Support

Community Infrastructure Levy (CIL) Preliminary Draft Charging Schedule and Regulation 123 List

Representation ID: 21690

Received: 26/09/2014

Respondent: Bovis Homes Ltd

Agent: Bidwells

Representation Summary:

Bovis Homes Ltd are content that strategic allocations have their own charging zone.

Full text:

PDCS Q3 - Do you agree with the proposed residential CIL charging zones?

Bovis Homes Ltd are content that strategic allocations have their own charging zone.

PDCS Q4 - Do you agree with the proposed CIL charge rates for residential uses?

Bovis Homes Ltd are in the process of preparing a masterplan for the Strategic Allocation at North East Bexhill. As soon as the scheme's parameters/development quantums are agreed with the Council, a cost and viability model will be prepared to test the scheme's viability and impact of CIL taking into account the local housing market conditions, a greater understanding of site development costs and S106 requirements not covered by CIL.

Due to unforeseen delays in agreeing the scheme's parameters, this cost and viability information will not be available before the preliminary CIL Consultation deadline on the 26 September 2014. It is therefore not yet possible to confirm whether the Council's proposed CIL rate of £100 per square metre for strategic allocations renders the NE Bexhill scheme unviable. However, experience on CIL rates in other comparable value areas would seem to suggest that the rate may be on the high side, particularly as education provision is excluded from CIL (reg 123 list). Bovis Homes Ltd therefore wish to reserve the right to provide a more definitive answer on site viability based on an agreed masterplan and up-to-date cost/market condition information through further consultation processes and potentially written statements prior to the CIL examination and at the hearing.

PDCS Q6 - Do you support the introduction of an instalment policy in Rother for CIL payments?

Bovis Homes Ltd consider it essential to introduce an instalment policy for strategic allocations. Without such an approach, the initial CIL liability may render the scheme unviable.

PDCS - Q7. Do you have any views on whether the District Council should introduce a discretionary and exceptional relief policy?

Bovis Homes Ltd consider it essential for local discretion on CIL charging, particularly on strategic allocations to take account of viability issues should they arise and should the Council's prioritise affordable housing provision over CIL receipts.

PCDS - Q8 Do you agree with the proposed Regulation 123 list?

Bexhill Homes Ltd do not agree with education facilities directly related to development being excluded from CIL. If related education facilities are required, which is the case in NE Bexhill, effectively the landowners/developers are being charged twice, to fund education facilities related to their development and other education provision elsewhere in Bexhill. The education 'bill' is very significant and a key component of determining viability. All education facilities should be provided through CIL