TRAFFORD METROPOLITAN BOROUGH COUNCIL v BRIAN POLLARD (Valuation Officer) RA/56/2004

UPPER TRIBUNAL
LANDS CHAMBER
RA/56/2004Case No RA/56/2004
TRAFFORD METROPOLITAN BOROUGH COUNCILApplicantBRIAN POLLARD (Valuation Officer)Respondent
The PresidentRichard Glover (instructed by GVA Grimley, chartered surveyors, by direct professional access) for AppellantTimothy Mould QC (instructed by the Solicitor of HM Revenue and Customs) for RespondentVenue Procession House, 110 New Bridge Street, London EC4V 6JLDate 25 January 2007Hearing 6 November 2006Property: TMBC Site comprising:, School & Premises,, Flixton County Secondary School for Girls,, Flixton Road, Urmston,, Manchester, M41 5DRCatchwords: RATING – hereditament – secondary school – sports centre for public and school use erected on school site – whether separate hereditament – held single hereditament – appeal allowed
[1]The appellant in this case owns and at all material times occupied a 5 ha site in the urban residential area of Urmston in Greater Manchester containing a school, the Flixton County Secondary School for Girls, and a sports centre, the Urmston Leisure Centre. In both the 1990 and the 1995 rating lists the valuation officer entered the site as two hereditaments, and the ratepayer’s appeal against this was dismissed by the Manchester South Valuation Tribunal. The ratepayer now appeals to this Tribunal, contending that there should be a single entry in each list because the site constitutes a single hereditament. This is the only point that arises. Whether the site constitutes one hereditament or two hereditaments makes a significant difference in terms of valuation. Valuation is on the contractor’s basis, but under the Non- Domestic (Miscellaneous Provisions) (No.2) Regulations 1989 and the Non-Domestic (Miscellaneous Provisions) (No.2) (Amendment) Regulations 1994 a lower decapitalisation rate applies in the case of a hereditament which is constructed or adapted for use for the purpose of a school and is wholly or mainly so used. If the sports centre constitutes a separate hereditament the higher decapitalisation rate would fall to be applied to it. The facts[2]There is no dispute as to primary fact. There is an agreed statement of facts. I viewed the site on 13 December 2006. The site runs between Flixton Road on the south and Bowfell Road on the north. Along the Flixton Road frontage are car parking areas serving the school and an astroturf pitch. Along Bowfell Road there is the school kitchen/canteen, the car park serving the sports centre, the sports centre itself (with a sign outside saying “Urmston leisure Centre”) and the school playing fields. The school buildings are situated behind these frontage elements on the central part of the site. A public footpath from Bowfell Road to Flixton Road runs across the western part of the site, dividing the kitchen/canteen building from the rest of the site. There is now tall iron fencing, erected for security reasons, around the principal part of the school. It separates the sports centre from the school; and it also runs along the footpath, so that the kitchen/canteen building is outside it, and between the school playing fields and the rest of the school site. At the material date for the 1990 valuation list none of this fencing had been erected. At the material date for the 1995 valuation list a section of it, between the school and the sports centre, had been erected.[3]The school is a local authority secondary education school. It was opened in 1938. The principal building dates from this time. Additional buildings were later constructed – a kitchen/dining room in 1955, a “Rosla” classroom building in 1974, a temporary classroom building in 1997 and an Arts/French classroom building in 1998. The total gross internal area of the buildings in 1998 was 6,199 m2. In 1989 the sports centre and an all-weather Astroturf pitch with floodlighting were built within the school grounds. The sports centre has a gross internal area of 2,809 m2. It contains an entrance/foyer reception, “dry” sports hall (612 m2 in area and marked out as a five-court badminton hall), an air-conditioned gym/fitness room, a 3 swimming pool (consisting of a 25 metre, 4-lane pool and an attached learner pool), café, poolside viewing/ café seating, sauna suite, changing rooms, licensed bar area (changed after the material dates to a multi-purpose activity room), administrative offices and plant areas. In 1999 a library 82 m2 in area was added to the sports centre building. It is run as a public library by the respondent council. It is not entered in the list as a separate hereditament.[4]Development of the sports centre upon the site enabled Trafford MBC to fulfil the joint requirements of replacing the old Urmston swimming pool, which was a short distance from the school site and had been built in 1931, and improving the physical education and sports facilities at the Flixton Girls School. The Urmston swimming pool had needed repair, but this was uneconomic. It was closed in June 1987 and then demolished. In 1983, Trafford MBC’s Leisure Department had built the George Carnall Sports Centre, which is rather over a mile from the site. Although only providing “dry” sports facilities, which are used by schools in the area, this site had been intended to accommodate a later swimming pool addition. However, as it was not centrally located within Urmston, Trafford MBC investigated other possible sites for the provision of new swimming facilities to replace the former Urmston pool.