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Object

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Representation ID: 200273

Received: 24/01/2025

Respondent: Abbey Properties Cambridgeshire Limited

Representation Summary:

The contribution is to be sought from all residential developments, mixed-use and major commercial developments. There is no stated formula for commercial developments. Applying a contribution to non-major housing schemes is considered to be inappropriate. This will delay planning applications and undermine delivery of schemes. The requirement should only apply to major housing proposals.

Full text:

The contribution is to be sought from all residential developments, mixed-use and major commercial developments. There is no stated formula for commercial developments. Applying a contribution to non-major housing schemes is considered to be inappropriate. This will delay planning applications and undermine delivery of schemes. The requirement should only apply to major housing proposals.

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Representation ID: 200283

Received: 24/01/2025

Respondent: Savills UK

Representation Summary:

Please see attached document for representations on behalf of Pigeon.

Full text:

Please see attached document for representations on behalf of Pigeon.

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Representation ID: 200314

Received: 24/01/2025

Respondent: Home Builders Federation

Representation Summary:

It is important that the Council has robust evidence to demonstrate that the contributions proposed in this SPD are necessary and directly related to the development. The HBF considers that in order for this policy to function it will be important that the Council has detailed evidence about the community facilities that are already available in the Greater Cambridge area, and their current capacity to meet local community needs. The HBF also considers that if provision is provided on-site, for one form of community facility that the Council will not seek provision for further facilities.

Full text:

This section of the SPD is based on Policy 85 of the Cambridge Local Plan and Policy SC/4 of the South Cambridgeshire Local Plan. The SPD states that all new residential developments are to make provision for community facilities to meet the needs arising from the development proposal. It goes on to state that proposals for sites of 200 or more dwellings are required to provide detailed assessments and strategies regarding community needs and how they will be met. It states for smaller developments where facilities are not delivered on-site, contributions may be required to address the needs generated by a new development. The SPD then sets out a contribution cost per dwelling from £789.63 for 1-bed dwellings to £2,092.84 for 4-bed+ dwellings. Finally, the SPD suggests that extra care housing and residential nursing homes will not normally be required to contribute towards community facilities, but this will be assessed on a case-by-case basis and that applications comprising retirement accommodation will be required to pay contributions in full.

The HBF generally supports the retention, enhancement and provision of community facilities to support local community and residents of new homes. However, it is important that the Council has robust evidence to demonstrate that the contributions proposed in this SPD are necessary, directly related to the development and reasonably related in scale to the development. The HBF considers that in order for this policy to function it will be important that the Council has detailed evidence about the community facilities that are already available in the Greater Cambridge area, and their current capacity to meet local community needs. The HBF also considers that if provision is provided on-site, for one form of community facility that the Council will not seek provision for further facilities.

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Representation ID: 200351

Received: 24/01/2025

Respondent: Jaynic

Representation Summary:

The SPD states that all new residential, mixed-use, and major commercial developments are to make
provision for community facilities to meet the needs arising from the development proposal.

Large scale commercial developments (above 5,000m2) will be required to consider how the needs of
their workers and visitors will be met for social and leisure facilities. If the need cannot be met though
existing or additional onsite facilities an offsite contribution to address the impact on facilities is
necessary and will be sought.

Jaynic are of the opinion that with regards to commercial development, community facilities should be
on a case-by-case basis, particularly as in some locations there are already other facilities which can
be utilised by new occupiers, and providing additional such space could jeopardize the sustainability of
the existing facilities. Jaynic also query how Greater Cambridge are determining the quantum of offsite contribution for commercial units, there is no table with figures like there is for residential.

Full text:

Please find attached our representations regarding the Planning Obligations SPD Consultation which ends at 5pm today.
You will see from our comments that we have raised a number of matters pertaining particularly to commercial development and would be more than happy to assist the Planning Policy Team going forward if required.

Attachments:

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Representation ID: 200360

Received: 24/01/2025

Respondent: Vistry Strategic Land and Major Projects

Agent: Turley

Representation Summary:

We note that the SPD sets out a requirement for applications of more than 200 dwellings to provide detailed assessments and strategies on community needs. This is a policy requirement in South Cambridgeshire within Policy SC/4, however the SPD extends this to Cambridge where a similar policy requirement does not exist.

The estimated costs appear to be based on the following (extracted from paragraphs 7.26-7.28 of the SPD):
• The South Cambridgeshire Local Plan 2018 sets a standard of 111m2 per 1000 population.
• The cost of providing community centres is £4,020 per m2 as a starting point for calculating developer contributions
• The cost associated with maintaining (utilities, decoration, services, etc) community facilities is £117.57 per m2.

Aside from the first point, the SPD has not set out the source of these costs and whether the costs indicated are representative of both Councils’ areas where construction costs and land values may vary between the two. It is noted that other contributions (such as the Indoor Sport contribution commented below) do differentiate between the two areas. Moreover, while the South Cambridgeshire Local Plan does set a quantum of floorspace required, it does not set out how this would translate to how a potential contribution would be calculated and therefore would not have been subject to viability testing.

Full text:

On behalf our client Vistry Strategic Land, please find attached our representations to the current Planning Obligations SPD consultation.

