Dear Warwick DC,

In reference to your consultation on the Community Infrastructure Levy please find the a response from the Federation of Small Businesses (FSB);

FSB Members are frequently involved in owning or constructing single dwellings or small developments. Prior to the introduction of CIL, these small developments rarely paid Section 106 developer contributions. The Community Infrastructure Levy (CIL) will be a new tax on these developments at a time when the need to build more new housing is one of the biggest challenges facing local authorities. At the same time, as detailed in your plan, you are extending your requirement for affordable housing to small developments. Although the requirement can be waived if it makes the development unviable, the burden of proof is falling on our members, adding to the cost and risk of development. I believe this disproportionate burden is not reflected in the viability modelling carried out by WDC.

The FSB recognises the requirement to avoid undue complexity in setting differential CIL rates but believes strongly that rates should reflect the real variations in viability by use, size and location of development across your area, and it is encouraging to see this has been considered by WDC. However, have WDC considered, within their viability assessment, the difference between out-of-town retail and prime high street frontage, against secondary trading locations and calculate CIL charges that reflects these differentials? We must encourage development within our town centres.

There is currently no requirement for councils to spend CIL funding on infrastructure in the neighbourhood where it was raised. CIL funding can be switched to fund or maintain infrastructure anywhere in the council area. This undermines and weakens the relationship between the impact and the benefit of a new development. The FSB calls on WDC to ensure that there is a link between the development paying CIL and the infrastructure it funds.