[5]In September 1986, a special meeting of the Trafford MBC’s Education Committee resolved to accept, as a basis for public consultation, proposals to re-organise secondary school provision in Trafford on a non-selective system of 10 comprehensive schools. Under those proposals, the Flixton Girls School was to be re-organised as a co-educational, comprehensive school for 11 to 16 years olds at or around a minimum size of six forms of entry (ie 900 pupils). In March 1987, Trafford MBC’s Leisure Services committee resolved that a new swimming pool be built on the grounds of the Flixton Girls School (on what is now the sports centre site) as a joint development with the proposal for the 6th form entry comprehensive school. The Education Committee resolved to agree to the use of land at the school as the site for the proposed Urmston swimming pool subject to (inter alia) assurances as to the ability of the school landholding to accommodate all anticipated uses, the design of the proposed scheme being capable of integrating new school accommodation with the new swimming pool, and the development of a scheme for joint use of the new swimming pool by the school and the public, involving sports hall provision and proposals to extend the school to 900 places for 11 to 16 year olds. In the event it was decided to retain the school as a single sex girls school with this number of places.[6]In June 1987, Trafford MBC’s Leisure, Education and Policy Joint Committees approved the Leisure Services Department’s Brief for Urmston Sports Centre. The Brief set out the background to the selection of the school site as the site for the new sports centre, summarised the final proposals for the sports centre scheme, and stated the philosophy of use of the new sports centre as a community dual use sports centre for use by the community, schools, and clubs, under the management of the Leisure Services Department. The School redevelopment proposals were considered by Trafford MBC against the requirements of the Education (School Premises) Regulation 1981 and the “Area Guidelines for Secondary Schools Design Note 34” issued by the Department of Education and Science Architects and Building Group in 1983. The Design Note suggested a systematic method for arriving at school accommodation based on area allocations for specific subjects relative to their importance in terms of curricular time and the activities which they involve, providing a common starting point to help all who 4 participate in the briefing for and design of secondary school buildings. Against these provisions the requirement for a new indoor sports hall was identified.[7]In July 1987 Trafford MBC’s Finance Committee resolved to approve the scheme for Urmston Sports Centre as recommended by the Leisure Committee. The Finance Committee also resolved that the revenue costs for the sports centre scheme be met proportionately from the Leisure Services and Education budgets. On 20 October 1987, Trafford MBC, on the joint application of its Leisure Services and Education Committees, gave notice of its resolution to carry out the development of the new sports centre at the School. The deemed planning permission contained a number of conditions, of which number 5 provided that use of the parking areas around the school must be provided and made available out of school hours at all times when the parking demand was sufficient to require it.[8]A report in November 1988 prepared for Trafford MBC Chief Officers advised that the provision of an astroturf pitch on the school site would enable the school to meet the land area requirements for sports pitches as synthetic sports surfaces counted as twice the area of grassed surfaces because they could be more intensively used. The astroturf pitch was completed in 1989/90. In a memorandum in January 1989 from the Chief Leisure Services Officer to the Chief Education Officer the concept of the dual usage of the sports centre was outlined. It provided a brief summary of the operating arrangements and permitted use of the particular activity areas of the sports centre. In April 1989 it was agreed that control of the site of the Leisure Centre (as it had come to be called) should be transferred to the Leisure Services Committee, subject to the consent of the school’s governing body, which was subsequently obtained. In 1997/1998, Trafford, MBC’s Leisure Services and Education Departments were merged into a single Department, the Education, Arts, and Leisure Department.