Cefnogi

ID sylw: 70317

Derbyniwyd: 16/01/2017

Ymatebydd: Bob Dilworth Design Ltd

No specific comments to make other than the proposal seems broadly in line with adopted CIL policies within neighbouring Local Authorities.

Cefnogi

ID sylw: 70318

Derbyniwyd: 17/01/2017

Ymatebydd: The Theatres Trust

Just a nitpicking comment - while it is implied that other uses not listed in table 2 are a nil rate by their omission, it may be useful to replace the final line for D1/ D2 with 'All other uses' to avoid future ambiguity.

Gwrthwynebu

ID sylw: 70319

Derbyniwyd: 17/01/2017

Ymatebydd: Hill Close Gardens

I am unhappy that land at Blackdown is identified for housing when the site is not in the current Draft Local Plan.
It should not be there.

Gwrthwynebu

ID sylw: 70320

Derbyniwyd: 18/01/2017

Ymatebydd: Mrs Sidney Syson

I do not object to the CIL proposals, but I do object to the fact that in the refreshed viability one of the sites referred to is 66.74 ha at Blackdown providing for 1665 houses.
This site is in the Green Belt and not in the current Draft Local Plan.

Gwrthwynebu

ID sylw: 70328

Derbyniwyd: 07/02/2017

Ymatebydd: Baginton Parish Council

Baginton Parish Council believes that the revised Draft Charging Schedule does not satisfactorily address the impact that some types of development will make on the community. Hotels and Industrial/Warehousing should not be Nil Band developments. This is especially true where Green Belt Land is utilised.
We would ask that a levy is charged on these types of development and would welcome a higher levy being charged on development in Green Belt. This would offset the loss of amenity to the community and actively encourage developments on non Green Belt sites as a more sustainable land management approach from WDC.

Cefnogi

ID sylw: 70329

Derbyniwyd: 10/02/2017

Ymatebydd: Budbrooke Parish Council

Budbrooke Parish Council believes that the parish of Budbrooke should be re-designated as Zone D in line with other villages within Budbrooke Ward.

Gwrthwynebu

ID sylw: 70330

Derbyniwyd: 17/02/2017

Ymatebydd: Hallam Land Management & William Davies Ltd

Asiant : Marrons Planning

An objection is raised on the basis that the evidence that has been provided shows the proposed rate or rates would threaten delivery of the relevant Plan as a whole. The Study Update adopts a benchmark land value for greenfield residential sites of between £247,000 to £371,000 per hectare based on a CLG Research Paper from 2011. These figures are very low, and if this assumption is carried forward will have a significant effect on the viability of development in the District.

Gwrthwynebu

ID sylw: 70331

Derbyniwyd: 17/02/2017

Ymatebydd: The Richborough Estates Partnership LLP

Asiant : Star Planning and Development

Richborough Estates seek the redefinition of Charging Zone A to include Site H51 at Hampton Magna in the same way that Site H27 is included within Charging Zone A rather than Charging Zone D. There appears no rationale or objective basis for a different approach to these sites being adopted.

Gwrthwynebu

ID sylw: 70333

Derbyniwyd: 20/02/2017

Ymatebydd: Landowner and Developer Consortium

Asiant : Savills

Please see attached full representation.

This is made without inclusion of any update to national, regional or local planning policy as a result of the Housing White Paper (published 7th February 2017), and subsequent consultation on CIL. We would particularly welcome the opportunity to revisit these representations should the results of the CIL consultation exercise, and change in Government approach to CIL, be published before the Examination of the Draft Charging Schedule.

