The University of Warwick is grateful for the opportunity to comment on the Draft Charging Schedule for the Community Infrastructure Levy which is being consulted upon alongside the new Local Plan.
The University's only concern is the proposed charge for student accommodation, which we note has increased from the previous Draft Charging Schedule 2013, from £80 per sq m to £100 per sq m. This is similar to supermarkets and retail parks, higher than some retail, and higher than hotels, offices, industrial warehouses and D1/D2 uses which attract no charge.
We note that one of the exemptions under para 6.1 of the Viability Study (2016) is for development by registered charities for the delivery of their charitable purposes, for which the University would qualify in respect of the development of its own residential accommodation.
The Viability Study prepared by BNP Paribas Real Estate in November 2016 states:
'If the University continues to develop its own student accommodation, developments would be exempt from CIL under Regulation 43, providing the provision of student accommodation is consistent with the University's charitable objectives. Consequently, only speculative student housing built by the private sector would be liable.'
We anticipate this would apply where the University develops student halls of residence on its own campus to be managed by the University for its own students. We would appreciate clarification that this exemption would apply for off-campus accommodation if the University chooses to develop student housing for its own use but in locations other than on campus.
The University is keen to ensure that purpose-built student accommodation can be provided in other locations, consistent with policy, in order to reduce reliance on Houses in Multiple Occupation which can
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disproportionately affect existing communities. It provides an important part of the range of housing available for students of different ages and personal circumstances.
The University previously (in its 2013 representations) raised the question of what infrastructure the levy would be contributing towards whose need arose from student accommodation. There was nothing evident in the IDP and no reference in either the 2013 or 2016 Viability Studies as to why a larger discount was applied in the earlier study than the more recent one between the contribution that can be afforded and that to be charged.
We ask that these representations are taken into account and would be happy to meet to discuss further the University's accommodation strategy.