CIL Preliminary Draft Charging Schedule

Yn dangos sylwadau a ffurflenni 31 i 60 o 81

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 57730

Derbyniwyd: 29/07/2013

Ymatebydd: Gladman Developments

Asiant : Carter Jonas

Crynodeb o'r Gynrychiolaeth:

CIL should not be used as a Council's mechanism for creating an unrealistic wish list of infrastructure projects within their area.
When establishing a funding gap that CIL receipts are intended to contribute to the Council should take account of every possible income stream. This has to take account of future New Homes Bonus and Council Tax and Business Rates receipts generated as a result of new developments allocated in the Local Plan, as well as central government funding streams.

Atodiadau:

Warwick CIL preliminary draft charging schedule - Gladman reps.pdf (840.94 KB)
IMG letter to Warwick District Council - 290713 - V1.pdf (155.48 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 57731

Derbyniwyd: 30/07/2013

Ymatebydd: Rowington Parish Council

Crynodeb o'r Gynrychiolaeth:

The overriding concern of the Parish Council is that any CIL is levied on a particular site and remains attached to that site area i.e no levy should be consumed within a central "pot"

Because CIL is intended to be mandatory, smaller developments such as those likely to occur in the rural settlements, may be unable to bear the cost of this levy and developers will not therefore be encouraged to come forward.

Testun llawn:

* Strong support for the retention of open spaces (Green Belt and Special Landscape Areas) Difficult to comment further without information regarding potential changes to green belt boundaries.
* Clarification of the area referred to as "Rowington" is still required. Reference is made to the settlement of Kingswood as "Lapworth" when in fact a large part of Kingswod is within Rowington Parish
* The data gathering exercise for the Rowington Parish Design Statement provides a strong evidence base of the need for small infill developments of residential units for the young and elderly alike, which would allow a balanced community to be maintained in the rural areas. This appears to have been largely ignored within the Development Strategy at this point.
* It seems that rather than spread the burden of new development across Warwick District, much of the proposed new housing is in the form of concentrated and large scale developments. As mentioned above, the proposals have ignored the needs of the small rural villages in favour of the big developers who are only interested in such large scale developments.

Community Infrastructure Levy Preliminary Draft Charging Schedule

* The overriding concern of the Parish Council is that any CIL is levied on a particular site and remains attached to that site area i.e. no levy should be consumed within a central "pot"
* Because CIL is intended to be mandatory, smaller developments such as those likely to occur in the rural settlements, may be unable to bear the cost of this levy and developers will not therefore be encouraged to come forward.

Sustainability Appraisal and Gypsy and Traveller Site Options

* Need further clarification on the definition of a "pitch" and how this is to be utilised i.e. single or multiple occupancy per pitch? Not clear what is meant by a "pitch".
* Clear guidelines on the numbers of pitches per site and a preference for permanent as opposed to itinerant occupancy. Permanent occupancy may encourage occupants to become part of the community and therefore develop a sense of inclusion and ultimately, responsibility.
* Will the proposed sites/occupiers incur rental charges etc? As in the case of council accommodation provided by WDC. We believe that the occupiers should be subject to rental and other charges and would like to know how such charges will be collected by WDC.
* How will these sites be administered i.e. will the sites be self managing or managed by
WDC? We are concerned that the sites will certainly need to incur costs associated with hygiene, waste disposal, school transport and maintenance alongside overall supervision/administration costs if they are to remain usable. These costs are running costs as opposed to capital infrastructure costs mentioned below.
* What are the likely costs of the provision of necessary infrastructure for these sites and how will such infrastructure be funded.
* Following the creation of approved sites, how will the settlement of travellers or gypsies of the type that are "unpredictable economic migrants" be handled in the event of their occupation of sites over and above the official sites provided?

Sylw

Preliminary Draft Charging Schedule

ID sylw: 59398

Derbyniwyd: 10/07/2013

Ymatebydd: Mr Simon Taylor

Crynodeb o'r Gynrychiolaeth:

Currently have one senior school and one sixth form in Kenilworth. 770 homes could bring another 1,400 plus children requiring education to Kenilworth. Will a new senior school be built? How will the sixth form be expanded to cope with the increased demand as it is already oversubscribed?

Testun llawn:

PO1 - Level of Growth
Where is this predicted growth to warrant 770 new homes in Kenilworth coming from? indigenous growth within Kenilworth or is it from increasing immigration from outside the UK? a very concerning development for the future make up of the town, though one I am sure one the Council does not want to accept as it is not deemed politically correct to talk about immigration.
Leamington residents are commenting to me about the increasing Polish community there with the associated difficulties that brings.

