Object

Representation ID: 1776

Received: 12/12/2014

Respondent: Cogent Land LLP (Cogent)

Cogent has fundamental concerns with the approach proposed by the Council notably:
* Unviable Rates - The current proposed CIL rates are unviable and risk rendering a significant
* proportion of the housing supply across the District undeliverable;
* Incorrect Assumptions - A number of the key viability inputs adopted by PBA are incorrect. This results in an over-estimation of the maximum CIL rates that can be supported;
* Housing Delivery Cogent believes it is important to highlight that an unviable CIL poses a real risk of a materially reduced housing delivery, which in turn will affect the level of receipts collected. This is important as the Council is relying on CIL contributing to the significant funding gap in the Borough;
* Charging Zones - scale of development. Whilst the principle of applying differential rates is not questioned, the proposed Charging Zone 1 includes areas that the viability evidence proves cannot support a CIL rate; and
* Housing Supply There has been persistent under-delivery housing supply is heavily reliant on unplanned development across the Borough. This is particularly important as the future housing requirements for the Council, based on emerging information from the Thames Gateway Partnership, indicates significantly higher numbers than previously delivered under the Core Strategy. It is therefore essential that a higher buffer (minimum of 40%) is incorporated to reflect the already existing risk to the housing supply and to ensure the delivery of infrastructure and community facilities required to support the enhanced level of growth across the Borough, whilst ensuring that SBCs strategic objectives are met.