Preliminary Draft Charging Schedule: Community Infrastructure Levy Schedule of Representations
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Preliminary Draft Charging Schedule: Community Infrastructure Levy Schedule of Representations Consultation 7th September – 2nd November 2015 Formal Representations Contents Unique Page Reference Number UR 115a 1 Ur 115b 3 UR 774 5 UR 1285 7 UR 1291 12 UR 1366 14 UR 1452a 17 UR 1452b 18 UR 1460 21 UR 1812 22 UR 2240 23 UR 2274 25 UR 2369 27 UR 2371 31 UR 2402 97 UR 2589 99 UR 2608 100 UR 2658 102 UR 2659 103 UR 2660 121 UR 2661 122 UR 2662 123 UR 115a Community Infrastructure Levy Preliminary Draft Charging Schedule Response Form If you do wish to make comments on the Preliminary Draft CIL Charging Schedule please complete the sections below. Comments should cover succinctly all the information, evidence and supporting information necessary to support or justify the comment and the suggested change. All comments must be submitted in writing by 2nd November 2015 either by post to: Planning Policy, Environment and Economy, 2nd Floor Civic Centre, Darwall Street, Walsall, WS1 1DG, or by email to: [email protected]. Please note that late representations will not be accepted. The CIL regulations require that any representations must be submitted to the examiner together with a summary of the main issues raised. Therefore, comments cannot be treated as confidential. They will be attributed to source and made available as public documents. Your Details Name Organisation (where Planning Prospects Ltd (on behalf of Norton & Proffitt relevant) Developments Ltd) Job Title (where Director relevant) Address (inc post 4 Mill Pool, Nash Lane, Belbroughton, Worcestershire code) Telephone Number Email Address Q1. Do you have any comments to make on Walsall’s Preliminary Draft CIL Charging Schedule and supporting information? Land identified as TC03 and TC26 in the emerging Walsall Town Centre Area Action Plan effectively relates to a single urban block, defined by Upper Hall Lane, Lower Hall Lane, George Street and High Street. Its development is being led by a single developer. However, whilst TC03 (the northern part of this land) falls into CIL Charging Zone 5, TC26 (the southern part) falls into CIL Charging Zone 3. This seems arbitrary, and difficult to justify. Both parts of this land represent challenging, inner urban locations that are also difficult to separate in market, land value and development cost terms. It is therefore considered that this land in its entirety should be included within Zone 5, and not exposed to the additional charge that a Zone 3 designation would convey. From the “Walsall Site Allocation, CIL Deliverability and Viability Study” (“the Study”) prepared for the Council by DTZ and published in September 2015 it appears that this apparent anomaly may arise from the analysis being undertaken at a relatively coarse, postcode sector, level of geography. Whilst this may be a necessity governed by data availability and the practical issue of undertaking borough wide studies there should still be scope to amend boundaries to reflect UR 115a the reality on the ground. Such an adjustment should be made so as to include both TC03 and TC26 in Charging Zone 5. More generally, the £5 / sq m nominal charge for residential development should be removed throughout the charging schedule. The Study states (section 10.3) that, “As illustrated in the viability results set out in this report, there remain a number locations and sectors on which CIL is not considered to be realistically viable in typical circumstances. Therefore it follows that a zero tariff should be set to reflect these results.” The Study goes on to note that other authorities have nonetheless set a nominal charge in such circumstances, although just a single example is identified (Leeds City Council). It states that, “…there is a case that [the nominal charge] would be unlikely to put delivery at risk” (emphasis added), before concluding that, “…it is not possible to substantiate this in economic viability terms.” As such, the inclusion of the nominal charge may put delivery at risk, and make development unviable. There is no evidence to support this charge; indeed, conversely, the evidence points to CIL not being realistically viable in certain instances. The decision to include it in the Preliminary Draft Charging Schedule appears to be based on nothing more robust than the fact that it has been done in Leeds, i.e. a large city in a different region with entirely different circumstances. The CIL rates recommended in the Study (Table 1) do not include the nominal charge. Unless the nominal charge can be stood up with sound evidence directly related to Walsall then it should be removed. Thank you for completing the questionnaire. UR 115b Community Infrastructure Levy Preliminary Draft Charging Schedule Response Form If you do wish to make comments on the Preliminary Draft CIL Charging Schedule please complete the sections below. Comments should cover succinctly all the information, evidence and supporting