West Community Infrastructure Levies

Preliminary Draft Charging Schedule Consultations

Statement of Community Engagement and Consultation

June 2014

Contents

Section Sub Content Page Section Number

1.0 Introduction 1

1.1 Purpose of this Statement 1

1.2 Background 1

1.3 The Joint Core Strategy 2

2.0 Consultation 3

2.1 The Preliminary Draft Charging Schedule 3

2.2 The Consultation Process 3

2.3 Results of the Preliminary Draft Charging Schedule 4 Consultation

3.0 Stakeholder Engagement 9

Appendix 1 List of consultation bodies i

Appendix 2 List of public inspection locations xi

Appendix 3 Summary of responses xii

1.0 Introduction

1.1 Purpose of this statement

1.1.1 This statement sets out the community engagement and consultation undertaken to date for the community infrastructure levies being delivered by District Council, Borough Council and District Council.

1.1.2 For six weeks during April and May 2013 the West Northamptonshire Joint Planning Unit managed a consultation on the Preliminary Draft Charging Schedules on behalf of the Partner Councils.

1.2 Background

1.2.1 In order for a Community Infrastructure Levy (CIL) to be adopted, it is required by the CIL Regulations 2010 (as amended) that the Council holds a minimum of two rounds of public consultation. The first round of consultation to be held is concerned with the Preliminary Draft Charging Schedule ‘PDCS’ and the second with the Draft Charging Schedule ‘DCS’. The Council has also adopted to hold stakeholder engagement sessions in order to gauge the opinions of developers, the local community and other organisations with an interest in development in the West Northamptonshire area.

1.2.2 Regulations 15 and 16 of the CIL Regulations specify the consultation bodies that the Council must consult for the PDCS and DCS. The Council has consulted beyond the statutory minimum requirement to ensure that a wider range of consultation bodies were given the opportunity to make representations. These consultation bodies were given the opportunity to make representations. These consultation bodies include parish councils, community groups and organisations, representatives from the affordable housing sector, local businesses and the development sector that operates locally.

1.2.3 The Partner Councils are required to publish a Statement of Community Involvement (SCI), the primary purpose of which is to clarify the breadth of consultation that will take place with respect to the preparation of the planning framework that will guide development in the area.

1.2.4 As the adoption of a CIL is embedded with planning legislation, regulations and guidance and its purpose is to support the funding of infrastructure

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associated with the planned growth set out within the emerging Joint Core Strategy it is appropriate to align public consultation for CIL with adopted SCI. As such the SCI, along with statutory consultation requirements of Regulations 15 and 16 of the CIL Regulations, helped form the basis for who has been consulted on CIL and how CIL will be achieved.

1.3 The West Northamptonshire Joint Core Strategy

1.3.1 West Northamptonshire is the area covered by , Northampton Borough and South Northamptonshire Councils. It includes the towns of Northampton, Daventry, and and all the villages and rural areas within the three Councils’ administrative areas.

1.3.2 The Joint Core Strategy has been prepared by the Joint Planning Unit on behalf of the three Councils of Daventry District, Northampton Borough and South Northamptonshire working together with Northamptonshire County Council.

1.3.3 The West Northamptonshire Joint Core Strategy (as submitted) provides a planning framework for the West Northamptonshire area up to 2029. It sets out the long term vision and objectives for the whole of the area and includes strategic policies for steering and shaping development. It identifies locations for strategic new housing and employment and details the infrastructure (such as transport improvements, schools, open space and community facilities) required to support this development. It also defines where development will be limited.

1.3.4 The Localism Act 2011 and the Town and Country Planning (Local Planning) () Regulations 2012 introduced a range of changes to the planning system, and the Joint Core Strategy will now be a Part 1 Local Plan alongside a range of Part 2 Local Plans covering different locations or topics that will contribute to guiding development and use of land in West Northamptonshire for the Plan period up to 2029. Together the Part 1 and Part 2 plans comprise the Development Plan for West Northamptonshire.

1.3.5 The CILs will collect charges from development to facilitate the delivery of infrastructure across West Northamptonshire. Combined with other sources of finance, such as s106 agreements and Government capital investment programmes, the CILs will contribute towards infrastructure required as a result of the growth outlined within the Development Plans.

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2.0 Consultations

2.1 The Preliminary Draft Charging Schedules

2.1.1 The purpose of the Preliminary Draft Charging Schedule (PDCS) consultations was to allow local communities, developers and businesses to make representations on the initial proposed charging schedules for each of the Partner Councils. The Joint Planning Unit managed the consultations on behalf of the three Partner Councils.

2.2 The Consultation Process

2.2.1 The consultation period for the PDCSs was held between Thursday 14 March and Monday 29 April 2013. The consultation for each PDCS was held in parallel and the process was identical for each.

2.2.2 The methods of consultation that were used are detailed below: i. Letter and email notification Notification by either letter or email was sent to the following:  The statutory consultation bodies as specified in Regulation 15 of the CIL Regulations;  The consultation bodies specified in each SCI; and  All those other companies, organisations and individuals in the development sector that the Partner Councils considered may have an interest in CIL. Every organisation and individual notified about the PDCS consultation over and above the statutory consultees received that notification by either standard letter or email. In total the Joint Planning Unit contacted 1783 consultees. Appendix 1 lists each consultee. ii. Advertisement on the West Northamptonshire Joint Planning Unit Website The consultation was made available online and the consultation featured on the front page of the website for the duration of the consultation period.

2.2.3 The PDCS and relevant evidence was made available for public inspection at the following locations: i. The Partner Councils’ principal offices A paper copy of the PDCS and relevant evidence was made available at the following locations:  Daventry District Council One Stop Shop, Lodge Road, Daventry, NN11 4FP 3

 Northampton Borough Council One Stop Shop, The Guildhall, St Giles Square, Northampton, NN1 1DE  South Northamptonshire Council Reception, Springfields, Towcester, Northamptonshire, NN12 6AE. ii. The offices of Northamptonshire County Council and of the West Northamptonshire Development Corporation. iii. The West Northamptonshire Joint Planning Unit Website An electronic copy of the PDCS and relevant evidence is available on the West Northamptonshire Joint Planning Unit website by visiting http://ldfconsultation.westnorthamptonshirejpu.org/consult.ti/WN_CIL_P DCSs_Consultation/consultationHome iv. Local libraries Paper copies of the PDCS and relevant evidence were held for public inspection on request at 34 libraries in the Borough and in adjoining Council libraries during the consultation period (See Appendix 2 for a list).

2.2.4 In order to assist respondents in the consideration of the consultation, a questionnaire was produced which posed 11 questions. These are discussed further in the following section.

2.3 Results of the Preliminary Draft Charging Schedule Consultations

2.3.1 The Joint Planning Unit received 53 responses to the PDCS consultations that included representations made by developers, Parish Councils, local businesses, local residents, affordable housing providers, infrastructure and utilities companies, public services, environmental groups and supermarkets. The 53 respondents submitted 218 separate comments. Most comments relate to all three of the Partner Councils but the table below lists the individual comments by district.

District Individual comments The area of West Northamptonshire 194 The area of Daventry District 9 The area of Northampton Borough 7 The area of South Northamptonshire 8

2.3.2 Those consulted were able to submit their comments electronically or in writing by letter or questionnaire. We received 29 emails, 19 online responses and 5 paper responses. Some of the key issues arising from the consultation are summarised in the tables below.

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Question 1 Having considered the evidence base (in terms of the CIL Economic Viability Assessment) do you agree that the proposed CIL rates achieve an appropriate balance between the desirability of funding infrastructure from CIL and the potential effects of the charge on the economic viability of development across the local authority area? Number of individual comments: 39 Summary of responses:  Housing market too fragile to sustain the charge.  Consider s106 assumption is too low for retail schemes.  Premature to determine rates until JCS adopted.  Affordable housing policy is excessive.  Rates should illustrate a buffer.  Sales values are too high.  Fixed assumptions, and therefore the interpretation of results, inaccurate.  The balance between viability and delivery of infrastructure is not achieved.  Insufficient evidence to support charges.

Question 2 Do you agree that the West Northamptonshire Infrastructure Delivery Plan (July 2012) demonstrates a funding gap that provides sufficient justification for the introduction of CIL within each of the local authority areas? Number of individual comments: 28 Summary of responses:  Concern that CIL + s106 is an unreasonable double levy for retail.  Information is not sufficient or robust.  Money should be spent on community amenities, schools, healthcare and roads.  Require further information on Objectively Assessed Housing Need.  Accurate costs for infrastructure projects are not available.  Adoption of CIL to bridge funding gap is welcomed.

Question 3 Do you agree with the Proposed Residential Charging Rates: Urban Zone (Including Strategic Urban Extensions (SUEs) - £50 per sqm? Number of individual comments: 18 Summary of responses:  Insufficient evidence provided.  Charges should be £150m2 for all developments, rural and SUE.  Rates for South Northants should be higher.  Retail rates will make development unviable.  Fixed rate for SUEs allows for certain sites to contribute more through s106.

Question 4 Do you agree with the Proposed Residential Charging Rates: Rural Zone - £150 per sqm? Number of individual comments: 19 Summary of responses:  Rate is too high.

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 Rate totally unviable. See Rugby rate of £50m2 in rural areas.  Not enough information provided.  Assumes all areas are homogenous.  Lower rates would provide flexibility and a more sustainable district.  Rural sites could have higher costs.  Viability testing demonstrates that charge is unviable.  £100m2 would be more appropriate.  Approach to benchmark land values is unrealistic.

Question 5 Do you agree with the Proposed Retail Charging Rates - £100 per sqm (excluding central zones in Daventry and Northampton)? Number of individual comments: 12 Summary of responses:  Rates are too high. Will make some development unviable.  S106 and s278 contributions under estimated.  Setting CIL levels at the maximum will not ensure viability.  Marginal rural retail like farm shops would be compromised.  More information required.  Consider it is a reasonable charge.

Question 6 Do you agree with the proposed charging zones (see Section 7 of the Preliminary Draft Charging Schedule documents)? Number of individual comments: 16 Summary of responses:  Zones are very specific. The levy should be uniform across the County.  Areas are not homogenous.  Case studies on a district basis required.  Approach is overly simplistic.  Challenge legality of approach.  SUEs should be charged the same as the rural rate.  Agree with approach. Not overly complex and treats all parishes equally.

Question 7 Do you agree that the CIL Economic Viability Assessment has assessed the overall economic viability of the development types most likely to occur in West Northamptonshire in the foreseeable future? If not, what other development types should be tested and what is your justification for this? Number of individual comments: 16 Summary of responses:  Has not tested lower densities. Most Daventry developments are below 30dph.  Abnormal costs not taken into account.  Assessment is too broad.  Infrastructure for DDC is in need of review.  Agriculture and rural workers’ dwellings should be exempt.  All major land uses assessed.  Rates do not achieve an appropriate balance. 6

Question 8 Do you consider the charging authorities should adopt a scheme of discretionary relief, so that in exceptional circumstances of economic viability developments that meet the essential criteria can be exempted from paying CIL? Number of individual comments: 14 Summary of responses:  Decision is welcomed.  Would provide flexibility.  Important to strike a balance to ensure relief given as appropriate but not at the expense of providing infrastructure.  Everyone will apply for relief which will cost the courts a great deal.  Relief should not be offered to SUEs.  Relief should be rare, can be removed if necessary.

Question 9 Do you consider that the charging authorities should have a policy for paying the chargeable amounts in instalments? If so, do you have a preference for how such a policy should be set, for example by percentages of the total amount and the length of time period in days? Number of individual comments: 16 Summary of responses:  Phasing and an instalment policy would work well.  Recommend quarterly instalments by equal %.  Recommend 33% at receipt of liability, 33% at start, 34% at completion.  Instalment will result in delays to provision of infrastructure.  Instalments should reflect type of development, for example size, location, timescale for delivery.

Question 10 Infrastructure projects required to support new development, especially those identified in the West Northamptonshire Infrastructure Delivery Plan, may be candidates for receiving any CIL obtained. This first stage of consultation will help inform the projects that may be prioritised for funding through CIL. Suitable projects may be identified on the Councils’ Regulation 123 List (the list of infrastructure projects and/or infrastructure types that CIL monies will be spent on). What do you consider should be included within the Councils Regulation 123 list? Number of individual comments: 22 Summary of responses:  Should consider neighbouring local authority and parish areas.  Transport, health, utilities, community facilities, green infrastructure and education were key priorities for respondents generally.  Work on CIL should be postponed until JCS has progressed further.

Question 11 Do you have a view on how the District/Borough Councils should coordinate and work with other infrastructure providers to ensure the delivery of infrastructure projects funded by CIL? Number of individual comments: 18

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Summary of responses:  CIL should strike a balance.  Partner Councils should set up a working group.  Governance arrangements are unclear.  Infrastructure providers should have an opportunity to work collaboratively.  Work on CIL should be postponed until JCS has progressed further.

2.3.3 The responses to the PDCS consultations have been published on the West Northamptonshire Joint Planning Unit website to inform the Draft Charging Schedule (DCS) consultations. An overview of the responses, which includes a précis of the representations, is available at Appendix 3. The full version of each response is available via the website at: http://ldfconsultation.westnorthamptonshirejpu.org/consult.ti/WN_CIL_PDCSs _Consultation/listRespondents

2.3.4 The table in Appendix 3 also summarises the response of the Partner Councils and each resulting ‘Action’.

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3.0 Stakeholder Engagement

3.1 Prior to embarking upon the preparation of the Preliminary Draft Charing Schedules, the Councils invited representatives of the development sector to CIL Workshops run by GVA, the consultants employed by the Councils to produce the viability assessment to inform the Partner Councils’ approach to rate setting.

3.2 The first event took place on Friday 27 July 2012. The event was targeted at agents, landowners and developers who would be able to provide constructive feedback into the CIL viability assessments being undertaken by GVA on behalf of the Partner Councils. An invitation was sent to 131 representatives of the development sector representing house builders, surveyors, planning consultants, promoters of commercial premises, land agents and the affordable housing sector. The event was attended by 23 stakeholders.