[9]Within the main 1938 school building there is an assembly hall/gymnasium, used for school assembly, as an examination hall and for sports and physical education. As at 1 April 1990 and 1 April 1995 and throughout the respective lifetimes of the 1990 and 1995 rating lists, the school assembly hall/gymnasium was solely used by the pupils of the school, apart from some limited evening session usage, which included the local girl guides group. The size of the room is 367.8m2, and there is a room divider that can be used to divide this area into separate areas for the assembly hall (178.3m2) and the gymnasium (189.5m2), if required. Sports and PE use included gymnasium classes, trampolining, netball and hockey (when the astroturf pitch was out of use due to wet weather), and dance classes.[10]The astroturf pitch is solely used by pupils of the school during school hours. Outside school hours (evenings, weekends, and school holidays) it is used by the public. With the exception of off peak times such as late Friday and Saturday evenings, public use by sports teams/groups is intensive and made by way of regular advanced block bookings. A variety of sports are played on the pitch but the predominant use is for football. The bookings are made through the sports centre, and public users of the astroturf pitch use the changing facilities within the sports centre. 5[11]Throughout the lifetimes of the 1990 and 1995 rating lists, the sports centre was operated by Trafford MBC. (Since 1 April 2003, it should be noted, it has been managed by Trafford Community Leisure Trust, and from that date the Trust and not the council has been the rateable occupier.) The sports hall at the sports centre has always been reserved for the sole use by the Flixton Girls School pupils during normal school hours, namely 9am to 6pm Mondays to Fridays during school terms. The school use activities include badminton, trampolining, dance, rounders, basketball, netball, indoor hockey, and keep fit to music, and these activities have not changed materially over the period in question. During certain periods of good weather in the summer term, some of these activities take place on an impromptu basis outside on the school playing field. School use the sports hall and facilities such as toilets and changing rooms are under the supervision of the teaching staff from the school that attend with the pupils. The teachers are responsible for setting up the equipment in the sports hall, with the sports centre staff available to assist if required.[12]The sports hall is available for use by the general public during periods when it is not reserved for use by the school pupils, namely evenings, weekends, and school holidays. As with the astroturf pitch, bookings for public hire are made through the sports centre. The swimming pool is available for public use on all days, subject to bookings made under the Trafford Schools and Lessons scheme. Bookings made under this scheme are commonly for one of the four swimming lanes for half hour sessions at various times. In addition to these arrangements the Flixton Girls school pupils enjoy some use of the pool, mainly limited to “free swims” by final year pupils (16 year olds). This overall pattern of use has not materially changed since the material days of the appeals. The remaining facilities within the sports centre (the gym/fitness room, the sauna suite, the licensed bar and the cafeteria) are provided for public/community use during all the hours that they are open. Whilst no numerical data is available it is agreed that at all material dates the overall volume of use of the Leisure Centre by the general public (including use by other schools) has exceeded the volume of use by pupils of the school. The valuation tribunal decision[13]In reaching its decision that the school and the sports centre were properly to be entered in the list as separate hereditaments, the valuation tribunal said this:
“In coming to a decision, the Tribunal had to consider the level of interdependence between the school and the leisure centre, bearing in mind that both premises were (until 1 April 2003) in the same occupation. In other words, to what extent did functional essentiality exist. Unfortunately the budget of the assessments was not available, as details of staff costs; takings, recharges, etc. would have been useful, although presumably only leisure centre staff ran the leisure centre. Looking at the ‘York Railway’ case, the Tribunal also had to consider if the school and leisure centre were used for different purposes. The members were of the opinion that they were as the school is used for educational purposes, although the public library in the building is arguably used partly for educational purposes. 6 Both parties were agreed that public use of the leisure centre was greater than for school use. But the members were of the opinion that the leisure centre could function without the presence of the school and the school could also function without the presence of the leisure centre. It is however convenient for the school to have these facilities next door but the PE function could be fulfilled using facilities elsewhere at the expense of more travelling time/costs. So although both facilities are contiguous to each other, and although the leisure centre was erected on land provided by the Education Committee and probably funded by the same committee, both could exist without the other.”
