Support

Representation ID: 30921

Received: 07/11/2022

Respondent: Sport England

The proposal for a zero CIL rate for all other development which would include community sports/leisure facilities is welcomed. Most community sports facilities such as leisure centres, playing fields etc are operated by local authorities, clubs and voluntary organisations on a not for profit basis to meet community needs. If CIL was charged for new facilities, or enhancements to existing facilities, this may have viability implications for implementing the proposals. In Sport England’s experience, viability work from elsewhere in the region has shown that such uses would not justify CIL payments and therefore have been specifically excluded being charged CIL.

Object

Representation ID: 30949

Received: 11/11/2022

Respondent: GL Hearn

It is submitted that the Brentwood draft
CIL rates proposed for residential development at £250/sq.m are exceptionally high and likely to cause
detrimental impacts on housing delivery and housing affordability within Brentwood. Continued slow housing
delivery will result in detrimental social impacts within Brentwood and the housing market area due to restricted
housing supply and availability, as well as detrimental economic impacts and restricted economic growth.

Comment

Representation ID: 30950

Received: 11/11/2022

Respondent: GL Hearn

The exceptionally high Brentwood draft CIL rates of £250/sq.m for residential are also directly opposed to the
aims, aspirations and targets to increase housing delivery as set out within the Brentwood Housing Action. Plan, November 2021 as well as the Council’s Housing Strategy for 2021-2026. The proposed Brentwood draft CIL rates at £250/sq.m for residential development are unusually high in comparison to CIL rates within similar local neighbouring authorities

Object

Representation ID: 30952

Received: 09/11/2022

Respondent: BNP Paribas Real Estate/Strutt & Parker

St Modwen consider that BEP should be exempt from CIL in the same way that Dunton Hills is, given both developments are providing significant s106 contributions as well as BEPs wider infrastructure benefits. If this can be agreed, St Modwen will withdraw their holding objection.

Object

Representation ID: 30955

Received: 09/11/2022

Respondent: Laura Dudley-Smith

The imposition of such CIL rates on employment generating development will undoubtedly place an additional burden on the owners/occupies and will in our view provide a barrier to further important economic uses coming forward. This will have significant potential impacts on the economic growth in the Borough.

Object

Representation ID: 30956

Received: 09/11/2022

Respondent: Laura Dudley-Smith

It is our view that the Council’s approach of seeking to double count/collect for the same infrastructure cannot be justified and if progressed would place additional and unsustainable demands on the viability of these projects.
The CIL consultation should also provide further clarification on the list of infrastructure it is intending to fund and the relationship with any proposed S106 contributions in accordance with the items in the published IDP.
There appears to be limited information available on this at present.

Object

Representation ID: 30957

Received: 09/11/2022

Respondent: Transport for London

TTLP are concerned that the proposed CIL rates set out in the CIL Draft Charging Schedule could have adverse implications for the viability of development on Brentwood Railway Station Car Park, the development of which could provide much needed housing (including affordable housing) and other public benefits.

Support

Representation ID: 30960

Received: 09/11/2022

Respondent: Mr David Barnes

CEG is supportive of the retained BLV because it is entirely appropriate and correct that the BLV for CIL should be the value which underpinned the preparation of the Local Plan, the associated policy aspirations and the evidence presented by the Council to the Inspectors who examined the Local Plan. Indeed, the Local Plan was only adopted by the Council in March 2022 and hence there can be no cogent reasons to depart from a BLV which informed such a recently adopted plan. The BLV
has been known to all parties since at least October 2018 and has not changed.

Object

Representation ID: 31075

Received: 09/11/2022

Respondent: Laura Dudley-Smith

The proposed rate of CIL for B8 uses would jeopardise new projects in the Borough

Object

Representation ID: 31076

Received: 09/11/2022

Respondent: Transport for London

There are significant abnormal costs for proposed development on the Brentwood Railway Station Car Park. The imposition of CIL could therefore render development on the site financially unviable. The significant abnormal costs on this site have not been appropriately assessed in the VA.