Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200155
Received: 29/11/2024
Respondent: Mr Mark Colville
Whilst the need for more housing, and therefore a desire to streamline planning applications, is understood, it is important to ensure that standards and level of scrutiny are not inappropriately reduced. In addition to schemes within Cambridge City, schemes like Northstowe make sense. Shoe-horning additional houses onto the fringes of existing villages, particularly where this involves developing green belt land, creating access and wider transport issues or increasing flooding risk (in the context of severe and immediate climate change) to existing properties absolutely does not. Even a streamlined planning application process should take due account of these facts.
Whilst the need for more housing, and therefore a desire to streamline planning applications, is understood, it is important to ensure that standards and level of scrutiny are not inappropriately reduced. In addition to schemes within Cambridge City, schemes like Northstowe make sense. Shoe-horning additional houses onto the fringes of existing villages, particularly where this involves developing green belt land, creating access and wider transport issues or increasing flooding risk (in the context of severe and immediate climate change) to existing properties absolutely does not. Even a streamlined planning application process should take due account of these facts.
Support
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200175
Received: 08/01/2025
Respondent: Cambridge Past, Present and Future
We are supportive of this SPD for the reasons set out in paragraph 1.3
We are supportive of this SPD for the reasons set out in paragraph 1.3
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200189
Received: 15/01/2025
Respondent: National Highways
We have reviewed the document and note that the details set out within the document are unlikely to have an severe impact on the operation of the trunk road and we offer No Comment.
Dear Sir/Madam,
Thank you for consulting us on the abovementioned document.
As you may be aware National Highways (formerly Highways England) is a strategic highway company under the provisions of the infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). As such we have responsibilities for managing the SRN in accordance of our licence and in general conformity with the requirements of the Highways Act 1980 and to satisfy the reasonable requirements of road safety.
It is noted that once adopted, this SPD will become a material consideration in the determining of planning applications. Where relevant, National Highways will be a statutory consultee on future planning applications within the area and will assess the impact on the SRN of a planning application accordingly.
Notwithstanding the above comments, we have reviewed the document and note that the details set out within the document are unlikely to have an severe impact on the operation of the trunk road and we offer No Comment.
Kind regards,
Philip Porter
Assistant Spatial Planner
Operations (East) | National Highways
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200225
Received: 22/01/2025
Respondent: Cambridge University Hospital NHS Foundation Trust
Agent: Mr Michael Hendry
We ask that the Planning Obligations SPD is left suitably flexible to allow contributions to be sought from a broader spectrum of healthcare impacts, recognizing we have not yet established a defined methodology.
In recognition of the above need to look at all forms of health infrastructure it is proposed that the definition is considered in its widest form as part of the SPD. We acknowledge that contributions could only be sought based on a robust evidence base and a clear method of calculation for any financial contributions, or on-site provision sought. Our intention is to develop this framework during 2025.
See attached letter
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200277
Received: 24/01/2025
Respondent: Savills UK
Please see attached document for representations.
Please see attached document for representations.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200311
Received: 24/01/2025
Respondent: Home Builders Federation
HBF is concerned about the use of this SPD to introduce additional financial burdens on a planning application. As they do not form part of the development plan, they cannot introduce new planning policies into the development plan.
The HBF is also concerned that this SPD is being introduced without the full consultation and examination that would have been given during the examination process, as would be befitting a new policy approach. PPG is clear that it is not appropriate for plan-makers to set out new formulaic approaches to planning document, as these would not be subject to examination.
The HBF considers that greater flexibility should be included within the SPD, this may include in relation to viability, scale of evidence required.
The HBF is concerned about the use of this SPD to introduce additional financial burdens on a planning application. It should be noted that PPG (ID: 61-008) states that ‘Supplementary planning documents (SPDs) should build upon and provide more detailed advice or guidance on policies in an adopted local plan. As they do not form part of the development plan, they cannot introduce new planning policies into the development plan. They are however a material consideration in decision-making. They should not add unnecessarily to the financial burdens on development.’
The HBF is also concerned that this SPD is being introduced without the full consultation and examination that would have been given during the examination process, as would be befitting a new policy approach as is set out in this note. The HBF do not consider that this is appropriate and do not consider that the SPD should be taken forward at this time. The PPG is clear that it is not appropriate for plan-makers to set out new formulaic approaches to planning obligations in supplementary planning documents or supporting evidence base documents, as these would not be subject to examination.
The HBF notes that the SPD covers a significant number of potential planning obligations, and that cumulatively, they could have a significant impact on the deliverability and viability of development. Whilst introducing a significant level of additional evidence and strategies to support applications, which will not only add additional cost, but also significant time resource for both the applicant and those involved in the determination of the application. The HBF considers that greater flexibility should be included within the SPD, this may include in relation to viability, scale of evidence required, or in relation to which elements are provided on-site or off-site.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200338
Received: 23/01/2025
Respondent: Historic England
Please see attached Historic England’s response to the Planning Obligations SPD.