The case for the appellant ratepayers[14]For the ratepayers Mr Richard Glover submitted, on the basis of Gilbert (VO) v S Hickinbottom & Sons Ltd [1956] QB 40, that the general rule was that properties which are contiguous to one another and in the same occupation should be treated for rating purposes as a single hereditament and that an exception to this rule was where there are two parts which are used for wholly different purposes. The issue in the present case, therefore, was whether the two parts of the site that the VO suggested should be treated as separate hereditaments were used for “wholly different purposes”. Mr Glover drew attention to the history of the development of the site. The proposals for school expansion required the provision of indoor sports facilities, which were located in the sports building, and an astroturf pitch. From the inception of the proposal to develop the sports centre in the school grounds it was envisaged as a joint development, the capital cost of which was to be shared between the budgets of the education and leisure departments. It was envisaged from the outset that the sports building and the astroturf pitch would be used by both the school and the public, and it was envisaged that the school would have priority in the use of the sports hall and the astroturf pitch.[15]The use of the site, Mr Glover said, had reflected these proposals. The astroturf pitch and the sports hall were dedicated to school use during school hours. Outside school hours both were available to be used by others and were so used. For both facilities bookings by the general public were arranged through staff at the sports centre. The changing facilities in the sports centre were used by the school as a necessary part of the school’s use of the sports hall and the swimming pool. Although not used exclusively for the educational purposes of the school, the sports centre was used to a significant extent for educational purposes. The sports hall was used predominantly for the purposes of the school and the swimming pool to a significant extent for those purposes. The two parts of the site were thus not used for entirely different purposes. Both parts were used for educational purposes and for the purposes of the community. The case for the respondent valuation officer[16]For the valuation officer Mr Timothy Mould QC accepted that the test of whether the two parts of the site should be treated as separate hereditaments was whether they were used for entirely different purposes. The question was one of fact and degree, and it was as much a 7 matter of impression as of examining the documents that were before the Tribunal. There were a number of matters that were of particular weight. The school and the sports centre were provided and administered by the appellant under separate and distinct statutory powers and functions. The appellant provided, occupied and operated the school in connection with its functions as local education authority. It provided, occupied and operated the sports centre in connection with its powers and functions for the provision of sports and leisure facilities. Although physically contiguous the sports centre and the school were nevertheless physically distinct premises with clearly identifiable boundaries, and by 1995 they were physically separated from each other by a boundary fence. Both the school and the sports centre were capable of being separately let by virtue of that degree of physical separation and their self- contained and operational characteristics.[17]The predominant use of the sports centre, Mr Mould said, was as a public leisure centre. It had been provided and was operated to meet the local community’s need for modern sports and leisure facilities. The use of the sports centre by Flixton County Secondary School and other local schools was both limited and part of the overall public leisure provision. The school was one of a number of local schools that made limited use of the swimming pools at the sports centre as part of their curriculum. Dry sports facilities were available for use at the nearby George Carnell Sports Centre and these were used by a number of local schools. In the absence of the sports hall in the sports centre these alternative facilities would have been available for use by Flixton County Secondary School. The circumstances of the all weather sports pitch were to be distinguished from those of the sports centre. The pitch was located plainly within the area of the school and it lacked any sufficient degree of physical or functional distinction or separation to enable it to be regarded as a separate hereditament. Conclusions[18]The leading case on the identification of hereditaments is Gilbert v Hickinbottom. There the premises in issue consisted of two properties occupied by the same ratepayer, a bakery on one side of a road and a maintenance depot for the bakery’s vans on the other. The Lands Tribunal (Erskine Simes QC), reversing the decision of the local valuation court, had rejected the VO’s contention that these should be entered in the valuation list as two hereditaments rather than one, and the Court of Appeal held that it had not erred in doing so. At [1956] QB 48 Denning LJ said this:
“The case therefore raises the important question, what is a separate hereditament for rating purposes? The statutes contain no definition, but the practice which has prevailed for many years warrants the following general rules: First, take the case where two or more properties are within the same curtilage or contiguous to one another, and are in the same occupation. In that case they are, as a general rule, to be treated for rating purposes as if they formed parts of a single hereditament. There are, however, exceptional cases where for some special reason they may be treated as two or more hereditaments. That may happen, for instance, when they are situate in different rating areas, or because they were valued at different times (see section 3(3) of the…[Rating and Valuation (Apportionment) Act 1928]): or 8 because they were at one time in different occupations (see Spillers Ltd v Cardiff Assessment Committee, per Avory J); or because one part is used for an entirely different purpose (see North Eastern Railway Co v Guardians of York Union).”
