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Jersey Infrastructure levy
Minister’s response to consultation
October 2017
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
2
Contents Contents ..................................................................................................................................................................................................................................................................................................... 2
Executive summary ................................................................................................................................................................................................................................................................................... 3
Survey responses ...................................................................................................................................................................................................................................................................................... 5
1. Levy principle ..................................................................................................................................................................................................................................................................................... 5
2. Proposed levy residential rates ........................................................................................................................................................................................................................................................ 10
3. Proposed levy office rates ................................................................................................................................................................................................................................................................ 15
4. Proposed levy retail rates ................................................................................................................................................................................................................................................................ 19
5. Exemptions ...................................................................................................................................................................................................................................................................................... 23
6. Proposed types of development to be subject to the levy ................................................................................................................................................................................................................ 27
7. Proposed levy thresholds ................................................................................................................................................................................................................................................................. 31
8. Reduced Planning Obligation Agreements ...................................................................................................................................................................................................................................... 35
9. Community share ............................................................................................................................................................................................................................................................................. 39
10. Spending the levy .......................................................................................................................................................................................................................................................................... 42
11. General comments ......................................................................................................................................................................................................................................................................... 43
12. Individually submitted responses .................................................................................................................................................................................................................................................... 47
12.1 States of Jersey Environment Minister - Addendum .................................................................................................................................................................................................................... 47
12.2 States of Jersey Minister for Housing – key points from letter dated 07 August 2017 ................................................................................................................................................................. 47
12.3 Association of Jersey Architects – key points from letter dated 06 September 2017 ................................................................................................................................................................... 48
12.4 States of Jersey Cultural Development Officer, EDTS – key points from email/letter dated 08 September 2017 ........................................................................................................................ 51
12.5 Jersey Chamber of Commerce – key points from letter dated 08 September 2017 ..................................................................................................................................................................... 51
12.6 Jersey Construction Council – key points from Lichfields letter & report dated 08 September 2017 ........................................................................................................................................... 52
12.7 Ports of Jersey – key points from letter dated 11 September 2017 ............................................................................................................................................................................................. 60
12.8 States of Jersey Development Company – key points from letter dated 11 September 2017 ..................................................................................................................................................... 62
13. Comment.gov.je Responses ............................................................................................................................................................................................................................................................. 63
Appendices – Individual submissions in full ......................................................................................................................................................................................................................................... 64
Executive summary Following extensive pre-consultation with stakeholders, beginning in October 2016, the Minister for the
Environment published a draft policy document proposing the introduction of a broad, low and fair
development charge called the Jersey Infrastructure Levy (JIL) on 23 June 2017. The consultation
period was extended until 11 September at the request of the development industry. A total of 35
individual survey responses were submitted with over 300 comments made on key areas of the
proposal and a further eight substantive submissions were made by groups and organisations.
All of the comments received have been included in this report and, where specific comments have
been made, they have been responded to directly. The comments can be summarised by category and
are set out as follows:
The principle of the levy
The principle of the Jersey Infrastructure Levy is that developers who benefit from the increase in land
value that comes from development permission, make a contribution to the impact of that development
on the local community.
Consultees were broadly equally split on their support for the principle of introducing a levy to Jersey
with those comments received from the development industry being more negative and those from
members of the public or interested groups being more positive. This is not surprising and is as
expected given that the levy would benefit the community whilst being paid for from the development of
land.
The main case made against the levy is that it is a new tax; that it is unfairly targeted on the
development industry; and that it will lead to increased prices for development (purchase and rental).
The Minster for the Environment is not disputing that the levy is a new form of tax, but is one that is
designed to come from the development of land directly in order to deliver some community benefit.
The levy is targeted at the development of land because it is believed that it is right for a small
proportion of the increase in land value arising from the grant of planning consent to be shared with the
community, rather than going solely to the landowner. It is also considered right that funds derived from
the development of land are used to offset some of the impact of that development upon the
community, to make them better places to live, work and visit.
Viability
The viability work that has been undertaken adopts a cautious and conservative approach in its
assumptions and demonstrates that the introduction of a levy would work in Jersey and that supply and
developer profits can still be maintained. It also shows that the introduction of a modest levy would
represent a small percentage of the final Gross Development Value, and no evidence has been
provided to demonstrate that this would add directly to end development prices, which are determined
by market forces. This conclusion is supported by recent work (2017) to review the operation of the
Community Infrastructure Levy in the UK and earlier work undertaken here in Jersey by Oxera to review
environmental land taxes in 2008.
Further economic advice will be sought from the Economics Unit to test and amend if necessary, a
more detailed levy proposal, should there be any evidence be forthcoming that the levy could lead to
higher prices and/or reduced supply.
Levy rates
The Minister’s draft policy document proposed a charge of £85 per square metre on new developments
that create over 75 square metres of new floor space - roughly the size of a two-bedroom apartment.
This would be applied to the development of net new retail, office and residential floorspace.
The responses to the proposed levy rates followed a similar pattern to the response to the principle of
introducing a levy, with the development industry offering objections and the community offering
support. Only one response (made by Lichfields on behalf of the Jersey Construction Council) provided
any evidence to challenge the proposed levy rates. Whilst this evidence supported a number of general
points it provided no new Jersey-specific data to challenge the assumptions made: The Lichfields
analysis in fact shows that most development is not viable if their assumptions are used and this is
clearly not the case in Jersey, as development is coming forward across the Island, and particularly in
St Helier, so in the view of the HDH consultant this undermines their case. The full response to the
Lichfields report is detailed in section 12.6 of this report.
Exemptions The Minister’s proposed policy stated that affordable housing and public developments, such as
government offices, would be exempt from the charge.
Comments about proposed exemptions were mixed suggesting that exemptions were too narrow or that
there should be no exemptions at all. None of the alternative suggestions received were evidenced and
were based on speculation or unsupported assertions.
Use of the levy The consultation document published by the Minister indicated that a levy could fund:
• new and improved streets, safe play spaces and recreational facilities, parks, tree planting and
community gardens, such as the Millennium Town Park and the Weighbridge
• improvements to public transport services and facilities, like more bus shelters and improved
services
• pedestrian improvement schemes and new footpaths, such as improvement to town streets
already completed in Conway Street and Broad Street
• new cycle routes, such as the Eastern Cycle Network or the St Peter’s Valley Cycle Path
• improvements to make local areas more resilient to climate change, by introducing sustainable
urban drainage schemes to help manage surface water; more tree planting to provide shade and
cooling; and better flood defences
Regulations would set out how these projects are identified and prioritised and a list will be published. It
was also proposed that 10% of JIL funds raised from development in a parish would be used for local
community improvements, to be administered by the parish.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
4
There was an even spread of views on what the levy could be spent on, with some making alternative
suggestions to those already identified: these views will be considered in more detail should the
principle of introducing the levy be supported.
The proposed allocation of 10% of any levy funds to the parishes, derived from development within that
parish, generated mixed views with some of those who supported it some suggesting a higher share.
Many comments identified the need for an audited and managed process to spending the levy: this
would be addressed as part of future regulations should the principle of introducing the levy be
supported.
Planning Obligation Agreements
The development industry expressed concern about being asked to contribute for the same
infrastructure twice, through both the levy and the planning obligation agreements (POAs). A review of
existing POA charges would be included in the development of a levy, if the principle of its introduction
is supported, and restrictions would be put in place, through regulation, to ensure that developers are
not charged twice for the same infrastructure.
It is likely that if JIL is introduced, the existing POA requirements would be significantly reduced and
simplified to cover only site-specific issues, while the new levy would cover area wide improvements.
Conclusions The Minister for the Environment has published a draft policy document proposing the introduction of a
broad, low and fair development charge called a Jersey Infrastructure Levy and has sought a broad
range of views on this.
An extensive and soundly evidenced viability report based on Jersey-specific data has been prepared,
in consultation with the Jersey development industry, to support the Minister’s proposal to introduce an
infrastructure levy to Jersey (Viability assessment for review of developer contributions report): this
demonstrates that the introduction of a levy would work in Jersey.
During this formal round of consultation, there has been no further submission of alternative evidence
that directly or substantively challenges this supporting work. Whilst it is clear that the development
industry does not support the introduction of a levy it has not been able to offer to offer any substantive
evidence which demonstrates that a levy would not work in Jersey. On this basis, the Minister is content
that the evidence prepared to support the principle of introducing a levy has been thoroughly scrutinised
and can be considered robust.
It is also considered reasonable to conclude, in light of this, that the Jersey development industry’s
opposition to the introduction of JIL is a matter of principle. The principle of the levy, however, is to
ensure that developers who benefit from the increase in land value that comes from development
permission, make a contribution to the impact of that development on the local community. The Minister
believes that this is right and is supported by those community groups who have responded to this
consultation.
The Minister is, therefore, of the opinion that the outcome of this consultation provides a sound basis for
taking a proposition to the States to seek the Assembly’s approval of the principle of introducing an
infrastructure levy in Jersey and, if supported, to subsequently develop law, policy and regulation.
Next Steps The Minister for the Environment will lodge a proposition in the States seeking the Assembly’s support
for the introduction of a Jersey Infrastructure Levy. The proposition will seek the support of the
Assembly in principle.
If the States Assembly supports the introduction of a Jersey Infrastructure Levy, in principle, further
work will then begin on the development of legislation, regulation and policy to enable the
implementation of the levy. This work would be undertaken during 2018.
New legislation is required for JIL to take effect in Jersey. This would remain to be the subject of
approval by the States Assembly. It is envisaged that this might take place during Q4 2018/ Q1 2019.
The setting of an infrastructure levy rate will likely be the subject of independent professional scrutiny,
probably by a planning inspector, during some form of public inquiry: the provisions of new legislation
will likely provide for this. Before JIL takes effect in Jersey, the current data and assumptions about
costs and values set out in the Viability Assessment for Review of Developer Contributions (May 2017),
would need to be reviewed and updated, to reflect any change in the Jersey development industry and
market. This would form the basis the Minister’s proposed JIL rate and work would need to be carried
out, once legislation has been introduced, to ensure that the most up-to-date information was being
used to inform any proposal. It is envisaged that this might take place during Q1/2 2019.
It is only once the JIL had been reviewed and set, following independent scrutiny and review, would it
take effect, likely sometime in the second half of 2019.
Survey responses
1. Levy principle The decision to propose a levy follows a viability study which concluded there was scope to introduce a levy in Jersey in order to improve the quality of neighbourhoods affected by new development.
Is the levy an appropriate policy to help deliver community infrastructure improvements and, if not, what alternative would you suggest?
Questionnaire consultation results
% Total Count
Agree 49% 16
Neither 2% 1
Disagree 49% 16
Total 100% 33
Summary of responses
Consultees were broadly equally split on their support for the principle of introducing
a levy to Jersey with those comments received from the development industry being
more negative and those from members of the public or interested groups being
more positive. This is not surprising and is as expected given that the levy would
benefit the community whilst being paid for from the development of land.
The main case made against the levy is that it is a new tax; that it is unfairly targeted
on the development industry; and that it will lead to increased prices for development
(purchase and rental). No alternative evidence was, however, presented that could
be tested to support the case made.
The Minister, however, believes that it is right for a small proportion of the increase
in land value arising from the grant of planning consent to be shared with the
community, rather than going solely to the landowner. It is also considered right that
funds derived from the development of land are used to offset some of the impact of
that development upon the community, to make them better places to live, work and
visit.
The viability work that has been undertaken adopts a cautious and conservative
approach in its assumptions and demonstrates that the introduction of a levy would
work in Jersey and that developer profits can still be maintained. It also shows that
the introduction of a modest levy would represent a small percentage of the final
Gross Development Value, and no evidence has been provided to demonstrate that
this would add directly to property prices, which are determined by market forces.
This conclusion is supported by recent work to review the operation of the
Community Infrastructure Levy in the UK.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
6
Please provide reasons for your answer and suggest any alternative proposals to deliver infrastructure improvements.
Ref Supporting/ Objecting Reasons for answer States of Jersey Response
JIL7 Agree It is right that an element of the economic value generated by allowing development should be reinvested in that locality in order to improve the living and working environment.
Comments noted
JIL10 Agree Excellent idea and would have a positive impact on the local environments. Examples could include any structure including greening of car parks relocation of services to allow tree planting directly into site rather than planters which although softening the landscape are higher maintenance and usually in locations where services stop direct planting.an element of funding put aside for refurbishment of locations would be wise as they do deteriorate as Liberation square.
Comments and suggestions for use of levy noted
JIL14 Agree Given the high level of development occurring in Jersey it is essential for money to be used to both adequately protect flora and fauna on the Island. Where the development is negatively impacting of these factors (proven via an EIA, or if an EIA is outside the scope of the development then assumed via the nature of the development) that appropriate mitigation, supplementary care (such as bat roost opportunities) or long term monitoring be provided for. There is currently inadequate screening of both planning and building control for property development and these is a major concern for species such as bats which rely upon the built environment for many of their roosts.
Comments noted on the levy proposal. (whilst outside the scope of the consultation, it is relevant to note that planning applications are screened and assessed relative to their impact on biodiversity)
JIL17 Agree Jersey requires significant investment in infrastructure particularly for pedestrians and cyclists
Comments noted As currently proposed the levy, if adopted, would be able to deliver improvements in these areas.
JIL18 Agree I live very close to a disused area of land adjacent to derelict greenhouses, it would be great if at some point this area was developed for families. If land like this were to be developed, there must be provision for outdoor play for children, this should allow for free play on natural surfaces as well as the usual static equipment. In an ideal world there would be provision of a "play team" that visited these areas to encourage resourceful play resilience and holistic appropriate social/emotional development.....these people would need a robust shed.
Comments noted As currently proposed the levy, if adopted, would be able to deliver improvements in these areas.
JIL21 Agree Seems reasonable Comments noted JIL23 Agree Infrastructure in Jersey needs a lot of upgrade work to meet the challenges of climate
change etc., and someone has to pay. People expending energy and carbon, and using up green land, developing properties in Jersey make a lot of easy money; there is no reason why they should not contribute substantially to this.
Comments noted As currently proposed the levy, if adopted, would be able to deliver improvements in these areas.
JIL25 Agree This is an appropriate policy providing it is adequately policed and that quality of the provision is the primary concern. Any community development must be fit for purpose and have the client group as its focus. It is not clear as to what % of each levy paid will be spent on the project it was raised from. 10% is to go to the Parish but what % is to be spent on the project from the money raised by the project?
Comments noted As currently proposed the levy, if adopted, would be pooled into one ‘pot’ to be spent on essential community infrastructure required to help improve the quality of places for people to live, work and visit. This may not be related to a specific development project. The management and governance of the fund remains to be determined through the development of detailed regulations. These regulations will set out how projects are identified and prioritised.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
7
Ref Supporting/ Objecting Reasons for answer States of Jersey Response
Work on the development of detailed regulations will follow if the principle of introducing an infrastructure levy is supported.
JIL27 Agree Provided the funds raised are ring fenced and used in addition to existing planned Government infrastructure spend (i.e. not to subsidise), then I' supportive. Re the use of the funds I absolutely support the importance for St H in developing first class network of cycle paths and pedestrianised areas, with more green space. As someone who lived in town for the past 2 years seeing the vibrant atmosphere along Queen Street, disappear whenever you get near slow moving cars pumping out exhaust fumes, always used to frustrate me. Now I cycle into town from Victoria Village every day, using main roads the real danger is unfortunately constant and also once again breathing in fumes from slow moving/ stationary traffic is most unpleasant. When I compare this with major cities like Amsterdam, Berlin and even London, you can see that cyclists and pedestrians are being prioritised, whereas in Jersey, the car remains king. When is traffic at its worst?, around school opening and closing times. Wouldn’t it be great if the norm for schools was walking, bike or as a last resort public transport (teachers take the lead?). A joined up strategy in this space would make a real difference, but we have to make cycling feel much safer and pleasant. In summary with some brave and joined up thinking Jersey could become a leading example such as the likes of Vancouver. They clearly have had a joined up plan, ensuring all the shore line is green and public access, cyclist routes required with every road development etc. With St we have a jewel, but it needs some polishing!
Comments noted As currently proposed the levy, if adopted, would be ring-fenced to develop new community infrastructure in the areas such as those identified. It would not be used to offset existing government revenue expenditure.
JIL29 Agree Infrastructure is important in ensuring communities are safe and healthy and include all members. A policy to support improvement is to be commended. Comments noted
JIL3 Agree Jersey is becoming over developed and no consideration is given to outside space or the general feel of the area. People live in their homes but they also live in the surrounding area. St Helier is becoming wall to wall concrete and is a horrible town. Years of planning failures have made it devoid of open space or nice areas for residents and people who work in the area. The planning department is failing in protecting any culture or heritage or open space for residents. A case in point is the new green street development of la Collette flats. The development shall remove the last bit of green space on green street. Their attitude: hey who cares I don't live there. But this continual creep of development eating up space is suffocating st Helier in concrete. It is quite literally a horrible place to live. They have more consideration for this in London. There are parks everywhere and the streets often have trees. They should provide
Comments noted As currently proposed the levy, if adopted, would be able to deliver improvements in these areas.
JIL1 Disagree If money is short in the States, it should be spent on supporting people, not frippery. and wasted projects like unused cycle paths
The levy represents a share of private profit from the increase in land values that occurs when planning permission is granted. The reinvestment of these funds will provide community benefit of value to people who live in, work in and visit these areas.
JIL2 Disagree The levy places the burden on one section of the business community only It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
8
Ref Supporting/ Objecting Reasons for answer States of Jersey Response
need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. Those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the community infrastructure needed to make development acceptable and sustainable.
JIL8 Disagree 1. Infrastructure improvements must only be provided by government if and when essential - we do not have the spare cash for fancy improvements. 2. If essential for safety, well-being or security, it is the job of government to provide infrastructure improvements through general taxation.
It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable. The department has consulted with the States Economic Advisor. There is no evidence to suggest that the levy would result in higher house prices. This conclusion is supported by recent work to review the operation of the Community Infrastructure Levy in the UK together with earlier work undertaken by Oxera in 2008 on land development taxes.
JIL9 Disagree Building is expensive, and the view seems to be that if you can afford to build, then you can afford to pay more. Everyone wants a finger in the pie - lawyers are allowed to charge exorbitant amounts for property conveyancing, the States charges stamp duty for doing next to nothing. And now this proposed Infrastructure Levy is aimed at taking even more from the cash cow. What about 'user pays'? Why should new homebuyers have to pay for community and Island infrastructure just because they want somewhere to live? The entire community will benefit from improved roads and public transport, parks and open spaces, public art and cycle paths. Funding for these should come from Island taxes and parish revenue and not be used as a ransom on planning permission to build a home. It is wrong.
JIL12 Disagree The fact that development is being undertaken in the first place is a benefit to the community itself Noted and accepted
JIL13 Disagree A carbon levy would be a lot more appropriate. Soil is capable of storing three times as much carbon than the atmosphere. New buildings generate lots of CO2, and then stop CO2 from being drawn down. If a CO2 levy was introduced and used to reward landowners who could prove CO2 drawdown, the benefits to Jersey would be fairer to everyone, and it would help Jersey meet its international commitments to the 4 per 1000 initiative.
Noted, but carbon reduction has no direct relevance to the proposed introduction of the infrastructure levy. The Energy Plan for Jersey is the policy vehicle for CO2 reduction in the Island.
JIL5 Disagree It's simply a tax on new home owners. Indirectly, it puts up the cost of home ownership, of office rental, which increases the cost of living.
The levy is not expected to increase house prices. There is no evidence to suggest that the levy would result in higher house prices. This conclusion is supported by recent work to review the operation of the Community Infrastructure Levy in the UK.
The levy will be a small part of the overall cost of building a home, and it is expected that developers will either negotiate to pay less for land they buy in time, or absorb some of the cost.
The levy will only be applied to new housing (about 30% of annual housing sales in Jersey) and will exclude affordable homes or developments by charitable trusts.
Developers set asking prices for new developments, but values are set by the market and this is usually based on what similar houses in the area sell for, as well as the formal valuation carried out by a bank’s appointed valuer, if the buyer is applying for a mortgage for the property.
JIL15 Disagree This is mad and will only further push up the cost of housing in Jersey. We already have very well-funded infrastructure and do not need yet another tax
JIL24 Disagree This will be passed on to the end-consumer and will further inflate the costs of buying property in Jersey (as if it isn't inflated enough already). Govt and Parishes should pay for "community infrastructure improvements" through tax and rates,
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
9
Ref Supporting/ Objecting Reasons for answer States of Jersey Response
A buyer of a new property will only pay a premium for a new property if it is more attractive than those in the wider market.
In the long-run, a fixed levy will provide certainty about the level of charge that a developer must pay and they will be able to factor this in to the price that they pay for land.
JIL19 Disagree The rubbish that has been fostered upon the public due to unsightly and buildings of little community importance unless your some ultra-egotistical finance leach on the island.
The aesthetics of new buildings will always invite opposing views and private developments will not always provide public community benefit. The introduction of an infrastructure levy is a way of providing wider public benefit from development to deliver real community improvements.
JIL11 Disagree This should be done via general tax revenues.
It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable. General income tax receipts will remain to fund other public services.
JIL26 Disagree Community infrastructure should be paid for out of income tax - this is the existing position and seems to have worked for decades. Commercial development of real estate is already taxed at 20%.
JIL28 Disagree The states already collect a levy from citizens, it’s called income tax. Adding further cost simply pushes up the cost of living in Jersey which is to no body’s advantage. The argument that there is a budget shortfall is not acceptable. The States should learn to manage within its means and not fund further spending through a range of stealth taxes.
JIL30 Disagree 1. This is a new tax and, as such, unwelcome. 2. It is a selective tax which falls unevenly in that it selects just one sector to pay a higher rate of tax than other sectors. 3. It is, in effect, a land tax and inevitably it will be passed on in the form of an increased cost of housing: Jersey has an acute housing shortage and the development sector should be encouraged to build more residential accommodation, not disincentivised through punitive taxation. 4. it is an inappropriate way to fund infrastructure development: government should manage our finances in such a way as to enable infrastructure development through 'normal' capital programmes, i.e. by managing revenue expenditure in such a way as to provide an annual surplus which can be diverted to capital expenditure. 5. An alternative way forward is for the Environment Department to cut costs. It employs people in environmental activities that should be left to the voluntary sector; these post should all be made redundant; the payback benefit for the cost of VR or CR would begin immediately.
JIL31 Disagree Cut red tape and your costs and spend the savings on infrastructure improvements. JIL4 Neither As it will not work I think that all Islanders should have a say as the government
always wants their ways to improve which does NOT work. This should be sent in the post as there are many people (especially the elderly) who DO NOT use cp,putors.
Comments noted. Consultation material was available in hard and electronic copy and the department welcomes the submission of comment in whichever way people find most convenient.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
10
2. Proposed levy Residential Rates A levy rate of £85 per square metre of development has been proposed for residential developments. Do you think that this is a viable rate?
Questionnaire consultation results
% Total Count
Yes 32% 11
No 55% 17
Not Sure 13% 5
Total 100% 33
Yes32%
No55%
not sure13%
2. Proposed levy Residential Rates
Summary of responses
The Minister’s draft policy document proposed a charge of
£85 per square metre on new residential developments that
create over 75 square metres of new floor space - roughly
the size of a two-bedroom apartment. This rate was based
upon the viability assessment for review of developer
contributions report which recommended viable rates of up
to £125/Sqm.
The responses to the proposed levy rates followed a similar
pattern to the response to the principle of introducing a levy,
with the development industry offering objections and the
community offering support.
Although this question provided a more negative view (55%)
from 33 respondents, some of those supporting the principal
of the levy opposed the levy rate as they considered it too
low (without evidence), which does not give a true picture to
the statistical response to this question.
With regards to those comments who were opposed to the
levy, a number of valid points were made but no new or
alternative direct local evidence is produced to support the
comments made.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
11
Please give reasons for your answer and provide any relevant evidence.
Ref Supporting/
Objecting Reasons for answer States of Jersey Response
JIL3 Yes Yes every developer I have seen is very rich. They probably don't even pay tax on their income" because they classify it as a capital gain. But this cannot be at the expense of the planning law. Continual pressure must be put on developers to provide improvements to the area, not just maximise profit.
The principal of the levy is to seek community improvements from the awarding of planning permission and a reasonable return (developer’s profit) is required in order to deliver successful developments.
JIL6 Yes For non-resident companies make it double! The policy will not consider the ownership of companies as this is outside the scope of the levy proposal.
JIL7 Yes We need simple and clear charging structure. Yes it could be higher or lower, but we have to start somewhere and this can then be reassessed with time/ experience
The single rate levy structure is considered to be simple and clear and more importantly viable.
JIL13 Yes All building should face the levy, Jersey has a responsibility even if it is small. The viability assessment for review of developer contributions report recommended that for small developments the levy could be unviable at the higher rates. Having variable rates is considered too complex for the outcome.
JIL16 Yes No comment Noted JIL17 Yes Seems a reasonable compromise amount Comments noted – the levy has been designed to be simple to use,fair and equitable. JIL21 Yes Yes, but fixed for what period, tied to inflation etc? The policy will be reviewed every 3 years and /or following significant changes in costs
or values. The rates and governance of the levy remains to be determined through the development of detailed regulations should the levy be approved in principle and which will then be subject to further public consultation and States approval.
JIL22 Yes I think it should be £100 The viability assessment for review of developer contributions report recommended a range of rates and for residential developments it could be as high as £125/Sqm, whilst for offices it was £80/Sqm. The Minister has proposed a consistent rate for all development types in order to provide a simple, equitable and fair policy framework. It is accepted that the proposed rate is at the lower end of the recommended range.
JIL23 Yes In line with UK, and we have to start somewhere Comments noted JIL27 Yes This needs to be measured though against the planning gain The contributions made by developers through the current planning obligation
agreement (POA) policy is included and is part of the modelling undertaken in the viability assessment for review of developer contributions report. It is considered that the levy is viable and will be delivered through the awarding of planning permission. Should the levy be adopted POA’s will be reviewed and some dropped. However some will still be in place to capture specific planning gain from developments that have a significant local impact (e.g. drainage, contamination, road junction improvements, etc.)
JIL10 not sure Might have a negative impact on residential prices any could drive development off the Island ,but would support a slightly lower levy of 60 to get the scheme started , suspect it has been set knowing it will come down.
The levy rate has been set based upon evidence from the viability assessment for review of developer contributions report undertaken by the consultants and local, surveyors. The rate will be adjusted according to new viability evidence as it emerges and is verified.
JIL14 not sure It may be a case to exempt some development or to charge upon a variable scale depending on the nature and scale of development (if it is the re-development of an existing structure, building on an existing footprint then perhaps to be treated differently to a green-site development).
The levy is applied only to certain development types (Residential, office and retail) and then only for net new development. A conversion of an existing floor space to residential for example would not be charged the levy unless a new additional floor area was added to the building.
JIL25 not sure If this sum is reached following local professional research then it is a viable rate. The viability assessment for review of developer contributions report was carried out by UK and local surveyors using Jersey specific evidence and is considered robust.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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Ref Supporting/ Objecting Reasons for answer States of Jersey Response
JIL29 Not sure Insufficient information available to make comment. The rates are based upon recommendations in the viability assessment for review of developer contributions report published with the survey
JIL35 Not Sure There definitely should be a levy but not sure a what rate. Could it not be based on a percentage of the profits out of the development?
The viability assessment for review of developer contributions report recommended that the current rates were viable and capable of delivering a sufficient annual community benefit from new developments on the Island. Other levy types were considered but the proposal put forward was favoured as being the simplest and fairest option.
JIL1 No Wow, a tax on buildings, bet the tax we pay in general will still all be spent It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable. General income tax receipts will remain to fund other public services.
JIL2 No The formula makes no reference to profit level, and will in any case be passed on to tenants or purchasers The model assumes a minimum profit level for developers of 20% GDV
JIL4 No As this seems too cheap it should be at least £100 minimum The modelling undertaken in the viability assessment for review of developer contributions report recommended a range of viable levy rates, with residential rates being able to be charged of up to £125. The Minister has decided to have a single rate across all in order to keep the levy simple to use, fair and equitable.
JIL5 No Adds £4,000 to a small property purchase. The levy is designed to come off land values and will vary according to the size of development proposed. The £4,000 indicated in the response has no supporting evidence and so is not clear how it is arrived at.
JIL8 No I do not agree with the levy on principle. Either a residential development is approved in accordance with the Island Plan because it is required (in which case no levy should be charged) or it is rejected, in which case such a levy is irrelevant.
The levy is separate to current planning policies and the principle is based upon using the profit from awarding planning permission to pay for community improvements for all Islanders. It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable.
JIL9 No Aside from the fact that this levy is no more than a stealth tax to avoid having to use central funding for community infrastructure improvements, £85/sq.m is between around 4% and 9% of build cost! It is extortionate.
The viability assessment for review of developer contributions report has calculated that the levy represents around 2.5% of Gross Development Value, which is a more
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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Ref Supporting/ Objecting Reasons for answer States of Jersey Response
relevant way of viewing the impact as it is not a direct cost to development as it is intended to come off the value of the land.
JIL11 No This just increases the general costs of development that are already excessive and have driven out the chance of any smaller developer. The island is now so expensive that only companies with huge financial resources can operate.
Larger companies are likely to have a more competitive edge on certain types of developments, particularly where economy of scales exist, however the levy is considered to be a marginal cost which should be negotiated from the land value and allow developers of all sizes to operate as normal on the island.
JIL12 No Should not apply to residential developments that remain under the ownership of the developer.
The residential land ownership considerations will not be included as exceptions to the levy unless the levy is for affordable housing. In some situations developers may already have purchased land and so won’t be in a position to adjust land values, although in a rising market land values will likely be higher the longer the ownership period to more than cover any potential levy imposition. This is also being mitigated by the Minister for the Environment’s clear, early signals to the industry of his intent to not introduce the levy until 2019 at the earliest and the fact the levy is being set at a low rate to maintain the incentives to develop. It will be a requirement that where planning permission has been granted before the implementation an infrastructure levy in Jersey a project will not be liable.
JIL15 No It is mad to tax building new homes and totally counterproductive. will lead to spending more money on housing subsides.
The levy is aimed to come off land values not increase house prices. Affordable housing is exempt.
JIL18 No This is far too high, I can only imagine you want this to fail before it is agreed! The rates are based upon recommendations in the viability assessment for review of developer contributions report which was an extensive and soundly evidenced piece of work and has recommended rates that would be viable.
JIL19 No Our ignorant politicians need to tackle the population crisis that is creating a number of issues to the island. As a single person it has been impossible for me to afford to purchase a property, this is not right or fair when we allow untold immigrants into the island. Which idiot thought up this levy?
Although the population is a major issue for the Island, it is not a major consideration in formulating the levy proposal. Affordable housing developments will be exempt from paying the levy and can only be accessed by eligible Jersey resident households.
JIL20 No This is just another "tax" on the end user. It is a "tax" which appears to be only based on the square metre-age of the site, therefore, if the development is a block of flats, it will only be based on the ground floor area? Every new development already includes, at the planning application stage, landscaping (trees, gardens, environment) and a play area (if appropriate). It also includes access and pathways.
The proposal is for the levy to be applied to all new net additional floor areas only and will only apply to the buildings and not landscaping or footpaths.
JIL28 No The states already collect a levy from citizens, it’s called income tax. Adding further cost simply pushes up the cost of living in Jersey which is to no body’s advantage. The argument that there is a budget shortfall is not acceptable. The States should learn to manage within its means and not fund further spending through a range of stealth taxes.
It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable. General income tax receipts will remain to fund other public services.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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Ref Supporting/ Objecting Reasons for answer States of Jersey Response
The Government is currently undertaking a major reform/efficiency programme aimed at improving Public Services which is not the appropriate route to fund public realm improvement plans from development related activities.
JIL30 No As stated above, this cost will be passed on by the developer and will emerge as higher building costs and ultimately the purchaser of the building will pay more. It will inflate dwelling unit prices.
The levy is not expected to increase house prices. There is no evidence to suggest that the levy would result in higher house prices. This conclusion is supported by recent work to review the operation of the Community Infrastructure Levy in the UK.
The levy will be a small part of the overall cost of building a home, and it is expected that developers will either negotiate to pay less for land they buy in time, or absorb some of the cost.
The levy will only be applied to new housing (about 30% of annual housing sales in Jersey) and will exclude affordable homes or developments by charitable trusts.
Developers set asking prices for new developments, but values are set by the market and this is usually based on what similar houses in the area sell for, as well as the formal valuation carried out by a bank’s appointed valuer, if the buyer is applying for a mortgage for the property.
A buyer of a new property will only pay a premium for a new property if it is more attractive than those in the wider market.
In the long-run, a fixed levy will provide certainty about the level of charge that a developer must pay and they will be able to factor this in to the price that they pay for land.
Through the informal consultation with the development industry that was carried out to inform the Viability Assessment, comments were received raising the concern that the levy would be added to the sale prices of developments thus increasing already high house prices in Jersey. The department has had initial discussions with the Economics Unit and their view is that charges like the Jersey Infrastructure Levy (JIL) that intend to capture a small fraction of the uplift in land values that arise when a site gets permission for development would normally be expected to impact on land values. In a competitive market developers would have a strong incentive to make sure the charge leads to lower land values because if not new built properties would become relatively more expensive than similar properties that have already been developed and were not subject to the levy. New build homes only form a minority of homes sold each year and in a competitive market prices will be determined by the interaction of overall supply and demand for properties and therefore general conditions in the market. This conclusion is supported by recent work to review the operation of the Community Infrastructure Levy in the UK together with earlier work undertaken by Oxera in 2008 on land development taxes.
JIL31 You have used incorrect build costs, the difference of which is roughly equivalent to the proposed levy, so it doesn't work.
No evidence has been provided for alternative costs and so this statement cannot be tested.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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3. Proposed levy Office Rates A levy rate of £85 per square metre of development has been proposed for office developments. Do you think that this is a viable rate?
Questionnaire consultation results
% Total Count
Yes 43% 14
No 43% 14
Not Sure 14% 5
Total 100% 31
Yes43%No
43%
not sure14%
3.Proposed levy office rates
Summary of Responses
Although this question provided a balanced view from respondents,
as with the residential rates, some of those supporting the levy
opposed the levy rate as they considered it too low (without
evidence), which does not give a true picture of the overall
statistical results to this question.
With regards to those comments who were opposed to the levy, a
number of valid points were made but no new or alternative direct
local evidence is produced to support the comments made.
Many of the comments received were repeated from the previous
question on residential rates and the subsequent one on retail
rates.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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Please give reasons for your answer and provide any relevant evidence.
Ref Supporting/ Objecting Reasons for answer States of Jersey Response
JIL3 Yes This should probably be higher. The rates are based upon recommendations in the viability assessment for review of developer contributions report which was an extensive and soundly evidenced piece of work and has recommended rates that would be viable.
JIL6 Yes for non resident companies double it
JIL7 Yes We need simple and clear charging structure. Yes it could be higher or lower, but we have to start somewhere and this can then be reassessed with time/ experience
The single rate levy structure is considered to be simple and clear and more importantly viable.
JIL10 Yes Agree as many businesses get away with not paying the portion of costs that residents pay Unable to comment
JIL14 Yes It may be a case to exempt some development or to charge upon a variable scale depending on the nature and scale of development (if it is the re-development of an existing structure, building on an existing footprint then perhaps to be treated differently to a green-site development)
Following recommendations made in viability assessment for review of developer contributions report, the levy is applied only to certain development types (Residential, office and retail) and then only for net new development. A conversion of an office use to residential for example would not be charged the levy unless a new additional floor was added to the building.
JIL17 Yes Seems a reasonable compromise amount Comments noted – the levy has been designed to be simple to use,fair and equitable. JIL18 Yes Jersey does not require any more office space, if this was the proposal developers
would think very carefully and those who can afford this i.e. the finance sector would go ahead.
Comments noted but not directly related to the Levy proposal.
JIL19 Yes No more offices please. We need houses not offices. Comments noted but not directly related to the Levy proposal. JIL20 Yes I agree with this, as commercial property incurs an enormous amount of
revenue. Every new development already includes, at the planning application stage, landscaping (trees, gardens, environment) and a play area (if appropriate). It also includes access and pathways.
Comments noted
JIL23 Yes In line with UK, and we have to start somewhere Comments noted JIL27 Yes This needs to be measured though against the planning gain The contributions made by developers through the current planning obligation
agreement (POA) policy is included and is part of the modelling undertaken in the viability assessment for review of developer contributions report. It is considered that the levy is viable and will be delivered through the awarding of planning permission. Should the levy be adopted POA’s will be reviewed and some dropped. However some will still be in place to capture specific planning gain from developments that have a significant local impact (e.g. drainage commination, road junction improvements, etc.
JIL22 Yes I think it should be £100 The viability assessment for review of developer contributions report recommended a range of rates across development types. The Minister has proposed a consistent rate for all development types in order to provide a simple, equitable and fair policy framework.
JIL21 not sure Are the levels of human traffic around an office development not higher and therefore more maintenance hungry than a residential development, a higher rate would seem sensible
JIL12 not sure Creation of office development contributes to the economy of the island directly Comments noted JIL25 not sure If this figure has been reached following local professional research then it is correct.
If this figure has been brought over from a local authority in the UK then it will not be applicable to Jersey, prices and wages are higher and community aspirations different. In the absence of a States Social Policy we are all working independantly to help integrate the community, we have to ensure anything we do is relevant to our community. Erecting a sculpture in business developments doesnt add much to peoples lives, living art does. Areas for families to meet at lunch time, areas for parents to feed and care for children, areas for outdoor meetings, play areas to allow
The viability assessment for review of developer contributions report was an extensive and soundly evidenced piece of work undertaken by both UK and local consultants using Jersey costs and values. Should the levy be adopted, it will deliver public realm improvements for the benefit of the wider community. The percent for art scheme is voluntary and will still run alongside any new JIL policy.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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Ref Supporting/ Objecting Reasons for answer States of Jersey Response
business areas to be part of community space, all these forms of art add quality to peoples working days.
JIL29 Not sure Insufficient information available to make comment. The rates are based upon recommendations in the viability assessment for review of developer contributions report published with the survey
JIL35 Not Sure Residential, retail and office developments are two very different things so it's unusual that you would charge the same rate?
The viability assessment for review of developer contributions report concluded that the potential rates that could be applied varied from between £80/Sqm- £150/Sqm depending upon the development types. However, the Minister has decided that for the levy to be simple to use, equitable and fair a lower standard rate should be applied to all development types.
JIL2 No Once again this care will be passed on and fails to address business which operate in jersey but which pay no corporation tax who should pay more
The levy is not expected to increase rental prices. The levy will be a small part of the overall cost of development, and it is expected that developers will either negotiate to pay less for land they buy in time, or absorb some of the cost.
JIL1 No Jersey business inflated rents here we go The levy represents a small percentage of GDV (2.5%) and is designed to be taken off the land. End rental values should not be significantly impacted by the levy. The levy is not expected to increase rental prices. The levy will be a small part of the overall cost of development, and it is expected that developers will either negotiate to pay less for land they buy in time, or absorb some of the cost. Developers set asking prices for new developments, but values are set by the market and this is usually based on what similar houses in the area sell for, as well as the formal valuation carried out by a bank’s appointed valuer, if the buyer is applying for a mortgage for the property. A buyer or renter of a new property will only pay a premium for a new property if it is more attractive than those in the wider market. In the long-run, a fixed levy will provide certainty about the level of charge that a developer must pay and they will be able to factor this in to the price that they pay for land. Through the informal consultation with the development industry that was carried out to inform the Viability Assessment, comments were received raising the concern that the levy would be added to the sale prices of developments thus increasing already high house prices in Jersey. The department has had initial discussions with the Economics Unit and their view is that charges like the Jersey Infrastructure Levy (JIL) that intend to capture a small fraction of the uplift in land values that arise when a site gets permission for development would normally be expected to impact on land values. In a competitive market developers would have a strong incentive to make sure the charge leads to lower land values because if not new built properties would become relatively more expensive than similar properties that have already been developed and were not subject to the levy. New developments only add a marginal increase to the existing stock each year and in a competitive market prices will be determined by the interaction of overall supply and demand for properties and therefore general conditions in the market. This conclusion is supported by recent work to review the operation of the Community Infrastructure Levy in the UK together with earlier work undertaken by Oxera in 2008 on land development taxes.
JIL30 No In the same way as residential property prices will be inflated, so office rental costs will spiral. It is not my purpose to be rude or offensive, but the public sector appears to have no regard for the long term effect on the economy of measures like this. One of Jersey's few USPs is its quality, but quality has a price ceiling too and this proposed tax will be another nail in the coffin of Jersey's competitiveness. Continue like this and our government will invoke a negative spiral of diminishing activity and further increases in taxes.
JIL5 No Increases rentals, in order to get a viable return.
JIL4 No This should be at least £200 per metre The rates are based upon recommendations in the viability assessment for review of developer contributions report, which was an extensive and soundly evidenced piece of work and has recommended rates that would be viable.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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Ref Supporting/ Objecting Reasons for answer States of Jersey Response
JIL8 No As above, I do not agree with the levy on principle. Either an office development is approved in accordance with the Island Plan because it is required (in which case no levy should be charged) or it is rejected, in which case such a levy is irrelevant.
The levy is separate to current planning policies and the principle is based upon using the profit from awarding planning permission to pay for community improvements for the benefit of all Islanders.
JIL9 No It is a stealth tax and should not be charged. JIL11 No This just increases the general costs of development that are already excessive and
have driven out the chance of any smaller developer. The island is now so expensive that only companies with huge financial resources can operate.
Larger companies are likely to have a more competitive edge on certain types of developments, particularly where economy of scales exist, however the levy is considered to be a marginal cost which should be negotiated from the land value and allow forms of all sizes to operate as normal on the island.
JIL13 No Business arguably produce more CO2 emissions, with that reasoning they should pay more.
The levy is not targeted to directly reduce the output of Co2. The Energy Plan for Jersey is the policy vehicle for Co2 reduction on Jersey.
JIL15 No The states have already put off investors building offices by having the states underwrite the IFC now they want to tax new developments perhaps to help ensure thier IFC built before they bring in the new tax has another advantage. Please stop this mad tax or I will look to invest elsewhere.
The levy will be applied to all developers of offices, including the Jersey Development company. The levy represents a small percentage of GDV (2.5%) and is designed to be taken off the land. JIL24 No The cost to a business of moving premises is already far too high and much more
expensive in Jersey than elsewhere. Businesses may move from the Island if the cost of doing business in Jersey is too high.
JIL31 No You have used incorrect build costs, the difference of which is roughly equivalent to the proposed levy, so it doesn't work.
No evidence has been provided for alternative costs and so this statement cannot be tested.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
19
4. Proposed levy Retail Rates A levy rate of £85 per square metre of development has been proposed for retail developments. Do you think that this is a viable rate?
Questionnaire consultation results
% Total Count
Yes 33% 11
No 52% 17
Not Sure 15% 5
Total 100% 33
Summary of responses
Although this question provided a more negative view (52%) from
33 respondents, some of those supporting the levy opposed the
levy rate as they considered it too low (without evidence), which
does not depict a true picture of the overall view of the imposition of
retail rates.
With regards to those comments who were opposed to the levy, a
number of valid points were made but no new or alternative direct
local evidence is produced to support the comments made.
Many of the comments received were repeated from the previous
question on residential and office rates.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
20
Please give reasons for your answer and provide any relevant evidence.
Ref Supporting/ Objecting Reasons for answer States of Jersey Response
JIL3 Yes This should probably be higher.
The rates are based upon recommendations in the viability assessment for review of developer contributions report which was an extensive and soundly evidenced piece of work and has recommended rates that would be viable.
JIL6 Yes for non-resident companies double it JIL7 Yes We need simple and clear charging structure. Yes it could be higher or lower, but we
have to start somewhere and this can then be reassessed with time/ experience JIL22 Yes I think it should be £100 JIL10 Yes Agree as many businesses get away with not paying the portion of costs that
residents pay JIL14 Yes It may be a case to exempt some development or to charge upon a variable scale
depending on the nature and scale of development (if it is the re-development of an existing structure, building on an existing footprint then perhaps to be treated differently to a green-site development)
Following recommendations made in viability assessment for review of developer contributions report, the levy is applied only to certain development types (Residential, office and retail) and then only for net new development. A conversion of an office use to residential for example would not be charged the levy unless a new floor was added to the building.
JIL16 Yes No comment Noted JIL20 Yes I agree with this, as retail developments incur an enormous amount of revenue. The rates are based upon the detailed recommendations in the viability assessment for
review of developer contributions report. JIL23 Yes In line with UK, and we have to start somewhere Comments noted JIL27 Yes This needs to be measured though against the planning gain The contributions made by developers through the current planning obligation
agreement (POA) policy is included and is part of the modelling undertaken in the viability assessment for review of developer contributions report. It is considered that the levy is viable and will be delivered through the awarding of planning permission. Should the levy be adopted POA’s will be reviewed and some dropped. However some will still be in place to capture specific planning gain from developments that have a significant local impact (e.g. drainage commination, road junction improvements, etc.
JIL12 not sure Creation of retail development contributes to the economy of the island directly Comments noted JIL25 not sure Retail developments should have quiet areas for people to sit, areas for children to
play and for families to be together. Spaces for performing arts should be available, small spaces for individual performers are as valuable as larger spaces for group performance. Again, this sum must be as a result of local research
Comments noted, the rate is based upon the detailed recommendations in the viability assessment for review of developer contributions report, which was undertaken using local relevant data.
JIL29 not sure Insufficient information available to make comment. The rates are based upon recommendations in the viability assessment for review of developer contributions report published with the survey
JIL35 not sure Residential, retail and office developments are two very different things so it's unusual that you would charge the same rate?
The modelling undertaken in the viability assessment for review of developer contributions report recommended a range of viable levy rates, with residential rates being able to be charged of up to £125/Sqm and retail up to £150/Sqm. The Minister has decided to have a single lower rate across all developments types in order to keep the levy simple to use, fair and equitable.
JIL4 No This should be £50 The rate is based upon the detailed recommendations in the viability assessment for review of developer contributions report.
JIL17 not sure Retail is suffering because of on line competition. If the £85 adds to retail overheads this may not be a good idea
JIL1 No Jersey retail inflated rents here we go
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
21
Ref Supporting/ Objecting Reasons for answer States of Jersey Response
JIL11 No This just increases the general costs of development that are already excessive and have driven out the chance of any smaller developer. The island is now so expensive that only companies with huge financial resources can operate.
The levy is not expected to increase rental prices. The levy will be a small part of the overall cost of development, and it is expected that developers will either negotiate to pay less for land they buy in time, or absorb some of the cost.
Developers set asking prices for new developments, but values are set by the market and this is usually based on what similar houses in the area sell for, as well as the formal valuation carried out by a bank’s appointed valuer, if the buyer is applying for a mortgage for the property.
A buyer or renter of a new property will only pay a premium for a new property if it is more attractive than those in the wider market.
In the long-run, a fixed levy will provide certainty about the level of charge that a developer must pay and they will be able to factor this in to the price that they pay for land.
Through the informal consultation with the development industry that was carried out to inform the Viability Assessment, comments were received raising the concern that the levy would be added to the sale prices of developments thus increasing already high house prices in Jersey. The department has had initial discussions with the Economics Unit and their view is that charges like the Jersey Infrastructure Levy (JIL) that intend to capture a small fraction of the uplift in land values that arise when a site gets permission for development would normally be expected to impact on land values. In a competitive market developers would have a strong incentive to make sure the charge leads to lower land values because if not new built properties would become relatively more expensive than similar properties that have already been developed and were not subject to the levy. New developments only add a marginal increase to the existing stock each year and in a competitive market prices will be determined by the interaction of overall supply and demand for properties and therefore general conditions in the market.
JIL30 No In the same way as residential property prices will be inflated, so retail rental costs will spiral. It is not my purpose to be rude or offensive, but the public sector appears to have no regard for the long term effect on the economy of measures like this. One of Jersey's few USPs is its quality, but quality has a price ceiling too and this proposed tax will be another nail in the coffin of Jersey's competitiveness. Continue like this and our government will invoke a negative spiral of diminishing activity and further increases in taxes.
JIL24 No Retailers won't come to the Island. The High Street will start to see vacant shops. This will impact on the whole economy.