Gwrthwynebu

ID sylw: 70334

Derbyniwyd: 20/02/2017

Ymatebydd: McCarthy and Stone Retirement Lifestyles Ltd

Asiant : The Planning Bureau

Test dummy etc

Gwrthwynebu

ID sylw: 70345

Derbyniwyd: 16/02/2017

Ymatebydd: Mr G E Cooper

The Joint Parish Council notes that the Draft Charging Schedules have been calculated using a hypothetical development plan which is broadly based on the 2013 draft of the Local Plan. Since 2013 there have been substantial changes to the draft Local Plan. For example, a substantial 'Strategic Development' of over 1000 homes at Blackdown has been removed from the draft Local Plan.
The Joint Parish Council is concerned that using a hypothetical development plan, which will be materially different from the final Local Plan, as the basis for the calculation of the Community Infrastructure Levy could result in materially inaccurate Levy rates. For this reason, the Joint Parish Council believes that the completion of the Community Infrastructure Levy rates should await the determination of the Local Plan and that the rates should be calculated on the basis of the actual Local Plan rather than a hypothetical development plan.

Gwrthwynebu

ID sylw: 70346

Derbyniwyd: 17/02/2017

Ymatebydd: Framptons

Comments on behalf of A C Lloyd Limited who have interests in a number of sites proposed to be allocated in the emerging Local Plan.
 South of Harbury Lane, Warwick (Proposed CIL Zone B)
 South of Sydenham (Proposed CIL Zone A)
 Land at Radford Semele (Proposed CIL Zone A)
 Land at Bishops Tachbrook (Proposed CIL Zone B)
 Land at Kingswood (Proposed CIL Zone D)
A C Lloyd Limited supported the parallel production of a CIL Charging regime and Local Plan.
Have reviewed the BNP Paribas 'Community Infrastructure Levy: Viability Study (2016 update)' in formulating submissions.
It is submitted that further justification for the proposed charging rates should be provided as the CIL document progresses towards adoption. The following should be taken into account:
1. The charges should differentiate between Previously Developed Land and Green field sites.
2. The document should identify what the funding gap is at paragraph 2.3 and provide a summary of the IDP. It should state whether the IDP funding gap is a 'fixed' figure or a
'moving target'.
3. The Council states in paragraph 2.5 that "it is clear that in the short to medium term there is a
significant gap between available funds from government and other agencies and the cost of infrastructure needed to support and mitigate planned growth. The introduction of CIL in the District will help to fill part of this funding gap." The draft document does not state what the perceived 'gap' is.
4. The draft document refers to an analysis of viability that has been undertaking by BNP Paribas to demonstrate that CIL is set at a level that will not prevent development. This is meaningless without knowing what level of 'gap' funding is sought.
This study has been commissioned to contribute towards an evidence base to inform Warwick District Council's ('the Council') CIL Charging Schedule ('CS'), as required by Regulation 14 of the CIL Regulations April 2010 (as subsequently amended). The aims of the study are summarised as follows:
 to test the impact upon the economics of residential development of a range of levels of CIL;
 for residential schemes, to test CIL alongside the Council's requirements for 40% affordable housing on sites of 10 or more units within urban areas and on sites of 5 or
more units in rural areas; as well as other planning obligations; and
 to test the ability of commercial schemes to make a contribution towards infrastructure through CIL.
It is considered that
1. The proposed charging rates and exceptions need to be linked to accurate and robust evidence on the 'costs' side of the equation to be sure that they are realistic.
2. It is not clear how the draft charging zones have been defined and the boundaries of the zones have been drawn
3. The recommended CIL charges set out in the Viability Study seem to be based on reduced affordable housing targets (20% for Warwick and low value rural; 30% for Kenilworth), not the 40% affordable housing requirement included in the Local Plan.
4. Under most scenarios for Warwick and the low value rural area, CIL would not be viable, but a £70 charge is proposed
5. The Viability Study shows that residential development type, the size of the development and proposed housing density and mix will have a significant bearing on viability with the proposed CIL charges making certain types of developments unviable
6. Have the benchmark land values been robustly justified?
7. Is the proposed the S106/S278 allowance underlying the viability study appropriate (£1,500 per dwelling)?
8. Is the assumed profit level (15%) sufficient?
9. It is submitted that the variation in the scale of the charge is too wide and potentially onerous in Zone B which will in itself be a disincentive to development taking place.
10. We are concerned that the document does not provide a clear statement as to what is included and excluded from the CIL charge. The document could usefully
include a table that identifies in more detail what types of infrastructure are included, or excluded, for different types of development.
This would avoid any confusion about what CIL is providing and avoid any criticism of 'double
dipping'.
I trust therefore that you will review and supplement the evidence base for the costs element of the CIL and re-issue for consultation.

