Comment
Draft CIL Consultation Information Booklet
Representation ID: 30937
Received: 09/11/2022
Respondent: Essex County Council
Section 9-IDP
ECC seeks clarification on which IDP version used for CIL viability work.Section 9 references IDP v.3(2019-produced prior to LP EIP Hearing sessions).IDP published January 2021 was examined by Inspectors at EIP (Infrastructure requirements updated to reflect then current proposed housing figures/employment land for LP site allocations and latest costs).Increased funding gap (£50.4 million (2019) £71 million (2021)).Unclear whether impact been considered as part of CIL viability. Unclear whether impact of increase in housing numbers on some LP residential site allocations (MM's to LP),or sites subsequently obtained planning consent have been considered as part of CIL viability work.
Section 9 - Evidence base documents - Infrastructure Delivery Plan
ECC seeks clarification on which version of the IDP has been used as part of the viability work for the CIL and for this to be referenced accordingly.
Section 9 makes reference to the IDP version 3 from 2019, which was produced prior to the Local Plan Examination in Public (EIP) Hearing sessions. The IDP published in January 2021 updated Part B (the Schedule of Costs) and was the version that was examined by the Inspectors as part of the Local Plan EIP. The infrastructure requirements set out in the January 2021 IDP were updated to reflect the then current proposed housing figures / employment land for the Local Plan site allocations, as well as the latest costs of the required infrastructure. This resulted in an increase in infrastructure costs and the funding gap increasing from £50.4 million (2019) to £71 million (2021). It is unclear whether the impact of this has been considered as part of the viability work for the CIL.
Furthermore, it is unclear whether the impact of an increase in housing numbers on some of the Local Plan residential site allocations (as requested by the Inspectors as part of the Main Modifications to the Local Plan), or sites that have subsequently obtained planning consent have been considered as part of the viability work for the CIL.