JIL2 No As this charge will be passed on it is merely going to hike jersey prices in a period of uncertainty and make jersey shops even less competent I've.
JIL5 No The extra rental costs will need higher prices, which drives business to the internet.
JIL8 No I do not agree with the levy on principle. Either a retail development is approved in accordance with the Island Plan because it is required (in which case no levy should be charged) or it is rejected, in which case such a levy is irrelevant.
The levy is separate to current planning policies and the principle is based upon using the profit from awarding planning permission to pay for community improvements for the benefit of all Islanders.
JIL9 No It is a stealth tax and should not be charged. The introduction of a levy is in line with practice elsewhere and is a way of ensuring that through the planning process, a small percentage of the profit from land development is allocated to improving or providing new community infrastructure to improve the quality of life for people living, working and visiting that area. The levy represents a small fraction of increase in land value taken from the awarding of planning permission and it is considered appropriate to use this to mitigate against the wider impact that development has on the local community
JIL13 No Business arguably produce more CO2 emissions, with that reasoning they should pay more.
The levy is not targeted to directly reduce the output of Co2. The Energy Plan for Jersey is the policy vehicle for Co2 reduction on Jersey.
JIL15 No The states have already put off investors building offices by having the states underwrite the IFC now they want to tax new developments perhaps to help ensure thier IFC built before they bring in the new tax has another advantage. Please stop this mad tax or I will look to invest elsewhere. it is wrong in principle ill thought out and will only damage the economy
The levy will be applied to all developers of offices, including the Jersey Development company. The levy represents a small percentage of GDV (2.5%) and is designed to be taken off the land.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
22
Ref Supporting/ Objecting Reasons for answer States of Jersey Response
JIL18 No I don't think the retail sector could afford this charge, and Jersey needs the retail sector.
The levy is not expected to increase rental prices. The levy will be a small part of the overall cost of development, and it is expected that developers will either negotiate to pay less for land they buy in time, or absorb some of the cost. The rates are well evidenced and based upon the detailed recommendations in the viability assessment for review of developer contributions report.
JIL19 No We pay GST why more levys, get rid of some of the surplus useless civil servants who work for planning and environment, I am clueless as to what they are doing to improve either.
GST was introduced to pay for a specific budget gap in Jersey finances following the introduction of zero-ten. The civil Service seeks to provide an excellent cost effective service to Jersey citizens, including the delivery of planned and future infrastructure community projects should the levy be adopted.
JIL21 No I think there's a reasonable expectation that a shop keeper would be managing their shop front and surrounding area for their own best interests, and that the taxpayer would commit to funding the upkeep of the shared spaces (eg King Street). Why put another barrier in front of the retail sector?
It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable. General income tax receipts will remain to fund other public services. The Government is currently undertaking a major reform/efficiency programme aimed at improving Public Services which is not the appropriate route to fund public realm improvement plans from development related activities.
JIL26 No Community infrastructure should be paid for out of income tax - this is the existing position and seems to have worked for decades. Commercial development of real estate is already taxed at 20%.
JIL28 No The states already collect a levy from citizens, its called income tax. Adding further cost simply pushes up the cost of living in Jersey which is to no bodies advantage. The argument that there is a budget shortfall is not acceptable. The States should learn to manage within its means and not fund further spending through a range of stealth taxes.
JIL31 No You have used incorrect build costs, the difference of which is roughly equivalent to the proposed levy, so it doesn't work.
No evidence has been provided for alternative costs and so this statement cannot be tested.
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5. Exemptions It is proposed that developments undertaken by the following would be exempt from paying the levy: •Developments for charitable purposes •Affordable housing providers •Public developments (e.g. schools & hospitals)
Questionnaire consultation results
% Total Count
Agree 42% 14
Neither 10% 3
Disagree 48% 16
Total 100% 33
Summary of responses
Although this question provided a slightly more negative view (48%)
from 33 respondents, some of those supporting the principle of the
levy opposed the proposed levy exemptions as they considered
them to be too generous (without evidence), which does not reflect
the overall statistical outcome of this question.
Comments about proposed exemptions were mixed suggesting that
exemptions were too narrow or that there should be no exemptions
at all. None of the alternative suggestions received were evidenced
and were based on speculation or unsupported assertions.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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Please give reasons for your answer and if appropriate provide evidence for alternatives to those listed.
Ref Supporting/ Objecting Reasons for answer States of Jersey Response
JIL4 Agree As many of these are used by the public (hospital, schools and affordable housing) this should be exempt Comments noted
JIL10 Agree Lifts the burden from the public who would most likely have to pay through taxes or direct donations for these. Comments noted
JIL22 Agree Seems fair Comments noted JIL23 Agree Those who are pocketing the highest unearned profits should contribute
the most The exceptions have been considered based upon evidence from the viability assessment for review of developer contributions report, which tested the levels of contribution a development could viably make. The minimum profit level assumed for all forms of development was 20% and so contributions could only be made above this level.
JIL27 Agree This needs to be measured though against the planning gain The contributions made by developers through the current planning obligation agreement (POA) policy is included and is part of the modelling undertaken in the viability assessment for review of developer contributions report. It is considered that the levy is viable and will be delivered through the awarding of planning permission. Should the levy be adopted POA’s will be reviewed and some dropped. However some will still be in place to capture specific planning gain from developments that have a significant local impact (e.g. drainage commination, road junction improvements, etc.
JIL29 Agree This proposal would seem appropriate given that providers are community focused. However, it could be that although there is exemption from payment of the levy and proposed development has to include information relating to how it will engage with the community and support its development.
Comment noted
JIL30 Agree And I'd go much further and exempt all development. In other words, scrap this plan. Comment noted
JIL35 Agree Totally agree, smart move. Comment noted JIL1 Disagree It just proves that the charge will be a burden on normal buildings if you are
already considering a reduction ion these areas It is unclear what is meant by ‘normal buildings’. The exceptions are based upon the detailed recommendations in the viability assessment for review of developer contributions report.
JIL2 Disagree How can you ensure charity status for a building. It may become retail at end of first lease. Unworkable
Detailed policy guidance will be developed to cover all administrative sides of the policy, including the exceptions made such as to charitable development, which will likely be linked to the new Charities (Jersey) Law 2014 for example.
JIL7 Disagree If one area has more public building development because of its preferred location then the locals should see an upside. Comment noted
JIL8 Disagree I do not agree with the levy on principle. Either a residential development is approved in accordance with the Island Plan because it is required (in which case no levy should be charged) or it is rejected, in which case such a levy is irrelevant.
The levy is separate to current planning policies and the principle is based upon using the profit from awarding planning permission to pay for community improvements for the benefit of all Islanders.
JIL11 Disagree I do not agree with exemptions because I do not agree with a levy period. Comment noted JIL12 Disagree But also where the owner is retaining ownership after development in
whatever capacity. Public developments also create pressure on infrastructure without necessarily contributing anything to the economy
The exceptions are based upon the detailed recommendations in the viability assessment for review of developer contributions report. Public buildings are by definition benefiting the Island community and often are developed to include additional public spaces which ordinarily a commercial development would not include.
JIL13 Disagree We have a responsibility to reducing the burden of climate change to our children, no one should be exempt. Comment noted
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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Ref Supporting/ Objecting Reasons for answer States of Jersey Response
JIL14 Disagree If the building is potentially causing net harm to the environment then a levy would be reasonable
The levy is not targeted to directly reduce the output of Co2. The Energy Plan for Jersey is the policy vehicle for Co2 reduction on Jersey.
JIL15 Disagree This tax will make slow development and hence cause more need for thing slink states provided social housing. Dropping this tax is the only sensible course if you have any wish to see investment and growth buildings in Jersey undertaken by the private sector.
The introduction of a levy is in line with practice elsewhere and the recent report A new approach to developer contributions from the CIL review group has not indicated any issues with reducing investment or growth in the construction sector. The levy represents a small fraction of increase in land value taken from the awarding of planning permission and it is considered appropriate to use this to mitigate against the wider impact that development has on the local community which will not have an appreciative effect on slowing or hindering the development process.
JIL18 Disagree I agree that Charities and Public developments should be exempt, however the public developments must be for the use of the general public or for the benefit of the general public. I think affordable housing developments could have a sliding attached to them as some developers would massage the criteria to enable their development to be exempt. What is the definition of "affordable housing" has this been agreed or debated?
Comments noted. Affordable housing is currently defined in the States approved Revised 2011 Island Plan as: Affordable (Category A) housing includes homes for social rent and purchase, provided to specified eligible households whose needs are not met by the commercial housing market. Affordable housing should meet the needs of persons on median incomes or below, who would otherwise have financial difficulties renting or purchasing residential accommodation in the general residential market, determined with regard to income levels and house prices prevailing in Jersey; and Affordable housing may be owned and managed by a housing trust or association which provides homes to eligible families or individuals by means of sale or lease or by any other means on conditions that will ensure that the home will remain available for eligible families in the future. In order to ensure that the benefit of and access to affordable housing provided under this policy is not lost to future eligible households, conditions or restrictions may be imposed to ensure that the benefit may be recycled or retained in order to ensure the provision of affordable housing meets the needs of this and future generations. The eligibility of households to access affordable housing shall be determined by their assessment through the Affordable Housing Gateway. The Minister is committed to good quality design in housing and, in particular, will require that affordable homes be built to meet or exceed the standards for homes set out in supplementary planning guidance. To ensure that homes are truly affordable the Minister will encourage innovation in construction methods and alternative methods of home ownership and housing delivery. The clear relationship between affordable housing and the Affordable Housing Gateway means that housing that is developed for sale on the open market (Category B) is excluded from the definition of affordable housing whatever price it is sold at.
JIL19 Disagree Stop cherry picking. If its not needed then why all this cost in a consultation.
The exceptions are based upon the detailed recommendations in the viability assessment for review of developer contributions report
JIL21 Disagree Single use homes, the 75 sq. metre is too small - if a person is investing heavily in their own 3 bed house for example, why charge them again. Affordable housing needs to be treated the same as any other development, communal space is communal space.
The 75 Sqm is only applicable on net new development. Charging the levy on affordable housing developments would be unviable and significantly impact the supply of new Homes planned by the affordable housing providers. The same residential standards are applied to all housing development, regardless if it is affordable or not.
JIL25 Disagree There should be no exemptions, this makes for a very clear situation. Keep it simple. Charities should be allowed to claim this levy back from the Tax Dept. All charities are registered with the Tax Dept in order to obtain charitable status so claiming this levy back will ensure only registered charities can do this. Public developments and affordable housing
The exceptions are based upon the detailed recommendations in the viability assessment for review of developer contributions report
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Ref Supporting/ Objecting Reasons for answer States of Jersey Response
providers have a responsibility to the community to provide something in exchange for the space they need
JIL31 Disagree This is discriminatory and the landowners would be the ones who benefitted, not the developing parties.
JIL34 Disagree I disagree that buildings for charitable purposes should be exempt for two reasons. Firstly as harsh as it sounds charities are effectively businesses. Their product is 'for good intention' but they operate with income,costs and profit. Jersey hospice are a rich local charity. They build new wings as it stimulates donations, enables them to treat more people and receive more income. Charities struggle to fundraise for operating costs, but capital builds have substance and are easily funded. Les ormes for example is a charity, yet it's becoming one of the largest tourist accommodation sites in the island, competing with all the commercial operators, to somes detriment. The staff get paid, it has a well paid Managing director, it's just the profit goes back in to continue its growth. Secondly housing trusts are in a similar vein. They run commercially save for their profits not being distributed they are just reinvested. The staff of the trusts and directors are all well paid.. and they compete with other providers. It is not inconceivable for large developers or wealthy individuals to setup a charity in which to provide a home and charge rent to bypass the fees.. there is an esplanade of lawyers who exist solely to find loopholes. Given there is actually no charity board here and thousands of charitable trusts etc this will soon be exploited.
Comments noted and will be reviewed further. Should the policy be adopted as published then the exceptions made such as to charitable development will likely be linked to the new Charities (Jersey) Law 2014 to ensure compliance.
JIL3 Neither You haven't defined these. If I build a block of flats and say one flat is affordable housing whatever that means then will I be exempt? Developers will utilise these loop holes and I bet planning who are all their mates will do nothing about it.
Detailed policy guidance will be developed to cover all administrative sides of the policy, including the exceptions made such as to affordable housing. Under the example provided, the single flat in the block of flats built for affordable housing would be exempt. The remaining floor space in the block of flats would not.
JIL24 Neither I don't support the Levy at all. Comment noted JIL26 Neither Community infrastructure should be paid for out of income tax - this is the
existing position and seems to have worked for decades. Commercial development of real estate is already taxed at 20%.
It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable. General income tax receipts will remain to fund other public services.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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6. Proposed types of development to be subject to the levy Viability testing demonstrated that only Residential, Office and Retail developments would be applicable for the new levy.
Questionnaire consultation results
% Total Count
Agree 33% 11
Neither 15% 5
Disagree 52% 17
Total 100% 33
Summary of responses
Although this question provided a more negative view (52%) from
33 respondents, some of those supporting the levy opposed the
levy rate as they considered more developments types should be
charged the levy (without evidence), which does not give a true
picture of the overall negative view to this question.
Equally, none of the alternative suggestions received were
evidenced, rather being based on speculation or unsupported
assertions.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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Please give reasons for your answer.
Ref Supporting/
Objecting Reasons for answer Minister’s Response
JIL4 Agree I think that this is a very good idea as many offices can afford to pay and possibility of residential and retail which make plenty of money to pay these fees Comment noted
JIL10 Agree Lifts the burden from the public who would most likely have to pay through taxes or direct donations for these. Comment noted
JIL16 Agree No comment No Comment noted JIL17 Agree I accept recommendation Comment noted JIL22 Agree Yes, think the viability range showed it could be a bit higher though. The viability assessment for review of developer contributions report recommended an
overall lower figure, although for residential developments it could be as high as £125/Sqm. The Minister has kept the rates the same in order to provide a simple, equitable and fair policy framework.
JIL23 Agree These are the developments that make the most profit, therefore they should be in the first tranche to have to pay the JIL Comment noted
JIL27 Agree This needs to be measured though against the planning gain The contributions made by developers through the current planning obligation agreement (POA) policy is included and is part of the modelling undertaken in the viability assessment for review of developer contributions report. It is considered that the levy is viable and will be delivered through the awarding of planning permission. Should the levy be adopted POA’s will be reviewed and some dropped. However some will still be in place to capture specific planning gain from developments that have a significant local impact (e.g. drainage commination, road junction improvements, etc.
JIL29 Agree This is supported on the basis that there is evidence from the viability testing. Comment noted JIL19 Agree Cherry picking is not normally acceptable by your department, so why now? The exceptions are based upon the detailed recommendations in the viability
assessment for review of developer contributions report JIL3 Disagree Surely all commercial developments. Again another loophole. JIL6 Disagree all should pay Comment noted JIL8 Disagree As above, I do not agree with the levy on principle. Comment noted JIL12 Disagree Not residential The exceptions are based upon the detailed recommendations in the viability
assessment for review of developer contributions report, no evidence is offered by the commentator to test removal of residential.
JIL9 Disagree Residential should definitely be exempt.
JIL13 Disagree We have a responsibility to reducing the burden of climate change to our children, no one should be exempt.
The levy is not targeted to directly reduce the output of Co2. The Energy Plan for Jersey is the policy vehicle for Co2 reduction on Jersey. The exceptions are based upon the detailed recommendations in the viability assessment for review of developer contributions report
JIL18 Disagree See previous: I agree that Charities and Public developments should be exempt, however the public developments must be for the use of the general public or for the benefit of the general public. I think affordable housing developments could have a sliding attached to them as some developers would massage the criteria to enable their development to be exempt. What is the definition of "affordable housing" has this been agreed or debated?
Comments noted. Affordable housing is currently defined in the Revised 2011 Island Plan – full definition is outlined response to Question 5.
JIL21 Disagree 'Residential use' too broad, specify the number of units and above before levy is applied. Exclude retail for the timebeing.
Residential will exclude affordable housing - defined in the Revised 2011 Island Plan and any development under 75Sqm. The exceptions are based upon the detailed recommendations in the viability assessment for review of developer contributions report, no evidence is offered by the commentator to test removal of retail.
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Ref Supporting/ Objecting Reasons for answer Minister’s Response
JIL25 Disagree All development should be liable for the new levy. Exempting States funded development is not a balanced position.
The exceptions are based upon the detailed recommendations in the viability assessment for review of developer contributions report, Commercial states developments (e.g. Esplanade Quarter) will not be exempt from the levy. it is right that Public buildings are exempt as they benefit the Island community and often include additional public spaces which ordinarily a commercial development would not.
JIL20 Disagree I do not agree that this "tax" should be included in residential developments (see my comments above).
It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable. General income tax receipts will remain to fund other public services. The Government is currently undertaking a major reform/efficiency programme aimed at improving Public Services which is not the appropriate route to fund public realm improvement plans from development related activities.
JIL26 Disagree Community infrastructure should be paid for out of income tax - this is the existing position and seems to have worked for decades. Commercial development of real estate is already taxed at 20%.
JIL28 Disagree The states already collect a levy from citizens, its called income tax. Adding further cost simply pushes up the cost of living in Jersey which is to no bodies advantage. The argument that there is a budget shortfall is not acceptable. The States should learn to manage within its means and not fund further spending through a range of stealth taxes.
JIL30 Disagree How many more times do I need to write this. This is a BAD idea - period! Comment noted JIL31 Disagree The viability is flawed, because the build costs are incorrect. No evidence has been provided for alternative costs and so this statement cannot be
tested. JIL5 Disagree The extra rental costs will need higher prices, which drives business to the internet. The levy is not expected to increase rental prices. The levy will be a small part of the
overall cost of development, and it is expected that developers will either negotiate to pay less for land they buy in time, or absorb some of the cost. Developers set asking prices for new developments, but values are set by the market and this is usually based on what similar houses in the area sell for, as well as the formal valuation carried out by a bank’s appointed valuer, if the buyer is applying for a mortgage for the property. A buyer or renter of a new property will only pay a premium for a new property if it is more attractive than those in the wider market. In the long-run, a fixed levy will provide certainty about the level of charge that a developer must pay and they will be able to factor this in to the price that they pay for land. Through the informal consultation with the development industry that was carried out to inform the Viability Assessment, comments were received raising the concern that the levy would be added to the sale prices of developments thus increasing already high house prices in Jersey. The department has had initial discussions with the Economics Unit and their view is that charges like the Jersey Infrastructure Levy (JIL) that intend to capture a small fraction of the uplift in land values that arise when a site gets permission for development would normally be expected to impact on land values. In a competitive market developers would have a strong incentive to make sure the charge leads to lower land values because if not new built properties would become relatively more expensive than similar properties that have already been developed and were not subject to the levy. New developments only add a marginal increase to the existing
JIL11 Disagree It is already far to costly JIL1 Disagree Another tax that will have to be passed on, with a small group of "committee"
members deciding how and where it is spent JIL15 Neither Viability testing? Any fool with simple economics know this will simply put up end use
cost and in an island with very high build costs already this is mad. You want new buildings that are fit for purpose so the people can work and live and great economic growth. This tax will simple slow down growth and keep Jersey lagging behind other jurisdictions that aren't so stupid.
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Ref Supporting/ Objecting Reasons for answer Minister’s Response
stock each year and in a competitive market prices will be determined by the interaction of overall supply and demand for properties and therefore general conditions in the market.
JIL2 Neither I don't agree that any levy is appropriate or workable Comment noted JIL7 Neither No comment No Comment noted JIL14 Neither If that is what the viability testing suggests then I cannot comment! No Comment noted JIL24 Neither I don't agree with this levy at all. Comment noted
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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7. Proposed levy thresholds It proposed that the levy will only apply to developments 75 square metres or more in size or where there is the creation of an additional residential unit.
Questionnaire consultation results
% Total Count
Agree 36% 12
Neither 18% 15
Disagree 46% 6
Total 100% 33
Summary of responses
There were some mixed comments that either suggested the 75
Sqm threshold is too high or that there should be no or a reduced
threshold to increase those developments liable to pay the levy.
None of the alternative suggestions received were evidenced,
rather being based on speculation or unsupported assertions.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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Please give reasons for your answer.
Ref Supporting/ Objecting Reasons for answer States of Jersey Response
JIL3 Agree This shouldn't penalise people simply wanting to improve their homes. It should be solely for developers drawing in this income from development. So this on initial consideration looks feasible
Comment noted – the minimum size is aimed at reducing the levy impact for those simply wishing to improve the family home for example.
JIL6 Agree for small extension don’t see why they should pay. Comment noted JIL7 Agree There does need to be some de-minimus Comment noted JIL10 Agree A reasonable starting point which would allow smaller extensions but catch the larger
site where the development would most likely be made for enhanced income. Comment noted
JIL16 Agree No comment No Comment noted JIL17 Agree This seems reasonable Comment noted JIL18 Agree Perhaps this question should have come earlier Comment noted JIL22 Agree Seems fair Comment noted JIL23 Agree Small developments do not make such a profit; those making the most profit should
pay Comment noted
JIL25 Agree This amount of space would allow the building on of accommodation for an elderly relative or a child with special needs. The community is being encouraged to care for themselves as far as possible so this would fit with the Social Care initiatives.
Comment noted
JIL27 Agree This needs to be measured though against the planning gain The contributions made by developers through the current planning obligation agreement (POA) policy is included and is part of the modelling undertaken in the viability assessment for review of developer contributions report. It is considered that the levy is viable and will be delivered through the awarding of planning permission. Should the levy be adopted POA’s will be reviewed and some dropped. However some will still be in place to capture specific planning gain from developments that have a significant local impact (e.g. drainage commination, road junction improvements, etc.
JIL2 Disagree If it is intended to encourage undersize and inappropriate hutches for working people then this is the way to go!
The levy will be applied to all developments over 75Sqm and represents a small percentage (2.5%) of Gross Development Value (GDV) which is designed to be taken off the value of the land. Other planning measures to control the size of dwellings will not be affected by the introduction of the levy and which are currently being reviewed with a view to increase minimum sizes.
JIL4 Disagree This should be for 60 square metres or more The 75 Sqm is equivalent to a 2 bedroom flat in size and was chosen because of the view that it was reasonable to allow families to develop their homes to create more family space for immediate or dependent relatives for example. Equally statistics from the planning register indicated that the 75 Sqm was the upper boundary of what is seen as more domestic scale developments.
JIL5 Disagree The extra rental costs will need higher prices, which drives business to the internet. The levy is not expected to increase rental prices. The levy will be a small part of the overall cost of development, and it is expected that developers will either negotiate to pay less for land they buy in time, or absorb some of the cost. Developers set asking prices for new developments, but values are set by the market and this is usually based on what similar houses in the area sell for, as well as the formal valuation carried out by a bank’s appointed valuer, if the buyer is applying for a mortgage for the property. A buyer or renter of a new property will only pay a premium for a new property if it is more attractive than those in the wider market.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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Ref Supporting/ Objecting Reasons for answer States of Jersey Response
In the long-run, a fixed levy will provide certainty about the level of charge that a developer must pay and they will be able to factor this in to the price that they pay for land. Through the informal consultation with the development industry that was carried out to inform the Viability Assessment, comments were received raising the concern that the levy would be added to the sale prices of developments thus increasing already high house prices in Jersey. The department has had initial discussions with the Economics Unit and their view is that charges like the Jersey Infrastructure Levy (JIL) that intend to capture a small fraction of the uplift in land values that arise when a site gets permission for development would normally be expected to impact on land values. In a competitive market developers would have a strong incentive to make sure the charge leads to lower land values because if not new built properties would become relatively more expensive than similar properties that have already been developed and were not subject to the levy. New developments only add a marginal increase to the existing stock each year and in a competitive market prices will be determined by the interaction of overall supply and demand for properties and therefore general conditions in the market.
JIL8 Disagree I do not agree with the levy on principle. Either a residential development is approved in accordance with the Island Plan because it is required (in which case no levy should be charged) or it is rejected, in which case such a levy is irrelevant.
The levy is separate to current planning policies and the principle is based upon using the profit from awarding planning permission to pay for community improvements for the benefit of all Islanders.
JIL9 Disagree Residential units of any kind should be exempt. Comment noted but reasons not provided and so cannot be tested. JIL11 Disagree I disagree with the levy Comment noted JIL12 Disagree Not residential Comment noted but not evidenced or reasoned and so unable to consider change JIL13 Disagree We have a responsibility to reducing the burden of climate change to our children, no
one should be exempt. The exceptions are based upon the detailed recommendations in the viability assessment for review of developer contributions report
JIL14 Disagree Creation of an additional office space or retail unit show also apply here? Any floor space for retail or office over 74Sqm wold be charged the levy. JIL19 Disagree Sort this mess out, some single sites are more obnoxious and imposing on the
community than larger sites, the building at La Coupe is one such site. This did nothing for the Coastal National Park farce.
Comment noted but does not directly relate to the levy.
JIL20 Disagree This is just another "tax" on the end user. It is a "tax" which appears to be only based on the square metre-age of the site, therefore, if the development is a block of flats, it will only be based on the ground floor area? Every new development already includes, at the planning application stage, landscaping (trees, gardens, environment) and a play area (if appropriate). It also includes access and pathways.
The proposal is for the levy to be applied to all new net floor areas only and will only apply to the buildings and not landscaping or footpaths.
JIL21 Disagree Definition is too small. An additional residential unit for a children or elderly relative should be supported without this additional charge applied to it. The premise is to take a fraction from the profits of the larger commercial developers as a public social responsibility, squeezing small amounts from individuals, families or smaller investors isn't right and unlikely to add any great value and therefore becomes a stealth tax.Define the purpose of the levy more clearly then implement and regulate it.
Developments of less than 75Sqm which are likely able to accommodate an elderly relative or children will not be charged the levy. Detailed policy guidance will be developed to cover all administrative sides of the policy once it has been approved in principle.
JIL26 Disagree Community infrastructure should be paid for out of income tax - this is the existing position and seems to have worked for decades. Commercial development of real estate is already taxed at 20%.
It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. JIL15 Neither We must not bring this mad tax in at all for all the above reasons.
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Ref Supporting/ Objecting Reasons for answer States of Jersey Response
JIL28 Disagree The states already collect a levy from citizens, its called income tax. Adding further cost simply pushes up the cost of living in Jersey which is to no bodies advantage. The argument that there is a budget shortfall is not acceptable. The States should learn to manage within its means and not fund further spending through a range of stealth taxes.
It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable. General income tax receipts will remain to fund other public services. The Government is currently undertaking a major reform/efficiency programme aimed at improving Public Services which is not the appropriate route to fund public realm improvement plans from development related activities.
JIL31 Disagree This is so small, it should start at zero The exceptions are based upon the detailed recommendations in the viability assessment for review of developer contributions report
JIL1 Neither Another tax that will have to be passed on, with a small group of "committee" members deciding how and where it is spent The levy will be spent according to publically agreed priorities.
JIL24 Neither I don't agree with this levy at all. Comment noted JIL29 Neither Insufficient information The exceptions are based upon the detailed recommendations in the viability
assessment for review of developer contributions report published with the survey JIL30 Neither If we do not have this levy the question is redundant. Comment noted JIL34 Neither How would this be policed. Could a large scale development of a lot of units of less
than 75m be setup as individual developments. If you build 150 units of 74m you would face a fee of almost £1m for £30,000 you could setup 150 different development companies developing a single unit of less than 75m and save almost £950,000, and yes people,would do it. It would also stagnate houses at a size of 75m or under as single builds, which is not necessarily beneficial.
Detailed policy guidance will be developed to cover all administrative sides of the policy once it has been approved in principle. The guidance will cover all of the points raised by this comment to ensure that such situations do not materialise and the levy is applied fairly and evenly across all developments.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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8. Reduced Planning Obligation Agreements
Introducing the levy will mean reviewing and reducing the current requirements for certain planning obligation agreements (e.g. bus and eastern cycle route contributions)
Questionnaire consultation results
% Total Count
Agree 25% 8
Neither 25% 8
Disagree 50% 16
Total 100% 32
Summary of responses
From the written responses it is clear that there is some misperception over the use and recent changes made to the POA policy. The significant number of respondents who disagreed (50%) did not want a reduction in the contributions made by developers with the introduction of the levy. This is not the intention but rather some items from the POA policy will be moved to be paid for from the levy. The development industry expressed some concerns about being asked to contribute for the same infrastructure through the levy and through the POA system. This is also not the intention and will be considered in more detail should the principle of the levy be adopted.
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
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Please give reasons for your answer.
Ref Supporting/ Objecting Reasons for answer Minister’s Response
JIL13 Agree Planning must review all applications on their impact on climate change, Likewise all proven drawdown methods including Regenerative Agriculture should have all restrictions taken away, we must draw down atmospheric CO2, CO2 reduction is not going to be enough. Please look up www.drawdown.com
The levy is not targeted to directly reduce the output of Co2. The Energy Plan for Jersey is the policy vehicle for Co2 reduction on Jersey.
JIL17 Agree It replaces the current arrangements Comment noted. Although the levy work alongside a reduced POA policy JIL22 Agree YEs, seems an excellent idea designed to allow better and more strategic planning of
spending for the public good. Comment noted
JIL23 Agree They shouldn't pay twice for the same thing, but the £85/m2 figure can always be revised upwards in the future as demands increase (climate change, carbon taxes, sea level rises, international commitments, etc will require more focussed thinking in this area in the years and decades to come)
The levy regulations and changes to the POA policy will ensure that there will be no ‘double dipping’. The rate of the levy will always be based upon the most current evidence of viability
JIL27 Agree This needs to be measured though against the planning gain The contributions made by developers through the current planning obligation agreement (POA) policy is included and is part of the modelling undertaken in the viability assessment for review of developer contributions report. It is considered that the levy is viable and will be delivered through the awarding of planning permission. Should the levy be adopted POA’s will be reviewed and some dropped. However some will still be in place to capture specific planning gain from developments that have a significant local impact (e.g. drainage commination, road junction improvements, etc.
JIL30 Agree In principle, much more development that is presently controlled should be deregulated.
Comment noted, the Minister has recently issued new guidance that extends the permitted development rights.
JIL31 Agree But this won't happen, because government is trying to squeeze every last £ from wherever it can. Cynical, but true.
Comment noted, but the levy rate has been conservatively proposed from viability evidence that suggested higher rates could be applied.
JIL35 Agree As long as though sort of things are not disregarded. It must be ensured that levy funds are put back into planning projects that better the community, The ring fencing of funds is a key principle of the proposal
JIL1 Disagree The tax is already a burden and two cycle paths (St Peters Valley and Airport) are not used by cyclists as it is, so are a gross waste of money
It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable. General income tax receipts will remain to fund other public services. Cycle paths are an important alternative safe travel option and are increasingly being used as cycle tracks become more accessible.
JIL3 Disagree There should be no reduction in the requirement for developers to not improve the area for the community.
Comment noted, the proposed levy will not replace but work alongside a reduced POA policy
JIL4 Disagree As there is so much traffic in the east the levy should be free The level of traffic in an area will not impact upon the levy rate. JIL6 Disagree Additional funding from this should not go towards existing obligations but new.
perhaps consider solar power on all developments, and where charitable social Comments noted and will be considered should the levy be adopted.
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Ref Supporting/ Objecting Reasons for answer Minister’s Response
housing etc use yhese new funds to provide that. After all it's these homes that have the least wealthy residents and it would help cut their living costs.
JIL7 Disagree We have to ensure we end up with more funds being allocated into cycle routes/ public transport solutions, not less.
Comments noted. The levy would provide more funding for transport as well as other important community initiatives.
JIL8 Disagree As above, I do not agree with the levy on principle. Comment noted JIL9 Disagree 'Agree', 'Neither', 'Disagree': The wording of this survey omits the glaringly obvious
3rd answer option: 'This proposed Levy is morally wrong and should be withdrawn!' Disagree comment noted.
JIL11 Disagree Government taxes enough already it needs to cut its cloth accordingly The levy represents a small fraction of increase in land value taken from the awarding of planning permission and it is considered appropriate to use this to mitigate against the wider impact that development has on the local community and not related to the general income tax policy which funds essential services
JIL12 Disagree If there was a reason for the obligations they should remain POA’s will remain in place for site specific matters such as drainage or junction/access improvements for example.
JIL20 Disagree I think that the current system works well. The recently published POA guidance has made the policy clearer but POA’s are limited to site specific matters and would not be able to provide the area wide benefits envisaged by the levy.
JIL24 Disagree The POA obligations are appropriate JIL16 Disagree I feel there is no real justification for a reduction in current requirements JIL19 Disagree The government should be sorting out cycle routes in an economical way, use
cheaper and more rider friendly asphalt. The avenuse cycle trak is not straight, has a porr quality and uneven surface, this route should be a priority. Also try cycling down Mont Felard between 7 and 9 am.
The levy will be able to improve and extend cycle areas, using the most cost effective delivery method but engineered to modern safe standards.
JIL21 Disagree An Island the size of Jersey surely only needs a single form of development levy!? This Jersey Infrastructure Levy should seek to replace all others entirely or should be shelved until a better solution is available, eg putting up Income Tax instead of these additional charges.
Comments noted but the existing POA’s system is required to ensure site specific matters are mitigated through a formal agreement to ensure their delivery as part of a planning application.
JIL25 Disagree Do not open the system to interpretation by reducing the requirements, this will lead to a reduction in the quality of the environment, green backdrops etc
This is not the intention and both the levy and POA’s will provide an effective and simpler policy regime to deliver public benefit.
JIL28 Disagree The whole levy is ill conceved and I cannot accept that it should substitute current practice Comments noted JIL2 Neither As I disagree with the levy no change is needed
JIL5 Neither I don't think there should be a levy, so the question is redundant, as my answer JIL10 Neither Cycle routes are expensive and usually go through the green belt which if done
correctly as St Peters can be a major funding issue and best provided through direct taxation and allow this proposal to target more urban environmental improvements
Comment noted and in some cases large infrastructure projects could be delivered in this way.
JIL14 Neither As long as other obligations laid out within a planning decision (EIA, scoping etc) are not bypassed then this is acceptable and if other obligations can be put upon the developers (such as inclusion of enforced mitigation within the schemes) then that would be useful.
This is the intention as both the levy and a reduced POA policy will be required.
JIL15 Neither As above every tax on investment is madness we want investment and new buildings that help our economy grow and provide good housing for our population why would you tax investment. This is also encourage making buildings inc houses as small as possible to reduce the level per sq metre.
The levy will provide significant benefits to the community whilst still enabling investment to be made in the built environment as evidenced in the viability assessment for review of developer contributions report and the introduction of a levy is in line with practice elsewhere and the recent report A new approach to developer contributions from the CIL review group has not indicated any issues with reducing investment or growth in the construction sector. The size of units are controlled by existing planning guidance and which are currently being reviewed with a view to increase minimum sizes.
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Ref Supporting/ Objecting Reasons for answer Minister’s Response
JIL18 Neither I don't have sufficient knowledge or information to make an informed decision Comment noted JIL26 Neither No view noted JIL29 Neither It would appear sensible to review any other relevant policies and obligations prior to
introducing the levy Noted
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9. Community share
It is proposed that Parishes and local communities where development occurs will receive 10% of the levy to pay for local community improvements. Questionnaire Consultation results
% Total Count
Agree 36% 12
Neither 9% 3
Disagree 55% 18
Total 100% 33
Summary of responses
The proposed 10% split of the levy for exclusive Parish use also generated
mixed views with some of those who supported it some suggesting a higher
share. This will be something for future consideration.
Many comments identified the need for an audited and managed process to
spending the levy and this will be part of future regulations should the levy be
adopted.
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Please give reasons for your answer.
Ref Supporting/
Objecting Reasons for answer Minister’s Response
JIL3 Agree Yes. Comment noted JIL10 Agree They may have a better insight on the local views and needs of their community Comments noted, engaging with the local community is key to delivering successful JIL
projects JIL13 Agree Any decentralization is a good thing, this will encourage Constables to do the right
thing to reduce the burden for you younger generation. Comment noted
JIL29 Agree Whilst this is agreed it is vital to recognise that there are different types of communities in addition to Parish and local (geographical) communities. There are communities of practice e.g. groups of interested parties focused on improving their practice, such as early years workers. There are community groups who come together for specific purposes or around specific interests e.g. special needs and disabilities. There are communities who may be defined by particular characteristics e.g. ethnicity. There are communities of people who come together around shared values to work together with a particular focus e.g. the Early Years and Childhood Partnership. It would be important in considering distribution of the levy to have regard for the different types of communities.
The levy would encourage local community groups to come forward and support projects that are specific to them and the local area, regardless of the parish boundaries. The levy could also for example act as seed capital for crowd funded projects and this has proven success elsewhere such as in Plymouth for example. www.crowdfunder.co.uk/funds/crowdfund-plymouth
JIL27 Agree I would though restrict this for schemes that demonstrably improve either pedestrian or cycle access.
The spending of the levy will be controlled through regulations limiting it to delivering agreed high priority community infrastructure projects.
JIL24 Disagree This is a "random" amount. How can it be guaranteed the parishes will properly spend the money. Where has the need for these "community infrastructure improvements" been identified? Each parish's needs will be different- what if a parish has a "need" but no developments? This is a random further tax and has no logic to it.
JIL26 Disagree Local community improvements should not be considered separately. There should be a holistic approach to infrastructure provision to prevent inefficiency and waste through excessive administration.
JIL14 Disagree Given the perhaps unwise use of money seen (for example in St Mary) for road improvements when money is given to Parishes then I do not feel that this would necessarily be the best use of the money. For Parishes to apply for money from the scheme for well thought out plans would be better.
JIL18 Agree With criteria imposed for the spending of this windfall i.e. for families and communities
JIL25 Agree This % should be given with a caveat that there is local consultation for the use of this money. Community improvements is open to interpretation by the Constables, the parishioners should have an opportunity to determin their environment.
JIL22 Agree Its a figure that allows some small scale local projects to also be delivered. For info I would like to see a likely sum/split to the parishes (based on hindcasting over a few years if the data is available?) just for info.
The 10% would represent an approximate annual income to parishes of around £150-£200k
JIL23 Agree Why not. We'll see what happens to it. Comment noted JIL30 Agree Of course. Because the parishes are much better at managing resources than central
government. That said, my argument is that this proposal should be dropped, in which circumstance there will be not new tax revenue to share.
Comment noted
JIL34 Agree Sadly the island does not have a good track record in community development. We are building parks which are badly designed with shared spaces, which have proven the have killed. Yet other core public areas such as liberation square are in a shambolic state. I think the funds should generate need to be reviews and not wasted
Comment noted, the levy will
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Ref Supporting/ Objecting Reasons for answer Minister’s Response
on overly designed or ambitious ill conceived plans, likemcycle tracks that have a surface that can't be cycled on.
JIL21 Disagree 10% means 90% could go to another part of the Island entirely, this is wrong, the area where development occurs needs to receive the lion's share of investment.
The intention is that the areas that accept new development will benefit from receiving levy funds and so given that St Helier has the largest share of new developments it is going to receive the greatest proportion of levy funding
JIL9 Disagree Unless the States' 'user pays' policy has been scrapped, at least 50% should benefit local community improvements so that the 'users' (eg. new residents) in an area might enjoy some of the benefits of their ill-gotten levy.
JIL20 Disagree I believe that the levy should be used within the development area only. JIL2 Disagree Why should country parish benefit from a scheme designed to enhance town
primarily. JIL35 Disagree Disagree, 10% is too low a figure it should me much higher. The funds are not to be
taken to "balance the books" the whole point of the levy is to benefit the community. When you only use 10% it basically just becomes a tax and makes the government look bad.
These comments are noted and will be considered when taking forward any proposal for adoption.
JIL16 Disagree I think this could be higher in the present economic climate, say 15 to 20% JIL4 Disagree There should be more paid to the parishes (like 20%) as 10% is too small JIL7 Disagree Whilst I agree the funds raised should be used to fund projects in that parish, I'm not
satisfied that the parish authorities have the skills/ controls to manage this in order to deliver maximum value for £ spent. Given we are only a small island, this should be one body with clear strategy set at Govt level
The mechanism for managing and delivering the parish share has not been detailed and so these points will be considered when developing the regulations on this part of the levy. JIL1 Disagree Another tax that will have to be passed on, with a small group of "committee"
members deciding how and where it is spent JIL8 Disagree As above, I do not agree with the levy on principle. Furthermore, the parishes are
perfectly capable of putting any improvements to their parishioners and agreeing to set rates appropriately if such improvements are democratically approved at a parish assembly.
Comments noted
JIL11 Disagree Developers are providing this island with a service by building what accommodation we need they should not be taxed further .Developers build the accommodation government through general taxation pay for the improvements.
It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable. General income tax receipts will remain to fund other public services.
JIL15 Neither We don't need extra tax and not on investment in our housing and office stock which need investment
JIL28 Disagree Parishes should be paying for local community improvements out of rates as they do at the moment. Major improvements should be decided on and funded by the states as at present.
JIL31 Disagree I disagree with the whole principle of a J.I.L. Also the parishes are functioning quite fine through their rates system. Comment noted
JIL12 Neither Irrelevant Comment noted
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10. Spending the Levy It has been estimated that based upon past conservative build rates and the final rate chosen that the levy could yield up to £1.5 and £2.5 million per year. Please rank the following items in order of preference you would like the levy to be spent on
Survey consultation results
Rank Preference % Total 1 New and improved streets, play spaces, community
gardens & parks 18%
2 Improved public open spaces 17% 3 safer pedestrian/cycle routes 14% 4 Climate change resilience- e.g Sustainable urban
drainage, tree planting, etc. 13%
5 none of these options 11% 6 improvements to public transport 10% 7 community facility/projects 11% 8 public art 6% Total 100%
new and improved streets, play spaces,
commmunity gardens & parks
18%
Improved public open spaces
17%
safer pedestrian/cycle
routes14%
Climate change resilience- e.g
Sustainable urban drainage, tree planting, etc.
13%
none of these options
11%
improvements to public transport
10%
community facility/projects
11%
public art6%
10. Spending the Levy
Summary of responses
There was a fairly even spread of priorities for spending the levy, although the most popular - new and improved streets, play spaces, community gardens & parks (18%) was 3 times more popular than the least – public art (6%). These views will be considered in more detail should the principle of the levy be adopted.
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11. General Comments
Please provide any other general comments.
Ref Reasons for answer Minister’s Response JIL1 Tax is tax, revenue should be collected and spending decided upon in a whole budget, not spread
by the back door to try and keep Jersey's headline tax at the famous 20%
It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable. General income tax receipts will remain to fund other public services. The Government is currently undertaking a major reform/efficiency programme aimed at improving Public Services which is not the appropriate route to fund public realm improvement plans from development related activities.
JIL8 This is a surrogate tax and goes beyond the remit of government. The £2.5m that could be raised is extremely small compared with the overall SOJ budget. It will introduce another layer of bureaucracy and has no real justification.
JIL15 I hope the island does not bring this mad tax on investment in housing and our working environments ie offices two areas we need investment if we are to keep top people in the island living and working which creates the main tax for our government ie income tax. This tax will reduce investment and over time lead to a working and living environment far below other countries.
JIL7 Jersey is falling well behind the UK in developing a cycle and pedestrian infrastructure in its built up environment. Given the UK is way behind European cities that is very embarrassing in deed. Our ration of cars per individual is equally shocking. We desperately need to plan long term infrastructure to move from car use to cycle/ walking and public transport through carrot and stick initiatives. All £ raised by any levy should directly go into initiatives to improve the living and working environment, focussed primarily on St Helier. Allowing development but ensuring that there is net more green space is delivered in that area can be done by i) being prepared to build higher and ii) reinvesting levies such as is now being proposed back into the locality- just look at the long term planning in Vancouver, where the foreshore has remained public access, more green space than virtually any other city yet a bustling and thriving local population (voted no2 best city to live in the world)
JIL11 Government through general taxation should pay for the improvements to the civic realm. JIL4 should be more open spaces in the smaller parishes i.e. St Clement as there are too many
buildings going up. The larger parishes should have more buildings made in their parish I.e St Mary , St John, St Ouen, St Peter
JIL30 This is a new tax. Instead of introducing new taxes government should be learning how to manage the economy more effectively. When (if) it does it will discover there is no need for new taxes. I am happy for my survey responses to be published.
JIL20 Ref: 10. above: surely our rates are for some of these things. Re the Viability Study: public opinion is that the States spend far too much money on "Consultants" to provide "reports" - the hospital is a prime example. It appears to me that The States waste so much money.
JIL31 It is about time that States departments learnt to live within their means and stopped dreaming up new taxes.
JIL32 Thank you for the opportunity to comment upon the above mentioned. This email is provided with the full knowledge and total backing of our entire client base. We are completed opposed to any further tax increases in Jersey, particularly during this period of global/European uncertainty. In December, 2016 the Island had just under 59,000 people working and 1/6 of retired also working, all paying tax (albeit some not paying Income Tax/Social Security). The general view is that the overall tax take when considering the above should be more than adequate to enable the island to meet all of its various public sector commitments. The wish to improve/upgrade the islands infrastructure, services and facilities is very laudable and supported but should be done from the Treasury using existing resources. This kind of tax has been in operation in the UK for some time and has been found to be very 'resource hungry' to operate, provocative leading to substantial delays and litigation, which all has a trickle down inflationary affect upon the market. There is also considerable concern that this particular tax would be very discriminatory and once outside of the
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Ref Reasons for answer Minister’s Response control of The States Chamber, liable to be increased ahead of the rate of inflation as indeed has been the case with several similar taxes locally now in operation. We would with the greatest respect urge you to impress upon the minister the depth and breath of these concerns.
JIL28 The States already collect a levy from citizens, its called income tax. Adding further cost simply pushes up the cost of living in Jersey which is to no bodies advantage. The agument that there is a budget shortfall is not acceptable. The States should learn to manage within its means and not fund further spending through a range of stealth taxes.
JIL9 As I said, the entire Island will benefit from improved roads and public transport, parks and open spaces, public art and cycle paths so funding for this should come from Island taxes and parish rates. It is yet another stealth tax, it is wrong and it should be withdrawn.
JIL13 What is Regenerative Agriculture and why a CO2 levy would be the right thing to do to encourage landowners to cultivate a new crop CO2 Conventional wisdom has long held that the world cannot be fed without chemicals and synthetic fertilizers. Evidence points to a new wisdom: The world cannot be fed unless the soil is fed. Regenerative agriculture enhances and sustains the health of the soil by restoring its carbon content, which in turn improves productivity—just the opposite of conventional agriculture. Regenerative agricultural practices include: no tillage, diverse cover crops, in-farm fertility (no external nutrients), no pesticides or synthetic fertilizers, and multiple crop rotations. Together, these practices increase carbon-rich soil organic matter. The result: vital microbes proliferate, roots go deeper, nutrient uptake improves, water retention increases, plants are more pest resistant, and soil fertility compounds. Farms are seeing soil carbon levels rise from a baseline of 1 to 2 percent up to 5 to 8 percent over ten or more years, which can add up to 25 to 60 tons of carbon per acre. It is estimated that at least 50 percent of the carbon in the earth’s soils has been released into the atmosphere over the past centuries. Bringing that carbon back home through regenerative agriculture is one of the greatest opportunities to address human and climate health, along with the financial well-being of farmers.
Noted, but carbon reduction has no direct relevance to the proposed introduction of the infrastructure levy. The Energy Plan for Jersey is the policy vehicle for Co2 reduction on Jersey.
JIL14 Provision of money to local NPO/Charities (such as the Jersey Bat Group - of which I am the chair) to enable us to effectively screen the developments, advise on best-practice (such as not using BRM in developments), suggest mitigation, monitor and educate about bats would be useful. Currently both planning decisions and building control 'requirements' are coming into conflict with bats. These are a protected species both locally and across the EU and Jersey is party to a number of MEAs to protect these animals.
Comments noted – such use of the levy will be subject to future discussion but it should be noted that the existing planning process makes provision for the mitigation, monitoring and protection of bats.
JIL16 There is a growing demand for motorcycle/scooter/moped parking as more and more motorists move away from commuting to work by car (single occupant) Too much on road parking is prioritised towards four-wheeled vehicles, and at a time when we need to reduced congestion and pollution caused by that congestion more could be done to encourage the use of two-wheeled vehicles whether motorised/electric or manually propelled. Perhaps new developments in partnership with Infrastructure could be made to provide allocated parking for motorcyclists and cyclists too.