Gwrthwynebu

ID sylw: 70347

Derbyniwyd: 17/02/2017

Ymatebydd: Delta Planning

Comments on behalf of A C Lloyd and Delta Planning who have interests in a number of sites proposed to be allocated in the emerging Local Plan.
* South of Harbury Lane, Warwick (Proposed CIL Zone B)
* South of Sydenham (Proposed CIL Zone A)
* Land at Radford Semele (Proposed CIL Zone A)
* Land at Bishops Tachbrook (Proposed CIL Zone B)
* Land at Kingswood (Proposed CIL Zone D)
A C Lloyd Limited supported the parallel production of a CIL Charging regime and Local Plan.
Have reviewed the BNP Paribas 'Community Infrastructure Levy: Viability Study (2016 update)' in formulating submissions.
It is submitted that further justification for the proposed charging rates should be provided as the CIL document progresses towards adoption. The following should be taken into account:
1. The charges should differentiate between Previously Developed Land and Green field sites.
2. The document should identify what the funding gap is at paragraph 2.3 and provide a summary of the IDP. It should state whether the IDP funding gap is a 'fixed' figure or a
'moving target'.
3. The Council states in paragraph 2.5 that "it is clear that in the short to medium term there is a
significant gap between available funds from government and other agencies and the cost of infrastructure needed to support and mitigate planned growth. The introduction of CIL in the District will help to fill part of this funding gap." The draft document does not state what the perceived 'gap' is.
4. The draft document refers to an analysis of viability that has been undertaking by BNP Paribas to demonstrate that CIL is set at a level that will not prevent development. This is meaningless without knowing what level of 'gap' funding is sought.
This study has been commissioned to contribute towards an evidence base to inform Warwick District Council's ('the Council') CIL Charging Schedule ('CS'), as required by Regulation 14 of the CIL Regulations April 2010 (as subsequently amended). The aims of the study are summarised as follows:
* to test the impact upon the economics of residential development of a range of levels of CIL;
* for residential schemes, to test CIL alongside the Council's requirements for 40% affordable housing on sites of 10 or more units within urban areas and on sites of 5 or
more units in rural areas; as well as other planning obligations; and
* to test the ability of commercial schemes to make a contribution towards infrastructure through CIL.
It is considered that
1. The proposed charging rates and exceptions need to be linked to accurate and robust evidence on the 'costs' side of the equation to be sure that they are realistic.
2. It is not clear how the draft charging zones have been defined and the boundaries of the zones have been drawn
3. The recommended CIL charges set out in the Viability Study seem to be based on reduced affordable housing targets (20% for Warwick and low value rural; 30% for Kenilworth), not the 40% affordable housing requirement included in the Local Plan.
4. Under most scenarios for Warwick and the low value rural area, CIL would not be viable, but a £70 charge is proposed
5. The Viability Study shows that residential development type, the size of the development and proposed housing density and mix will have a significant bearing on viability with the proposed CIL charges making certain types of developments unviable
6. Have the benchmark land values been robustly justified?
7. Is the proposed the S106/S278 allowance underlying the viability study appropriate (£1,500 per dwelling)?
8. Is the assumed profit level (15%) sufficient?
9. It is submitted that the variation in the scale of the charge is too wide and potentially onerous in Zone B which will in itself be a disincentive to development taking place.
10. We are concerned that the document does not provide a clear statement as to what is included and excluded from the CIL charge. The document could usefully
include a table that identifies in more detail what types of infrastructure are included, or excluded, for different types of development.
This would avoid any confusion about what CIL is providing and avoid any criticism of 'double
dipping'.
I trust therefore that you will review and supplement the evidence base for the costs element of the CIL and re-issue for consultation.

