in the report. Where such signs were not evid­ent dur­ing any inspec­tion made, it has been assumed that the prop­erty (includ­ing its site) and neigh­bour­ing prop­er­ties are not con­tam­in­ated and are free of radon gas, haz­ard­ous sub­stances and oth­er adverse envir­on­ment­al impacts. Where a risk of flood­ing is iden­ti­fied dur­ing any inspec­tion made, or from know­ledge of the loc­al­ity, this will be repor­ted to you. The absence of any such indic­a­tion should not be taken as imply­ing a guar­an­tee that flood­ing can nev­er occur.

LDG21a (16.09.20) Private and Con­fid­en­tial Page 6

Cli­ent Ref: CNP7603 VOA Ref: Date: 1749005 DVS Prop­erty Spe­cial­ists 13 Novem­ber 2020

1. Prop­erty Information

3.1 Loc­a­tion

The com­muted pay­ment policy is to apply to the CNPA area.

There are five Loc­al Author­it­ies cov­er­ing the Nation­al Park:

• Aber­deen­shire
• Angus
• High­land
• Moray
• Perth and Kinross.

The iden­ti­fied Hous­ing Mar­ket Areas (HMA’s) cov­er­ing the nation­al park area are as follows:

Aber­deen­shire

The cur­rent Aber­deen City and Aber­deen­shire HNDA was pub­lished in 2017. The area of Aber­deen­shire with­in the Cairngorms Nation­al Park has been included in the Rur­al HMA. The Hous­ing stock with­in the CNPA is only a very small per­cent­age of the over­all Aber­deen­shire and Aber­deen City Hous­ing Mar­ket areas.

Hous­ing Need and Demand Assess­ment Aber­deen City and Shire 2017

LDG21a (16.09.20) Private and Con­fid­en­tial Page 7

Cli­ent Ref: CNP7603 VOA Ref: 1749005 Date: 13 Novem­ber 2020 Angus DVS Prop­erty Specialists

Angus has been des­ig­nated as 4 HMAs. The area with­in the Nation­al Park is with­in the West Angus HMA. Accord­ing to the Brief, there are only 33 dwell­ings in the Angus area of the Nation­al Park.

Hous­ing Mar­ket Area Pro­file Angus Over­view (2019 Update)

https://​www​.angus​.gov​.uk/​s​i​t​e​s​/​a​n​g​u​s​-​c​m​s​/​f​i​l​e​s​/2020 – 01/​Housing mar­ket area pro­file — Angus Over­view 2019.pdf

High­land

The High­land Hous­ing Need and Demand Assess­ment (HDNA) (2015) iden­ti­fies Badenoch and Strath­spey as a HMA, the major­ity of the hous­ing stock (97.6%) of the HMA lies with­in the Nation­al Park’s Boundary.

file:///C:/Users/7207314/Downloads/HNDA oct2015 third CHMA sub­mis­sion 2.1%20(1).pdf LDG21a (16.09.20) Private and Con­fid­en­tial Page 8

Cli­ent Ref: CNP7603 VOA Ref: 1749005 Date: 13 Novem­ber 2020 Moray DVS Prop­erty Specialists

The Moray Coun­cil HNDA (2018) con­cludes that the whole of Moray is a func­tion­al HMA, with­in which six sub or loc­al HMAs exist. One of these loc­al HMAs lies with­in CNPA and is described as Cairngorms Loc­al HMA.

http://​www​.moray​.gov​.uk/​m​o​r​a​y​_​s​t​a​n​d​a​r​d​/​p​a​g​e​_​9​4​6​6​5​.html Perth and Kinross

Perth and Kinross Loc­al Hous­ing Strategy 2017 – 2021 iden­ti­fies the area with­in the Nation­al Park area as part of two HMA’s — High­land HMA and East­ern HMA.