The provision of parking for all forms of vehicles is provided by the planning parking guidance, which is currently being reviewed and updated to account for modern parking requirements.
JIL26 In my view, the questions to this consultation have been drafted so as to bias responses as they presuppose the introduction of the levy and highlight the 'selling points' to those who will not bear the cost of implementation. They do not even attempt to identify whether the respondent will actually be likely to pay the levy or whether it would affect the intentions or otherwise have consequences for developers. For the avoidance of doubt, I am neither a developer nor do I act for developers.
The levy is not expected to increase rental prices. The levy will be a small part of the overall cost of development, and it is expected that developers will either negotiate to pay less for land they buy in time, or absorb some of the cost. Developers set asking prices for new developments, but values are set by the market and this is usually based on what similar houses in the area sell for, as well as the formal valuation carried out by a bank’s appointed valuer, if the buyer is applying for a mortgage for the property. A buyer or renter of a new property will only pay a premium for a new property if it is more attractive than those in the wider market.
JIL12 If implemented such a levy may prevent private/individual developments that would benefit the community whilst major developments will only pass on the charge directly to the occupants thereby potentially raising costs across the whole spectrum.
JIL24 I think this levy is completely wrong. Where has the need been identified? The need may not be in the parish where development is being undertaken. It is a tax on business (another one) and will
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Ref Reasons for answer Minister’s Response be passed on to the end-consumer. The cost of "doing business in Jersey" is becoming far too high. Govt should manage its finances properly and stop taxing business when it fails to do so.
In the long-run, a fixed levy will provide certainty about the level of charge that a developer must pay and they will be able to factor this in to the price that they pay for land. Through the informal consultation with the development industry that was carried out to inform the Viability Assessment, comments were received raising the concern that the levy would be added to the sale prices of developments thus increasing already high house prices in Jersey. The department has had initial discussions with the Economics Unit and their view is that charges like the Jersey Infrastructure Levy (JIL) that intend to capture a small fraction of the uplift in land values that arise when a site gets permission for development would normally be expected to impact on land values. In a competitive market developers would have a strong incentive to make sure the charge leads to lower land values because if not new built properties would become relatively more expensive than similar properties that have already been developed and were not subject to the levy. New developments only add a marginal increase to the existing stock each year and in a competitive market prices will be determined by the interaction of overall supply and demand for properties and therefore general conditions in the market.
JIL35 You must try and ensure two things, that the levy isn't just passed on to the consumer and that the the majority, if not all, of the funds are used to better the community.
JIL17 I am in favour of this levy so long as the cost ultimately falls on the person making the development gain. I am not in favour of it increases the cost of housing and retail
JIL19 Get a Minister and executive who are not sucking up to major developers and have some environmental understanding and have the will to undertake some meaningful environmental and historical conservation rather than the corrupt bunch we have had to date.
The Minister and the executive have an excellent track record in improving and applying an effective policy framework that to deliver significant historic and environmental conservation benefits for the Island. The development of a levy will enable further conservation efforts to be made, which in turn requires a strong development sector to be in place.
JIL21 Agree with the principle of a development charge, disagree with the 'small and broad-based' nature of it. Needs to target multi-unit developments that will significantly increase footfall, traffic, parking etc and not include the addition of a bedroom to an existing property etc.
The levy will only be applied to residential units over 75 Sqm in size and so single bedrooms, unless over 75 Sqm would not be included.
JIL18 There are many sources of research available that show our children are not having enough time outdoors. Many of our children exhibit weight problems brought about in some cases by poor diet and not enough exercise. Parents state that working life inhibits their ability to provide healthy food and opportunities for exercise in the outdoors, they also state that stranger danger and traffic stop them allowing their children to play out. The Dutch Woonerf concept allows for childrens play https://nacto.org/docs/usdg/woonerf_concept_collarte.pdf Developers who followed this design could be exempt from the Levy
Comments noted As currently proposed the levy, if adopted, would be able to deliver improvements in these areas.
JIL29 There are many sources of research available that show our children are not having enough time outdoors. Many Jersey children have weight problems brought about, in some cases by poor diet and not enough exercises. Parents state that working life inhibits their ability to provide healthy food and opportunities for exercise in the outdoors. They also state that stranger danger and traffic stop them allowing their children to play out. The Dutch Woonerf concept allows for children's play in residential areas. Information can be assessed at https://nacto.org/docs/usdg/woonerf_concept_collarte.pdf It is proposed that developed who followed this design could be exempt from the levy. Many parts of the UK are now developing "play streets" e.g. http://www.leeds.gov.uk/residents/Pages/Play-Streets.aspx This would be a useful concept to consider in relation to the levy. Similarly if play rangers were to be considered in the distribution of the levy, this could provide support for children and help parents feel more secure. Information is available at: https://playgloucestershire.org.uk/ There is an area of discussed land adjacent to derelict greenhouses in St Clement. This has the potential to be developed for families and the elderly. If land like this were to be developed, there must be provision for outdoor play for children. This should allow for free play on natural surfaces as well as the usual static equipment. The development, delivery and sustainability of such proposals would be significantly supported by the creation of a "play team" that encouraged resourceful play, resilience and holistic appropriate social/emotional development. Historically, there has been agreement Play is of fundamental importance to the general health, well-being and overall development of all children and young people. Play has also been recognised as providing positive outcomes for children in terms of their journey into adulthood. Whilst many adults
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Ref Reasons for answer Minister’s Response possess memories of being free to roam and experience their local environment and all the excitement and dangers that it held, children of today are protect to the point of stifling their natural ability to develop their own resilience, common sense and self-regulation skills. Jersey's children and young people are not always able to access the same range of services, facilities or opportunities that others have in the UK, mainland Europe or elsewhere although what we do have in abundance are beautiful beaches, some lovely parks and open spaces just waiting for children and families to claim them. What is clear is that all children, regardless of their socio-economic background, should have access to good quality play opportunities that hey can access safely on their own and with their friends. These play opportunities should provide physical and mental challenge for our children, who are then ready to test and grow their resilience, self-esteem and social development. Good play provision in Jersey should provide the following: * Extends the choice and control that children have over their play, the freedom they enjoy, and the satisfaction they gain from it * Recognises that children need to test boundaries, and responds positively to that need * Recognises that children have a voice and gives them the opportunity to be involved in the planning of play spaces * Manages the balance between the need to offer risk and the need to keep children safe from harm * Maximises the range of play opportunities * Promotes independence and healthy self esteem * Encourages the child's respect for others and offers opportunities for social interaction * Supports the child's well-being, healthy growth and development, knowledge and understanding, creativity and capacity to elarn It may come as a surprise to learn that "play" benefits the Community by involving children and their families in positive activities. This is turn helps to reduce anti-social behaviour and the risk of crime. Having play opportunities at the hub of a community helps to create a focal point. Families are encouraged to be social, building enhanced support networks and children are guided towards their adults lives by a range of significant experienced and unrelated people. "We don't stop playing because we grow old; we grow old because we stop playing." George Bernard Shaw, 1856 - 1950 Jersey's children are our future. The levy provides a brilliant opportunity to invest in the future through our children.
JIL25 In the absence of a States Social Policy all fight their own corners. We want children and families to be supported by all people in power being aware of the way they work impacts on this group. Building pushes play spaces further away from where children live. Facilities that allow children to "play out" independently, without adult supervision in a safe area near to their home. Traffic is the greatest danger to childrens safety, by removing traffic you provide children with the space to play out. Bristol University have recently published findings on this and Bristol Council have been working to provide for children for many years. No traffic zones benefit all the community, they dont have to be permanent, electric bollards in use twice a week is enough to start regular patterns for play and leisure. Cul de sacs, grassy banks, back to back housing with a lane between the gardens that can be blocked off and used by people from the houses for their own public space, the list of opportunities to develop the community is endless. Play England has research and ideas for community development as does a blog "Playing Out". These types of initiatives support educational development in children, provide healthy exercise and community integration. Jersey Early Years Association is a registered charity, we hold expertise on childrens play and work voluntarily to promote the well being of young children and their families.
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12. Individually submitted responses
A number of individual responses were also received by post or email outside of the online consultation. These are listed below together with responses to specific points where appropriate.
12.1 States of Jersey Environment Minister - Addendum
1. During the consultation it was pointed out that there was a tying error on page 65 of the viability assessment for review of developer contributions report. This is acknowledged and table 7.2 should have been published with the figures in bold (the published incorrect figures are bracketed below the correct figures). The error did not affect the overall final total build costs figures or any of the subsequent conclusions reached in the viability modelling which used the correct total figure.
Table 7.2 Summary of Costs for Housing Only Schemes Cost Adjustment For Appraisal £/m2
Construction Costs – BICIS 2017 £1,067.00 1.2 £1,280.40
(£1380.40)
Site Costs 15% £192.06 (£92.06)
Brownfield 10% £128.04 £1600.50 Contingency 5% £80.03 Total £1,680.53 £1,680.53
Source: HDH March 2017
2. For the purposes of demonstrating that the principle of introducing an infrastructure levy in Jersey is viable, the Minister has set out a notional levy rate of £80 per Sqm (amended from the published £85 per sqm) to ensure an even rate is applied across all proposed developments on the Island. This is because although the maximum rates of £125 per Sqm for residential and £150 per Sqm for retail were suggested by the consultant (HDH) in the viability assessment for review of developer contributions report, the maximum rate for offices was £80 per sqm and this should have been reflected in the flat rate published in the consultation by the Minister. Should the principle of the levy be approved then all the recommendations will be revised and updated based upon any new evidence at that time. This will then lead to final rates being proposed which are then be subject to further public consultation and review by an independent planning inspector before final adoption.
12.2 States of Jersey Minister for Housing – key points from letter dated 7th August 2017
Ref Comment States of Jersey Para
3 I am also pleased to note that registered affordable housing providers will be exempt from the levy. Affordable housing providers make a significant contribution towards meeting the housing needs of the community – such as first-time buyers and households who are unable to access suitable housing in the private sector – so it is right to exempt them from the levy. I agree with the consultation document that there is potential for the exemption to encourage the provision of more affordable housing.
Comments noted
Para 4
I recognise concern about the impact that the proposed levy might have on the price of housing in Jersey. Clearly, it is important that the levy does not have an adverse effect on the feasibility of new housing development, and it is reassuring to note that the viability study confirms there is scope to introduce a levy on larger-scale developments. I further note that the States of Jersey Economics Unit has concluded that a levy would be unlikely to affect land values because, in a competitive market like Jersey, developers have a strong incentive to factor in a levy and press for a drop in the price of the land.
Comments noted
Para 5
Moreover, I agree with the assessment that the proposed levy will not increase house prices, which are determined by the market and the interaction between the supply and demand of housing. Comments noted
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12.3 Association of Jersey Architects – key points from letter dated 6th September 2017
Ref Comment States of Jersey Response 1 We agree with the sentiment expressed by the Minister and his opening statement within the JIL
consultation document in that 'the spaces around and between buildings including parks, squares and streets, has a major part to play in the character, attractiveness and success of places' we also recognise the Ministers view that the 'delivery of a successful place requires strong partnership between government, land owners, developers and the public'.
Comment noted.
2 As architects we have required skills and knowledge to advise and deliver these places and our profession should be at the forefront of these types of regeneration projects / improvement schemes which aim to enhance the public realm and we believe that consultation and engagement with our association members should be at the forefront of any proposed public realm improvement proposals.
Comment noted.
3 Our Association fully understands the Planning Ministers desire to enhance and improve the public realm within St. Helier but we do not accept that the proposed Jersey Infrastructure levy (JIL) is a fair or reasonable method of delivering these improvements.
Comment noted.
4 The improvements proposed which will benefit from the introduction of this Levy are not clearly defined and are merely representative and they lack clarity and focus. The concept of introducing this levy (development tax) without the presentation of a coherent plan showing the public realm improvements is not acceptable.
The Minister is at this stage only trying to establish the principle of introducing a levy. Developing detailed plans of schemes without any levy (budget) in place is a bit ‘cart before the horse’ and not the best use of internal resources. The consultation document does however very clearly set out those broad areas that would benefit from using the levy, namely;
• New and improved streets, play spaces, community gardens & parks • Improved public open spaces • safer pedestrian/cycle routes • Climate change resilience- e.g. sustainable urban drainage, tree planting, etc. • improvements to public transport • community facility/projects • public art
5 If adopted we do not accept that this fund / pot as it is defined in the executive summary should be managed only by the Minister for the Environment.
Noted but reasons not given and so unable to comment. Ring fencing the money received from the levy will be established though regulation and directed by an executive to meet clear community benefits. Views on who the chair of the executive is have not been decided and further opportunity to discuss these points will be available should the principle of introducing a levy be adopted.
6 We have grave concerns regarding the use of the term 'infrastructure' and the wide definition of this term and the types of projects that could be deemed as infrastructure projects which could then seek funding from this income source / levy (if adopted).
Agreed, the term can be confusing and an alternative may emerge over time to provide a clearer understanding of the policy.
7 We do not accept that construction projects are singularilary responsible for the Islands infrastructure requirements and it is therefore fundamentally unacceptable for the construction industry to be individually targeted and subjected to an additional taxation to fund infrastructure projects.
It is considered right for a small proportion of the increase in land value arising from the grant of planning consent to be shared with the community, rather than going solely to the landowner. It is also considered right that funds derived from the development of land are used to offset some of the impact of that development upon the community, to make them better places to live, work and visit. Almost all development has some impact on the need for infrastructure, services and amenities - or benefits from it - so it is only fair that all such development pays a
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Ref Comment States of Jersey Response share of the cost. It is also right that those who benefit financially when planning permission is given should share some of that gain with the community which granted it, to help fund the infrastructure needed to make development acceptable and sustainable. General income tax receipts will remain to fund other public services.
8 We do not accept that the proposed infrastructure levy will not be passed on in some way either in full or partially from the landowner to the developer and then onto the purchaser and it is naive of the Planning Department to suggest otherwise.
This statement is difficult to comment upon as no evidence that it will has been provided. Advice has been taken from the economics department that is contrary to this. The Economics Unit view is that charges like the Jersey Infrastructure Levy (JIL), would normally be expected to impact land values. In a competitive market, developers would have a strong incentive to make sure the charge leads to lower land values because if not, new built properties would become relatively more expensive than similar properties that have already been developed and were not subject to the levy. Earlier work undertaken here in Jersey by Oxera, and more recent work undertaken in the UK to assess the impact of the Community Infrastructure there, has concluded that the introduction of a levy has little long-term economic impact on the supply of development land. This backs up the view expressed by Oxera’s report Further analysis of land/development-based environmental taxes: what is the impact on Jersey? (January 2008), which concluded that: Assuming that the proportion of the increase in value to be taken in tax would be relatively small, even if the full incidence of the tax fell on owners, it is likely that there would be little effect on the overall supply of land made available for development. Recent research from the UK (The value, impact and delivery of the Community Infrastructure Levy: Report of Study (Feb 2017) DCLG ) demonstrates that the introduction of CIL has not adversely affected the overall supply of developable land. Further economic advice will be sought from the Economics Unit to test and amend if necessary, a more detailed levy proposal, should there be any likelihood that the levy could lead to higher prices and/or reduced supply.
9 We do not believe that any levy or tax applied to any planning approval should be used for matters such as improved transport services, drainage systems or flood defences as noted in the infrastructure levy consultation document. We also note that within the ARUP report infrastructure is defined as: (a) roads and other transport facilities, (b) flood defences, (c) schools and other educational facilities, (d) medical facilities, (e) sporting and recreational facilities (f) open spaces and (g) affordable housing (although it's accepted that affordable housing will not be funded by this tax). These simple definitions clearly show how the funds generated from this levy (if introduced) could be used or miss-appropriated. All of the above should be funded through general taxation.
The consultation makes it clear what could be funded by the levy and what should not. The Arup definition is based upon UK policy and background information as part of the viability study which is not directly applied to Jersey.
10 We are concerned that the control of these funds could be passed to another States department or Minister simply be Ministerial order without any consultation with industry
Concern noted. Should the principle of the levy be adopted then regulations will be written which will ensure that the levy is managed in the most appropriate way to meet the anticipated community benefits.. These regulations will be fully consulted upon.
11 We are concerned that the current infrastructure budgets / income raised from general taxation will be reduced on the basis of this new income stream. This is not the intention of the new levy as existing budgets will not be replaced with the levy.
12 We are concerned that the levy rate as proposed has not been based on a considered view of what projects will be undertaken or funded through the levy. In its current form it is simply an additional tax (fund generator) that will then be spent
See point 4 above.
13 If adopted we have concerns as to how the payment system will be implemented. We have been advised that this may be administered through the building control work stage notification process, so could this mean that if payment is not made building control would not visit the development.
See point 10 above.
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Ref Comment States of Jersey Response 14 It is unclear from the proposal document how the charges and the threshold levels will be
assessed. If the threshold is 75m2 and a development proposal for a net gain of 85m2 is granted approval, is the charge applied to 10m2 or to the whole 85m
The charge will be for the whole net increase of 85 Sqm, as discussed in our meeting during the consultation period.
15 Within the Levy proposals, reference is made to the current Planning Obligation Agreements (POA's) being significantly reduced and simplified, but there is no reference or detail of these proposals and we do not accept that the introduction of any additional charge should be proposed without the proposed reductions in the POA’s being clearly defined.
The Minister is currently establishing the principle of the levy and one of the clear intentions is that there will be no “double dipping”, in other words POA’s and the levy will not be imposed on developments to pay for the same item. Should the principle of the levy be approved then a review will be undertaken of the current POA guidance alongside the development of the levy policy and be subject to full public and direct industry consultation
16 There is no acknowledgement within the proposal that other Island industries / sectors will benefit from the improvements to the public realm and improved public spaces, alfresco opportunities, tourism benefits. We would use the example of the benefits to Bellagio’s at Charing Cross, which now benefits from alfresco tables adjacent to the new pedestrian improvement scheme. This is clearly a direct benefit to a private enterprise that in the future would be funded by the proposed Jersey Infrastructure Levy.
Al fresco is important and welcome street life activity derived from new developments and benefits the commercial operators/land owners and of course the wider public. The levy alongside other delivery mechanisms will continue to provide these opportunities. The Charing Cross scheme was a publically funded scheme.
17 Before the introduction of any Levy or additional taxation we would expect the Department of the Environment to provide evidence of the States of Jersey Development Companies payments (both forecast and actual payments) which are due to be paid under P.60/2008, which were to be ring fenced for the regeneration of St. Helier. We also expect the Planning Minister to provide a coherent plan for how these monies are spent and on what regeneration projects they are to be used on.
The use of the one –off monies to be generated from the development of the Waterfront/Esplanade Quarter under P.60/2008 would be clearly welcome in helping the regeneration of the town of St. Helier. The Minister for the Environment is currently reviewing and will be updating the Waterfront master plan and so details of future plans will be available once they are adopted. This is likely to be undertaken prior to the final adoption of a levy and so can provide further input into the meeting the objectives of the levy policy at that time.
18 We are concerned that there is no acknowledgement or recognition of the Islands immigration policy and the impact that this has on the Islands infrastructure needs
This is an important area but one which does not directly impact upon the viability assessment work carried out to determine if a levy would be viable in Jersey.
19 Before the adoption or introduction of any proposal which has the potential to place an additional taxation on the construction industry / landowners we would expect the States assembly to demand a fully detailed proposal for debate. In conclusion, the AJA do not consider that it is appropriate for the Jersey Infrastructure Levy Proposal to be taken forward by the Planning Minister in its current form for debate in the States. It does not provide the reassurances that development in the Island will not be adversely affected by this additional taxation. It individually targets the construction industry with an additional tax burden that does not accord with the long term tax policy principles agreed to by the States as part of the Strategic Plan 2015-2018, namely that: • Taxation must be necessary, justifiable and sustainable • Taxes should be low, broad, simple and fair • Everyone should make an appropriate contribution to the cost of providing services, while those on the lowest incomes are protected • Taxes must be internationally competitive • Taxation should support economic, environmental and social policy The use of the term ‘Infrastructure’ and the lack of definition of this term, leaves the proposed levy open to interpretation and miss-use, which is further compounded by the omission of any detailed proposals of what improvements are proposed. There is no recognition of any other factors which impact on the Islands Infrastructure and the proposed Levy charges have not been justified on the basis of any specific requirements. The levy has clearly been set as a tax generator which is exemplified within the viability study (item 3.4) which states ‘the purpose of this study is to quantify the costs of the various policies in the Island Plan, and to assess the effect of these and of developer contributions and then to make a judgement as to whether or not land prices may be squeezed to such an extent that the Island Plan is threatened.’ The proposal does not recognise that property ownership does not directly equate to income or that an increase in property value equates to the owner having the means to pay an additional property tax.
The levy is going through an extensive consultation process and this will include: • Two States debates, one on the principle and if approved, one on the detailed planning
law and regulations. • There will then be further independent planning inspector review of the levy rates
before final adoption. The principle points raised about the long term purpose of tax policies are sound and the levy as applied to developments through the planning system will pick up on these principles. The consultation document made it very clear as to what infrastructure the levy would be spent on – see comment made to point 4 above. The levy is a small proportion of overall development value to be secured from the uplift in the value of land from the awarding of significant planning permissions, often led by developers or landowner/developers. It is not going to impact typical homeowners, as the threshold for the levy will exempt most domestic level extensions.
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12.4 States of Jersey Cultural Development Officer, EDTS – key points from email/letter dated 8th September 2017
Ref Comment States of Jersey Surprisingly, given the importance of percentage for art, the consultative document on the
Infrastructure Levy does not mention the enhancement of the public realm through public art; nor does it consider the implications of introducing the Levy on existing policy. Neither public art nor a percentage for art scheme are mentioned among the examples of potential beneficiaries. It is true that public art contributes to improved streets and public spaces but there appears to be no specific intention to use the Levy to support the States policy on public art, nor percentage for art as a prime delivery mechanism. This raises the question of whether the existing percentage for art policy would continue to be advocated and encouraged alongside the Levy; it is not clear from the document that this is the case. On the contrary, the assurances given about the commercial impact of the Levy do not address the simultaneous application of the percentage for art policy, so that the implication is that it would not be advocated. Even if it were, given that it is a voluntary policy, the likelihood that it would continue to deliver benefit must be minimal. Officer discussion preceding the development of the consultation paper broached the issue of the importance of percentage for art within the policy development around the proposed Levy. This appears to be outstanding. In the context of strengthening the percentage for art scheme and enhancing the public realm through public art of all kinds, it is important that the benefits of this States policy continue to be delivered. Under the Infrastructure Levy proposal it is not clear how this would be achieved.
Public art is one of the areas that is specifically listed in the consultation document as part of the potential beneficiaries of having an established levy in place. Discussions have taken place with the Cultural Development Officer on the specific issue of the future operation of the Percent for Art policy in the Island Plan. The Minister will continue to encourage developers to use this policy on schemes and does not at this time intend to amend the Island Plan.
12.5 Jersey Chamber of Commerce – key points from letter dated 8th September 2017
Ref Comment States of Jersey 1 Critical JIL questions have not been addressed or responded to now or previously
The Minister has been very open about his views on why the levy should be introduced and that it must be viable. The Minister announced his intention to introduce a land development charge in January 2016, and the Department of the Environment has been listening to industry views on the principle of a charge since then. We have held numerous meetings and discussions, individually and collectively, to gather feedback. After a stakeholder consultation in the autumn of 2016, we took on board many of the points made by industry, and adjusted our assumptions. These were included in the formal study we commissioned from independent UK and local consultants with considerable experience, and which was published in the spring of this year.
2 Scrutiny have not carried out a review of the proposed levy, with regards the impact it may have on development and the islands economy
Departmental officers have been in touch with Scrutiny officers throughout the consultation process and kept them fully informed. Further meetings will take place over the next few weeks to discuss the outcome of the consultation. A public scrutiny meeting is scheduled with the construction industry and then separately with the Minister in November 2017 and this will further scrutinise all of the issues raised on the in principle introduction of a levy.
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Ref Comment States of Jersey If the States agree an in-principle proposal to introduce a Jersey Infrastructure Levy then we will develop a more detailed policy and carry out another round of viability testing and impact assessment before developing detailed policy proposals. The States will be asked to consider detailed policy proposals again before formal adoption. We welcome the critical challenge provided by Scrutiny if they choose to assess and ‘call in’ a fully formed and more detailed policy prior to final consideration. The policy proposals will be subject to a comprehensive and in-depth independent examination in public led by an independent planning inspector to ensure that the detail of the policy works for Jersey.
3 In light of Brexit, the fall in the value of sterling and the impact it is having on the cost of goods and a reduced migrant workforce, commerce is looking to Jersey’s government to implement measures that boost confidence and grow the economy, not increase the tax burden and costs associated with doing business in the island
Brexit will affect many aspects of Island life and we have ensured that the viability study on the Jersey Infrastructure Levy includes a significant contingency for the potential cost of Brexit. We’ve looked at the potential impact to development viability under Brexit and thought about how it would affect the introduction of the levy and, given the cautious approach used in the viability work, JIL is still considered a viable policy which will benefit Jersey in the future.
12.6 Jersey Construction Council – key points from Lichfields letter & report dated 8th September 2017
Ref Summary of Comment States of Jersey Response Letter
Page 6
Percentage for Art We note that the Viability Study excludes the 0.75% of construction costs which developers are encouraged to make as a contribution to Art in Jersey. This represents another existing cost which is currently already being absorbed by developers. The Viability Study states that this contribution is assumed to be assimilated into any new levy. However, there is no mention of this and any potential changes to do so within the Proposal. This represents just one element of the calculation which undermines the proposed £85/sqm JIL charge proposed.
The percent for art is a voluntary policy and the minister will continue to encourage developers to provide art with their schemes where appropriate.
Page 6
With regard to the relationship between existing POAs and JIL, we note that the JeCC has already highlighted some of these issues within its letter to the Planning Policy and Projects Team, dated 22 May 2017. The most recent review of POAs has been adopted via the SPG advice note. The JeCC’s main concerns relate to the fact that the proposed introduction of JIL has not been considered in conjunction with reviews to POAs. As we set out below, it appears POAs and JIL are expected to fund similar infrastructure, and there is a lack of clarity as to exactly what each is expected to fund. This gives rises to a concern that is described in England and Wales as “double dipping” and something that the PPG in England specifically seeks to avoid, where it states4: “There should be not actual or perceived ‘double dipping’ with developers paying twice for the same item of infrastructure.” (our emphasis).
Should the levy be adopted it is important the POA system is rationalised and the relationship between POA and JIL is really clear to avoid double dipping. To do this some form of assessment of the infrastructure requirements to support new development (an IDP) would be undertaken to produce the equivalent of a CIL Regulation 123 list.
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Under the Proposal, affordable housing schemes will be exempt from JIL. Unlike in the UK, affordable housing is not required on market-led developments, instead being provided directly through 100% affordable housing schemes. At present Andium Homes (the former States of Jersey Housing Department, which is now an arms-length corporatised state-owned housing company) is the only development body with access to Government funding to provide such affordable homes. The assumption in the Viability Study (and the entire premise of the JIL charge)
Policy H3 (to provide affordable housing through market led schemes) was dropped following pressure from the construction industry and so the model is now for affordable housing to be generated through Affordable Housing Providers (AHP), including Andium homes, Christians Together in Jersey (CTJ) and Jersey Homes Trust (JHT) and le Vaux.
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Ref Summary of Comment States of Jersey Response is that the costs of a JIL will come off the land value (as opposed to, for example, being a cost fronted by the home-buyer, which in the case of affordable housing would benefit first time buyers). JeCC has real concern that this effectively makes the introduction of a JIL an anti-competitive policy which, in terms of accessing land for development in the market, disbenefits private developers on the Island in favour of, what is effectively, a State body.
Although Andium have been the principal beneficiaries of the housing bond this has been used to bring the existing housing stock up to decent homes standards and the construction industry have benefited from this as they have been the recipients of procuring this work. Where existing affordable housing providers are seeking to develop additional private brown field sites (e.g. CTJ development for affordable housing on the Scope Furnishing site), they are competing in the open market. Their acquisition is based upon a long term rental model at affordable housing levels (90% market rents) and so this is a difficult area to compete in when set against alternative open market value opportunities. Applying a levy to affordable housing developments would not be viable and so has not been applied. From the comment made it is not clear how this open mechanism is anti-competitive or whether the suggestion is that a levy should be applied to affordable housing.
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1. The evidence in the Viability Study shows significant variations in the cost of residential land, and there is little available evidence on the cost of other types of land due to the limited number of transactions that take place. Given the difficulty in determining a single charge across all development which would not undermine the viability of a significant number of sites, the States of Jersey should not seek to implement a JIL. It should instead continue with the existing POA system.
The levy rate has been set based upon the best available evidence in Jersey (including a review of land transactions based on the Royal Courts data) and follows best practice guidelines. It is recognised that more data would be beneficial but the information gathered is considered appropriate to support the conclusions reached in the viability assessment for review of developer contributions report undertaken by the consultants and local surveyors.
In the event that the States of Jersey decides nonetheless to continue with preparation of a JIL charge, we have identified a number of significant flaws within the Viability Study which should be corrected. These are essential in order for the States to demonstrates that any proposed JIL charge is underpinned by suitable and robust evidence (which, at present, we believe it is not) The flaws should be remedied by the following:
2. Test brownfield sites based on a range of existing uses, including office, retail and hotel uses, which are more reflective of the site typologies likely to come forward in the Plan period;
It is recognised that more data would be beneficial but the information gathered is considered appropriate to support the conclusions reached in the viability assessment for review of developer contributions report undertaken by the consultants and local, surveyors. Hotel sites are not considered viable and wold not require further testing
3. Sensitivity test these values to allow for higher viability thresholds and a more diverse range of potential values, reflecting the greater incentive often needed to make a sale and the taxes which apply to profits, as well as better reflecting the diverse range of outcomes experienced in previous transactions;
The viability assessment included sensitivity testing in relation to changes in values and build costs. A wide range of data has been considered and it is accepted that land trades at above the thresholds used it also trades at less. The purpose of the viability testing is to assess the generality of the market rather than specific sites and the requirements of particular land owners.
4. Consult with stakeholders and local quantity surveyor firms to reach an agreed consensus over build costs on the Island, including sensitivity testing of this; and
Extensive consultation was undertaken with the industry prior to the formal consultation phase and costs have been cross checked by a local surveyor against Jersey specific construction costs. The cost information evidenced in the Lichfield’s report are not helpful or testable as they are not broken down and it is not clear what assumptions are made about them – see comments made against paragraph 3.29.
5. Provide significantly greater clarity over the relationship of JIL with POAs and the infrastructure to be funded by each to avoid potential for actual or perceived ‘double dipping’.
See comment made above ref page 6.
Report 2.4 The principles set out in the NPPF are supplemented by guidance on viability and CIL within
England’s Planning Practice Guidance (PPG), which reiterates the need for planning authorities to set the scale of obligations such that the Local Plan is not undermined. Against, the below is not set out because it is the relevant guidance for Jersey, but because it sets out some useful
It is important to note that whilst much of the process and practice in planning is very similar on Jersey when compared to England, there are very few allocations. Most
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Ref Summary of Comment States of Jersey Response principles to which the design of a JIL might usefully subscribe. The PPG clarifies, amongst other things, that: “Charging authorities should set a rate which does not threaten the ability to develop viably the sites and scale of development identified in the relevant Plan” (ID 25-008) 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…. Jersey Infrastructure Levy Proposal : Review of Viability Assessment Pg 3 This balance is at the centre of the charge-setting process. In meeting the regulatory requirements (see regulation 14(1), as amended by the 2014 Regulations), 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….(ID 25-009) (our emphasis)
development comes forward on brownfiled sites that are being redeveloped from an existing use.
The English equivalent would be ‘windfall sites’. There are no remaining development sites identified in the Plan, which in any event would principally be developed as affordable housing and be exempt from the elvy.
2.5 When setting out how development should be valued for the purposes of CIL, the PPG states; “A charging authority should use an area-based approach, involving a broad test of viability across their area, as the evidence base to underpin their charge. The authority will need to be able to show why they consider that the proposed levy rate or rates set an appropriate balance between the need to fund infrastructure and the potential implications for the economic viability of development across their area. There are a number of valuation models and methodologies available to charging authorities to help them in preparing this evidence. There is no requirement to use one of these models, but charging authorities may find it helpful in defending their levy rates if they do. A charging authority must use ‘appropriate available evidence’ (as defined in the section 211(7A) of the Planning Act 2008) to inform their draft charging schedule. The government recognises that the available data is unlikely to be fully comprehensive. 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. A charging authority should draw on existing data wherever it is available. They may consider a range of data, including values of land in both existing and planned uses, and property prices – for example, house price indices and rateable values for commercial property. They may also want to build on work undertaken to inform their assessments of land availability. In addition, 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 (the Local Plan in England, Local Development Plan in Wales, and the London Plan in London) relies, and those sites where the impact of the levy on economic viability is likely to be most significant (such as brownfield sites). 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. For example, this might not be appropriate if the evidence pointed to setting a charge right at the margins of viability. There is room for some pragmatism. 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. In all cases, the charging authority should be able to explain its approach clearly. (ID 25-019) (our emphasis)
Lichfields underline three sections in the quotes. 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. This is exactly what has been done – drawing on all the accessible data. consider a range of data This has been done, considering the widest range of data available – including the records of all property sales. Overall our approach is consistent with the principles set out.
No alternative or extra data is suggested or provided.
3.1 The Study’s conclusions, and the conclusions on the level of JIL that development in Jersey could bear, are ultimately drawn from a number of viability appraisals for different types of development which each embed a series of assumptions around the values and costs of development on the island. The robustness of the Study’s conclusions is therefore directly related to the
The viability study is based on the ‘Existing Use Value (EUV) plus’ method. This does not seem to be contested and no alternative approach is put forward. Much of the criticism is about the lack of evidence. We (the Department, officers and HDH) were very aware of this as we were developing the report. This lead to us
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Ref Summary of Comment States of Jersey Response reasonableness of those individual assumptions. Lichfields and the JeCC have considerable concerns with the assumptions and approaches adopted within the Study and these are set out as follows.
reviewing all the relevant transactions recorded in the Royal Court data. It would have been preferable to have more data – but there is not more data to be had. This is not a reason not to proceed by itself.
3.4 In addition, not all brownfield sites will have been previously in industrial use, and these may have a much higher value than assumed in the Study (which, as noted, does not appear itself to be based on any evidence). Within its assessment of viability, the Study assumes (with the exception of small paddock site developments, one residential conversion scheme and two office conversions) that all brownfield sites are in industrial use and therefore have industrial land value (of £1.9m/ha). The Study itself accepts this limitation, but it is not then reflected within the viability modelling, meaning one should be very cautious indeed about basing conclusions upon it: “It is important to note that much of the development that does come forward in St Helier in particular is on previously developed land that has a value that is greater than an industrial value.” (para 6.61)
The criticism that we have relied on industrial values is one that came up through the informal consultation so was one that we addressed from 10.14 of the Viability Assessment.
3.5 Brownfield land located in built-up areas - which is where the Council intends to concentrate most development - may have different alternative use values higher than industrial. These brownfield sites may have been in a number of previous uses including hotels or offices, and one member of the JeCC gave examples of brownfield sites which were currently in use as car parking/retail, and another in use as a bank. We note that while the Study has modelled office conversion schemes, it has not modelled any brownfield developments in other previous uses either as conversions or redevelopments. These sites could have a substantially higher alternative use value to the £1.9m/ha assumed (again, noting that this figure is not evidence based).
We agree industrial land could have a higher value – but there is no evidence tabled to support the contention.
Many of the sites for conversions were not considered as they would no attract the levy.
3.7 The Study’s existing figures (for residual value vs existing value and viability threshold) for the brownfield sites, based on an industrial value, are shown graphically in Figure 3.1 below. It is clear that for these sites, the residual value would appear to exceed existing use value (EUV) and viability threshold comfortably.
The graph that included at Figure 3.1 is useful as it clearly shows the scale of the gap between the Residual Value and Viability Threshold. This further supports that taken in the viability study is a very cautious view. HDH recommended a rate of JIL in the broad band of £50/m2 and £150/m2 and a rate of £85/m2 was settled on by the Government. From Table 10.5 of the Viability Assessment it can be seen that at £100/m2 most sites have a Residual Value of over £6,000,000/ha. It is therefore misleading for to imply that industrial plus 20% is applied in a dogmatic way – it has not been.
3.9 3.10
Despite the Study accepting that brownfield land values in the built-up areas are likely to be higher than industrial values, which has been supported by information provided to Lichfields by members of the JeCC and their experiences in developing brownfield sites, this is unfortunately not reflected in the Study’s assessment. The sensitivities undertaken for alternative viability thresholds (see Table 10.3 of the Study) are tested up to a threshold of £6.5m/ha (at which six of the total sites become unviable), however this is still below the upper end of the range for secondary retail space. Secondary retail space is a likely future contributor to housing development in Jersey and the Study is flawed by failing to adequate assess these scenarios. By way of further illustration, Figure 3.3 shows the residual values compared with primary retail land values. Again, while these could be slightly over-estimates of land value, they nonetheless demonstrate that many sites would be at the margins of viability. Development of primary retail space may be a realistic source of brownfield land for housing; the Study states that there is little demand for additional retail units, with even the primary areas seeing some long term vacancy across several units (para 6.32 onwards).
Similar points with regard to primary and secondary retail – what that don’t go on to acknowledge is that the proposed rates of JIL only relate to net new development – in part as the conversion of retail (and office) as tested in the viability study are not likely to be viable.
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Ref Summary of Comment States of Jersey Response 3.11 In addition to retail sites, there are also examples of brownfield sites which are conversions from
hotel to residential uses. The Study cites examples of the Metropole Hotel (sold for £9.5m/ha), Shakespeare Hotel (£14.6m/ha) and Old Court House Hotel (£3.9m/ha). With the exception of the Old Court House Hotel, the sales values of these sites exceed almost all the residual values of the brownfield sites, as shown in Figure 3.4. It is possible that the value of such sites will increase in the future as the supply of vacant hotels available for residential conversion diminishes.
It is not practical to test every possible scenario – but JIL is only applicable to net new development so conversion or redevelopment would not be subject to the charge.
3.14 As set out above, the Study has assessed the majority of its brownfield sites against an industrial land value of £1.9m/ha, which equates to a value of £320/sqm (assuming 60% coverage on a site). On a per sqm comparison basis, the value of secondary office space is therefore over seven times the industrial figure used for most brownfield site assessments. The absence of any further testing of office sites (either as conversions or complete redevelopments) is yet another significant flaw of the Study. The concentration of development in built-up areas means redevelopment of office space is likely to contribute to future housing supply and it is imperative these typologies are properly assessed for viability.
These have been specifically tested in typologies 9 and 10 in the viability study – and that analysis lead to the conclusion there should be a zero rate of JIL so it is unclear what the criticism is here.
Summary on
Page 10
The Study has not provided any evidence for the industrial values assumed in its modelling and it even appears to accept these are “low”. There are clearly other site typologies likely to come forward for development in Jersey where the alternative use value is higher than industrial, including retail, office and hotel uses. The Study ultimately fails to adequately test the range of developments likely to come forward in Jersey, reflecting the fact that development is mostly concentrated within built-up areas which contain a range of uses. Comparing the Study’s residual values to other alternative land value estimates and viability benchmarks shows significant variation in viability with many sites at the margins of viability or unviable altogether. This is also likely to be the case when assessing sites in secondary office use, given values of these sites are substantially higher than the industrial value per sqm currently used.
We would accept the criticism there is not extensive evidence to support the industrial values as transactions are not as frequent – but when it comes to making recommendations we have given much greater weight to residential values in the market. Equally, we could have tested more conversions (from retail), although as there will be little conversion of retail to residential, and further, due to the EUV assumptions it is unlikely that JIL would be applicable. We accept there is a variation – hence the cautious approach. Should the principle of the levy be adopted then we will in any event revisit all of the assumptions and gather new evidence where available from either further research or new evidence presented.
From 3.17
These sites may appear outliers in the view of the Study’s authors, however, given that even once they are removed values still range from £1m-£14m/ha, and that these represent two of the 17 sites, they should arguably not be removed from the sample. Indeed, 22 La Colomberie represents a conversion scheme in St Helier built-up area; this is precisely the type of development which is encouraged within the Island Plan, which severely restricts development in the countryside.
This section deals with Residential Values. With regards to the discounting of outliers, at the start of the rep they include various quotes from the English Planning Guidance (whilst acknowledging Jersey is not England). One part they do not quote says: In all cases, estimated land or site value should … be informed by comparable, market-based evidence wherever possible. Where transacted bids are significantly above the market norm, they should not be used as part of this exercise. (ID: 10-014-20140306) These two transactions are over 50% higher than the next highest amount paid – it is therefore is reasonable to discount them.
3.18 Having removed the purported ‘outliers’ the Study has considered the average of these values (median and mean) before reaching a judgment value of £6m/ha which it takes forward in the Viability modelling. Whilst taking the average land value may not be an unreasonable approach, this is only likely to be an appropriate representation of average land values where:
• The overall sample size is large; • There is a clear clustering of values around the average, which is the value that could be
expected for most sites; and • There are few instances of severe values at the extremes, above or below the average.
We accept the sample size is small and less than ideal – ideally there would have been numerous transactions. We have included all the available evidence in an open and transparent way. Accepting the evidence is thin we consulted with the industry and there was a consensus that the £6,000,000 assumption was about right – one (at 6.22) consulted they has paid £4.65m per hectare on average. No alternative evidence is provided and we have used the available data. It is of course possible to present the data in a number of ways – our use of a straight forward average avoids the misleading use of statistics. Should the principle of the levy be adopted then we will in any event revisit all of the assumptions and gather new evidence where available from either further research or new evidence presented.
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Ref Summary of Comment States of Jersey Response 3.22 Shown in this context, it would clearly be extremely difficult to set a CIL rate for an area where
some land values were as low as in Coventry, while in other areas as high as in Central London. It is highly questionable how it would be possible to set a CIL rate in such an area which would not undermine viability across some sites. This demonstrates that the use of an average residential land value in Jersey is not appropriate given the wide range of values seen. There is a real and significant risk that the introduction of an infrastructure levy, based on the viability study would undermine viability of a significant proportion of sites. This further lends support to the existing POA system whereby infrastructure contributions are considered on a site-by-site basis.
The implication here is that land priced don’t vary elsewhere – they do. Just because it is difficult does not mean the average is not an appropriate figure to use.
3.23 Notwithstanding our criticisms of the approach taken to land values, it would appear that the Study has not taken forward its £6m/ha valuation when assessing the viability of Site 16. This site is an example of 3 larger detached dwellings, modelled as the redevelopment of an existing residential site. The Study assesses this site as ‘marginal’ on the basis that its residual value exceeds the EUV, but not the viability threshold (EUV + 20%).
The value in this site was based on a small site being redevelopment from 1 to 3 houses. The results informed the recommendation not to apply JIL to conversions for new development so the use of a higher figure would not result in a change in the recommendations.
3.26 Section 7.0 of the Viability Study sets out the assumed development costs which have been used in assessing viability. The Development costs set out in paras 7.2-24 cover baseline construction costs, other normal development costs, abnormal development/brownfield costs, fees and contingencies. We have looked at each in turn to assess the reasonableness of these assumptions.
The review moves on to Build Costs. The assumptions were not just based on the BCIS costs as implied by the comments – if they were an index of 1.12 would have been used. We relied on John Poole from CSP who advised 1.2 would be more appropriate.
3.29 Dandara has provided Lichfields with additional information on build costs in Jersey which suggests that the Viability Study significantly under-estimates this. Dandara is the biggest property developer in Jersey, focusing on new homes, homes for the elderly and commercial premises. This build cost information provided by a local quantity surveyor firm, and verified by Dandara against their own experience, estimates build costs of a residential-led mixed used scheme c.25% higher than those assumed in the Study, at £2,368/sqm. This equates to an under-estimate of build costs of £450/sqm. This estimate would appear to be in line with comments received from stakeholders during consultation, which suggested a higher index (of 1.4-1.56) should be used, and reflect other factors such as the weaker pound.
When we engaged with Dandara it was clear that they were including more than the pure construction cost of the units so the prices were not comparable to those we had used. We used £1,938/m2 for higher format flats, £1,430/m2 for lower format flats and £1,280/m2 for housing. The local surveyors used to inform the viability work, Colin Smith and Partners, have made the following recent comments to support this assumption:
1) We state that we have used BCIS as a recognisable base and during our consultation. There was some consensus reached in this although there were some more extreme views on costs up to 56% more I noted.
2) Lichfield are incorrect in stating that the index is distorted by other Islands. The BCIS location study which shows Jersey on the last line of the last page. This is the latest study based on analysis of 46 projects (BCIS state that anything less than 20 is more unreliable) and gives an index range of 91 to 138. Note that in March 2017 we were not using the BCIS index but our own higher figure of indexed at 120 which equated to Central London, a reasonable point to be considering the latest survey.
3) It is important to relate the costs to a date, in March this year we were beginning to see build cost inflation and this has accelerated through the year. This will be kept under review if JIL is progressed and may have an impact on the results.
4) In terms of the cost per m2 quoted, it is important to understand the basis of these costs given to JeCC, historically we have been often told “I can build for £100 per sq ft” but the question is what! Does it have foundations, drainage, roads etc in the cost and often we get the reverse where a developer says the build cost is £3,000/m2 and then find that this is total cost divided by sales area, not gross floor area. We would need evidence of detailed costs to substantiate the figures quoted.
It is also worth noting that on the other side of the equation, Sqm sales values have also been recently seen to have risen in some cases by 10-15% compared to the original values used in the viability appraisal.
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Ref Summary of Comment States of Jersey Response 3.32 As part of developments in Jersey, developers are encouraged to make a public art contribution
equivalent to 0.75% of construction costs on sites. Whilst the Study states at para 7.31 that this will be assimilated into any new levy, the Jersey Infrastructure Levy Proposal consultation document makes no reference to the contribution for the Arts, and whether this will change following introduction of a new levy. Until is it clear that such a cost would be assimilated into any other charge, this should be included within current development costs. This represents a further development cost for which the Study has failed to account.
The percent for art is a voluntary policy and the minister will continue to encourage developers to provide art with their schemes where appropriate.
3.33 The Study states that although it was suggested during consultation with stakeholders, an allowance for 20% ‘income tax’ was not accepted. However, shareholders of development companies in Jersey are liable to pay tax at 20% (which is generally paid out of the funds of the company). The effect of a company tax on development in Jersey is an important consideration for two reasons: 1 It is likely to affect the level of developer profit required; and 2 It is likely to affect the viability thresholds (which we return to later in this report), since the scale of uplift on existing use will need to be high enough to incentivise a sale, taking account of profit, taxes and other factors (such as no inheritance taxes). One member of the JeCC stated that it has sold land for a “significant” premium above EUV to allow for profits and taxes.
This is the personal taxation point – it is unclear how this would be applied in the appraisals. How you would deal with personal allowances etc.? It will depend on the individual shareholders, the specific thresholds, whether they are a partnership, high value residents etc. etc.
The consultant is not aware of a single viability study that tries to consider personal taxation.
3.35 Le Masurier is an example of a commercial property company in Jersey which has held land on the Island for long periods, in some cases since 1835. Members of the JeCC give examples of sites which were sold at “significant premiums” to residential developers to ensure a profit and tax free disposal. This demonstrates another fundamental difference between the property markets in England and in Jersey which means it is not possible to appropriately and robustly assess viability based on the identical approach as in England, then set a proposed infrastructure levy on development.
This is not unusual. In England The Northumberland Estates have a 500 year business plan, the Church Commissioners, the Crown Estates, many Oxford Colleges etc. are long term land owners.
3.36 The existence of tax on land sales combined with the absence of inheritance tax means that the viability thresholds are likely to be in excess of those assumed within the Study. This is in addition to our previous criticisms raised about the value of brownfield land assumed, which, even under the Study’s current assumption (of 20%) would undermine viability when comparing residual land values.
This is conjecture – no evidence is provided that could test this.
3.38 When applied to the alternative use value on paddock land (£150,000/ha) the Study’s viability threshold amounts to £180,000/ha (see Table 10.2). The Study itself accepts that paddock land already attracts a premium (around 4-5 times the value) over agricultural land (valued at £36,000/ha) due to being of amenity value, for use as pony paddocks or to provide protection/privacy. Therefore, it is questionable whether a landowner would accept an uplift of just 20% on a sites in EUV as a paddock (equivalent to an additional £30,000/ha) if there were a possibility of the land being developed for residential uses.
