The Consortium have reviewed the Interim Viability Study (November 2019) and have a number of comments. Of particular concern is the lack of consideration given to strategic-scale sites (i.e. 1000+ dwellings). The largest scale development typology is 600 units, which is significantly smaller than the scale of development proposed on a number of sites, including site GNLP0132, and therefore not a reliable or robust comparator. Furthermore, no allowance is included for the provision of strategic infrastructure on larger sites.

In addition, the timing of the CIL Review is such that any comments regarding viability must be accepted on the basis of the current regime, and the outcome of the CIL Review may have significant implications on viability, and this must be acknowledged by the Councils.