P02 Community Infrastructure Levy
Currently we have one senior school and one sixth form in Kenilworth, 770 homes could bring another 1400 plus children requiring education to Kenilworth, will a new senior school be built? How will the sixth form be expanded to cope with the increased demand? - I understand it is already oversubscribed.

P07 - Gypsies and Travellers
I would fully support that the District does not have any sites for Gypsies and Travellers. Why is consideration being given to non tax paying groups? It would appear to me they are given more consideration than tax payers, look at the time and resource to remove them from Beausale, I am sure if I infringed planning regulations I would not be afforded the leniency they have been afforded.
What is happening with Brookside Willows caravan park outside Warwick, I see a lot has been spent by Local Authorities on this "travellers" site and it remains empty.
Why are WDC rewarding this group, look at the cost and chaos the Horse fair causes in and around Kenilworth.

P08 - Economy
What employment opportunities beyond the building of the houses does the Kenilworth development offer? I cannot see any.

P016 - Green Belt
I do not believe the Local Authorities have given any consideration to retaining the Green Belt around Kenilworth, the intention would appear to be to destroy it.

For the above reasons I would like to register my strong opposition to the above elements of this Local Plan, these are not "preferred options" for Kenilworth or it's residents.

I look forward to your response

Cefnogi

Preliminary Draft Charging Schedule

ID sylw: 59671

Derbyniwyd: 29/07/2013

Ymatebydd: Hallam Land Management and William Davis

Asiant : Marrons

Crynodeb o'r Gynrychiolaeth:

Supports the preparation of a Community Infrastructure Levy (CIL) to fund the infrastructure needed to service the sites south of Warwick.

Atodiadau:

8278_R.pdf (19.63 MB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 59889

Derbyniwyd: 29/07/2013

Ymatebydd: Walter Bush

Crynodeb o'r Gynrychiolaeth:

Needs to be a consistent levy across the board to reflect the impact on communities and ensure that commercial development fund the true cost. Employment development such as the Gateway should not be exempt simply because they are not viable.

Atodiadau:

391_R.pdf (927.78 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 60038

Derbyniwyd: 29/07/2013

Ymatebydd: Highways England

Crynodeb o'r Gynrychiolaeth:

The Highways Agency is keen to ensure that it is fully involved in further discussions as the CIL charging scheme develops. This is particularly important in respect of any priority list of infrastructure projects, particularly in terms of drawing up the Regulation 123 list of CIL infrastructure and how the listed schemes would interrelate with other requirements secured via other means such as Section 106 Obligations and Section 278 Agreements and with the list of transport related mitigation schemes as set out in the revised development strategy.

The HA believe it is critical that the relevant mechanisms dovetail and are prioritised/ managed effectively to ensure timely provision of the necessary infrastructure in parallel with new development to ensure that impacts arising from new development are acceptable.

The HA will continue to work collaboratively with the Council and Warwickshire County Council as the local highway authority to ensure that the necessary infrastructure is identified and deliverable.

Atodiadau:

SKMBT_42313072916180.pdf (90.71 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63277

Derbyniwyd: 26/07/2013

Ymatebydd: H E Johnson

Asiant : Bond Dickinson LLP

Crynodeb o'r Gynrychiolaeth:

We also note that paragraph 6.17 of the CIL Viability Study states that where a scheme is unviable before application of CIL, it will need to be the Section 106 requirement that changes in order to make the development viable. Where this is the intended approach (rather than exemption from CIL), it should be made express in the explanatory text to the Charging Schedule and cross referenced to Local Plan policy.

Atodiadau:

9603_R.pdf (387.21 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63278

Derbyniwyd: 26/07/2013

Ymatebydd: H E Johnson

Asiant : Bond Dickinson LLP

Crynodeb o'r Gynrychiolaeth:

Para 5.1

We welcome the proposed exemption from CIL of the parts of a development which are to be used for affordable housing but suggest that where such a high proportion as 40% affordable housing is required, this exemption may not go far enough, and consideration should be given to exempting the whole Red House Farm site from CIL

Atodiadau:

9603_R.pdf (387.21 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63279

Derbyniwyd: 26/07/2013

Ymatebydd: H E Johnson

Asiant : Bond Dickinson LLP

Crynodeb o'r Gynrychiolaeth:

Appendix A

The Residential Zones plan shows land between Lillington and Cubbington as Zone A and the extended RHF site shown by a broken red line at Figure 1 to Appendix 1 of the Bruton Knowles Representations, in Zone D for the purposes of the Draft Charging Schedule. We object to this categorisation and submit that it is necessary to categorise the whole of the RHF site in zone A and define it as a Strategic Site with the lower charging level for regeneration purposes and that the land between Lillington and Cubbinton, which the SHLAA identifies as not suitable for development, is categorised at the higher level Zone D.