This is accepted – but we have relied on the £6,000,000/ha value rather the EUV Plus in the end.
3.41 As a result of the degree to which the Viability Study has under-estimated the EUV of brownfield sites:
– our analysis above shows that when comparing against more likely land values the residual land value does not exceed to viability threshold (even at 20%) for most sites;
developer contributions is flawed and incorrect;
This point is not clear – is there an error or it is wrong as the assumptions are wrong? These are two very different things.
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Ref Summary of Comment States of Jersey Response 3.50
The above highlights two fundamental issues with determining viability in Jersey; 1 The scale of viability has been significantly over-estimated in the Study, leading the authors to incorrectly conclude there is sufficient scope to introduce a JIL; and 2 The inherent difficulty in determining land values on the Island means that viability is nearly impossible to determine altogether. The sensitivity of viability to land values is clearly demonstrated above and earlier in this Section.
Lichfields analysis shows that most development is not viable if their assumptions are used. This can’t be right as development is coming forward across the Island and particularly in St Helier now so in the view of the HDH consultant this undermines their case. A range of different views were also expressed through the consultation, however the Viability Assessment takes a generally cautious approach and produces results that are broadly reflective of the current market in terms of values being paid for land. The point at 3.50(2) is not in line with what consultees said earlier in the process with regard to levels of return and does not seem to be in line with their own analysis which shows that with a £6,000,000 land value 3 of the first 4 sites (in table 3.1) make a loss.
3.52 Under the heading ‘Sensitivity Testing’ the Viability Study references concerns raised during stakeholder consultation about the impact of the weak pound following the EU referendum.
Care needs to be taken not to make any predictions as to how the market and inflation may change as a result of Brexit – rather just setting out various scenarios. No alternative approach is suggested that could be used.
3.54 As set out in the main representations and above, we consider that the differences in the Jersey housing market compared to those in the UK make it difficult to assess viability and implement a CIL charge altogether. However, the Viability Study provides some comparisons of CIL rates set in local authority areas in England, which appear to support the Study’s conclusion.
In this section all the points they make are fair – the point ignored is that all the other places referred to require affordable housing (up to 50% of developments), unlike Jersey.
4 Regrettably, the Viability Study is not a robust assessment of viability in Jersey upon which to set a JIL charge. Notwithstanding that the JeCC considers the principle of a JIL on the Island itself to be not possible, we have identified a number of flaws within the Study. Most of these criticisms alone would undermine the proposed JIL; however, when considered in combination, they demonstrate the degree to which viability has been overstated for the Island.
HDH are very comfortable with the work undertaken and consider that is provides a robust evidence base for taking forward the principle of adopting a levy. We do recognise however that it would be worthwhile giving further consideration to industrial and retail land values should further data be made available over the coming months.
With regards to cost, these have been cross checked once more using direct independent professional advice and we are also comfortable with the approach taken on build costs
Should the principle of the levy be adopted then we will in any event revisit all of the assumptions and gather new evidence where available from either further research or new evidence presented.
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12.7 Ports of Jersey – key points from letter dated 11th September 2017
Note: Many of the issues and direct questions raised by this submission were addressed in the published consultation document and so have been re-used in the States response.
Ref Comment States of Jersey 1
The recently published POA guidance has made the policy clearer but POA’s are limited to site specific matters and would not be able to provide the area wide benefits envisaged by the levy. Further information is found in the Jersey infrastructure levy proposal consultation document pages 10 & 20
2
The consultation is clear that the levy will only be applied to Residential office and retail developments
3
All costs, including planning fees were included in the viability testing on the levy and there are no plans to reduce or cap fees if a levy in introduced.
4
The mechanism for paying the levy has not been detailed, although the Jersey infrastructure levy proposal consultation document makes it clear that only a percentage of the levy will be paid at the start of the construction phases (page 16) and the majority at the end in line with the English system. The payment schedule will be detailed when developing the regulations on this part of the levy and be subject to further consultation.
5
This figure is based upon a levy rate of £85 applied to the typical rate of development built over the past 5 years.
6
The viability modelling is a high level generalised study using industry standard methodologies across a wide range of developments by type and size. Some sites even without a levy will not generate sufficient profit and some will generate profits far in excess of 20%. The 20% profit level was used as part of the generalised modelling to demonstrate general viability rather than to be used for future specific testing of sites.
7
Improving and reducing the POA process with a levy will streamline this part of the planning application process and will give developers certainty and quicker planning decisions. There are no plans to introduce a statutory time limit on determining planning applications as this would not be practical given the complexity of some schemes.
8
Only public services based developments will be exempt. Any commercial residential, office or retail developments would have to pay the levy.
9 The Jersey infrastructure levy proposal consultation document makes it clear that the following
exemptions will be made (page 14): • Development resulting in the creation of less than 75 sqm of net floorspace, unless it
involves the creation of a new residential unit. • Dwellings constructed by Registered Affordable Housing providers • Developments constructed by Registered Charitable Trusts • Refurbishment of existing floorspace unless it results in a net increase of floorspace over 75
sqm
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Ref Comment States of Jersey 10
Yes
11
Yes
12
The definition of a building used in the viability work was based upon total net floor area. The definitions will be detailed when developing the regulations on this part of the levy and be subject to further consultation.
13
The Jersey infrastructure levy proposal consultation document makes it clear that the following exemptions will be made (page 14):
• Refurbishment of existing floorspace unless it results in a net increase of floorspace over 75 sqm
14
See response to 2 and 13.
15
The intention is that the areas that accept new development will benefit from receiving levy funds Given that St Helier has the largest share of new developments it is going to receive the greatest proportion of levy funding, which is the current focus of improvement. Priorities may change over time.
16
This has not stopped the widespread adoption of CIL in the UK and given the low levy rate when compared to GDV it is considered to be viable in Jersey as presented in the viability assessment for review of developer contributions report
17
Jersey has very similar limitations relative to its size as many other areas in the UK where strong green belt and other policies restrict the development opportunities. The cross rail is a major infrastructure development and Jersey clearly does not operate on this scale.
18
This is not planned and no evidence has been presented to do so.
19
We are not and are not required to follow a UK policy
20
See response to 13.
21
The UK policy has become an unwieldy and over complicated policy, which was recently reviewed and recommendations made to streamline it. Jersey is seeking to develop a simple, fair and equitable policy proposal. Should the principle of the levy be approved, there will then follow detailed discussions and consultation on the exemptions as part of the detailed policy proposal and accompanying regulations.
22
There needed to be a balance between allowing for incremental development improvements and capturing a reasonable levy to pay for community improvements. The 75 Sqm is equivalent to a 2
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Ref Comment States of Jersey bedroom flat in size and was chosen because of the view that it was reasonable to allow families to develop their homes to create more family space for immediate or dependent relatives for example. Equally statistics from the planning register indicated that the 75 Sqm was the upper boundary of what is seen as more domestic scale developments.
23
See response to 13.
Final para
Ports of Jersey are liable to pay the levy if they are developing commercial office, residential or retail space that do not meet the exemptions listed.
12.8 States of Jersey Development Company – key points from letter dated 11th September 2017
Ref Comment States of Jersey i There should be a comparison between green field/windfall sites and brown field sites as the
latter carries significantly higher costs Green fields were omitted as they would not normally get permission for anything other than affordable housing or agricultural related developments.
ii There should be a differential in the residential levy between houses and flats as the latter carries additional costs; for example basement parking (which costs more than the end value) and the building fabric for example lifts and sound proofing.
There was no evidence found to indicate difference between the two types. Parking was included in the costs for the viability appraisals.
iii The calculations should be based on saleable/lettable areas. Apartment developments for example contain circulation space of around 15% to 20% of the gross internal area that costs the developer to build and is not saleable. To be charged a levy on this space would not seem equitable.
A 15% communal space figure for flats was netted off and is included as part of the viability modelling.
iv Retail values vary significantly and are driven by location. The existing retail core is already fully developed and regeneration of other parts of St. Helier should encourage active uses on the ground floor however, these end value of any retail in these areas will not match the value of units in the established retail core. In our opinion the level of the CIL for retail would appear to be a disincentive for developers to produce new retail spaces.
Table 5.1 breaks down retail into two distinct values - primary shops (£500/Sqm) and secondary (£375/Sqm) areas were reviewed and included in the overall modelling. Retail demonstrated a high viability rate of up to 150/Sqm and so given the proposed lower rates it is not considered that there will be any significant disincentive.
v There should be no charge for non-habitable basements There was no evidence and the modelled the cost in the appraisals vi Developer’s contributions to public realm and public infrastructure should be taken into account
and JIL contributions reduced accordingly. For example, JDC spent £1m on public realm around IFC 1 and will be spending more on IFC 5. Looking to the future, JDC will be delivering a new underground public car park at the IFC. This is a significant piece of public infrastructure that will have a net cost of c.£20.
The Minister is currently establishing the principle of the levy and one of the clear intentions is that there will be no “double dipping”, in other words POA’s and the levy will not be imposed on developments to pay for the same item. Should the principle of the levy be approved then a review will be undertaken of the current POA guidance alongside the development of the levy policy and be subject to full public and direct industry consultation
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13. Comment.gov.je Responses
A number of comments were received through the consult.gov.je web site (https://comment.gov.je/jersey-infrastructure-levy) in response to a blog set up to ask what the levy should be spent on. These will be considered as part of the development of a more detailed policy should the levy be adopted
Date Comment 2017-07-05
Trees improve health and well-being, and provide habitats for wildlife. Too often I see trees being cut down and not replaced - including listed trees, which people seem to be able to get de-listed at the drop of a hat!
2017-07-05
There seem to be a lot of trees being cut down at the moment eg SW airport, around Le Squez which are not seeming being replaced. We should always replace any trees that are cut down and maybe should not cut down the trees in the first place. Trees are beneficial to us as well as to the many species that rely on them for habitat, food, shelter.
2017-07-05
The parks should no so much be re-furbished as re-wilded. Plant wildflower meadows and make the parks bigger. The Millennium Park should be extended. More trees should be planted in other public spaces.
2017-07-17
Both Minden place and Green street are overflowing for bike parking in the summer There is a seasonal need for more motorcycle and bicycle parking and undercover parking in winter at more locations around town
2017-07-17
I think better cycling paths are definitely a great idea, could also be used to attract more tourists.....
Jersey Infrastructure Levy Minister’s response to consultation (October 2017)
64
Appendices – Individual submissions in full
PA
TRO
N: C
olin
Pe
rch
ard
, CV
O O
BE
PRES
IDEN
T: C
olin
Bu
esn
el B
A (
Ho
ns)
Dip
Arc
h (
Ho
ns)
RIB
A
Da
te: 6th Se
ptemb
er 20
17
Mr Ra
lph Bu
chho
lz De
partm
ent o
f the
Envir
onme
nt So
uth H
ill St.
Heli
er JE
2 4US
By
Post
& Em
ail
Dear
Ralph
The J
ersey
Infra
struc
ture L
evy
The
view
s of t
he As
socia
tion o
f Jers
ey Ar
chite
cts
Havin
g rev
iewed
the p
ropo
sed J
ersey
Infra
struc
ture L
evy (
JIL) p
ropo
sals
the As
socia
tion o
f Jers
ey Ar
chite
cts (A
JA) a
re un
able
to su
ppor
t this
prop
osal
in its
curre
nt for
m. W
e que
stion
the p
racti
caliti
es of
takin
g suc
h a pr
opos
al to
the m
ain bo
dy of
the
States
for d
ebate
in th
is pr
elimi
nary
form
to es
tablis
h the
princ
iple w
hen m
uch m
ore c
larity
, deta
il and
certa
inty i
s req
uired
as
to ho
w it w
ill be
imple
mente
d and
enfor
ced.
Ou
tlined
below
are a
selec
tion o
f our
spec
ific co
ncern
s, ob
serva
tions
and c
omme
nts, w
hich h
ave b
een r
aised
by ou
r Asso
ciatio
n me
mbers
hip an
d we t
rust
that t
hese
matt
ers w
ill be
fully
revie
wed a
nd co
nside
red by
the D
epar
tmen
t of t
he En
viron
ment,
the
Depa
rtmen
tal ad
visor
s and
perso
nally
the M
iniste
r, be
fore a
ny su
ch pr
opos
al is
taken
forw
ard.
1. We
agree
with
the s
entim
ent e
xpres
sed b
y the
Mini
ster a
nd hi
s ope
ning s
tatem
ent w
ithin
the JI
L con
sulta
tion d
ocum
ent in
tha
t 'the
spac
es ar
ound
and b
etwee
n buil
dings
inclu
ding p
arks
, squ
ares
and s
treets
, has
a ma
jor pa
rt to
play i
n the
char
acter
, att
racti
vene
ss an
d suc
cess
of pla
ces'
we al
so re
cogn
ise th
e Mini
sters
view
that t
he 'd
elive
ry of
a suc
cessf
ul pla
ce re
quire
s str
ong p
artne
rship
betw
een g
overn
ment,
land
owne
rs, de
velop
ers an
d the
publi
c'.
2. As
arch
itects
we h
ave r
equir
ed sk
ills an
d kno
wled
ge to
advis
e and
deliv
er the
se pl
aces
and o
ur pr
ofessi
on sh
ould
be at
the
forefr
ont o
f the
se ty
pes o
f reg
enera
tion p
rojec
ts /
impr
ovem
ent s
chem
es w
hich a
im to
enha
nce t
he pu
blic r
ealm
and w
e be
lieve
that
cons
ultati
on an
d eng
agem
ent w
ith ou
r asso
ciatio
n mem
bers
shou
ld be
at th
e for
efron
t of a
ny pr
opos
ed pu
blic
realm
impr
ovem
ent p
ropo
sals.
3.
Our A
ssocia
tion f
ully u
nders
tands
the P
lannin
g Mini
sters
desir
e to e
nhan
ce an
d imp
rove
the p
ublic
realm
with
in St.
Heli
er bu
t we d
o not
acce
pt tha
t the
prop
osed
Jerse
y Inf
rastr
uctur
e lev
y (JIL
) is a
fair
or re
ason
able
metho
d of d
elive
ring t
hese
im
prov
emen
ts.
4. Th
e imp
rove
ments
prop
osed
whic
h will
bene
fit fr
om th
e intr
oduc
tion o
f this
Levy
are n
ot cle
arly
defin
ed an
d are
merel
y rep
resen
tative
and t
hey l
ack c
larity
and f
ocus
. The
conc
ept o
f intr
oduc
ing th
is lev
y (de
velop
ment
tax) w
ithou
t the
pres
entat
ion
of a c
ohere
nt pla
n sho
wing
the p
ublic
realm
impr
ovem
ents
is no
t acce
ptable
. 5.
If ad
opted
we d
o not
acce
pt tha
t this
fund
/ po
t as i
t is de
fined
in th
e exe
cutiv
e sum
mary
shou
ld be
man
aged
only
by th
e Mi
nister
for t
he En
viron
ment.
6.
We ha
ve gr
ave c
once
rns r
egar
ding t
he us
e of t
he te
rm 'in
frastr
uctur
e' an
d the
wide
defin
ition o
f this
term
and t
he ty
pes o
f pr
ojects
that
could
be de
emed
as in
frastr
uctur
e pro
jects
which
could
then
seek
fund
ing fr
om th
is inc
ome s
ource
/ le
vy (i
f ad
opted
).
7. We
do no
t acce
pt tha
t con
struc
tion p
rojec
ts ar
e sing
ularil
ary r
espo
nsibl
e for
the I
sland
s inf
rastr
uctur
e req
uirem
ents
and i
t is
theref
ore f
unda
menta
lly un
acce
ptable
for t
he co
nstru
ction
indu
stry t
o be i
ndivi
duall
y tar
geted
and s
ubjec
ted to
an ad
dition
al tax
ation
to fu
nd in
frastr
uctur
e pro
jects.
8.
We do
not a
ccept
that t
he pr
opos
ed in
frastr
uctur
e lev
y will
not b
e pas
sed o
n in s
ome w
ay ei
ther i
n full
or pa
rtiall
y fro
m the
lan
down
er to
the de
velop
er an
d the
n onto
the p
urch
aser
and i
t is na
ive of
the P
lannin
g Dep
artm
ent t
o sug
gest
otherw
ise.
9. We
do no
t beli
eve t
hat a
ny le
vy or
tax a
pplie
d to a
ny pl
annin
g app
rova
l sho
uld be
used
for m
atters
such
as im
prov
ed
trans
port
servi
ces,
drain
age s
ystem
s or f
lood d
efenc
es as
noted
in th
e inf
rastr
uctur
e lev
y con
sulta
tion d
ocum
ent. W
e also
note
that w
ithin
the AR
UP re
port
infra
struc
ture i
s defi
ned a
s: (a
) roa
ds an
d othe
r tra
nspo
rt fac
ilities
, (b)
floo
d defe
nces
, (c)
schoo
ls an
d othe
r edu
catio
nal f
acilit
ies, (
d) m
edica
l fac
ilities
, (e)
spor
ting a
nd re
creati
onal
facilit
ies (f
) ope
n spa
ces a
nd (g
) aff
orda
ble ho
using
(alth
ough
it's a
ccepte
d tha
t affo
rdab
le ho
using
will
not b
e fun
ded b
y this
tax)
. The
se si
mple
defin
itions
cle
arly
show
how
the fu
nds g
enera
ted fr
om th
is lev
y (if
intro
duce
d) co
uld be
used
or m
iss-ap
prop
riated
. All o
f the
abov
e sh
ould
be fu
nded
thro
ugh g
enera
l taxa
tion.
10. W
e are
conc
erned
that
the co
ntrol
of the
se fu
nds c
ould
be pa
ssed t
o ano
ther S
tates
depa
rtmen
t or M
iniste
r sim
ply be
Mi
nister
ial or
der w
ithou
t any
cons
ultati
on w
ith in
dustr
y. 11
. We a
re co
ncern
ed th
at the
curre
nt inf
rastr
uctur
e bud
gets
/ inc
ome r
aised
from
gene
ral ta
xatio
n will
be re
duce
d on t
he
basis
of th
is ne
w inc
ome s
tream
. 12
. We a
re co
ncern
ed th
at the
levy
rate
as pr
opos
ed ha
s not
been
base
d on a
cons
idered
view
of w
hat p
rojec
ts wi
ll be
unde
rtake
n or f
unde
d thr
ough
the l
evy.
In its
curre
nt for
m it i
s sim
ply an
addit
ional
tax (f
und g
enera
tor) t
hat w
ill the
n be
spen
t. 13
. If ad
opted
we h
ave c
once
rns a
s to h
ow th
e pay
ment
syste
m wi
ll be i
mplem
ented
. We h
ave b
een a
dvise
d tha
t this
may
be
admi
nister
ed th
roug
h the
build
ing co
ntrol
work
stag
e noti
ficati
on pr
oces
s, so
could
this
mean
that
if pa
ymen
t is no
t mad
e bu
ilding
contr
ol wo
uld no
t visi
t the
deve
lopme
nt.
14. I
t is un
clear
from
the p
ropo
sal d
ocum
ent h
ow th
e cha
rges
and t
he th
resho
ld lev
els w
ill be
asse
ssed.
If the
thres
hold
is 75
m2 and a
deve
lopme
nt pr
opos
al for
a ne
t gain
of 85
m2 is gr
anted
appr
oval,
is th
e cha
rge a
pplie
d to 1
0m2 or
to th
e who
le 85
m2 15
. With
in the
Levy
prop
osals
, refe
rence
is m
ade t
o the
curre
nt Pla
nning
Obli
gatio
n Agr
eeme
nts (P
OA's)
being
sign
ifican
tly
reduc
ed an
d sim
plifie
d, bu
t the
re is
no re
feren
ce or
detai
l of t
hese
prop
osals
and w
e do n
ot ac
cept
that t
he in
trodu
ction
of an
y ad
dition
al ch
arge
shou
ld be
prop
osed
with
out t
he pr
opos
ed re
ducti
ons i
n the
POA’s
being
clea
rly de
fined
. 16
. The
re is
no ac
know
ledge
ment
withi
n the
prop
osal
that o
ther I
sland
indu
stries
/ se
ctors
will b
enefi
t fro
m the
impr
ovem
ents
to the
publi
c rea
lm an
d imp
rove
d pub
lic sp
aces
, alfr
esco
oppo
rtunit
ies, to
urism
bene
fits.
We w
ould
use t
he ex
ample
of th
e be
nefit
s to B
ellag
io’s a
t Cha
ring C
ross,
whic
h now
bene
fits f
rom
alfres
co ta
bles a
djace
nt to
the ne
w pe
destr
ian im
prov
emen
t sch
eme.
This
is cle
arly
a dire
ct be
nefit
to a
priva
te en
terpr
ise th
at in
the fu
ture w
ould
be fu
nded
by th
e pro
pose
d Jers
ey
Infra
struc
ture L
evy.
17. B
efore
the in
trodu
ction
of an
y Lev
y or a
dditio
nal ta
xatio
n we w
ould
expe
ct the
Dep
artm
ent o
f the
Envir
onme
nt to
prov
ide
evide
nce o
f the
State
s of J
ersey
Dev
elopm
ent C
ompa
nies p
ayme
nts (b
oth fo
recas
t and
actua
l pay
ments
) whic
h are
due t
o be
paid
unde
r P.60
/200
8, wh
ich w
ere to
be ri
ng fe
nced
for t
he re
gene
ratio
n of S
t. Heli
er. W
e also
expe
ct the
Plan
ning M
iniste
r to
prov
ide a
cohe
rent p
lan fo
r how
thes
e mon
ies ar
e spe
nt an
d on w
hat r
egen
eratio
n pro
jects
they a
re to
be us
ed on
.
18. W
e are
conc
erned
that
there
is no
ackn
owled
geme
nt or
reco
gnitio
n of t
he Is
lands
immi
grati
on po
licy a
nd th
e imp
act t
hat
this h
as on
the I
sland
s inf
rastr
uctur
e nee
ds.
19. B
efore
the ad
optio
n or i
ntrod
uctio
n of a
ny pr
opos
al wh
ich ha
s the
poten
tial to
plac
e an a
dditio
nal ta
xatio
n on t
he
cons
tructi
on in
dustr
y / la
ndow
ners
we w
ould
expe
ct the
State
s asse
mbly
to de
mand
a fu
lly de
tailed
prop
osal
for de
bate.
In
conc
lusion
, the A
JA do
not c
onsid
er tha
t it is
appr
opria
te for
the J
ersey
Infra
struc
ture L
evy P
ropo
sal to
be ta
ken f
orwa
rd by
the
Plan
ning M
iniste
r in i
ts cu
rrent
form
for de
bate
in the
State
s. It
does
not p
rovid
e the
reas
sura
nces
that
deve
lopme
nt in
the
Islan
d will
not b
e adv
ersely
affec
ted by
this
addit
ional
taxati
on.
It ind
ividu
ally t
arge
ts the
cons
tructi
on in
dustr
y with
an ad
dition
al tax
burd
en th
at do
es no
t acco
rd w
ith th
e lon
g term
tax
polic
y prin
ciples
agree
d to b
y the
State
s as p
art o
f the
Stra
tegic
Plan 2
015-2
018,
name
ly tha
t:
• Ta
xatio
n mus
t be n
eces
sary,
justi
fiable
and s
ustai
nable
•
Taxe
s sho
uld be
low,
broa
d, sim
ple an
d fair
•
Every
one s
hould
mak
e an a
ppro
priat
e con
tribu
tion t
o the
cost
of pr
ovidi
ng se
rvice
s, wh
ile th
ose o
n the
lowe
st inc
omes
are p
rotec
ted
• Ta
xes m
ust b
e inte
rnati
onall
y com
petiti
ve
• Ta
xatio
n sho
uld su
ppor
t eco
nomi
c, en
viron
menta
l and
socia
l poli
cy
The u
se of
the t
erm ‘I
nfra
struc
ture’
and t
he la
ck of
defin
ition o
f this
term
, leav
es th
e pro
pose
d lev
y ope
n to i
nterp
retati
on an
d mi
ss-us
e, wh
ich is
furth
er co
mpou
nded
by th
e omi
ssion
of an
y deta
iled p
ropo
sals
of wh
at im
prov
emen
ts ar
e pro
pose
d. Th
ere
is no
reco
gnitio
n of a
ny ot
her f
actor
s whic
h imp
act o
n the
Islan
ds In
frastr
uctur
e and
the p
ropo
sed L
evy c
harg
es ha
ve no
t bee
n jus
tified
on th
e bas
is of
any s
pecif
ic req
uirem
ents.
Th
e lev
y has
clea
rly be
en se
t as a
tax g
enera
tor w
hich i
s exe
mplifi
ed w
ithin
the vi
abilit
y stud
y (it
em 3.
4) w
hich s
tates
‘the
pu
rpose
of thi
s stud
y is t
o qua
ntify
the co
sts of
the v
ariou
s poli
cies i
n the
Islan
d Plan
, and
to as
sess t
he ef
fect o
f the
se an
d of
deve
loper
contr
ibutio
ns an
d the
n to m
ake a
judg
emen
t as t
o whe
ther o
r not
land p
rices
may b
e squ
eeze
d to s
uch a
n exte
nt tha
t the I
sland
Plan
is th
reaten
ed.’
The p
ropo
sal d
oes n
ot rec
ognis
e tha
t pro
perty
owne
rship
does
not d
irectl
y equ
ate to
inco
me or
that
an in
creas
e in p
rope
rty
value
equa
tes to
the o
wner
havin
g the
mea
ns to
pay a
n add
itiona
l pro
perty
tax.
We lo
ok fo
rwar
d to r
eceiv
ing th
e Mini
ster’s
view
s and
comm
ents
in res
pons
e to t
hese
issu
es.
Your
s Sinc
erely
For a
nd on
beha
lf of
the As
socia
tion o
f Jers
ey Ar
chite
cts
Colin
Bues
nel
BA
(Hon
s), D
ip Ar
ch (H
ons),
RIBA
AJ
A Pres
ident
2016
– 20
18
cc. AJ
A Mem
bersh
ip /
Jerse
y Cha
mber
of Co
mmerc
e / Is
land P
ress
PR
ESID
ENT:
Co
lin B
ue
sne
l c
/o D
yso
n a
nd
Bu
esn
el A
rch
itec
ts, 1
08 H
alk
ett
Pla
ce
, St.
He
lier,
Je
rse
y JE
2 4W
H
Tel:
(015
34)
8808
61
M: 0
7797
725
656
E: c
oiin
.b@
db
arc
hite
cts
.co
.je
Jers
ey
Infr
astr
uct
ure
Lev
y an
d P
ub
lic A
rt
Co
nte
xt
Jers
ey’s
pu
blic
rea
lm c
on
tain
s m
any
exa
mp
les
of
pu
blic
art
wh
ich
giv
e in
tere
st, a
tmo
sph
ere
and
a
stro
ng
sen
se o
f p
lace
to
th
eir
imm
edia
te e
nvi
ron
men
t.
The
bes
t e
xam
ple
s ill
um
inat
e J
erse
y’s
un
iqu
e cu
ltu
ral h
isto
ry.
The
Ro
yal S
qu
are
wo
uld
no
t b
e th
e sa
me
wit
ho
ut
the
stat
ue
of
Kin
g G
eorg
e II
dat
ing
bac
k to
th
e m
id
C1
8th
; nei
ther
wo
uld
oth
er m
ore
co
nte
mp
ora
ry s
pac
es h
ave
the
sam
e p
ub
lic a
pp
eal w
ith
ou
t eq
ual
ly
stri
kin
g e
xam
ple
s o
f p
ub
lic a
rt.
Wes
t’s
Ce
ntr
e b
enef
its
fro
m s
tro
ng
pu
blic
en
gage
men
t w
ith
La
Vaq
ue
dé
Jèrr
i, th
e gr
ou
pin
g o
f Je
rsey
co
ws
wh
ich
mar
k th
e 5
0th
an
niv
ers
ary
of
the
Wo
rld
Jer
sey
Cat
tle
Bu
reau
an
d t
he
pro
xim
ity
of
the
old
cat
tle
mar
ket;
th
e sa
me
is t
rue
in L
iber
atio
n S
qu
are
wit
h
the
Ph
ilip
Jac
kso
n s
culp
ture
ere
cte
d o
n 9
May
19
95
wh
ich
inva
riab
ly a
ttra
cts
visi
tors
kee
n t
o
un
der
stan
d t
he
sign
ific
ance
of
the
cele
bra
tory
fig
ure
s.
Ho
wev
er, t
he
con
trib
uti
on
is f
ar g
reat
er t
han
mig
ht
be
assu
med
fro
m t
hes
e m
ore
ob
vio
us
exam
ple
s.
The
full
exte
nt
of
pu
blic
art
(to
20
10)
in a
nd
aro
un
d S
t H
elie
r is
set
ou
t in
a le
afle
t p
ub
lish
ed b
y th
e
Jers
ey
Pu
blic
Scu
lptu
re T
rust
‘Pu
blic
Art
in S
t H
elie
r’.
Stat
es
Po
licy
Mu
ch o
f th
e re
cen
t w
ork
was
cre
ate
d a
s a
con
seq
ue
nce
of
the
ener
gy o
f th
e Je
rsey
Pu
blic
Scu
lptu
re
Tru
st d
uri
ng
the
199
0s; t
he
Tru
st w
as r
esp
on
sib
le f
or
– o
r p
laye
d a
sig
nif
ican
t p
art
in -
th
e d
eliv
ery
of
the
Lib
erat
ion
Scu
lptu
re a
nd
wo
rks
in Q
uee
n S
tree
t, C
olo
mb
erie
, th
e A
lber
t P
ier
and
Jar
din
s d
e la
Mer
, to
giv
e o
nly
a f
ew e
xam
ple
s. I
t ca
mp
aign
ed f
or
the
intr
od
uct
ion
of
the
per
cen
tage
fo
r ar
t p
olic
y
as a
mea
ns
to in
crea
se t
he
qu
alit
y o
f th
e p
ub
lic r
ealm
th
rou
gh p
rovi
sio
n o
f w
ork
s o
f ar
t.
Stat
es P
olic
y o
n p
ub
lic a
rt in
th
e en
viro
nm
ent
and
th
e b
road
er p
ub
lic r
ealm
was
info
rmed
by
thes
e
init
iati
ves
and
is s
et o
ut
in t
he
Stat
es C
ult
ura
l Str
ate
gy (
20
05
):
ww
w.g
ov.
je/g
ove
rnm
ent/
pag
es/s
tate
srep
ort
s.as
px?
rep
ort
id=7
14
;
Two
ob
ject
ives
in t
he
Cu
ltu
ral S
trat
egy
re
late
sp
ecif
ical
ly t
o a
rt in
th
e p
ub
lic r
ealm
:
To im
pro
ve t
he
pu
blic
do
mai
n b
y d
evel
op
ing
and
ext
end
ing
the
curr
ent
Pu
blic
Art
Po
licy
and
by
dev
elo
pin
g p
ub
lic a
rt s
trat
egie
s fo
r d
iffe
ren
t lo
cati
on
s. (
4.1
)
To s
tren
gth
en t
he
exis
tin
g P
erce
nt
for
Art
po
licy
for
all f
utu
re d
evel
op
men
ts, b
oth
pu
blic
an
d
pri
vate
. (4
.2)
The
Do
E fo
llow
ed o
ne
of
the
spec
ific
re
com
men
dat
ion
s o
f th
e St
rate
gy, i
n r
elat
ion
to
str
engt
hen
ing
po
licy,
by
issu
ing
the
Sup
ple
men
tary
Pla
nn
ing
Gu
idan
ce t
hat
en
cou
rage
s th
e P
erce
nt
for
Art
po
licy:
ww
w.g
ov.
je/p
lan
nin
gbu
ildin
g/la
wsr
egs/
spg/
advi
cen
ote
s/p
ages
/per
cen
tage
art.
asp
x
The
po
licy
has
re
sult
ed in
a n
um
ber
of
imp
ort
ant
pu
blic
art
co
mm
issi
on
s w
hic
h h
ave
no
t o
nly
se
rved
to e
nh
ance
th
e p
ub
lic r
ealm
bu
t al
so t
o c
on
solid
ate
a d
isti
nct
ive
sen
se o
f p
lace
. In
ad
dit
ion
, so
me
hav
e re
sult
ed in
tal
ks a
nd
wo
rksh
op
s fo
r th
e lo
cal c
om
mu
nit
y an
d o
ther
s in
co
mm
issi
on
s fo
r lo
cal
arti
sts.
Th
ere
are,
th
eref
ore
, ed
uca
tio
nal
an
d e
con
om
ic o
utc
om
es a
lon
gsid
e th
e p
rin
cip
al o
bje
ctiv
e
of
en
han
cin
g th
e p
ub
lic r
ealm
.
The
imp
ort
ance
of
the
per
cen
tage
fo
r ar
t p
olic
y as
a m
ech
anis
m t
o d
eliv
er a
rt in
th
e p
ub
lic r
ealm
is
con
solid
ated
in t
he
Isla
nd
Pla
n (
Po
licy
GD
8).
The
Imp
licat
ion
s o
f th
e In
fras
tru
ctu
re L
evy
Surp
risi
ngl
y, g
ive
n t
he
imp
ort
ance
of
per
cen
tage
fo
r ar
t, t
he
con
sult
ativ
e d
ocu
men
t o
n t
he
Infr
astr
uct
ure
Lev
y d
oes
no
t m
enti
on
th
e en
han
cem
ent
of
the
pu
blic
rea
lm t
hro
ugh
pu
blic
art
; no
r
do
es it
co
nsi
der
th
e im
plic
atio
ns
of
intr
od
uci
ng
the
Levy
on
exi
stin
g p
olic
y.
Nei
ther
pu
blic
art
no
r a
per
cen
tage
fo
r ar
t sc
hem
e ar
e m
enti
on
ed a
mo
ng
the
exam
ple
s o
f p
ote
nti
al
ben
efic
iari
es.
It is
tru
e th
at p
ub
lic a
rt c
on
trib
ute
s to
imp
rove
d s
tree
ts a
nd
pu
blic
sp
aces
bu
t th
ere
app
ears
to
be
no
sp
ecif
ic in
ten
tio
n t
o u
se t
he
Levy
to
su
pp
ort
th
e St
ates
po
licy
on
pu
blic
art
, no
r
per
cen
tage
fo
r ar
t as
a p
rim
e d
eliv
ery
mec
han
ism
.
This
rai
ses
the
qu
esti
on
of
wh
eth
er t
he
exis
tin
g p
erce
nta
ge f
or
art
po
licy
wo
uld
co
nti
nu
e to
be
advo
cate
d a
nd
en
cou
rage
d a
lon
gsid
e th
e Le
vy; i
t is
no
t cl
ear
fro
m t
he
do
cum
ent
that
th
is is
th
e ca
se.
On
th
e co
ntr
ary,
th
e as
sura
nce
s gi
ven
ab
ou
t th
e co
mm
erci
al im
pac
t o
f th
e Le
vy d
o n
ot
add
ress
th
e
sim
ult
aneo
us
app
licat
ion
of
the
per
cen
tage
fo
r ar
t p
olic
y, s
o t
hat
th
e im
plic
atio
n is
th
at it
wo
uld
no
t
be
advo
cate
d.
Even
if it
wer
e, g
iven
th
at it
is a
vo
lun
tary
po
licy,
th
e lik
elih
oo
d t
hat
it w
ou
ld c
on
tin
ue
to d
eliv
er b
enef
it m
ust
be
min
imal
.
Off
icer
dis
cuss
ion
pre
ced
ing
the
dev
elo
pm
ent
of
the
con
sult
atio
n p
aper
bro
ach
ed t
he
issu
e o
f th
e
imp
ort
ance
of
per
cen
tage
fo
r ar
t w
ith
in t
he
po
licy
dev
elo
pm
ent
aro
un
d t
he
pro
po
sed
Lev
y. T
his
app
ears
to
be
ou
tsta
nd
ing.
In t
he
con
text
of
stre
ngt
hen
ing
the
per
cen
tage
fo
r ar
t sc
hem
e an
d e
nh
anci
ng
the
pu
blic
re
alm
thro
ugh
pu
blic
art
of
all k
ind
s, it
is im
po
rtan
t th
at t
he
ben
efit
s o
f th
is S
tate
s p
olic
y co
nti
nu
e to
be
del
iver
ed.
Un
der
th
e In
fras
tru
ctu
re L
evy
pro
po
sal i
t is
no
t cl
ear
ho
w t
his
wo
uld
be
ach
ieve
d.
Ro
d M
cLo
ugh
lin
Cu
ltu
ral D
evel
op
men
t O
ffic
er, E
DTS
C
The
Jers
ey C
ham
ber
of C
omm
erce
C
ham
ber
Ho
use
, 25
Pie
r R
oad
, St
Hel
ier
Jers
ey, C
han
nel
Isla
nd
s, J
E2 4
XW
Te
l: 0
15
34 7
24
536
E-
mai
l: ad
min
@je
rsey
cham
ber
.co
m
Web
site
: ww
w.je
rsey
cham
ber
.co
m
8th
Sep
tem
ber
20
17
R
esp
ons
e to
th
e P
lan
nin
g M
inis
ter,
reg
ard
ing
the
Jers
ey In
fras
tru
ctu
re L
evy
Co
nsu
ltat
ion
Jo
int
lett
er f
rom
: Je
rsey
Cha
mb
er o
f C
omm
erce
Je
rsey
Co
nst
ruct
ion
Cou
ncil
The
Jers
ey H
osp
ital
ity
Ass
ocia
tio
n
Jers
ey F
arm
ers
Un
ion
Port
s o
f Je
rsey
Th
e A
sso
ciat
ion
of
Jers
ey A
rch
itec
ts
CC
A
ll St
ates
Mem
ber
s
Loca
l Med
ia
Dea
r M
inis
ter,
Th
is is
a j
oin
t, o
pen
lett
er o
n b
ehal
f o
f th
e J
erse
y C
ham
ber
of
Co
mm
erce
Bu
ildin
g an
d D
evel
op
men
t C
om
mit
tee
an
d a
ll o
f th
e ab
ove
lis
ted
bu
sin
ess
rep
rese
nta
tive
org
anis
atio
ns
in J
erse
y, i
n d
irec
t re
spo
nse
to
th
e p
rop
ose
d
Jers
ey
Infr
astr
uct
ure
Le
vy
(JIL
) C
on
sult
atio
n.
Each
o
f th
ese
org
anis
atio
ns
will
in
div
idu
ally
re
spo
nd
to
th
e co
nsu
ltat
ion
an
d w
e w
ou
ld v
ery
mu
ch e
nco
ura
ge y
ou
to
rea
d t
ho
se r
esp
on
ses,
in c
on
jun
ctio
n w
ith
th
is le
tter
. B
y vi
rtu
e o
f th
e fa
ct t
hat
all
ou
r o
rgan
isat
ion
s ar
e co
ntr
ibu
tin
g to
war
ds
and
in
agr
eem
ent
wit
h t
he
con
ten
ts o
f th
is r
esp
on
se, i
t sh
ou
ld il
lust
rate
th
e co
nsi
der
able
co
nce
rn f
elt
by
the
sect
or
rega
rdin
g JI
L.
Such
is
the
exte
nt
of
app
reh
ensi
on
fo
r JI
L, C
ham
ber
hel
d a
n e
mer
gen
cy m
eeti
ng
in A
ugu
st t
o d
iscu
ss t
he
levy
, w
hic
h c
an o
nly
be
view
ed a
s a
new
ad
dit
ion
al c
on
stru
ctio
n s
pec
ific
bu
sin
ess
tax.
As
you
will
see
fro
m t
his
re
spo
nse
, th
ere
is c
on
sid
erab
le c
on
cern
, co
nfu
sio
n a
nd
fru
stra
tio
n f
elt
by
the
sect
or
as t
o t
he
po
ten
tial
im
plic
atio
ns
for
loca
l d
evel
op
men
t, t
he
con
stru
ctio
n i
nd
ust
ry,
the
isla
nd
s ec
on
om
y an
d J
erse
y, a
ll o
f w
hic
h
sho
uld
no
t b
e u
nd
eres
tim
ated
. W
hile
co
mm
erce
is
app
reci
ativ
e o
f yo
ur
des
ire
to c
on
sult
, w
e w
ou
ld v
ery
mu
ch h
op
e th
at y
ou
, as
th
e P
lan
nin
g M
inis
ter,
alo
ng
wit
h t
he
Pla
nn
ing
Dep
artm
ent,
th
e C
ou
nci
l of
Min
iste
rs a
nd
fel
low
po
litic
ian
s, w
ill t
ake
seri
ou
sly
the
sen
tim
ent
exp
ress
ed in
th
is r
esp
on
se.
As
wo
uld
no
rmal
ly b
e th
e st
ruct
ure
of
each
of
ou
r o
rgan
isat
ion
s re
spo
nse
to
su
ch l
egis
lati
ve p
rop
osa
ls a
nd
co
nsu
ltat
ion
s, f
eed
bac
k w
ou
ld b
e p
rovi
ded
on
sp
ecif
ic e
lem
ents
th
at o
ur
mem
ber
s h
igh
ligh
ted
as
area
s o
f co
nce
rn.
Ho
wev
er,
hav
ing
read
th
rou
gh t
he
enti
re c
on
sult
atio
n d
ocu
men
t, w
e al
l fe
el t
hat
th
e p
rop
ose
d l
evy
is
fun
dam
enta
lly f
law
ed a
nd
des
pit
e h
avin
g p
revi
ou
sly
pro
vid
ed d
etai
led
, ta
rget
ed a
nd
cri
tica
l co
mm
ents
on
el
emen
ts o
f JI
L, t
hey
do
no
t ap
pea
r to
hav
e b
een
tak
en o
n b
oar
d o
r d
irec
tly
answ
ered
an
d t
her
e re
mai
ns
sign
ific
ant
ano
mal
ies,
gre
y ar
eas
and
fla
wed
info
rmat
ion
wit
hin
th
e c
on
sult
atio
n d
ocu
men
t.
Ther
efo
re, w
e h
ave
join
tly
reac
hed
th
e fo
llow
ing
con
clu
sio
ns:
1.
Cri
tica
l JI
L q
ues
tio
ns,
(lis
ted
in
th
e co
nsu
ltat
ion
res
po
nse
s fr
om
eac
h o
f th
e ab
ove
lis
ted
org
anis
atio
ns)
h
ave
no
t b
een
ad
dre
ssed
or
resp
on
ded
to
no
w o
r p
revi
ou
sly
2.
Scru
tin
y h
ave
no
t ca
rrie
d o
ut
a re
view
of
the
pro
po
sed
lev
y, w
ith
reg
ard
s th
e im
pac
t it
may
hav
e o
n
dev
elo
pm
ent
and
th
e is
lan
ds
eco
no
my
3
. In
lig
ht
of
Bre
xit,
th
e fa
ll in
th
e va
lue
of
ster
ling
and
th
e im
pac
t it
is
hav
ing
on
th
e co
st o
f go
od
s an
d a
re
du
ced
mig
ran
t w
ork
forc
e, c
om
mer
ce i
s lo
oki
ng
to Jersey’s
gove
rnm
ent
to i
mp
lem
ent
mea
sure
s th
at
bo
ost
co
nfi
den
ce a
nd
gro
w t
he
eco
no
my,
no
t in
crea
se t
he
tax
bu
rden
an
d c
ost
s as
soci
ated
wit
h d
oin
g b
usi
nes
s in
th
e is
lan
d
Ou
r jo
int
resp
on
se t
o t
he
JIL
con
sult
atio
n h
as d
elib
erat
ely
bee
n k
ept
bri
ef, a
s w
e fe
el t
he
sen
tim
ent
exp
ress
ed is
cl
ear,
th
at J
IL m
ust
no
t b
e im
ple
men
ted
.
If y
ou
req
uir
e fu
rth
er i
nfo
rmat
ion
in
res
pec
t o
f o
ur
join
t co
mm
ents
, o
r w
ou
ld l
ike
a jo
int
mee
tin
g w
ith
ou
r o
rgan
isat
ion
s to
dis
cuss
th
is f
urt
her
, we
wo
uld
be
hap
py
to f
acili
tate
.
You
rs S
ince
rely
,
Je
rsey
Cha
mbe
r o
f Com
mer
ce, B
uild
ing
& D
evel
op
men
t C
om
mit
tee
Jers
ey C
on
stru
ctio
n C
oun
cil
Jers
ey F
arm
ers
Un
ion
The
Ass
oci
atio
n o
f Je
rsey
Arc
hit
ects
The
Jers
ey H
osp
ital
ity
Ass
ocia
tion
Po
rts
of
Jers
ey
Registered in England No. 2778116
Regulated by the RICS
Ral
ph
Bu
chh
olz
Dep
artm
ent
of t
he
En
viro
nm
ent
Sou
th H
ill
St. H
elie
r JE
2 4U
S
Da
te:
8h S
epte
mbe
r 20
17
Ou
r re
f: 1
5974
/MS/
BH
y/14
7269
14v3
Y
ou
r re
f:
Dea
r M
r B
uch
hol
z
Je
rse
y In
fra
stru
ctu
re L
evy
Pro
po
sal
Lic
hfi
eld
s h
as b
een
inst
ruct
ed b
y th
e Je
rsey
Con
stru
ctio
n C
oun
cil (
JeC
C)
and
ass
ocia
ted
mem
ber
com
pan
ies
(Dan
dar
a L
td, C
omp
rop
Ltd
, C L
e M
asu
rier
Ltd
, Gra
nge
Dev
elop
men
ts L
td a
nd
th
e Je
rsey
Far
mer
s U
nio
n)
to
revi
ew t
he
Jers
ey I
nfr
astr
uct
ure
Lev
y (J
IL)
Pro
pos
al (
Jun
e 20
17)
(“th
e JI
L P
rop
osal
”) a
nd
th
e V
iabi
lity
A
sses
smen
t fo
r R
evie
w o
f Dev
elop
er C
ontr
ibu
tion
s (M
ay 2
017
) (“
the
Via
bili
ty S
tud
y”)
wh
ich
un
der
pin
s th
e P
rop
osal
, in
res
pon
se t
o th
e co
nsu
ltat
ion
on
th
e p
rop
osed
intr
odu
ctio
n o
f a J
IL. T
his
lett
er a
nd
its
Ap
pen
dix
re
pre
sen
ts t
he
JeC
C’s
rep
rese
nta
tion
s to
th
e JI
L P
rop
osal
con
sult
atio
n.
Ba
ckg
rou
nd
We
reco
gnis
e th
at a
levy
for
Jers
ey n
eed
s to
res
pon
d t
o th
e St
ates
of J
erse
y’s
own
req
uir
emen
ts a
nd
le
gisl
ativ
e an
d p
olic
y co
nte
xt, b
ut
in fr
amin
g Je
CC
’s c
onsi
der
atio
n o
f th
e JI
L P
rop
osal
, use
ful r
efer
ence
can
be
mad
e to
cu
rren
t p
ract
ice
in E
ngl
and
as
a gu
ide
for
wh
at m
ay o
r m
ay n
ot b
e ef
fect
ive1 . T
he
pri
nci
ple
s fo
r co
nsi
der
atio
n o
f via
bili
ty w
ith
in a
levy
-bas
ed a
pp
roac
h a
re s
et o
ut
wit
hin
En
glan
d’s
Nat
ion
al P
lan
nin
g P
olic
y F
ram
ewor
k (N
PP
F)
and
acc
omp
anyi
ng
Pla
nn
ing
Pra
ctic
e G
uid
ance
(P
PG
) w
hic
h w
e co
nsi
der
in m
ore
det
ail
in t
he
Rev
iew
we
carr
y ou
t of
th
e V
iabi
lity
Stu
dy
wh
ich
is a
ttac
hed
as
Ap
pen
dix
1 t
o th
is r
epre
sen
tati
on. T
he
un
der
lyin
g m
essa
ge o
utl
ined
in t
he
NP
PF
an
d P
PG
is t
hat
via
bili
ty a
sses
smen
ts s
hou
ld b
e ev
iden
ce-b
ased
an
d a
ny
scal
e of
pla
nn
ing
obli
gati
ons
shou
ld n
ot b
e of
a s
cale
wh
ich
th
reat
ens
dev
elop
men
t an
d d
eliv
ery
of a
p
lan
.
