Gladman Developments Limited has considerable experience in the development industry in a number of sectors, including residential and employment land. Gladman note that the intention of this consultation is to seek comments on the Draft CIL Charging Schedule for Warwick District. The Council is currently in the process of examination of its Local Plan, a further round of hearings concluded in December 2016.
Gladman have previously made representations into consultations on the CIL for Warwick in both 2013 and 2015. In our responses in both 2013 and 2015 we included reference to work undertaken by Carter Jonas on behalf of Gladman developments, considering a wide range of issues in the evidence base which underpin the CIL. It is understood that the Council have now refreshed the evidence base which underpins the charging schedule and this letter sets out Gladmans' response to both the charging schedule and its accompanying evidence base.
It is noted that the Council state in paragraph 4.2 of the charging schedule that the Councils responses were reported, to the 2013 consultation, in January 2015. Gladman noted in our last representation that these responses did not take into the consideration the points made by Carter Jonas in the duly made representation from 2013. We note that we have still seen no record from the Council that these representations have been considered, nor have we seen any counter point to the evidence put forward by Carter Jonas.
Although each CIL charging schedule needs to be locally evidenced, to take account of local circumstances, the proposed rates for Warwick District (Zones B and D) are the highest currently proposed of any authority in the
East or West Midlands1. Indeed authorities, which may be considered good comparisons, such as Stratford-on-
Avon and Solihull have upper end residential charges of £150 p/sqm. Whilst high these are nearly 25% lower
than those proposed for Zones B and D in Warwick. It is noted that the ongoing examination of the CIL for
Stratford-on-Avon has been particularly protracted.
Gladman and Carter Jonas have previously cautioned against the potential for such large CIL rates to have a
negative impact of 'market shock' upon Warwick District. The cost of providing 40% affordable housing in
combination with the rate of £195 p/sqm will be far in excess of the current payments secured through Section
106 mechanisms. We strongly urge that the levies attached for Zones B and D are reconsidered, failure to do so
could negatively impact the land supply within the District.
Charging Zones
Gladman maintain the view previously expressed that the proposed boundaries for the Charging Zones are not
robustly justified. Whilst we understand the broad premise for the Charging Zones, it is not clear how the
District Council has arrived at the proposed boundaries. Furthermore the map which accompanies the charging
schedule is unclear in certainty areas, raising confusion as to which charging zone certain areas may fall within.
CIL Viability Report
Gladman have considered the tables set out in the BNP Paribas report on pages 33 and 34. It is noted that a
number of development scenarios are offered. As outlined in our previous representations we retain a number
of concerns with regard to the way in which the evidence base has assessed the viability assumptions that the
CIL charges will have. We are particularly concerned about the cumulative impact of the CIL rate in the higher
zones with an affordable housing requirement of 40%. We do not consider that the charging schedule is fully
evidenced to demonstrate that development viability will not be compromised.
Regulation 123 List
It is noted that at this time the Regulation 123 infrastructure list has not been published. The Council will need
to publish this documentation for comment. Local planning authorities need to be able to demonstrate the
infrastructure need and subsequent funding gap and must ensure that the level of total CIL receipts that could
be generated through the levy reflects the true needs and proposals in the Local Plan. The CIL should not be
used by Council's as a mechanism for creating an unrealistic 'wish list' of infrastructure projects in their area.
When establishing a funding gap that CIL receipts are intended to contribute towards filling, it is vital that the
Council take account of every possible income stream. This has to include an accurate assessment of future New
Homes Bonus and council tax and business rates receipts generated as a result of new developments allocated
in the Local Plan, as well as central government funding streams. This should also include an assessment of
statutory undertakers' asset management plans, as these companies will at some stage be upgrading their
systems/facilities. This also needs to be taken account of when assessing the infrastructure requirements of the
authority.
The Council need to have an up to date, robust evidence base that fully justifies the infrastructure needs based
on the amount of development that is required. Information on these infrastructure needs should, wherever
possible, be drawn directly from the infrastructure planning that underpins the Development Plan, as this
should identify the quantum and type of infrastructure required to realise their local development needs. If the
authority's infrastructure planning is weak or out of date then the Council should undertake an exercise to
refresh this. If the evidence base is not complete, robust and up to date the charging schedule will be unsound
1 http://www.planningresource.co.uk/article/1121218/cil-watch-whos-charging-what
and the local planning authority will have difficulty adequately demonstrating their funding gap and subsequent
CIL requirements.
Conclusions
We strongly urge the Council to revisit its evidence base in line with the reasons outlined in this representation
and our previous representations. Gladman maintain that the Council have failed to adequately consider the potential cumulative negative impacts of the CIL Charge and the level of affordable housing required to be
delivered.
Gladman would request to be heard at any hearings, should the charging schedule move forward to examination.