Gwrthwynebu

ID sylw: 56161

Derbyniwyd: 26/07/2013

Ymatebydd: Home Builders Federation Ltd

Confusion regarding zones A and B between para 4.3 and the zoning map caused by typing errors.

Gwrthwynebu

ID sylw: 63280

Derbyniwyd: 26/07/2013

Ymatebydd: Home Builders Federation Ltd

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.

Gwrthwynebu

ID sylw: 63281

Derbyniwyd: 26/07/2013

Ymatebydd: Home Builders Federation Ltd

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).

Gwrthwynebu

ID sylw: 63282

Derbyniwyd: 26/07/2013

Ymatebydd: Home Builders Federation Ltd

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.

Gwrthwynebu

ID sylw: 63283

Derbyniwyd: 26/07/2013

Ymatebydd: Home Builders Federation Ltd

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.

Gwrthwynebu

ID sylw: 63284

Derbyniwyd: 26/07/2013

Ymatebydd: Home Builders Federation Ltd

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.