Atodiadau:

9603_R.pdf (387.21 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63280

Derbyniwyd: 26/07/2013

Ymatebydd: Home Builders Federation Ltd

Crynodeb o'r Gynrychiolaeth:

Considers that the Council has prepared its viability study in advance of a detailed IDP and that the imposition of CIL Levy Rate should balance the deliverability of funding infrastructure from the levy and the potential effects on the development across the area.

Atodiadau:

7773_R.pdf (875.29 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63281

Derbyniwyd: 26/07/2013

Ymatebydd: Home Builders Federation Ltd

Crynodeb o'r Gynrychiolaeth:

Implies that Council has not set out clearly what developers will be expected to pay through the route of S106 (to avoid paying twice for the same item).
S106 should be scaled back to those matters that are directly related to a specific site (not set on the Reg 123 list).

Atodiadau:

7773_R.pdf (875.29 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63282

Derbyniwyd: 26/07/2013

Ymatebydd: Home Builders Federation Ltd

Crynodeb o'r Gynrychiolaeth:

Suggest that the PDCS does not take account of national regulatory changes to be implemented in relation to build costs. An example being potential changes to building regulations that will have to be met to meet Code for Sustainable Homes Level 5.
Section 5 of the RDS consultation proposes that 25% of homes are built to lifetime homes standards. It is stated that the cost of complyin with this is a further £1525 per dwelling.
Sales and marketing costs in the viability study are set at the lowest percentage of 3%. The Harman Report recommends between 3-5% of gross development value.

Atodiadau:

7773_R.pdf (875.29 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63283

Derbyniwyd: 26/07/2013

Ymatebydd: Home Builders Federation Ltd

Crynodeb o'r Gynrychiolaeth:

The viability assessment appears to use a reduced profit margin of 6% for the affordable housing. The validity of this is questionable and suggests that a figure of 20% of GDV is reasonable.
On land values the Harman Report recommends a premium over current value, plus the use of a viability cushion. The appropriate premium is to be determined locally. The premium used by BNP Paribas is 20% above CUV.
The Harman Report recognises that green field and strategic sites will necessitate the greater use of benchamarks. The correct benchmarking of land values is critical given that 66% of the RDS is green field.

Atodiadau:

7773_R.pdf (875.29 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63284

Derbyniwyd: 26/07/2013

Ymatebydd: Home Builders Federation Ltd

Crynodeb o'r Gynrychiolaeth:

Section 5 of the RDS consultation proposes 40% affordable housing on new developments. The Council must reconcile the proposed CIL charges with its affordable housing policy. The Council must be mindful of the Mid Devon CIL Examiners report, which reduced the proposed residential CIL rate as the LPA had failed to take into account the appropriate rate of affordable housing.

Atodiadau:

7773_R.pdf (875.29 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63287

Derbyniwyd: 29/07/2013

Ymatebydd: Gallagher Estates

Asiant : Pegasus Group

Crynodeb o'r Gynrychiolaeth:

Concerned regarding the relationship between CIL and the continued use of s106.
There needs to be absolute clarity between the relationship and the extent to which s106 will be required on individual schemes.
Will education, open space/leisure contributions be financed through CIL or s106?

Atodiadau:

014JH.CILRepsLetter290713.pdf (1.08 MB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63288

Derbyniwyd: 29/07/2013

Ymatebydd: Gallagher Estates

Asiant : Pegasus Group

Crynodeb o'r Gynrychiolaeth:

The CIL Viability Study make a blanket assumption of £10,000 per unit but there is no explanation of the basis for this assumption. There is therefore a lack of clarity between CIL/s106. The future charging schedule address this and be accompanied by a clear explanation.
£90.00 per sqm on strategic sites zone B CIL for residential will impact significantly. The level to which CIL can be implemented without impacting on viability needs to be clearly established and the relationship between s106 needs to be set out.

