09 Jun 2023

CIH submission to the Infrastructure Levy Consultation

CIH have now submitted our response to the government’s consultation on the Infrastructure Levy (IL) proposals. Our response follows a consultation survey and roundtable event with members, and sets out CIH's concerns with the Infrastructure Levy and its application to affordable housing.

Hannah Keilloh, planning policy lead, provided this summary of our consultation response:

"The current s106 system is not perfect, and we welcome the government’s ambition to make the process clearer for all and ensure that there is less scope for the evasion of contributions on viability grounds, however, we have multiple concerns around the Levy proposals.

"Our primary concern is that Levy could lead to a reduction in much needed truly affordable homes, particularly social rented homes. The proposals could also have implications for the onsite delivery of affordable homes and the important creation of mixed communities. Proposals around the use of IL receipts to fund needs unconnected to the development risks the funding for affordable housing and infrastructure being used to finance other priorities and to ‘plug gaps’ in much stretched local authority budgets.

"The Levy in its current form seems unlikely to support the government’s own ambitions to ‘level up’ the country, and this could be particularly pronounced in locations with low land values, where affordable and social housing need can be acute and the need to ‘level up’ most urgent. Rather than providing a simpler system, the proposals add layers of complexity and could create significant burdens on already stretched local planning authorities.

"At this time of critical housing emergency and given the crucial role s106 plays in delivery genuinely affordable homes (particularly social rented homes), we would like to see the government exploring opportunities to improve the current s106 system rather than investing huge time and resources in the proposed Levy."