Question 3

Showing comments and forms 1 to 6 of 6

Support

Community Infrastructure Levy (CIL)

Representation ID: 1682

Received: 04/09/2014

Respondent: McCarthy and Stone Retirement Lifestyles Ltd.

Agent: Mr Ziyad Thomas

Representation Summary:

Support proposed 'Retirement and Extra Care' levy rate.

Support

Community Infrastructure Levy (CIL)

Representation ID: 1685

Received: 08/09/2014

Respondent: Mrs Pat Holden

Representation Summary:

looks reasonable

Object

Community Infrastructure Levy (CIL)

Representation ID: 1726

Received: 30/01/2015

Respondent: Cogent Land LLP (Cogent)

Representation Summary:

We have reviewed the Viability Study supporting the PDCS, in particular the results of the viability appraisals run by BNP. Our client's particular concern relates to the "nominal" rate of £20 per sq m proposed by BNP, which has been applied to Market Areas 1-3.
We have reproduced the viability appraisal results for Typologies 7-9, which are based on policy compliant affordable housing (30%) provision and a residual Section 106 allowance of £1,012 per unit:
All of these results show that the Market Area 1-3 sites cannot support a CIL rate, even with varying BLVs. A point acknowledged by BNP, who commented "the results indicate that viability of residential development is currently challenging in certain locations". Even with reductions in affordable housing levels, BNP acknowledges that "the results indicate that viability of residential development is currently challenging in certain locations". These certain locations refer to Market Areas 1-3, with Areas 2-3 remaining widely unviable and Area 1 completely unviable.

Object

Community Infrastructure Levy (CIL)

Representation ID: 1727

Received: 30/01/2015

Respondent: Cogent Land LLP (Cogent)

Representation Summary:

We therefore question how a CIL rate of £20 per sq m can be justified when the supporting viability evidence clearly shows that it is unviable. A point that becomes even harder to understand when you consider the local housing supply position, which indicates a reliance on windfall sites and a previous under-delivery. The Council does not therefore know where a significant amount of housing will be delivered, which puts an even greater importance on the CIL rates be set at a viable rate in all market areas. The following commentary by BNP is therefore concerning:
"For residential schemes, the application of CIL is unlikely to be an overriding factor in determining whether or not a scheme is viable. When considered in context of total scheme value, CIL will be a modest amount, typically accounting for between 0.9% and 1.6% of value. Some schemes would be unviable even if a zero CIL were adopted. We therefore recommend that the Council pays limited regard to these schemes."

Object

Community Infrastructure Levy (CIL)

Representation ID: 1728

Received: 30/01/2015

Respondent: Cogent Land LLP (Cogent)

Representation Summary:

The CIL Guidance clearly states that "If the evidence shows that the area includes a zone, which could be a strategic site, which has low, very low or zero viability, the charging authority should consider setting a low or zero levy rate in that area. The same principle should apply where the evidence shows similarly low viability for particular types and/or scales of development." A point further emphasised by the CIL Guidance which highlights that Local Authorities have a positive duty to show that their CIL rates are appropriate: "A charging authority must use 'appropriate available evidence' to inform their draft charging schedule...Charging authorities need to demonstrate that their proposed levy rate or rates are informed by 'appropriate available' evidence and consistent with that evidence across their areas as a whole.'.

Object

Community Infrastructure Levy (CIL)

Representation ID: 1729

Received: 30/01/2015

Respondent: Cogent Land LLP (Cogent)

Representation Summary:

In light of these decisions, we are therefore of the view that a "nominal" rate of £20 per sq m is not appropriate. Particularly as the evidence base prepared by BNP clearly indicates that the application of a CIL rate renders sites unviable.

We would therefore ask that SBC review their CIL rates.