Th
e Je
CC
rep
rese
nts
mem
bers
from
acr
oss
the
con
stru
ctio
n in
du
stry
in J
erse
y, in
clu
din
g th
e la
rges
t an
d
mos
t ac
tive
firm
s in
del
iver
ing
new
dev
elop
men
t. T
hey
th
eref
ore
hav
e u
np
aral
lele
d e
xper
ien
ce a
nd
kn
owle
dge
of t
he
pro
per
ty m
arke
t in
Jer
sey
and
we
hav
e so
ugh
t to
leve
rage
th
is e
xper
ien
ce a
nd
insi
ght
in
pre
par
ing
this
res
pon
se t
o th
e JI
L p
rop
osal
s.
1 W
e n
ote
that
th
e V
iabi
lity
Ass
essm
ent
for
revi
ew o
f Dev
elop
er C
ontr
ibu
tion
s u
sed
to
just
ify
the
Pro
pos
al m
akes
sim
ilar
ref
eren
ce t
o th
e
NP
PF
an
d P
PG
, as
wel
l as
to t
he
RIC
S G
uid
ance
an
d H
arm
an R
evie
w, t
o w
hic
h w
e h
ave
also
giv
en c
onsi
der
atio
n.
Pg 2/10
14726914v3
Lic
hfi
eld
s is
th
e p
re-e
min
ent
pla
nn
ing
and
dev
elop
men
t co
nsu
ltan
cy in
th
e U
K. T
hro
ugh
ou
r w
ork
in
En
glan
d a
nd
Wal
es, w
e h
ave
been
invo
lved
in t
he
dev
elop
men
t an
d a
pp
lica
tion
of t
he
Com
mu
nit
y In
fras
tru
ctu
re L
evy
(CIL
), in
clu
din
g p
arti
cip
atin
g in
th
e ex
amin
atio
n o
f CIL
rat
es a
cros
s E
ngl
and
an
d W
ales
, p
rovi
din
g u
s th
e n
eces
sary
insi
ght
on t
he
pra
ctic
alit
ies
of a
n in
fras
tru
ctu
re le
vy-t
ype
of a
pp
roac
h. L
ich
fiel
ds
was
RT
PI
pla
nn
ing
con
sult
ancy
of t
he
year
for
thre
e su
cces
sive
yea
rs 2
012
-20
14 a
nd
we
advi
se c
entr
al
Gov
ern
men
t, lo
cal a
uth
orit
ies
and
pri
vate
dev
elop
ers
(in
clu
din
g th
e la
rges
t h
ouse
buil
der
s an
d d
evel
oper
s)
on p
roje
cts
thro
ugh
out
the
UK
.
Bas
ed u
pon
a r
evie
w o
f th
e ev
iden
ce, t
he
JeC
C h
as s
ign
ific
ant
con
cern
s an
d r
eser
vati
ons
abou
t th
e p
rop
osed
in
trod
uct
ion
of a
n in
fras
tru
ctu
re le
vy in
Jer
sey.
Th
e V
iabi
lity
Stu
dy
up
on w
hic
h t
he
pro
pos
ed J
IL is
bas
ed
con
tain
s a
nu
mbe
r of
flaw
s an
d s
ign
ific
antl
y ov
erst
ates
th
e vi
abil
ity
of d
evel
opm
ent
in J
erse
y, a
nd
fail
s to
re
cogn
ise
the
inh
eren
t d
iffi
cult
ies
in a
sses
sin
g vi
abil
ity
in J
erse
y al
toge
ther
. Th
e d
isti
nct
cir
cum
stan
ces
that
ex
ist
wit
hin
Jer
sey
mea
n t
hat
th
e in
fras
tru
ctu
re le
vy s
yste
m c
ann
ot s
imp
ly b
e tr
ansf
erre
d o
ver
from
En
glan
d
and
Wal
es, a
nd
in a
ny
case
th
e U
K G
over
nm
ent’
s re
cen
t in
dep
end
ent
CIL
rev
iew
has
dem
onst
rate
d t
hat
th
e sy
stem
ad
opte
d h
as n
ot m
et it
s ex
pec
tati
ons.
In
th
is c
onte
xt, t
he
JeC
C s
tron
gly
urg
es t
he
Stat
es o
f Jer
sey
to
reco
nsi
der
its
pro
pos
als
to in
trod
uce
JIL
, un
til a
t le
ast
the
issu
es id
enti
fied
wit
h t
he
Via
bili
ty S
tud
y ca
n b
e re
solv
ed.
Lic
hfi
eld
s’ r
ev
iew
of
the
Via
bil
ity
Stu
dy
(Ap
pe
nd
ix 1
)
Ap
pen
dix
1 o
f ou
r re
pre
sen
tati
on s
ets
out
a re
view
of
the
Via
bili
ty S
tud
y, w
hic
h u
nd
erp
ins
the
curr
ent
JIL
p
rop
osal
(an
d it
s ra
te o
f £8
5/sq
m).
Th
is s
how
s th
at L
ich
fiel
ds
has
a n
um
ber
of c
once
rns
abou
t th
is S
tud
y,
wh
ich
are
su
mm
aris
ed a
s fo
llow
s:
1 T
he
alte
rnat
ive
use
val
ue
of m
ost
of t
he
site
s as
sess
ed is
bas
ed o
n a
n a
ssu
mp
tion
of i
nd
ust
rial
val
ue;
h
owev
er, t
he
Stu
dy
has
no
evid
ence
to
sup
por
t th
is fi
gure
;
2 W
ith
th
e ex
cep
tion
of a
few
sch
emes
, th
e St
ud
y as
sess
es a
ll b
row
nfi
eld
sit
es a
s be
ing
in in
du
stri
al u
se,
des
pit
e th
e fa
ct t
hat
in J
erse
y re
lati
vely
few
bro
wn
fiel
d s
ites
are
act
ual
ly li
kely
to
be in
ind
ust
rial
use
, an
d a
re m
ore
like
ly t
o be
oth
er u
ses
wh
ich
hav
e h
igh
er v
alu
es (
e.g.
hot
els,
ret
ail s
pac
e an
d o
ffic
e sp
ace)
. O
ur
esti
mat
ion
of l
and
val
ues
of s
econ
dar
y re
tail
sp
ace
show
s th
at t
he
resi
du
al v
alu
es w
ould
not
su
ffic
ien
tly
exce
ed t
he
viab
ilit
y th
resh
old
acr
oss
mos
t d
evel
opm
ents
;
3 T
he
viab
ilit
y th
resh
old
use
d in
th
e St
ud
y as
sum
es a
20
% u
pli
ft o
n e
xist
ing
use
val
ue
(EU
V)
wou
ld
ince
nti
vise
a la
nd
own
er t
o se
ll. I
t is
qu
esti
onab
le h
ow, i
n t
he
case
of J
erse
y, it
is p
ossi
ble
to d
eter
min
e su
ch a
val
ue,
giv
en t
he
spec
ific
tax
an
d la
nd
ow
ner
ship
cir
cum
stan
ces
on t
he
Isla
nd
, wh
ich
var
y co
mp
ared
to
the
UK
. It
is o
f not
e th
at in
Lon
don
(w
ith
dif
fere
nt
tax
and
lan
d o
wn
ersh
ip c
ircu
mst
ance
s),
the
May
or o
f Lon
don
’s r
ecen
tly
pro
du
ced
Aff
ord
able
Hou
sin
g SP
D p
rop
oses
via
bili
ty a
pp
roac
hes
bas
ed
on a
n E
UV
+ w
ith
an
up
lift
of u
p t
o 30
%, a
t th
e sa
me
tim
e as
giv
ing
flex
ibil
ity
to u
se a
n a
lter
nat
ive
use
va
lue.
JeC
C m
embe
rs’ e
xper
ien
ce is
th
at a
sig
nif
ican
t p
rem
ium
is o
ften
req
uir
ed, t
o re
flec
t ta
xes
and
p
rofi
t m
argi
ns.
It
is a
lso
like
ly t
hat
th
e pr
emiu
m w
ill v
ary
dep
end
ing
on t
he
typ
e of
lan
d; f
or e
xam
ple
, ow
ner
s of
pad
doc
k la
nd
like
ly t
o d
eman
d a
mu
ch h
igh
er p
rem
ium
giv
en t
he
amen
ity
valu
e of
su
ch la
nd
; an
d
4 T
he
con
stru
ctio
n c
osts
are
like
ly t
o be
a s
ign
ific
ant
un
der
-est
imat
e, n
ot le
ast
beca
use
BC
IS d
ata
(on
w
hic
h t
he
Stu
dy
reli
es)
has
lim
ited
info
rmat
ion
wh
ich
dir
ectl
y re
late
s to
Jer
sey.
Sta
keh
old
ers
sugg
este
d
hig
her
cos
ts d
uri
ng
con
sult
atio
n, a
nd
figu
res
pu
t to
Lic
hfi
eld
s by
mem
bers
of t
he
JeC
C (
base
d o
n lo
cal
QS
surv
eys)
dem
onst
rate
th
at t
he
un
der
esti
mat
ion
in b
uil
d c
osts
alo
ne
wou
ld e
nti
rely
wip
e ou
t an
y p
oten
tial
JIL
con
trib
uti
on.
Pg 3/10
14726914v3
In a
dd
itio
n t
o ou
r co
nce
rns
abou
t th
e sp
ecif
ic a
pp
roac
h a
nd
ass
um
ptio
ns
in t
he
Via
bili
ty S
tud
y, t
he
JeC
C a
lso
hav
e a
nu
mbe
r of
con
cern
s ab
out
the
over
all p
rin
cip
le o
f ad
opti
ng
such
a le
vy in
Jer
sey.
We
turn
to
thes
e be
low
.
Th
e p
rin
cip
le o
f a
n I
nfr
ast
ruct
ure
Le
vy f
or
Je
rse
y
We
not
e th
at m
any
of t
he
un
der
lyin
g p
rin
cip
les
beh
ind
th
e sc
hem
e d
esig
n fo
r th
e C
IL in
En
glan
d a
nd
Wal
es
hav
e be
en c
arri
ed fo
rwar
d t
o Je
rsey
. How
ever
, th
ere
are
a n
um
ber
of fu
nd
amen
tal d
iffe
ren
ces
in t
he
pro
per
ty
mar
ket
wh
ich
mea
n t
hat
an
En
glan
d a
nd
Wal
es-s
tyle
infr
astr
uct
ure
levy
ch
arge
can
not
be
seen
to
dir
ectl
y tr
ansl
ate
into
th
e ci
rcu
mst
ance
s of
Jer
sey.
Mos
t si
gnif
ican
tly,
th
ere
are
fun
dam
enta
l dif
ficu
ltie
s in
ass
essi
ng
viab
ilit
y on
a c
onsi
sten
t ba
sis,
giv
en t
he
sign
ific
ant
vari
atio
ns
in r
esid
enti
al la
nd
val
ues
see
n o
n t
he
isla
nd
.
Acc
ura
tely
ass
ess
ing
via
bil
ity
Th
e V
iabi
lity
Stu
dy
not
ed t
hat
con
cern
s w
ere
rais
ed d
uri
ng
con
sult
atio
n a
bou
t th
e ov
eral
l abi
lity
to
asse
ss
viab
ilit
y in
Jer
sey,
bu
t th
e au
thor
s of
th
e V
iabi
lity
Stu
dy
reje
cted
th
em. H
owev
er, t
he
evid
ence
set
ou
t w
ith
in
the
Via
bili
ty S
tud
y it
self
see
ms
to s
up
por
t th
ose
con
cern
s ra
ther
th
an t
he
con
clu
sion
s of
th
e au
thor
s, i.
e. t
hat
vi
abil
ity
is t
oo d
iffi
cult
to
det
erm
ine
accu
rate
ly e
nou
gh t
o ju
stif
y im
pos
ing
a fi
xed
flat
-rat
e co
st o
n
dev
elop
men
t, i.
e. J
IL.
As
set
out
in p
aras
3.1
5-25
of o
ur
Rev
iew
of t
he
Via
bili
ty S
tud
y (A
pp
end
ix 1
), t
her
e ar
e re
lati
vely
few
sal
es o
f h
ousi
ng
lan
d in
Jer
sey,
ave
ragi
ng
arou
nd
1-2
sit
es p
er y
ear
over
th
e la
st 1
0 y
ears
wh
ich
itse
lf r
aise
s si
gnif
ican
t qu
esti
ons
abou
t sa
mp
le s
ize
and
wh
eth
er it
is a
su
ffic
ien
tly
stro
ng
evid
enti
al p
latf
orm
for
mak
ing
assu
mp
tion
s on
via
bili
ty. E
ven
acr
oss
this
sm
all s
amp
le, t
he
pri
ce p
aid
(p
er h
ecta
re)
on t
hes
e si
tes
ran
ges
sign
ific
antl
y, fr
om £
1.4m
2 per
hec
tare
(si
mil
ar t
o la
nd
val
ues
in C
oven
try3 )
to £
23m
/ha
(sim
ilar
to
lan
d
valu
es in
cen
tral
Lon
don
), a
s sh
own
bel
ow. P
lace
d in
th
is c
onte
xt, i
t w
ould
cle
arly
be
very
dif
ficu
lt t
o as
sess
vi
abil
ity
(an
d c
oncl
ud
e u
pon
a C
IL r
ate,
wh
ich
did
not
th
reat
en v
iabi
lity
) in
an
En
glis
h lo
cal a
uth
orit
y ar
ea
wh
ere
lan
d v
alu
es v
arie
d t
o th
is e
xten
t.
2 £
1.4m
/ha
is t
he
low
est
valu
e w
hic
h a
pp
ears
in T
able
6.1
of t
he
Via
bili
ty S
tud
y, h
owev
er p
ara
6.20
of
the
Via
bili
ty S
tud
y ci
tes
the
low
est
valu
e be
ing
£71
6,41
8/h
a. T
he
sou
rce
of t
he
£71
6,41
8 fi
gure
is n
ot k
now
n.
3 Sou
rce:
DC
LG
Lan
d V
alu
e E
stim
ates
for
Pol
icy
Ap
pra
isal
, 20
15
Pg 4/10
14726914v3
Figure 1 Range of Residen
tial Land Values in
Jersey ‐ 2006‐17
Source: Lichfields based
on Viability Study
Wh
ilst
th
e V
iabi
lity
Stu
dy
has
att
empt
ed t
o m
ake
a ju
dge
men
t ov
er t
he
app
roxi
mat
e av
erag
e of
th
ese
valu
es -
es
tim
atin
g £
6m/h
a –
it is
it e
vid
ent
that
sit
es a
ctu
ally
sel
l for
figu
res
wel
l abo
ve a
nd
bel
ow t
his
. Th
e u
se o
f an
av
erag
e la
nd
val
ue
in d
eter
min
ing
viab
ilit
y is
on
ly r
obu
st if
mos
t si
tes
hav
e a
valu
e w
hic
h is
th
e sa
me
or
clu
ster
s cl
osel
y ar
oun
d t
he
aver
age,
an
d w
her
e th
ere
are
few
if a
ny
valu
es w
hic
h d
evia
te s
ign
ific
antl
y fr
om it
. In
Jer
sey,
th
is is
cle
arly
not
th
e ca
se.
Th
e p
rin
cip
le o
f ass
essi
ng
viab
ilit
y ac
ross
all
res
iden
tial
dev
elop
men
t on
th
e is
lan
d is
th
eref
ore
un
der
min
ed
by t
he
fact
th
at la
nd
val
ues
var
y so
sig
nif
ican
tly
from
th
e av
erag
e, w
ith
no
clea
r p
atte
rn o
ver
loca
tion
, tim
e or
si
ze o
f eac
h s
ite.
Th
is w
ould
mak
e it
ext
rem
ely
dif
ficu
lt, i
f not
imp
ossi
ble,
to
det
erm
ine
a si
ngl
e in
fras
tru
ctu
re
levy
rat
e w
ith
an
y re
ason
able
or
just
ifie
d c
onfi
den
ce t
hat
it w
ould
not
un
der
min
e th
e vi
abil
ity
of a
sig
nif
ican
t n
um
ber
of s
ites
in J
erse
y.
Ince
nti
visi
ng
la
nd
sa
les
An
oth
er k
ey d
iffi
cult
y in
det
erm
inin
g vi
abil
ity
wit
hin
Jer
sey
rela
tes
to h
ow m
uch
up
lift
is r
equ
ired
on
lan
d
valu
es t
o in
cen
tivi
se la
nd
own
ers
to s
ell.
Th
e ab
sen
ce o
f in
her
itan
ce t
ax in
Jer
sey
mea
ns
that
lan
dow
ner
s ar
e n
ot s
ubj
ect
to t
he
sam
e fi
nan
cial
‘pen
alti
es’ a
s th
eir
En
glis
h c
oun
terp
arts
, sh
ould
th
ey w
ish
to
mai
nta
in
own
ersh
ip o
f th
eir
lan
d. I
n E
ngl
and
, th
e p
rosp
ect
of in
her
itan
ce t
ax is
like
ly t
o re
sult
in la
nd
own
ers
acce
pti
ng
a p
rice
wh
ich
is lo
wer
wer
e in
her
itan
ce t
ax n
ot a
pp
lica
ble,
th
us
mak
ing
it e
asie
r to
est
imat
e th
e sc
ale
of u
pli
ft
on e
xist
ing
valu
e re
quir
ed t
o in
cen
tivi
se a
sal
e. T
he
esti
mat
e of
th
e sc
ale
of u
pli
ft is
als
o u
nd
oubt
edly
ass
iste
d
by t
he
fact
th
at t
her
e ar
e si
mp
ly m
ore
lan
d t
ran
sact
ion
s.
In J
erse
y, t
he
abse
nce
of i
nh
erit
ance
tax
mea
ns
that
lan
dow
ner
s m
ay r
equ
ire
a gr
eate
r in
cen
tive
to
sell
th
an
in E
ngl
and
(if
at
all)
, an
d d
iffe
ren
t la
nd
own
ers
may
req
uir
e d
iffe
ren
t p
rem
ium
s d
epen
din
g on
ind
ivid
ual
an
d
wid
er c
ircu
mst
ance
s. T
his
mak
es it
inh
eren
tly
dif
ficu
lt t
o d
eter
min
e w
hat
sca
le o
f up
lift
is c
onsi
der
ed
nec
essa
ry t
o in
cen
tivi
se a
lan
dow
ner
to
sell
, ad
din
g ye
t m
ore
com
ple
xity
an
d u
nce
rtai
nty
to
the
viab
ilit
y
Viability Study
£0
£5
£10
£15
£20
£25 May‐05
Oct‐06
Feb‐08
Jul‐09
Nov‐10
Apr‐12
Aug‐13
Dec‐14
May‐16
Sep‐17
Price per hectare (£millions)
Sale date
Pg 5/10
14726914v3
asse
ssm
ent.
Th
e ex
iste
nce
of a
20
% t
ax (
via
shar
ehol
der
s) a
lso
pu
ts fu
rth
er u
pw
ard
pre
ssu
re o
n t
he
up
lift
re
quir
ed t
o in
cen
tivi
se s
ales
. Th
is m
ean
s th
e 20
% u
pli
ft t
o E
UV
on
wh
ich
th
e V
iabi
lity
Stu
dy
is b
ased
is li
kely
to
be
a si
gnif
ican
t u
nd
er-e
stim
ate
of w
hat
is r
equ
ired
. Th
ese
fact
ors
hav
e n
ot b
een
ad
equ
atel
y co
nsi
der
ed b
y th
e V
iabi
lity
Stu
dy.
Reg
ener
ati
on a
rea
s
Th
e n
eed
to
ince
nti
vise
lan
d s
ales
(an
d s
ubs
equ
entl
y d
evel
op s
ites
) is
of p
arti
cula
r im
por
tan
ce fo
r si
tes
wit
hin
St
Hel
ier
(an
d o
ther
bu
ilt
up
are
as)
wh
ich
are
par
t of
reg
ener
atio
n a
reas
. Th
e V
iabi
lity
Stu
dy
acce
pts
th
at s
uch
sit
es t
ypic
ally
hav
e lo
wer
val
ues
du
e to
th
eir
sett
ing
(par
a 4.
33-4
) an
d t
he
cost
s ar
e li
kely
to
be h
igh
gi
ven
th
e m
ore
com
ple
x n
atu
re o
f th
ese
site
s (c
omp
ared
wit
h, f
or e
xam
ple
, pad
doc
k la
nd
on
th
e ed
ge o
f se
ttle
men
ts).
Th
is a
lrea
dy
mea
ns
such
sit
es a
re a
lrea
dy
like
ly t
o be
op
erat
ing
at t
he
mar
gin
s of
via
bili
ty.
Th
e Is
lan
d P
lan
’s p
olic
ies
(not
ably
Pol
icy
SP1)
see
ks t
o d
irec
t m
uch
of t
he
Isla
nd
’s d
evel
opm
ents
to
St H
elie
r (a
nd
oth
er b
uil
t-u
p a
reas
), w
ith
rel
ease
of g
reen
fiel
d la
nd
alm
ost
com
ple
tely
res
tric
ted
. Pol
icy
H1
of t
he
Isla
nd
Pla
n s
tate
s th
at le
adin
g th
e re
gen
erat
ion
of t
he
Isla
nd
’s u
rban
are
as t
hro
ugh
res
iden
tial
dev
elop
men
t is
on
e of
th
e h
ousi
ng
obje
ctiv
es. T
his
mea
ns
that
th
e G
over
nm
ent
wil
l nee
d t
o en
sure
th
ese
rege
ner
atio
n s
ites
re
mai
n v
iabl
e, s
o as
not
to
un
der
min
e th
e P
lan
ove
rall
. Th
e im
ple
men
tati
on o
f an
ad
dit
ion
al, f
lat-
rate
ch
arge
(i
.e. J
IL)
wh
ich
doe
s n
ot r
efle
ct t
he
nat
ure
of s
uch
dev
elop
men
ts is
like
ly t
o be
det
rim
enta
l to
(an
d u
ltim
atel
y u
nd
erm
ine)
th
e P
lan
’s a
mbi
tion
s fo
r re
gen
erat
ion
.
A p
oten
tial
sol
uti
on t
o th
is w
ould
be
to in
trod
uce
var
yin
g JI
L r
ates
or
exem
pti
ons
by a
rea
or fo
r ce
rtai
n t
ypes
of
dev
elop
men
t. H
owev
er, L
ich
fiel
ds
doe
s n
ot c
onsi
der
th
is t
o be
ap
pro
pri
ate
give
n o
ur
revi
ew o
f th
e V
iabi
lity
Stu
dy
has
ind
icat
ed t
hat
a J
IL c
har
ges
shou
ld n
ot b
e im
ple
men
ted
at
all o
n t
he
Isla
nd
(se
e ou
r re
com
men
dat
ion
s be
low
).
Ex
isti
ng
pla
nn
ing
co
ntr
ibu
tio
ns
In d
ecid
ing
wh
eth
er o
r n
ot t
o in
trod
uce
an
infr
astr
uct
ure
levy
, it
wou
ld b
e h
elp
ful t
o n
ote
the
exis
tin
g co
ntr
ibu
tion
s th
e d
evel
opm
ent
ind
ust
ry a
lrea
dy
mak
es t
o in
fras
tru
ctu
re a
nd
th
e w
ider
eco
nom
y in
Jer
sey.
T
hes
e in
clu
de
(bu
t ar
e n
ot li
mit
ed t
o) b
us
stop
s, t
he
Eas
tern
Cyc
le R
oute
, per
cen
tage
for
Art
, car
ryin
g ou
t ba
t su
rvey
s (a
nd
ass
ocia
ted
mit
igat
ion
), s
tam
p d
uty
an
d p
lan
nin
g fe
es (
and
ass
ocia
ted
pro
fess
ion
al fe
es).
Th
e in
du
stry
has
rec
entl
y al
so s
een
incr
ease
s in
cos
ts a
ssoc
iate
d w
ith
bu
ild
ing
regu
lati
ons,
incr
ease
s in
sta
mp
d
uty
an
d t
he
cost
s/re
quir
emen
ts a
ssoc
iate
d w
ith
sta
te-o
wn
ed u
tili
ties
. Th
e re
cen
tly
adop
ted
PO
A
Sup
ple
men
tary
Pla
nn
ing
Gu
idan
ce (
SPG
) (J
uly
20
17)
sets
ou
t in
dic
ativ
e co
sts
of P
OA
s fo
r tr
avel
an
d
tran
spor
t w
hic
h in
clu
des
, am
ongs
t ot
her
s:
1 £
1,35
0 p
er r
esid
enti
al u
nit
for
cycl
e an
d w
alki
ng
rou
tes;
2 £
1,35
0 p
er r
esid
enti
al u
nit
for
th
e E
aste
rn C
ycle
Rou
te;
3 £
240
-£8
00
per
un
it fo
r cy
cle
lock
ers
(aga
inst
a m
inim
um
req
uir
emen
t of
1 p
er b
edro
om fo
r re
sid
enti
al
un
its)
;
4 £
6,5
00
per
con
nec
ted
str
eet
lam
p, a
pp
lica
ble
on s
ites
of m
ore
than
20
un
its;
an
d
5 V
aryi
ng
con
trib
uti
ons
for
hig
hw
ay a
cces
s an
d ju
nct
ion
/car
riag
eway
alt
erat
ion
s (d
epen
din
g on
sit
e sp
ecif
ic is
sues
).
So, w
ith
out
a JI
L, d
evel
opm
ents
hav
e an
d w
ill c
onti
nu
e to
mak
e ap
pro
pri
ate
con
trib
uti
ons
for
infr
astr
uct
ure
th
at t
he
JIL
pro
pos
al is
su
gges
tin
g w
ould
be
add
ress
ed v
ia t
he
new
levy
. Eve
n w
ith
out
the
con
cern
s ab
out
the
imp
act
on v
iabi
lity
(w
hic
h c
ould
red
uce
th
e sc
ale
of d
evel
opm
ent
and
th
eref
ore
infr
astr
uct
ure
pro
vid
ed),
th
e JI
L’s
sca
le o
f ‘ad
ded
val
ue’
in t
erm
s of
ad
dit
ion
al in
fras
tru
ctu
re d
eliv
ery
is t
her
efor
e re
lati
vely
lim
ited
.
Pg 6/10
14726914v3
Re
lati
on
ship
be
twe
en
JIL
an
d e
xis
tin
g P
OA
s
Wit
h r
egar
d t
o th
e re
lati
onsh
ip b
etw
een
exi
stin
g P
OA
s an
d J
IL, w
e n
ote
that
th
e Je
CC
has
alr
ead
y h
igh
ligh
ted
som
e of
th
ese
issu
es w
ith
in it
s le
tter
to
the
Pla
nn
ing
Pol
icy
and
Pro
ject
s T
eam
, dat
ed 2
2 M
ay
2017
.
Th
e m
ost
rece
nt
revi
ew o
f PO
As
has
bee
n a
dop
ted
via
th
e SP
G a
dvi
ce n
ote.
Th
e Je
CC
’s m
ain
con
cern
s re
late
to
th
e fa
ct t
hat
th
e p
rop
osed
intr
odu
ctio
n o
f JIL
has
not
bee
n c
onsi
der
ed in
con
jun
ctio
n w
ith
rev
iew
s to
P
OA
s. A
s w
e se
t ou
t be
low
, it
app
ears
PO
As
and
JIL
are
exp
ecte
d t
o fu
nd
sim
ilar
infr
astr
uct
ure
, an
d t
her
e is
a
lack
of c
lari
ty a
s to
exa
ctly
wh
at e
ach
is e
xpec
ted
to
fun
d. T
his
giv
es r
ises
to
a co
nce
rn t
hat
is d
escr
ibed
in
En
glan
d a
nd
Wal
es a
s “d
oubl
e d
ipp
ing
” an
d s
omet
hin
g th
at t
he
PP
G in
En
glan
d s
pec
ific
ally
see
ks t
o av
oid
, w
her
e it
sta
tes4 : “
The
re s
hou
ld b
e n
ot a
ctu
al o
r p
erce
ived
‘dou
ble
dip
pin
g’ w
ith
dev
elop
ers
pa
yin
g t
wic
e fo
r th
e sa
me
item
of
infr
ast
ruct
ure
.” (
our
emp
has
is).
Ap
pen
dix
1 o
f th
e P
OA
SP
G s
ets
out
wh
ere
pla
nn
ing
obli
gati
ons
may
be
sou
ght.
Th
ese
incl
ud
e (b
ut
are
not
li
mit
ed t
o);
1 N
atu
ral E
nvi
ron
men
t –
incl
ud
ing
off-
site
lan
dsc
apin
g, t
ree-
pla
nti
ng,
en
viro
nm
enta
l im
pro
vem
ents
, an
d
ced
ing
lan
d t
o th
e p
ubl
ic;
2 H
isto
ric
En
viro
nm
ent
– in
clu
din
g re
stor
atio
n o
f a li
sted
bu
ild
ing,
on
goin
g m
ain
ten
ance
, ced
ing
pro
per
ty
to t
he
pu
blic
, rem
oval
/rec
ord
ing
of a
rch
aeol
ogic
al a
rtef
acts
;
3 So
cial
, Com
mu
nit
y an
d O
pen
Sp
ace
– in
clu
din
g w
orks
to
lan
d o
n o
r of
f sit
e to
imp
rove
qu
alit
y an
d
acce
ssib
ilit
y;
4 T
rave
l an
d T
ran
spor
t -
foot
pat
h e
nh
ance
men
ts, c
ycle
rou
tes,
ped
estr
ian
cro
ssin
g, o
ff-s
ite
cycl
e p
arki
ng,
bu
s sh
elte
r, b
us
serv
ice
subs
idy;
5 N
atu
ral r
esou
rces
an
d w
aste
man
agem
ent
faci
liti
es.
Th
e JI
L P
rop
osal
sta
tes
that
th
e P
OA
pro
cess
wil
l ch
ange
if a
JIL
is in
trod
uce
d t
o co
ver
only
sit
e-sp
ecif
ic
issu
es a
nd
th
e n
ew J
IL le
vy w
ill c
over
are
a-w
ide
imp
rove
men
ts. H
owev
er, a
n e
quiv
alen
t to
th
e E
ngl
ish
‘R
egu
lati
on 1
23’ l
ist
of in
fras
tru
ctu
re w
hic
h J
IL w
ould
be
exp
ecte
d t
o co
ver
has
not
yet
bee
n p
rep
ared
, hen
ce
is it
un
clea
r w
het
her
th
ere
wou
ld b
e ‘d
oubl
e-d
ipp
ing’
lead
ing
to p
erce
pti
ons
of p
oten
tial
‘dou
ble-
dip
pin
g’.
How
ever
, it
is c
lear
th
at t
he
exis
tin
g P
OA
obl
igat
ion
s co
ver
a w
ide
ran
ge o
f on
an
d o
ff-s
ite
infr
astr
uct
ure
- t
he
list
abo
ve o
f are
as w
her
e P
OA
s co
uld
be
requ
ired
is r
emar
kabl
y si
mil
ar t
o th
e li
st o
f pot
enti
al in
fras
tru
ctu
re
wh
ich
cou
ld b
e fu
nd
ed b
y JI
L s
et o
ut
on p
age
19 o
f th
e Je
rsey
In
fras
tru
ctu
re L
evy
Pro
pos
al. T
he
ben
efit
of
JIL
is t
hu
s w
hol
ly u
ncl
ear.
Per
cen
tag
e fo
r A
rt
We
not
e th
at t
he
Via
bili
ty S
tud
y ex
clu
des
th
e 0
.75%
of
con
stru
ctio
n c
osts
wh
ich
dev
elop
ers
are
enco
ura
ged
to
mak
e as
a c
ontr
ibu
tion
to
Art
in J
erse
y. T
his
rep
rese
nts
an
oth
er e
xist
ing
cost
wh
ich
is c
urr
entl
y al
read
y be
ing
abso
rbed
by
dev
elop
ers.
Th
e V
iabi
lity
Stu
dy
stat
es t
hat
th
is c
ontr
ibu
tion
is a
ssu
med
to
be a
ssim
ilat
ed in
to a
ny
new
levy
. How
ever
, th
ere
is n
o m
enti
on o
f th
is a
nd
an
y p
oten
tial
ch
ange
s to
do
so w
ith
in t
he
Pro
pos
al. T
his
rep
rese
nts
just
on
e el
emen
t of
th
e ca
lcu
lati
on w
hic
h u
nd
erm
ines
th
e p
rop
osed
£8
5/sq
m J
IL c
har
ge p
rop
osed
.
4 A
t P
PG
ID
: 23b
-00
2
Pg 7/10
14726914v3
Ex
em
pti
on
s o
f si
tes
for
aff
ord
ab
le h
ou
sin
g
Un
der
th
e P
rop
osal
, aff
ord
able
hou
sin
g sc
hem
es w
ill b
e ex
emp
t fr
om J
IL. U
nli
ke in
th
e U
K, a
ffor
dab
le
hou
sin
g is
not
req
uir
ed o
n m
arke
t-le
d d
evel
opm
ents
, in
stea
d b
ein
g p
rovi
ded
dir
ectl
y th
rou
gh 1
00
%
affo
rdab
le h
ousi
ng
sch
emes
. At
pre
sen
t A
nd
ium
Hom
es (
the
form
er S
tate
s of
Jer
sey
Hou
sin
g D
epar
tmen
t,
wh
ich
is n
ow a
n a
rms-
len
gth
cor
por
atis
ed s
tate
-ow
ned
hou
sin
g co
mp
any)
is t
he
only
dev
elop
men
t bo
dy
wit
h
acce
ss t
o G
over
nm
ent
fun
din
g to
pro
vid
e su
ch a
ffor
dab
le h
omes
. Th
e as
sum
pti
on in
th
e V
iabi
lity
Stu
dy
(an
d
the
enti
re p
rem
ise
of t
he
JIL
ch
arge
) is
th
at t
he
cost
s of
a J
IL w
ill c
ome
off t
he
lan
d v
alu
e (a
s op
pos
ed t
o, fo
r ex
amp
le, b
ein
g a
cost
fron
ted
by
the
hom
e-bu
yer,
wh
ich
in t
he
case
of a
ffor
dab
le h
ousi
ng
wou
ld b
enef
it fi
rst
tim
e bu
yers
). J
eCC
has
rea
l con
cern
th
at t
his
eff
ecti
vely
mak
es t
he
intr
odu
ctio
n o
f a J
IL a
n a
nti
-com
pet
itiv
e p
olic
y w
hic
h, i
n t
erm
s of
acc
essi
ng
lan
d fo
r d
evel
opm
ent
in t
he
mar
ket,
dis
ben
efit
s p
riva
te d
evel
oper
s on
th
e Is
lan
d in
favo
ur
of, w
hat
is e
ffec
tive
ly, a
Sta
te b
ody.
Le
sso
ns
fro
m t
he
UK
: th
e C
IL R
ev
iew
(2
017
)
As
inte
nd
ed in
Jer
sey,
CIL
in t
he
UK
cam
e in
to fo
rce
wit
h t
he
inte
nti
on o
f pro
vid
ing
cert
ain
ty t
o d
evel
oper
s,
loca
l pla
nn
ing
auth
orit
ies
and
com
mu
nit
ies
on in
fras
tru
ctu
re a
nd
fun
din
g as
par
t of
new
dev
elop
men
t. I
n t
he
UK
, loc
al a
uth
orit
ies
hav
e be
en a
ble
to s
et C
IL c
har
ges
sin
ce le
gisl
atio
n c
ame
into
pla
ce in
Ap
ril 2
010
. D
esp
ite
the
Gov
ern
men
t’s
inte
nti
on o
f pro
vid
ing
of a
sim
ple
sys
tem
of l
and
val
ue
cap
ture
, CIL
has
(fa
mou
sly)
be
en s
ubj
ect
to r
epea
ted
legi
slat
ive
chan
ges
to t
ry a
nd
dea
l wit
h u
nfo
rese
en p
robl
ems
and
un
inte
nd
ed
adve
rse
con
sequ
ence
s. I
n N
ovem
ber
2015
th
e G
over
nm
ent
com
mis
sion
ed a
n in
dep
end
ent
revi
ew o
f CIL
to
asse
ss it
s ef
fect
iven
ess.
Th
e re
view
com
pri
sed
:
1 A
res
earc
h r
epor
t (p
rep
ared
by
Un
iver
sity
of R
ead
ing
and
Th
ree
Dra
gon
s), w
hic
h lo
oked
at
the
valu
e of
C
IL, w
ho
is p
ayin
g, h
ow m
uch
is b
ein
g pa
ssed
to
nei
ghbo
urh
ood
s an
d w
het
her
CIL
is a
ffec
tin
g vi
abil
ity;
an
d;
2 A
rep
ort
by t
he
CIL
Rev
iew
tea
m, w
hic
h is
info
rmed
by
the
fin
din
gs o
f th
e re
sear
ch r
epor
t. T
his
look
ed a
t (a
mon
gst
oth
ers)
th
e re
lati
onsh
ip b
etw
een
CIL
an
d S
ecti
on 1
06,
exe
mp
tion
s an
d r
elie
fs, a
dm
inis
trat
ive
arra
nge
men
ts r
egar
din
g C
IL, a
ny
imp
act
on v
iabi
lity
an
d t
he
geog
rap
hy
of C
IL.
Th
e re
por
ts’ f
ind
ings
wer
e p
ubl
ish
ed in
Feb
ruar
y 20
17, a
nd
incl
ud
e so
me
rele
van
t fi
nd
ings
an
d le
sson
s w
hic
h
are
of u
se t
o th
e G
over
nm
ent
of J
erse
y. W
e n
ote
the
JIL
Pro
pos
al a
ckn
owle
dge
s b0
th o
f th
ese
rep
orts
an
d
clai
ms
that
Jer
sey
can
‘lea
rn’ f
rom
th
e le
sson
s of
CIL
in t
he
UK
. Un
fort
un
atel
y, it
is w
hol
ly u
ncl
ear
exac
tly
wh
at t
his
mea
ns,
or
how
it h
as b
een
ref
lect
ed in
th
e co
nce
pt o
r d
esig
n o
f JIL
. Am
ongs
t ot
her
th
ings
, th
e C
IL
Rev
iew
Tea
m r
epor
t se
ts o
ut
that
:
T
he
CIL
Rev
iew
Gro
up
doe
s n
ot b
elie
ve C
IL is
rai
sin
g as
mu
ch m
oney
as
envi
sage
d b
y G
over
nm
ent
wh
en
it w
as in
trod
uce
d;
It
is e
stim
ated
th
at C
IL is
yie
ldin
g be
twee
n 5
% a
nd
20
% o
f th
e co
st o
f new
infr
astr
uct
ure
, lea
vin
g si
gnif
ican
t fu
nd
ing
gap
s. I
t is
rec
ogn
ised
th
at, a
lth
ough
idea
lly,
th
e le
vel o
f CIL
wou
ld b
e se
t by
th
e co
st
of in
fras
tru
ctu
re w
hic
h is
nee
ded
, in
rea
lity
th
is e
nd
s u
p b
ein
g ba
sed
on
via
bili
ty a
nd
wh
at d
evel
opm
ent
can
aff
ord
to
pay
;
T
he
stra
tegi
c n
atu
re o
f CIL
mea
ns
that
in o
rder
to
ensu
re a
ll s
chem
es a
re v
iabl
e, s
ome
hig
her
val
ue
dev
elop
men
ts a
re p
ayin
g le
ss t
han
un
der
th
e p
revi
ous
syst
em. T
his
is r
ecog
nis
ed a
s on
e be
nef
it o
f th
e Se
ctio
n 1
06
syst
em (
equ
ival
ent
to P
OA
in J
erse
y);
In
man
y ca
ses
loca
l au
thor
ity
hav
e ad
opte
d n
il o
r ve
ry lo
w C
IL r
ates
for
com
mer
cial
use
s as
a w
ay o
f en
cou
ragi
ng
econ
omic
gro
wth
;
O
vera
ll, “
CIL
ha
s n
ot p
rovi
ded
the
un
iver
sal a
nd
the
refo
re ‘f
air
for
all’
ap
pro
ach
to
dev
elop
er
con
trib
uti
ons
tha
t w
as
orig
ina
lly
envi
sag
ed”
(Rep
ort
by t
he
CIL
Rev
iew
Tea
m, p
ara
4.1.
3).
Pg 8/10
14726914v3
In a
pp
lyin
g a
‘flat
rat
e’ le
vy a
pp
roac
h in
Jer
sey
- an
are
a th
at is
bot
h d
isti
nct
an
d m
odes
t in
sca
le -
th
ere
is
sign
ific
ant
risk
th
at a
‘mis
-cal
ibra
ted
’ ap
pro
ach
(as
has
occ
urr
ed in
loca
l au
thor
itie
s ac
ross
En
glan
d a
nd
W
ales
) w
ill h
ave
a si
gnif
ican
t d
elet
erio
us
imp
act
on t
he
flow
of d
evel
opm
ent.
In
tu
rn t
his
wou
ld s
erio
usl
y u
nd
erm
ine
imp
lem
enta
tion
of t
he
Isla
nd
Pla
n.
Je
CC
Re
com
me
nd
ati
on
s
Bas
ed o
n o
ur
revi
ew o
f th
e V
iabi
lity
Stu
dy,
on
beh
alf
of t
he
JeC
C, w
e p
rop
ose
the
foll
owin
g re
com
men
dat
ion
s fo
r th
e St
ates
of J
erse
y:
1 T
he
evid
ence
in t
he
Via
bili
ty S
tud
y sh
ows
sign
ific
ant
vari
atio
ns
in t
he
cost
of r
esid
enti
al la
nd
, an
d t
her
e is
litt
le a
vail
able
evi
den
ce o
n t
he
cost
of o
ther
typ
es o
f lan
d d
ue
to t
he
lim
ited
nu
mbe
r of
tra
nsa
ctio
ns
that
tak
e p
lace
. Giv
en t
he
dif
ficu
lty
in d
eter
min
ing
a si
ngl
e ch
arge
acr
oss
all d
evel
opm
ent
wh
ich
wou
ld
not
un
der
min
e th
e vi
abil
ity
of a
sig
nif
ican
t n
um
ber
of s
ites
, th
e St
ates
of J
erse
y sh
ou
ld n
ot
see
k t
o
imp
lem
en
t a
JIL
. It
sho
uld
in
ste
ad
co
nti
nu
e w
ith
th
e e
xis
tin
g P
OA
sys
tem
.
In t
he
even
t th
at t
he
Stat
es o
f Jer
sey
dec
ides
non
eth
eles
s to
con
tin
ue
wit
h p
rep
arat
ion
of a
JIL
ch
arge
, we
hav
e id
enti
fied
a n
um
ber
of s
ign
ific
ant
flaw
s w
ith
in t
he
Via
bili
ty S
tud
y w
hic
h s
hou
ld b
e co
rrec
ted
. Th
ese
are
esse
nti
al in
ord
er fo
r th
e St
ates
to
dem
onst
rate
s th
at a
ny
pro
pos
ed J
IL c
har
ge is
un
der
pin
ned
by
suit
able
an
d
robu
st e
vid
ence
(w
hic
h, a
t p
rese
nt,
we
beli
eve
it is
not
) T
he
flaw
s sh
ould
be
rem
edie
d b
y th
e fo
llow
ing:
2 T
est
brow
nfi
eld
sit
es b
ased
on
a r
ange
of e
xist
ing
use
s, in
clu
din
g of
fice
, ret
ail a
nd
hot
el u
ses,
wh
ich
are
m
ore
refl
ecti
ve o
f th
e si
te t
ypol
ogie
s li
kely
to
com
e fo
rwar
d in
th
e P
lan
per
iod
;
3 Se
nsi
tivi
ty t
est
thes
e va
lues
to
allo
w fo
r h
igh
er v
iabi
lity
th
resh
old
s an
d a
mor
e d
iver
se r
ange
of p
oten
tial
va
lues
, ref
lect
ing
the
grea
ter
ince
nti
ve o
ften
nee
ded
to
mak
e a
sale
an
d t
he
taxe
s w
hic
h a
pp
ly t
o p
rofi
ts,
as w
ell a
s be
tter
ref
lect
ing
the
div
erse
ran
ge o
f ou
tcom
es e
xper
ien
ced
in p
revi
ous
tran
sact
ion
s;
4 C
onsu
lt w
ith
sta
keh
old
ers
and
loca
l qu
anti
ty s
urv
eyor
firm
s to
rea
ch a
n a
gree
d c
onse
nsu
s ov
er b
uil
d
cost
s on
th
e Is
lan
d, i
ncl
ud
ing
sen
siti
vity
tes
tin
g of
th
is; a
nd
5 P
rovi
de
sign
ific
antl
y gr
eate
r cl
arit
y ov
er t
he
rela
tion
ship
of J
IL w
ith
PO
As
and
th
e in
fras
tru
ctu
re t
o be
fu
nd
ed b
y ea
ch t
o av
oid
pot
enti
al fo
r ac
tual
or
per
ceiv
ed ‘d
oubl
e d
ipp
ing’
.
On
ce t
he
abov
e h
ave
been
cor
rect
ed a
nd
agr
eed
up
on b
y al
l par
ties
, we
con
sid
er t
hat
th
ese
wil
l dem
onst
rate
it
is n
ot p
ossi
ble
to im
ple
men
t a
JIL
wit
hou
t u
nd
erm
inin
g th
e Is
lan
d P
lan
. In
th
e ev
ent
that
th
is w
ork
sugg
ests
impl
emen
tati
on o
f a J
IL m
ay s
till
be
pos
sibl
e, it
is in
ou
r vi
ew li
kely
to
be a
t a
sign
ific
antl
y lo
wer
ra
te t
han
th
e le
vel c
urr
entl
y p
rop
osed
, an
d m
ay d
emon
stra
te t
hat
in c
erta
in a
reas
(e.
g. w
ith
in b
uil
t-u
p a
reas
) or
sp
ecif
ic t
ypes
of s
ite
or d
evel
opm
ent,
a n
il J
IL r
ate
shou
ld b
e im
pos
ed.
Co
ncl
usi
on
We
tru
st t
hat
th
e ab
ove
repr
esen
tati
ons
and
th
e en
clos
ed R
evie
w o
f th
e V
iabi
lity
Stu
dy
are
of a
ssis
tan
ce t
o th
e St
ates
of J
erse
y in
un
der
stan
din
g th
e co
nce
rns
of t
he
JeC
C o
ver
the
curr
ent
JIL
pro
pos
als,
an
d p
rovi
de
the
basi
s fo
r a
sign
ific
ant
reco
nsi
der
atio
n o
f th
e p
rop
osal
s. N
eith
er t
he
JeC
C n
or t
he
Stat
es o
f Jer
sey
wil
l w
ish
to
see
the
Isla
nd
Pla
n’s
obj
ecti
ves
and
sp
atia
l str
ateg
y fo
r d
evel
opm
ent
un
der
min
ed b
y a
mis
-cal
ibra
ted
le
vy-b
ased
app
roac
h a
nd
ou
r re
com
men
dat
ion
s ab
ove
are
des
ign
ed t
o as
sist
th
e St
ates
of J
erse
y in
en
suri
ng
this
doe
s n
ot o
ccu
r.
Pg 9/10
14726914v3
If y
ou h
ave
any
quer
ies
on t
hes
e re
pre
sen
tati
ons
or r
equ
ire
furt
her
info
rmat
ion
, ple
ase
do
not
hes
itat
e to
co
nta
ct m
e.
You
rs s
ince
rely
Ma
tth
ew
Sp
ry
Sen
ior
Dir
ecto
r C
opy
Jers
ey C
onst
ruct
ion
Cou
nci
l
Ap
pe
nd
ix 1
: Lic
hfi
eld
s re
view
of J
erse
y V
iabi
lity
Stu
dy
Pg 10/10
14726914v3
Ap
pe
nd
ix 1
: L
ich
fie
lds
revi
ew
of
Je
rse
y V
iab
ilit
y S
tud
y
Je
rs
ey
In
fra
str
uc
tur
e L
ev
y
Pr
op
os
al
Re
vie
w o
f V
iab
ilit
y
As
se
ss
me
nt
Je
rse
y I
nfr
as
tru
ctu
re
Le
vy
Co
ns
ult
ati
on
Jer
sey
Co
nst
ruct
ion
Co
un
cil
Sep
tem
ber
20
17
© 2
01
7 N
ath
anie
l Lic
hfi
eld
& P
artn
ers
Ltd
, tra
din
g as
Lic
hfi
eld
s. A
ll R
igh
ts R
eser
ved
. Reg
iste
red
in
Engl
and
, no
. 277
81
16.
