Draft Charging Schedule

Support

Representation ID: 68037

Received: 10/04/2015

Respondent: Place Partnership Limited (PPL)

Introduction:
Under paragraph 1.5, the continued use of Section 106 agreements is welcome as this will have potential to continue to provide funding for police infrastructure costs that are directly related to the new development. The Schedule does not address the potential implications of the restrictions on the pooling of Section 106 contributions. In particular the document should outline how these
restrictions will be operated in practice and whether there is potential to address some of these infrastructure requirements and generate sufficient funding through CIL.
* In calculating the CIL charge and balancing this with viability, as set out under paragraphs 1.7 to
1.11, it is essential to be clear which elements of infrastructure are to be funded through CIL and which through Section 106 agreements.
Needs and Delivery:
Warwickshire Police (WP) and West Mercia Police (WMP) welcome the inclusion of emergency
services under paragraph 2.2 of the policy, reflecting the findings of the Infrastructure Delivery Plan.
It is, however unclear from this which elements of emergency services infrastructure will be covered
by CIL and which will continue to be collected through S106 contributions. This needs to be clearly
set out in the Regulation 123 list.
* WP/WMP are currently working on a Strategic Infrastructure Assessment for Warwick and Stratford
Districts, which will help to inform police infrastructure requirements across South Warwickshire.
Proposed CIL Charging Rates:
The larger Strategic Sites as referred to in paragraph 5.2 are likely to be those where there is most
demand for increased police presence and therefore new infrastructure. If there are to be reduced
CIL payments for these sites it needs to be clear from the schedule that S106 payments would be
required towards on-site infrastructure, including police infrastructure.
* The charging rates are set at quite a cautious level, which is acceptable as long as S106
agreements continue to be used as the main funding source for police infrastructure. However, the
Regulation 123 list needs to clearly demonstrate those items to be funded through CIL and S106
and there needs to be a clear approach across the District to deal with the restrictions on pooling of
S106 contributions. We consider that the current wording in the Draft Regulation123 List relating to
'Police equipment and other costs' is much too vague and may jeopardise future requests from the
police for site-specific funding through S106. With the rates set at a cautious level it seems very
unlikely that CIL would produce the levels of contributions identified (£1 million) in the Draft
Regulation 123 List. As the 'police equipment and other costs' would be likely to relate to specific
sites, we would wish to see this aspect removed from the Draft Regulation 123 List and to continue
to be funded through S106. The Police Custody Suite should continue to be funded through CIL.
Exemptions and Payment Terms:
Infrastructure cannot be delivered incrementally i.e. small sections of a road or a police station
cannot be built in isolation. Developers should be factoring this in as part of their calculations. With
an instalment policy the risk is that a given scheme will get all of the benefits of particular
infrastructure, but share only limited costs.
* Payments for police infrastructure such as police offices, officer training, vehicles and ANPR will
need to be payable prior to occupation of the dwellings. As these would be capital costs, it would not normally be feasible for these to be paid in instalments.