3.3 The workshop was underpinned by a presentation by officers of the Joint Planning Unit and GVA that set the scene to CIL, and the approach of GVA to setting assumptions to be used to determine viability of different types of development across West Northamptonshire. There was discussion on the types of development that it might be appropriate to test, the place of affordable housing and the relationship with the future of s106 planning obligations.

3.4 GVA offered any person attending the opportunity to make direct contact by telephone or email to discuss any matter that may arise subsequent to the event.

3.5 The second event took place on Friday 11 January 2013. An invitation was sent to 177 stakeholders. This event was organised to present the viability conclusions and provide an opportunity for further comment prior to the finalisation of the viability report. The event was attended by 16 stakeholders.

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Appendix 1 – List of and Whiston Parish Council Parish Council consultation bodies Parish Council Parish Council The consultation was sent directly to Cosgrove Parish Council all organisations and individuals on our Parish Council Cottisford Parish Meeting database, including: Parish Meeting Parish Council Town and Parish Councils: Crick Parish Council Croughton Parish Council Parish Council Parish Council Adderbury Parish Council Daventry Parish Council Parish Meeting Daventry Town Council Alderton Parish Meeting Parish Council Parish Council Deddington Parish Council Parish Council Denton Parish Council Ashton Parish Council Dodford Parish Council Parish Council Draughton with Parish Council Parish Council Dunchurch Parish Council Parish Council Parish Council Town Council Earls Barton Parish Council Barby and Onley Parish Council Parish Council Beachampton Parish Council Parish Council Biddlesden Parish Council Parish Meeting Billing Parish Council Ecton Parish Council Parish Council Parish Meeting Parish Council Elkington Parish Council Boddington Parish Council Parish Council Bodicote Parish Council Parish Council Boughton Parish Council Parish Council Brackley Town Council Parish Council Parish Meeting Fathingstone Parish Council Brafield on the Green Parish Council Parish Council Parish Council Flore Parish Council Brington Parish Council Flore, Byfield and Parish Parish Council Council Brockhall Parish Council Gayton Parish Council Broughton Parish Council Parish Meeting Parish Council Grange Park Parish Council Byfield Parish Council Great Houghton Parish Council Calverton Parish Council Parish Council Parish Council Parish Council Parish Council Parish Council Castlethorpe Parish Council Grendon Parish Council Catesby Parish Council Parish Council Parish Council Parish Council Parish Council Hannington Parish Council Parish Council Parish Council Church & Parish Council Parish Council Church with Chapel Brampton Parish Hardwick & Tusmore Parish Meeting Council Parish Council Parish Council Parish Council Claydon with Clattercott PC Harrington Parish Council Clifton Hampden Parish Council Hartwell Parish Council Clifton Upon Dunsmore Parish Council Parish Council Clipston Parish Council Parish Council

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Helmdon Parish Council Parish Council Heselbech Parish Council Slapton Parish Meeting Parish Council Souldern Parish Council Parish Council Parish Council Parish Council Stanford Parish Council Parish Council Staverton Parish Council Parish Council Parish Council Kings Sutton Parish Council Stoke Goldington Parish Council Parish Council Stoke Lyne Parish Council Lamport Parish Council Stoneton Parish Meeting Leckhampstead Parish Council Town Council Parish Council Parish Council Sulby Parish Council Lillingstone Dayrell with Luffield Abbey Parish Council Parish Councils Parish Council Lillingstone Lovell Parish Council Sywell Parish Council Parish Council Parish Meeting Little Houghton Parish Council Thornby Parish Council Loddington Parish Council Thornton Parish Council Long Buckby Parish Council Parish Council Parish Council Parish Council Maidwell Parish Council Towcester Town Council Marston St Lawrence Parish Council Turweston Parish Council Parish Meeting Upper Heyford Parish Meeting Mid Northamptonshire Parishes 2001 Upton Parish Council Parish Council Parish Council Parish Council Parish Council Mixbury Parish Meeting Wardington PC Parish Council Wardington PC Moulton Parish Council Warkworth Parish Meeting Parish Council Warkworth Parish Meeting Parish Council Warrington Parish Council Newbottle Parish Council Watford Parish Council Newnham Parish Council Parish Council Norton Parish Council Weedon Parish Council Old Parish Council Welford Parish Council Parish Council Welton Parish Council Olney Town Council Parish Council Orton Parish Council Weston and Weedon Parish Council Overstone Parish Council Weston Underwood Parish Council Overthorpe Parish Council Parish Council Parish Council Whitfield Parish Meeting Parish Council Parish Council Parish Council Wicken Parish Council Parish Council Willoughby Parish Council Prestcote Parish Meeting Winwick Parish Council Parish Council Wolverton Town Council Priors Hardwick Parish Council Woodend Parish Meeting Priors Marston Parish Council Woodford cum Membris Parish Council Quinton Parish Council Wootton Parish Council Parish Meeting Wormleighton Parish Meeting Ravensthorpe Parish Council Parish Council Ravenstone Parish Council Parish Council Parish Council Parish Council

Rothersthorpe Parish Council Parish Council Residents Associations: Parish Council Banbury Lane Residents Association Parish Council ii

Blackthorn Residents Association Northampton Area Partnership 7 Boothville Community Council Northampton Area Partnership 8 Residents Association Northampton East Area Partnership Briar Hill 2 Residents Association Briar Hill Residents Association Brookside Residents Association Community Groups and other Camp Hill Residents Association Organisations: Castle St James Residents Association Ability Northants Castles Residents Association ACERT Collingtree Park Residents Association African Caribbean Elders Society Colwyn Road Residents Association Age Concern Community & Residents Association of Ashby St Ledgers Conservation Group Southfields Asian Men Sports & Social Club Drayton Residents Association B.R.D Conservation Group Eastfield Residents Association Barrack Road CAAC Evenley Residents Association Berkeley Community Villages Far Cotton Residents Association Blisworth Historic Buildings Society Trust Friars Residents Association Blisworth Heritage Society Green Park Residents Association Brackley Amenity Society Hood Street Residents Association Brackley Cottage Hospital Hopping Hill Residents Association Brackley Fox Lane Trust Hunsbury Residents Association Brackley Means Business Kings Heath Residents Association Brackley Mencap Hollow Residents Association Brackley Residents Action Group Lake View Residents Association Brackley Vision Lawrence & Deal Court, Deal, & British Geological Survey Duke Street Residents Association British Horse Society Northampton Federation of Residents' Brixworth Residents Against Unnecessary Associations Development Overstone Lodge & Goldings Residents Brockwatch Association Buckingham Canal Society PEMBA Residents Association Bugbrooke History Society Phippsville Residents Association CABE Queens Crescent Residents Association CALA (Campaign against Lorry Abuse) Queens Park Residents Association CAMRA Rectory Farm Residents Association CAN SPCC Residents’ Association Carers Forum Northamptonshire Spencer Dallington Residents Association Church Commissioners Spring Boroughs Residents Association Church of England St David's Residents Association Churches Together in all Northamptonshire Standens Barn Residents Association Cinema Theatre Association Tanfield Residents Association Citizen's Advice Buerau Thorpeville Residents Association Civic Trust Thorplands Residents Council Civil Aviation Authority Thrift Streets & Vernon Terrace Residents' Collingtree CAAC Association Commission for Racial Equality Tunnells Residents Association Whitehills & Spring Prk Residents Connexions Association Conservation Officer Group & Partners Wilby St, East St & South Tce Residents Council for British Archaeology Association Council for Ethnic Minorities Communities Residents Association (Northampton) Council for Voluntry Services (Northampton) Area Partnerships: Countryside Agency Northampton Area Partnership 3 CPRE Northamptonshire Northampton Area Partnership 4 Crossroad Care Northampton Area Partnership 5 Cut Waste Improve Competitiveness Northampton Area Partnership 6 CWICK iii

Cyclists Touring Club Conservancy DACT Freight Transport Association Dallington CAAC Friends of Alderton Monuments Dallington Sheltered Housing Residents Friends of Boughton Area Association Friends of Bradlaugh Fields Daventry Allotment Association Friends of the Earth Daventry and District Civic Society Friends of the Earth (East ) Daventry and South Northants MAGRAH Friends of the Earth () Daventry Villages Together Friends of the Racecourse Daventry Volunteer Centre Government Office for the Daventry Women's Institiute Grandfield Partnership Deafconnect Great Houghton CAAC Deanshanger Heritge Society Gypsy and Traveller Law Reform Coalition Department for Business, Enterprise and Health & Safety Executive Regulatory Reform Heart of England Tourist Board Department for Children, Schools and Help the Aged Families Highways Agency Department for Constitutional Affairs Hinton in the Hedges Parish Meeting Department for Culture, Media and Sport HM Prison Service Department for Innovation, Universities and Hobden Partnership Skills Home Builders Federation Department for Transport Rail Group Home Housing Association Department for Work and Pensions Home Office Department of Communities and Local Home Start Government Home Start Northampton Department of Transport House Builders Federation DIAL Housing Corporation Dialogue Inclusion & Pupil Support Diocesan Board of Finance Inclusive Environment Group Disability Rights Commission Indian Hindu Welfare Organisation (IHWO) Disabled Persons Transport Advisory Inland Waterways Association Committee Inland Waterways Association - District Development Consultancy Northampton Branch Domestic Violence Forum In-Motion Travel Duston Local History Society Innes England East Midlands Arts Board Institute of Directors (London) East Midlands Churches Forum Invest Northamptonshire East Midlands Development Agency Jehovah's Witnesses East Midlands Planning Aid Service Community Architects East Midlands Regional Assembly Kettering Rd, East Park Parade Residents East Midlands Regional Housing Board & Community Association East Midlands Sports Kingsley CAAC Ekins Allotment Association Kingsley Park Methodist Church EMDA Kingsoak Emmanuel Church Weston Favell Centre Kingsthorpe CAAC English as 2nd Language Group Kingsthorpe Grove Allotments Association English Heritage Landmark Information Group English Historic Towns Forum Landscope English Partnerships Learning & Skills Council Enterprise Solutions Legal Services Commission Environment Agency Lifelong Learning EPCAD Long Buckby Rail Users' Group Equal Opportunities Commission MAGRAH Explore Northamptonshire Midlands Rural Housing Fable Gospel Hall Trust Milton Malsor Action Group Forest Enterprise Milton Malsor Historical Society Forestry Commission MIND Forestry Commission, East Midlands Moulton Environment Group iv

National Association of Local Councils Northamptonshire Environmental Network National Consultancy Unit, English Northamptonshire Federation of the Partnerships Women's Institute National Council for the Conservation of Northamptonshire Lesbian and Gay Plants and Gardens Alliance National Council of Women Northamptonshire Race Equality Council National Farmers Union Northamptonshire Racial Equality Council National Federation of Bus Users Northamptonshire Rural Housing National Playing Fields Association Association National Probation Service Northamptonshire Sport National Society of Allotments & Leisure Northamptonshire Voluntary and Gardeners Ltd Community Sector Alliance National Trust Northants Wildlife Trust Natural England Partnerships Ltd Ncompass Norton Village Design Statement Steering Nene Flood Prevention Alliance Group Nene Housing Society Community Housing New Testament Church of God Association NFBU NSV Northampton & Lamport Railway NTACT Northampton Auctions PLC Office of Government Commerce Northampton Borough Allotment and Old Road Securities Plc Garden Council Oxfordshire Archaeological Unit Northampton Central Area Partnership Parklands Allotments Association Northampton Chamber of Trade Peterborough Diocesan Board of Finance Northampton College Peterborough Diocese Northampton Commissioning PCG Pleydell Road Allotment Committee Northampton Connolly Post Office Property Holdings Northampton Diesel & Electrical Services Princes Foundation Northampton Disabled People Forum Rail Freight Group Northampton Door to Door Service (NDDS) Rail Users Group Northampton Friends of the Earth Railfuture Northampton General Hospital NHS Trust Ramblers' Association Northampton Lesbian, Gay and Bisexual RIBA People Forum Ridge Northampton Pensioners Forum Regional Park Northampton Race Equality Forum RMC Group Services Ltd Northampton Rail Users Group RNRP Northampton Rapid Transit System Limited Road Haulage Association Northampton Taxi Cab Association Rotary Club Northampton Transport Users Forum Royal Commission on Historic Monuments Northampton Volunteering Centre RSPB Northampton Women Forum Seeda Headquarters Northampton Women's Aid Semilong Community Forum Northampton Youth Forum Showmans Guild of Great Britain Northamptonshire ACRE Silverstone Pre-School Group Northamptonshire Adult Learning Service SOS Campaign Northamptonshire Archeaological Society Development Agency Northamptonshire Association of Local South Northamptonshire Independent Councils Parishes Northamptonshire Chamber South Northamptonshire Tenants Group Northamptonshire Community Foundation South Northamptonshire Volunteer Bureau Northamptonshire Co-operative South Northamptonshire Youth Council Development Agency South Warwickshire Housing Association Northamptonshire County Council Fire and Southbrook Junior School Rescue Service Sport England Northamptonshire Enterprise Ltd Sport England (East Midlands) Northamptonshire Environmental Forum St Georges Community & Wildlife Group v