14
Reg
ent’
s W
har
f, A
ll Sa
ints
Str
eet,
Lo
nd
on
N1
9R
L Fo
rmat
ted
fo
r d
ou
ble
sid
ed p
rin
tin
g.
Pla
ns
bas
ed u
po
n O
rdn
ance
Su
rvey
map
pin
g w
ith
th
e p
erm
issi
on
of
Her
Maj
est
y’s
Stat
ion
ery
Off
ice.
©
Cro
wn
Co
pyr
igh
t re
serv
ed. L
icen
ce n
um
ber
AL5
06
84A
1
46
82
128
v1
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Co
nte
nts
1.0
In
tro
du
cti
on
1
Ba
ckg
rou
nd
1
2.0
P
oli
cy
Co
nte
xt
an
d G
uid
an
ce
– E
ng
lan
d
2
Na
tio
na
l P
lan
nin
g P
oli
cy F
ram
ewo
rk
2
Pla
nn
ing
Pra
ctic
e G
uid
an
ce
2
Oth
er G
uid
an
ce
4
3.0
R
ev
iew
of
Je
rse
y V
iab
ilit
y S
tud
y
5
La
nd
Pri
ces
5
Bu
ild
co
sts
13
Via
bil
ity
Ass
essm
ents
14
Co
mp
ari
son
wit
h E
ng
lish
CIL
Ra
tes
19
4.0
C
on
clu
sio
ns
2
0
Rec
om
men
da
tio
ns
20
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Pg
1
1.0
In
tro
du
cti
on
1.1
Lic
hfi
eld
s h
as
be
en a
sked
by
th
e J
erse
y C
on
stru
ctio
n C
ou
nci
l (“
Je
CC
”) a
nd
oth
er
sta
keh
old
ers
to
ma
ke
rep
rese
nta
tio
ns
on
th
eir
beh
alf
to
th
e S
tate
s o
f J
ers
ey c
on
sult
ati
on
on
th
e p
rop
ose
d J
erse
y
Infr
ast
ruct
ure
Le
vy
(“J
IL”)
. T
his
re
po
rt p
rov
ides
a r
evie
w o
f th
e J
erse
y V
iab
ilit
y A
sses
smen
t fo
r
Rev
iew
of
De
vel
op
er C
on
trib
uti
on
s (“
the
Via
bil
ity
Stu
dy
” “t
he
Stu
dy
”),
pu
bli
shed
in
Ma
y 2
017
an
d p
rep
are
d b
y c
on
sult
an
ts A
rup
an
d H
DH
.
1.2
T
he
Stu
dy
co
ncl
ud
es t
ha
t a
JIL
ra
te o
f b
etw
een
£5
0/s
qm
an
d £
150
/sq
m w
ou
ld b
e su
pp
ort
ed o
n
the
Isla
nd
. T
he
Sta
tes
of
Je
rsey
pro
po
ses
a c
ha
rge
of
£8
5/s
qm
on
res
ide
nti
al
dev
elo
pm
en
t
(res
ult
ing
in
a n
et i
ncr
ease
of
at
lea
st 7
5 s
qm
or
an
y n
ew
dw
elli
ng
) a
nd
£8
5/s
qm
on
off
ice
an
d
reta
il s
pa
ce.
Ba
ck
gr
ou
nd
1.3
T
he
con
cep
t o
f a
n i
nfr
ast
ruct
ure
lev
y i
s a
n e
sta
bli
shed
on
e in
a U
K c
on
tex
t. W
ith
in E
ng
lan
d a
nd
Wa
les,
le
gis
lati
on
ca
me
into
fo
rce
in
20
10 t
o a
llo
w l
oca
l p
lan
nin
g a
uth
ori
ties
(“L
PA
s”)
to
imp
lem
en
t a
co
mm
un
ity
in
fra
stru
ctu
re l
evy
(“C
IL”)
. T
his
wa
s a
fla
t ra
te c
on
trib
uti
on
ma
de
acr
oss
dev
elo
pm
ents
(a
lth
ou
gh
LP
As
can
va
ry r
ate
s a
cro
ss t
hei
r a
rea
, b
y t
yp
e o
f d
ev
elo
pm
ent
or
sca
le o
f d
evel
op
men
t) t
o c
on
trib
ute
to
lo
cal
an
d w
ider
in
fra
stru
ctu
re.
1.4
A
s a
t 2
017
, co
ver
ag
e o
f C
IL c
ha
rgin
g s
ched
ule
s is
pa
tch
y a
cro
ss E
ng
lan
d a
nd
Wa
les.
So
me
LP
As
ha
ve
sim
ply
no
t o
pte
d t
o i
mp
lem
en
t a
CIL
ch
arg
ing
sch
edu
le (
for
exa
mp
le,
du
e to
fa
vo
uri
ng
Sec
tio
n 1
06
ag
reem
en
ts),
so
me
ha
ve
fou
nd
CIL
to
be
un
via
ble
so
are
no
t a
ble
to
im
ple
men
t C
IL,
an
d o
ther
s h
av
e u
sed
CIL
in
co
mb
ina
tio
n w
ith
Sec
tio
n 1
06
(th
e E
ng
lan
d a
nd
Wa
les
equ
iva
len
t o
f
Jer
sey
’s P
lan
nin
g O
bli
ga
tio
n A
gre
em
ents
) to
va
ryin
g d
egre
es.
Th
e su
cces
s o
f C
IL h
as
bee
n
con
sid
ered
by
an
in
de
pen
den
t re
po
rt c
om
mis
sio
ned
by
Go
ver
nm
ent,
pu
bli
shed
in
20
17,
wh
ich
we
dis
cuss
in
ou
r m
ain
re
pre
sen
tati
on
.
1.5
Th
e S
tate
s o
f J
erse
y i
s cu
rren
tly
see
kin
g t
o i
mp
lem
ent
a b
roa
dly
sim
ila
r le
vy
– a
Jer
sey
Infr
ast
ruct
ure
Le
vy
(“J
IL”)
on
res
ide
nti
al,
off
ice
an
d c
om
mer
cia
l d
evel
op
me
nts
. It
pro
po
ses
to
giv
e th
e P
ari
shes
10
% o
f th
ese
lev
ies
an
d p
ote
nti
all
y m
ore
wh
ere
a V
illa
ge
Pla
n i
s in
pla
ce.
1.6
T
he
Stu
dy
un
der
pin
s th
e p
rop
ose
d J
IL r
ate
. H
ow
ever
, L
ich
fiel
ds
an
d t
he
JeC
C h
av
e a
nu
mb
er o
f
crit
icis
ms
of
the
Stu
dy
’s a
ssu
mp
tio
ns
an
d a
pp
roa
ch,
as
wel
l a
s th
e p
rin
cip
le o
f th
e in
tro
du
ctio
n
of
a J
IL a
lto
get
her
in
th
e u
niq
ue
con
tex
t o
f J
erse
y.
Th
e cr
itic
ism
s o
f th
e S
tud
y a
re e
xp
lore
d i
n
this
re
po
rt,
wh
ich
sh
ou
ld b
e re
ad
alo
ng
sid
e o
ur
ma
in l
ette
r o
f re
pre
sen
tati
on
s.
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 2
2.0
P
oli
cy
Co
nte
xt
an
d G
uid
an
ce
– E
ng
lan
d
2.1
W
hil
st t
he
pla
nn
ing
sy
stem
, d
evel
op
me
nt
ind
ust
ry a
nd
ho
usi
ng
ma
rket
are
sel
f-e
vid
entl
y n
ot
the
sam
e b
etw
een
En
gla
nd
an
d J
erse
y,
ther
e a
re s
imil
ari
tie
s in
ter
ms
of
the
pri
nci
ple
s u
nd
erp
inn
ing
bo
th C
IL (
in E
ng
lan
d)
an
d t
he
pro
po
sed
JIL
. In
pra
ctic
al
term
s, t
he
sam
e ch
all
eng
es e
xis
t in
term
s o
f d
evis
ing
a l
ev
y-b
ase
d a
pp
roa
ch t
ha
t is
eff
ecti
ve
in d
eliv
erin
g i
ts o
bje
ctiv
es o
f tr
yin
g t
o
fun
d i
nfr
ast
ruct
ure
wh
ilst
at
the
sam
e ti
me
no
t st
ym
iein
g d
evel
op
men
t a
cro
ss t
he
are
a.
It i
s in
this
co
nte
xt
tha
t th
e p
rin
cip
les
an
d g
uid
an
ce s
et o
ut
wit
hin
En
gla
nd
’s n
ati
on
al
po
licy
pro
vid
es
use
ful
con
tex
t fo
r co
nsi
der
ing
ho
w a
JIL
mig
ht
be
fra
med
an
d t
he
ba
sis
for
rev
iew
ing
th
e
via
bil
ity
ev
ide
nce
un
der
pin
nin
g t
he
JIL
as
pro
po
sed
. C
lea
rly
, th
is a
na
lysi
s is
no
t p
ut
forw
ard
as
bei
ng
th
e a
pp
lica
ble
po
licy
fra
mew
ork
fo
r J
erse
y a
s th
at
is a
ma
tter
fo
r th
e S
tate
s o
f J
erse
y i
tsel
f.
Na
tio
na
l P
lan
nin
g P
oli
cy
Fr
am
ew
or
k
2.2
T
he
Na
tio
na
l P
lan
nin
g P
oli
cy F
ram
ewo
rk (
NP
PF
) is
th
e G
ov
ern
me
nt’
s a
pp
roa
ch t
o o
per
ati
on
of
the
pla
nn
ing
sy
stem
in
En
gla
nd
, u
nd
erp
inn
ed b
y a
fo
cus
on
‘su
sta
ina
ble
dev
elo
pm
ent’
. In
ensu
rin
g s
ust
ain
ab
le d
ev
elo
pm
en
t, t
he
NP
PF
ref
ere
nce
s th
e n
eed
to
en
sure
de
vel
op
me
nt
is
via
ble
(p
ara
17
3),
sta
tin
g:
“Pu
rsu
ing
su
sta
ina
ble
dev
elo
pm
ent
req
uir
es c
are
ful
att
enti
on
to
via
bil
ity
an
d c
ost
s in
pla
n-
ma
kin
g a
nd
dec
isio
n-t
ak
ing
. P
lan
s sh
ou
ld b
e d
eliv
era
ble
. T
her
efo
re,
the
site
s a
nd
th
e sc
ale
of
dev
elo
pm
ent
iden
tifi
ed i
n t
he
pla
n s
ho
uld
no
t b
e su
bje
ct t
o s
uch
a s
cale
of
ob
lig
ati
on
s a
nd
po
licy
bu
rden
s th
at
thei
r a
bil
ity
to
be
dev
elo
ped
via
bly
is
thre
ate
ned
. T
o e
nsu
re v
iab
ilit
y,
the
cost
s o
f a
ny
req
uir
emen
ts l
ikel
y t
o b
e a
pp
lied
to
dev
elo
pm
ent,
su
ch a
s re
qu
irem
ents
fo
r
aff
ord
ab
le h
ou
sin
g,
sta
nd
ard
s, i
nfr
ast
ruct
ure
co
ntr
ibu
tio
ns
or
oth
er r
equ
irem
ents
sh
ou
ld,
wh
en t
ak
ing
acc
ou
nt
of
the
no
rma
l co
st o
f d
evel
op
men
t a
nd
mit
iga
tio
n,
pro
vid
e co
mp
etit
ive
retu
rns
to a
wil
lin
g l
an
d o
wn
er a
nd
wil
lin
g d
evel
op
er t
o e
na
ble
th
e d
evel
op
men
t to
be
del
iver
ab
le.”
(o
ur
emp
ha
sis)
2.3
In
oth
er w
ord
s, t
his
est
ab
lish
es t
he
key
pri
nci
ple
th
at
an
y i
nfr
ast
ruct
ure
le
vy
sh
ou
ld n
ot
be
set
at
such
a l
evel
or
in s
uch
a w
ay
as
to f
un
da
men
tall
y u
nd
erm
ine
via
bil
ity
an
d s
teri
lise
gro
wth
/de
vel
op
men
t a
cro
ss a
n a
rea
.
Pla
nn
ing
Pr
ac
tic
e G
uid
an
ce
2.4
T
he
pri
nci
ple
s se
t o
ut
in t
he
NP
PF
are
su
pp
lem
ente
d b
y g
uid
an
ce o
n v
iab
ilit
y a
nd
CIL
wit
hin
En
gla
nd
’s P
lan
nin
g P
ract
ice
Gu
ida
nce
(P
PG
), w
hic
h r
eit
era
tes
the
nee
d f
or
pla
nn
ing
au
tho
riti
es
to s
et t
he
sca
le o
f o
bli
ga
tio
ns
such
th
at
the
Lo
cal
Pla
n i
s n
ot
un
der
min
ed.
Ag
ain
st,
the
bel
ow
is
no
t se
t o
ut
bec
au
se i
t is
th
e r
elev
an
t g
uid
an
ce f
or
Jer
sey
, b
ut
bec
au
se i
t se
ts o
ut
som
e u
sefu
l
pri
nci
ple
s to
wh
ich
th
e d
esig
n o
f a
JIL
mig
ht
use
full
y s
ub
scri
be.
Th
e P
PG
cla
rifi
es,
am
on
gst
oth
er t
hin
gs,
th
at:
“Ch
arg
ing
au
tho
riti
es s
ho
uld
set
a r
ate
wh
ich
do
es n
ot
thre
ate
n t
he
ab
ilit
y t
o d
evel
op
via
bly
the
site
s a
nd
sca
le o
f d
evel
op
men
t id
enti
fied
in
th
e re
lev
an
t P
lan
” (
ID 2
5-0
08
)
Th
e le
vy
is
exp
ecte
d t
o h
av
e a
po
siti
ve
eco
no
mic
eff
ect
on
dev
elo
pm
ent
acr
oss
a l
oca
l p
lan
are
a.
Wh
en d
ecid
ing
th
e le
vy
ra
tes,
an
ap
pro
pri
ate
ba
lan
ce m
ust
be
stru
ck b
etw
een
ad
dit
ion
al
inv
estm
ent
to s
up
po
rt d
evel
op
men
t a
nd
th
e p
ote
nti
al
effe
ct o
n t
he
via
bil
ity
of
dev
elo
pm
ents
….
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Pg
3
Th
is b
ala
nce
is
at
the
cen
tre
of
the
cha
rge
-set
tin
g p
roce
ss.
In m
eeti
ng
th
e re
gu
lato
ry
req
uir
emen
ts (
see
reg
ula
tio
n 1
4(1
), a
s a
men
ded
by
th
e 2
014
Reg
ula
tio
ns)
, ch
arg
ing
au
tho
riti
es
sho
uld
be
ab
le t
o s
ho
w a
nd
ex
pla
in h
ow
th
eir
pro
po
sed
lev
y r
ate
(o
r ra
tes)
wil
l co
ntr
ibu
te
tow
ard
s th
e im
ple
men
tati
on
of
thei
r re
lev
an
t p
lan
an
d s
up
po
rt d
evel
op
men
t a
cro
ss t
hei
r
are
a…
.(ID
25
-00
9)
(ou
r em
ph
asi
s)
2.5
W
hen
set
tin
g o
ut
ho
w d
ev
elo
pm
ent
sho
uld
be
va
lued
fo
r th
e p
urp
ose
s o
f C
IL,
the
PP
G s
tate
s;
“A c
ha
rgin
g a
uth
ori
ty s
ho
uld
use
an
are
a-b
ase
d a
pp
roa
ch,
inv
olv
ing
a b
roa
d t
est
of
via
bil
ity
acr
oss
th
eir
are
a,
as
the
evid
ence
ba
se t
o u
nd
erp
in t
hei
r ch
arg
e. T
he
au
tho
rity
wil
l n
eed
to
be
ab
le t
o s
ho
w w
hy
th
ey c
on
sid
er t
ha
t th
e p
rop
ose
d l
evy
ra
te o
r ra
tes
set
an
ap
pro
pri
ate
ba
lan
ce
bet
wee
n t
he
nee
d t
o f
un
d i
nfr
ast
ruct
ure
an
d t
he
po
ten
tia
l im
pli
cati
on
s fo
r th
e ec
on
om
ic
via
bil
ity
of
dev
elo
pm
ent
acr
oss
th
eir
are
a.
Th
ere
are
a n
um
ber
of
va
lua
tio
n m
od
els
an
d m
eth
od
olo
gie
s a
va
ila
ble
to
ch
arg
ing
au
tho
riti
es
to h
elp
th
em i
n p
rep
ari
ng
th
is e
vid
ence
. T
her
e is
no
req
uir
emen
t to
use
on
e o
f th
ese
mo
del
s, b
ut
cha
rgin
g a
uth
ori
ties
ma
y f
ind
it
hel
pfu
l in
def
end
ing
th
eir
lev
y r
ate
s if
th
ey d
o.
A c
ha
rgin
g a
uth
ori
ty m
ust
use
‘ap
pro
pri
ate
av
ail
ab
le e
vid
ence
’ (a
s d
efin
ed i
n t
he
sect
ion
211
(7A
) o
f th
e P
lan
nin
g A
ct 2
00
8)
to i
nfo
rm t
hei
r d
raft
ch
arg
ing
sch
edu
le.
Th
e g
ov
ern
men
t
reco
gn
ises
th
at
the
av
ail
ab
le d
ata
is
un
lik
ely
to
be
full
y c
om
pre
hen
siv
e. C
ha
rgin
g a
uth
ori
ties
nee
d t
o d
emo
nst
rate
th
at
thei
r p
rop
ose
d l
evy
ra
te o
r ra
tes
are
in
form
ed b
y ‘a
pp
rop
ria
te
av
ail
ab
le’ e
vid
ence
an
d c
on
sist
ent
wit
h t
ha
t ev
iden
ce a
cro
ss t
hei
r a
rea
as
a w
ho
le.
A c
ha
rgin
g a
uth
ori
ty s
ho
uld
dra
w o
n e
xis
tin
g d
ata
wh
ere
ver
it
is a
va
ila
ble
. T
hey
ma
y
con
sid
er a
ra
ng
e o
f d
ata
, in
clu
din
g v
alu
es o
f la
nd
in
bo
th e
xis
tin
g a
nd
pla
nn
ed u
ses,
an
d
pro
per
ty p
rice
s –
fo
r ex
am
ple
, h
ou
se p
rice
in
dic
es a
nd
ra
tea
ble
va
lues
fo
r co
mm
erci
al
pro
per
ty.
Th
ey m
ay
als
o w
an
t to
bu
ild
on
wo
rk u
nd
ert
ak
en t
o i
nfo
rm t
hei
r a
sses
smen
ts o
f
lan
d a
va
ila
bil
ity
.
In a
dd
itio
n,
a c
ha
rgin
g a
uth
ori
ty s
ho
uld
dir
ectl
y s
am
ple
an
ap
pro
pri
ate
ra
ng
e o
f ty
pes
of
site
s
acr
oss
its
are
a,
in o
rder
to
su
pp
lem
ent
exis
tin
g d
ata
. T
his
wil
l re
qu
ire
sup
po
rt f
rom
lo
cal
dev
elo
per
s. T
he
exer
cise
sh
ou
ld f
ocu
s o
n s
tra
teg
ic s
ites
on
wh
ich
th
e re
lev
an
t P
lan
(th
e L
oca
l
Pla
n i
n E
ng
lan
d,
Lo
cal
Dev
elo
pm
ent
Pla
n i
n W
ale
s, a
nd
th
e L
on
do
n P
lan
in
Lo
nd
on
) re
lies
,
an
d t
ho
se s
ites
wh
ere
the
imp
act
of
the
lev
y o
n e
con
om
ic v
iab
ilit
y i
s li
kel
y t
o b
e m
ost
sig
nif
ica
nt
(su
ch a
s b
row
nfi
eld
sit
es).
A c
ha
rgin
g a
uth
ori
ty’s
pro
po
sed
ra
te o
r ra
tes
sho
uld
be
rea
son
ab
le,
giv
en t
he
av
ail
ab
le
evid
ence
, b
ut
ther
e is
no
req
uir
emen
t fo
r a
pro
po
sed
ra
te t
o e
xa
ctly
mir
ror
the
evid
ence
. F
or
exa
mp
le,
this
mig
ht
no
t b
e a
pp
rop
ria
te i
f th
e ev
iden
ce p
oin
ted
to
set
tin
g a
ch
arg
e ri
gh
t a
t th
e
ma
rgin
s o
f v
iab
ilit
y.
Th
ere
is r
oo
m f
or
som
e p
rag
ma
tism
. It
wo
uld
be
ap
pro
pri
ate
to
en
sure
tha
t a
‘bu
ffer
’ or
ma
rgin
is
incl
ud
ed,
so t
ha
t th
e le
vy
ra
te i
s a
ble
to
su
pp
ort
dev
elo
pm
ent
wh
en
eco
no
mic
cir
cum
sta
nce
s a
dju
st.
In a
ll c
ase
s, t
he
cha
rgin
g a
uth
ori
ty s
ho
uld
be
ab
le t
o e
xp
lain
its
ap
pro
ach
cle
arl
y.
(ID
25
-019
) (o
ur
emp
ha
sis)
2.6
W
hen
dis
cuss
ing
ho
w d
evel
op
men
t co
sts
sho
uld
be
refl
ecte
d w
he
n s
etti
ng
CIL
, th
e P
PG
cla
rifi
es
tha
t p
lan
nin
g a
uth
ori
ties
nee
d t
o h
av
e “a
rea
list
ic u
nd
erst
an
din
g o
f co
sts”
(ID
25
-02
0)
an
d t
ha
t
thes
e sh
ou
ld i
ncl
ud
e co
sts
fro
m e
xis
tin
g r
egu
lato
ry r
eq
uir
eme
nts
an
d a
ny
po
lici
es
on
pla
nn
ing
ob
lig
ati
on
s in
th
e r
elev
an
t P
lan
. T
he
PP
G g
oes
on
to
co
nfi
rm t
ha
t L
PA
s ca
n s
et d
iffe
ren
t C
IL
rate
s b
y a
rea
, ty
pe
of
de
vel
op
me
nt
or
size
of
dev
elo
pm
en
t (I
D 2
5-0
21)
. T
he
JIL
do
es
no
t p
rop
ose
dif
fere
nti
al
rate
s b
y a
rea
, a
lth
ou
gh
it
do
es p
rop
ose
dif
fere
nt
rate
s b
y c
erta
in t
yp
es o
f
dev
elo
pm
ent;
in
du
stri
al
an
d s
om
e fo
rms
of
com
me
rcia
l d
evel
op
men
t a
re p
rop
ose
d t
o h
av
e a
nil
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 4
JIL
ch
arg
e,
wh
ile
resi
de
nti
al,
off
ice
an
d r
eta
il d
evel
op
men
t is
pro
po
sed
to
ha
ve
a c
ha
rge
of
£8
5/s
qm
.
Oth
er
Gu
ida
nc
e
2.7
O
ther
fo
rms
of
gu
ida
nce
ex
ist
in t
he
form
of
the
Ha
rma
n G
uid
an
ce1 a
nd
th
e R
ICS
Gu
ida
nce
2 ;
ho
we
ver
th
ese
are
set
ou
t in
Ch
ap
ter
2 o
f th
e V
iab
ilit
y S
tud
y a
nd
th
rou
gh
ou
t a
nd
hen
ce a
re n
ot
rep
eate
d h
ere.
1 V
iab
ility
Tes
tin
g Lo
cal P
lan
s: A
dvi
ce f
or
pla
nn
ing
pra
ctit
ion
ers
- h
ttp
s://
ww
w.lo
cal.g
ov.
uk/
site
s/d
efau
lt/f
iles/
do
cum
ents
/via
bili
ty-
test
ing-
loca
l-p
-50
c.p
df
2 R
ICS
Pro
fess
ion
al G
uid
ance
, En
glan
d: F
inan
cial
Via
bili
ty in
Pla
nn
ing
htt
p:/
/ww
w.r
ics.
org
/Do
cum
ents
/Fin
anci
al%
20
viab
ility
%2
0in
%2
0p
lan
nin
g.p
df
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Pg
5
3.0
R
ev
iew
of
Je
rs
ey
Via
bil
ity
Stu
dy
3.1
T
he
Stu
dy
’s c
on
clu
sio
ns,
an
d t
he
con
clu
sio
ns
on
th
e le
vel
of
JIL
th
at
dev
elo
pm
en
t in
Jer
sey
cou
ld b
ear,
are
ult
ima
tely
dra
wn
fro
m a
nu
mb
er o
f v
iab
ilit
y a
pp
rais
als
fo
r d
iffe
ren
t ty
pes
of
dev
elo
pm
ent
wh
ich
ea
ch e
mb
ed a
ser
ies
of
ass
um
pti
on
s a
rou
nd
th
e v
alu
es a
nd
co
sts
of
dev
elo
pm
ent
on
th
e is
lan
d.
Th
e ro
bu
stn
ess
of
the
Stu
dy
’s c
on
clu
sio
ns
is t
he
refo
re d
irec
tly
rela
ted
to
th
e re
aso
na
ble
ne
ss o
f th
ose
in
div
idu
al
ass
um
pti
on
s. L
ich
fiel
ds
an
d t
he
JeC
C h
av
e
con
sid
era
ble
co
nce
rns
wit
h t
he
ass
um
pti
on
s a
nd
ap
pro
ach
es a
do
pte
d w
ith
in t
he
Stu
dy
an
d
thes
e a
re s
et o
ut
as
foll
ow
s.
La
nd
Pr
ice
s
Alt
er
na
tiv
e u
se
va
lue
s
3.2
D
evel
op
me
nts
on
bro
wn
fiel
d l
an
d h
av
e a
n a
ssu
med
alt
ern
ati
ve
lan
d u
se v
alu
e o
f in
du
stri
al
lan
d
(pa
ra 6
.8).
Th
e st
ud
y (
pa
ra 6
.28
) in
dic
ate
s th
at
this
va
lue
is £
1.9
m/h
a.
3.3
A
s a
pre
lim
ina
ry i
ssu
e,
the
Stu
dy
sta
tes
tha
t “w
e h
av
e n
o e
vid
ence
of
wa
reh
ou
se l
an
d
tra
nsa
ctio
ns
at
this
tim
e.”
(pa
ra 6
.27
) b
efo
re g
oin
g o
n t
o m
ak
e a
n a
ssu
mp
tio
n o
n t
he
va
lue
of
ind
ust
ria
l la
nd
. T
his
est
ima
te d
oes
no
t a
pp
ear
to b
e e
vid
ence
-ba
sed
an
d d
oes
no
t ci
te s
pec
ific
exa
mp
les
of
the
va
lue
of
ind
ust
ria
l la
nd
in
Jer
sey
. T
his
ref
lect
s th
e fa
ct t
ha
t th
ere
is l
ittl
e
ind
ust
ria
l la
nd
wit
hin
Jer
sey
; h
isto
rica
lly
th
e m
ain
in
du
stri
es h
av
e b
een
fa
rmin
g a
nd
ho
spit
ali
ty.
It i
s th
ere
fore
qu
esti
on
ab
le h
ow
th
is f
igu
re c
an
be
use
d a
s a
ben
chm
ark
wh
en
tes
tin
g v
iab
ilit
y.
Th
e S
tud
y i
tsel
f st
ate
s th
at
this
is
a “
rela
tiv
ely
lo
w”
va
lue
(pa
ra 1
0.1
3).
3.4
In
ad
dit
ion
, n
ot
all
bro
wn
fiel
d s
ites
wil
l h
av
e b
een
pre
vio
usl
y i
n i
nd
ust
ria
l u
se,
an
d t
hes
e m
ay
ha
ve
a m
uch
hig
her
va
lue
tha
n a
ssu
med
in
th
e S
tud
y (
wh
ich
, a
s n
ote
d,
do
es n
ot
ap
pea
r it
self
to
be
ba
sed
on
an
y e
vid
ence
). W
ith
in i
ts a
sses
smen
t o
f v
iab
ilit
y,
the
Stu
dy
ass
um
es (
wit
h t
he
exce
pti
on
of
sma
ll p
ad
do
ck s
ite
dev
elo
pm
en
ts,
on
e re
sid
enti
al
con
ver
sio
n s
chem
e a
nd
tw
o o
ffic
e
con
ver
sio
ns)
th
at
all
bro
wn
fiel
d s
ites
are
in
in
du
stri
al
use
an
d t
her
efo
re h
av
e in
du
stri
al
lan
d
va
lue
(of
£1.
9m
/ha
). T
he
Stu
dy
its
elf
acc
epts
th
is l
imit
ati
on
, b
ut
it i
s n
ot
then
ref
lect
ed w
ith
in
the
via
bil
ity
mo
del
lin
g,
mea
nin
g o
ne
sho
uld
be
ver
y c
au
tio
us
ind
eed
ab
ou
t b
asi
ng
co
ncl
usi
on
s
up
on
it:
“It
is i
mp
ort
an
t to
no
te t
ha
t m
uch
of
the
dev
elo
pm
ent
tha
t d
oes
co
me
forw
ard
in
St
Hel
ier
in
pa
rtic
ula
r is
on
pre
vio
usl
y d
evel
op
ed l
an
d t
ha
t h
as
a v
alu
e th
at
is g
rea
ter
tha
n a
n i
nd
ust
ria
l
va
lue.
” (p
ara
6.6
1)
3.5
B
row
nfi
eld
la
nd
lo
cate
d i
n b
uil
t-u
p a
rea
s -
wh
ich
is
wh
ere
the
Co
un
cil
inte
nd
s to
co
nce
ntr
ate
mo
st d
evel
op
men
t -
ma
y h
av
e d
iffe
ren
t a
lter
na
tiv
e u
se v
alu
es h
igh
er t
ha
n i
nd
ust
ria
l. T
hes
e
bro
wn
fiel
d s
ites
ma
y h
av
e b
een
in
a n
um
ber
of
pre
vio
us
use
s in
clu
din
g h
ote
ls o
r o
ffic
es,
an
d o
ne
mem
ber
of
the
JeC
C g
av
e e
xa
mp
les
of
bro
wn
fiel
d s
ites
wh
ich
wer
e cu
rre
ntl
y i
n u
se a
s ca
r
pa
rkin
g/r
eta
il,
an
d a
no
the
r in
use
as
a b
an
k.
We
no
te t
ha
t w
hil
e th
e S
tud
y h
as
mo
del
led
off
ice
con
ver
sio
n s
che
mes
, it
ha
s n
ot
mo
del
led
an
y b
row
nfi
eld
dev
elo
pm
ents
in
oth
er p
rev
iou
s u
ses
eith
er a
s co
nv
ersi
on
s o
r re
dev
elo
pm
ents
. T
hes
e si
tes
cou
ld h
av
e a
su
bst
an
tia
lly
hig
her
alt
ern
ati
ve
use
va
lue
to t
he
£1.
9m
/ha
ass
um
ed (
ag
ain
, n
oti
ng
th
at
this
fig
ure
is
no
t ev
iden
ce-
ba
sed
).
Alt
er
na
tiv
e u
se
- R
eta
il
3.6
B
y w
ay
of
illu
stra
tio
n,
the
Stu
dy
giv
es t
he
va
lue
of
seco
nd
ary
la
nd
va
lues
fo
r re
tail
sit
es o
f £
37
5-
£7
00
/sq
m (
pa
ra 6
.35
), w
hic
h i
s su
bst
an
tia
lly
hig
her
th
an
th
e £
32
0/s
qm
(p
ara
6.2
7)
for
ind
ust
ria
l la
nd
. T
he
va
lue
of
seco
nd
ary
sit
es p
er h
ecta
re t
her
efo
re r
an
ge
fro
m £
3.7
5m
/ha
to
£7
m/h
a (
alt
ho
ug
h t
his
ass
um
es 1
00
% c
ov
era
ge
wh
ich
ma
y b
e o
ver
-re
pre
sen
tati
ve
).
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 6
3.7
T
he
Stu
dy
’s e
xis
tin
g f
igu
res
(fo
r re
sid
ua
l v
alu
e v
s ex
isti
ng
va
lue
an
d v
iab
ilit
y t
hre
sho
ld)
for
the
bro
wn
fiel
d s
ites
, b
ase
d o
n a
n i
nd
ust
ria
l v
alu
e, a
re s
ho
wn
gra
ph
ica
lly
in
Fig
ure
3.1
bel
ow
. It
is
clea
r th
at
for
thes
e s
ites
, th
e re
sid
ua
l v
alu
e w
ou
ld a
pp
ea
r to
ex
ceed
ex
isti
ng
use
va
lue
(E
UV
) a
nd
via
bil
ity
th
resh
old
co
mfo
rta
bly
.
Figu
re 3
.1 R
esid
ual
Val
ue
of
Bro
wn
fie
ld S
ites
co
mp
ared
to
Alt
ern
ativ
e U
se V
alu
e (I
nd
ust
rial
) an
d V
iab
ility
Th
resh
old
Sou
rce:
Lic
hfi
eld
s b
ased
on
Tab
le 1
0.2
of
the
Via
bili
ty S
tud
y
3.8
H
ow
ever
, fo
r co
mp
ari
son
, th
e re
sid
ua
l v
alu
es o
f th
ese
site
s w
hen
co
mp
are
d w
ith
se
con
da
ry
reta
il v
alu
es a
re s
ho
wn
in
Fig
ure
3.2
. F
or
sim
pli
city
, th
e v
alu
es (
£m
/ha
) h
av
e b
een
ca
lcu
late
d
ass
um
ing
10
0%
co
ver
ag
e (w
hic
h m
ay
no
t b
e th
e ca
se f
or
all
sit
es,
an
d m
ay
be
slig
htl
y l
ow
er),
ho
we
ver
it
is e
vid
ent
tha
t th
ere
are
ver
y f
ew s
ites
wh
ich
co
mfo
rta
bly
ex
ceed
th
e u
pp
er e
nd
of
the
ran
ge
.
3.9
D
esp
ite
the
Stu
dy
acc
epti
ng
th
at
bro
wn
fiel
d l
an
d v
alu
es i
n t
he
bu
ilt-
up
are
as
are
lik
ely
to
be
hig
her
th
an
in
du
stri
al
va
lue
s, w
hic
h h
as
bee
n s
up
po
rte
d b
y i
nfo
rma
tio
n p
rov
ided
to
Lic
hfi
eld
s
by
me
mb
ers
of
the
Je
CC
an
d t
hei
r e
xp
eri
en
ces
in d
evel
op
ing
bro
wn
fiel
d s
ites
, th
is i
s
un
fort
un
ate
ly n
ot
refl
ecte
d i
n t
he
Stu
dy
’s a
sses
smen
t. T
he
sen
siti
vit
ies
un
der
tak
en
fo
r
alt
ern
ati
ve
via
bil
ity
th
resh
old
s (s
ee T
ab
le 1
0.3
of
the
Stu
dy
) a
re t
este
d u
p t
o a
th
resh
old
of
£6
.5m
/ha
(a
t w
hic
h s
ix o
f th
e to
tal
site
s b
eco
me
un
via
ble
), h
ow
eve
r th
is i
s st
ill
bel
ow
th
e u
pp
er
end
of
the
ran
ge
for
seco
nd
ary
ret
ail
sp
ace
. S
eco
nd
ary
ret
ail
sp
ace
is
a l
ikel
y f
utu
re c
on
trib
uto
r
to h
ou
sin
g d
evel
op
me
nt
in J
erse
y a
nd
th
e S
tud
y i
s fl
aw
ed b
y f
ail
ing
to
ad
equ
ate
ass
ess
thes
e
scen
ari
os.
Ind
ust
rial
Via
bili
ty T
hre
sho
ld
02468
10
12
14
16
18
20
Site
1Si
te 2
Site
3Si
te 4
Site
5Si
te 6
Site
7Si
te 8
Site
11
Site
12
Site
13
Site
14
Value £m/ha
Site
s te
ste
d a
s b
row
nfi
eld
in
in
du
stri
al u
se
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Pg
7
Figu
re 3
.2 R
esid
ual
Val
ue
of
Bro
wn
fie
ld S
ites
co
mp
ared
to
Alt
ern
ativ
e U
se V
alu
e (S
eco
nd
ary
Re
tail)
an
d V
iab
ility
Th
resh
old
Sou
rce:
Lic
hfi
eld
s b
ased
on
Tab
le 1
0.2
of
the
Via
bili
ty S
tud
y
3.1
0
By
wa
y o
f fu
rth
er i
llu
stra
tio
n,
Fig
ure
3.3
sh
ow
s th
e re
sid
ua
l v
alu
es c
om
pa
red
wit
h p
rim
ary
ret
ail
lan
d v
alu
es.
Ag
ain
, w
hil
e th
ese
cou
ld b
e sl
igh
tly
ov
er-e
stim
ate
s o
f la
nd
va
lue
, th
ey n
on
eth
eles
s
dem
on
stra
te t
ha
t m
an
y s
ite
s w
ou
ld b
e a
t th
e m
arg
ins
of
via
bil
ity
. D
ev
elo
pm
ent
of
pri
ma
ry r
eta
il
spa
ce m
ay
be
a r
eali
stic
so
urc
e o
f b
row
nfi
eld
la
nd
fo
r h
ou
sin
g;
the
Stu
dy
sta
tes
tha
t th
ere
is l
ittl
e
dem
an
d f
or
ad
dit
ion
al
reta
il u
nit
s, w
ith
ev
en t
he
pri
ma
ry a
rea
s se
ein
g s
om
e lo
ng
ter
m v
aca
ncy
acr
oss
sev
era
l u
nit
s (p
ara
6.3
2 o
nw
ard
s).
Re
tail
(lo
we
r)
Re
tail
(up
pe
r)
Via
bili
ty T
hre
sho
ld
Via
bili
ty T
hre
sho
ld
02468
10
12
14
16
18
20
Site
1Si
te 2
Site
3Si
te 4
Site
5Si
te 6
Site
7Si
te 8
Site
11
Site
12
Site
13
Site
14
Value £m/ha
Site
s te
ste
d a
s b
row
nfi
eld
in
in
du
stri
al u
se
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 8
Figu
re 3
.3 R
esid
ual
Val
ue
of
Bro
wn
fie
ld S
ites
co
mp
ared
to
Alt
ern
ativ
e U
se V
alu
e (P
rim
ary
Re
tail)
an
d V
iab
ility
Th
resh
old
Sou
rce:
Lic
hfi
eld
s b
ased
on
Tab
le 1
0.2
of
the
Via
bili
ty S
tud
y
Alt
er
na
tiv
e u
se
- H
ote
ls
3.1
1 In
ad
dit
ion
to
ret
ail
sit
es,
ther
e a
re a
lso
ex
am
ple
s o
f b
row
nfi
eld
sit
es w
hic
h a
re c
on
ver
sio
ns
fro
m
ho
tel
to r
esid
enti
al
use
s. T
he
Stu
dy
cit
es e
xa
mp
les
of
the
Met
rop
ole
Ho
tel
(so
ld f
or
£9
.5m
/ha
),
Sh
ak
esp
eare
Ho
tel
(£14
.6m
/ha
) a
nd
Old
Co
urt
Ho
use
Ho
tel
(£3
.9m
/ha
). W
ith
th
e e
xce
pti
on
of
the
Old
Co
urt
Ho
use
Ho
tel,
th
e sa
les
va
lues
of
thes
e si
tes
exce
ed a
lmo
st a
ll t
he
resi
du
al
va
lues
of
the
bro
wn
fiel
d s
ites
, a
s sh
ow
n i
n F
igu
re 3
.4.
It i
s p
oss
ible
th
at
the
va
lue
of
such
sit
es w
ill
incr
ease
in
th
e fu
ture
as
the
su
pp
ly o
f v
aca
nt
ho
tels
av
ail
ab
le f
or
resi
de
nti
al
con
ve
rsio
n
dim
inis
hes
.
3.1
2
Ag
ain
th
is r
ep
rese
nts
a r
eali
stic
fu
ture
sce
na
rio
fo
r h
ou
sin
g d
ev
elo
pm
ent
in J
ers
ey w
hic
h t
he
Stu
dy
ha
s fa
iled
to
ad
equ
ate
ly a
sses
s. I
t fu
rth
er d
emo
nst
rate
s th
e d
egre
e o
f u
nd
ere
stim
ati
on
of
alt
ern
ati
ve
lan
d v
alu
es o
f b
row
nfi
eld
sit
es l
ikel
y t
o c
om
e fo
rwa
rd f
or
dev
elo
pm
en
t, l
ead
ing
to
th
e
Stu
dy
sig
nif
ica
ntl
y o
ver
sta
tin
g t
he
via
bil
ity
of
such
sit
es.
Re
tail
(lo
we
r)
Re
tail
(up
pe
r)
Via
bili
ty T
hre
sho
ld
Via
bili
ty T
hre
sho
ld
02468
10
12
14
16
18
20
Site
1Si
te 2
Site
3Si
te 4
Site
5Si
te 6
Site
7Si
te 8
Site
11
Site
12
Site
13
Site
14
Value £m/ha
Site
s te
ste
d a
s b
row
nfi
eld
in
in
du
stri
al u
se
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Pg
9
Figu
re 3
.4 R
esid
ual
Val
ue
of
Bro
wn
fie
ld S
ites
co
mp
ared
to
Sal
es V
alu
es o
f H
ote
l Sit
es
Sou
rce:
Lic
hfi
eld
s b
ased
on
Via
bili
ty S
tud
y
Alt
er
na
tiv
e u
se
– O
ffic
es
3.1
3
Th
e S
tud
y a
sses
ses
the
va
lue
of
seco
nd
ary
off
ice
spa
ce f
or
con
ver
sio
n a
t £
2,3
89
/sq
m.
Th
e S
tud
y
ass
esse
s tw
o c
on
ver
sio
n s
chem
es o
f se
con
da
ry o
ffic
es,
into
six
an
d 2
5 f
lats
res
pec
tiv
ely
.
3.1
4
As
set
ou
t a
bo
ve
, th
e S
tud
y h
as
ass
esse
d t
he
ma
jori
ty o
f it
s b
row
nfi
eld
sit
es a
ga
inst
an
in
du
stri
al
lan
d v
alu
e o
f £
1.9
m/h
a,
wh
ich
eq
ua
tes
to a
va
lue
of
£3
20
/sq
m (
ass
um
ing
60
% c
ov
era
ge
on
a
site
). O
n a
per
sq
m c
om
pa
riso
n b
asi
s, t
he
va
lue
of
seco
nd
ary
off
ice
spa
ce i
s th
eref
ore
ov
er
sev
en
tim
es t
he
ind
ust
ria
l fi
gu
re u
sed
fo
r m
ost
bro
wn
fiel
d s
ite
ass
essm
ents
. T
he
ab
sen
ce o
f a
ny
fu
rth
er
test
ing
of
off
ice
site
s (e
ith
er a
s co
nv
ersi
on
s o
r co
mp
lete
red
evel
op
me
nts
) is
yet
an
oth
er
sig
nif
ica
nt
fla
w o
f th
e S
tud
y.
Th
e co
nce
ntr
ati
on
of
dev
elo
pm
ent
in b
uil
t-u
p a
rea
s m
ean
s
red
evel
op
me
nt
of
off
ice
spa
ce i
s li
kel
y t
o c
on
trib
ute
to
fu
ture
ho
usi
ng
su
pp
ly a
nd
it
is i
mp
era
tiv
e
thes
e ty
po
log
ies
are
pro
pe
rly
ass
esse
d f
or
via
bil
ity
.
Me
tro
po
le H
ote
l
Shak
esp
ear
e H
ote
l
Old
Co
urt
Ho
use
02468
10
12
14
16
18
20
Site
1Si
te 2
Site
3Si
te 4
Site
5Si
te 6
Site
7Si
te 8
Site
11
Site
12
Site
13
Site
14
Value £m/ha
Site
s te
ste
d a
s b
row
nfi
eld
in
in
du
stri
al u
se
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 10
Re
sid
en
tia
l la
nd
va
lue
s
3.1
5
Ta
ble
6.1
of
the
Stu
dy
sh
ow
s th
e sa
les
va
lue
s o
f d
evel
op
men
t si
tes
bet
wee
n 2
00
6 a
nd
20
16;
in
tota
l it
sh
ow
s ju
st 1
7 s
ites
ov
er a
10
yea
r p
erio
d,
an
av
era
ge
of
1-2
sit
es p
er y
ear.
As
a m
att
er o
f
pri
nci
ple
, th
is i
s a
n e
xce
pti
on
all
y s
ma
ll s
am
ple
siz
e u
po
n w
hic
h t
o d
eter
min
e a
ver
ag
e v
alu
es a
nd
sub
seq
uen
tly
in
fra
stru
ctu
re l
evy
ch
arg
es,
pa
rtic
ula
rly
wh
en t
he
va
lues
va
ry t
o t
he
deg
ree
th
at
is
seen
in
Jer
sey
. T
he
lo
wes
t v
alu
e se
en i
n t
he
sa
mp
le i
s £
1.5
m/h
a (
in L
es P
iece
s S
t M
art
in,
in
20
14)
bu
t th
is r
an
ges
up
to
£2
3m
/ha
at
Wa
ver
ley
Ho
use
. W
e n
ote
th
at
wit
hin
th
e t
ext
(pa
ra
6.2
0)
the
Via
bil
ity
Stu
dy
su
gg
ests
la
nd
va
lues
as
low
as
£7
16,4
18/h
a,
alt
ho
ug
h t
his
ca
nn
ot
be
seen
in
th
e co
rres
po
nd
ing
ta
ble
.
3.1
6
Th
e S
tud
y h
as
rem
ov
ed t
wo
‘ou
tlie
rs’ w
hic
h w
ere
sold
fo
r a
pri
ce o
f £
23
m/h
a.
Th
ese
are
;
Wa
ver
ley
Ho
use
, a
sit
e o
f 0
.05
ha
wh
ich
so
ld f
or
£1.
15m
in
20
14,
or
£2
3m
/ha
; a
nd
22
La
Co
lom
ber
ie,
St
Hel
ier,
a s
ite
of
0.0
7 h
a w
hic
h s
old
fo
r £
1.6
m i
n 2
014
, o
r £
22
.8m
/ha
.
3.1
7
Th
ese
site
s m
ay
ap
pea
r o
utl
iers
in
th
e v
iew
of
the
Stu
dy
’s a
uth
ors
, h
ow
ever
, g
iven
th
at
eve
n o
nce
they
are
rem
ov
ed v
alu
es s
till
ra
ng
e fr
om
£1m
-£14
m/h
a,
an
d t
ha
t th
ese
rep
rese
nt
two
of
the
17
site
s, t
hey
sh
ou
ld a
rgu
ab
ly n
ot
be
rem
ov
ed f
rom
th
e sa
mp
le.
Ind
eed
, 2
2 L
a C
olo
mb
erie
rep
rese
nts
a c
on
ver
sio
n s
chem
e in
St
Hel
ier
bu
ilt-
up
are
a;
this
is
pre
cise
ly t
he
typ
e o
f
dev
elo
pm
ent
wh
ich
is
enco
ura
ged
wit
hin
th
e Is
lan
d P
lan
, w
hic
h s
ever
ely
res
tric
ts d
evel
op
men
t
in t
he
cou
ntr
ysi
de.
3.1
8
Ha
vin
g r
emo
ved
th
e p
urp
ort
ed ‘o
utl
iers
’ th
e S
tud
y h
as
con
sid
ered
th
e a
ve
rag
e o
f th
ese
va
lues
(med
ian
an
d m
ean
) b
efo
re r
each
ing
a j
ud
gm
en
t v
alu
e o
f £
6m
/ha
wh
ich
it
tak
es f
orw
ard
in
th
e
Via
bil
ity
mo
del
lin
g.
Wh
ilst
ta
kin
g t
he
av
era
ge
lan
d v
alu
e m
ay
no
t b
e a
n u
nre
aso
na
ble
ap
pro
ach
,
this
is
on
ly l
ikel
y t
o b
e a
n a
pp
rop
ria
te r
ep
rese
nta
tio
n o
f a
ver
ag
e la
nd
va
lues
wh
ere
:
Th
e o
ver
all
sa
mp
le s
ize
is l
arg
e;
Th
ere
is a
cle
ar
clu
ster
ing
of
va
lues
aro
un
d t
he
av
era
ge
, w
hic
h i
s th
e v
alu
e th
at
cou
ld b
e
exp
ecte
d f
or
mo
st s
ites
; a
nd
Th
ere
are
few
in
sta
nce
s o
f se
ver
e v
alu
es a
t th
e e
xtr
em
es,
ab
ov
e o
r b
elo
w t
he
av
era
ge.