[19]Denning LJ went on, in passages that are not material for present purposes, to consider cases where two properties were not contiguous with each other or were separated by a public highway. Then (at 50) he said that whether a case came within one of the general rules or an exception to it was a question of degree and therefore of fact for the tribunal of fact, so long as it properly directed itself on the matter. Morris LJ (at 51), having referred to North Eastern Railway Co v Guardians of York Union, identified the issue of law that arose in the appeal as whether on the facts regard could be had to the use to which the premises were put. He went on: “It was submitted that if premises are in the same occupation and if they are contiguous, or if they are within the same curtilage, the prima facie they are to be regarded as one hereditament; but that in such circumstances a distinct and separate user of some part of such premises may justify regarding that part as a separate hereditament. The case of the hotel at York station in the case cited was given as an example. But it was submitted that if premises which are in the same occupation are structurally and geographically separate and if they are capable of being separately let, then the us to which the premises are put must be entirely excluded from consideration and the premises must be held to be separate hereditaments. I do not feel able to accept this approach. I do not think that it is appropriate to lay down propositions of the above nature as being inevitably or invariably applicable. If, as I think, the decision as to whether premises form one hereditament is a question of fact, then I think that it is undesirable to prescribe some formula in words or to seek to define certain considerations as being relevant and to stipulate that others must be excluded. Parliament has not laid down a definition of hereditament and difficulties might result if a rigid judicial definition were formulated. In the great majority of cases there will be no difficulty, after assessing all the considerations which apply according to the weight they command, in deciding whether premises comprise a hereditament. In the borderline cases where difficulty arises it is better to employ a common-sense assessment of the features of the case than to seek to have recourse to some standard formula. Thus, to illustrate, there may be several buildings or structures in the same occupation which can properly be regarded as being one hereditament. It may be that they are within one enclosure. That may be one circumstance which points to the conclusion that they comprise one unit; that circumstance may supply a useful basis or test. So also, buildings which, though not actually enclosed together and are not separated by the presence of other buildings and are being put to one common use may be regarded as comprising one hereditament. There can be no doubt that ordinarily very great weight will be placed on what may be called the geographical test. But the question is always one of fact and degree. On the other hand, where there are several buildings within one enclosure or curtilage, they may constitute separate hereditaments. This may be so if the buildings, though not separately let, are capable of being separately let and are used for separate purposes. (See North Eastern Railway Co v Guardians of York Union.)” 9[20]Parker LJ at 53-4 said this:
“Whether or not premises in one occupation fall to be entered in the valuation list as one or more hereditaments depends upon a number of considerations. Without attempting an exhaustive list, the following considerations can be mentioned:- (1) Whether the premises are in more than one rating area… (2) Whether two or more parts of the premises are capable of being separately let. If not, then the premises must be entered as a single hereditament. (3) Whether the premises form a single geographical unit. (4) Whether though forming a single geographical unit the premises by their structure and layout consist of two or more separate parts. (5) Whether the occupier finds it necessary or convenient to use the premises as a whole for one purpose, or whether he uses different parts of the premises for different purposes. Whereas a consideration of questions (1) and (2) will in certain events conclude the matter one way or the other, the same does not, I think, result from a consideration of any one of the other questions alone. The conclusion, where the considerations of (1) and (2) are not decisive, must depend on the weight to be attached on the facts of each case to the other considerations. No doubt the most important of these other considerations is whether the premises form a geographical unit. Can they be ringed round on a map?”
[21]Later (at 55) Parker LJ, rejecting the contention that a functional test was wholly inapplicable where the premises occupied were geographically and structurally separate, said this:
“Each case must be considered on its particular facts, due weight being given to the degree and nature of the separation on the one hand and the importance of the functional connexion on the other.”