Gwrthwynebu

ID sylw: 70348

Derbyniwyd: 27/01/2017

Ymatebydd: Leamington Society

L48 Land at Blackdown (extension to L Spa)
Also in Appendix 4 (all schedules)
The site is not in the WDC Local Plan and is in the Green Belt. It is therefore inappropriate to calculate CIL charges for residential development there.

Gwrthwynebu

ID sylw: 70349

Derbyniwyd: 21/02/2017

Ymatebydd: Mrs Ann Kelsey

CIL contribution should be applied to all new developments as all benefit from the infrastructure.
For housing, this contribution should be a very small percentage of the market value of the property, which would enable the quantum assessment to accommodate economic fluctuations and be up-to-date without the need to frequently reassess the whole schedule. It would share the burden more equitably.
An overly complex model has resulted in a schedule which is both cumbersome and unfair.
Of the 5 strategic sites selected for the Viability Study, Blackdown was by far the largest designated for up to 1600 houses, but failing to include construction and maintenance of supporting infrastructure such as school, medical services, green spaces or shops. This site had been removed which makes nonsense of including it in a meaningful Viability Study.
Blackdown and Old Milverton are rural farming areas but were categorised in the 2013 CIL as urban fringe development areas. This issue was raised in the submissions at that time but has not been corrected.
These farming parishes consist of just a hamlet, surrounded by extensive fields. The land values should be in the highest rural category for the purpose of accurate CIL calculations.
If the complex viability study had been based on accurate information, then more confidence could be placed in the Draft Community Infrastructure Levy Report being reliable, useful and worthy of support.
Further thoughts for consideration
1. Further adjustments should be considered to take into account infrastructure projects that may never be built
2. The infrastructure levy should be applied just to those who would benefit most from the proposed developments.

