3.7.1
Savills has made separate representations on this table as part of the CIL Charging Schedule and therefore we seek changes to be made to the CIL requirements in accordance with such representations and these to be carried through into future versions of this document.

In addition however, a number of the items mentioned within the table are considered unreasonable. Public Art should not be referenced. The NPPG (2014) specifically refers to public art as

"clearly not necessary to make a development acceptable in planning terms" (NPPG Ref ID:23b-004-20140306).

It is therefore strongly advise that the City Council should remove reference to Public Art in Table 1. Public art, whilst possibly desirable, cannot be said to meet the tests in CIL Regulation 122 and cannot therefore be funded through S106.

The table includes city wide public art as being funded through CIL. Public art does not fall within the statutory definition of infrastructure in S216 of the Planning Act 2008 and therefore can not be funded through CIL. Given the identified infrastructure deficit, we also consider it would be bizarre to use scarce funds to deliver public art when other more important infrastructure items meeting the tests should be more of a priority

The document simply states which items fall within which category (Obligations/ Conditions or CIL), but does not give any indication of how this will be achieved in practice. In 1.1.2 the purpose of the document is set out as to clearly set out the Council's approach, policies and procedures. It is not considered that due weight has been given to the approach and procedures in this section to avoid double counting and overlap contrary to Regulation 122 of the CIL regulations and the NPPF (para 204).