residential development. At a time when office accommodation along the Albert Embankment is standing empty, indeed being converted to residential use (eg Eastbury House), and the current development emphasis at Vauxhall is on residential, student and hotel use, it seems risky to equate Waterloo and Vauxhall rates in this way. 125 per sqm seems high compared with neighbouring borough areas, and we think a lower, encouraging rate should be set for the Vauxhall part of the area, at say 50 to 75 per sqm. 11 As regards retail development, we agree that the charge is best targeted at stores over 2,500 sqm "superstores". But some supermarkets will develop incrementally from below the 2,500 sqm level to above it, and we think the retail charge should catch both new developments of  2,500 sqm and above, and new developments of smaller size that take an existing retail development over the 2,500 sqm threshold. CIL -- The Meaningful Proportion 12 Now that the CIL can be raised in one part of Lambeth and spent in another, (breaking the S106 principle of direct relation between the development and its mitigation that the S106 money was meant to be spent on), we note that the Government has suggested that "a meaningful proportion" should still be spent locally to the development paying the CIL, and has consulted (without conclusion) on what that proportion should be. Suggestions have been as low as 5%, reaching to 40%. We think that  anything as low as 5% would be an