3.1
9
Th
e a
va
ila
ble
da
ta f
or
Je
rse
y i
s sh
ow
n i
n F
igu
re 3
.5 b
elo
w.
As
exp
ecte
d d
ue
to t
he
sma
ll n
um
ber
of
site
s, t
her
e is
a s
ign
ific
an
t ra
ng
e a
bo
ve
an
d b
elo
w t
he
av
era
ge.
Th
e lo
wes
t la
nd
va
lues
see
n a
re
on
e q
ua
rter
of
the
av
era
ge
(£
1.5
m/h
a),
wh
ile
th
e h
igh
est
va
lues
are
fo
ur
tim
es t
he
av
era
ge.
Ev
en
Su
mm
ar
y
Th
e S
tud
y h
as
no
t p
rov
ided
an
y e
vid
ence
fo
r th
e in
du
stri
al
va
lues
ass
um
ed i
n i
ts m
od
elli
ng
an
d i
t ev
en
ap
pea
rs t
o a
ccep
t th
ese
are
“lo
w”.
Th
ere
are
cle
arl
y o
ther
sit
e ty
po
log
ies
lik
ely
to
com
e fo
rwa
rd f
or
dev
elo
pm
ent
in J
erse
y w
he
re t
he
alt
ern
ati
ve
use
va
lue
is h
igh
er t
ha
n
ind
ust
ria
l, i
ncl
ud
ing
ret
ail
, o
ffic
e a
nd
ho
tel
use
s.
Th
e S
tud
y u
ltim
ate
ly f
ail
s t
o a
de
qu
ate
ly t
es
t th
e r
an
ge
of
de
ve
lop
me
nts
lik
ely
to
co
me
fo
rw
ar
d i
n J
er
se
y,
refl
ecti
ng
th
e fa
ct t
ha
t d
evel
op
me
nt
is m
ost
ly c
on
cen
tra
ted
wit
hin
bu
ilt-
up
are
as
wh
ich
co
nta
in a
ra
ng
e o
f u
ses.
Co
mp
ar
ing
th
e S
tud
y’s
re
sid
ua
l v
alu
es
to
oth
er
alt
er
na
tiv
e l
an
d v
alu
e e
sti
ma
tes
an
d v
iab
ilit
y b
en
ch
ma
rk
s s
ho
ws
sig
nif
ica
nt
va
ria
tio
n i
n v
iab
ilit
y w
ith
ma
ny
sit
es
at
the
ma
rg
ins
of
via
bil
ity
or
un
via
ble
alt
og
eth
er
. T
his
is
als
o l
ikel
y t
o b
e th
e
case
wh
en
ass
essi
ng
sit
es i
n s
eco
nd
ary
off
ice
use
, g
iven
va
lues
of
thes
e si
tes
are
su
bst
an
tia
lly
hig
her
th
an
th
e in
du
stri
al
va
lue
per
sq
m c
urr
entl
y u
sed
.
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Pg
11
on
ce t
hes
e ‘o
utl
iers
’ are
re
mo
ved
, th
e h
igh
est
va
lues
in
th
e sa
mp
le (
c.£
14m
/ha
) a
re s
till
ov
er
do
ub
le t
he
av
era
ge.
3.2
0
Th
is o
bse
rva
tio
n a
lon
e re
pre
sen
ts a
sig
nif
ica
nt
sho
rtco
min
g w
hen
att
emp
tin
g t
o a
sses
s v
iab
ilit
y
an
d s
et a
JIL
ch
arg
e fo
r th
e Is
lan
d.
If a
JIL
is
to b
e im
po
sed
as
a c
ha
rge
on
all
dev
elo
pm
ents
, it
nee
ds
to e
nsu
re t
ha
t d
evel
op
me
nt
acr
oss
Jer
sey
rem
ain
s v
iab
le,
wh
ich
oft
en
mea
ns
loo
kin
g a
t
the
‘wo
rst-
case
sce
na
rio
’, o
r ‘l
ow
est
com
mo
n d
en
om
ina
tor’
. T
his
is
on
e o
f th
e li
mit
ati
on
s o
f C
IL
in E
ng
lan
d,
iden
tifi
ed w
ith
in t
he
CIL
Re
vie
w G
rou
p R
ep
ort
(w
hic
h w
e d
iscu
ss i
n o
ur
ma
in
rep
rese
nta
tio
ns)
.
Figu
re 3
.5 R
esid
enti
al L
and
Val
ues
in J
erse
y an
d V
iab
ility
Stu
dy
assu
mp
tio
n
Sou
rce:
Lic
hfi
eld
s b
ased
on
Via
bili
ty S
tud
y
3.2
1 T
o d
emo
nst
rate
th
e d
iffi
cult
y i
n s
etti
ng
CIL
ra
tes
ba
sed
on
th
e ra
ng
e o
f la
nd
va
lue
s se
en i
n
Jer
sey
, F
igu
re 3
.6 s
ho
ws
the
pri
ce p
aid
(£
m p
er h
ecta
re)
for
the
sit
es i
n J
ers
ey,
lab
elle
d w
ith
com
pa
rato
r L
oca
l A
uth
ori
ties
fro
m E
ng
lan
d (
i.e.
wh
ere
res
iden
tia
l la
nd
va
lues
are
sim
ila
r).
It
sho
ws
tha
t la
nd
va
lues
at
the
low
er e
nd
of
the
ran
ge
in J
erse
y a
re a
kin
to
va
lues
se
en i
n p
art
s o
f
the
Wes
t M
idla
nd
s (C
ov
entr
y,
Str
atf
ord
-on
-Av
on
) w
hil
st t
he
hig
hes
t v
alu
es s
een
in
Jer
sey
are
ak
in t
o t
ho
se s
een
in
Ce
ntr
al
Lo
nd
on
(H
ari
ng
ey,
Ha
rro
w,
Ha
ckn
ey a
nd
Ea
lin
g).
A d
irec
t
com
pa
riso
n w
ith
va
lues
see
n i
n J
erse
y i
s n
ot
wh
oll
y a
pp
lica
ble
bec
au
se t
he
com
pa
rato
r v
alu
es
for
En
gla
nd
ex
clu
de
an
y e
ffec
t fr
om
s.1
06
ag
reem
ent
ob
lig
ati
on
s, w
her
eas
tho
se i
n J
erse
y w
ill
refl
ect
the
imp
osi
tio
n o
f P
OA
co
sts.
3.2
2
Sh
ow
n i
n t
his
co
nte
xt,
it
wo
uld
cle
arl
y b
e ex
tre
mel
y d
iffi
cult
to
set
a C
IL r
ate
fo
r a
n a
rea
wh
ere
som
e la
nd
va
lues
wer
e a
s lo
w a
s in
Co
ven
try
, w
hil
e in
oth
er a
rea
s a
s h
igh
as
in C
entr
al
Lo
nd
on
.
It i
s h
igh
ly q
ues
tio
na
ble
ho
w i
t w
ou
ld b
e p
oss
ible
to
se
t a
CIL
ra
te i
n s
uch
an
are
a w
hic
h w
ou
ld
no
t u
nd
erm
ine
via
bil
ity
acr
oss
so
me
site
s. T
his
dem
on
stra
tes
tha
t th
e u
se o
f a
n a
ver
ag
e
resi
den
tia
l la
nd
va
lue
in J
erse
y i
s n
ot
ap
pro
pri
ate
giv
en t
he
wid
e ra
ng
e o
f v
alu
es s
een
. T
he
re i
s a
rea
l a
nd
sig
nif
ica
nt
risk
th
at
the
intr
od
uct
ion
of
an
in
fra
stru
ctu
re l
evy
, b
ase
d o
n t
he
via
bil
ity
stu
dy
wo
uld
un
der
min
e v
iab
ilit
y o
f a
sig
nif
ica
nt
pro
po
rtio
n o
f si
tes.
Th
is f
urt
her
le
nd
s su
pp
ort
to t
he
exis
tin
g P
OA
sy
ste
m w
her
eby
in
fra
stru
ctu
re c
on
trib
uti
on
s a
re c
on
sid
ered
on
a s
ite
-by
-sit
e
ba
sis.
Via
bili
ty S
tud
y
£0
£5
£1
0
£1
5
£2
0
£2
5 Ma
y-0
5O
ct-0
6Fe
b-0
8Ju
l-0
9N
ov-
10
Ap
r-1
2A
ug-
13
De
c-14
Ma
y-1
6Se
p-1
7
Price per hectare (£millions)
Sale
dat
e
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 12
Figu
re 3
.6 R
esid
enti
al L
and
Val
ues
in J
erse
y an
d E
ngl
and
LA
co
mp
arat
ors
Sou
rce:
Lic
hfi
eld
s b
ased
on
Via
bili
ty S
tud
y an
d D
CLG
Lan
d V
alu
e Es
tim
ates
fo
r P
olic
y A
pp
rais
al (
20
15
)
Re
sid
en
tia
l v
alu
es
us
ed
in
via
bil
ity
as
se
ss
me
nt
3.2
3
No
twit
hst
an
din
g o
ur
crit
icis
ms
of
the
ap
pro
ach
ta
ken
to
la
nd
va
lues
, it
wo
uld
ap
pe
ar
tha
t th
e
Stu
dy
ha
s n
ot
tak
en f
orw
ard
its
£6
m/h
a v
alu
ati
on
wh
en
ass
essi
ng
th
e v
iab
ilit
y o
f S
ite
16.
Th
is
site
is
an
ex
am
ple
of
3 l
arg
er
det
ach
ed d
wel
lin
gs,
mo
de
lled
as
the
red
ev
elo
pm
ent
of
an
ex
isti
ng
resi
den
tia
l si
te.
Th
e S
tud
y a
sses
ses
this
sit
e a
s ‘m
arg
ina
l’ o
n t
he
ba
sis
tha
t it
s re
sid
ua
l v
alu
e
exce
eds
the
EU
V,
bu
t n
ot
the
via
bil
ity
th
resh
old
(E
UV
+ 2
0%
).
3.2
4
Its
exis
tin
g u
se a
s a
res
iden
tia
l si
te w
ou
ld i
mp
ly a
va
lue
of
£6
m/h
a s
ho
uld
be
use
d,
as
sta
ted
thro
ug
ho
ut
the
Stu
dy
. H
ow
ever
, T
ab
le 1
0.2
of
the
Stu
dy
sh
ow
th
e a
ssu
med
alt
ern
ati
ve
use
va
lue
for
this
sit
e is
£4
m/h
a (
wit
h a
via
bil
ity
th
resh
old
of
£4
.8m
), n
ot
£6
m/h
a.
We
no
te t
ha
t th
e
exis
tin
g d
wel
lin
g i
s a
ssu
me
d t
o h
av
e a
va
lue
of
£8
00
,00
0 (
as
sta
ted
in
10
.13
of
the
Stu
dy
)
alt
ho
ug
h t
his
do
es n
ot
exp
lain
th
e d
iffe
ren
ce i
n E
UV
.
3.2
5
Wit
h a
res
idu
al
va
lue
of
£4
.2m
, th
is w
ou
ld m
ak
e th
e s
ite
un
via
ble
, n
ot
ma
rgin
al,
as
the
Stu
dy
imp
lies
. A
rev
iew
of
the
resi
den
tia
l d
evel
op
me
nt
ap
pra
isa
ls p
rov
ided
in
Ap
pen
dix
6 o
f th
e S
tud
y
con
firm
s th
at
the
va
lue
of
£4
m h
as
bee
n u
sed
in
th
e a
sses
smen
t.
Co
ven
try
Stra
tfo
rd-o
n-A
von
Da
rtfo
rd
Ch
ich
este
rA
du
rH
erts
mer
e
Bre
ntw
oo
dC
hil
tern
St A
lba
ns
Ha
veri
ngElm
bri
dge
Ho
un
slo
wHa
rin
gey
Ha
rro
w
Eali
ng
Ha
ckn
ey
£0
£5
£1
0
£1
5
£2
0
£2
5
Price per hectare (£millions)
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Pg
13
Bu
ild
co
sts
3.2
6
Sec
tio
n 7
.0 o
f th
e V
iab
ilit
y S
tud
y s
ets
ou
t th
e a
ssu
med
dev
elo
pm
ent
cost
s w
hic
h h
av
e b
een
use
d
in a
sses
sin
g v
iab
ilit
y.
Th
e D
evel
op
men
t co
sts
set
ou
t in
pa
ras
7.2
-24
co
ver
ba
seli
ne
con
stru
ctio
n
cost
s, o
ther
no
rma
l d
evel
op
men
t co
sts,
ab
no
rma
l d
ev
elo
pm
ent/
bro
wn
fiel
d c
ost
s, f
ees
an
d
con
tin
gen
cies
. W
e h
av
e lo
ok
ed a
t ea
ch i
n t
urn
to
ass
ess
the
rea
son
ab
len
ess
of
the
se
ass
um
pti
on
s.
3.2
7
It i
s e
vid
ent
fro
m T
ab
le 7
.1 o
f th
e V
iab
ilit
y S
tud
y t
ha
t b
uil
d c
ost
s in
Jer
sey
are
su
bje
ct t
o
sig
nif
ica
nt
flu
ctu
ati
on
s. T
he
curr
ent
da
ta s
ho
ws
tha
t th
e B
uil
d C
ost
in
dex
ha
s b
ee
n a
s h
igh
as
1.3
9 i
n F
eb
rua
ry 2
014
. T
he
Stu
dy
sta
tes
tha
t d
uri
ng
co
nsu
lta
tio
n,
com
men
ts w
ere
rec
eiv
ed
wh
ich
su
gg
este
d t
he
ind
ex
wa
s a
s h
igh
as
1.4
or
1.5
6;
ho
wev
er,
thes
e w
ere
no
t ta
ke
n i
nto
acc
ou
nt
wit
hin
th
e s
tud
y a
nd
an
in
dex
of
1.2
is
use
d.
As
BC
IS d
ata
fo
r J
erse
y i
s a
lso
ba
sed
on
va
lues
see
n
in t
he
Isle
of
Ma
n a
nd
Isl
e o
f W
igh
t, w
ith
a v
ery
sm
all
da
ta s
am
ple
fro
m J
erse
y,
this
un
der
min
es
the
reli
ab
ilit
y o
f th
e B
CIS
fig
ure
s to
pro
vid
e a
n a
pp
rop
ria
te e
stim
ate
of
bu
ild
co
sts
in J
erse
y.
3.2
8
Fu
rth
erm
ore
, th
e S
tud
y i
tse
lf s
tate
s th
at
du
rin
g s
tak
eho
lder
co
nsu
lta
tio
n,
ther
e w
as
a c
on
sen
sus
tha
t in
fla
tio
n i
n t
he
curr
ent
yea
r w
ou
ld b
e g
rea
ter
tha
n a
nti
cip
ate
d d
ue
to i
mp
act
of
the
wea
k
po
un
d (
as
a r
esu
lt o
f th
e U
K’s
dec
isio
n t
o l
eav
e th
e E
U).
3.2
9
Da
nd
ara
ha
s p
rov
ided
Lic
hfi
eld
s w
ith
ad
dit
ion
al
info
rma
tio
n o
n b
uil
d c
ost
s in
Jer
sey
wh
ich
sug
ges
ts t
ha
t th
e V
iab
ilit
y S
tud
y s
ign
ific
an
tly
un
der
-est
ima
tes
this
. D
an
da
ra i
s th
e b
igg
est
pro
per
ty d
evel
op
er i
n J
erse
y,
focu
sin
g o
n n
ew
ho
mes
, h
om
es f
or
the
eld
erl
y a
nd
co
mm
erci
al
pre
mis
es.
Th
is b
uil
d c
ost
in
form
ati
on
pro
vid
ed b
y a
lo
cal
qu
an
tity
su
rvey
or
firm
, a
nd
ver
ifie
d b
y
Da
nd
ara
ag
ain
st t
he
ir o
wn
ex
per
ien
ce,
esti
ma
tes
bu
ild
co
sts
of
a r
esid
enti
al-
led
mix
ed u
sed
sch
eme
c.2
5%
hig
her
th
an
th
ose
ass
um
ed i
n t
he
Stu
dy
, a
t £
2,3
68
/sq
m.
Th
is e
qu
ate
s to
an
un
der
-est
ima
te o
f b
uil
d c
ost
s o
f £
45
0/s
qm
. T
his
est
ima
te w
ou
ld a
pp
ear
to b
e in
lin
e w
ith
com
men
ts r
ecei
ved
fro
m s
tak
eho
lder
s d
uri
ng
co
nsu
lta
tio
n,
wh
ich
su
gg
este
d a
hig
her
in
dex
(o
f
1.4
-1.5
6)
sho
uld
be
use
d,
an
d r
efle
ct o
ther
fa
cto
rs s
uch
as
the
wea
ke
r p
ou
nd
.
3.3
0
Ev
ide
ntl
y,
if b
uil
d c
ost
s h
av
e b
een
un
der
-est
ima
ted
by
an
yth
ing
ov
er t
he
£8
5/s
qm
JIL
ch
arg
e
pro
po
sed
, th
is m
ean
s it
wil
l n
ot
be
po
ssib
le t
o i
mp
lem
en
t th
is c
ha
rge
wit
ho
ut
ma
kin
g s
che
mes
un
via
ble
. T
he
deg
ree
to w
hic
h t
he
Stu
dy
un
der
-est
ima
tes
lik
ely
bu
ild
co
sts
is s
uff
icie
nt
alo
ne
to
wip
e o
ut
an
y p
ote
nti
al
via
bil
ity
hea
dro
om
fo
r a
JIL
ch
arg
e.
3.3
1 H
ow
ever
, in
ad
dit
ion
to
th
is,
du
rin
g c
on
sult
ati
on
wit
h s
tak
eho
lder
s, i
t w
as
sug
ges
ted
th
at
incr
ease
d b
uil
din
g s
tan
da
rds
in J
erse
y w
ou
ld a
dd
a f
urt
her
4%
to
th
e b
uil
d c
ost
s. B
y w
ay
of
com
pa
riso
n,
via
bil
ity
stu
die
s u
nd
erta
ke
n i
n E
ng
lan
d h
av
e m
ad
e sp
ecif
ic a
llo
wa
nce
s fo
r
Su
mm
ar
y
Re
sid
en
tia
l la
nd
va
lue
s i
n J
er
se
y a
re
in
pr
inc
iple
dif
fic
ult
to
es
tab
lis
h d
ue
to
th
e
sm
all
nu
mb
er
of
tra
ns
ac
tio
ns
th
at
tak
e p
lac
e.
As
a m
att
er
of
pr
inc
iple
, th
is
hig
hli
gh
ts t
he
ov
er
all
dif
fic
ult
y i
n e
sta
bli
sh
ing
a J
IL,
bec
au
se t
he
imp
osi
tio
n o
f su
ch
a c
ha
rge
sho
uld
no
t u
nd
erm
ine
the
via
bil
ity
of
cert
ain
ty
pes
of
site
.
Th
e v
ari
ati
on
in
la
nd
va
lues
is
clea
r w
hen
co
mp
ari
ng
to
va
lues
in
En
gli
sh l
oca
l a
uth
ori
ties
;
the
dif
ficu
ltie
s in
ass
essi
ng
via
bil
ity
in
Jer
sey
bec
om
e cl
ear
wh
en s
et i
n t
his
co
nte
xt.
Th
e
av
era
ge
va
lue
use
d i
s o
f li
ttle
ass
ista
nce
in
tes
tin
g v
iab
ilit
y,
as
dem
on
stra
ted
th
ere
are
a
nu
mb
er o
f si
tes
sold
fo
r £
mil
lio
ns/
ha
hig
her
th
an
th
is.
We
als
o n
ote
an
err
or
in t
he
ex
isti
ng
use
va
lue
of
site
16
, w
hic
h s
ho
uld
be
ass
esse
d a
s
un
via
ble
, n
ot
ma
rgin
al.
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 14
ad
dit
ion
al
bu
ild
co
sts
ass
oci
ate
d w
ith
bu
ild
ing
to
hig
he
r st
an
da
rds,
in
clu
din
g C
od
e f
or
Su
sta
ina
ble
Ho
mes
lev
el 4
3.
Ho
wev
er,
the
Stu
dy
ha
s o
pte
d n
ot
to m
ak
e a
n a
dju
stm
en
t fo
r a
ny
sim
ila
r co
sts,
ke
epin
g b
uil
d c
ost
s a
t th
e B
CIS
co
sts,
wit
h a
1.2
in
de
x.
Th
is f
urt
he
r d
emo
nst
rate
s
the
deg
ree
to w
hic
h b
uil
d c
ost
s h
av
e b
een
un
der
esti
ma
ted
in
th
e S
tud
y,
lea
din
g t
o v
iab
ilit
y b
ein
g
sig
nif
ica
ntl
y o
ve
r-st
ate
d,
lea
din
g t
o t
he
co
ncl
usi
on
th
at
it w
ou
ld n
ot
be
via
ble
to
in
tro
du
ce a
JIL
cha
rge
on
dev
elo
pm
en
t.
Pe
rc
en
tag
e f
or
Ar
t
3.3
2
As
pa
rt o
f d
evel
op
men
ts i
n J
erse
y,
dev
elo
per
s a
re e
nco
ura
ged
to
ma
ke
a p
ub
lic
art
co
ntr
ibu
tio
n
equ
iva
len
t to
0.7
5%
of
con
stru
ctio
n c
ost
s o
n s
ites
. W
hil
st t
he
Stu
dy
sta
tes
at
pa
ra 7
.31
tha
t th
is
wil
l b
e a
ssim
ila
ted
in
to a
ny
new
le
vy
, th
e J
erse
y I
nfr
ast
ruct
ure
Lev
y P
rop
osa
l co
nsu
lta
tio
n
do
cum
ent
ma
kes
no
ref
ere
nce
to
th
e co
ntr
ibu
tio
n f
or
the
Art
s, a
nd
wh
eth
er t
his
wil
l ch
an
ge
foll
ow
ing
in
tro
du
ctio
n o
f a
new
le
vy
. U
nti
l is
it
clea
r th
at
such
a c
ost
wo
uld
be
ass
imil
ate
d i
nto
an
y o
ther
ch
arg
e,
this
sh
ou
ld b
e in
clu
ded
wit
hin
cu
rren
t d
evel
op
men
t co
sts.
Th
is r
epre
sen
ts a
furt
her
de
vel
op
men
t co
st f
or
wh
ich
th
e S
tud
y h
as
fail
ed t
o a
cco
un
t.
Co
mp
an
y t
ax
3.3
3
Th
e S
tud
y s
tate
s th
at
alt
ho
ug
h i
t w
as
sug
ges
ted
du
rin
g c
on
sult
ati
on
wit
h s
tak
eh
old
ers,
an
all
ow
an
ce f
or
20
% ‘i
nco
me
tax
’ wa
s n
ot
acc
epte
d.
Ho
wev
er,
sha
reh
old
ers
of
dev
elo
pm
ent
com
pa
nie
s in
Jer
sey
are
lia
ble
to
pa
y t
ax
at
20
% (
wh
ich
is
gen
era
lly
pa
id o
ut
of
the
fu
nd
s o
f th
e
com
pa
ny
). T
he
effe
ct o
f a
co
mp
an
y t
ax
on
dev
elo
pm
en
t in
Jer
sey
is
an
im
po
rta
nt
con
sid
era
tio
n
for
two
rea
son
s:
1 It
is
lik
ely
to
aff
ect
the
lev
el o
f d
evel
op
er p
rofi
t re
qu
ire
d;
an
d
2
It i
s li
kel
y t
o a
ffec
t th
e v
iab
ilit
y t
hre
sho
lds
(wh
ich
we
retu
rn t
o l
ate
r in
th
is r
ep
ort
), s
ince
th
e
sca
le o
f u
pli
ft o
n e
xis
tin
g u
se w
ill
nee
d t
o b
e h
igh
en
ou
gh
to
in
cen
tiv
ise
a s
ale
, ta
kin
g
acc
ou
nt
of
pro
fit,
ta
xes
an
d o
ther
fa
cto
rs (
such
as
no
in
her
ita
nce
ta
xes
). O
ne
mem
ber
of
the
JeC
C s
tate
d t
ha
t it
ha
s so
ld l
an
d f
or
a “
sig
nif
ica
nt”
pre
miu
m a
bo
ve
EU
V t
o a
llo
w f
or
pro
fits
an
d t
ax
es.
Via
bil
ity
As
se
ss
me
nts
Via
bil
ity
th
re
sh
old
s
3.3
4
Th
e S
tud
y a
ssu
mes
a v
iab
ilit
y t
hre
sho
ld (
bei
ng
th
e sc
ale
ab
ov
e th
e ex
isti
ng
/alt
ern
ati
ve
use
va
lue
exce
eds
for
the
site
to
be
via
ble
) o
f 2
0%
. P
ara
6.5
4 o
f th
e S
tud
y s
tate
s th
at
this
su
pp
ort
ed b
y
“wo
rk d
on
e el
sew
her
e a
nd
ap
pea
l d
ecis
ion
s, a
s se
t o
ut
in C
ha
pte
r 2
”. C
ha
pte
r 2
of
the
Stu
dy
sets
ou
t so
me
of
the
va
rio
us
gu
ida
nce
wit
hin
th
e E
ng
lish
PP
G r
eg
ard
ing
via
bil
ity
, a
nd
it
is w
ho
lly
3 F
or
exam
ple
, see
So
uth
Oxf
ord
shir
e V
iab
ility
Stu
dy,
wh
ich
ad
ds
6%
fo
r th
is. T
hat
Stu
dy
cite
s re
sear
ch b
y C
yrill
Sw
eett
un
der
take
n
on
beh
alf
of
the
Dep
artm
ent
of
Co
mm
un
itie
s an
d L
oca
l Go
vern
men
t o
n t
he
imp
act
of
bu
ildin
g to
CSH
sta
nd
ard
s.
Su
mm
ar
y
Ov
era
ll t
he
Via
bil
ity
Stu
dy
ha
s si
gn
ific
an
tly
un
der
-est
ima
ted
co
nst
ruct
ion
co
sts.
Th
e S
tud
y
itse
lf n
ote
s th
at
du
rin
g c
on
sult
ati
on
sta
keh
old
ers
ind
ica
ted
bu
ild
co
sts
wer
e su
bst
an
tia
lly
hig
her
th
an
th
ose
ass
um
ed i
n t
he
Stu
dy
, a
nd
Da
nd
ara
ha
ve
con
firm
ed t
his
to
be
the
case
.
Th
e B
CIS
da
ta s
ho
uld
be
use
d w
ith
ca
uti
on
giv
en l
ittl
e d
ata
is
act
ua
lly
av
ail
ab
le f
or
Jer
sey
.
Th
e s
ca
le o
f u
nd
er
es
tim
ati
on
in
bu
ild
co
sts
alo
ne
is
su
ffic
ien
t to
en
tir
ely
wip
e
ou
t a
ny
po
ten
tia
l in
fra
str
uc
tur
e l
ev
y c
on
trib
uti
on
, c
ur
re
ntl
y p
ro
po
se
d a
t
£8
5/s
qm
.
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Pg
15
un
clea
r h
ow
th
ese
sup
po
rt t
he
spec
ific
20
% u
pli
ft p
rop
ose
d f
or
Jer
sey
, a
s st
ate
d i
n t
he
Stu
dy
.
Th
e J
eCC
co
nsi
der
th
at
this
co
mp
lete
ly d
isre
ga
rds
loca
l ci
rcu
mst
an
ces
spec
ific
to
Jer
sey
, fo
r
exa
mp
le a
s th
ere
is n
o i
nh
eri
tan
ce t
ax
in
Jer
sey
, th
ere
is l
ess
of
an
in
cen
tiv
e fo
r in
div
idu
al
lan
do
wn
ers
to s
ell,
co
mp
are
d t
o i
n E
ng
lan
d.
Th
e J
eC
C s
tate
s th
at
ther
e a
re m
an
y e
xa
mp
les
of
pro
per
ty b
ein
g h
an
ded
do
wn
th
rou
gh
ge
ner
ati
on
s a
nd
on
ly s
old
“w
hen
th
e ti
me
an
d v
alu
e is
rig
ht”
.
3.3
5
Le
Ma
suri
er i
s a
n e
xa
mp
le o
f a
co
mm
erci
al
pro
per
ty c
om
pa
ny
in
Je
rsey
wh
ich
ha
s h
eld
la
nd
on
the
Isla
nd
fo
r lo
ng
per
iod
s, i
n s
om
e ca
ses
sin
ce 1
83
5.
Mem
ber
s o
f th
e J
eC
C g
ive
ex
am
ple
s o
f
site
s w
hic
h w
ere
sold
at
“sig
nif
ica
nt
pre
miu
ms”
to
res
iden
tia
l d
evel
op
ers
to e
nsu
re a
pro
fit
an
d
tax
fre
e d
isp
osa
l. T
his
dem
on
stra
tes
an
oth
er f
un
da
me
nta
l d
iffe
ren
ce b
etw
een
th
e p
rop
erty
ma
rket
s in
En
gla
nd
an
d i
n J
erse
y w
hic
h m
ean
s it
is
no
t p
oss
ible
to
ap
pro
pri
ate
ly a
nd
ro
bu
stly
ass
ess
via
bil
ity
ba
sed
on
th
e id
enti
cal
ap
pro
ach
as
in E
ng
lan
d,
then
set
a p
rop
ose
d
infr
ast
ruct
ure
lev
y o
n d
evel
op
men
t.
3.3
6
Th
e ex
iste
nce
of
tax
on
la
nd
sa
les
com
bin
ed w
ith
th
e a
bse
nce
of
inh
erit
an
ce t
ax
me
an
s th
at
the
via
bil
ity
th
resh
old
s a
re l
ikel
y t
o b
e in
ex
cess
of
tho
se a
ssu
med
wit
hin
th
e S
tud
y.
Th
is i
s in
ad
dit
ion
to
ou
r p
rev
iou
s cr
itic
ism
s ra
ised
ab
ou
t th
e v
alu
e o
f b
row
nfi
eld
la
nd
ass
um
ed,
wh
ich
,
even
un
der
th
e S
tud
y’s
cu
rren
t a
ssu
mp
tio
n (
of
20
%)
wo
uld
un
der
min
e v
iab
ilit
y w
hen
com
pa
rin
g r
esid
ua
l la
nd
va
lues
.
3.3
7
Th
e v
iab
ilit
y t
hre
sho
ld m
ay
als
o b
e h
igh
er w
her
e d
ev
elo
per
s a
pp
roa
ch l
an
do
wn
ers
in
circ
um
sta
nce
s w
her
e th
e si
te i
s in
use
. T
his
is
bec
au
se n
ot
on
ly w
ill
the
lan
do
wn
er r
equ
ire
a
pre
miu
m a
bo
ve
the
EU
V,
bu
t m
ay
see
k a
hig
her
pre
miu
m t
o c
om
pe
nsa
te f
or
the
nee
d t
o v
aca
te
the
pre
mis
es a
nd
th
e in
con
ven
ien
ce.
Pa
dd
oc
k l
an
d
3.3
8
Wh
en a
pp
lied
to
th
e a
lter
na
tiv
e u
se v
alu
e o
n p
ad
do
ck l
an
d (
£15
0,0
00
/ha
) th
e S
tud
y’s
via
bil
ity
thre
sho
ld a
mo
un
ts t
o £
180
,00
0/h
a (
see
Ta
ble
10
.2).
Th
e S
tud
y i
tsel
f a
ccep
ts t
ha
t p
ad
do
ck l
an
d
alr
ead
y a
ttra
cts
a p
rem
ium
(a
rou
nd
4-5
tim
es t
he
va
lue
) o
ver
ag
ricu
ltu
ral
lan
d (
va
lued
at
£3
6,0
00
/ha
) d
ue
to b
ein
g o
f a
men
ity
va
lue,
fo
r u
se a
s p
on
y p
ad
do
cks
or
to p
rov
ide
pro
tect
ion
/pri
va
cy.
Th
eref
ore
, it
is
qu
esti
on
ab
le w
het
her
a l
an
do
wn
er
wo
uld
acc
ept
an
up
lift
of
just
20
% o
n a
sit
es i
n E
UV
as
a p
ad
do
ck (
equ
iva
len
t to
an
ad
dit
ion
al
£3
0,0
00
/ha
) if
th
ere
we
re
a p
oss
ibil
ity
of
the
lan
d b
ein
g d
evel
op
ed f
or
resi
de
nti
al
use
s.
3.3
9
Th
ose
liv
ing
on
th
e ed
ge
of
sett
lem
ents
wh
o o
wn
sm
all
pa
rcel
s o
f la
nd
alo
ng
th
e ed
ge
of
the
sett
lem
ent
cou
ld d
ecid
e n
ev
er t
o s
ell
such
la
nd
fo
r d
ev
elo
pm
ent,
pu
ttin
g a
sig
nif
ica
ntl
y h
igh
er
va
lue
on
th
e a
men
ity
an
d p
riv
acy
it
pro
vid
es;
a v
alu
e w
hic
h c
an
no
t n
eces
sari
ly b
e m
easu
red
thro
ug
h a
via
bil
ity
stu
dy
. T
his
is
lik
ely
to
be
fu
rth
er c
om
po
un
ded
by
th
e a
bse
nce
of
inh
erit
an
ce
tax
in
Jer
sey
all
ow
ing
su
ch l
an
d t
o b
e p
ass
ed o
n w
ith
no
fin
an
cia
l p
ena
lty
.
3.4
0
Th
e S
tud
y’s
ap
pro
ach
to
dev
elo
pm
ent
of
pa
dd
ock
la
nd
is
an
ex
tre
me
ov
ersi
mp
lifi
cati
on
of
a v
ery
com
ple
x s
yst
em
, in
wh
ich
in
cen
tiv
es t
o s
ell
are
aff
ecte
d b
y a
ra
ng
e o
f p
erso
na
l a
nd
wid
er
eco
no
mic
fa
cto
rs.
No
ex
am
ple
s h
av
e b
een
cit
ed i
n t
he
Via
bil
ity
Stu
dy
wh
ich
ju
stif
y i
ts
ass
um
pti
on
s.
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 16
Stu
dy
Ou
tpu
ts
3.4
1 A
s a
res
ult
of
the
de
gre
e to
wh
ich
th
e V
iab
ilit
y S
tud
y h
as
un
der
-est
ima
ted
th
e E
UV
of
bro
wn
fiel
d
site
s:
Th
e ‘A
dd
itio
na
l P
rofi
t’ s
ho
wn
in
Ta
ble
10
.4 o
f th
e S
tud
y i
s in
corr
ect
– o
ur
an
aly
sis
ab
ov
e
sho
ws
tha
t w
he
n c
om
pa
rin
g a
ga
inst
mo
re l
ike
ly l
an
d v
alu
es t
he
resi
du
al
lan
d v
alu
e d
oes
no
t
exce
ed t
o v
iab
ilit
y t
hre
sho
ld (
even
at
20
%)
for
mo
st s
ites
;
Th
e S
tud
y’s
co
ncl
usi
on
th
at
this
‘Ad
dit
ion
al
Pro
fit’
dem
on
stra
tes
ther
e is
cle
ar
cap
aci
ty f
or
dev
elo
pe
r co
ntr
ibu
tio
ns
is f
law
ed a
nd
in
corr
ect;
Th
e S
tud
y’s
su
bse
qu
ent
ass
essm
ents
of
the
sca
le o
f a
po
ten
tia
l J
IL a
re a
lso
fla
wed
.
Alt
er
na
tiv
e V
iab
ilit
y T
es
tin
g
Re
sid
ua
l L
an
d V
alu
es
3.4
2
Usi
ng
th
e H
om
es a
nd
Co
mm
un
itie
s A
gen
cy (
HC
A)
De
vel
op
men
t A
pp
rais
al
To
ol4 L
ich
fiel
ds
ha
s
recr
eate
d t
he
Via
bil
ity
Stu
dy
’s a
sses
smen
ts f
or
Sit
e 3
(a
20
Un
it B
row
nfi
eld
sit
e),
on
th
e b
asi
s
tha
t th
e J
eC
C c
on
sid
ers
this
on
e o
f th
e m
ore
lik
ely
ty
pes
of
site
to
co
me
forw
ard
in
Jer
sey
. T
his
use
s th
e a
ssu
mp
tio
ns
set
ou
t w
ith
in t
he
Via
bil
ity
Stu
dy
an
d a
s sh
ow
n i
n A
pp
end
ix 6
of
the
Stu
dy
. L
ich
fiel
ds
ha
s th
en m
ad
e so
me
am
end
men
ts t
0 t
he
via
bil
ity
ass
essm
ent
ba
sed
on
th
e
JeC
C’s
alt
ern
ati
ve
ass
um
pti
on
s, w
hic
h a
re:
A c
on
stru
ctio
n p
erio
d o
f 3
6 m
on
ths
(co
mp
are
d t
o 2
1 m
on
ths
in t
he
Stu
dy
);
Sa
les
per
iod
en
din
g u
p t
o 1
2 m
on
ths
po
st-c
om
ple
tio
n (
com
pa
red
to
6 m
on
ths
in t
he
Stu
dy
);
10%
fo
r co
nti
ng
enci
es (
com
pa
red
to
5%
in
th
e S
tud
y);
Incr
easi
ng
de
vel
op
ers
retu
rn t
o 2
5%
(co
mp
are
d t
o 2
0%
in
th
e S
tud
y,
to a
llo
w f
or
inte
rest
an
d t
ax
); a
nd
Incl
ud
ing
th
e p
erce
nta
ge
for
Art
(a
t 0
.75
% o
f b
uil
d c
ost
s).
3.4
3
Ma
kin
g t
he
ab
ov
e ch
an
ges
sh
ow
s a
res
idu
al
lan
d v
alu
e o
f £
2.2
m f
or
this
sit
e, e
qu
iva
len
t to
£5
.8m
/ha
, w
ith
ou
t th
e in
clu
sio
n o
f th
e p
rop
ose
d J
IL.
Wh
en J
IL i
s in
clu
ded
, th
is f
all
s to
£5
.1m
/ha
. F
ull
ou
tpu
ts c
an
be
fou
nd
in
Ap
pe
nd
ix 1
of
this
re
po
rt.
3.4
4
Th
e S
tud
y n
ote
s th
at
con
cern
s w
ere
rais
ed d
uri
ng
co
nsu
lta
tio
n t
ha
t th
e b
uil
d c
ost
s w
ere
too
lo
w,
an
d t
ha
t a
n i
nd
ex
of
1.4
sh
ou
ld b
e a
ssu
med
on
th
e B
CIS
(a
s o
pp
ose
d t
o t
he
1.2
use
d i
n t
he
4 S
ee h
ttp
s://
ww
w.g
ov.
uk/
gove
rnm
ent/
colle
ctio
ns/
dev
elo
pm
ent-
app
rais
al-t
oo
l
Su
mm
ar
y
A g
ener
al
20
% u
pli
ft h
as
be
en a
pp
lied
to
alt
ern
ati
ve
use
va
lues
to
det
erm
ine
wh
at
va
lue
wo
uld
in
cen
tiv
ise
a l
an
do
wn
er t
o s
ell,
ho
we
ver
th
is d
oe
s n
ot
re
fle
ct
the
sp
ec
ific
lo
ca
l
cir
cu
ms
tan
ce
s (
pa
rti
cu
lar
ly r
ela
ted
to
ta
x)
in J
er
se
y.
La
nd
ow
ne
rs i
n J
erse
y d
o n
ot
ha
ve
the
sam
e in
cen
tiv
e to
rel
ease
la
nd
as
tho
se i
n t
he
UK
, w
ith
hig
her
pre
miu
ms
oft
en
req
uir
ed.
Th
e la
ck o
f ev
iden
ce p
rese
nte
d o
n s
ale
s a
nd
dev
elo
pm
ent
of
pa
dd
ock
la
nd
, a
nd
giv
en l
an
do
wn
ers
ma
y p
lace
an
in
fin
itel
y h
igh
er v
alu
e o
n t
hei
r la
nd
fo
r u
se a
s a
me
nit
y s
pa
ce
(or
to p
rote
ct t
he
ir p
riv
acy
) m
ak
es i
t d
iffi
cult
, if
no
t im
po
ssib
le,
for
the
Via
bil
ity
Stu
dy
to
det
erm
ine
a v
iab
ilit
y t
hre
sho
ld f
or
thes
e ty
pes
of
site
.
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Pg
17
Stu
dy
). A
do
pti
ng
th
is i
nd
ex w
ou
ld g
ive
a r
esid
ua
l la
nd
va
lue
of
£4
.7m
/ha
(a
s ca
n b
e se
en i
n
Ap
pe
nd
ix 1
). W
ith
th
e p
rop
ose
d J
IL i
ncl
ud
ed,
this
fa
lls
to £
3.9
m/h
a
3.4
5
Ho
wev
er,
mem
ber
s o
f th
e J
eCC
ra
ise
con
cern
s a
bo
ut
the
BC
IS o
ver
all
fo
r J
erse
y (
sin
ce i
t
incl
ud
es f
ew s
am
ple
s fr
om
Jer
sey
an
d d
raw
s u
po
n d
ata
fro
m e
lse
wh
ere
, e.
g.
the
Isl
e o
f M
an
),
an
d D
an
da
ra h
as
pu
t a
lter
na
tiv
e b
uil
d c
ost
fig
ure
s to
Lic
hfi
eld
s o
f £
2,6
38
/sq
m.
Th
e V
iab
ilit
y
Stu
dy
als
o s
tate
s th
at
du
rin
g c
on
sult
ati
on
, a
sta
keh
old
er
ind
ica
ted
th
at
va
lues
30
% h
igh
er t
ha
n
BC
IS,
eq
uiv
ale
nt
to a
1.5
6 i
nd
ex w
as
ap
pro
pri
ate
. O
n t
he
ba
sis
of
the
bu
ild
co
sts
per
sq
m
ind
exed
to
1.5
6,
the
resi
du
al
lan
d v
alu
e o
f S
ite
3 w
ou
ld b
e £
3.7
m/h
a.
On
ce a
CIL
ch
arg
e5 h
as
bee
n i
nco
rpo
rate
d,
this
fa
lls
to £
3.0
m/h
a.
3.4
6
Th
e o
utc
om
es o
f th
e a
bo
ve
ass
essm
ents
are
sh
ow
n i
n t
he
con
tex
t o
f th
e p
rice
pa
id p
er h
ecta
re o
f
resi
den
tia
l si
tes
sho
wn
in
th
e S
tud
y (
as
set
ou
t p
rev
iou
sly
) in
Fig
ure
3.7
. It
sh
ow
s th
at
ad
just
ing
bu
ild
co
sts
to a
n i
nd
ex
of
1.4
on
th
e B
CIS
wo
uld
, w
he
n p
rop
ose
d J
IL i
s in
clu
ded
, re
sult
in
resi
du
al
lan
d v
alu
e b
elo
w t
he
pri
ce p
aid
on
alm
ost
ev
ery
sit
e so
ld i
n J
erse
y s
ince
20
06
. W
hen
usi
ng
Da
nd
ara
’s h
igh
er e
stim
ate
of
bu
ild
co
sts,
res
idu
al
lan
d v
alu
e is
clo
se t
o £
0,
an
d s
lig
htl
y
neg
ati
ve
wh
en t
he
pro
po
sed
JIL
is
incl
ud
ed.
Figu
re 3
.7 R
esid
ual
Lan
d V
alu
es (
Lich
fiel
ds'
Ass
essm
ent)
co
mp
ared
to
Sal
es V
alu
es o
f R
esi
den
tial
Sit
es
in J
ers
ey. D
ash
ed
lin
es s
ho
w
RLV
wh
en p
rop
ose
d J
IL is
incl
ud
ed.
Sou
rce:
Lic
hfi
eld
s u
sin
g H
CA
To
ol a
nd
bas
ed o
n V
iab
ility
Stu
dy/
JeC
C f
igu
res.
Tw
o s
ite
s w
ith
val
ue
of
£23
m/h
a n
ot
sho
wn
.
Su
rp
lus
/De
fic
it
3.4
7
In a
dd
itio
n t
o t
he
ab
ov
e,
by
wa
y o
f ex
am
ple
, L
ich
fiel
ds
ha
s a
lso
mo
del
led
fo
ur
of
the
site
s (S
ites
2,
3,
4 a
nd
5)
to d
ete
rmin
e w
het
her
th
ere
is a
su
rplu
s/d
efic
it,
ma
kin
g a
dju
stm
ents
fo
r b
uil
d
cost
s et
c. (
as
set
ou
t a
bo
ve)
.
5 T
o e
nsu
re t
hat
CIL
is n
ot
set
at t
he
mar
gin
s o
f vi
abili
ty, C
IL is
inp
ut
into
th
e H
CA
Dev
elo
pm
ent
Ap
pra
isal
To
ol a
s £
17
0/s
qm
; th
is
effe
ctiv
ely
app
lies
a 5
0%
bu
ffer
to
th
e p
rop
ose
d £
85
/sq
m.
Via
bili
ty S
tud
y
£1
.0
£2
.0
£3
.0
£4
.0
£5
.0
£6
.0
£7
.0
£8
.0
£9
.0
£1
0.0
£1
1.0
£1
2.0
£1
3.0
£1
4.0
£1
5.0
Price per hectare (£millions)
JeC
C A
ssu
mp
tio
ns
JeC
C, w
ith
bu
ild c
ost
s in
de
xed
to
1.4
JeC
C, w
ith
bu
ild c
ost
s in
de
xed
to
1.5
6
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 18
3.4
8
To
pro
vid
e a
be
nch
ma
rk,
the
Stu
dy
’s a
ssu
mp
tio
ns
ha
ve
bee
n i
np
ut
into
th
e m
od
el.
Th
is g
ives
a
fig
ure
wh
ich
ali
gn
s b
roa
dly
wit
h t
he
‘Ad
dit
ion
al
Pro
fit’
set
ou
t fo
r ea
ch s
ite
in
Ap
pe
nd
ix 6
of
the
Stu
dy
(a
lbei
t w
ith
a s
ma
ll m
arg
in o
f er
ror
du
e to
dif
fere
nce
s in
th
e to
olk
its
emp
loy
ed).
Th
is i
s
sho
wn
in
th
e fi
rst
colu
mn
of
Ta
ble
3.1
.
3.4
9
By
all
ow
ing
fo
r L
ich
fiel
ds
alt
ern
ati
ve
ass
um
pti
on
s (a
s se
t o
ut
ab
ov
e a
nd
in
mo
re d
eta
il i
n
Ap
pe
nd
ix 2
), a
nd
acc
epti
ng
(fo
r th
e p
urp
ose
s o
f th
is e
xer
cise
) th
e v
iab
ilit
y t
hre
sho
ld o
f
£2
.28
m/h
a,
it i
s ev
iden
t th
at
the
pu
rpo
rted
su
rplu
s in
th
e V
iab
ilit
y S
tud
y i
s d
rast
ica
lly
red
uce
d.
Fo
r si
te 4
th
e s
urp
lus
red
uce
s fr
om
£1.
2m
to
ju
st £
27
9,0
00
. H
ow
ever
, th
e p
ract
ica
liti
es o
f
ass
essi
ng
via
bil
ity
an
d s
etti
ng
a J
IL r
ate
bec
om
e ev
en m
ore
cle
ar
wh
en
co
nsi
der
ing
th
e
va
ria
bil
ity
of
lan
d v
alu
es.
Th
is h
as
bee
n e
xp
lore
d i
n d
ep
th a
bo
ve
, w
hic
h s
ho
ws
the
va
ria
tio
n i
n
resi
den
tia
l la
nd
va
lues
in
Je
rsey
ba
sed
on
pre
vio
us
tra
nsa
ctio
ns,
th
e p
ote
nti
all
y h
igh
er v
alu
es
of
reta
il a
nd
ho
tel
site
s, a
nd
th
e la
ck o
f ev
iden
ce a
lto
get
her
rel
ati
ng
to
in
du
stri
al
lan
d v
alu
es.