St Lawrence C of E Church Service Providers: Stony Stratford Association Adolescent Services STOP Northants Advantage West Midlands Sustainable Transport Ancient Monuments Society Sustrans East Midlands Ancient Tree Forum Sworders Anglian Water The Churches' Officer for New Arts Council England, East Midlands Communities Boughton Primary School The Coal Authority British Chemical Distributors & Traders The Community Mental Health Team Association The Federation of Master Builders British Ecological Society The Football League British Gas PLC The Garden History Society British Gas PLC (South) The Georgian Group British Railways Board The Grange British Shops and Stores Association The Gypsy Council British Telecom The House Builders Federation British Waterways The Landscape Partnership British Waterways South East The Littman Partnership British Wind Energy Association The Naseby Battlefield Project Buckingham and River Ouzel Internal The National Trust Drainage Board The Northamptonshire Residents Alliance Cable & Wireless UK The Police Authority Campion School The Studio Caroline Chisholm Scool The Theatres Trust Central Networks The Victorian Society Central Railways The Wantage Gospel Trust Chenderit School The Wildlife Trust Children and Families The Woodland Trust Community Access and Language The Youth Offending Team Service Thorburn Colquhoun Community Mental Health Team Time 2 Talk Community Windpower Ltd TORCH Connells Land and Planning TORCH Northamptonshire Conrad Ritblat Erdman Total Reclaims Demolition Ltd Cooper Partnership Tove Valley Baptist Fellowship Corus Property Department Towcester & District Local History Spociety Country Properties Towcester and District Local History Countryside Properties (Special Society Projects) Ltd Towcester Business Club Crest Homes Towcester Partnership Crest Nicholson Developments Ltd Town Centre CAAC Croudace Transport Users Group Crown Estate Commissioners Traveller Law Reform Coalition Daventry District Council Twentieth Century Society Daventry and South Northants PCT United Reformed Church Daventry Fire Service Victim Support Daventry Job Centre Weedon History Society Daventry Police Welfare Rights Advisory Service Daventry Tertiary College Welford Action Group East Midlands Ambulance Service Women's Aid East Midlands Electricity Women's National Commission Entec UK Ltd WWF EWS Ltd YMCA Fire Service Youth Offending Team First Bus – Northampton Zindgani (Aston Main Group) Gridcom UK

Hutchinson 3G UK Limited Kingsbrook School vi

Magdalen School Advance Housing Association Mereway Ambulance Station AIG Property PCT Andrew Granger & Co MK Metro Andrew Martin Associates Mobile Operators Association Anthony Ricketts Moulton College Aracon UK Moulton Surgery Aragon National Grid Arnold Thompson Network Rail Arun Investments NHS Confederation Ashby St Ledgers Farms LTD NHS East Midlands Atis Real Weatheralls NHS Estates Atkins (Property Service, NCC) NHS Executive (Anglia & Oxford) AWG Property Limited NHS Executive South East Region Barratt (Northampton) North Oxfordshire PCT Barris Liptrott Northampton Borough Council Barry Howard Homes Ltd Northamptonshire County Council Barton Willmore Northamptonshire Fire & Rescue Service Barwood Land Northamptonshire Healthcare NHS Trust Bayly and Co Beacon Housing Association Northamptonshire Police - Western Area Pilgrims Housing Association Northamptonshire Probation Area Bellinge Residents Association Northamptonshire Teaching Primary Bellway Homes Care Trust Ben Coleman Associates NPower (Renewables) Berkeley Homes (North London) LTD NTL Group Limited Bernard and Mary Sunley Ltd O2 (UK) Limited Berry Morris Orange Personal Communications Ltd Bidwells Powergen Bidwells Drake Quinton House School Bletsoe & Son Roade School Bloor Homes Silverlink Train Services Blue Boar Group Holdings South Midlands LIFT Project Team Boots Properties PLC Sponne School Boots the Chemists Ltd St Andrews Hospital Bovis Homes Ltd St. Loys Church of England Primary Boyer Planning School BPA Ltd Bpha (Bedfordshire Pilgrims Housing Sywell Aerodrome Association) Thames Water Property Brafield Stadium- Brafield Motorsports T-Mobile (UK) Limited Branston and Company Transco BRB (Residuary) Ltd University of Northampton Brian Barber Associates Ltd Brian Cornley Vodafone Group PLC Briton Properties Ltd Yorks Coaches Bromford Housing Group Yorks Travel Brown & Co BT PP426 Derngate ATE BTCV Businesses, Developers, Agents and Buchanan Consulting Engineers Landowners: Budworth Hardcasstle Abbey Developments Ltd Burbage Realty Abbey Ross Burnett Planning and Developmet Abbeyfield UK HA Business Link Northamptonshire Abbot Anstey Reader Butler Sherborn AC Adam Development Ltd Calvoyden Property Ltd Adams Holmes Associates Camargue Consultants Cannons Group Limited vii

Carillion URS DTZ Pieda Consulting Carlsberg Tetley East Midlands Housing Association Carpenter Planning Easynet Group Carter Jonas English Churches Housing Group Cavendish Properties English Courtyard Developments Ltd CB Richard Ellis Ltd First City CBI (East Midlands) Firstplan CDS Development Services Fisher German Celeford Essex Associates Fox, Bennett & Hackney Centex Strategic Land FPD Savills CGMS Frampton Chadwick McRae Chartered Surveyors Frazer Kircaldy Chancellors Freeman Leisure Chapman Warren Freeth Cartwright LLP Charles Church Developments Frontier Estates Charles F Jones Fuller Pieser Charles Planning Associates G A Soame & Associates Chesterhouse G L Hearn Planning Chesterton Plc G R Kenning Chetwood Associates Gallagher Estates Chiltern Hundreds Housing Association Gardner Associates Chris Thomas Ltd Gazeley Properties Ltd Christ Church Oxford Genesis Holdings Christina Cherry Geoff Amos Coaches CJC Development George Wimpey South Midlands Ltd Clayson Country Homes George Wimpey UK Ltd Clayson Haselwood George Wimpey West Midlands Ltd Clelford Essex Gerald Eve Cluttons Gill Pawson Planning Colliers CRE Godfrey Payton Cushman & Wakefield Goldfinch Cushman and Wakefield Healy and Baker Goode Coaches D M Wood Will Trust Gotch, Saunders and Surridge Dalton Warner Davis Goth Dandara Holdings Gough Planning Services Danetree Consortium Gregory Gray Associates Darland Property Management Ltd GVA Grimley Daventry Business Breakfast Club Hadland Chartered Surveyors David L Walker Halkins and Haskins David Lock Associates Hallam Land Management Ltd David Wilson Estates Hardys and Hansons Dbi Consulting Harris Lamb Planning Consultancy De Pol Associates Hartwell Bond Defence Estates East Harwoods Dennis Faulkner & Alsop Hawksmoor Property Services Derek Lovejoy Partnership Haywood and White Development Land & Planning Head Mann Associates Devplan UK Healey & Baker Diamond Estates Henry H. Bletsoe & Sons Dignity Funerals Ltd Hepher Dixon DLA LLP Hewitsons Dolton Warner Davies Highgrade Motors Donaldsons LLP Hinton In The Hedges Airfield DPDS Consulting Group Holme Holdings DRH Architectural Design Holmes Antill Drivers Jonas Howard Sharp and Partners LLP DTZ IG Land and Planning

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Indigo Planning Ltd McIntyres J & J Design MCL Property Consultants J A Pye Meccantice Land J B Planning Associates Merrys J B Planning Associates Ltd (for Kier Land Midsummer Housing Association Ltd) Mike Hardy Planning Consultant J S Bloor Services Miller Homes James Bailey Planning Minster General Housing Association James Martin and Co. Molyneux Planning Januarys Montague Evans Jennifer Lampert Associates Montagu-Evans John Drake & Co Morrison Supermarkets PLC John Heber Evans Chartered Designers Mott McDonald John Martin & Associates MSP John Phillips Planning NAI Fuller Peiser Jones Day Nathaniel Lichfield and Partners JS Bloor Homes Nicholas Tye Kember Loudon Williams Ltd Northampton Landlords' Association Kemp & Kemp Number One Kensington Homes Oldfield King Planning Kier Land Ltd Orbit Housing Association King Sturge O'Riordan Bond King West Osborne & Shellard King West Blacklee Smith Paradigm Housing Group Kirkby and Diamond Paul & Company Lafarge Aggregates Peacock and Smith Laing Homes Pegasus Planning Group Lambert Smith Hampton Persimmon Homes Lane Fox Residential Ltd Persimmon Homes (Midlands) Ltd LDA Design Peter Brett Associates Legal & General Peter Haddon & Partners Leicester Housing Association Phillips Planning Services Ltd Leith Planning Plainwood Holdings LEVVEL Consulting Ltd Planning Bureau LHA Housing Association Planning Issues Lidl UK Planning Potential Linfield Ltd & Lintec Systems Ltd Plant Hire Contractors Lloyd Thomas Architects R Stafford Charles & Son Loveday & Davis Rapleys Lovejoy Rapleys LLP Lovejoy Partnership Redline Town and Planning Development Lovell Johns Consultants Lucas Land and Planning Consultants Ltd Redrow Homes (Midlands) Ltd Malcolm Judd & Partners Robco-Reed Ltd Malcolm Scott Consultants Ltd Robert Doughty Consultancy Mansford Holdings Plc Robert Hitchins Ltd Marchfield Developments Robert Turley Associates Marriott Hardcastle Robinson & Hall Marrons Rockingham Forest Housing Association Marston St Lawrence Estate Roger Coy Marston's Plc Roger Mason Planning Martin Grant Homes (UK) Ltd Roger Tym and Partners Martin Pendered Royal Mail Marwalk Royal Mail Group Mason Richards Planning Royal Mail Group c/o Atisreal McCann Homes Royal Mail Operations West Territory McCarthy and Stone Royal Mail Property Holdings McGowan Investments RPS ix

Rudding Esate Office White Young Green Planning Rugby Cement Whites Estates Agents Samuel Rose Ltd Wilbraham Associates Ltd Savills Wilcon Homes Midlands Ltd Second Site Property William Davies Ltd Servite Houses Willow Inns Limited Shaftsbury Society Wilson Bowden Properties Shoosmiths Wilson Connolly (Home Counties) Shortland King Wimpey Homes Slough Estates Wimpey Homes (East Midlands) Smith Stuart Reynolds Wm Morrison Supermarket Plc Smith Woolley Woods Hardwick Planning Limited Smiths Gore Woolf Bond Planning Stamford Homes Ltd WSP Group Ltd

Stansgate Planning Consultants Star Planning & Development Adjoining Councils: Steer Ethelston Aylesbury Vale District Council Stepnell Estates Limited County Council Strangford Property Consultancy Ltd Borough Council of Strategic Land Partnerships Cherwell District Council Strutt & Parker Borough Council Stuart Michael Associates Ltd Council Stuart Ross Associate Council Taylor New Homes Kettering Borough Council Taylor Williams Properties County Council Taylor Woodrow Developments Ltd Milton Keynes Council Taywood Homes Ltd Joint Planning Unit Tenscentral Ltd Oxfordshire County Council Terence O'Rourke Rugby Borough Council Tesco Stores Ltd Stratford upon Avon District Council Tetlow King Planning Warwickshire County Council Tew and Smith

TFM Readers The Bell Cornwell Partnership The Planning Bureau Ltd The Planning Inspectorate Topaz Developments Ltd Towcester Vetinary Surgery Town Planning Consultancy TPK Consulting Trevor Jolley Design Turley Associates Turweston Flight Centre Ltd Twigden Homes Twigg & Associates Ltd Underwoods Vartec Telecom Europe Verres De Vin Wines Company Video Inn Production WA Fairhurst and Partners Walker Morris Warmingtons Watermead Homes Ltd Westbury Homes (Holdings) Ltd Westleigh Developments Ltd Weston Favell Shopping Centre White Mitchell Charterd Surveyors

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Appendix 2 – List of public inspection locations

Council/ Development Corporation Offices Daventry District Council - One Stop Shop Northampton Borough Council – One Stop Shop Northamptonshire County Council – County Hall South Northamptonshire Council – Springfields West Northamptonshire Development Corporation

West Northamptonshire Libraries Northamptonshire Central Library, Northampton Abington Library Brackley Library Brixworth Library Daventry Library Deanshanger Library Duston Library Far Cotton Library Hunsbury Library Kingsthorpe Library Long Buckby Library Middleton Cheney Library Moulton Library Roade Library St James Library Towcester Library Weston Favell Library Library Wootton Library

Adjoining Councils Libraries Banbury Library Buckingham Library Library Dunchurch Library and Information Centre Earls Barton Library Kettering Library Library Milton Keynes Central Library Newport Pagnell Library Olney Library Rothwell Library Rugby Library and Information Centre Stony Stratford Library Wellingborough Library Wolverton Library

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Appendix 3 – Summary of responses

The responses are summarised in the following table. A full version of each response is available via the West Northamptonshire Joint Planning Unit website at: http://ldfconsultation.westnorthamptonshirejpu.org/consult.ti/WN_CIL_PDCSs_Cons ultation/listRespondents

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Respondent Comment Partner Council Response Action

Question 1 Having considered the evidence base (in terms of the CIL Economic Viability Assessment) do you agree that the proposed CIL rates achieve an appropriate balance between the desirability of funding infrastructure from CIL and the potential effects of the charge on the economic viability of development across the local authority area? Anglian Water Funding of water and wastewater unlikely Response noted. n/a to form part of CIL provisions. Arthingworth Parish  Do not agree. Will have detrimental The proposed CIL charges will partially n/a Council effect on those wishing to get onto the replace existing charges already property ladder. negotiated via s106 agreements.  Housing market too fragile to sustain charge. Asda Stores Ltd  Propose flat rate across all Viability evidence illustrates that not all n/a development across its boundaries. use classes are able to sustain a CIL  Provide draft instalment policy. charge. The Partner Councils are  No evidence presented of s106 required to introduce charges which contributions. would not put delivery of the Joint Core  Underestimate s106 and s278 Strategy as a whole at risk. contributions from retail schemes. Aynho Parish Proposed CIL rates will achieve a viable Response noted. All development has n/a Council balance to achieve investment in the some impact on the need for necessary infrastructure to support the infrastructure, services and amenities or development target as stated and that benefits from them so it is fair that such those proposed rates will not be development pays a share of the cost. detrimental to the economic viability of the CIL is the government’s preferred method planned development across the local of seeking contributions to all but directly authority area. site related infrastructure and will largely replace the need for S106 agreement xiii

Respondent Comment Partner Council Response Action

contributions.

