Proposed Revisions to Draft Local Plan (Preferred Options)

Comment ID 1071
Document Section 1. Preferred Options Revisions Section 9 - New Implementation Policy New Implementation Policy [View all comments on this section]
Respondent StJohnsCollege [View all comments by this respondent]
Response Date 17 Mar 2017
What is the nature of this representation?
  • Object
Comment

It is noted that this is a first working draft of this plan and that it will continue to be updated and amended as it develops. However we would set out the following comments in relation to this document.

4.2. Paragraph 9 of the Plan suggests that the Council is considering whether a reduced or even zero rated Community Infrastructure Levy should be applied to the strategic development sites. This is due to the fact that the infrastructure requirements on these sites will be significant and will be better delivered through a Section 106 agreement rather than the CIL. It is our experience elsewhere that many authorities are taking the zero rated CIL approach on strategic sites precisely because of this issue. It allows both the developer and the local authority much more flexibility in order for timely delivery of key infrastructure on these strategic development sites which are crucial to the delivery of the overall local plan strategy. Many of these strategic development sites are envisaged to deliver the strategic route network which is required to underpin the overall development strategy. This is likely to add significant costs to the development of these sites and therefore we consider that CIL would be inappropriate to be applied to these sites. Under CIL, there could also be issues around the timing of funding for the infrastructure that is required for delivery of development.

4.3. At Paragraph 25 the document refers to the Transport Strategy and states that public consultation will be undertaken on this in the near future. Given that this Transport Strategy is crucial to the overall delivery of the Local Plan and the detail that it is likely to include it is difficult to provide sensible comments on this element of the plan without this detail.

4.4. Towards the end of the document is a table setting out a schedule of Local Plan key infrastructure. The first of the key infrastructure requirements specified is affordable housing. The table states that affordable housing should be provided as an integral part of each phase of development subject to CIL viability. However there is no acknowledgement of the potential upfront infrastructure costs associated with the delivery of strategic sites. It should be made clear that whilst 30% affordable housing should be achieved across the site it may not be possible to provide 30% affordable housing in the early phases of development. Therefore some flexibility should be acknowledged in this part of the delivery plan.

The transport infrastructure set out in the delivery plan states that all of the inner circuit requirements will be developer funded. At present there are no figures associated with the cost of the inner circuit other than the widening of Shottendane Road which is expected to be up to £30 million. Whilst the Council acknowledge they are also seeking LEP funding it is unclear what if any other funding may be available to contribute towards these transport improvements. Without any details around the cost of the improvements it is impossible for meaningful comment to be made on this element of infrastructure delivery other than to reserve our position until such costs are known.

 

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Proposed Change
Notes