Richborough Estates Limited OBJECT to the Community Infrastructure Levy: Draft Charging Schedule (Jan/Feb 2017).

As identified at Appendix 1 of the Draft Charging Schedule, Charging Zone A covers, in part, the western side of Warwick including the settlement of Hampton Magna. Indeed, Hampton Magna is not identified in Table 4.4.3 of the Community Infrastructure Levy: Viability Study (2016 Updated) as a settlement within the rural area of a 'higher value'. This is an important context for the consideration of Richborough Estate's objection

Included within this defined Charging Zone A is the housing allocation at Arras Boulevard, Hampton Magna as defined in the Warwick District Local Plan (Site H27). The inclusion of this site in the edge of Hampton Magna within Zone A is entirely logical and appropriate because the activities of future resident of the proposed housing would impact upon the infrastructure and services to the west of Warwick. It also reflects the 'lower value' rural settlement status of Hampton Magana.

However, probably because it was only included as part of the Proposed Modifications (February 2016) rather than the originally submitted version of the Local Plan, the housing allocation at Lloyd Close, Hampton Magna (Site H51) is treated differently from Site H27. Although the site is on the edge of Hampton Magna and the future residents would have the same impacts on the infrastructure and services to the west of Warwick as those of Site H27, Site H51 is included in Charging Zone D rather than Zone A.

There are no clear and obvious reasons why these 2 housing allocations identified on the edge of Hampton Magna, which is a 'lower value' rural settlement, should be treated differently in respect of the amount of Community Infrastructure Levy that would be paid.

It would be both illogical and unfair if different Charging Zones were applied to these allocated sites. Indeed, the difference in payment between the 2 sites could be an average of say £7,000 per market dwelling which is financially a significant difference for a housing allocation at a 'lower value' rural settlement.

Based upon a simple comparison there are no geographical or spatial reasons why Site H27 and H51 should be treated differently. Indeed, the sites are on the edge of Hampton Magana and adjoin one another.

The character of the sites is no different suggesting any points of differentiation such as dwellings on Site H51 would attract a higher sales value to justify a Levy being paid because they are within a 'higher value' rural settlement.

The costs of developing Site H27 and H51 are similar, including matters such as access, ground conditions and utility services. There is nothing to suggest Site H51 can support the higher level of Levy payment whereas Site H27 cannot.

The anticipated impacts of the occupiers of each dwelling which might be constructed on both infrastructure and services must be similar. It would be illogical to assume that more people would occupy a dwelling on Site H51 and thereby have a greater impact on infrastructure and services.

It appears to Richborough Estates that the failure to include Site H51 within Charging Zone A is a simple oversight associated with this allocation at Hampton Magna only being introduced via the Proposed Modifications. Accordingly, an amendment to the map at Appendix A of the Draft Charging Schedule is sought by Richborough Estates whereby Charging Zone A includes both Site H27 and Site H51 as part of Hampton Magna reflecting its status as a 'lower value' rural settlement.

Whether similar discrepancies apply to other allocations introduced via the Proposed Modifications is a matter which the Council and the Examiner may wish to consider more fully.