Community Infrastructure Levy Draft Charging Schedule - Regulation 16
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Community Infrastructure Levy Draft Charging Schedule - Regulation 16
Question 1: Do you have any comments on the content of the CIL Viability Assessment Update?
Representation ID: 30951
Received: 09/11/2022
Respondent: BNP Paribas Real Estate/Strutt & Parker
It is therefore important that St Modwen responds to the assumptions of viability made in the Assessment. They consider that whilst the s106 costs referenced are broadly correct, land values and development costs have changed significantly this year, and particularly in the last 2 months, and this substantially changes some of the inputs to the appraisal. St Modwen consider that BEP should be.
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Community Infrastructure Levy Draft Charging Schedule - Regulation 16
Question 4: Do you have any comments on the proposed CIL rates?
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.
See attached
Object
Community Infrastructure Levy Draft Charging Schedule - Regulation 16
Question 8: Do you have any other comments on the draft CIL Charging Schedule?
Representation ID: 30953
Received: 09/11/2022
Respondent: BNP Paribas Real Estate/Strutt & Parker
Concern regarding double counting if CIL is directed to paying for strategic infrastructure.
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Object
Community Infrastructure Levy Draft Charging Schedule - Regulation 16
Question 1: Do you have any comments on the content of the CIL Viability Assessment Update?
Representation ID: 31067
Received: 09/11/2022
Respondent: BNP Paribas Real Estate/Strutt & Parker
Object to assumptions within the VA, where the following has not been sufficiently considered, and therefore require amendments to the VA:
- A 30% reduction in capital values in the industrial and logistics sector. Prime yields have shifted from 3.25% to 5.25% in a 3 month period. Far more significant is the impact on land values for industrial and logistics development which have generally reduced by 60% to 65% since June 2022. This is a consequence of not only the outward yield shift on the GDV but the compounding effect of considerable inflation on construction and infrastructure costs as well as higher finance rates and increased risk margins applied through all aspects of development appraisals.
- Revenue - The capital value per sq/m of £2,800 in terms of assumed rent and yield requires clarification.
- Project programme - It is unclear how the project programme has been tested.
- Buyers costs - The VA does not take into account Stamp Duty Land Tax, sales agent fees and sales legal fees.
- Construction costs - It is unclear which BCIS cost rate has been applied.
- The VA does not include all infrastructure costs for the site, which should be £116m.
- Contingency - a 5% contingency should be applied.
- Commercial letting and legal fees - Include a commercial letting and legal fees of 15% in the first year of rent for letting fees and 5% for legal fees.
- Finance - The finance rate of 6% should be increased to account for the recent base rate increase.
See attached