Ta
ble
3.1
sh
ow
s th
at
if l
an
d v
alu
es
incr
ease
d t
o £
4m
/ha
, o
ne
of
the
fou
r si
tes
wo
uld
bec
om
e u
nv
iab
le,
at
£6
m/h
a t
hre
e o
f th
e fo
ur
bec
om
e u
nv
iab
le a
nd
ov
er £
8m
/ha
all
are
un
via
ble
. T
hes
e in
crea
sed
lan
d v
alu
es a
re n
ot
ou
tlie
rs:
15 o
f th
e 17
tra
nsa
cted
sit
es w
ere
at
or
ab
ov
e £
4m
an
d 1
0 w
ere
ov
er
£6
m p
er
hec
tare
.
Tab
le 3
.1 S
urp
lus/
Def
icit
usi
ng
Lich
fie
lds
assu
mp
tio
ns
and
at
vary
ing
lan
d v
alu
es
St
ud
y A
ssu
mp
tio
ns
Lich
fiel
ds
Ass
um
pti
on
s
Site
Su
rplu
s/d
efic
it
at S
tud
y V
iab
ility
Th
resh
old
Surp
lus
Def
icit
at
£2
.28
m/h
a Su
rplu
s D
efic
it
at £
4m
/ha
Surp
lus
Def
icit
at
£6
m/h
a Su
rplu
s D
efic
it
at £
8m
/ha
Surp
lus
Def
icit
at
£1
2m
/ha
1
£5
,13
2,0
00
£
2,7
95
,00
0
£1
,17
9,0
00
-£
70
1,0
00
-£
2,5
80
,00
0
-£6
,33
8,0
00
2
£3
,22
5,0
00
£
1,7
69
,00
0
£6
80
,00
0
£7
48
,00
0
-£1
,85
5,0
00
-£
4,3
89
,00
0
3
£2
,09
5,0
00
£
1,0
98
,00
0
£3
91
,00
0
-£4
31
,00
0
-£1
,25
3,0
00
-£
2,8
97
,00
0
4
£1
,22
1,0
00
£
27
9,0
00
-£
42
8,0
00
-£
1,2
50
,00
0
-£2
,07
2,0
00
-£
3,7
15
,00
0
Sou
rce:
Lic
hfi
eld
s b
ased
on
HC
A D
AT
and
Via
bili
ty S
tud
y
3.5
0
Th
e a
bo
ve
hig
hli
gh
ts t
wo
fu
nd
am
enta
l is
sues
wit
h d
ete
rmin
ing
via
bil
ity
in
Jer
sey
;
1 T
he
sca
le o
f v
iab
ilit
y h
as
be
en s
ign
ific
an
tly
ov
er-e
stim
ate
d i
n t
he
Stu
dy
, le
ad
ing
th
e a
uth
ors
to i
nco
rrec
tly
co
ncl
ud
e th
ere
is s
uff
icie
nt
sco
pe
to i
ntr
od
uce
a J
IL;
an
d
2
Th
e in
her
en
t d
iffi
cult
y i
n d
eter
min
ing
la
nd
va
lues
on
th
e Is
lan
d m
ean
s th
at
via
bil
ity
is
nea
rly
im
po
ssib
le t
o d
eter
min
e a
lto
get
her
. T
he
sen
siti
vit
y o
f v
iab
ilit
y t
o l
an
d v
alu
es i
s
clea
rly
dem
on
stra
ted
ab
ov
e a
nd
ea
rlie
r in
th
is S
ecti
on
.
3.5
1 L
ich
fiel
ds
fin
din
gs
usi
ng
th
e H
CA
to
ol
are
in
lin
e w
ith
via
bil
ity
ca
lcu
lati
on
s u
nd
erta
ken
inte
rna
lly
by
th
e J
eCC
wh
ich
sh
ow
th
at
wit
h i
ts a
dju
ste
d a
ssu
mp
tio
ns
an
d i
np
uts
, v
iab
ilit
y
wo
uld
be
ma
rgin
al
on
th
is s
ite,
wit
h a
dev
elo
per
ret
urn
aft
er i
nte
rest
of
just
bel
ow
5%
.
Imp
ac
t o
f th
e U
K l
ea
vin
g t
he
Eu
ro
pe
an
Un
ion
3.5
2
Un
der
th
e h
ead
ing
‘Sen
siti
vit
y T
esti
ng
’ th
e V
iab
ilit
y S
tud
y r
efer
ence
s co
nce
rns
rais
ed d
uri
ng
sta
keh
old
er c
on
sult
ati
on
ab
ou
t th
e im
pa
ct o
f th
e w
eak
po
un
d f
oll
ow
ing
th
e E
U r
efer
end
um
.
3.5
3
Wh
ilst
th
e S
tud
y d
oes
un
de
rta
ke
sen
siti
vit
y t
esti
ng
, v
ary
ing
bu
ild
co
sts
by
bet
wee
n +
5%
an
d
+2
0%
, th
e o
utp
uts
of
thes
e a
sses
smen
ts a
re f
un
da
men
tall
y f
law
ed g
iven
th
ey a
re u
nd
erp
inn
ed
by
la
nd
va
lue
ass
um
pti
on
s a
nd
via
bil
ity
th
resh
old
s (a
nd
va
rio
us
oth
er
ass
um
pti
on
s) w
hic
h
them
selv
es a
re f
law
ed.
Ou
r a
na
lysi
s a
bo
ve
ad
op
ts h
igh
er
bu
ild
co
sts
an
d s
ho
ws
a s
ign
ific
an
t
red
uct
ion
in
res
idu
al
lan
d v
alu
e re
sult
s.
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Pg
19
Co
mp
ar
iso
n w
ith
En
gli
sh
CIL
Ra
tes
3.5
4
As
set
ou
t in
th
e m
ain
re
pre
sen
tati
on
s a
nd
ab
ov
e,
we
con
sid
er t
ha
t th
e d
iffe
ren
ces
in t
he
Je
rsey
ho
usi
ng
ma
rket
co
mp
are
d t
o t
ho
se i
n t
he
UK
ma
ke
it d
iffi
cult
to
ass
ess
via
bil
ity
an
d i
mp
lem
ent
a C
IL c
ha
rge
alt
og
eth
er.
Ho
wev
er,
th
e V
iab
ilit
y S
tud
y p
rov
ides
so
me
com
pa
riso
ns
of
CIL
ra
tes
set
in l
oca
l a
uth
ori
ty a
rea
s in
En
gla
nd
, w
hic
h a
pp
ear
to s
up
po
rt t
he
Stu
dy
’s c
on
clu
sio
n.
3.5
5
Ta
ble
12
.1 o
f th
e S
tud
y s
ets
ou
t C
IL c
ha
rgin
g r
ate
s (w
he
re a
do
pte
d)
for
are
as
slig
htl
y m
ore
an
d
slig
htl
y l
ess
exp
en
siv
e (i
n t
erm
s o
f a
ve
rag
e h
ou
se p
rice
s) t
ha
n J
ers
ey,
fro
m O
xfo
rd (
£4
75
,73
2)
to
Win
ches
ter
(£4
32
,55
7).
Ho
wev
er,
to
un
der
sta
nd
wh
eth
er t
hes
e a
re a
pp
rop
ria
te c
om
pa
rato
rs f
or
Jer
sey
(w
hic
h i
n p
rin
cip
le,
we
con
sid
er
they
are
no
t) i
t is
nec
essa
ry t
o u
nd
erst
an
d w
ha
t ev
iden
ce
ha
s u
nd
erp
inn
ed t
hes
e C
IL c
ha
rges
. A
ve
rag
e h
ou
se p
rice
s in
iso
lati
on
are
no
t a
n a
pp
rop
ria
te
com
pa
rato
r fo
r C
IL c
ha
rges
; a
rea
s w
ith
sim
ila
r a
ver
ag
e h
ou
se p
rice
s w
ill
ha
ve
va
ryin
g
resi
den
tia
l la
nd
va
lues
an
d b
uil
d c
ost
s, a
nd
wit
hin
lo
cal
au
tho
rity
are
as
ther
e a
re o
ften
va
ryin
g
CIL
ra
tes.
Th
is i
s ev
iden
t, f
or
exa
mp
le,
in K
ensi
ng
ton
an
d C
hel
sea
(th
e m
ost
ex
pe
nsi
ve
loca
l
au
tho
rity
in
En
gla
nd
) w
her
e C
IL r
ate
s a
re a
ctu
all
y n
il i
n s
om
e p
art
s o
f th
e B
oro
ug
h.
3.5
6
Th
e S
tud
y g
ives
th
e e
xa
mp
le o
f S
ou
th O
xfo
rdsh
ire
6 w
hic
h h
as
a C
IL c
ha
rge
of
£8
5-£
150
/sq
m f
or
ho
usi
ng
an
d £
70
fo
r su
per
ma
rket
s. A
lth
ou
gh
ha
vin
g a
sim
ila
r a
ver
ag
e h
ou
se p
rice
to
Jer
sey
,
av
era
ge
resi
den
tia
l la
nd
va
lues
are
mu
ch l
ow
er i
n S
ou
th O
xfo
rdsh
ire
th
an
th
e a
ver
ag
e w
hic
h h
as
bee
n u
sed
in
th
e V
iab
ilit
y S
tud
y (
at
£3
.7m
/ha
7)
wh
ich
is
at
the
low
er e
nd
of
the
ran
ge
see
n i
n
Jer
sey
. L
an
d v
alu
es f
or
oth
er t
yp
es o
f la
nd
(e
.g.
off
ice
spa
ce)
are
als
o s
ub
sta
nti
all
y l
ow
er t
ha
n i
n
Jer
sey
, fo
r ex
am
ple
sit
es i
n c
urr
ent/
his
tori
c em
plo
ym
en
t u
se i
n S
ou
th O
xfo
rdsh
ire
are
va
lued
bet
we
en £
32
5k
/ha
to
£7
50
k/h
a.
Th
is i
s li
kel
y t
o r
efle
ct S
ou
th O
xfo
rdsh
ire’
s lo
cati
on
, w
ith
off
ice
dem
an
d b
ein
g c
on
cen
tra
ted
wit
hin
Ox
ford
an
d R
ead
ing
(i.
e.
ne
igh
bo
uri
ng
au
tho
riti
es).
Bu
ild
cost
s a
re a
lso
lo
wer
in
So
uth
Ox
ford
shir
e th
an
in
Jer
sey
, m
ean
ing
th
ere
is l
ikel
y t
o b
e m
ore
sco
pe
for
CIL
co
ntr
ibu
tio
ns.
3.5
7
Th
e S
ou
th O
xfo
rdsh
ire
Via
bil
ity
Ass
essm
ent
incl
ud
es a
10
% a
llo
wa
nce
fo
r co
nti
ng
ency
(d
ou
ble
tha
t u
sed
in
th
e J
erse
y S
tud
y)
an
d a
fu
rth
er
6%
fo
r m
eeti
ng
Co
de
for
Su
sta
ina
ble
Ho
mes
. A
s
sta
ted
ab
ov
e th
e V
iab
ilit
y S
tud
y a
lrea
dy
un
der
-est
ima
tes
bu
ild
co
sts
in J
erse
y,
an
d w
ere
sim
ila
r
cost
s (t
o t
ho
se a
pp
lied
in
So
uth
Ox
ford
shir
e) t
o b
e in
clu
ded
wit
hin
th
e V
iab
ilit
y,
it i
s li
kel
y t
he
sco
pe
for
intr
od
uct
ion
of
a J
IL w
ou
ld f
urt
her
be
red
uce
d.
3.5
8
It i
s cl
ear
tha
t w
hil
st J
erse
y h
as
sim
ila
r a
ver
ag
e h
ou
se p
rice
s to
th
e ex
am
ple
s g
ive
n o
f lo
cal
au
tho
riti
es i
n E
ng
lan
d,
com
pa
riso
ns
of
CIL
ch
arg
es i
n t
ho
se a
uth
ori
ties
(o
r ev
en
th
e ex
iste
nce
of
a C
IL c
ha
rge
alt
og
eth
er)
do
es n
ot
sup
po
rt t
he
exis
ten
ce o
f C
IL c
ha
rge
in J
erse
y8 .
6 S
ou
th O
xfo
rdsh
ire
CIL
Via
bili
ty S
tud
y -
htt
p:/
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w.s
ou
tho
xon
.go
v.u
k/si
tes/
def
ault
/file
s/C
IL%
20
Via
bili
ty%
20
stu
dy%
20
Oct
%2
02
01
4.p
df
7 S
ou
rce:
DC
LG L
and
Val
ue
Esti
mat
es f
or
Po
licy
Ap
pra
isal
htt
p:/
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lest
atea
pp
rais
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o.u
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p-c
on
ten
t/u
plo
ads/
20
13
/07
/201
5-
DC
LG-L
and
-Val
ue-
Esti
mat
es.p
df
8 A
lth
ou
gh t
he
Stu
dy
corr
ectl
y n
ote
s in
En
glan
d a
ffo
rdab
le h
ou
sin
g is
req
uir
ed o
n n
ew m
arke
t d
eve
lop
men
ts, t
he
leve
l of
affo
rdab
le h
ou
sin
g se
t w
ith
in a
Lo
cal P
lan
is it
self
su
bje
ct t
o v
iab
ility
tes
tin
g, a
nd
var
ies
bet
wee
n lo
cal a
uth
ori
ty a
reas
. Th
is w
ill
fact
or
in b
uild
co
sts,
sal
es
valu
es a
nd
dev
elo
per
pro
fit
wh
ich
var
y to
Jer
sey
hen
ce d
o n
ot
pro
vid
e a
dir
ect
co
mp
aris
on
.
Su
mm
ar
y
Th
e co
mp
ara
tor
au
tho
riti
es f
rom
En
gla
nd
pre
sen
ted
in
th
e S
tud
y m
ust
be
see
n i
n t
he
con
tex
t
of
exa
ctly
wh
at
ev
iden
ce a
nd
ass
um
pti
on
s u
nd
erp
in t
ho
se C
IL c
ha
rges
, n
ot
just
a s
imp
le
com
pa
riso
n o
f a
ve
rag
e h
ou
se p
rice
s. T
he
low
er l
an
d v
alu
es i
n S
ou
th O
xfo
rdsh
ire
, fo
r
exa
mp
le,
are
lik
ely
to
co
ntr
ibu
te t
o t
he
sco
pe
for
CIL
, a
nd
su
ch f
act
ors
wil
l v
ary
be
twee
n
are
as.
Th
ese
do
no
t su
pp
ort
th
e im
ple
men
tati
on
of
a J
IL i
n J
erse
y.
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 20
4.0
C
on
clu
sio
ns
4.3
R
egre
tta
bly
, th
e V
iab
ilit
y S
tud
y i
s n
ot
a r
ob
ust
ass
essm
ent
of
via
bil
ity
in
Jer
sey
up
on
wh
ich
to
set
a J
IL c
ha
rge
. N
otw
ith
sta
nd
ing
th
at
the
JeC
C c
on
sid
ers
the
pri
nci
ple
of
a J
IL o
n t
he
Isla
nd
itse
lf t
o b
e n
ot
po
ssib
le,
we
ha
ve
iden
tifi
ed a
nu
mb
er o
f fl
aw
s w
ith
in t
he
Stu
dy
. M
ost
of
thes
e
crit
icis
ms
alo
ne
wo
uld
un
der
min
e th
e p
rop
ose
d J
IL;
ho
wev
er,
wh
en
co
nsi
der
ed i
n c
om
bin
ati
on
,
they
dem
on
stra
te t
he
de
gre
e to
wh
ich
via
bil
ity
ha
s b
een
ov
erst
ate
d f
or
the
Isla
nd
. In
su
mm
ary
:
1 T
he
alt
ern
ati
ve
use
va
lue
of
mo
st o
f th
e si
tes
ass
esse
d i
s b
ase
d o
n a
n a
ssu
mp
tio
n o
f
ind
ust
ria
l v
alu
e;
ho
we
ver
, th
e S
tud
y h
as
no
ev
ide
nce
to
su
pp
ort
th
is f
igu
re;
2
Wit
h t
he
exce
pti
on
of
a f
ew s
chem
es,
the
Stu
dy
ass
esse
s a
ll b
row
nfi
eld
sit
es a
s b
ein
g i
n
ind
ust
ria
l u
se,
des
pit
e th
e f
act
th
at
in J
erse
y b
row
nfi
eld
sit
es a
re l
ikel
y t
o b
e o
ther
use
s
wh
ich
ma
y h
av
e h
igh
er v
alu
es.
Th
is i
ncl
ud
es h
ote
l si
tes,
ret
ail
sp
ace
an
d o
ffic
e sp
ace
, w
hic
h
ha
ve
a h
igh
er v
alu
e,
an
d a
s su
ch t
he
Stu
dy
ha
s fa
iled
to
ass
ess
the
typ
es o
f si
te w
hic
h a
re
lik
ely
to
co
me
fo
rwa
rd.
Th
e S
tud
y a
ccep
ts t
ha
t th
e in
du
stri
al
va
lue
ma
y b
e lo
w a
nd
sit
es
ma
y b
e i
n o
ther
use
s, b
ut
it f
ail
s to
ca
rry
fo
rwa
rd a
ny
of
thes
e o
bse
rva
tio
ns
into
its
via
bil
ity
mo
del
lin
g.
Ou
r es
tim
ati
on
of
lan
d v
alu
es o
f se
con
da
ry r
eta
il s
pa
ce s
ho
ws
tha
t th
e re
sid
ua
l
va
lues
wo
uld
no
t su
ffic
ien
tly
ex
ceed
th
e v
iab
ilit
y t
hre
sho
ld a
cro
ss m
ost
dev
elo
pm
en
ts;
3
Th
e v
iab
ilit
y t
hre
sho
ld u
sed
in
th
e S
tud
y a
ssu
mes
a 2
0%
up
lift
on
ex
isti
ng
va
lue
wo
uld
ince
nti
vis
e a
la
nd
ow
ner
to
sel
l. I
t is
qu
esti
on
ab
le h
ow
, in
th
e ca
se o
f J
erse
y,
it i
s p
oss
ible
to
det
erm
ine
such
a v
alu
e, g
iven
th
e sp
ecif
ic t
ax
an
d l
an
d o
wn
ersh
ip c
ircu
mst
an
ces
on
th
e
Isla
nd
, w
hic
h v
ary
co
mp
are
d t
o t
he
UK
. J
eC
C m
em
ber
s cl
ari
fy t
ha
t a
sig
nif
ica
nt
pre
miu
m i
s
oft
en r
equ
ired
, to
ref
lect
ta
xes
an
d p
rofi
t m
arg
ins.
It
is a
lso
lik
ely
th
at
the
pre
miu
m w
ill
va
ry d
epen
din
g o
n t
he
typ
e o
f la
nd
, w
ith
ow
ner
s o
f p
ad
do
ck l
an
d l
ikel
y t
o d
ema
nd
a m
uch
hig
her
pre
miu
m g
iven
th
e a
men
ity
va
lue
of
such
la
nd
. In
Lo
nd
on
, su
bje
ct t
o U
K-
ass
um
pti
on
s, t
he
Ma
yo
r’s
late
st a
ffo
rda
ble
ho
usi
ng
SP
D a
ssu
mes
an
up
lift
to
EU
V o
f u
p t
o
30
% a
nd
its
eff
ect
on
ma
rket
be
ha
vio
ur
is s
o f
ar
un
test
ed;
an
d
4
Th
e co
nst
ruct
ion
co
sts
are
lik
ely
to
be
a s
ign
ific
an
t u
nd
er-e
stim
ate
, n
ot
lea
st b
eca
use
BC
IS
da
ta h
as
lim
ited
in
form
ati
on
wh
ich
dir
ectl
y r
ela
tes
to J
erse
y.
Sta
keh
old
ers
sug
ges
ted
hig
he
r
fig
ure
s d
uri
ng
co
nsu
lta
tio
n,
an
d f
igu
res
pu
t to
Lic
hfi
eld
s b
y m
emb
ers
of
the
Je
CC
(b
ase
d o
n
loca
l Q
S s
urv
eys)
dem
on
stra
te t
ha
t th
e u
nd
eres
tim
ati
on
in
bu
ild
co
sts
alo
ne
wo
uld
en
tire
ly
wip
e o
ut
an
y p
ote
nti
al
JIL
co
ntr
ibu
tio
n;
Ad
dit
ion
al
calc
ula
tio
ns
un
der
tak
en b
y t
he
Je
CC
of
Sit
es
3 a
nd
4 s
ho
w t
ha
t co
rrec
tin
g
for
con
stru
ctio
n c
ost
s (a
mo
ng
st o
ther
err
ors
) w
ou
ld r
esu
lt i
n a
ret
urn
on
in
ves
tme
nt
of
1% t
o 5
% o
n b
row
nfi
eld
sit
es
of
12-2
0 u
nit
s –
cle
arl
y t
his
is
un
via
ble
. O
ur
ow
n
ass
essm
ent
usi
ng
th
e H
CA
ap
pra
isa
l to
ol
va
lid
ate
th
e J
eCC
’s a
sses
sme
nts
.
Re
co
mm
en
da
tio
ns
4.4
N
otw
ith
sta
nd
ing
ou
r co
nce
rns
ab
ou
t th
e o
ver
all
pri
nci
ple
of
a J
IL (
as
set
ou
t in
ou
r m
ain
rep
rese
nta
tio
ns)
, in
th
e ev
en
t th
at
the
Sta
tes
of
Jer
sey
dec
ide
s n
on
eth
eles
s to
co
nti
nu
e w
ith
pre
pa
rati
on
of
a J
IL c
ha
rge,
we
ha
ve
iden
tifi
ed a
nu
mb
er o
f si
gn
ific
an
t fl
aw
s w
ith
in t
he
Via
bil
ity
Stu
dy
wh
ich
sh
ou
ld b
e c
orr
ecte
d.
Th
ese
are
ess
en
tia
l in
ord
er f
or
the
Sta
tes
to d
emo
nst
rate
s th
at
an
y p
rop
ose
d J
IL c
ha
rge
is u
nd
erp
inn
ed b
y s
uit
ab
le a
nd
ro
bu
st e
vid
ence
(w
hic
h,
at
pre
sen
t, w
e
bel
iev
e is
no
t) T
he
fla
ws
sho
uld
be
rem
edie
d b
y t
he
foll
ow
ing
:
1 T
es
t b
ro
wn
fie
ld s
ite
s b
as
ed
on
a r
an
ge
of
ex
isti
ng
us
es
, in
clu
din
g o
ffic
e, r
eta
il a
nd
ho
tel
use
s, w
hic
h a
re m
ore
ref
lect
ive
of
the
site
ty
po
log
ies
lik
ely
to
co
me
forw
ard
in
th
e P
lan
per
iod
;
2
Se
ns
itiv
ity
te
st
thes
e v
alu
es t
o a
llo
w f
or
hig
her
via
bil
ity
th
resh
old
s, r
efle
ctin
g t
he
gre
ate
r
ince
nti
ve
oft
en n
eed
ed t
o m
ak
e a
sa
le a
nd
th
e ta
xes
wh
ich
ap
ply
to
pro
fits
;
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Pg
21
3
Co
nsu
lt w
ith
sta
ke
ho
lder
s a
nd
lo
cal
qu
an
tity
su
rvey
or
firm
s to
re
ac
h a
nd
ag
re
ed
co
ns
en
su
s o
f b
uil
d c
os
ts o
n t
he
isla
nd
, in
clu
din
g s
en
sit
ivit
y t
es
tin
g t
o t
his
;
4
Pro
vid
e si
gn
ific
an
tly
gre
ate
r cl
ari
ty o
ver
th
e re
lati
on
ship
of
JIL
wit
h P
OA
s a
nd
th
e
infr
ast
ruct
ure
to
be
fun
ded
by
ea
ch t
o a
vo
id p
ote
nti
al
for
ac
tua
l o
r p
er
ce
ive
d ‘
do
ub
le
dip
pin
g’
4.5
O
nce
th
e a
bo
ve
ha
ve
bee
n c
orr
ecte
d a
nd
ag
reed
up
on
by
all
pa
rtie
s, w
e c
on
sid
er t
ha
t th
ese
wil
l
dem
on
stra
te i
t is
no
t p
oss
ible
to
im
ple
me
nt
a J
IL w
ith
ou
t u
nd
erm
inin
g t
he
Isla
nd
Pla
n.
In t
he
even
t th
at
this
do
es d
em
on
stra
ted
im
ple
men
tati
on
of
a J
IL m
ay
be
po
ssib
le,
it i
s li
kel
y t
o b
e
sig
nif
ica
ntl
y l
ow
er
tha
n t
he
lev
el c
urr
entl
y p
rop
ose
d,
an
d m
ay
dem
on
stra
te t
ha
t in
cer
tain
are
as
(e.g
. w
ith
in b
uil
t-u
p a
rea
s) o
r sp
ecif
ic t
yp
es
of
site
a n
il J
IL r
ate
sh
ou
ld b
e im
po
sed
.
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 22
Ap
pe
nd
ix 1
: O
utp
uts
of
HC
A D
ev
elo
pm
en
t A
pp
ra
isa
l T
oo
l fo
r R
LV
Ca
lcu
lati
on
s
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t
Pg
23
Ou
tpu
ts –
Je
CC
ass
um
pti
on
s, w
ith
Via
bil
ity
Stu
dy
bu
ild
co
sts
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sid
ua
l L
an
d v
alu
ati
on
£0
HC
A D
EV
EL
OP
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NT
AP
PR
AIS
AL
TO
OL
SC
HE
ME
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dre
ss
Je
rse
yD
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of a
pp
rais
al
27
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entia
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a (
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t sp
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retu
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void
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etu
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lue
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r he
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cta
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er
acre
Pre
ss f
or
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gle
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ge
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ary
Pre
ss f
or
4 p
ag
e d
eta
il
Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 24
Ou
tpu
ts –
Je
CC
ass
um
pti
on
s, w
ith
Via
bil
ity
Stu
dy
bu
ild
co
sts,
in
clu
din
g J
IL
Re
sid
ua
l L
an
d v
alu
ati
on
£0
HC
A D
EV
EL
OP
ME
NT
AP
PR
AIS
AL
TO
OL
SC
HE
ME
Site
Ad
dre
ss
Je
rse
yD
ate
of a
pp
rais
al
27
/03
/20
17
Site
Re
fere
nce
Ne
t R
esid
entia
l Site
Are
a (
he
cta
res)
0.3
84
File
So
urc
eA
uth
or
& O
rga
nis
atio
n
Sche
me
De
scri
ptio
n2
0 u
nit b
row
nfie
ld s
ite
Re
gis
tere
d P
rovi
de
r (w
he
re a
pp
lica
ble
)0
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PIT
AL
VA
LU
E O
F O
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N M
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Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
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of
Via
bili
ty A
sses
smen
t
Pg
29
Ap
pe
nd
ix 2
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pu
ts a
nd
as
su
mp
tio
ns
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r
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rp
lus
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fic
it c
alc
ula
tio
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Jers
ey In
fras
tru
ctu
re L
evy
Pro
po
sal :
Rev
iew
of
Via
bili
ty A
sses
smen
t P
g 30
Tab
le 4
.1 C
om
par
iso
n o
f as
sum
pti
on
s in
Via
bili
ty S
tud
y an
d L
ich
fiel
ds
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essm
ent
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iab
ility
Stu
dy
Lich
fie
lds
Via
bili
ty T
hre
sho
ld
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.28
m/h
a £
2.2
8m
/ha
/ va
riab
le
Res
iden
tial
un
it m
ix, s
ize
and
val
ue
A
s p
er A
pp
end
ix 6
of
Via
bili
ty S
tud
y
Bu
ild c
ost
s p
er s
qm
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r fl
ats
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or
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r fl
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or
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fess
ion
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r A
rt
No
ne
0.7
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nti
nge
ncy
5
%
10
%
Infr
astr
uct
ure
per
sq
m
As
per
Ap
pen
dix
6 o
f V
iab
ility
Stu
dy
Site
pu
rch
ase
lega
l fee
s 1
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Inte
rest
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gal
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Stam
p D
uty
A
s p
er A
pp
end
ix 6
of
Via
bili
ty S
tud
y
Cyc
ling
into
St
Hel
ier
A J
erse
y in
Tra
nsiti
on S
usta
inab
le T
rans
port
Gro
up tr
affic
su
rvey
, Ju
ly 2
017
Surv
ey r
ep
ort
, 1
3 July
20
17
Copyri
ght
© 2
017
Jers
ey in T
ransi
tion.
Publis
hed
un
der
a C
reati
ve C
om
mons
Att
rib
uti
on
4.0
In
tern
ati
onal Li
cense
.C
onta
ct n
igel@
mis
tweb.n
et
or
Ruth
at
rolls
3@
mac.
com
Su
mm
ary
On
Tue
sday
4 J
uly
2017
, on
a dr
y, m
ild, s
umm
er m
orni
ng, v
olun
teer
s fr
om J
erse
y in
Tra
nsit
ion
repe
ated
the
cycl
e su
rvey
that
the
orga
nisa
tion
had
car
ried
out
on
Tue
sday
24
Janu
ary
the
sam
e ye
ar. T
he to
tal n
umbe
r of
cyc
lists
com
ing
into
St H
elie
r be
twee
n 8
and
9 am
had
incr
ease
d by
60%
to
a to
tal o
f 61
6. T
hese
cyc
list
s re
pres
ent a
sig
nifi
cant
ass
et to
Jer
sey
life
as th
eir
effo
rts
redu
ce th
e am
ount
of
road
traf
fic
and
cong
estio
n. T
hey
impr
ove
the
air
qual
ity f
or e
very
one,
they
red
uce
the
num
ber
of c
ar p
arks
we
need
in S
t Hel
ier
and
they
are
fitt
er, m
ore
read
y fo
r a
busy
day
’s w
ork,
and
le
ss o
f a
burd
en o
n th
e he
alth
ser
vice
s no
w a
nd in
the
futu
re, t
han
if th
ey h
ad d
rive
n in
in th
eir
cars
.
We
are
surp
rise
d th
at th
e co
mpa
riso
n be
twee
n w
inte
r an
d su
mm
er c
yclin
g w
as o
nly
a 60
% in
crea
se.
We
wou
ld h
ave
expe
cted
a d
oubl
ing
or tr
eblin
g. W
e ar
e ke
en to
ask
– to
sta
rt a
nd to
join
the
deba
te
abou
t – w
hat c
an b
e do
ne to
enc
oura
ge m
ore
peop
le o
f al
l age
s to
cyc
le to
wor
k, s
choo
l, sh
oppi
ng
and
leis
ure.
The
re is
con
side
rabl
e re
sear
ch o
n th
e su
bjec
t wor
ldw
ide,
as
virt
ually
eve
ry c
ount
ry a
nd
city
is a
skin
g th
e sa
me
ques
tion.
The
pot
enti
al b
enef
its f
or th
e ec
onom
y, f
or in
divi
dual
s, a
nd f
or th
e en
viro
nmen
t, ar
e hu
ge, a
nd s
ome
othe
r m
ajor
juri
sdic
tions
are
way
ahe
ad o
f us
her
e in
Jer
sey.
Rat
ion
ale
Thi
s su
rvey
is a
rep
eat o
f th
e ‘C
yclin
g in
to S
t Hel
ier’
sur
vey
carr
ied
out i
n Ja
nuar
y 20
17 b
y Je
rsey
in
Tra
nsiti
on. T
he p
urpo
se is
to p
rovi
de c
ompa
rativ
e da
ta in
the
sam
e ye
ar f
rom
win
ter
to s
umm
er
usin
g, a
s fa
r as
pos
sibl
e, id
entic
al m
etho
dolo
gy.
2
In th
e re
port
of
the
Janu
ary
surv
ey, w
e w
rote
abo
ut
the
mis
sed
targ
et in
201
5 to
hav
e re
duce
d pe
ak
hour
mot
oris
ed tr
affi
c by
15%
, with
onl
y 1.
6%
achi
eved
. We
wro
te a
bout
the
was
te r
epre
sent
ed b
y th
ousa
nds
of p
eopl
e fo
r sc
ores
on
min
utes
eac
h da
y sa
t in
cars
in h
eavi
ly c
onge
sted
traf
fic.
We
also
w
rote
abo
ut th
e gr
eenh
ouse
gas
es, a
nd th
eir
effe
ct
on J
erse
y m
eeti
ng it
s gl
obal
war
min
g co
mm
itmen
ts.
We
high
light
ed a
ir q
uali
ty p
robl
ems
for
mot
oris
ts,
cycl
ists
, ped
estr
ians
and
res
iden
ts, e
spec
ially
with
re
gard
to th
e 20
14 R
icar
do-A
EA
rep
ort ‘
Air
qu
alit
y m
onit
orin
g in
Jer
sey.
’ At t
he ti
me,
the
gov.
je a
ir q
uali
ty m
onito
ring
res
ults
pag
e sh
owed
tw
o er
ror
mes
sage
s. T
oday
, alt
houg
h it
has
wor
ked
in th
e m
eant
ime,
onl
y on
e se
t of
live
resu
lts
is
avai
labl
e. S
ince
the
last
rep
ort,
ther
e ha
s be
en ta
lk
of e
stab
lishi
ng m
ore
air
qual
ity m
onito
ring
poi
nts
in S
t Hel
ier,
and
even
of
atta
chin
g m
onito
ring
eq
uipm
ent t
o bu
ses
so th
at is
land
-wid
e m
easu
rem
ents
are
obt
aine
d. J
erse
y in
Tra
nsit
ion
wou
ld
wel
com
e su
ch in
itia
tives
, and
we
hope
that
the
talk
will
soo
n re
sult
in a
ctio
n.
Six
mon
ths
ago,
we
wro
te a
bout
the
harm
that
pol
luti
on le
vels
bey
ond
EU
dir
ectiv
es d
o th
e re
puta
tion
of J
erse
y as
a s
elf-
gove
rnin
g ju
risd
icti
on, a
nd a
lso
abou
t the
har
m th
at s
uch
leve
ls d
o to
th
e he
alth
of
loca
l res
iden
ts –
and
the
actu
al c
osts
of
this
in te
rms
of h
ealt
h sp
endi
ng, q
uite
apa
rt
from
the
redu
ctio
n in
peo
ple’
s qu
ality
of
life.
Fin
ally
we
wro
te a
bout
the
heal
th b
enef
its o
f cy
clin
g ac
cord
ing
to U
K N
HS
and
oth
er m
edic
al
evid
ence
. The
y ar
e co
nsid
erab
le c
ompa
red
to th
e se
dent
ary
lifes
tyle
of
a tr
uly
com
mitt
ed m
otor
ist.
We
stan
d by
our
pre
viou
s co
mm
ents
, and
ref
er th
e re
ader
to th
e ea
rlie
r re
port
for
fur
ther
det
ails
and
ci
tati
ons.
3
Met
ho
do
log
y
Exa
ctly
as
in J
anua
ry 2
017,
Jer
sey
in T
rans
itio
n vo
lunt
eers
sto
od a
t all
the
maj
or r
oute
s w
here
a
cycl
ist m
ay e
nter
St H
elie
r. C
ycli
sts
pass
ing
each
che
ckpo
int,
com
ing
into
tow
n be
twee
n 8.
00 a
nd
9.00
am
on
Tue
sday
24
Janu
ary
2017
wer
e co
unte
d. I
llust
ratio
n 1
show
s th
e po
siti
ons
of th
e ch
eckp
oint
s. C
ycli
sts
wer
e co
unte
d co
min
g in
to to
wn
at th
e fo
llow
ing
loca
tions
.
4
Illu
stra
tion
1:
Red
sta
rs m
ark
the
surv
ey c
heck
poin
ts, o
n al
l the
maj
or r
oads
com
ing
into
St H
elie
r. T
hank
s to
Ope
n St
reet
Map
for
the
map
.
1.O
n th
e W
este
rn C
ycle
Pat
h, b
esid
e th
e se
awal
l at W
est P
ark
2.O
n th
e In
ner
Roa
d, a
t the
Wes
t Par
k bu
s sh
elte
r3.
On
Que
ens
Roa
d, ju
st b
efor
e th
e ro
unda
bout
4.O
n T
rini
ty H
ill, n
ear
the
Rob
in H
ood
pub
5.O
n S
t Sav
iour
s H
ill, o
ppos
ite
the
turn
off
to T
he B
ridg
e6.
On
Mon
t Mill
ais,
bef
ore
the
light
s ne
ar H
owar
d D
avis
Par
k7.
On
Rou
te d
u Fo
rt, n
ear
the
new
Pol
ice
Sta
tion
8.A
t Hav
re d
es P
as, n
ear
the
bath
ing
pool
, bef
ore
For
t d’A
uver
gne
For
the
purp
ose
of th
e su
rvey
, cyc
lists
incl
uded
thos
e on
ele
ctri
c bi
cycl
es a
nd o
ne-f
oot s
coot
ers.
Tw
o pe
ople
on
a ta
ndem
wou
ld b
e co
unte
d as
two
cycl
ists
.
Vol
unte
ers
wer
e pr
ovid
ed w
ith ‘
clic
ker’
tally
-cou
nter
s an
d as
ked
to r
ecor
d th
e w
eath
er, t
he n
umbe
r of
cyc
lists
cou
nted
, and
any
com
men
ts o
r an
ecdo
tes.
Re
sult
sT
he w
eath
er w
as m
ild
and
clou
dy w
ith o
ccas
iona
l sun
ny p
erio
ds, 1
6 to
18
degr
ees
C, w
ith n
o ra
in
and
littl
e w
ind.
The
che
ckpo
int c
ount
s w
ere
as f
ollo
ws
Ch
eck
poi
nt
Cou
nt
of c
ycli
sts,
8 –
9 a
m
Jan
uar
y 20
17Ju
ly 2
017
Incr
ease
Cyc
le p
ath
at W
est P
ark
199
312
57%
Inne
r R
oad
2233
50%
Que
ens
Roa
d13
2912
3%
Tri
nity
Hill
5479
46%
St S
avio
urs
Hill
1227
125%
Mon
t Mill
ais
1221
75%
Rou
te d
u F
ort
3752
41%
Hav
re d
es P
as37
6370
%
Tot
al38
661
660
%
Imp
ress
ion
s an
d a
nec
do
tes
The
vol
unte
ers
at W
est P
ark
bus
shel
ter
on th
e In
ner
Roa
d, o
n th
e W
este
rn C
ycle
Pat
h at
Vic
tori
a A
venu
e an
d on
Que
ens
Roa
d no
ted
larg
e nu
mbe
rs o
f pe
dest
rian
s w
alki
ng in
to to
wn,
som
etim
es
sign
ific
antl
y m
ore
than
the
cycl
ists
. Vol
unte
ers
at Q
ueen
s R
oad,
Mon
t Mill
ais
and
Hav
re d
es P
as
rem
arke
d on
the
heav
y m
otor
ised
traf
fic.
Air
qua
lity
was
men
tione
d by
vol
unte
ers
at V
icto
ria
Ave
nue
and
‘fum
es a
nd th
e sm
ell o
f pe
trol
’ on
St S
avio
urs
Hill
.
Sev
eral
vol
unte
ers
note
d th
e no
ise,
bus
tle, ‘
mad
ness
’ and
intim
idat
ory
natu
re o
f th
e bu
sy r
oads
. M
any
cycl
ists
cho
se to
‘ta
ke th
e la
ne’ a
nd c
ycle
in a
mon
gst t
he m
ovin
g tr
affi
c. T
his
mea
nt th
at th
ey
5
wer
e tr
avel
ling
fas
t and
clo
se to
car
s an
d pe
dest
rian
s, d
epen
dent
for
thei
r sa
fety
on
the
deci
sion
s of
m
any
othe
r ro
ad u
sers
. In
othe
r ca
ses,
incl
udin
g th
e co
mpl
icat
ed ju
nctio
n at
the
botto
m o
f M
ont
Mill
ais
arou
nd th
e ga
tes
to H
owar
d D
avie
s P
ark,
and
at H
avre
des
Pas
, in
desp
erat
ion
cycl
ists
wer
e se
en to
use
ped
estr
ian
cros
sing
s an
d pa
vem
ents
to a
void
wai
ting
for
the
light
s, a
nd a
lso
pres
umab
ly
for
safe
ty, f
eeli
ng th
reat
ened
in th
e bu
stlin
g tr
affi
c fl
ows.
Oth
er c
omm
ents
incl
uded
the
larg
e nu
mbe
rs o
f si
ngle
-occ
upan
cy c
ars
and
the
lack
of
cycl
e he
lmet
s on
Tri
nity
Hill
and
at H
avre
des
Pas
, and
the
disa
ppoi
ntin
g to
tal a
bsen
ce o
f ch
ildr
en c
yclin
g on
the
Wes
tern
Cyc
le P
ath.
Man
y of
the
com
men
ts m
ade
appl
ied
on o
ther
rou
tes
too,
but
we
can
only
rep
ort t
he r
emar
ks w
e re
ceiv
ed.
Co
ncl
usi
on
s an
d r
eco
mm
end
atio
ns
We
wer
e su
rpri
sed
that
the
over
all i
ncre
ase
in c
yclin
g fr
om w
inte
r to
sum
mer
was
so
smal
l, on
ly
60%
. We
expe
cted
, with
the
war
mer
wea
ther
and
with
ext
ra d
aylig
ht d
urin
g bo
th d
aily
com
mut
ing
tim
es, t
hat n
umbe
rs o
f cy
clis
ts w
ould
at l
east
dou
ble
if n
ot tr
eble
. It a
ppea
rs th
at J
erse
y ha
s a
stal
war
t gro
up o
f co
mm
itte
d cy
cle
com
mut
ers
who
bra
ve a
ll w
eath
ers
and
seas
ons,
and
not
that
m
any
fair
-wea
ther
cyc
lists
who
wai
t for
the
mild
mor
ning
s an
d lo
ng w
arm
eve
ning
s.
The
larg
e in
crea
se in
ped
estr
ian
com
mut
ing
in th
e su
mm
er w
as in
tere
stin
g. F
or a
giv
en jo
urne
y le
ngth
, the
re is
mor
e ex
erci
se to
be
had
wal
king
than
cyc
ling.
Ped
estr
ians
are
als
o fe
el n
atur
ally
sa
fer,
bein
g in
here
ntly
allo
wed
on
the
pave
men
ts a
nd b
eing
pro
vide
d w
ith s
afe
and
esta
blis
hed
road
cr
ossi
ngs.
The
ran
king
of
the
rout
es, i
n te
rms
of c
yclin
g po
pula
rity
, did
not
cha
nge
from
win
ter
to s
umm
er.
Mon
t Mill
ais
and
St S
avio
urs
Hill
are
the
leas
t cyc
led,
but
sin
ce th
ey c
ombi
ne a
t Fiv
e O
aks,
they
ac
tual
ly s
erve
the
sam
e se
ctor
of
the
isla
nd a
nd s
o th
at is
pro
babl
y no
t sur
pris
ing.
In d
istin
ctio
n to
the
Wes
tern
Cyc
le P
ath,
mos
t of
the
nort
hern
and
eas
tern
rou
tes
into
St H
elie
r ar
e bi
g, d
ange
rous
hill
s an
d ro
ads,
with
litt
le p
rovi
sion
for
cyc
lists
. Res
earc
h ha
s sh
own
that
peo
ple
who
do
not c
urre
ntly
cyc
le s
ay, w
hen
aske
d, th
at th
ey d
o no
t wan
t to
cycl
e m
ixed
with
hea
vy
mot
oris
ed tr
affi
c, th
at th
ey f
ind
heav
y tr
affi
c in
timid
atin
g, a
nd th
at th
ey w
ant s
ubje
ctiv
ely
to f
eel
safe
whe
n cy
clin
g.1 2
Sho
rt o
f co
veri
ng J
erse
y’s
coun
trys
ide
in m
ore
tarm
ac, o
r pu
rcha
sing
pre
mis
es a
nd g
arde
ns to
w
iden
roa
ds, t
he o
nly
way
s to
giv
e cy
clis
ts m
ore
spac
e –
spac
e th
at is
and
that
fee
ls s
afe
– is
to ta
ke
som
e co
nven
ienc
e aw
ay f
rom
som
e m
otor
ists
. Min
or la
nes
in th
e co
untr
ysid
e th
at d
o no
t see
muc
h tr
affi
c ca
n be
clo
sed
alto
geth
er to
mot
oris
ed tr
affi
c an
d tu
rned
into
cyc
le la
nes.
If
thes
e ar
e jo
ined
up
and
ser
ve u
sefu
l rou
tes,
then
cyc
lists
will
use
them
, and
mot
oris
ed tr
affi
c w
ill r
educ
e ac
cord
ingl
y.
1U
nder
stan
ding
wal
king
and
cyc
ling
, Lan
cast
er E
nvir
onm
ent C
entr
e, L
anca
ster
Uni
vers
ity.
201
12
Res
pons
e to
all
-par
ty p
arli
amen
tary
cyc
ling
gro
up in
quir
y, ‘
Get
Bri
tain
Cyc
ling
’, C
ycli
ng E
mba
ssy
of G
reat
B
rita
in. 2
013
6
Suc
h a
prog
ram
of
conv
ersi
on c
an b
e ph
ased
in. F
irst
of
all t
he c
losu
re to
mot
or tr
affi
c ca
n be
at
peak
tim
es o
nly.
Peo
ple
who
act
uall
y liv
e on
thes
e la
nes
can
be g
iven
res
iden
ts’ p
erm
its
allo
win
g th
em to
dri
ve o
nly
to a
nd f
rom
thei
r ho
mes
, per
haps
with
a s
peed
lim
it s
uch
as 1
5 m
ph. I
f th
e sc
hem
e is
suc
cess
ful,
the
hour
s ca
n be
ext
ende
d up
to 2
4x7,
and
the
resi
dent
s’ p
erm
its
may
beg
in to
re
quir
e a
fee
(aft
er a
ll, th
e re
side
nts
live
on a
cyc
le p
ath:
they
may
con
side
r ta
king
up
cycl
ing)
. T
here
will
alw
ays
be e
xcep
tions
for
em
erge
ncy
vehi
cles
, hom
e re
mov
als,
larg
e de
liver
ies
and
so o
n.
It is
dif
ficu
lt to
see
how
this
can
be
exte
nded
to m
ajor
two-
lane
roa
ds s
uch
as Q
ueen
s R
oad
and
Mon
t Mill
ais
with
hom
es a
nd g
arde
ns a
gain
st e
ach
side
, but
if o
ther
mea
sure
s re
duce
the
volu
me
of
mot
or tr
affi
c, ‘
crit
ical
mas
s’ p
oint
s w
ill b
e re
ache
d, p
arti
cula
rly
at c
erta
in ti
mes
of
day,
whe
n cy
clis
ts a
nd p
edes
tria
ns d
omin
ate
the
road
s, w
ith th
e fe
elin
g of
saf
ety
that
that
bri
ngs.
Thi
s is
kn
own
to h
appe
n fo
r ex
ampl
e in
pla
ces
like
Cop
enha
gen
and
Am
ster
dam
, as
wel
l as
else
whe
re.
Rel
evan
t to
any
long
term
traf
fic
infr
astr
uctu
re p
lann
ing
mus
t be
rece
nt d
ecis
ions
, suc
h as
the
one
by V
olvo
to c
ease
pro
duct
ion
of a
ll no
n-el
ectr
ic v
ehic
les
by 2
040.
Cou
ntri
es a
re a
lso
mak
ing
plan
s;
such
as
Fra
nce
to b
an a
ll p
etro
l and
die
sel v
ehic
les
by 2
040,
Nor
way
to d
o so
by
2025
, and
G
erm
any
by 2
035.
Par
is m
ay b
an a
ll d
iese
ls a
s so
on a
s 20
20, a
nd th
e w
hole
EU
may
ban
all
petr
ol
and
dies
el v
ehic
les
by 2
030.
We
have
see
n ho
w th
e In
tern
et h
as a
ppea
red
from
obs
curi
ty in
the
last
20
year
s an
d tr
ansf
orm
ed
man
y in
dust
ries
and
hum
an a
ctiv
itie
s. S
mok
ing
indo
ors
has
gone
fro
m n
orm
al to
nev
er in
less
tim
e th
an th
at. I
t is
impo
rtan
t tha
t Jer
sey
does
not
app
ear,
to a
wor
ld th
at is
mov
ing
on, t
o be
stu
ck in
a
tim
ewar
p, r
eliv
ing
the
1960
s w
hile
eve
ryon
e el
se is
pla
nnin
g fo
r th
e 20
60s.
7