information necessary to support or justify the comment and the suggested change. All comments must be submitted in writing by 2nd November 2015 either by post to: Planning Policy, Environment and Economy, 2nd Floor Civic Centre, Darwall Street, Walsall, WS1 1DG, or by email to: [email protected]. Please note that late representations will not be accepted. The CIL regulations require that any representations must be submitted to the examiner together with a summary of the main issues raised. Therefore, comments cannot be treated as confidential. They will be attributed to source and made available as public documents. Your Details Name Organisation (where Planning Prospects Ltd (on behalf of St Modwen relevant) Developments Ltd) Job Title (where Director relevant) Address (inc post 4 Mill Pool, Nash Lane, Belbroughton, Worcestershire code) Telephone Number Email Address Q1. Do you have any comments to make on Walsall’s Preliminary Draft CIL Charging Schedule and supporting information? St Modwen Developments Ltd have made separate representations to the Site Allocations Document (SAD), specifically in terms of the absence of an up to date assessment of housing need, and of a clear position in terms of the deliverability of identified housing sites. Those representations conclude that: • The SAD does not draw on an up to date assessment of housing need • It does not specify the deliverable housing supply • It is therefore not possible to calculate how many years’ supply Walsall has, relative to the NPPF five year requirement • It takes no account of and does not plan for the additional demand that will be placed on Walsall by exported housing requirement from Birmingham The imposition of CIL has an obvious impact on the deliverability of housing. Until the issues raised in relation to housing supply and demand are resolved, such that UR 115b the Council can clearly demonstrate a schedule of what it considers to be deliverable sites to meet an identified need and establish a five year supply, it is not possible to comment on the extent to which the rates set out in the Preliminary Draft Charging Schedule are acceptable, or not. For example, if the deliverable sites rely heavily (say) on locations within Zone 3, then the ability of development within this Zone to support CIL should be subjected to far more detailed scrutiny than might otherwise be the case. It is therefore suggested that further work and consultation on the Draft Charging Schedule should wait until the issues surrounding the fundamentals of the housing supply and demand are resolved. At that point St Modwen expect to make further representations in terms of the appropriateness of the proposed charges. Thank you for completing the questionnaire. District Council House, Frog Lane UR 774 Lichfield WS13 6YZ Your Ref 25th September, 2015 Dear Sir, Walsall Site Allocation Document Walsall Town Centre Area Action Plan Community Infrastructure Levy- Preliminary Draft Charging Schedule Thank you for the opportunity to comment on the aforementioned documents. None of the documents are accompanied by a sustainability assessment or Strategic Environmental Assessment, nor Habitat Regulations Assessment and it is therefore not possible to assess the impact of the documents upon sensitive habitats such as the Cannock Chase SAC. Evidence prepared to support the Lichfield Local Plan has identified that development within the boundary of Walsall Council will have an adverse impact upon the Cannock Chase SAC and a lack of evidence which can be considered in association with this consultation which seeks to address these responsibilities is concerning. In addition I have noted from the evidence base there is a lack of a Green Belt Review and whilst reference is made within the document to consideration of this matter this does not appear to be currently provided within the evidence base. Walsall Site Allocation Document and Walsall Town Centre Area Action Plan The Strategy as a whole which focuses development within existing centres, including Walsall Town Centre and seeks to re-use brownfield land is supported in principle. Walsall Site Allocation Document Whilst Lichfield District Council is not the mineral planning authority, as this responsibility lies with Staffordshire County Council, I would like to make the following comments. With regard to mineral site MP5 Land at Brownhills Common, which is identified as dormant, the recognition that an assessment of the impacts upon Chasewater and Southern Staffordshire Coalfield Heaths SSSI is supported. However with regard to the impacts of mineral development upon sites of nature conservation value and especially where they link as part of the larger ecological network extending between Cannock Chase and Sutton Park at sub para ix the sites should be required to mitigate for their impact during the operation of the site not just retain the existing habitats as long as possible and then restore. The early phasing of the restoration should be sought where possible to enable the retention of a corridor for nature conservation.