Gwrthwynebu

ID sylw: 70350

Derbyniwyd: 20/02/2017

Ymatebydd: Savills

Kings Hill (allocated for residential led development within the emerging Warwick Local Plan).
The objective of this representation is not to oppose CIL; it seeks clarity in regard to the proposed rates.
The Proposed CIL Charges
This representation is concerned with the proposed CIL rates for strategic residential sites allocated within the Local Plan. WDC propose differential rates for such development by geographical location. The proposed allocation at Kings Hill is located within Zone D and as a strategic residential development site, would be subject to a proposed rate of £55 per sq m.
LSL welcome the reduction in the CIL rate for this area from that proposed within the Preliminary Draft Charging Schedule (£110 per sq m).
We have some reservations over the assumptions used by BNP Paribas in respect of strategic residential build costs. The £12,000 per unit allowance for on-site infrastructure is considered to be too low.
Whilst it is stated that this is based on average infrastructure costs on strategic Greenfield sites in the south east no evidence is provided to support this within the BNP Paribas Study.
It is crucial that the assumption on infrastructure costs is not underestimated as this will have a significant impact on site viability, and if underestimated across the District, housing supply will be severely compromised.
Viability is at the forefront of Local Plan and CIL testing. It is therefore important that the Council fully understands the trade-off that occurs between affordable housing, Section 106 contributions and CIL when assessing the potential for charging a CIL rate in the District.
Regulations (as amended).
Regulation 14(1) of the CIL Regulations sets out the key test that the Charging Schedule is measured:
"In setting rates (including differential rates) in a charging schedule, a charging authority must strike an appropriate balance between -
a) The desirability of funding from CIL (in whole or in part) the actual and expected estimated total cost of infrastructure required to support the development of its area, taking in to account other actual and expected sources of funding; and
b) The potential effects (taken as a whole) of the imposition of CIL on the economic viability of development across its area."
The onus has therefore shifted away from being a matter of opinion to a matter of fact.
It is therefore of paramount importance that the proposed CIL rates are supported and consistent with the viability evidence and that the Council has undertaken sufficient work to demonstrate that the proposed rates will not put their housing supply at risk.
Deliverability of the Development Plan
The trajectories required by the LP allocations should not be made unviable. The NPPF supports.
The CIL Guidance2 confirms that Local Authorities must have an "up-to-date" development strategy and must be able to demonstrate how the proposed levy rates will contribute towards the implementation of the Local Plan.
The emerging Warwick District Plan, which was subject to Examination in 2015 and 2016, plans for at least 16,776 new homes between 2011 and 2029
WDC has proposed the allocation of land to the south of Coventry within the emerging Local Plan to help meet Coventry's need. This includes the allocation of land at Kings Hill for 4,000 dwellings, with 1,800 of these to be delivered within the plan period. The strategic nature of this site, and the fact that it is fundamental to the delivery of the overall strategy means that it is essential that sufficient viability testing has been undertaken at this stage in the process.
Large, strategic sites require a significant amount of land to enable them to deliver on-site infrastructure. The Council should take steps to ensure that the CIL charges are set well below the margins of viability to ensure that they do not threaten the delivery of the identified housing need.
Given the timescales and phasing which would inevitably be a part of developing a site of this strategic scale, it is important that CIL is considered in the round across the entire land in the Consortium's control.
Regulation 123 List
The Community Infrastructure Levy (Amendment) Regulations 2014 require the Regulation 123 list to form part of the evidence base (Regulation 14 (5)).
Warwick District published a Draft Regulation 123 List in January 2015 as part of a 'first' round of consultation on the Draft Charging Schedule however this has not been updated and published as part of the current stage of consultation.
Under the CIL Regulations, the Regulation 123 list should only include infrastructure necessary to deliver the objectives set out in the development plan. Infrastructure specific to a development therefore should not be included on this list to avoid 'double dipping'.
In the absence of an updated Regulation123 List it is unclear whether WDC fully understand the implications of Section 106 pooling post-CIL and its impact on its intended delivery mechanism for vital infrastructure in the District.
We therefore recommend that WDC produces a draft Planning Obligations SPD document to set out how CIL and Section 106 will work alongside one another on all sites. This should then be published for consultation.
Effective Operation of CIL
Despite the narrow scope of the Examination, we urge WDC to make clear at the earliest opportunity, the supporting documentation needed to operate CIL and to make it available for consultation, particularly the Regulation 123 List. Practically, this needs to be done as soon as possible.
Relief
The Warwick District CIL Charging Schedule proposes that where a developer can clearly demonstrate that a CIL Charge will impact on scheme viability and that the scheme can clearly deliver sustainable development, then the Council may consider the case for exceptional relief on a case by case basis".
LSL welcomes the Council's stance in understanding that there may be legitimate viability concerns that would otherwise impede the delivery of housing. This should be a factor in the consideration of a CIL rate for strategic residential sites such as Kings Hill, for which the delivery of the emerging Local Plan depends on.
Instalments
We note that WDC state that they are prepared to accept payment of CIL in instalments (depending in the total amount of the liability). WDC state that details of the instalments policy will be determined prior to adoption of CIL.
BNP Paribas have modelled instalment policies of 3 payments for all sites regardless of size. We request further clarity as to the extent this reflects current WDC policy.
Review
The CIL Guidance states that charging authorities 'must keep their Charging Schedules under review' to ensure that CIL is fulfilling its aim and responds to market conditions. The Consortium therefore requests that regular monitoring is undertaken by WDC to ensure that any detrimental impact of CIL on housing delivery is noticed promptly and remedied.

