Joint infrastructure delivery plans and CIL - Public forum - Planning Advisory Service (PAS)

I am working with the Greater Norwich Development Partnership (3 districts and county) www.gndp.org.uk. We have a joint core strategy and a joint delivery plan (the LIPP) and have identified "joint" i.e. strategic infrastructure. We are consulting (jointly) on 3 separate charging schedules as the regs require. In terms of evidence to support the schedules, the genuinely strategic nature of significant elements of the infrastructure and the overall scale of the bill means that apportionment of the strategic infrastructure has not been a major issue. Apportionment related to delivery will require ongoing joint management.

Thanks for that Phil. Your arrangements are much better than ours as we have no joint committee, the two core strategies are separate (and at different stages of progress) and we must have two separate charging schedules, which is where my difficulties arise. Apportioning the strategic infrastructure from the joint infrastructure delivery plan for the purposes of drawing up the councils CIL infrastructure lists is not straightforward as all the strategic allocations and the infrastructure required to serve them are interdependent.

Brian I appreciate your situation' there ought to be national guidance on this as authorities are rightly being encouraged to cooperate on infrastruture delivery as many projects are likely to have wider than single District significance. However the main message coming out of CLG on CIL is keep it simple. You need to demonstrate a funding gap which is not usually difficult. Central Lancashire is three Districts working together with County Council involvement. We are splitting our IDS into 3 district level parts for those projects which are only located in one district plus a pan-CL list for schemes (transport ones) which span more than one district. All show a funding gap so that aspect of the job is fulfilled. I suggest you simply base your work on the actual infrastructure locations, you can revise your funding priorities at any time in the future without having to consult.

Julian I fully agree about the need for national guidance as many projects are likely to have cross boundary significance but this may be a vain hope in this the new age of localism. It's more likely the case that we are going to have to work things out for ourselves. Thank you for your suggested approach, which is helpful. To make sure I am understanding correctly however, are you saying that you will make no attempt to apportion pan-CL infrastructure and to simply produce the pan-CL list alongside the three districts' lists at their CIL examinations as part of their evidence base? Is the thinking that providing the districts' lists show a funding gap that will be sufficient? The pan-CL list will comprise further evidence for the examiner that there is additional infrastructure on top of that identified in the district lists which requires funding?

Brian (and everyone else out there!) For examination evidence we may need to notionally apportion the pan-CL funding gap and show the effect this would have when the apportionments are added to the relevant individual districts' funding gaps. Although there will be a need to have three separate examinations it would clearly make sense for them to be held at around the same time by the same examiner so that it is clear to that person how the jigsaw will fit together. But the wider point is that it may make little difference whether the funding gap is 'large enough' or even larger to the final charge rates set. I appreciate the need to have an 'appropriate balance' between charge rates and meeting the funding gap but the rates can only go as high as viability allows.

I'[m taking a similar approach to Lancashire. I'm preparing a county infrastructure plan that sets out strategic projects (such as education, waste, flood risk). Where possible I have identified which district(s) those projects relate to. The district councils are preparing their own IDPs which will combine the strategic projects from the county plan, with their own local projects (such as open space, community centres, leisure facilities) to identify the overall funding gap. There are also county-wide projects that I haven't apportioned to individual districts (e.g. highways). I suppose the difficulty I have is deciding an equitable way of apportioning the costs. It's not always possible to pinpoint the location of a project especially if it's a road that crosses lots of boundaries, or to say exactly which areas are going to benefit. A simple equal split or some sort of weighted split based on area or population or proposed housing numbers doesn't seem fair either. For the purposes of the CIL examination, I think we just need to show the Inspector what the funding gap is for projects specifically relating to that district. I think it's important to identify the county-wide projects, because they are often the most costly and shouldn't be left of the Regulation 123 list, but at the examination, they will just serve to show that even more funding is required on top. As Julian has said, the actual level of the funding gap is really quite irrelevant, because in line with the regs, the level of CIL will need to be adjusted to account for viability (or lack of), even if that means the full cost of infrastructure is not met.

Thank you both for your helpful comments. I am waiting for a reply to the enquiry on this subject which I have made to DCLG. I will post it when (and if) I get it. If there is anyone else with something to contribute please do so in the meantime for the benefit of all.