Object

Representation ID: 8430

Received: 24/03/2020

Respondent: Letchworth Garden City Heritage Foundation

Agent: Planning Matters

1.3.4 - The document fails to address the relationship of developer contributions and Community Infrastructure Levy (CIL) and request that greater clarity is given on the Council’s approach concerning CIL and whether this will be introduced.

We suggest that as the Developer Contributions SPD is subject to public consultation there is an opportunity to include formulaic calculations.

In its current form, the Developer Contributions SPD presents possible future inconsistency, which takes away a degree of certainty.

1.3.5 - Where this complies with the fairness requirements stated at Paragraph 1.3.3 and we recommend that a reference or definition should be provided within the text for the need to ensure pooling contributions is fair.

1.9.2 - NHDC should be the central body charged with administering S106 monies to third parties and should be responsible for ensuring compliance with S106 clauses stating when and how the funds will be used by and secure for their return, after an agreed period of time,
where they are not (in accordance with Planning Policy Guidance Planning Obligations, Paragraph 021).

There is no reference in the document to the requirement for parties to payback unspent planning obligations (Planning Policy Guidance: Planning Obligations, Paragraph 021).

Furthermore, we would expect that the Heritage Foundation to be one of the organisations who could be a party to S106.

1.10.1 - We request that there should be greater clarity when the Infrastructure Development Plan will be updated, with a timetable.

1.11.2 - The text is misleading and requires better explanation. It is essential that there is clarity for planning obligations on strategic sites, such as LG1, without this these sites will be delayed or not come forward.