The viability evidence demonstrates that the proposed rates support the delivery of the Joint Core Strategy without undermining the overall economic viability of delivery across its area. Barwood Land & Without a firm housing number to consider Response noted. n/a Estate Ltd the CIL against in terms of delivering the necessary infrastructure for the area, we consider that it would be premature to comment on the proposed rates at this time. Boughton Parish The Parish Council is extremely concerned CIL is collected by the Charging Authority Draft R123 List Council that the majority share of the CIL will go to and annual monitoring of receipts and prepared for next the charging authorities and be retained for spend will illustrate how funds are being consultation. expenditure in other parts of the directed. The R123 List (a list of projects County/Borough/District. that will benefit from CIL funds) will form part of the Draft Charging Schedule consultation and stakeholders will have an opportunity to comment at that stage. It is also noted that the CIL Regulations provide for 15 to 25% of the levy arising from developments within parish council areas to be passed directly to those parish councils. In parishes with a neighbourhood plan in place, the

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Respondent Comment Partner Council Response Action

proportion will be 25% uncapped. In parishes without a neighbourhood plan the proportion will be 15% and capped at £100 per dwelling in the parish per year. In unparished areas the council will be able to use the proportion for local priorities in consultation with local residents. Brixworth Parish Affordable housing of 40% in rural areas is Viability evidence for Affordable Housing n/a Council excessive. has been completed by Three Dragons. This work has been examined independently by a Planning Inspector at the Joint Core Strategy hearings. Cherwell & South CIL must leave a buffer and cannot be CIL Guidance states that all approaches n/a Northants DC charged at the maximum headroom. must be explained clearly. The viability work has been updated and continuous work by the Partner Councils illustrates improving house prices providing a robust support to the approach taken. Coventry and Supports the evidence and has no further Response noted. n/a Warwickshire Local comments to make. Enterprise Partnership D Neale The evidence base is flawed as sales rates Viability evidence has been undertaken Charging authorities in rural areas are nowhere near £220 per by professional consultants GVA. They will increase the rate sq ft. In Crick they are £170 per sq ft. are assured that appropriate assumptions for smaller sites have been made in support of their work. which fall below the

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Respondent Comment Partner Council Response Action

The viability work has been updated and affordable housing continuous work by the Partner Councils threshold. illustrates improving house prices providing robust support to the approach taken. It was previously recognised by our consultants that smaller sites, without the requirement of supply affordable housing, are more capable of sustaining a higher CIL rate. Previous CIL Regulations and Guidance did not support this approach. Duston Parish Monies should be spent on community Response noted. The R123 List (a list of Draft R123 List Council amenities. projects that will benefit from CIL funds) prepared for next will be available alongside the Draft consultation. Charging Schedule consultation and stakeholders will have an opportunity to comment at that stage. It is also noted that the CIL Regulations provide for 15 to 25% of the levy arising from developments within parish council areas to be passed directly to those parish councils. In parishes with a neighbourhood plan in place, the proportion will be 25% uncapped. In parishes without a neighbourhood plan the proportion will be 15% and capped at £100 per dwelling in the parish per year.

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Respondent Comment Partner Council Response Action

In unparished areas the council will be able to use the proportion for local priorities in consultation with local residents. Framptons Information is not sufficient and robust. Key Response noted. Infrastructure need is CIL Background infrastructure costs not included. shown in the Infrastructure Delivery Plan paper to be made and is further supported by the CIL available during Background Paper to be made available consultation on Draft alongside the Draft Charging Schedule Charging Schedules. consultations. Francis Jackson Ensure CIL levels are not too high. GVA are confident that the proposed CIL n/a Homes Ltd rates are at a level which would not put (Gladman overall development across West Developments) Northamptonshire at serious risk. Gladman CIL rates must not threaten Local Plans. GVA are confident that the proposed CIL n/a Developments rates are at a level which would not put overall development across West Northamptonshire at serious risk. Hampton Brooks CIL must not hinder development. GVA are confident that the proposed CIL n/a Estate Ltd rates are at a level which would not put overall development across West Northamptonshire at serious risk. HBF Consortium HBF Consortium express these concerns Viability evidence has been undertaken CIL Viability Study through specific analysis of key by professional consultants GVA. They update to provide assumptions within the GVA CIL Economic are assured that appropriate assumptions further clarification. Viability Assessment relating to matters have been made in support of their work. including Development Profit; Professional The CIL Viability Study has been updated

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Respondent Comment Partner Council Response Action

Fees (specifically on SUEs); Section 106 to provide more clarification on the work Assumptions; Contingency; Viability assessed. Buffers; Planning Promotion Costs; Affordable Housing; Benchmark Land Values (specifically for SUEs); and the resulting Interpretation of Results in setting the proposed CIL rates. Highcross Strategic Insufficient evidence to demonstrate these CIL Guidance states that all approaches n/a Advisers Ltd assumptions. No appropriate buffer, rates must be explained clearly. The viability appear to be at the maximum level. work has been updated and continuous work by the Partner Councils illustrates improving house prices providing a robust support to the approach taken. Highways Agency Welcoming of a CIL charge. Response noted. n/a

Kimbell Trust GVA assessment of the house prices is GVA are confident that the proposed CIL n/a flawed largely because of it reflects the rates are at a level which would not put same methodology of the Three Dragon’s overall development across West study which is flawed. Northamptonshire at serious risk.

Viability work completed by Three Dragons has been examined independently by a Planning Inspector at the Joint Core Strategy hearings. Kleinwort Benson Evidence base ignores realistic build costs. Viability evidence has been undertaken n/a as Trustees of the by professional consultants GVA and Muriel Jackson- adheres to national guidance on viability.

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Respondent Comment Partner Council Response Action

Stops Settlement They are assured that appropriate assumptions have been made in support of their work. Mr. Moore New development should be targeted at Response noted. The Joint Core Strategy n/a brownfield sites. aims to maximise the urban capacity across West Northamptonshire. National Farmers CIL should be reduced for rural areas. Viability evidence has been undertaken The Partner Councils Union by professional consultants GVA. Their propose a higher rate work illustrates that residential for rural sites below development in rural areas is capable of the affordable meeting a higher CIL rate. housing threshold. CIL Guidance states that all approaches must be explained clearly. The viability work has been updated and continuous work by the Partner Councils illustrates improving house prices providing a robust support to the approach taken. They further propose a higher CIL rate for sites which fall below the affordable housing threshold. The approach to differential charging based on size is now supported by the CIL Regulations (as amended 2014). Natural England Local Plan should be Habitat Regulation Response noted. n/a Assessment compliant. Northampton The level of affordable contributions from The Partner Councils must balance the The Partner Councils County Council – both CIL and s106 identified in the cost of funding infrastructure with the will present evidence

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Respondent Comment Partner Council Response Action

Highways, consultation documentation raise serious viability of development. The CIL charges of historic s106 Transport and concerns about the deliverability of the key proposed, combined with assumptions for agreements and Infrastructure elements of transport infrastructure s106 contributions, are comparable with provide information to necessary to open up the Sustainable current s106 negotiations. support their Urban Extension for development. judgement on the appropriate balance for Examination.

The Partner Councils will continue to work collectively with service providers to identify alternative and supplementary funding mechanisms and ensure the timely delivery of infrastructure. Northampton Affordability of other infrastructure and The Joint Core Strategy has been subject n/a County Council – modal shift measures necessary to to Examination and the Infrastructure Planning and Policy mitigate the impact of development on Delivery Plan (IDP) forms part of the existing communities and in particular to evidence base in support of the Plan. The reduce the level of congestion which would IDP is updated annually and is a living otherwise be forecast to achieve the draft. Both documents have been made ambition of Joint Core Strategy must be available during consultations. seriously called into question. All relevant service providers have

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Respondent Comment Partner Council Response Action

agreed that the infrastructure projects identified within the IDP will accommodate the levels of growth across West Northamptonshire. Site promoters have not indicated any issues regarding the deliverability of sites. Pegasus Group It is clear that an appropriate balance The Joint Core Strategy has been subject The Partner Councils between the desirability of funding to Examination and the Infrastructure will present evidence infrastructure from the levy and the Delivery Plan (IDP) forms part of the of historic s106 potential effects of the levy upon the evidence base in support of the Plan. The agreements and economic viability of development across IDP is updated annually and is a living provide information to West Northamptonshire has not been met draft. Both documents have been made support their with regard to the majority of the SUEs as available during consultation. judgement on the they are situated within low value areas. appropriate balance All relevant service providers have for Examination. agreed that the infrastructure projects identified within the IDP will The Partner Councils accommodate the levels of growth across will continue to work West Northamptonshire. Site promoters collectively with have not indicated any issues regarding service providers to the deliverability of sites. identify alternative and supplementary The CIL charges proposed, combined funding mechanisms with assumptions for s106 contributions, and ensure the timely are comparable with current s106 delivery of negotiations. infrastructure.

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Respondent Comment Partner Council Response Action

Persimmon Homes/ CIL rates do not achieve an appropriate The Joint Core Strategy has been subject The Partner Councils Bloor Homes/ balance between the desirability of funding to Examination and the Infrastructure will present evidence Barratt Homes infrastructure from CIL and the potential Delivery Plan (IDP) forms part of the of historic s106 effects of the economic viability of evidence base in support of the Plan. The agreements and development. IDP is updated annually and is a living provide information to draft. Both documents have been made support their available for consultation. judgement on the appropriate balance All relevant service providers have for Examination. agreed that the infrastructure projects identified within the IDP will The Partner Councils accommodate the levels of growth across will continue to work West Northamptonshire. Site promoters collectively with have not indicated any issues regarding service providers to the deliverability of sites. identify alternative and supplementary The CIL charges proposed, combined funding mechanisms with assumptions for s106 contributions, and ensure the timely are comparable with current s106 delivery of negotiations. infrastructure. Portfutures & UKSL We consider that progress with CIL should Response noted. The Joint Core Strategy n/a be postponed until the JPU has progressed Part I has been examined independently further work with the local plan SA/SEA by a Planning Inspector. and housing needs assessment work that has to be carried out or alternatively that, given the current debate at the local plan EIP over infrastructure and viability.

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Respondent Comment Partner Council Response Action

Prologis UK Limited Mainly agree with the questionnaire. Response noted. n/a

Ropemaker Respondent concludes that Northampton Response noted. The Partner Councils n/a Properities Limited Borough Council should be mindful of are mindful of legislative changes. The forthcoming legislative changes in the Draft Charging Schedules have been progression of their CIL and so we reiterate prepared in line with Guidance and our view that further evidence must be legislation. given. Rugby Borough Supports the evidence. Response noted. n/a Council Sport England We are concerned that the infrastructure The Infrastructure Delivery Plan (IDP) is Partner Councils to delivery plan may be based on evidence updated annually to reflect the continuous ensure that work to that is out of date or indeed not available. engagement with service providers. This update infrastructure plan will also be informed by new evidence in support evidence produced in support of the Part of the Part II Local II Local Plans. Plans is reflected in future iterations of the IDP. The Theatres Trust We support the nil rate for ‘all other uses’ Response noted. n/a for Daventry DC, Northampton BC and South Northampton DC. University of Imposing a CIL charge for retail Viability evidence has been undertaken Northampton developments in a fragile market makes it by professional consultants GVA. Their less likely developers will be able to afford work illustrates that retail development is these uses which provide amenity and capable of meeting a CIL rate. employment. It will make some development unviable.

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Respondent Comment Partner Council Response Action

Walgrave Parish We do not agree with the proposed level of Infrastructure to be wholly or partly Draft R123 List Council investment as a general rule. This is delivered by CIL will be available for prepared for next because the context is different for different consultation within the R123 List at the consultation. communities. Infrastructure in rural same time as the Draft Charging localities is not well provided. Schedule. It is also noted that the CIL Regulations provide for 15 to 25% of the levy arising from developments within parish council areas to be passed directly to those parish councils. In parishes with a neighbourhood plan in place, the proportion will be 25% uncapped. In parishes without a neighbourhood plan the proportion will be 15% and capped at £100 per dwelling in the parish per year. In unparished areas the council will be able to use the proportion for local priorities in consultation with local residents. West Haddon Principle interest is in Residential Rural Increasing the complexity of the charge Following Parish Council Zone levy rate, so have some concerns makes CIL calculation and collection amendments to the with the possible effect of having one rate increasingly difficult. The Regulations CIL Regulations in for whole of the Daventry District Council provide that CIL should not be overly 2014, the Partner Rural area given that there are one or two complex. Whilst some rural areas might Councils are house price hotspots identified. This price viably be able to afford a higher CIL proposing a higher hotspot and the flat rate for the district will charge, the Charging Authorities have rate for sites below quite clearly have a greater attractiveness simplified the charging zones to maintain the affordable

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Respondent Comment Partner Council Response Action

to swing development to these areas given a balance between projected returns and housing threshold. a greater margin will be accrued. administrative burden. However, it was previously recognised by our consultants that smaller sites, without the requirement of supply affordable housing, are more capable of sustaining a higher CIL rate. Previous CIL Regulations and Guidance did not support this approach. Whittlebury Parish The Council has insufficient information to Response noted. The Charging Partner Councils to Council form a judgement as to whether the Authorities are able to provide support provide support and proposed preliminary draft charging and assistance to Parish Councils at any assistance as schedule at section 7 of the consultation stage to provide more information on the requested and paper is either acceptable or sufficient to CIL process. required for Parish provide the necessary support for new Councils. development. William Davis Ltd Concerned that the approach towards Viability evidence has been undertaken CIL Viability Study assessing acceptable uplift from by professional consultants GVA. They updated. ‘benchmark’ land values, in the Viability are assured that appropriate assumptions Assessment, is unrealistic. have been made in support of their work. The CIL Viability Study has been updated to provide more clarification on the work assessed. WNDC The balance between the desirability of Government guidance suggests a review Adopted CIL Charing funding infrastructure from CIL and the of CIL as economic conditions improve or Schedules will be potential effects of the charge on the worsen. It is intended that the Partner monitored annually. economic viability of developments needs Councils will monitor the implementation

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Respondent Comment Partner Council Response Action

to be kept when/if economic conditions of CIL alongside delivery of residential improve/worsen. The CIL rates therefore and retail development. need to be flexible.