[22]Although each of the lords justices emphasised that each case must depend on its own facts, they each referred to North Eastern Railway Co v Guardians of York Union [1900] 1 QB 733 as showing that part of a property in single occupation may be properly treated as a separate hereditament if it is used for “an entirely different purpose” (per Denning LJ at 48) or “used for separate purposes” (per Morris LJ at 52) or where this is justified by “the manner in which different parts are used” (per Parker LJ at 54). On a case stated by an arbitrator the issue in that case was whether, as the ratepayer railway company contended, various parts of its property in one rating area had to be treated as separate hereditaments. The parts consisted of operational elements such as the railway lines, York station, engine sheds, and so forth. They also included the hotel and refreshment rooms at York station. The arbitrator found that the whole of the premises, including the hotel and refreshment rooms, formed one continuous area 10 approached by gates, under the sole control of the railway company, and completely fenced round except where the main lines passed through. There was access from every part to every other part, and the whole property was closed at night. At the hearing before the arbitrator the Union, as rating authority, had admitted that they could and would put a separate value on the hotel and refreshment rooms as a separate item. No question therefore arose on the separate rating of this part of the property.[23]Channell J, with whom Bucknill LJ agreed, held that the respondents were not bound to assess and rate separately the parts of the property that had been identified. He went on (at 739):
“I agree that it is almost entirely a question of fact. If the whole of the whole of these different portions of property were one hereditament, they ought to be rated in one lump sum, and whether they are one hereditament or more seems to me to be a question of fact. One thing I think is clear, that property must be rated according to what it is, and not according to what it might be. You may have a thing which, as it is, is one hereditament, but which is quite capable of being made into two. The owner of a field may sell half of it, and it may become two hereditaments in different occupations; but while it is undivided it is one hereditament. The fact that the different portions of the property here are capable of being made separate hereditaments is immaterial. The facts stated by the arbitrator shew that at present they are one, though possibly with some slight alteration they might be made into separate hereditaments.”
[24]Channell J then said with reference to the hotel:
“We are not asked to give any opinion about the hotel and refreshment rooms. If we had to give a decision upon them, I think the matter would be one of greater difficulty. If it is a mere question of fact whether the hotel is to be treated as a separate hereditament from the rest of the station, speaking for myself, I should be inclined to find that it ought to be so treated. In arriving at that conclusion I should be influenced by the fact that the hotel and the rest of the railway station are used for wholly different purposes. It would be like the case of a man occupying two shops, in one of which he carried on one business, and in the other another business.”
[25]In Coventry and Solihull Waste Disposal Co Ltd v Russell (VO) [1998] RA 427, which concerned the rating of an electricity generating waste incinerator, the question arose whether a pipeline leading from the premises to supply a nearby factory with heated water as a by- product of the incineration and generation operations was to be treated as part of the same hereditament as the remainder of the premises or as a separate hereditament. The Tribunal (Judge Marder QC) said that he saw no reason on the facts to depart from what Denning LJ called “the general rule”: in his judgment the pipeline formed part of a single hereditament comprising incinerator plant, generating plant, and pipeline. Robert Walker LJ (at 437) said that he considered that this was a conclusion of fact and degree that was unassailable in law. Waller LJ (at 441) agreed with this and also with the conclusion on this issue expressed by Hobhouse LJ at 444, where he said: 11 “Whether there is a single hereditament or more than one hereditament is a question of fact for the fact finding tribunal. If the fact finding tribunal misdirects itself upon the law or has manifestly failed to apply the right test, an appellate tribunal of law may reverse the finding. In the present case there is no indication whatsoever that the Lands Tribunal applied the wrong criterion. Judge Marder expressly directed himself by reference to what had been said by the Court of Appeal in Gilbert v Hickinbottom. The two parcels of land adjoined one another. Therefore it was necessary for the [valuation officer] to show that the pipeline was used for an entirely different purpose to that for which the remainder of the ratepayer company’s land was used. On the evidence and upon the facts found it was clear that the pipeline was not used for an entirely different purpose. It was used as part of the operation being carried on at this waste disposal plant.”