Gwrthwynebu

ID sylw: 70351

Derbyniwyd: 20/02/2017

Ymatebydd: McCarthy & Stone Retirement Lifestyles Ltd

Asiant : The Planning Bureau

The Warwick CIL viability evidence is one of the few that does not appear to test the viability of specialist housing. Given the extent of the projected housing need for older persons accommodation, it is paramount that the WDC CIL charging schedule does not provide a rate of CIL that renders these forms of development unviable within the Authority.
Despite our representations the Council has not deemed it necessary to test the viability of specialist older persons accommodation.
The Council's recently refreshed CIL Viability Update 2016, demonstrates that high density flatted developments will not be able to support CIL and policy compliant levels of affordable housing.
Specialist accommodation for the elderly is also high density flatted development on previously developed sites, albeit the viability is more marginal given the increased proportion of communal floor space and build costs. We therefore have significant concerns that the CIL rates as proposed will hinder the delivery of these forms of development in Warwick district.

Gwrthwynebu

ID sylw: 70352

Derbyniwyd: 20/02/2017

Ymatebydd: Gladman Developments

It is understood that the Council have now refreshed the evidence base which underpins the charging schedule and this letter sets out Gladmans' response to both the charging schedule and its accompanying evidence base.
The Council states in paragraph 4.2 of the charging schedule that the Councils responses were reported, to the 2013 consultation, in January 2015. Gladman noted in our last representation that these responses did not take into the consideration the points made by Carter Jonas in the duly made representation from 2013. We note that we have still seen no record from the Council that these representations have been considered, nor have we seen any counter point to the evidence put forward by Carter Jonas.
Although each CIL charging schedule needs to be locally evidenced, to take account of local circumstances, the proposed rates for Warwick District (Zones B and D) are the highest currently proposed of any authority in the East or West Midlands1. Indeed authorities, which may be considered good comparisons, such as Stratford-on- Avon and Solihull have upper end residential charges of £150 p/sqm. Whilst high these are nearly 25% lower than those proposed for Zones B and D in Warwick.
We have previously cautioned against the potential for such large CIL rates to have a negative impact of 'market shock' upon Warwick District.
Charging Zones
Gladman maintain the view that the proposed boundaries for the Charging Zones are not robustly justified. Whilst we understand the broad premise for the Charging Zones, it is not clear how the District Council has arrived at the proposed boundaries. Furthermore the map which accompanies the charging schedule is unclear.
CIL Viability Report
Gladman have considered the tables set out in the BNP Paribas report on pages 33 and 34. It is noted that a number of development scenarios are offered. We retain a number of concerns with regard to the way in which the evidence base has assessed the viability assumptions that the CIL charges will have, particularly about the cumulative impact of the CIL rate in the higher zones with an affordable housing requirement of 40%.
Regulation 123 List
The Regulation 123 infrastructure list has not been published. The Council will need to publish this documentation for comment. Local planning authorities need to be able to demonstrate the infrastructure need and subsequent funding gap and must ensure that the level of total CIL receipts that could be generated through the levy reflects the true needs and proposals in the Local Plan
When establishing a funding gap that CIL receipts are intended to contribute towards filling, it is vital that the Council take account of every possible income stream.
The Council need to have an up to date, robust evidence base that fully justifies the infrastructure needs based on the amount of development that is required. Information on these infrastructure needs should, wherever possible, be drawn directly from the infrastructure planning that underpins the Development Plan, as this should identify the quantum and type of infrastructure required to realise their local development needs.

Cefnogi

ID sylw: 70353

Derbyniwyd: 14/02/2017

Ymatebydd: Highways England

In Warwick District, the A45 and A46 trunk roads and the M40 are part of the SRN.
We have reviewed the Draft Charging Schedule, and it is considered that Highways
England has no comments to provide. We would however like to continue to engage
with the Council in regular reviews of the Regulation 123 List, and with regard to the
application of CIL funds for relevant highways infrastructure projects.