Question 2 Do you agree that the West Northamptonshire Infrastructure Delivery Plan (July 2012) demonstrates a funding gap that provides sufficient justification for the introduction of CIL within each of the local authority areas? Asda Stores Ltd There is a concern that as local authorities Local authorities cannot seek site-specific n/a will still seek site- specific commitments commitments under S.106, for under the s106 regime as well as CIL that infrastructure that is to be provided the two charges together represent an through CIL. unreasonable double levy for infrastructure The Viability work completed by GVA which is seemingly being placed onto a provides evidence as to which types of very limited category of development. development are able to sustain a CIL charge. Barwood Land & Needs to be sure of objective assessment Comments can therefore only be made n/a Estates Ltd of housing needs number before once West Northamptonshire Joint Core comments can be made on CIL. Strategy is adopted. To ensure the timely provision of infrastructure it is necessary for the Partner Councils to pursue the CIL charging regime in advance of adoption. Brixworth Parish I feel that we have to rely on the statement Agreed. Response noted. n/a Council that there is a funding gap here although quantifying it is beyond our ability. The projected increase in housing completions over the years 12/13 to 24/25 would

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Respondent Comment Partner Council Response Action

certainly seem to create a funding gap. Cherwell & South Any CIL charging rate would to be It is not expected that CIL rates will be n/a Northants DC appropriate, tested and viable. If viable CIL set so low as to be uneconomic to collect. rate were to be so low (e.g. £5-£10) as to However, if viable CIL rates were to be be uneconomic to collect, then it might be set so low as to be uneconomic to collect, better to simply secure this through s.106 then local authorities have the option of means, and consider the option of not not adopting use of CIL. adopting the use of CIL. The Partner Councils also recognise that there are strategic infrastructure projects required to support the Joint Core Strategy Part I. Some of these projects would not be capable of delivery under the pooling restrictions for s106 to be imposed from April 2015. Duston Parish Money should be spent on community CIL receipts will be spent in accordance n/a Council amenities etc. with the Infrastructure Delivery Plan and Reg123 Lists. Parish Councils will receive a percentage of CIL receipts to spend on community amenities, etc. English Heritage Should recognise the importance of Response noted. n/a historical sites. Framptons The information which has been provided Have not specified in what way the n/a is not sufficient and robust. information is considered insufficient and not robust. Viability evidence has been undertaken by professional consultants GVA. They are assured that appropriate assumptions xxvii

Respondent Comment Partner Council Response Action

have been made in support of their work. The CIL Viability Study has been updated to provide more clarification on the work assessed. Gladman Funding gap - The Council needs to Not agreed. The costs of infrastructure CIL Background Developments ensure that they have a full understanding needed to serve new development have Paper to be made of the potential costs of infrastructure been identified sufficiently through the available alongside projects needed to meet the infrastructure IDP, to clearly identify a significant the Draft Charging needs. Gladman believe that it is funding gap and allow setting of Schedules. inappropriate to set the levy based on a appropriate and viable CIL charging partial understanding of these rates. This work is further supplemented infrastructure costs and in particular if the by the CIL Background Paper available total money needed for infrastructure is alongside the Draft Charging Schedule unknown. consultations. Hampton Brook Further work on objectively assessed need Comments can therefore only be made n/a Estates Ltd and SA work is required before they make once West Northamptonshire Joint Core a comment. Strategy is adopted. To ensure the timely provision of infrastructure it is necessary for the Partner Councils to pursue the CIL charging regime in advance of adoption. HBF Consortium CIL rates should be based on accurate CIL rates are based on viability n/a estimates of known site-specifics. assessment. Site-specific requirements will continue to be provided for under the S.106 regime, but only if they have not been funded through a CIL charge.

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Respondent Comment Partner Council Response Action

Highcross The Infrastructure Needs Assessment Not agreed. The costs of infrastructure CIL Background Strategic Advisers does not seek to identify accurate costs of needed to serve new development have Paper to be made Ltd projects. There is a lack of clarity and been identified sufficiently through the available alongside justification and therefore a sound funding IDP, to clearly identify a significant the Draft Charging gap has not been justified in this instance funding gap, and allow setting of to justify the levels of CIL set out. appropriate and viable CIL charging Schedules. rates. This work is further supplemented by the CIL Background Paper available alongside the Draft Charging Schedule consultations. Highway Agency The HA considers that the evidence Agreed. This work is further CIL Background presented by the authorities demonstrates supplemented by the CIL Background Paper to be made that there will be significant infrastructure Paper available alongside the Draft available alongside funding gap across the West Charging Schedule consultations. the Draft Charging Northamptonshire area and in each Schedules. separate charging authority. Kimbell Trust It is impossible to verify as only the JPU CIL rates are based on GVA viability The updated has access to the background information. assessment, which is available on-line. presentation of the What is not clear is whether the funding Site-specific requirements will continue to CIL related funding gap takes into account existing s.106 be provided for under S.106 regime, but gap to be presented agreements? And future s.106 agreements only if they have not been funded through in a Background between now and when CIL is adopted and CIL charge. Paper. enforced? Kleinworth Benson Charging rates for the land owned by the CIL charging rates are applied uniformly. n/a as Trustee of the Trustees should be lower to reflect the Issues of viability for individual sites will Muriel Jacks- requirements for developments. continue to be addressed through the

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Respondent Comment Partner Council Response Action

Stops Settlement S.106 regime.

Litchborough Did not feel competent to challenge any of Noted. There will be a further chance to Partner Councils to Parish Council the figures or assumptions presented. comment when the Draft Charging provide support and Schedule is consulted on. assistance as requested and required to Parish Councils. Mr. Moore Should be spent on more schools, A draft R123 List is to be provided for the Draft R123 List to be healthcare and roads. Draft Charging Schedule consultation. provided at consultation. NHS Property A funding gap of 9.3m for healthcare was S.106 contributions are not being phased n/a Services Ltd identified in the IDP. This is a significant out, and can still be sought on individual sum, and with the phasing out of s.106 sites, provided that developers have not contributions from April 2014, there is no contributed towards healthcare through other viable planning mechanism which CIL charge. can help to adequately address this deficit. Northamptonshire Northamptonshire County Council, as Agreed and response noted. The Partner Councils County Council – highway authority agrees that there is a will continue to work Highways and large funding gap in the monies available collectively with Infrastructure for infrastructure provision. Worryingly this service providers to funding gap is largest with regard to identify alternative highway infrastructure; therefore the and supplementary introduction of CIL as one of the measures funding mechanisms to support funding of infrastructure is and ensure the timely welcome. delivery of infrastructure. xxx

Respondent Comment Partner Council Response Action

Northamptonshire The county council agrees that there is a Agreed and response noted. The Partner Councils County Council large funding gap in the monies available will continue to work Planning and for infrastructure provision. Worryingly this collectively with Policy funding gap is largest with regards to service providers to highway infrastructure; therefore the identify alternative introduction of CIL as one of the measures and supplementary to support funding of infrastructure is funding mechanisms welcome. and ensure the timely delivery of infrastructure. Pegasus Group It is necessary to ensure that the s106 Agreed, but note that any S.106 n/a Ltd requirements sought by the JPU in addition requirements will continue to be sought to the proposed CIL charges are not by the individual Partner Councils, not the onerous and are also “carefully considered JPU. in the context of viability”. Persimmon Pegasus considers that the proposed CIL In accordance with the Regulations, CIL n/a Homes/Bloor rates do not achieve an appropriate rates have to be set so as to leave Homes/ Barratt balance between the desirability of funding development viable. Homes infrastructure from CIL and the potential effects of the economic viability of development. Portfutures and We consider that progress with the CIL CIL cannot be adopted until after the Joint n/a UKSL should be postponed until the JPU has Core Strategy has been adopted. progressed further work with the local plan SA/SEA and housing needs assessment work that has to be carried out or alternatively that, given the current debate

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Respondent Comment Partner Council Response Action

at the local plan EIP over infrastructure and viability.

Sports England We are concerned that the infrastructure The Infrastructure Delivery Plan (IDP) is Partner Councils to delivery plan may be based on evidence updated annually to reflect the continuous ensure that work to that is out of date or indeed not available. engagement with service providers. This update infrastructure plan will also be informed by new evidence in support evidence produced in support of the Part of the Part II Local II Local Plans. Plans is reflected in future iterations of the IDP. Walgrave Parish DDC needs are underestimated due to Not agreed, as DDC ‘needs’ form part of n/a Council apparent lack of budget for cultural viability assessment and IDP. development and public realm. West Haddon The delivery plan doesn’t drive down into Not agreed, as ‘infrastructure need n/a infrastructure need potential in light of potential’ forms part of viability development progress throughout life of a assessment and IDP. plan as any patterns emerge. Little account of social infrastructure needs alongside structural infrastructure at macro level. Whittlebury Parish The Council has insufficient information to Noted. There will be a further chance to Partner Councils to Council form a judgement as to whether the comment when the Draft Charging provide support and proposed preliminary draft charging Schedule is consulted on. assistance as schedule at section 7 of the consultation required to Parish paper is either acceptable or sufficient to Councils. provide the necessary support for new xxxii

Respondent Comment Partner Council Response Action

development.

Wildlife Trust We would like to make sure that Noted. Final allocation of any CIL n/a investment into Green Infrastructure and receipts will be decided by the partner the natural environment is given authorities, at the appropriate stage. comparable weighting when deciding which of the competing infrastructure types will receive funding through mechanisms such as CIL. WNDC Transport and Education infrastructure Noted. Final allocation of any CIL n/a require the most funding out of all types receipts will be decided by the partner suggested in each authority’s preliminary authorities, at the appropriate stage. drafting schedule. The drafting schedule also shows these two types of infrastructure have the largest funding gaps. There is an estimated overall gap of £439.6m. Improving infrastructure is a catalyst for further development. Question 3 Do you agree with the Proposed Residential Charging Rates: Urban Zone (Including Strategic Urban Extensions (SUEs) - £50 per sqm? Brixworth Parish These charges seem to be rationally Response noted. N/a Council based.

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Respondent Comment Partner Council Response Action

Cherwell and South Please refer to response to Question 1, The CIL Viability Study acknowledges N/a Northants District above. Any CIL charge rate would have to that the urban areas of Northampton and Councils be viable, and if a viable rate were to be so Daventry are predominantly ‘low value’ low (e.g. £5-£10) as to be uneconomic to areas. Therefore a nominal rate of collect, then might be better to consider the £50/sqm is proposed. option of not adopting use of CIL. It is not expected that CIL rates will be set so low as to be uneconomic to collect. However, if viable CIL rates were to be set so low as to be uneconomic to collect, then local authorities have the option of not adopting use of CIL. The Partner Councils also recognise that there are strategic infrastructure projects required to support the Joint Core Strategy Part I. Some of these projects would not be capable of delivery under the pooling restrictions for s106 to be imposed from April 2015. Deanshanger Deanshanger Parish Council tried to The different charging zones reflect Partner Councils to Parish Council complete the response form but felt they differences in residential values within the provide support and could not answer the questions. They are sub-region. This approach is informed by assistance as very specific and the information provided evidence and is supported by guidance. required to Parish is not sufficient to answer properly. There It is regrettable that Deanshanger Parish Councils. is concern about different bands for rural Council felt they were unable to fully and urban – surely the levy should be respond to the consultation. However uniform across the county. town and parish councils were supplied with all relevant documentation necessary

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Respondent Comment Partner Council Response Action

to provide a response to the consultation on the Preliminary Draft Charging Schedule. Framptons It is considered that further justification for The guidance requires Charging n/a the proposed charging rates should be Authorities to use an area-based provided as the document progresses approach which involves a broad test of towards adoption. The charging rates viability across the area to underpin their should differentiate between Previously charge. A range of development Developed Land and Greenfield sites. scenarios has been tested. Future Presently it is considered that insufficient development is expected to come forward justification has been included in on a range of sites including both consultation document and evidence base brownfield and greenfield land. papers. The CIL Economic Viability Study anticipates that based on the Joint Core Strategy, the majority of development (excluding the SUEs) will be brought forward on previously developed land. This includes rural areas where development is expected to be predominantly within settlement boundaries and has either been previously developed or has significant hope value due to planning policy allocation. Where the current use is agricultural or horticultural, the study assumes the landowner will require a xxxv

Respondent Comment Partner Council Response Action

minimum land price of £247,000 per hectare.

It is therefore considered that the range of scenarios tested broadly reflect the likely form of future development as indicated by the Joint Core Strategy. Gladman Local planning authorities need to be able On behalf of the Partner Councils, the Draft R123 to be Developments to demonstrate the infrastructure need and Joint Planning Unit publishes an annual available at subsequent gap and must ensure that the update of the Infrastructure Delivery Plan consultation. level of total CIL receipts that could be (IDP). The IDP identifies infrastructure Background Paper to generated through the levy reflects these necessary to implement the Joint Core outline CIL related true needs and the proposals in the Local Strategy and indicates a funding gap. funding gap in more Plan. The CIL should not be used by Due to the funding gap, the Partner detail. Council’s as a mechanism for creating an Councils feel it is justified and appropriate unrealistic ‘wish list’ of infrastructure to implement a CIL charge. projects in their area. The Charging Authorities intend to publish draft Regulation 123 Infrastructure Lists alongside the Draft Charging Schedule. The authorities’ Infrastructure Lists will be informed by the IDP. Hampton Brook Ensure that CIL does not stifle The CIL Economic Viability Study n/a Estate Ltd development. identifies the urban areas of Northampton and Daventry as ‘low value’ and Brackley and Towcester as ‘medium value’. The

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Respondent Comment Partner Council Response Action

study acknowledges that much of the development in West Northamptonshire will be brought forward at Strategic Urban Extensions (SUEs) and that the SUEs may experience higher enabling costs.

In light of the evidence, the partner authorities are proposing a nominal CIL charge of £50/sqm in the urban zone. HBF Consortium Certain elements of the evidence need to The CIL is being worked up alongside the CIL Viability Study be revised and made readily available. preparation of the Joint Core Strategy updated. and informed by an up-to-date evidence base. The documentation relating to the CIL is available via the West Northamptonshire Joint Planning Unit’s website.

Viability evidence has been undertaken by professional consultants GVA. They are assured that appropriate assumptions have been made in support of their work. The CIL Viability Study has been updated to provide more clarification on the work assessed. Litchborough Parish Did not feel competent to challenge any of It is regrettable that Litchborough Parish Partner Councils to Council the figures or assumptions presented. Council felt they were unable to fully provide support and respond to the consultation. However all assistance as xxxvii

Respondent Comment Partner Council Response Action

town and parish councils were supplied required to Parish with all documentation necessary to Councils. provide a response to the consultation on the Preliminary Draft Charging Schedule.

