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Comment

Draft Charging Schedule and Draft Regulation 123 List

Representation ID: 21784

Received: 16/03/2015

Respondent: Robertsbridge Enterprise Group

Representation:

5 If it is possible to identify certain road projects in Bexhill, why has it not been possible to identify road projects elsewhere in Rother?

Full text:

On behalf of Robertsbridge Enterprise Group, we would wish to make the following comments:

1 Our first comment is unrelated to the specific detail in this consultation document, but is a simple question; why has it taken RDC so long to get to this stage, particularly in the light of its performance in using s106 obligations? The funding gap of £45m could have been so much smaller had RDC seized the opportunity from the start to investigate CIL.
2 The great differential between Zone 1 and Zone 2 rate at the boundary line seem very difficult to justify. By way of comparison, at the western boundary of Zone 1, Wealden are proposing charging £200, or £150 in the southern parts. That would appear to be a fairer differential, considering the relative few differences at the border between Zones 1 and Zone 2 as to the vibrancy and attractiveness of the respective communities.
3 We refer to the statement in Appendix 2 and particularly to the fact that it states: 'RDC retains the right to determine where CIL contributions are spent and projects and priorities will be set out through governance protocols'. Where then is the consultation about these all-important 'governance protocols' which would appear to go the heart of any fair operation of CIL levies?
4 It is interesting to note that the only place-specific projects referred to are in Bexhill, Battle and Rye. Why is this? Does it mean that priorities have already been accorded to these projects as they are now site-specific?
5 If it is possible to identify certain road projects in Bexhill, why has it not been possible to identify road projects elsewhere in Rother?
6 What consultation will take place with parishes, and in particular parishes with emerging Neighbourhood Plans, on specific ideas for the R123 list?
7 There are a number of worthy project ideas listed in Infrastructure Delivery Plan (February 2015) but no sites are identified. Therefore it is impossible to know whether any specific project, say for transport, (improvement of bus services) or (improvement to walking and cycling corridors) or (access improvements to stations) or (more bus/transport services serving groups with access difficulties) can be appreciatively assessed or indeed prioritised. The same question applies to other sections such as library services, green infrastructure, environment and emergency services.

If you need any further information, please let me know.

Yours faithfully

Stephen Hardy
Chairman
Robertsbridge Enterprise Group

Comment

Draft Charging Schedule and Draft Regulation 123 List

Representation ID: 21786

Received: 16/03/2015

Respondent: Robertsbridge Enterprise Group

Representation:

7 There are a number of worthy project ideas listed in Infrastructure Delivery Plan (February 2015) but no sites are identified. Therefore it is impossible to know whether any specific project, say for transport, (improvement of bus services) or (improvement to walking and cycling corridors) or (access improvements to stations) or (more bus/transport services serving groups with access difficulties) can be appreciatively assessed or indeed prioritised. The same question applies to other sections such as library services, green infrastructure, environment and emergency services.

Full text:

On behalf of Robertsbridge Enterprise Group, we would wish to make the following comments:

1 Our first comment is unrelated to the specific detail in this consultation document, but is a simple question; why has it taken RDC so long to get to this stage, particularly in the light of its performance in using s106 obligations? The funding gap of £45m could have been so much smaller had RDC seized the opportunity from the start to investigate CIL.
2 The great differential between Zone 1 and Zone 2 rate at the boundary line seem very difficult to justify. By way of comparison, at the western boundary of Zone 1, Wealden are proposing charging £200, or £150 in the southern parts. That would appear to be a fairer differential, considering the relative few differences at the border between Zones 1 and Zone 2 as to the vibrancy and attractiveness of the respective communities.
3 We refer to the statement in Appendix 2 and particularly to the fact that it states: 'RDC retains the right to determine where CIL contributions are spent and projects and priorities will be set out through governance protocols'. Where then is the consultation about these all-important 'governance protocols' which would appear to go the heart of any fair operation of CIL levies?
4 It is interesting to note that the only place-specific projects referred to are in Bexhill, Battle and Rye. Why is this? Does it mean that priorities have already been accorded to these projects as they are now site-specific?
5 If it is possible to identify certain road projects in Bexhill, why has it not been possible to identify road projects elsewhere in Rother?
6 What consultation will take place with parishes, and in particular parishes with emerging Neighbourhood Plans, on specific ideas for the R123 list?
7 There are a number of worthy project ideas listed in Infrastructure Delivery Plan (February 2015) but no sites are identified. Therefore it is impossible to know whether any specific project, say for transport, (improvement of bus services) or (improvement to walking and cycling corridors) or (access improvements to stations) or (more bus/transport services serving groups with access difficulties) can be appreciatively assessed or indeed prioritised. The same question applies to other sections such as library services, green infrastructure, environment and emergency services.

If you need any further information, please let me know.

Yours faithfully

Stephen Hardy
Chairman
Robertsbridge Enterprise Group