Gwrthwynebu

ID sylw: 70358

Derbyniwyd: 20/02/2017

Ymatebydd: Turley

The University's only concern is the proposed charge for student accommodation, which we note has increased from the previous Draft Charging Schedule 2013, from £80 per sq m to £100 per sq m. This is similar to supermarkets and retail parks, higher than some retail, and higher than hotels, offices, industrial warehouses and D1/D2 uses which attract no charge.
We note that one of the exemptions under para 6.1 of the Viability Study (2016) is for development by registered charities for the delivery of their charitable purposes, for which the University would qualify in respect of the development of its own residential accommodation.
The Viability Study prepared by BNP Paribas Real Estate in November 2016 states:
'If the University continues to develop its own student accommodation, developments would be exempt from CIL under Regulation 43, providing the provision of student accommodation is consistent with the University's charitable objectives. Consequently, only speculative student housing built by the private sector would be liable.'
We anticipate this would apply where the University develops student halls of residence on its own campus. We would appreciate clarification that this exemption would apply for off-campus accommodation.
The University is keen to ensure that purpose-built student accommodation can be provided in other locations, in order to reduce reliance on Houses in Multiple Occupation which can disproportionately affect existing communities.
The University previously raised the question of what infrastructure the levy would be contributing towards whose need arose from student accommodation. There was nothing evident in the IDP and no reference in either the 2013 or 2016 Viability Studies as to why a larger discount was applied in the earlier study than the more recent one between the contribution that can be afforded and that to be charged.

Gwrthwynebu

ID sylw: 70359

Derbyniwyd: 17/02/2017

Ymatebydd: WYG Planning and Environment

We object to the proposed 'convenience based supermarkets, superstores and retail park' charge rate of £105 per sqm identified in the RDCS (2017). We consider that the category is poorly defined, providing no clarity as to which forms of development it would apply to. We consider that the evidence base informing the proposed CIL charge for these types of development is not robust having not tested a sufficient range of sites/development and not taking account of up to date cost information.
Notwithstanding these concerns, we maintain that the initial increase in CIL rate between the publication of the PDCS and the DCS (as maintaining in the RDCS) is irrational, is unexplained and would have a disproportionate impact on these types of development, along with the unexplained removal of the 'retail other areas' category and what is constituted.
We consider that the CIL charge for these types of development (supermarket/superstore and retail park) should be zero rated. Failing that, any charge should not exceed that set out in the PDCS.

Gwrthwynebu

ID sylw: 70360

Derbyniwyd: 16/02/2017

Ymatebydd: Spitfire Bespoke Homes Ltd

The authority has not stated the date at which it will give notice for the relief for exceptional circumstances in its area.
In light of the viability issues at Aylesbury House Hotel, with the proposed development, it should be considered for exceptional relief from the £195 per square metre. Without this the scheme is not viable and will not come forward.

Gwrthwynebu

ID sylw: 70361

Derbyniwyd: 17/02/2017

Ymatebydd: CLLR Peter Phillips

Within my District Ward of Budbrooke, the villages of Barford, Hampton-on-the-Hill, Norton Lindsey, Hatton Park and Hatton Green are all classified as being Zone D.
Hampton Magna, which is very similar in character to Hatton Park, is classified as being in Zone A.
I would request that Hampton Magna should be reclassified to Zone D, in line with all of the other villages within Budbrooke Ward.
NB: At this stage I neither object nor support the proposals. This is merely a representation on behalf of my residents.

Gwrthwynebu

ID sylw: 70362

Derbyniwyd: 20/01/2017

Ymatebydd: Mrs Barbara Lynn

Please note that Blackdown is in the Green Belt and not in the Draft Local Plan. It should therefore not be shown on a map of zones.

Gwrthwynebu

ID sylw: 70363

Derbyniwyd: 17/02/2017

Ymatebydd: Turley

For the reasons set out within this representation, it is IM's firm view that the proposed charging rates within the CIL DCS are fundamentally flawed.
The CIL DCS is based upon an inadequate viability study (the VS 2016), which fails to represent appropriate available evidence in accordance with the CIL Regulations and PPG as a basis for setting CIL rates. It is considered that the flaws within the VS 2016 significantly overstate the propensity of sites to accommodate CIL and, consequently, the rates within the CIL DCS are erroneously skewed upwards.
IM has made multiple requests for additional clarifications, corrections and the preparation of additional supporting viability evidence within this representation. Without provision of this additional evidence, IM maintains that the CIL DCS should be found unsound at Examination.