Moulton Parish Charges should be £150 sq m for all The evidence presented in the CIL n/a Council developments, rural and SUE. economic viability study does not support a £150 per sqm rate in the urban zone including SUEs. Residential sales values are lower in the urban zone than the rural zone. In addition, development at SUEs is expected to require higher enabling costs than other sites. Mr. Moore The areas identified as SUE should be It is estimated that the SUEs will n/a treated the same as rural areas and experience sales values in line with the charged at £150 per sqm. adjoining current market areas in Northampton, Daventry, Brackley and Towcester and are therefore included within the Urban Zone. Northamptonshire CIL rate proposed seems fair for Northants The evidence suggests that Brackley and n/a County Council and Daventry however; it seems low for Towcester command higher residential Planning and Policy Towcester and Brackley. values than Northampton and Daventry. The CIL Economic Viability Study identifies Towcester and Brackley as ‘medium value’. The SUEs adjoining each may therefore benefit from the higher prices. However as they will have xxxviii

Respondent Comment Partner Council Response Action

the same issues concerning enabling costs, it is believed there is a strong case to treat those SUEs in the same way as the SUEs located at Northampton and Daventry. Pegasus Group Ltd It is considered that the boundary line for It is noted that the boundaries of the Amend Urban and the Rural Zone and the SUE should also SUEs are subject to review through the Rural Charging be reviewed following the WNJCS examination process. The Joint Planning Zones to reflect SUE Examination. Unit presented Proposed Modifications to boundaries following the Joint Core Strategy in March 2014. the Joint Core Those modifications do include Strategy examination. amendments to the boundaries of certain SUEs. The CIL Viability Study has been reviewed accordingly.

The Urban and Rural Charging Zones must therefore reflect the boundaries of the SUEs indicated in the West Northamptonshire Joint Core Strategy (should the document be found sound and adopted by the partner authorities). Persimmon Pegasus considers that the proposed CIL The CIL Economic Viability Study The Partner Councils Homes/Bloor rates do not achieve an appropriate identifies the urban areas of Northampton will present evidence Homes/ Barratt balance between the desirability of funding and Daventry as ‘low value’ and Brackley of historic s106 Homes infrastructure from CIL and the potential and Towcester as ‘medium value’. The agreements and effects of the economic viability of study acknowledges that much of the provide information to development. development in West Northamptonshire support their

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Respondent Comment Partner Council Response Action

will be brought forward at the Strategic judgement on the Urban Extensions (SUEs), and that the appropriate balance SUEs may experience higher enabling for Examination. costs. The Partner Councils In light of the evidence, the partner will continue to work authorities are proposing a nominal CIL collectively with charge of £50/sqm in the urban zone. service providers to identify alternative and supplementary funding mechanisms and ensure the timely delivery of infrastructure. Protfutures and Refer to question 1. The CIL is being worked up alongside the n/a UKSL preparation of the Local Plan (i.e. the West Northamptonshire Joint Core Strategy) as recommended by national policy. University of Imposing a CIL charge for retail In working up a CIL the authorities have Northampton developments in a fragile market makes it adopted an area-based approach which less likely developers will be able to afford involves a broad test of viability across these uses which provide amenity and their area as evidence to underpin the employment. It will make some charge. Inevitably there is a risk that development unviable. some development proposals may be unviable. In setting a CIL, the Partner Councils are seeking to strike a balance

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Respondent Comment Partner Council Response Action

between securing additional investment for infrastructure to support development, and the potential economic effect of imposing the levy upon development across the area. West Haddon Little account for social infrastructure The Infrastructure Delivery Plan (IDP) n/a Parish Council needs alongside structural infrastructure at supports the Joint Core Strategy and a macro level. identifies the infrastructure required to deliver new development over the plan period. The IDP has been prepared through consultation with service providers. It should be noted that many service providers are working up strategic plans of their own to meet future needs. Furthermore the ‘duty to pass CIL to local councils’ will empower local communities to spend CIL funds on locally important infrastructure projects. William Davis Ltd Concerned that the approach towards The 20% uplift from benchmark land Review additional assessing acceptable uplift from values employed by the study is informed evidence if/when ‘benchmark’ land values, in the Viability by the findings of recent examinations on received. Assessment, is unrealistic. other CIL studies; from national guidance (Viability Testing Local Plans, Local Housing Group, 2012); the consultants’ (GVA) own experiences; and, the approach adopted by neighbouring authorities.

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Respondent Comment Partner Council Response Action

The partner authorities would encourage the respondent to submit additional evidence of current land values and landowner’s expectations. WNDC The identified SUE’s differ in land value Response noted. n/a because of the different locations; however there are issues of enabling costs which create challenge to viability and sustainability. £50 per sqm for each CIL is consistent across West Northamptonshire. Therefore implementing a fixed rate for all SUE’s allows for certain SUE’s to contribute more within s106 in addition to CIL. Question 4 Do you agree with the Proposed Residential Charging Rates: Rural Zone - £150 per sqm?

Cherwell & South Please refer to response to Question 1, Noted. Agreed that a low charge would n/a Northants DC above. Any CIL charge rate would have to not be viable to collect, however at the be viable, and if a viable rate were to be so rates proposed it would be viable. Partner low (e.g. £5-£10) as to be uneconomic to Councils can determine not to adopt a collect, then might be better to consider the CIL at any time. option of not adopting use of CIL. D Neale Totally unviable as demonstrated by JPU’s Viability evidence has been undertaken Charging authorities own study. Will prevent development by professional consultants GVA. will apply an coming forward in rural areas as will not increased the rate for

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Respondent Comment Partner Council Response Action

stack up financially. Rates need to be It was previously recognised by our smaller sites which much lower. Neighbouring Rugby’s rate consultants that smaller sites, without the fall below the £50 per sqm in rural areas. requirement of supply affordable housing, affordable housing are more capable of sustaining a higher threshold. CIL rate. Previous CIL Regulations and Guidance did not support this approach. Deanshanger Not enough information provided. The respondent has not indicated what Partner Councils to Parish Council information is lacking. provide support and assistance as required to Parish Councils. Framptons Information is not sufficient and robust. The respondent has not indicated what n/a information is lacking.

Viability evidence has been undertaken by professional consultants GVA. They are assured that appropriate assumptions have been made in support of their work. The CIL Viability Study has been updated to provide more clarification on the work assessed. Francis Jackson Assumes all areas are homogenous. It is necessary to make broad n/a Homes Ltd assumptions , otherwise the system wold become more complex to evidence and more expensive to operate (if there were many different zones and rates for example)

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Respondent Comment Partner Council Response Action

Gladman Lower CIL rates would provide flexibility See section 1 above n/a Developments and reflect a more sustainable District. Gladman Differential charging rates - It is integral Noted. In defining areas for different n/a Developments when setting differential rates for different rates it is necessary to strike a balance geographical areas that these differential between reflecting local variations in rates are based on accurate, up to date values and setting up a system which is housing market intelligence forming the not overly complex. evidence base for this decision. Hampton Brooks Rural sites could have higher costs. No evidence has been provided to n/a Estates Ltd support this view HBF Consortium Certain elements of the evidence need to In response to the consultation, GVA has GVA update Viability be revised and made readily available. updated the viability study which will be Study. available during the next consultation. Kimbell Trust  As demonstrated in Section 1), the See section 1 above n/a viability evidence is flawed and despite this the testing demonstrates that £150 per sqm of CIL is not viable.  The maximum levy under the optimum scenario of £100 per sqm and it is considered that if £100 per sqm was adopted that would still be a major challenge and still generate double the receipts currently being generated by s.106 agreements if say looking at an average 100 sqm house on a medium sized development (Three Dragons study says s.106 average is £5k so

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Respondent Comment Partner Council Response Action

£10k would be double.  A £100 per sqm rate would also be in line with Rugby with similar land values/house prices etc. as confirmed by GVA. In fact, the rural area charge in Rugby is £50 per sqm. Kleinwort Benson Charging rates for SUEs are too high. The respondent has not provided any n/a as Trustees of the evidence to support this view Muriel Jackson- Stops Settlement Litchborough Parish Did not feel competent to challenge any of Response noted Partner Councils to Council the figures or assumptions presented. provide support and assistance as required to Parish Councils. National Farmers CIL should be reduced in rural areas. Viability evidence has been undertaken Charging authorities Union by professional consultants GVA. will apply an increased rate for It was previously recognised by our smaller sites which consultants that smaller sites, without the fall below the requirement of supply affordable housing, affordable housing are more capable of sustaining a higher threshold. CIL rate. Previous CIL Regulations and Guidance did not support this approach. Northamptonshire The proposed charging rates do reflect the Noted. A review will be undertaken in n/a County Council current market which is currently due course, but there is no precise Planning and Policy depressed. To ensure that uplift in the timetable currently.

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Respondent Comment Partner Council Response Action

rising market is captured provision should be made for an early review when conditions change. Pegasus Group Ltd Prices for CIL for the rural zone are too See section 1 above n/a high. Portfutures and See question 1. - - UKSL Walgrave Parish Cost of private transport and the Response noted. n/a Council inadequacies of public transport. The current cost of private transport and the inadequacies of public transport which has caused migration from rural areas. Should development take place this will need addressing. West Haddon The answers don’t provide the necessary In defining areas for different rates it is Partner Councils Parish response option. Given prior answers, necessary to strike a balance between propose to increase price Hotspot in West Haddon would make reflecting local variations in values and the rate for smaller development here more attractive as setting up a system which is not overly sites which fall below greater margins for residual land value are complex. the affordable possible – is it sensitive enough? housing threshold, However, it was previously recognised by this approach clarified our consultants that smaller sites, without through CIL the requirement of supply affordable Regulations (as housing, are more capable of sustaining a amended 2014). higher CIL rate. Previous CIL Regulations and Guidance did not support this approach.

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Respondent Comment Partner Council Response Action

William Davis Ltd Concerned that the approach towards See section 1 above n/a assessing acceptable uplift from ‘benchmark’ land values, in the Viability Assessment, is unrealistic. Question 5 Do you agree with the Proposed Retail Charging Rates - £100 per sqm (excluding central zones in Daventry and Northampton)?

ASDA Stores Ltd  ASDA often can revitalise and The partner authorities intend to publish a Partner Councils to rejuvenate areas where it sets up. draft Instalment Policy for consultation review retail  Propose flat rate across all alongside the publication of the draft proposals to confirm development across its boundaries. Charging Schedule. that in broad terms  Provide draft instalment policy. s106 costs are nil, or  No evidence presented of s106 The CIL Economic Viability Study low. contributions. assumes that there are no s106  Underestimate s106 and s278 obligations in respect of the schemes and Partner authorities to contributions from retail schemes. that costs, such as s278 agreements are undertake review of absorbed into the site enabling costs planning obligations and/or CIL payment. However, in testing policies. scenarios the study incorporates assumptions as to compliance with the BREEAM ‘Very Good’ standard and site preparation costs.

The adoption of the CIL and changes to regulation regarding pooling of s106 contributions will require the partner authorities to review their policies for

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Respondent Comment Partner Council Response Action

imposing planning obligations through s106 agreements. Framptons Information is not sufficient and robust. The CIL Economic Viability Study tests a Review retail charge range of retail scenarios. It is not clear if/when additional from the respondent what additional evidence is supplied. information is required. The respondent is invited to supply additional evidence to ensure the CIL is robust. Gladman Differential charging rates - It is integral The CIL Economic Viability Study uses Explore the Developments when setting differential rates for different land registry data for all sold property, requirement to geographical areas that these differential and is therefore considered accurate. update study, to rates are based on accurate, up to date However it is acknowledged that such ensure current values housing market intelligence forming the data may require regular review to ensure are reflected. evidence base for this decision. it is kept up to date. Hampton Brook Retail is important for both economic Response noted. n/a Homes growth and employment. Highcross Strategic Setting CIL levels at the maximum will not A nil rate is proposed in the town centre n/a Advisers Ltd ensure viability and does not meet the for retail uses. Different retail scenarios funding gap. provide a broad range of viability scenarios. National Farmers Support a nil levy on all other development Planning permission is not normally Partner authorities to Union but we object to the proposed CIL for retail required if an existing building is used as provide clarity on the development of £100 per sqm. This a farm shop only for the sale of application of CIL. proposal would include marginal rural unprocessed goods produced on that development like farm shops which I’m farm. However, where a farm shop sells sure were not supposed to be included in significant amount of produce from the CIL proposals. elsewhere, planning permission may be xlviii

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required.

In the first scenario, CIL is unlikely to be chargeable (perhaps the activity could be considered either ancillary or de minimis). Furthermore where there is no net gain to the floorspace of the existing building, CIL would not be applicable.

In the second scenario, where planning permission is required, CIL is likely to be chargeable on any additional floorspace created from the proposal. Northamptonshire The proposed charging rates do reflect the It is intended that CIL will be subject to n/a County Council current market which is currently regular review to ensure rates Planning and Policy depressed. To ensure that uplift in the appropriately reflect development rising market is captured provision should viability. be made for an early review when conditions change. Portfutures and Refer to question 1. Refer to question 1. n/a UKSL Ropemaker Please see answer to question 1 – the The proposed rate for ‘other uses’ is nil. n/a Properties Limited rates proposed for different ‘intended uses’ A range of development scenarios are cannot be supported by reference to Reg tested indicating low viability. 14, without significantly more thorough and clearly evidenced justification being provided in an updated Economic Viability

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Assessment.

University of Imposing a CIL charge for retail In working up a CIL the authorities have n/a Northampton developments in a fragile market makes it adopted an area-based approach which less likely developers will be able to afford involves a broad test of viability across these uses which provide amenity and their area as evidence to underpin the employment. It will make some charge. Inevitably there is a risk that development unviable. some development proposals may be unviable. In setting a CIL, the partner authorities are seeking to strike a balance between securing additional investment for infrastructure to support development, and the potential economic effect of imposing the levy upon development across the area.

