Comment

Representation ID: 1806

Received: 12/12/2014

Respondent: Cogent Land LLP (Cogent)

Viability Buffer
Site specific circumstances mean that the economics of the development pipeline will vary from the typical levels identified via analysis of the theoretical typology. This is inevitable given the varied nature of housing land supply and costs associated with bringing forward development. It is therefore important when setting rates that the Local Authorities apply an appropriate viability 'buffer' as discussed in the PPG: "It would be appropriate to ensure that a 'buffer' or margin is included, so that the levy rate is able to support development when economic circumstances adjust. This is particularly relevant in the case of Southend-on-Sea for the following reasons:
*Unplanned Development a significant proportion of development is anticipated to take place on windfall sites. The exact nature and scale of these developments is subsequently unknown;
*Brownfield Sites brownfield sites. The viability testing supporting the CIL rates makes no allowance for site specific abnormal costs; and
*Delivery the area experiences persistent under-delivery and there has been failure to achieve annual housing targets since 2007
Each of these points means that the Council is at a greater risk of failing to deliver its housing numbers. It is therefore of paramount importance that the Council can demonstrate that these risks have been taken in to account when setting their CIL rates. Failure to do so will result in the Regulation 14 test being failed, as the CIL rates would threaten the delivery of the housing supply anticipated to come forward during the Plan period.