Object

Representation ID: 68042

Received: 10/04/2015

Respondent: Taylor Wimpey Plc, Crest Nicholson Strategic Projects, Spitfire Properties LLP, Nurton Developments Ltd and Persimmon Homes Ltd

Agent: Savills

The BLV methodology and assumptions made by BNP - the application of generic BLVs is entirely inappropriate in this case - land values are extremely location-sensitive.
* The assumptions used in the viability models require attention. Most notably, we have concerns regarding the application of sales values, enabling costs and developer's profit as well as the fact that no site typologies of between 100 and 300 units have been tested.
* The rates are not supported by the viability evidence and would have the effect of putting a significant proportion of the housing supply at risk. For example, our analysis of BNP's own viability evidence, combined with our own evidence, illustrates that the majority of strategic sites allocated within the emerging Local Plan cannot realistically support a CIL rate. It is currently anticipated by the emerging Local Plan that 3,677 homes will be delivered through strategic sites across the Plan period. This equates to 29% of the District's housing supply across Zones A, B and C (which equates to over 58% of allocated sites).
* The rates to be applied in Zone D are not reflective of housing market areas on the ground. This will likely stifle the ability to deliver allocated housing sites on the edge of existing urban settlements (where the sales values to be achieved are likely to be more akin to the adjoining urban area than more, exclusive sites in higher value villages such as Lapworth, Shrewley or Leek Wootton). The 'jump' between the rates applied in different Charging Zones (particularly to the east of Warwick where rates appear to increase from £30 - £50 per sq m in Zone A to £110-£180 per sq m in Zone D) is concerning in this regard and must be addressed at the earliest opportunity or else put at risk the delivery of housing on allocated and non-allocated sites (which account for over 50% of the District's housing supply) within Zone D.
Warwick District Council CIL DCS
The Statutory CIL Guidance is clear on the narrow focus of the CIL Examination process permitted by the Regulations:
"The Examiner should establish that:
 the charging authority has complied with the required procedures set out in Part 11 of the Planning Act 2008 and the CIL Regulations;
 the charging authority's draft charging schedule is supported by background documents containing appropriate available evidence;
 the proposed rate or rates are informed by and consistent with, the evidence on economic viability across the charging authority's area; and
 evidence has been provided that shows the proposed rate (or rates) would not threaten delivery of the relevant Plan as a whole."1
This representation is therefore structured in three parts to mirror these requirements. Part 1 provides commentary on the Viability Study prepared by BNP to assess whether the Draft Charging Schedule (DCS) is supported by appropriate available evidence. Part 2 assesses the analysis and interpretation of the Viability Study2 results to determine whether the rates are informed by and consistent with the viability evidence. Finally, Part 3 analyses whether the proposed CIL rates will put the overall development in Warwick at risk.
Development appraisals have been appended to this representation.