Object

Representation ID: 1708

Received: 30/01/2015

Respondent: Cogent Land LLP (Cogent)

Following a thorough review of the PDCS and supporting evidence, CLL wish to make the following key observations:
The Council does not currently have an up-to-date Objectively Assessed Housing Needs (OAHN) or NPPF-compliant Local Plan including site allocations. We would therefore recommend that this work is undertaken to inform the CIL process, prior to the Draft Charging Schedule being published for consultation;
The proposed "nominal" CIL rates are not supported by the Viability Study;
An insufficient viability buffer has been applied to the proposed CIL rates; and
A number of the assumptions adopted in the Viability Study are inappropriate and result in the Viability Study over-estimating the capacity for CIL.