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Comments on 3 papers from FBC

(Submitted 6th August 2014)

 

 

Fareham Borough Council

Civic Offices

Civic Way

Fareham

Hampshire

PO16 7AZ

 

6th August 2014

 

Dear Sir/Madam

 

The Fareham Society wishes to submit the following comments on the:

 

Community Infrastructure Levy First Review

Welborne's Planning Obligations and Affordable Housing document

Planning Obligations and Affordable Housing Document (excluding Welborne)

 

The Society understands that the benefits from the use of the Community Infrastructure Levy (CIL) include ensuring greater transparency for local people, because they will be able to understand how new development is contributing to their community, and providing developers with much more certainty 'up front' about how much money they will be expected to contribute. It also enables local authorities to allocate at least a 15 percent share of the levy raised in a neighbourhood to deliver the infrastructure the neighbourhood wants and identified through a proper consultation process.

 

The proposed use of Section 106 agreements for all infrastructure at Welborne is undemocratic because there is no public consultation on the preparation/content of the agreements and they are generally treated as confidential. Agreements are also subject to review after 5 years or at the request of the landowner/developer.

 

Agreements therefore reduce certainty; the flexibility benefits are all in favour of the landowner/developer and place the provision of the infrastructure when it is needed at considerable risk. This is demonstrated by the predominance of the section on the deferral of contributions in the SPD.

 

The use of agreements also removes the requirement to allocate at least 15 percent to infrastructure that the neighbourhood wants.

 

The current promoters of Welborne do not control the whole site, therefore the agreements can only relate to their part of the site, resulting in further uncertainty about the implementation and provision of infrastructure relating to the parts of the site they do not control.

 

The Welborne Planning Obligations and Affordable Housing document is inadequate as it provides too much scope for infrastructure not being provided when it is required or not being provided at all. This is likely to lead to the requirement for further public subsidy for the provision of the necessary infrastructure when this should be provided by the landowners/developers from the greatly enhanced value of the land created by the proposed development.

 

The Society believes that the Welborne and the Fareham excluding Welborne SPDs should include the same appendices relating to the Solent Disturbance and Mitigation Project and On-site Open Space, Outdoor Sports and Children's Play Equipment Standards.

 

Yours faithfully,