Draft Charging Schedule and Draft Regulation 123 List
Representation ID: 21767
Respondent: Bovis Homes Ltd
Proposed R123 list
Bovis Homes Ltd does not agree with the regulation 123 list's exclusion of a new primary school and nursery at the NE Bexhill Strategic Allocation from the items covered by CIL. If related education facilities are required, which is the case in NE Bexhill, effectively the NE Bexhill strategic allocation's landowners/developers are being charged twice, to fund primary education facilities related to their development and also other primary education provision elsewhere in Bexhill. Education 'bill' is very significant part of the s106, a key component of determining the allocation's viability. Education facilities should be provided through CIL.
Proposed CIL charge rates for Strategic Allocations (paragraph 9)
Bovis Homes Ltd is in the process of preparing a masterplan to support a planning application for the Strategic Allocation at North East Bexhill. The masterplan is still in preparation and discussions continue with the Council to agree the scheme's parameters/development quantums (residential and commercial uses, open space and other supporting infrastructure etc). Discussions have also commenced with the Council regarding the S106 to accompany the planning application. Currently the S106 is progressing on the basis that the application will be determined prior to the adoption of CIL, but with the potential for it to be varied should CIL be adopted prior to the determination of the application.
Bovis Homes Ltd are preparing a cost and viability model to inform the planning application and S106 discussions and until such time as the scheme's parameters/development quantums and its accompanying s106 package (i.e. including those items that would still be required in the event of CIL being adopted) are agreed with the Council, the cost and viability model cannot be finalised and it is not yet possible to properly and thoroughly test the scheme's viability, taking into account the impact of the proposed CIL rate (£100), additional s106 package and the local housing market conditions etc. It is therefore not yet possible to confirm whether or not, the proposed CIL rate of £100 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 Strategic Allocations rate may be on the high side, particularly as primary education provision and off site highways infrastructure is excluded from CIL for the strategic allocation (reg 123 list).
Bovis Homes Ltd therefore wish to register a holding representation and reserve the right to provide a more definitive answer on the CIL Charge rate and site viability (based on an agreed masterplan and up-to-date cost/market condition information) potentially through written statements prior to the CIL examination (if requested by the Inspector) and at the hearing sessions.
CIL Charging Zones (paragraph 10)
Bovis Homes Ltd supports the proposal that strategic allocations have their own charging zone.
Proposed Instalment Policy (paragraph 12)
Bovis Homes Ltd considers it essential to introduce an instalment policy for strategic allocations. Without such an approach, the initial CIL liability may render the scheme unviable. Bovis Homes Ltd, hope to be consulted on the Instalment policy for the Strategic Allocations.
Exemptions and Discretionary Relief from CIL (paragraph 15)
Bovis Homes Ltd consider it essential for local discretion on CIL charging, particularly on strategic allocations to take account of viability issues and should the Council's prioritise affordable housing over CIL receipts.
Proposed Regulation 123 list (paragraph 17)
Bovis Homes Ltd does not agree with the regulation 123 list's exclusion of a new primary school and nursery at the NE Bexhill Strategic Allocation from the items covered by CIL. If related education facilities are required, which is the case in NE Bexhill, effectively the NE Bexhill strategic allocation's landowners/developers are being charged twice, to fund primary education facilities related to their development and also other primary education provision elsewhere in Bexhill. The education 'bill' is very significant part of the s106 and a key component of determining the allocation's viability. All education facilities should be provided through CIL.
NE Bexhill land values (PBA report)
The PBA report does not confirm whether the NE Bexhill Strategic Allocation threshold land value of £700,000 is related to a net developable hectare or gross developable hectare of the strategic allocation. The NE Bexhill masterplan currently has a relatively low (compared to smaller sites) net to gross development ratio, due to the need for strategic open space corridors, landscaping, sports pitches, primary school and ecology mitigation corridors etc. Bovis Homes Ltd will have clearer view of the threshold land values at NE Bexhill following the completion of the viability modelling, and will be able to advise through the submission of additional material to/appearance at the hearings. Also, the fact the Council has allowed for elements of the NE Bexhill Strategic Allocation in advance of the main part of the site will have some effects on viability and threshold land values.