LDG21a (16.09.20) Private and Confidential

https://​www​.pkc​.gov​.uk/​m​e​d​i​a​/​1​8​0​8​6​/​L​o​c​a​l​-​H​o​u​s​i​n​g​-​S​t​r​a​t​e​g​y​-2016 – 21 — -Final-Draft/pdf/PK_LHS_Final_version.pdf Page 9

Cli­ent Ref: CNP7603 VOA Ref: 1749005 Date: 13 Novem­ber 2020 3.2 Descrip­tion DVS Prop­erty Specialists

The valu­ation meth­od­o­logy is out­lined below in sec­tion 4 with ref­er­ence to the Scot­tish Gov­ern­ment PAN2/2010, More Homes Divi­sion Guid­ance Notes ²⁰²⁰⁄₀₂ and the guid­ance notes issued by the RICS, in par­tic­u­lar ​‘Valu­ation of Land for Afford­able Hous­ing Scot­land’ GN100/2013, VIP 12 ​“Valu­ation of Devel­op­ment Land” and GN ​“Valu­ation of Devel­op­ment Prop­erty” Octo­ber 2019.

In line with this guid­ance and in order to assess the value of the notion­al plots the fol­low­ing has been assumed, regard­ing the notion­al plot, with­in each of the Loc­al Author­ity areas and for the Nation­al Park as a whole.

The notion­al house type is a 2‑storey, 4‑apartment (3‑bedroom), detached house built to a good stand­ard of spe­cific­a­tion. It is assumed that it has private garden grounds, off-street park­ing but no gar­age. The prop­erty is assumed to have a GIA of 96m² and the accom­mod­a­tion is assumed to comprise:

Ground Floor: Liv­ing room, kit­chen, cloak room.

First Floor: 3‑bedrooms and bathroom.

It is assumed that the units will be built to a good qual­ity fin­ish meet­ing all required Build­ing Stand­ards. It is fur­ther assumed that the units will adhere to the required RSL stand­ards for afford­able hous­ing, these tend to be high­er than main­stream require­ments which can, in our exper­i­ence, lead to high­er con­struc­tion costs.

Heat­ing is not spe­cified, but it is assumed to be a good stand­ard and could com­prise for example elec­tric (includ­ing forms of renew­able energy such as ground or air- source heat pump) or gas where available.

Park­ing pro­vi­sion is assumed to be avail­able and in line with the loc­al author­it­ies cur­rent policy on parking.

It is also assumed that the plots will be ser­viced up to the site bound­ary with the neces­sary infra­struc­ture in place.

3.3 Ten­ure

Owner’s her­it­able interest with vacant pos­ses­sion is assumed.

3.4 Title Restrictions

In terms of the valu­ation for private sale, it is assumed there are no title restrictions.

In terms of the valu­ations for the Social Ren­ted accom­mod­a­tion it is assumed the land will be restric­ted to the pro­vi­sion of Afford­able Hous­ing in perpetuity.

LDG21a (16.09.20) Private and Con­fid­en­tial Page 10

Cli­ent Ref: CNP7603 VOA Ref: 1749005 Date: 13 Novem­ber 2020 3.5 Ser­vices DVS Prop­erty Specialists

PAN 2/2010 states that the com­muted pay­ment should be of a ​“value equi­val­ent to the cost of provid­ing a per­cent­age of ser­viced land required by the policy” and would there­fore assume that the mains ser­vices of water, drain­age and elec­tri­city will be provided up to the site boundary.

3.6 Access and Highways

It is under­stood that the land is ser­viced with the neces­sary infra­struc­ture, includ­ing roads up to the site bound­ary. It is fur­ther assumed that the main­ten­ance of roads and foot­paths ex adverso the prop­erty is the respons­ib­il­ity of the loc­al authority.

3.7 Energy Per­form­ance Certificate

As the valu­ation is for notion­al plots, EPC rat­ings are not known. How­ever, it is assumed that the units will be con­struc­ted to meet build­ing stand­ards in force at the time of con­struc­tion and will have a rel­at­ively good energy rating.