[26]Since, as all the above judgments make clear, it is a question of fact and degree for the decision-maker (VO, VT or the Lands Tribunal) whether property in one occupation should be entered in the list as one or more than one hereditament, it follows that there can be no conclusive tests for determining the issue when it arises. Mr Glover submitted that the decisive question in the present case was whether the two parts of the site were used for wholly, or entirely, different purposes, and Mr Mould said that before the VT the VO had approached the matter on the basis that the test was the “entirely different purpose” one and he did not now seek to go behind this. They were in agreement that the valuation differences that arose, depending on whether the site was treated as one hereditament or as two, should be left out of account.[27]While I can accept that the difference in the use of the two parts of the site is the most important consideration that arises, it is not, in my view the only one, and the issue is not to be determined by focussing exclusively on the words “wholly [or entirely] different purpose” and seeking to apply them to the facts as though they were words in a statute. Indeed counsel did not confine their arguments in this way, and they both addressed, as material considerations, the following in particular:(a) Whether the two parts of the site were capable of separate occupation;(b) The nominal purpose for which the two parts of the site were used (as a school and as a sports or leisure centre);(c) The activities comprehended in the use of each part of the site;(d) The extent to which parts of the VO’s school hereditament were used by the public and the sports centre was used by the school;(e) The history of the proposal for the dual use facilities;(f) How the sports centre was financed;(g) The separate management of the two parts under different statutory powers; 12(h) The degree of physical separation between the two parts.[28]I agree that all these matters are material considerations. Consideration (a), whether the two parts were capable of separate occupation, would be determinative if no separate occupation was possible. Mr Glover drew attention to condition 5 in the sports centre planning permission, which required that the parking areas around the school must be provided and made available out of school hours at all times when the parking demand was sufficient to require it. He suggested that this had the effect that the sports centre could not be occupied separately from the school. I do not think that this is so. It would be open to an occupier of the sports centre so to operate it that the level of parking demand was never sufficient to require the use of extra parking at the school. I accept, however, that the requirement is a factor to be taken with the other relevant matters in determining as a matter of judgment whether the site should be treated as one hereditament or two.[29]In relation to consideration (h), the degree of physical separation, Mr Mould relied on the fact that at the material date for the 1995 list fencing had been erected between the sports centre and the school. I attach little weight to this. The purpose of the fencing was evidently to prevent trespass rather than to separate the two parts of the site. It has now been extended around the whole of the principal part of the school. The kitchen/canteen lies beyond the fencing that has been erected beyond the footpath. There is, however, access to the kitchen/canteen through a locked gate, and there is similarly access through a locked gate to the sports centre.[30]What seem to me to be the most significant considerations are that the sports centre and the all-weather pitch were conceived as dual-use facilities and are operated as such. The cost of construction was borne by both the education and the leisure services budgets. The sports hall, constituting a substantial part of the sports centre building, was required to enable the standards for such facilities to be met. It is dedicated to school use during school hours and it is evidently well used for this purpose. It is effectively in use as part of the school in the same way as the smaller sports hall in the principal block of school buildings. The all-weather pitch within the VO’s school hereditament, while in school use during the day, is used by the public out of school hours as a facility additional to those provided inside in the sports centre. The degree of interaction between the two parts of the site is thus significant, and the concept of this interaction was a fundamental part of the development that was carried out in 1989.[31]It is, of course, the case, that the two parts of the site can readily be identified as a school on the one hand and as a sports centre on the other and that they are managed separately under different statutory powers. These, in my view, are important considerations, which argue quite strongly in favour of treating them as separate hereditaments. On balance, however, in the light of all the considerations, I think that Mr Glover is right in contending that the degree of functional connection between the two parts of the site is such that the whole site is properly to be treated as a single hereditament. The appeal must, therefore, be allowed. 13[32]I direct that the hereditament should be entered in the rating list as “School, sports centre and premises” at the rateable values that are agreed, that is to say £178,500 in the 1990 list and £150,000 in the 1995 list. The parties are now invited to make submissions on costs, and a letter dealing with this accompanies this decision, which will become final when the question of costs has been determined. Dated 20 December 2006 George Bartlett QC, President Addendum on costs[33]I have received submissions on costs. The appellant asks for its costs, and the respondent does not resist this. Accordingly I order that the respondent pay the appellant’s costs, such costs if not agreed to be subject to detailed assessment by the Registrar on the standard basis. Dated 25 January 2007 George Bartlett QC, President 14