Community Infrastructure Levy (CIL) Preliminary Draft Charging Schedule and Regulation 123 List
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Community Infrastructure Levy (CIL) Preliminary Draft Charging Schedule and Regulation 123 List
Q1. Do you agree that Rother District Council should introduce a CIL?
Representation ID: 21653
Received: 25/09/2014
Respondent: MichaelDHall Building Design Services Ltd
Agent: MichaelDHall Building Design Services Ltd
Accept the principle of a CIL but cannot agree to the claimed shortfall of £133million and likewise other aspects which will be commented in answer to questions hereon.
Accept the principle of a CIL but cannot agree to the claimed shortfall of £133million and likewise other aspects which will be commented in answer to questions hereon.
Comment
Community Infrastructure Levy (CIL) Preliminary Draft Charging Schedule and Regulation 123 List
Q2. Do you agree that there is clear infrastructure funding gap?
Representation ID: 21654
Received: 25/09/2014
Respondent: MichaelDHall Building Design Services Ltd
Agent: MichaelDHall Building Design Services Ltd
No. The funding gap of £133 million seems based on a wish list without thought to what might be realisable or realistic. Think: Christmas list by a child. No local authority, no organisation ever has enough funds for what in an ideal world they may wish to spend and provide. You cannot, none of us can have all that we want or desire. An estimated shortfall of £133 million without doubt serves to suggest that aspirations are out of reach and unrealistic.
No. The funding gap of £133 million seems based on a wish list without thought to what might be realisable or realistic. Think: Christmas list by a child. No local authority, no organisation ever has enough funds for what in an ideal world they may wish to spend and provide. You cannot, none of us can have all that we want or desire. An estimated shortfall of £133 million without doubt serves to suggest that aspirations are out of reach and unrealistic.
Comment
Community Infrastructure Levy (CIL) Preliminary Draft Charging Schedule and Regulation 123 List
Q3. Do you agree with the proposed residential CIL charging zones?
Representation ID: 21655
Received: 25/09/2014
Respondent: MichaelDHall Building Design Services Ltd
Agent: MichaelDHall Building Design Services Ltd
One size does not fit all. To simply daw a line between say, east and west or north and south does not reflect a fair assessment of vale. There are many areas to the east of Rother with high value properties, there are many not so. The same may be said in the western part of Rother. Any charging might be based perhaps on local rateable values, these may well vary in one street. Simple will not work and there is no good in pretending or suggesting it will.
One size does not fit all. To simply daw a line between say, east and west or north and south does not reflect a fair assessment of vale. There are many areas to the east of Rother with high value properties, there are many not so. The same may be said in the western part of Rother. Any charging might be based perhaps on local rateable values, these may well vary in one street. Simple will not work and there is no good in pretending or suggesting it will.
Comment
Community Infrastructure Levy (CIL) Preliminary Draft Charging Schedule and Regulation 123 List
Q4. Do you agree with the proposed CIL charge rates for residential uses?
Representation ID: 21656
Received: 25/09/2014
Respondent: MichaelDHall Building Design Services Ltd
Agent: MichaelDHall Building Design Services Ltd
I do not agree with the charging schedule based as it presumably is on a claimed shortfall of £133 million in turn reflecting an unrealistic aspiration for the district. The rates are unaffordable for housebuilders save perhaps for a few high volume national developers. The small developer, often building the better quality small or larger dwellings, will be moreorless kicked into touch.
I do not agree with the charging schedule based as it presumably is on a claimed shortfall of £133 million in turn reflecting an unrealistic aspiration for the district. The rates are unaffordable for housebuilders save perhaps for a few high volume national developers. The small developer, often building the better quality small or larger dwellings, will be moreorless kicked into touch.
Object
Community Infrastructure Levy (CIL) Preliminary Draft Charging Schedule and Regulation 123 List
Q9. Do you have any further comments on the PDCS?
Representation ID: 21685
Received: 25/09/2014
Respondent: MichaelDHall Building Design Services Ltd
CIL evidently poorly thought out. Unrealistic wish list without regard for what may be practical and equitable. CIL in this form will exclude and prohibit many competent housebuilders from housebuilding. Those able to build under these restraints will be limited to national housebuilders and housing associations.CIL in this form, with figures or rates near those proposed will more or less bring housebuilding to a standstill. Whilst profits may outwardly appear good they are not as good as presumed and they are achieved at considerable risk. Progress in housebuilding will cease. This proposes taking assumed profit before it has been earned.
CIL evidently poorly thought out. Unrealistic wish list without regard for what may be practical and equitable. CIL in this form will exclude and prohibit many competent housebuilders from housebuilding. Those able to build under these restraints will be largely limited to a few national housebuilders and housing associations. Is that what is wanted? This should most certainly not be the case. CIL in this form, with figures or rates near those proposed will more or less bring housebuilding to a standstill. Where do legislators think the costs will come from? Profits? Whilst profits may outwardly appear good they are not as good as presumed and they are achieved at considerable risk. Ass the cost of CIL to house prices and thus mortgages? Will land prices fall? Unlikely for some long while and stalemate will ensue. Progress in housebuilding, providing homes, will cease. Again, the authors and local authorities propose taking assumed profit before it has been earned, and if it is not realised what price to the local authority. Nil, the loss falls to the developer, the housebuilder.
Object
Community Infrastructure Levy (CIL) Preliminary Draft Charging Schedule and Regulation 123 List
Q5. Do you agree with the proposed CIL rates for non-residential development?
Representation ID: 21686
Received: 25/09/2014
Respondent: MichaelDHall Building Design Services Ltd
Do not agree. Forget private retail shops, the traditional perhaps long gone. There will be no chance of a return after this, room only for chain shops, no individual shops, may be anticipated unless they be of less than 100 sqm. If there is potential for profit it would seem that the local authority want a greater part of it (on top of LA fees, tax on profits, VAT, etc). The trouble is they want it before it has occurred. CIL is in danger of giving birth to cheaper construction as cuts are made to make development viable.
Do not agree. Forget private retail shops, the traditional perhaps long gone now mythical notion of a nation of shopkeepers idyll. There will be no chance of a return after this, room only for chain shops, no individual shops, may be anticipated unless they be of less than 100 sqm presumably including storage, wcs, restrooms and staff bicycle storage facility. If there is potential for profit it would seem that the local authority want a greater part of it (on top of LA fees, tax on profits, VAT, etc). The trouble is they want it before it has occurred. It has to be earnt and it not always is. There may not be any and by taking it before the business even opens its doors they lessen the prospect of profit arising. CIL is in danger of giving birth to cheaper construction as cuts are made to make development viable.