3.8 Plan­ning

Rel­ev­ant nation­al guid­ance is con­tained in Plan­ning Advice Note (PAN) 2/2010 and More Homes Divi­sion Guid­ance Notes ²⁰²⁰⁄₀₂.

I have sum­mar­ised below the cur­rent policies and guid­ance from each Loc­al Author­ity area.

CNPA

The cur­rent Loc­al Devel­op­ment Plan 2015 was adop­ted on 27 March 2015. Policy 1 New Hous­ing Devel­op­ment out­lines the con­tri­bu­tion to Afford­able Hous­ing for new devel­op­ments. Non-stat­utory Sup­ple­ment­ary Guid­ance has also been pub­lished in rela­tion to Policy 1.

The level of afford­able hous­ing required under the 2015 is gen­er­ally no more than 25% of the total num­ber of units.

Pro­pos­als for less than four open mar­ket dwell­ings are required to make a con­tri­bu­tion towards afford­able hous­ing. This is in the form of a cash pay­ment towards the meet­ing of hous­ing need in the loc­al area. (Pro­pos­als for off­s­ite con­tri­bu­tions will be con­sidered where com­munity needs assess­ments, or sim­il­ar assess­ments, sup­port this as a bet­ter way of meet­ing the hous­ing needs of the community).

The Sup­ple­ment­ary Guid­ance states that ​‘The value of the fin­an­cial con­tri­bu­tion will be spe­cific­ally related to the value of the site being developed. The guide for this fin­an­cial con­tri­bu­tion is £25,000 per unit for devel­op­ments of four houses or more. This may how­ever vary due to the loc­a­tion and value (high­er value sites requir­ing high­er con­tri­bu­tions) of the devel­op­ment, or the spe­cif­ics of the site’.

LDG21a (16.09.20) Private and Con­fid­en­tial Page 11

Cli­ent Ref: CNP7603 VOA Ref: 1749005 Date: 13 Novem­ber 2020 DVS Prop­erty Specialists

It fur­ther recog­nises that where a devel­op­ment is of less than four houses, a per­cent­age of the £25,000 bench­mark is sought and in these cases the fol­low­ing val­ues act as a guide: One house: 5% of the £25,000 bench­mark = £1,250 Two houses: 10% of the £25,000 bench­mark = £2,500 Three houses: 15% of the £25,000 bench­mark = £3,750

CNPA are cur­rently in the pro­cess of pre­par­ing the next LDP (2020). The Report­er pub­lished the Exam­in­a­tion Report on 24 August 2020, which sets out their find­ings and a list of recom­men­ded modi­fic­a­tions to the Plan. The CNPA has three months to con­sider the Reporter’s recom­mend­a­tions and sub­mit the Pro­posed Plan as mod­i­fied to Scot­tish Min­is­ters. Dur­ing this peri­od the board will review the recom­mend­a­tions before seek­ing final approv­al from Scot­tish Min­is­ters pri­or to adop­tion of the new Loc­al Devel­op­ment Plan 2020.

The pro­posed hous­ing policy has been con­sul­ted on dur­ing the Pro­posed Plan con­sulta­tion. It requires that 45% of all hous­ing be afford­able for sites of 4 units or more in the set­tle­ments of Aviemore, Bal­later, Blair Atholl and Brae­mar. Oth­er set­tle­ments and areas will be required to provide 25%. There is also a require­ment for a fin­an­cial con­tri­bu­tion to be made for sites under 4 units. There­fore a robust meth­od of cal­cu­lat­ing the level of con­tri­bu­tion is required which will be used in the sup­ple­ment­ary guidance.

