Note provided to Examiner following day 1 of MCIL2 Examination in Public 11 September 2018
I said I would provide a note of the various document references I made earlier today (as part of the ‘Broad Approach’ agenda item) – as I appreciate it may have been difficult to jot down all of the references correctly. These are as follows:
References in the ‘MCIL2 DCS Supporting Information’ (June 2018)
Paragraph 3.7 – this paragraph includes the following statement ‘…the Mayor does not consider his proposed MCIL2 rates will impede delivery in the London Plan’s Opportunity Areas.’ I referenced this as an example of a sweeping statement without any back-up viability testing of the Opportunity Areas (especially those of concern: Elephant and Castle, Waterloo and Battersea/Nine Elms).
Table 5 – this compares the Crossrail S.106 and MCIL2 rates and the related percentage change. The table does not include an explanation of the percentage change for Elephant and Castle, Waterloo and Battersea/Nine Elms. This is straightforward to work out, but for ease the figures are:
Charging MCIL1 rate Proposed Change Change (%) areas and uses (forecast MCIL2 rate (£/sqm) index at Q2 2019) (nb. no Crossrail S.106 rate applies) Battersea/Nine Elms Opportunity Area Office £64.57 £185 £120.43 +186.5% Retail £64.57 £165 £100.43 +155.5% Hotel £64.57 £140 £75.43 +116.8% Elephant and Castle Opportunity Area Waterloo Opportunity Area Office £45.20 £185 £139.80 +309.3% Retail £45.20 £165 £119.80 +265% Hotel £45.20 £140 £94.80 +209.7%
Section 4 – I referenced this as an example of concerns expressed in representations about Elephant and Castle, Waterloo and Battersea/Nine Elms not being set out.
References in the JLL ‘MCIL2 Viability Evidence Base’ (November 2017)
Paragraph 1.4.3 – I referenced this to explain the broadness of the market commentary and that it does not look at market conditions associated with Elephant and Castle, Waterloo and Battersea/Nine Elms.
Paragraph 2.1.7 – The approach is explained as rolling Crossrail S.106 rates into the MCIL2 charging regime. I made reference to this as it does not explain the relationship with Elephant and Castle, Waterloo and Battersea/Nine Elms.
Paragraph 2.1.16 – This paragraph explains that the Crossrail S.106 charges have not been negotiated downwards. I made reference to this point as it is not able to be applied to Elephant and Castle, Waterloo and Battersea/Nine Elms.
Section 6 – This section includes an explanation that the approach to MCIL2 has not been to propose significant changes or sharp changes to the rates. I made reference to this point because what is said in this Section does not ‘fit’ with the approach taken to Elephant and Castle, Waterloo and Battersea/Nine Elms.
Craig Tabb (dp9)