Financial Viability Appraisals (FVA’s) for Supported Housing – A Cost Consultant Perspective.

Targeted delivery of new homes

As the much-heralded, and long-hoped-for, reforms to the National Planning Policy Framework (NPPF) appear to be becoming a reality, the pressure will be on the Local Planning Authorities to deliver a huge increase in targeted delivery of new homes.

Brownfield first strategy

From what we have been told so far, the strategy is ‘brownfield-first’ but councils will need to review their Green Belt boundaries to identify ‘grey belt’ areas. Also, on the table, is to increase affordable provision to 50% from the established 20% benchmark.

With such a resultant increase in development, the submissions of Financial Viability Appraisals (FVAs) will increase accordingly. This, when taken down to a granular local perspective will be challenging, to say the least even setting aside the problem of actually delivering such a vast number of homes.

Green belt land of any shade will come with what we expect to be a greater resistance to allow planning permissions unless the approvals process is made by the local planning authority purely on the merits of developments fulfilling housing needs alone, without local councilors being part of the equation. This however is a matter for Government review and policy – as quantity surveyors, we are focussing on costs!

As viability appraisals are simply revenue less cost, and whether it be working for developers or Local Authorities, surveyors who work within this niche sector on the cost portion of the equation (our Registered Valuer brethren doing the heavy lifting on the revenue side) are heading for increased difficulty in having costs presented as being appropriate and robust.

Why is this?

The underlying principles of where we source our costs from are set out within the current Planning Practice Guidance (PPG)

How should costs be defined for the purpose of viability assessment?

Build costs based on appropriate data, for example, that of the Building Cost Information Service”. The current RICS guidance summarises the current viability process set out in the NPPF and PPG in a table. The evidence base is defined within this table as: at the ‘Plan making stage’ and states “ Costs and values will be based on average rates from comparable schemes.” This process is to be based on comparable, not actual schemes.

Furthermore, the table states that at the ‘Development management stage’ a detailed build cost plan and schedule of value should be provided. The RICS guidance goes on to describe the evidence collected to support assumptions on costs could include ‘the expected build cost (a full quantity surveyor’s cost report showing how costs have been estimated should be made available for site-specific information) and that plan making may have to rely on BCIS or other online information.’

As cost consultants, we present costs based on how much information is available for us to estimate such. Floor plans only would be BCIS using the relevant category. With more detail comes more ability to account for specifics, so progressively Order of Cost, and Detailed Cost Plans for RIBA stage 3 level of design with supporting specialist reports.

These are not hardlines as we should endeavour to capture all we can see and interpret from the information. Order of Cost and Detailed Costs Plans do not cause a problem, it is the BCIS Average Prices which do.

Generally, the BCIS average prices are used for FVAs due to the level of design detail available at the moment in time when the FVAs are prepared. To expand on the Supported Housing dataset, the number of samples being submitted to the BCIS database is reducing. The aimed sample size is at least 20 with a minimum of 10. Looking at the sample size for the 5-year max age within Supported Housing, all are below the minimum so we cannot use the 5-year dataset for cost/ m2 to show ‘comparable schemes.

Even using the 10-year dataset we can see 3 of the 4 sub-categories below 20 with two at 10 or below. Many BCIS Tender Price indexes were suspended as of February 2021 due to insufficient sample sizes, leaving only the All-in Tender Price Index and the Refurbishment Tender Price Index. This also points to questioning the reliability of the remaining datasets.

In Short – The BCIS dataset for supported housing is however close to being unusable.

So what is the way forward?

The simplest solution is to input more analyses. However, this has always been generally resisted by the private sector as their costs are ‘commercially sensitive’, and, of course, they do not want competitors to know such.

The landscape of appraisal is changing and so should be the mindset.

A greater number of schemes within the dataset provides an easier route for appraisal submissions, rather than having to engage consultants to prepare cost estimates. Even the most optimistic of us would agree that this will not happen overnight, and the challenge is clear and present in providing build costs that are representative of comparable schemes.

This can only be achieved in the short term by the provision of ‘Order of Cost’ or ‘Detail Cost Plan’ estimates being included for those development types with a shortage of data within the BCIS category. The greatest shortfall is within 843 Supported Housing.

An indirect benefit of providing cost estimates from the initial submission would be in easing the viability reviews that are becoming more commonplace. Starting with developments within London, which have been subject to viability reviews (Early, Mid-Term, and Late Stage) for several years, other councils have introduced viability reviews under Supplemental Planning Documents (SPDs).

There is no doubt that a standardisation of the planning process is coming with a major change to the NPPF driven by the new Labour government policies.

A further benefit is for the costs to be able to reflect specification differences between tenures and specific types of development (Extra Care, Retirement Living, etc.). Shared ownership is higher than that of Affordable/ Social Rent due to driving demand and justification of sales values for the unit.

So, it’s going to be scale rules at the ready for the foreseeable!

Want to chat through anything? 

We’re happy to help – so do please get in touch with a specialist member of our team as below.

Jonathan Purcell – j.purcell@pooledick.co.uk

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