It should be noted that whilst the respons­ib­il­ity for pro­du­cing the LDP lies with the Cairngorms Nation­al Park Author­ity (CNPA), most plan­ning applic­a­tions in the Nation­al Park are determ­ined by the rel­ev­ant loc­al author­ity although CNPA ​“calls in” and determ­ines the applic­a­tions which are of gen­er­al sig­ni­fic­ance to the aims of the Park. The CNPA also does not pro­duce its own Hous­ing Need and Demand Assess­ments (HNDA) as these are the respons­ib­il­ity of the Loc­al Authorities.

Aber­deen­shire

Aber­deen­shire Coun­cil has a policy for Afford­able Hous­ing set out in the Aber­deen­shire Loc­al Plan 2017 — sup­ple­ment­ary guid­ance- Afford­able Hous­ing 2017. It is stated that:

‘In the rare and excep­tion­al cases where a com­muted sum is con­sidered appro­pri­ate in lieu of on-site pro­vi­sion, the amount pay­able will be a value equi­val­ent to the cost of provid­ing the per­cent­age of ser­viced land required by the policy. The amount will be based on an exer­cise under­taken by the Dis­trict Valu­er using a bench­mark approach. The bench­mark approach is based on plot val­ues for a notion­al 3 bed­roomed semi-detached prop­erty for unres­tric­ted mar­ket sale and for the value of an identic­al plot restric­ted in per­petu­ity to the pro­vi­sion of afford­able hous­ing. The dif­fer­ence between the afford­able hous­ing plot value and the mar­ket plot value rep­res­ents the com­muted sum pay­able (for a single plot). This bench­mark ana­lys­is is under­taken for areas with­in Aber­deen­shire with com­par­able mar­ket char­ac­ter­ist­ics (based on Academy catch­ments) to pro­duce a range of com­muted sum require­ments that reflect loc­al mar­ket con­di­tions. The total com­muted sum require­ment for any devel­op­ment site will be cal­cu­lated by mul­tiply­ing the rel­ev­ant indi­vidu­al plot value by the total num­ber of afford­able hous­ing units required by the policy. Based on an assess­ment under­taken in 2014, the com­muted sum require­ments are:

LDG21a (16.09.20) Private and Con­fid­en­tial Page 12

Cli­ent Ref: CNP7603 VOA Ref: 1749005 Date: 13 Novem­ber 2020 DVS Prop­erty Specialists

Loc­a­tion	Com­muted sum require­ment (per plot)
West­hill, Stonehaven	£50,000
Port­leth­en, Ban­chory, Inver­urie Stonehaven	£48,000
Kem­nay, Inverurie	£46,000
Ellon, Old­meldrum, Aboyne, Alford	£40,000
Laurencekirk	£38,000
Peterhead, Huntly, Turriff	£30,000
Fraser­burgh, Tur­riff, Huntly, Ban­ff, Macduff	£27,000

After mak­ing enquir­ies of the Plan­ning Author­ity, I under­stand that there is likely to be a move away from stat­utory Sup­ple­ment­ary Guid­ance in favour of Plan­ning Advice Notes fol­low­ing the adop­tion of the new Loc­al Devel­op­ment Plan which is aimed for mid-2021. The plan­ning advice notes are hoped to be more flex­ible so that stake­hold­ers can react more quickly although they might not have as much weight as the stat­utory guidance.

Aber­deen­shire Coun­cil rarely allow com­muted pay­ments, it is usu­ally only where viab­il­ity is called into question.

Whilst there is no cur­rent guid­ance of what form com­muted pay­ments will take under the 2021 LDP it is likely that the bench­mark approach will con­tin­ue. It appears to be accep­ted by both LA and developers as it offers an ele­ment of cer­tainty. It is likely the 2014 fig­ures (which are index linked) will be reviewed and updated.