A nil rate is proposed in the town centre for retail uses. Different retail scenarios provide a broad range of viability scenarios. West Haddon The retail market will decide and the CIL Response noted. n/a Parish Council rate will have little impact. WNDC The evidence base recognises there are Response noted. n/a higher development costs in the town centre of Northampton and Daventry; however a CIL rate of £100 per sqm is a reasonable contribution for outside the

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Respondent Comment Partner Council Response Action

town centre.

Question 6 Do you agree with the proposed charging zones (see Section 7 of the Preliminary Draft Charging Schedule documents)?

D Neale Not sure whether they are lawful as per Schedules have been prepared in n/a. advice in GVA study. accordance with CIL Regulations and guidance. Deanshanger They are very specific and the information The zones attempt to reflect variations in n/a Parish Council provided is not sufficient to answer the value of development across the properly. There is concern about different area, but as noted above a balance has bands for rural and urban – surely the levy to be struck between reflecting local should be uniform across the county. variations in values and setting up a system which is not overly complex. Francis Jackson Evidence is required to demonstrate the A balance has to be struck between n/a Homes Ltd proposed CIL level is flexible and will not reflecting local variations in values and act as a barrier to housing and affordable setting up a system which is not overly housing delivery across the charging/plan complex. area with more worked examples on a District by District basis. Gladman Areas are not homogenous. Noted n/a Developments Hampton Brook Current zoning appears to be overly A balance has to be struck between n/a Estates Ltd simplistic and to the potential detriment of reflecting local variations in values and some sites especially falling within the setting up a system which is not overly higher charged rural zone. Drastic change complex. in the price of zones (rural/urban).

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Respondent Comment Partner Council Response Action

Kimbell Trust No objection per sqm but questions the Different rates per charging zone are n/a legality of this method - There have been permitted, provided this is supported by high profile cases where supermarket evidence operators have successfully challenged differential rates and been successful. The courts have ruled that you can only have one rate per land use, so just one flat rate for residential development. Most authorities with adopted CIL only have one rate and not charging zones. Kleinwort Benson Wood Burcote Court, Towcester should be The Partner Councils will consider n/a excluded from the charging zone to reflect responses before considering whether to special circumstances. adopt any CIL discretionary relief, beyond the statutory relief set out in the Regulations. This would address concerns regarding site specific viability. Litchborough Parish Did not feel competent to challenge any of Noted Partner Councils to Council the figures or assumptions presented. provide support and assistance as required to Parish Councils. Moulton Parish All zones should be equal. This is not supported by the evidence n/a Council Mr. Moore SUEs should be charged the same as the This is not supported by the evidence n/a rural sites. Pegasus Group Ltd Review the boundary line of rural and Agree that this would be sensible Review boundary urban zones following the Core Strategy between SUEs and lii

Respondent Comment Partner Council Response Action

examination. rural areas following examination. Portfutures and Refer to question 1. - - UKSL Ropemaker Refer to question 1. - - Properties Limited University of Imposing a CIL charge for retail In working up a CIL the authorities have n/a Northampton developments in a fragile market makes it adopted an area-based approach which less likely developers will be able to afford involves a broad test of viability across these uses which provide amenity and their area as evidence to underpin the employment. It will make some charge. Inevitably there is a risk that development unviable. some development proposals may be unviable. In setting a CIL, the partner authorities are seeking to strike a balance between securing additional investment for infrastructure to support development, and the potential economic effect of imposing the levy upon development across the area.

A nil rate is proposed in the town centre for retail uses. Different retail scenarios provide a broad range of viability scenarios. West Haddon Wholly in line with Core Strategy – whether Noted n/a Parish Council the zones will bring about the desired effect is pure speculation.

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Respondent Comment Partner Council Response Action

WNDC The current mapping is in keeping with the Noted n/a CLG requirements of avoiding an overly complex operation of CIL. This is particularly relevant to the rural zone because it is made of up of many different Parishes. The CIL is therefore operating at a strategic rather than local level. If the Parishes were to be changed individually issues surrounding time, efficiently and confusion my arise, as further appraisals would need to take place and developers might find certain Parishes preferable to them based on lower CIL rates. Question 7 Do you agree that the CIL Economic Viability Assessment has assessed the overall economic viability of the development types most likely to occur in West Northamptonshire in the foreseeable future? If not, what other development types should be tested and what is your justification for this? Anyho Parish Negative impact of new neighbourhood New ‘neighbourhood developments’ have n/a Council developments. been assessed. D Neale Has not tested for lower density All likely densities of development have n/a development. Most developments in been tested for. Daventry District are below 30 dwelling per hectare (dph). Framptons Why have certain development sites have Does not specify which (major) sites have n/a been omitted? been ‘omitted’. Hampton Brook Abnormal development costs not taken into Any abnormal development costs can still n/a Estates Ltd account. be taken into account through the S.106 liv

Respondent Comment Partner Council Response Action

regime, and assessing the viability of individual development sites. Highcross Strategic Assessment has been undertaken at a Economic viability assessment has been n/a Advisers Ltd very broad level. undertaken to a sufficient level, to enable the setting of viable CIL rates. Kimbell Trust No minimum density is required anymore. Agreed, but developments must still make n/a best and most efficient use of land. Litchborough Parish Did not feel competent to challenge any of Noted – there will be a further chance to Partner Councils to Council the figures or assumptions presented. comment when the Draft Charging provide support and Schedule is consulted on. assistance as required to Parish Councils. Moulton Parish Road improvements – infrastructure over Response noted. n/a Council DDC area is in need of review. National Farmers Agricultural and rural workers’ dwellings This is not a matter for local authorities, n/a Union should be exempted from CIL. but could only be addressed through Government changes to the CIL Regulations. NHS Property Pleased that PDCS will not impose a CIL Response noted. n/a Services charge on any new healthcare facilities. Pegasus Group Ltd All major land uses assessed. Agreed. n/a

Persimmon Pegasus considerations that the proposed See Q2. n/a Homes/Bloor CIL rates do not achieve an appropriate Homes/Barratt balance between the desirability of funding Homes infrastructure from CIL and the potential effects of the economic viability of lv

Respondent Comment Partner Council Response Action

development.

Portfutures and Refer to question 1. Response noted. n/a UKSL Prologis UK Limited Mainly agree with the questionnaire. Response noted. n/a

The Theatres Trust We support the nil rate for ‘all other uses’ Agreed. n/a for Daventry DC, Northampton BC and South Northampton DC. Theatre uses are generally unable to bear the cost of CIL for viability reasons. The Theatres Trust therefore supports either the setting of a nil rate, the application of charitable or discretionary reliefs, applying D1/D2 rates where differential rates are proposed, or recycling the charge to the theatre development where a single rate is proposed. West Haddon Agree in the main. Response noted. n/a Parish Council Question 8 Do you consider the charging authorities should adopt a scheme of discretionary relief, so that in exceptional circumstances of economic viability developments that meet the essential criteria can be exempted from paying CIL? ASDA Stores Ltd Decision is welcomed. The Partner Councils will consider n/a responses before considering whether to adopt any CIL discretionary relief, beyond the statutory relief set out in the lvi

Respondent Comment Partner Council Response Action

Regulations.

English Heritage Do not put heritage sites at risk as a result The Partner Councils will consider n/a of CIL. responses before considering whether to adopt any CIL discretionary relief, beyond the statutory relief set out in the Regulations. Framptons Provide flexibility for major developments. The Partner Councils will consider n/a responses before considering whether to adopt any CIL discretionary relief, beyond the statutory relief set out in the Regulations. Kleinwort Benson A planning application for land at Wood The Regulations as amended allow for n/a Burcote Court, Towcester includes the payments in kind. creation of a new town park and the transfer of the land to Towcester Town Council together with a commuted sum for future management. It is considered that the gross value of the park and the commuted sum should be included in the calculation of CIL for any development proposed on the balance of the site. Litchborough Parish Did not feel competent to challenge any of Response noted. n/a Council the figures or assumptions presented. Moulton Parish Additional developments should carry Response noted. CIL allows for a charge n/a Council responsibility for infrastructure additions. to be set against developments which might not previously have been required lvii

Respondent Comment Partner Council Response Action

to contribute via a s106 agreement. This ensures that smaller developments contribute towards the cumulative impact on infrastructure. Mr. Moore Everyone will ask for discretionary relief The Partner Councils will consider n/a which will cost the courts a great deal. responses before considering whether to adopt any CIL discretionary relief, beyond the statutory relief set out in the Regulations. Northamptonshire To strike a balance which ensures that The Partner Councils will consider n/a County Council – relief is given where appropriate but is not responses before considering whether to Highways, at the expense of the delivery of the new adopt any CIL discretionary relief, beyond Transport and improved infrastructure needed to support the statutory relief set out in the Infrastructure future development. Regulations. Northamptonshire A scheme of relief should not be adopted The Partner Councils will consider n/a County Council by any local authorities or for SUE’s. responses before considering whether to Planning Policy adopt any CIL discretionary relief, beyond the statutory relief set out in the Regulations. Pegasus Group Ltd Highly likely schemes will experience The Partner Councils will consider n/a difficulties and should have the option to be responses before considering whether to viability tested for relief and where adopt any CIL discretionary relief, beyond necessary exemption, especially where the statutory relief set out in the schemes are required to provide a number Regulations. of planning obligations through s106 agreements. Portfutures and Refer to question 1. - -

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Respondent Comment Partner Council Response Action

UKSL The Theatres Trust Refer to previous question. - - West Haddon There should be a scheme of discretionary The Partner Councils will consider n/a Parish Council relief for Social housing and charitable responses before considering whether to purposes. These are not precursors for adopt any CIL discretionary relief, beyond exceptional circumstances. Exceptional the statutory relief set out in the circumstances relief will only lead to lack of Regulations. clarity, delay and expense to manage given everyone will want a go at it. WNDC The need for a scheme of relief should be The Partner Councils will consider n/a rare based upon the viability assessment responses before considering whether to of the CIL however to comply with Regs 56 adopt any CIL discretionary relief, beyond the scheme should be provided. The the statutory relief set out in the scheme of relief can be removed if Regulations. necessary if it appears the need to use the scheme increases. Question 9 Do you consider that the charging authorities should have a policy for paying the chargeable amounts in instalments? If so, do you have a preference for how such a policy should be set, for example by percentages of the total amount and the length of time period in days? Asda Stores Ltd Phasing and an instalment policy would A draft instalment policy has been A Draft Instalment work well. prepared for consultation. policy is available for the next consultation. Brixworth Parish We recommend quarterly instalments by A draft instalment policy has been A Draft Instalment Council equal percentages and capable of being prepared for consultation. policy is available for apportioned by days.

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the next consultation.

Framptons Instalment would be very similar to phasing A draft instalment policy has been A Draft Instalment under s106. prepared for consultation. policy is available for the next consultation.

Gladman Council should adopt an instalment policy. A draft instalment policy has been A Draft Instalment Developments prepared for consultation. policy is available for the next consultation.

Hampton Brooks Introduce an instalment policy. A draft instalment policy has been A Draft Instalment Estates Ltd prepared for consultation. policy is available for the next consultation.

HBF Consortium Monitoring of CIL should take place on a 6- The Regulations require Annual Reports Adopted CIL Charing monthly basis. to be made available for inspection. Schedules will be However, the Partner Councils recognise monitored annually. that CIL monitoring is an ongoing process. Kleinwort Benson Payment by instalments should be allowed. A draft instalment policy has been A Draft Instalment prepared for consultation. policy is available for the next consultation. Litchborough Parish Did not feel competent to challenge any of Response noted. n/a Council the figures or assumptions presented. Mr. Moore Instalments should be related to the A draft instalment policy has been A Draft Instalment

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Respondent Comment Partner Council Response Action

completion of each dwelling. prepared for consultation. policy is available for the next consultation.

Northamptonshire Instalment will result in delays in the A draft instalment policy has been A Draft Instalment County Council – provision of infrastructure. prepared for consultation. policy is available for Highways, the next consultation. Transport and Infrastructure Northampton For all areas an instalments policy should A draft instalment policy has been A Draft Instalment County Council be considered in order to avoid the upfront prepared for consultation. policy is available for Planning Policy costs of CIL becoming a barrier to new the next consultation. housing. Pegasus Group Ltd CIL paid by instalments should be allowed. A draft instalment policy has been A Draft Instalment prepared for consultation. policy is available for the next consultation.

Portfutures and Refer to question 1. - A Draft Instalment UKSL policy is available for the next consultation.

Walgrave Parish On cash payments: On approval of A draft instalment policy has been A Draft Instalment Council planning permission or receipt of liability prepared for consultation. policy is available for notice – 33% Start of building (on the next consultation. commencement notice) – 33%,Completion – 34% ,On a land Transfer: All land transferred at approval – 100%

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Respondent Comment Partner Council Response Action

West Haddon Benefit to community for CIL funds should A draft instalment policy has been A Draft Instalment Parish Council impact as soon as possible and moreover prepared for consultation. policy is available for where certain infrastructure projects the next consultation. inevitably will precede CIL income. Larger development schemes are almost always phased over time and pace fluctuates with scales, hence leading to unpredictability over cash flow emanating from CIL levies, if in fact they actually are delivered in full. Compounding effect on inflation on value over time should be avoided. Instalments should not be offered. WNDC Instalments should reflect the type of A draft instalment policy has been A Draft Instalment development, for example the size, the prepared for consultation. policy is available for location, the timescale for delivery etc. the next consultation. There should be checks and balances in The Regulations provide the legislation place to mitigate such risks as unpaid CIL. necessary to initiate proceedings to recover unpaid CIL. Question 10 Infrastructure projects required to support new development, especially those identified in the West Northamptonshire Infrastructure Delivery Plan, may be candidates for receiving any CIL obtained. This first stage of consultation will help inform the projects that may be prioritised for funding through CIL. Suitable projects may be identified on the Councils’ Regulation 123 List (the list of infrastructure projects and/or infrastructure types that CIL monies will be spent on). What do you consider should be included within the Councils Regulation 123 list? Aynho Parish  Traffic impact relief projects to divert The County Council, as Highways Draft R123 List Council traffic induced by SNC and Cherwell Authority, and the Highways Agency, prepared for next Development Plans. In that traffic responsible for the Strategic Road consultation.

