(Update 6th November: I have received the Development Pipeline Analysis commissioned from EY.)
Fingal’s Development Contribution Scheme is up for review. There are some significant decisions to be taken. I will be arguing for us to end an exemption which favours car parking over housing, and to do what we can to facilitate shared spaces, communal, social and cultural facilities.
A Development Contribution Scheme sets out the rate of development contribution levied on new developments to (partially) fund the infrastructure that enables the developments. A draft was brought to the full Council last week, but we didn’t have time to get into the details of it. It is based on an analysis by EY, which also hadn’t been circulated.
In addition to seeking the EY report and any other relevant background information, I have asked for answers to the following questions in order to prepare a response to the public consultation. I will make a more detailed submission when I have the necessary information.
- Why is it proposed to apply differential rates for residential and commercial development? What would be the rate if we were to apply the same rate to both types of development with a view to raising the same total revenue from the forecast development?
Background: We are proposing a higher rate for residential than for commercial. South Dublin does the same. Dublin city has it the other way around, with a higher rate for commercial. Dún Laoghaire Rathdown, Kildare and Meath apply the same rate. My initial thought is that with the need for additional housing, we should consider applying the same rate.
- What is the rationale for the proposed car parking exemptions? If car parking was not exempted, what would be the impact on total revenue?
Background: Effectively, the draft, which is also the current rule, favours car parking over housing. We’re charging developers less when they provide car parking spaces than when they provide space for people. This makes no sense. We should include car parking spaces in the development contributions and set the rate accordingly, bringing down the rate per m2 for housing and making car parking get closer to paying its own way. My Green colleagues on Dublin City Council got part of the way there in the last revision of their development contribution scheme, with commercial car parking paying a full development contribution and residential paying 25%.
- Dublin City Council doesn’t include within the gross floor area of multi-unit residential buildings the following: “common circulation areas, bin and bicycle storage areas and ancillary uses solely for residents.” Am I correct that our draft does include those in the calculations? What would be the average reduction in contribution per apartment if we used the same basis for calculation as Dublin City Council? What would be the impact on total revenue?
Background: There’s a strong argument for helping the affordability of apartments and the quality of apartments by exempting these essential ancillary spaces. As with other changes, we should vary the rate to achieve the same overall revenue take.
- What would be the impact on total revenue if we were to include “Communal, social and cultural facilities associated with a housing development” within the exemptions?
Background: These important amenities, being the sort of infrastructure we spend development contributions on, shouldn’t have to pay levies.
- Why is the rate for renewable energy above 0.5MW the same as in the 2021 scheme? Is it correct that this rate was not index-linked in the previous scheme and is not index-linked in the current scheme? What would be the rate and the impact on total revenue we were to now index-link it from the 2021 baseline?
Background: I’m a bit surprised that other rates are being updated in line with construction inflation and these haven’t. Renewable energy infrastructure is vital, but it can pay its fair share of infrastructure costs.
- Noting that Dublin City Council exempts cost rental housing, why is it proposed to not exempt cost rental housing? What would be the impact on total revenue if cost rental were to be exempted?
Background: I simply don’t understand why two authorities should approach this differently, or why cost rental should be different to other publicly owned housing, i.e. social housing. The money to build all types of public housing ultimately comes from central government; is there a central government fund to replace the money lost to councils by exempting this housing? In a worst-case scenario, do we risk underfunding infrastructure in local authorities where we provide a lot of social and cost-rental housing?
- What is planned or under consideration as regards s.49 Development Contributions in areas to be served by Metrolink?
Background: S. 49 of the Planning Act allows for special development contributions schemes for major infrastructure like the metro. There was a s.49 Development Contribution Scheme for the previous metro proposal but it was abandoned and the money refunded when the project didn’t proceed. Now that a new version has planning approval, it seems obvious that we should be funding it from the uplift in land value it creates in its vicinity.