Response - Community Infrastructure Levy

Our key areas of concern are:

·         That there is no clear proposal for an exemption or significant discount from CIL for affordable housing

·         The possible negative impact of CIL on the delivery of affordable housing through planning obligations, and the need for affordable housing delivered through section 106 agreements to have first call, ahead of CIL, on developer contributions

·         The lack of a clearly articulated risk management strategy to protect the continued delivery of affordable housing through planning obligations.

Shelter, along with the National Housing Federation (NHF) and the Chartered Institute of Housing (CIH), has consistently highlighted concerns about the possible negative impact of CIL on the delivery of affordable housing and advocated for protections to be built into both the Planning Act and CIL regulations.

We remain concerned that, despite Shelter, the NHF and the CIH actively seeking to resolve numerous issues over the last 18 months, the consultation document does not outline clear proposals on the application of CIL to affordable housing. This is especially disappointing given the intention that the CIL regulations will come into force by 6 April 2010, which will give only a limited period of time between the end of the consultation and finalising the regulations to address these outstanding issues.