Please see attached Historic England’s response to the Planning Obligations SPD.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200342
Received: 24/01/2025
Respondent: Central Bedfordshire Council
Please find attached Central Bedfordshire Council’s response to the draft Planning Obligations SPD.
Please find attached Central Bedfordshire Council’s response to the draft Planning Obligations SPD.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200366
Received: 24/01/2025
Respondent: University of Cambridge
Overall, the use of “per bedroom” obligations is unhelpful. There is a significant difference between the population yield per bedroom for different tenures and types of housing; and even more so for specific specialist housing that could be associated with the University, its students
and workers. There is some acknowledgement of this in the draft but a clear statement should be included to this effect.
In general, it is more appropriate to have a per population estimate of demand – which can be adapted to the specific circumstances of a development.
Please find attached a response from the University of Cambridge to the Planning Obligations SPD consultation.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200393
Received: 24/01/2025
Respondent: U+I (Cambridge) Limited and Cambridge 4 LLP
Agent: Carter Jonas
U+I (Cambridge) Limited and Cambridge 4 LLP support the purpose of a Planning Obligations SPD to provide
supplementary planning guidance on planning obligations required to secure infrastructure necessary to
support the needs generated by proposed developments. The draft SPD’s aim to provide greater transparency
on the types of planning obligations that may be applicable to new development is fully supported. However, the exact nature of some contributions and how certain financial contributions are calculated and justified, is questioned.
On behalf of our client, U+I (Cambridge) Limited and Cambridge 4 LLP, please find attached our formal Representations to the Draft Greater Cambridge Planning Obligations Supplementary Planning Document.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200413
Received: 24/01/2025
Respondent: Fowlmere Parish Council
FPC noted that there was some suggestion that in some cases heads of terms would suffice and the s.106 agreement could be prepared after the resolution to grant. FPC strongly suggests that the circumstances in which heads of terms are acceptable should be very limited, closely circumscribed and confined to the very largest developments.
FPC is also concerned at failures to monitor the progress of developments. FPC urges SCDC to put fully effective monitoring and enforcement measures in place to ensure that benefits and infrastructure are not lost or delayed.
Please find attached Folwmere Parish Council's response to the Draft Greater Cambridge Planning Obligations Supplementary Planning Document.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200436
Received: 24/01/2025
Respondent: Mr Howard Felstead
It is crucial that the SPD makes clear that no planning obligations may be sought in relation to a particular proposed development pursuant to Chapters 4-23 of the SPD unless they are fully justified in accordance with Regulation 122 and paragraph 58 of the NPPF.
Please see attached comments on the draft SPD.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200437
Received: 24/01/2025
Respondent: Mr Howard Felstead
The drafted SPD does not appear to give sufficient emphasis to paragraph 58 of the NPPF. To avoid the risk that the SPD is followed without proper consideration of the legal and policy tests, it would be beneficial for the SPD to state that it is not appropriate to seek any of the planning obligations referred to within it other than to the extent that they satisfy the requirements Regulation 122.
Please see attached comments on the draft SPD.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200456
Received: 23/01/2025
Respondent: Hill Residential Ltd (Hill)
Agent: Tor & Co
The SPD seeks to follow guidance in the PPG, in particular, paragraph 004 (23b-004-201901) which states that policies on planning obligations should be informed by evidence and that it is not appropriate to set out formulaic approaches to planning obligations in supplementary planning documents. Hill welcomes this approach and the SPD’s confirmation that each application is to be assessed on its merits and only those obligations necessary to make the development acceptable in planning terms will be requested.
On behalf of Hill Residential Ltd (Hill), we have set out in the attached letter a response to the following draft Greater Cambridge Planning Obligations SPD.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200465
Received: 23/01/2025
Respondent: Hill Residential Ltd (Hill)
Agent: Tor & Co
As a general point, it is suggested that all tables within the SPD be given identification numbers.
On behalf of Hill Residential Ltd (Hill), we have set out in the attached letter a response to the following draft Greater Cambridge Planning Obligations SPD.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200530
Received: 24/01/2025
Respondent: University of Cambridge
There is no source provided for many of the costs set out in the document and it would be helpful and transparent for this to be provided. The costs listed need to be explicit about what they include or exclude, for example fixtures, fittings and furniture, so that additional costs are not levied in addition if not required. This appears in some cases but not all.
Please find attached a response from the University of Cambridge to the Planning Obligations SPD consultation.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200535
Received: 16/01/2025
Respondent: British Horse Society
This SPD promotes urban style walking, cycling and wheeling opportunities from which horse riders are excluded but promotes off road access for these groups, often designed to bring cyclists on the inside of horse riders which is contrary to the highway code and impacts negatively on road safety for all users. There is opportunity within this SPD to correct the imbalance and improve the rights of way provision.
Please see attached report.