Atodiadau:

014JH.CILRepsLetter290713.pdf (1.08 MB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63289

Derbyniwyd: 29/07/2013

Ymatebydd: A C Lloyd Homes Ltd and Northern Trust

Asiant : Framptons

Crynodeb o'r Gynrychiolaeth:

Charges should differentiate between previously developed land and greenfield.

Atodiadau:

6105_R.pdf (440.52 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63290

Derbyniwyd: 29/07/2013

Ymatebydd: A C Lloyd Homes Ltd and Northern Trust

Asiant : Framptons

Crynodeb o'r Gynrychiolaeth:

The Council has not fully ascertained its level of growth in the RDS and will not therefore have a full understanding of its infrastructure requirements.

The draft document does not quantify the infrastructure funding gap.

Atodiadau:

6105_R.pdf (440.52 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63291

Derbyniwyd: 29/07/2013

Ymatebydd: A C Lloyd Homes Ltd and Northern Trust

Asiant : Framptons

Crynodeb o'r Gynrychiolaeth:

The BNP Viability study does not take account of the estimated infrastructure costs associated with the strategic sites in the Local Plan. The exercise is simply an appraisal of current land values

Atodiadau:

6105_R.pdf (440.52 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63292

Derbyniwyd: 29/07/2013

Ymatebydd: A C Lloyd Homes Ltd and Northern Trust

Asiant : Framptons

Crynodeb o'r Gynrychiolaeth:

The variation in the scale of the charges is too wide and potentially onerous in Zone B.

Atodiadau:

6105_R.pdf (440.52 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63293

Derbyniwyd: 29/07/2013

Ymatebydd: Gladman Developments

Asiant : Carter Jonas

Crynodeb o'r Gynrychiolaeth:

CIL should be set at a level that does not put at risk the overall development of an area. The rate will also need to be appropriate over time, bearing in mind land values, market conditions and the wider economic climate.

Atodiadau:

Warwick CIL preliminary draft charging schedule - Gladman reps.pdf (840.94 KB)
IMG letter to Warwick District Council - 290713 - V1.pdf (155.48 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63294

Derbyniwyd: 29/07/2013

Ymatebydd: Gladman Developments

Asiant : Carter Jonas

Crynodeb o'r Gynrychiolaeth:

The Council should ensure that it has a full understanding of the potential costs of infrastructure projects. Gladman believes it is inappropriate to set the levy based on a partial understanding of infrastructure costs.

Atodiadau:

Warwick CIL preliminary draft charging schedule - Gladman reps.pdf (840.94 KB)
IMG letter to Warwick District Council - 290713 - V1.pdf (155.48 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63295

Derbyniwyd: 29/07/2013

Ymatebydd: Gladman Developments

Asiant : Carter Jonas

Crynodeb o'r Gynrychiolaeth:

CIL levy rates should be realistic and not set too high. Arbitrarily high rates may jeopardise the delivery of housing schemes and be contrary to the Government aim of "significantly boosting the supply of housing".

Atodiadau:

Warwick CIL preliminary draft charging schedule - Gladman reps.pdf (840.94 KB)
IMG letter to Warwick District Council - 290713 - V1.pdf (155.48 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63296

Derbyniwyd: 29/07/2013

Ymatebydd: Gladman Developments

Asiant : Carter Jonas

Crynodeb o'r Gynrychiolaeth:

Gladman would urge the Council to adopt an instalments policy for CIL payments. This will facilitate cash flow and therefore development viability.
The Council should be reminded of the need to review CIL tariffs once these have been set.

Atodiadau:

Warwick CIL preliminary draft charging schedule - Gladman reps.pdf (840.94 KB)
IMG letter to Warwick District Council - 290713 - V1.pdf (155.48 KB)

Gwrthwynebu

Preliminary Draft Charging Schedule

ID sylw: 63297

Derbyniwyd: 29/07/2013

Ymatebydd: Sainsbury's Supermarkets Ltd

Asiant : Turley Associates

Crynodeb o'r Gynrychiolaeth:

The Draft charging schedule proposes alternative rates for different areas in relation to retail development. This approach is confused by the inclusion of the superstores, supermarkets and retail parks category which is defined by type and not location (zone).
The Council needs to demonstrate that a distinction can be made between the described uses. This needs to be supported by fine grain viability evidence to demonstrate their different viability characteristics. It is considered that this has not been done and this part of the charging schedule does not comply with the regulations.

Testun llawn:

6195.pdf (168.80 KB)