Angus

Angus Coun­cil has a policy for Afford­able Hous­ing set out in the Angus Loc­al Plan adop­ted by Angus Coun­cil in Septem­ber 2016 – policy TC3: Afford­able Hous­ing states:

“Angus Coun­cil will seek to secure the deliv­ery of afford­able hous­ing equi­val­ent to 25% of the total num­ber of res­id­en­tial units pro­posed on all res­id­en­tial sites of 10 or more units, or where a site is equal to or exceeds 0.5ha. Where a qual­i­fy­ing site is being developed in phases of less than 10 units or less than 0.5 hec­tares the afford­able hous­ing require­ment will be applied based on the over­all capa­city of the site. Angus Coun­cil will work in part­ner­ship with developers and con­sider innov­at­ive and flex­ible approaches to secure deliv­ery of an appro­pri­ate afford­able hous­ing con­tri­bu­tion. Where appro­pri­ate, Sec­tion 75 or oth­er leg­al agree­ments may be used”.

In addi­tion to the above Loc­al Plan, Angus Coun­cil pub­lished Developer Con­tri­bu­tions and Afford­able Hous­ing Sup­ple­ment­ary Guid­ance in Decem­ber 2016. This out­lines the pro­cess for deliv­er­ing the required Afford­able Hous­ing and the cir­cum­stances where a com­muted sum can be made in lieu of on-site provision.

LDG21a (16.09.20) Private and Con­fid­en­tial Page 13

Cli­ent Ref: CNP7603 VOA Ref: 1749005 Date: 13 Novem­ber 2020 DVS Prop­erty Specialists

The VOA has recently provided valu­ation advice to Angus Coun­cil, which is based on the ​‘bench­mark approach’. The pub­lished fig­ures (val­id until 30 June 2019) are as fol­lows and are not expec­ted to change for 30 June 2020:

Hous­ing Mar­ket Area (HMA)	Value for Private Sale (£)	Value for Social Rent (£)	Com­muted Payment (£)
	Range <	Range >	Typ­ic­al
West	£23,000	£29,000	£26,000	£1,000	£25,000

High­land

The review of the High­land-wide Loc­al Devel­op­ment Plan (HwLDP) is cur­rently post­poned until the implic­a­tions of the Plan­ning Bill are more clearly under­stood. There is cur­rently an inter­im pos­i­tion based on an ini­tial review of com­ments received, which was agreed by the Plan­ning, Devel­op­ment and Infra­struc­ture Com­mit­tee on 17 August 2016.

With regards to Afford­able Hous­ing, this is set out in Policy 32 of HwLDP. Devel­op­ments of four or more homes require to con­trib­ute 25% equi­val­ent of afford­able hous­ing in areas of need.

Cur­rently afford­able hous­ing con­tri­bu­tions are required for devel­op­ments of four or more houses, how­ever devel­op­ments of less than four units also require to make an equi­val­ent afford­able hous­ing con­tri­bu­tion in cer­tain cir­cum­stances. High­land areas with­in CNP are classed as one of these excep­tion­al cir­cum­stances as the Nation­al Park LDP spe­cifies the need for afford­able hous­ing con­tri­bu­tions for devel­op­ments of less than four units.

Com­muted afford­able hous­ing pay­ments will only be accept­able on an excep­tion­al basis and will be assessed on a case by case basis. Developers are required to enter into early dis­cus­sions with the Hous­ing Author­ity to agree the ten­ure split and type of afford­able hous­ing required on a case by case basis.

It is recog­nised that fixed com­muted sums pay­able to the Coun­cil will vary over time and will dif­fer by area. They are updated reg­u­larly and pub­lished online via the Council’s web­site. The pub­lished guid­ance states that for indic­at­ive budget­ing pur­poses, a four house devel­op­ment would be expec­ted to make an afford­able hous­ing con­tri­bu­tion in the order of £25,000 to £35,000, equat­ing to £6,250 to £8,750 per home.

