Community Infrastructure Levy - Preliminary Draft Charging Schedule

Document Section Community Infrastructure Levy - Preliminary Draft Charging Schedule Spending the CIL Q17 Do you agree that this table sets out an appropriate split between CIL and Section 106 funded infrastructure? Are there any changes you would propose? [View all comments on this section]
Comment ID 1074881/cil/10
Respondent Deleted User [View all comments by this respondent]
Agent Deleted User
Response Date 04 Jan 2013
Current Status Accepted
Comment

The whole basis for CIL is to establish the strategic needs of an area through a Strategic Infrastructure Delivery Plan, quantify the costs and set a viable charging regime based upon this. It should not be the remit to then use the monies elsewhere, as this would bring into question the evidence base underpinning the charging schedule.

As set out earlier, it is of concern that the Infrastructure Delivery Plan is limited in the extent of information and published evidence to support the costs now being taken forward through CIL.

Mead Realisations Ltd does however support the need to prioritise some infrastructure projects and in consultation with its other partners, the priority should focus on enabling the two strategic developments at Parklands and Winterstoke villages.

The intention to take the maximum 5% administration fee has been questioned earlier. Given that the majority of development is strategic and owned/ operated by a small number of organisations and agencies, the need to charge 5% is questioned. There is no published evidence to suggest that administration will cost £7.45m? Is the Council intending to prepare a budget plan based upon this to explain the expenditure?

The Relationship Between CIL and Section 106 Agreements

The relationship between CIL and S106 is of paramount importance to the delivery of development. Whilst viability of CIL has been broadly tested (albeit with some reservations from Mead Realisations Ltd), the relationship with S106 contributions still needs to achieve the same viable result for development to proceed. The Council should recognise the need to retain flexibility through the S106 process to ensure viability can be achieved.

Some concern is expressed with regard to the ambiguity of the Table set out on pages 17-19 of the Primary draft charging schedule. For example it splits early and later phases of the strategic flood risk solution but gives no indication as to what that means? Furthermore, an arbitrary split is presented between synthetic sports pitch provision and other sports pitch provision? Again, it is questioned, why on large developments community halls are provided through the S106 process and for other developments they are provided through CIL? This would suggest that large developments will pay for this type of facility through CIL and also through S106 as there is no discounting mechanism for CIL.

A further mismatch arises when the table on pages 17-19 are compared with the IDP requirements set out on pages 8-10 of the Primary draft charging schedule. The Council appears to be basing the CIL on the requirements of key strategic projects, but is then listing a wider range of non-strategic projects where CIL might be spent. This brings into question the basis upon which CIL has been derived from the IDP or something else? It is suggested that a clearer distinction is drawn between CIL/ IDP needs and other S106 requirements.

Further questions are raised about how some of the strategic highway infrastructure is being apportioned to either CIL or S106 and there appears to be a mismatch again when the two sets of tables are compared. This can only lead to a confused position with regard to S106 negotiations and a protracted process of agreement.

Conclusion

Mead Realisations Ltd welcomes the opportunity to be consulted in relation to the preliminary draft CIL charging schedule. As it is currently presented, the CIL is somewhat confused and there is concern that any S106 negotiations which will sit alongside it could be protracted by this, thus delaying development.

The CIL should have a much closer relationship with IDP schemes and not be so wide ranging as to cause contributions to be sought twice through CIL and S106. CIL offers little flexibility and to remove the only relief provisions which may help delivery in the future is short sighted as they offer a good level of control and independent examination.

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