I object to the Draft CIL Charging schedule as in my opinion it is flawed.
Community Infrastructure Levy contribution should be applied to all new developments as all benefit from the infrastructure.
In the case of housing, this contribution should be a very small percentage of the market value of the property, which would enable the quantum assessment to accommodate economic fluctuations and be up-to-date without the need to frequently reassess the whole schedule. It would share the burden more equitably between those in need of affordable housing and the remaining 60% struggling to raise a mortgage.
An overly complex model is used to calculate the different levies and their variations, due mostly to regulations, obligations, anomalies and special pleadings. The result appears to be a schedule which is both cumbersome and unfair.
Of the 5 strategic sites selected for the Viability Study, Blackdown was by far the largest designated for up to 1600 houses, but failing to include construction and maintenance of supporting infrastructure such as school, medical services, green spaces or shops. This site had been removed from the 2013 Local Plan, which makes nonsense of including it as a major strategic site in a meaningful Viability Study.
Blackdown and Old Milverton are rural farming areas but were categorised in the 2013 CIL as urban fringe development areas. This issue was raised in the submissions at that time but has not been corrected, despite the Parish boundaries having been moved to exclude North Leamington School with adjacent new dwellings and a small estate in Milverton.
These two farming parishes of Old Milverton and Blackdown, now consist of just a hamlet, a scattering of commercial properties and houses, all surrounded by extensive fields. The land values should be in the highest rural category for the purpose of accurate CIL calculations.
If the complex viability study had been based on accurate information, and the most up to date Local Plan (i.e. 2015, updated 2016 Plan, requiring minor modifications in 2017 to be sound) then more confidence could be placed in the Draft Community Infrastructure Levy Report being reliable, useful and worthy of support.
Further thoughts for consideration
1. Further adjustments should be considered to take into account infrastructure projects that may never be built
2. The infrastructure levy should be applied just to those who would benefit most from the proposed developments. I refer primarily to landowners, many of whom have inherited high quality, food producing land at relatively low value, which they are prepared to sacrifice in the interest of vastly inflated land values for speculative developments. This would make for much easier calculations and payment in advance of development.