Open Letter from Chamber to the Environment Officer & his Response
Wednesday 21 December 12:00
Chamber has sent an open letter to the Environment Minister re proposed Community Infrastructure Levy (CIL),
First of all I would like to thank you for attending our Building & Development Committee meeting on Wednesday 9th November 2016, to update the committee and discuss the proposal of a Community Infrastructure Levy (CIL).
Chamber is always encouraged by the willingness of government Ministers to engage with our committees and we were very reassured to hear from you, that if your consultation and subsequent CIL report proves that such a levy is not viable, then you will not seek to pursue it as policy for Jersey.
As part of your investigation, we would like to suggest that your research thoroughly examines the potential negative impact any such levy is likely to have on local development and the wider island economy, as we believe CIL has the potential for far reaching negative effects that will be felt outside the construction industry.
Following on from our meeting with you, the committee has a number of serious concerns regarding CIL, which are outlined for you below:
- CIL, despite being called a ‘levy’ is in fact another tax for Jersey, specifically the construction industry
- A tax for every development and construction project, whether a private individual or commercial property owner is increasing the size of their build or making use of additional land.
- A tax that will be inconsistently administered, with varying rates depending on each properties location, with countryside sites taxed at a higher rates than town.
- A tax which is complex and will generate additional administrative burdens and confusion, as a Planning Obligation Agreement (POA) will still have to remain in place for areas where a site specific improvement is required.
- An additional tax, on top of planning fees, planning requirements, parish requirements, HSPC, POA’s, new insulation standards, repeated appeals, additional legal fees and changes to plans.
- A tax that will stop development. Property owners and developers will only look to develop a site if the project is financially viable. An additional tax, which further erodes at profit margins will be the tipping point of work going ahead or not.
While the committee acknowledge the Minister is considering CIL, in order to raise money to improve areas of St Helier, we feel it is unfair to simply tax one sector of the economy when our capital is used by everyone. Surely improvements for town, should be funded from a central infrastructure pot, not home or land owners or developers who wish to make changes to their existing property.
We would strongly advise that your department thoroughly research similar schemes which the UK government had previously considered and who have subsequently dismissed them, due to similar concerns we have listed above.
As I mentioned at the start of this letter, the committee are encouraged by your reassurance that CIL is not a fait accompli and that should your consultation and CIL report prove that such a levy is not viable, that you will not seek to pursue it as policy for Jersey. To be clear the Jersey Chamber of Commerce, Building & Development Committee would strongly recommend you do not introduce this policy in Jersey.
We look forward to hearing from you once your CIL report is published.
On behalf of Jersey Chamber of Commerce Building & Development Committee.