LDG21a (16.09.20) Private and Con­fid­en­tial Page 14

Cli­ent Ref: CNP7603 VOA Ref: 1749005 Date: 13 Novem­ber 2020 Moray DVS Prop­erty Specialists

The Moray Loc­al Devel­op­ment Plan (MLDP) 2020 Afford­able Hous­ing Policy is found at DP2 Housing

‘(d) Afford­able Hous­ing Pro­pos­als for all hous­ing devel­op­ments (includ­ing con­ver­sions) must provide a con­tri­bu­tion towards the pro­vi­sion of afford­able housing.

Pro­pos­als for new hous­ing devel­op­ments of 4 or more units (includ­ing con­ver­sions) must provide 25% of the total units as afford­able hous­ing in afford­able ten­ures to be agreed by the Hous­ing Strategy and Devel­op­ment Man­ager. For pro­pos­als of less than 4 mar­ket hous­ing units a com­muted pay­ment will be required towards meet­ing hous­ing needs in the loc­al hous­ing mar­ket area.

A high­er per­cent­age con­tri­bu­tion will be con­sidered sub­ject to fund­ing avail­ab­il­ity, as informed by the Loc­al Hous­ing Strategy. A less­er con­tri­bu­tion or altern­at­ive in the form of off-site pro­vi­sion or a com­muted pay­ment will only be con­sidered where excep­tion­al site devel­op­ment costs or oth­er pro­ject viab­il­ity issues are demon­strated and agreed by the Hous­ing Strategy and Devel­op­ment Man­ager and the Stra­tegic Plan­ning and Devel­op­ment Man­ager. Inter­me­di­ate ten­ures will be con­sidered in accord­ance with the HNDA and Loc­al Hous­ing Strategy, and agreed with the Hous­ing Strategy and Devel­op­ment Manager.’

The 2017 LDP lowered the threshold so that indi­vidu­al house pro­pos­als are required to make a con­tri­bu­tion towards afford­able hous­ing pro­vi­sion. This con­tri­bu­tion is in the form of a com­muted sum pay­ment as s a developer oblig­a­tion. The cost fig­ure is pub­lished annu­ally on the Coun­cil web­site http://​www​.moray​.gov​.uk/​m​o​r​a​y​_​s​t​a​n​d​a​r​d​/​p​a​g​e​_​9​4​6​6​5​.html. It is based on an assess­ment of the value of ser­viced land for afford­able hous­ing in Moray. For ²⁰²⁰⁄₂₁ the com­muted pay­ment is£16,000 in lieu of each unit of afford­able hous­ing required under the Council’s policy. This amount is reviewed annu­ally- the next review being due on 1 April 2021.

Perth and Kinross

Perth and Kinross Council’s policy for afford­able hous­ing is set out in the Developer Con­tri­bu­tions and Afford­able Hous­ing Sup­ple­ment­ary Guid­ance 2020.

A bench­mark approach has been adop­ted. The fol­low­ing details are provided with­in the Guidance:

‘The com­muted sum pay­ment relates to the cost of provid­ing ser­viced land for afford­able hous­ing for the same hous­ing mar­ket area. Assum­ing that the Hous­ing Sup­ply and Innov­a­tion Divi­sion of Scot­tish Gov­ern­ment will make Hous­ing Asso­ci­ation Grant (HAG) avail­able, then the value of the land is the dif­fer­ence between the afford­able land plot which can be pur­chased using the sub­sidy and the value of the site for private devel­op­ment i.e. the com­muted sum is the addi­tion­al amount the hous­ing asso­ci­ation or loc­al author­ity would have to pay over and above the afford­able hous­ing land value to obtain an altern­at­ive site’.

LDG21a (16.09.20) Private and Con­fid­en­tial Page 15

Cli­ent Ref: CNP7603 VOA Ref: 1749005 Date: 13 Novem­ber 2020 DVS Prop­erty Specialists

A resid­ual approach is adop­ted and the valu­ations provided assume notion­al house plots for the erec­tion of a semi-detached house, with­in a devel­op­ment of ten houses, two storey, three apartment