Comment

Representation ID: 200270

Received: 24/01/2025

Respondent: Abbey Properties Cambridgeshire Limited

The monitoring fees in paragraph 2.38 appear excessive with the potential for a 10 unit residential scheme to be faced with monitoring costs of £5,000 which would not be proportionate. Further justification should be provided for these costs - particularly in the context of the substantial planning application fee increases which are due to take place in April 2025.

Comment

Representation ID: 200278

Received: 24/01/2025

Respondent: Savills UK

Please see attached document for representations.

Comment

Representation ID: 200348

Received: 24/01/2025

Respondent: Vistry Strategic Land and Major Projects

Agent: Turley

It is essential that the preparation of this SPD should not fetter or obstruct in any way, the ability of the Local Plan to support sustainable development over the plan period. More fundamentally, we note that the SPD seeks to establish new policy requirements and expectations which are not contained within adopted Development Plan Documents.

This SPD should only provide more detailed advice or guidance on policies in the adopted Local Plans. The SPD should not, as appears to be the case in some circumstances, seek to amend or change the requirements of the adopted Local Plans.

Comment

Representation ID: 200358

Received: 24/01/2025

Respondent: Vistry Strategic Land and Major Projects

Agent: Turley

Neither Council has adopted a Community Infrastructure Levy (CIL) charging schedule, although both have previously consulted on one. Paragraphs 1.18-1.19 of the SPD highlight that the Councils are continuing to review whether CIL should be introduced to support the delivery of the emerging Greater Cambridge Local Plan. If a CIL is introduced, we note that this should not duplicate existing obligations. We reserve the right to comment further on CIL matters if this progresses and we note that future CIL requirements could have further viability implications alongside those highlighted above.

Comment

Representation ID: 200367

Received: 24/01/2025

Respondent: University of Cambridge

Paragraph 2.50 states that viability appraisals should follow a recognised UK professional standard, such as the RICS Red Book. The SPG should instead signpost to Planning Practice Guidance on Viability, as they are specifically designed to address the unique context of planning decisions.

Paragraph 2.54 makes clear the expectation that viability discussions must be concluded to the satisfaction of the LPA before any meaningful negotiations between the applicant and the LPA can commence, and similar expectations are set out in paragraph 4.32. The need for early engagement during the pre-application stage is acknowledged and encouraged, to allow for
matters on housing and viability to be progressed as far as is reasonably practical. However, recognising that there may be matters unresolved / subject to change, this should not prevent an application from being submitted.

Comment

Representation ID: 200394

Received: 24/01/2025

Respondent: U+I (Cambridge) Limited and Cambridge 4 LLP

Agent: Carter Jonas

Regarding paragraph 2.26, U+I (Cambridge) Limited and Cambridge 4 LLP do not consider it reasonable or lawful to link contributions to the date of committee resolution or the consultation date identifying the contribution amounts. It is requested that this sentence is removed from the SPD.

Comment

Representation ID: 200439

Received: 24/01/2025

Respondent: Mr Howard Felstead

In relation to paragraph 2.3. Whilst accelerating the planning process and the negotiation of s.106 obligations has numerous benefits, but the reference to a planning obligation being signed before Committee poses practical difficulties and rather than speeding the process up, may lead to committee meetings being delayed to meet this objective.

Paragraph 2.19 states "planning obligations run with the land, all owners, lessees and mortgagees must be signatories.” This is an oversimplification and often wrong. The appropriate signatories in the context of each particular case are matters for the Councils’ lawyers to advise on. The statement should allow for flexibility.

Comment

Representation ID: 200441

Received: 24/01/2025

Respondent: Mr Howard Felstead

Paragraph 2.39 states "“The base fee of £1,000 is payable within 30 days of completion of the s106 Agreement with the balance due upon commencement of development.” It is not clear why any monitoring fee is due until commencement of development. This requirement should be deleted.

Paragraph 2.40- Interest at five percent above the base rate appears excessive and disproportionate.

Paragraph 2.41- Currently the paragraph is legally incorrect and jumbles together various different statutory power and requirements. Inaccuracies should be addressed to ensure the SPD is legally correct and consistent with statutory requirements.

Comment

Representation ID: 200443

Received: 24/01/2025

Respondent: Mr Howard Felstead

Paragraph 2.68 states “A person against whom an affordable housing requirement is enforceable may apply to the Council for its variation or modification pursuant to s106A.”

This is also legally incorrect and incomplete. Section 106BA provides for modification or discharge of affordable housing requirements by application. Affordable housing requirements may also be varied by agreement under s.106A(1)(a).

Comment

Representation ID: 200571

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

Regarding paragraph 2.26 it is not considered reasonable or unlawful to link contributions to the date of the committee resolution or the consultation date identifying the contribution amounts. It is requested that this sentence is removed from the SPD.

Comment

Representation ID: 200586

Received: 24/01/2025

Respondent: Cambridgeshire County Council

It would be good to see climate change and carbon embedded throughout the chapters, as a reminder to developers that delivery of any planning obligations must adhere to the relevant policies in the Local Plans (such as Policy 28 & 29 from the Cambridge Local Plan and CC/1 and CC/3 from the South Cambridgeshire Local Plan).

The County Council welcomes that the SPD references digital connectivity in existing local plans, however stronger digital connectivity proposals, particularly around mobile connectivity could be implemented through the SPD.

We welcome the inclusion of biodiversity and public open space within this document, particularly the explanation of how planning obligations will be used to secure biodiversity net gain. The use of planning obligations to delivery public open space will be important for both health & wellbeing and reducing visitor pressures on existing wildlife sites.