Attachments:

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Representation ID: 200368

Received: 24/01/2025

Respondent: University of Cambridge

Representation Summary:

Paragraph 7.22 states that funding for Community Workers could be required. While we
understand that for very large developments a community co-ordination role can be valuable
as part of the stewardship strategy in early phases; the paragraph then goes on to suggest this
role could include youth workers or health workers.

While a community co-ordinator may indirectly have some role to play in supporting young
people or the health of the community, the specific role of a youth worker or health worker is
specialist and quite different from a general community development role – and is not a
planning matter. This is raised again in paragraph 8.13 – the funding of mental health, domestic
violence prevention etc are not planning matters and it is not practical or appropriate for those
services to be delivered by or funded by an individual development/developer. These references should be removed from the SPD

Full text:

Please find attached a response from the University of Cambridge to the Planning Obligations SPD consultation.

Attachments:

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Representation ID: 200396

Received: 24/01/2025

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

Agent: Carter Jonas

Representation Summary:

Paragraph 7.18 states that the starting point for the negotiation of faith space is 0.5 hectares or heavily discounted land per 3,000 dwellings. U+I (Cambridge) Limited and Cambridge 4 LLP consider this requirement should be based on an identified level of need in a geographical area, rather than an arbitrary standard requirement. It is also unclear how the 0.5 hectare figure has been derived and evidenced, and if the use of this obligation would make a development acceptable in planning terms.

Paragraph 7.19 uses the terminology 'pump priming contributions'. What this is and how it is applied to development should be explained in the supporting text or glossary.

Paragraph 7.22 where it states "Community Support Workers could be required to address a range of issues" There appears to be no evidence to support this obligation. The obligation should be reviewed and justified against criteria set out in Regulation 122.

Full text:

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: 200457

Received: 23/01/2025

Respondent: Hill Residential Ltd (Hill)

Agent: Tor & Co

Representation Summary:

Hill has concern with the approach set out in paragraph 7.22 that the obligations for community facilities within large scale phased schemes could include temporary ‘meanwhile uses’. Hill recommend adding the following wording: “Where a need is identified planning obligations may be sought, subject to viability and in accordance with paragraph 58 of the NPPF, including: Meanwhile uses…”. This will ensure any obligations of this nature align with the requirements of national policy and are necessary, directly related to development and fair and reasonable in scale and kind

Full text:

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: 200458

Received: 23/01/2025

Respondent: Hill Residential Ltd (Hill)

Agent: Tor & Co

Representation Summary:

The South Cambridgeshire Local Plan (2018) sets a standard of 111m2 per 1,000 people for contributions towards community facilities. This equates to 0.111m2 per person, so 1m2 would support 10 people (rounded up from 9.009). The cost of provision of a community facility is identified in the SPD as £4,020 per m2 and the maintenance cost is identified as £117.57 per m2 (it is unclear if this is per year or total cost, it is assumed to be the latter). Therefore, the total cost to provide 1m2 of community space is £4137.57, which would equate to £413.76 per person. For a 1-bed property with an assumed population of 1.23 people (average occupancy set out in Appendix A) this would give a contribution of £508.92. It is therefore unclear how the value of £789.63 set out in the table after paragraph 7.28 has been reached.

Full text:

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: 200566

Received: 24/01/2025

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

Agent: Carter Jonas

Representation Summary:

Paragraph 7.23 where it states “Small grants scheme (community chest): A contribution, to be agreed, will be required for the development of community grants or an investment fund to support local residents of the new development". We consider this to be a broad requirement and again recommend that further evidence is provided.

Paragraph 7.27 states the cost of community centres as well as the costs associated with maintaining. It is unclear how these figures have been derived, what comparable schemes have been used and how these costs have been calculated in relation to specification. Same comments apply to figures in the community contribution by dwelling size table.

Full text:

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: 200573

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

Representation Summary:

Paragraph 7.18- states the starting point for the negotiation of faith space is 0.5 hectares of free or heavily discounted land per 3,000 dwellings. The evidence base for this dates back to 2008 and therefore we suggest that this in not likely to represent the most up to date guidance. It is also considered that this requirement should be based on on an identified level of need in a geographical area rather than an arbitrary requirement.

Paragraph 7.19- the terminology 'pump priming contributions' should be explained in the supporting text.

Paragraph 7.22- Is a broad requirement and there appears to be no evidence to support such an obligation. CLP policy 73 does not mention community support workers. Therefore, the necessity of this obligation should therefore be reviewed and justified against the criteria set out in Regulation 122.

Paragraph 7.23 - Regarding small grants schemes, it is considered that this is a broad requirement that may not be specific to mitigating the effects of a development on a particular site. Evidence for the planning obligation does not appear to be contained within adopted policy wording.

Paragraph 7.27- states the cost of providing and maintaining community facilities. It is unclear how these figures as well as community facilities by dwelling size table have been derived.

Full text:

Dear Sir / Madam,

Here are some representations in respect of the above reference consultation draft SPD’s submitted on behalf of the following named clients:
• TLC Group
• Rockley Dene Homes Ltd
• The Fellows House Ltd
• SPK Residential Cambridge Ltd
• London Inn Hotels (Cambridge) Ltd

Yours faithfully

Colin Brown

Colin Brown MRTPI
Partner, Head of Planning & Development