Cefnogi

ID sylw: 70364

Derbyniwyd: 17/01/2017

Ymatebydd: HSE Health and Safety Executive

We have concluded that we have no representation to make at this stage of your local planning process. This is because there is insufficient information in the consultation document on the location and use class of sites that could be developed. In the absence of this information, HSE is unable to give advice regarding the compatibility of future developments within the consultation zones of major hazard establishments and MAHPs located in the area of your local plan.

Cefnogi

ID sylw: 70365

Derbyniwyd: 17/02/2017

Ymatebydd: Warwickshire County Council [Archaeological Information and Advice]

No comments to make on draft charging schedule.
The county council wishes to be involved in updates to documents.
WCC will work with the district on highway issues and delivery of sites.
Request reviews every two years.

Gwrthwynebu

ID sylw: 70407

Derbyniwyd: 20/02/2017

Ymatebydd: Kenilworth Town Council

1. Whilst little comment can be made as to the actual charging levels, Kenilworth Town Council appreciate the need for different rates across the District, but see the resulting zones as a rather coarse solution. There is as much logic for a variable rate within the town as there is between Kenilworth and Warwick. It would seem more logical to relate somehow to total house price rather than floor area, but the Town Council assume that this is not possible?

2. Kenilworth Town Council are totally intrigued by the defined boundary for Kenilworth, which reflects neither the Town Boundary nor the projected urban area in the Local Plan, and would welcome an explanation.

Cefnogi

ID sylw: 70408

Derbyniwyd: 20/02/2017

Ymatebydd: Sport England

Sport England do not object to the CIL Draft Charging Schedule but would like to make the following comments:

It is considered that the following three guidelines should apply:
1. CIL should specifically exclude any mitigation measures required to make a development proposal satisfactory in planning terms
2. CIL 123 lists should only include defined projects and not use generic statements such as 'Indoor Sports Provision' and 'Outdoor Sports Provision'.
3. CIL 123 lists should be kept to a list of major key priority projects and not seek to deliver all infrastructure.

Sport England therefore recommends:
1. The CIL list includes specific projects for sport facilities (indoor and/or outdoor) and not generic statements.
2. The statement clarifies that:
a. Mitigation for loss under NPPF Para 74 falls OUTSIDE of CIL
b. Clarification that S106 agreements will be used to secure new sports facilities needed to meet new demand arising from development for sports facilities (indoor and outdoor) where not already sought through the CIL (e.g. CIL may be used to fund a new leisure centre to meet growth in demand for swimming pool BUT S106's would be used to fund

Gwrthwynebu

ID sylw: 70409

Derbyniwyd: 20/02/2017

Ymatebydd: Building Arts CIC

It should be made clear that extensions to existing buildings are not to be charged.

Since only the ground space and roof space covered by the new development effects the need for access and additional water run off, it is unfair to charge for additional floors of living space.

1.4
2- 5 % of total development costs is a hefty fee, not a modest one, and a may encourage developers to cut corners and will raise house prices even more
Is this to replace Section 106 planning obligation? Is so, it would be better to make that clear.

There should be no discrepancy between area with or without a Neighbourhood Plan. Areas without a Neighbourhood Plan are probably more in need than those with, therefore the funds allocated to the Local communities should all be at the higher rate of 25%.

1.5
The infrastructure should include rainwater harvesting and renewable energy specifically.

All references to the direct impact of development should take into account environmental sustainability specifically. This is to be in accordance with
The Strategic Environmental Assessment Directive: Guidance for Planning Authorities

2.2
The list of items of new or improved infrastructure does not include provision for rainwater collection or renewable energy.