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Respondent Comment Partner Council Response Action

through Aynho will double on top of the Network, have advised the Joint Planning existing heavy burden we would like to Unit and Partner Councils on highway see the provision of a relief road round improvements necessary as a result of the village. growth outlined within the Joint Core  The village already suffers acute noise, Strategy. These agencies work closely to vibration and pollution impacts from the identify cross boundary issues. current volume of traffic. Bicester and Banbury combined have a plan for the The draft R123 list will be made available provision of in excess of 16,000 new for consultation and provides scope for homes and 6 large industrial/retail different schemes to be identified developments by 2031, traffic volumes throughout the plan period. into and through the village will grow significantly exacerbated by the traffic flows from the SNC development plan. Boughton Parish CIL must strike a balance within Government legislation provides a Draft R123 List Council communities. proportion of CIL to be spent on areas prepared for next directly impacted by development. The consultation. Partner Councils will work with communities to identify locally specific projects alongside those required across the strategic area of West Northamptonshire. The operation of CIL will require a percentage to be provided directly to Parish Councils. Brixworth Parish Priority should be given to roads and Response noted. Highways projects from n/a Council footways. the largest section of the Infrastructure

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Respondent Comment Partner Council Response Action

Delivery Plan.

Environment The Environmental Agency would welcome Response noted. The Joint Planning Unit n/a Agency the opportunity to meet with the JPU and has actively engaged with the the Lead Local Authority to: Update the Environment Agency (EA) throughout IDP to include the findings and development of the Joint Core Strategy. recommendations of the SFRA’s; Water The EA is contacted prior to each update Cycle Studies; Nene flood storage study; of the IDP and the Partner Councils are Northampton Standard of Protection review actively engaged with several strategic – Final Oct 2010; River Nene Catchment projects to identify green, water and flood Flood Management Plan; Anglian River risk projects. Basin Management Plan; and Local Flood Risk Management Study. Agree which green; water; and flood risk (fluvial and surface water) management infrastructure projects are most suitable for inclusion on the Councils’ Regs 123 List. Framptons Costs should be accurate. Costs are made available by service n/a providers and are the best cost estimates for works available at the time of publication. Some projects, such as large Sustainable Urban Extensions, require masterplans prior to the completion of detailed infrastructure estimates. As plans advance, costs will become more detailed. Hartwell Parish Extension to school, Local Safety The County Council, as Highways Draft R123 List

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Respondent Comment Partner Council Response Action

Council initiatives. Authority and Local Education Authority, prepared for next and the Highways Agency, have advised consultation. the Joint Planning Unit and Partner Councils on highway and education improvements necessary as a result of growth outlined within the Joint Core Strategy.

The draft R123 list, now available for consultation, provides scope for different schemes to be identified throughout the plan period. HBF Consortium Highlight the importance of Regs 123 List. The draft R123 list is now available for Draft R123 List consultation and will be part of the prepared for next package of documents available at consultation. Examination. Highways Agency NGMS to be included in the Regs 123 List. Response noted. The NGMS is included. n/a Kimbell Trust Transport, Health and Education. Response noted. The draft R123 list is Draft R123 List now available for consultation. Some prepared for next service providers consider that their consultation. service area might best be delivered via site specific s106 agreements. The R123 list reflects the discussions we have had with service providers. Litchborough Parish Did not feel competent to challenge any of Response noted. n/a Council the figures or assumptions presented.

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Respondent Comment Partner Council Response Action

Moulton Parish CIL’s should be used for the areas Some of the infrastructure impacts of n/a Council accepting new developments only, not for development will be addressed by site town centre improvements etc. specific s106 agreements. CIL is intended to address the cumulative impact of development and it is recognised that whilst this will include local projects such as road improvements, the cumulative development proposed across West Northamptonshire will have a significant impact on infrastructure items such as the strategic road network, service centres and green infrastructure networks. Mr. Moore Roads, sustainable transport plans, Response noted. The draft R123 list is Draft R123 List schools, hospitals, emergency services, now available for consultation. Some prepared for next provision of recreational and open space service providers consider that their consultation. etc. service area might best be delivered via site specific s106 agreements. The R123 list reflects the discussions we have had with service providers. Natural England  Local Plan should be Habitat A Habitat Regulation Assessment has n/a Regulation Assessment compliant. been completed for the Joint Core  CIL plays an important role in Strategy. Response noted. delivering such a strategic approach. Nene Valley Nature  Accessible natural green space should Response noted. The draft R123 list, now Draft R123 List Improvement Area be included in all Regs 123 list. available for consultation, provides scope prepared for next  CIL is good way to fund some green for different schemes to be identified consultation. infrastructure. throughout the plan period.

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Respondent Comment Partner Council Response Action

NHS Properties  The type of healthcare infrastructure Response noted. The Partner Councils Continuation of that should be funded should not be and Joint Planning Unit are actively collaboration with limited to primary care but should also engaged with healthcare providers to healthcare providers. include mental health and acute identify projects. secondary care. Northamptonshire  Highways, transport, education, health, Response noted. The draft R123 list is Draft R123 List County Council – utilities, community and leisure, open now available for consultation. Some prepared for next Highways, space and green infrastructure. service providers consider that their consultation. Transport and  All the various elements of service area might best be delivered via Infrastructure infrastructure mentioned above are site specific s106 agreements. The R123 necessary to support the principles of list reflects the discussions we have had sustainable development. with service providers. Northamptonshire  Transport and highways, education, Response noted. The draft R123 list is Draft R123 List County Council flooding, fire and rescue, library now available for consultation. Some prepared for next Planning and Policy services, mineral, waste and culture. service providers consider that their consultation. These are county council service areas service area might best be delivered via that are directly affected by new site specific s106 agreements. The R123 development. list reflects the discussions we have had  All various elements of infrastructure with service providers. mentioned above are necessary to support principles of sustainable development. Portfutures and We consider that progress with the CIL Response noted. n/a UKSL should be postponed until the JPU has progressed further work with the local plan SA/SEA and housing needs assessment work that has to be carried out or

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Respondent Comment Partner Council Response Action

alternatively that, given the current debate at the local plan EIP over infrastructure and viability. Sport England Sport England does not wish to raise any Response noted. n/a issues with regard to the Draft Charging Schedule. West Haddon  IT should be included. There are certain restrictions to projects n/a Parish Council  Broadband & mobile access in rural which could be identified for funding areas is an issue. through CIL. Due to State Aid rules, the  Business location and hence localised Partner Councils are unable to provide employment opportunities are being significant funding to private, profit severely impacted currently by IT. generating, companies.  BT has local monopoly. Wildlife Trust  Importance of Biodiversity. Response noted. The Partner Councils Draft R123 List  It is disappointing to see that wider and Joint Planning Unit are actively prepared for next partners have been involved in helping engaged with green infrastructure consultation. compiling this list. sponsors and developers to identify projects. The R123 list, now available for consultation, provides flexibility to identify projects throughout the plan period. WNDC  WNDC thinks that these should be on Utilities Draft R123 List the R123 list. Funding for Utilities projects is identified prepared for next Utilities: from service providers and developers consultation.  In the Infrastructure Delivery Plan utility will be expected to procure site specific projects make up 5 of the 12 key service provisions directly with each utility Continuation of infrastructure projects. The key company. collaboration with infrastructure projects are considered Transport service providers.

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Respondent Comment Partner Council Response Action

to be significant to all of West Transport projects form the largest Northamptonshire. There is also section of the IDP. The Partner Councils utilities infrastructure cost of £116m. will work with the local Highways Transport: Authority and Highways Agency to  In the infrastructure Delivery Plan prioritise funding and promote schemes transport projects make up 4 of the 12 for external funding throughout the plan key infrastructure projects. The key period and beyond. infrastructure projects are considered Green Infrastructure to be significant to all of West The Partner Councils and Joint Planning Northamptonshire. There is a known Unit are actively engaged with green transport infrastructure cost of £270.5 infrastructure sponsors and developers to m. There is also a substantial funding identify projects. The R123 list, now gap for transport which is estimates at available for consultation, provides £184.1m across West flexibility to identify projects throughout Northamptonshire. the plan period. Green Infrastructure: Education  Linked-up green space throughout Noted. Some service providers consider West Northamptonshire. There is a that their service area might best be funding gap across all three local delivered via site specific s106 authorities to provide for green agreements. The R123 list reflects the infrastructure. discussions we have had with service Education providers.  Education is worth considering as a type of infrastructure to be considered on under the 123 list because although primary education is localised and can be contributed to within S106,

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Respondent Comment Partner Council Response Action

secondary education could be considered as this is less localised. Question 11 Do you have a view on how the District/Borough Councils should coordinate and work with other infrastructure providers to ensure the delivery of infrastructure projects funded by CIL? Aynho Parish Don’t just focus on the impacts of Service providers work closely to identify Draft R123 List Council developments within the West cross boundary issues and many prepared for next Northamptonshire area. Where a village agencies have their own strategic consultation. abuts the eco system of a neighbourhood infrastructure plans. council these infrastructure plans must also take account of the Development Plans of The draft R123 list, now available for that neighbouring authority and the impact consultation, provides scope for different that those plans will have in villages lying schemes to be identified throughout the within the West Northamptonshire area. plan period. Boughton Parish CIL must strike a balance within See Question 10 Response. - Council communities. Deanshanger Money should be spent on community The draft R123 list, now available for Draft R123 List Parish Council amenities. consultation, provides scope for different prepared for next schemes to be identified throughout the consultation. plan period. It is recognised that some community facilities will be provided directly via s106 agreements. The operation of CIL will require a percentage to be provided directly to Parish Councils. HBF Consortium Regs 123 List is very important. Response noted. n/a

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Respondent Comment Partner Council Response Action

Highways Agency The task of developing a forward Response noted. n/a infrastructure programme with diverse infrastructure and an uncertain funding stream will represent a significant challenge for the authorities. Kimbell Trust Infrastructure that crosses boundaries. Service providers work closely to identify Draft R123 List cross boundary issues and many prepared for next agencies have their own strategic consultation. infrastructure plans.

The draft R123 list, now available for consultation, provides scope for different schemes to be identified throughout the plan period. Kleinwort Benson Set up a working group. Response noted. The Partner Councils Continuation of as Trustees of the are currently considering options for the development of Muriel Jackson- future Governance of CIL. internal processes Stops Settlement and procedures for the governance of CIL. Litchborough Parish Did not feel competent to challenge any of Response noted. n/a Council the figures or assumptions presented. Moulton Parish Consult with, and give adequate Noted – there will be a further chance to Partner Councils to Council consideration to local views, parish comment when the Draft Charging provide support and councils in particular. Schedule is consulted on. assistance as required to Parish Councils.

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Respondent Comment Partner Council Response Action

NHS Properties NHS would welcome regular liaison Response noted. The Partner Councils Continuation of through infrastructure delivery meetings and Joint Planning Unit are actively collaboration with and if the JPU circulated regular reports on engaged with healthcare providers to healthcare providers. how CIL monies are being spent. identify projects. Northamptonshire Unclear how CIL will be spilt when it comes Response noted. The Partner Councils Continuation of County Council – to the provision of infrastructure. are currently considering options for the development of Highways, future Governance of CIL. internal processes Transport and and procedures for Infrastructure the governance of CIL. Northamptonshire It is unclear what the administration and Response noted. The Partner Councils Continuation of County Council governance arrangements of CIL. are currently considering options for the development of Planning and Policy future Governance of CIL. internal processes and procedures for the governance of CIL. Pegasus Group Ltd Ensure CIL payments fund projects The IDP provides a list of key Draft R123 List outlined in the IDP. infrastructure projects required to deliver prepared for next the growth outlined within the Joint Core consultation. Strategy. The prioritisation of funds will be considered further as the Partner Continuation of Councils consider options for the future development of Governance of CIL. internal processes and procedures for the governance of CIL.

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Respondent Comment Partner Council Response Action

Portfutures and We consider that progress with the CIL Response noted. n/a UKSL should be postponed until the JPU has progressed further work with the local plan SA/SEA and housing needs assessment work that has to be carried out or alternatively that, given the current debate at the local plan EIP over infrastructure and viability. Sport England  I can advise Sport England does not Response noted. Some service providers Draft R123 List wish to raise any issues with regard to consider that their service area might best prepared for next the draft charging schedule. We are be delivered via site specific s106 consultation. however concerned that the agreements. The R123 list reflects the infrastructure delivery plan may be discussions we have had with service based on evidence that is out of date providers. or indeed not available.  Sport England contends that evidence which is in excess of three years old without significant review could be considered out of date and therefore not robust. I can also advise that I understand Northampton Borough Council are considering plans for Leisure centre redevelopment along with the Trust. I am unsure of the funding package and if therefore the facility should be included in the IDP.

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Respondent Comment Partner Council Response Action

West Haddon Do they have any capacity to coordinate? I Response noted. Partner Councils to Parish Council don’t see much. Certainly not with NCC or provide support and Parish Councils. assistance as required to Parish Councils. Wildlife Trust Wildlife Trust would like to emphasis the Response noted. The Partner Councils Draft R123 List multiple benefits that the natural and Joint Planning Unit are actively prepared for next environment provides such as to health engaged with green infrastructure consultation. and wellbeing, the economy and wider sponsors and developers to identify ecosystem services. projects. Continuation of collaboration with service providers.

WNDC Four of Northampton’s SUE’s overlap into Response noted. The Partner Councils Continuation of neighbouring authorities. There should be are currently considering options for the development of an opportunity for infrastructure providers future Governance of CIL. This includes internal processes such as NNC, Highways Agency, the ongoing work to identify specific and procedures for Environment Agency, Anglian Water and projects and the collaborative work the governance of energy suppliers to have a collaborative required to deliver the SUEs. CIL. approach to delivering infrastructure requirements. This would allow for funding to be coordinated in a way that could assist with delivering infrastructure for the Regs123 list.

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