It would be useful to provide a definition of commercial developments so that NHS clinical development with ancillary commercial components are not unintentionally captured or treated in the same way as offices or research and development facilities.

Paragraph 15.6, final sentence to read “This strategy will be kept up to date and provision should take account of the most up to date version.”

Please see attached document for representations on behalf of Pigeon.

These contributions appear to be a 'double dip' as the home occupier then has to pay to use the new or improved facilities. These facilities are commercial enterprises as it is not a developers fault if the facility has not been improved or extended. There may be some justification for contributions from larger strategic scale schemes. This would further jeopardise small and medium scale developments.

This section of the SPD is based on Cambridge Local Plan Policy 68 and South Cambridgeshire Local Plan Policy SC/4. This SPD suggests that planning obligations will be sought from all residential development, it suggests that on-site provision is only likely to be required in the largest forms of development. Off-site contributions will be guided by the Sports England Facilities Calculator, and the SPD sets out a contribution per house based on the number of bedrooms, with slightly differing costs in Cambridge and South Cambridgeshire but ranging from £276.75 to £769.36 for swimming contributions and £227.55 to £726.98 for Indoors Sports Hall contributions.

Draft Greater Cambridge Planning Obligations Supplementary Planning Document

Thank you for consulting Sport England on the above.

As I am sure you are aware, Sport England has an established role within the planning system which includes providing advice and guidance on all relevant areas of National and Local Planning Policy as well as supporting Local Authorities in developing their evidence base for sport facilities.

Sport England aims to ensure positive planning for sport and creating opportunities for physical activity by enabling the right facilities to be provided in the right places based on robust and up-to-date assessments of need and strategies for all levels of sport and for all sectors of the community. To achieve this aim our planning objectives are to PROTECT sports facilities from loss as a result of redevelopment, ENHANCE existing facilities through improving their quality, accessibility and management and to PROVIDE new facilities that are fit for purpose and meet demands for sport participation and physical activity now and into the future. You will also be aware that Sport England is a statutory consultee on planning applications affecting playing fields. Further detail on Sport England’s role and objectives within the planning system can be found at https://www.sportengland.org/guidance-and-support/facilities-and-planning/planning-sport

Sport England has considered the Draft Planning Obligations Supplementary Planning Document (SPD) in light of these planning objectives and Sport England have the following comments:

Chapter 14: Public Open Space

Outdoor sports facilities are sought based on a standards approach of which Sport England are not supportive of. Reason being is this approach does not reflect the nuances of playing pitch/field provision, for example it does not explain what playing pitch provision should be provided, it could result in playing pitches/fields too small meet the needed playing pitch provision to mitigate the impact of the development and could have implications for maintenance costs. Sport England however recognises that a standards approach was adopted as part of the Cambridge Local Plan and the South Cambridgeshire Local Plan. The open space and recreation standards set out within the SPD are reflective of those within the Cambridge Local Plan and South Cambridgeshire Local Plan.

In terms of on-site provision, paragraph 14.16 of the SPD outlines that the provision of on-site outdoor playing pitches should be made with regard to the most recently adopted Greater Cambridge Playing Pitch Strategy. The existing Playing Pitch Strategy, adopted in 2016 and updated in 2019, is now considerably outdated. Consequently, the SPD would fail to accord with paragraph 103 of the NPPF because the SPD would not be ‘based on robust and up-to-date assessment of the need for… sport… and opportunities for new provision. Information gained from the assessments should be used to determine what open space, sport and recreational provision is needed, which plans should then seek to accommodate.’ Should an applicant dispute the data in the adopted Playing Pitch Strategy, such figures would be deemed outdated. Sport England suggests that text should be incorporated under the subheading for outdoor sports, similar to the guidance provided for indoor sports in paragraph 15.10, informing applicants that an updated Playing Pitch Strategy is set to be adopted in due course.

Sport England has tools that could assist the Council in determining an appropriate level of contribution based on the needs generated from a development. An estimate of the demand generated for outdoor sports provision can be provided by Sport England’s Playing Pitch Calculator strategic planning tool. Team data from the Council’s sport facility strategy can be applied to the Playing Pitch Calculator which can then assess the demand generated in pitch equivalents (and the associated costs of delivery) by the population generated in a new residential development. It can also calculate changing room demand to support the use of this pitch demand. Sport England therefore recommends text is included under the subheading outdoor sports facilities, advising that a Playing Pitch Strategy is due to be adopted, and the data within those documents should be inputted into Sport England’s calculators to determine onsite/offsite contributions. In doing so, this would ensure the contributions sought are based on robust and up-to-date assessments in accordance with Paragraph 103 of the NPPF. In addition, Sport England calculate facility costs quarterly using estimates of what it typically costs to build sport facilities, including fees and external work. This can be found at https://www.sportengland.org/guidance-and-support/facilities-and-planning/design-and-cost-guidance/facility-cost-guidance

In terms of off-site provision, it is unclear how the capital costs in the SPD have been calculated. A footnote, or explanation, should be provided to ensure it is transparent and clear how these calculations have been equated. Notwithstanding this, as advised above, Sport England recommends our Playing Pitch Calculator is used to calculate costs based on an updated Playing Pitch Strategy.

Chapter 15: Indoor Sports, including Swimming

Indoor sports facilities are sought based on a standards approach of which Sport England are not supportive of for the reasons explained above for indoor sports. Sport England recognises that a standards approach was adopted as part of the Cambridge Local Plan and the South Cambridgeshire Local Plan. The standards set out within the SPD are reflective of those within the Cambridge Local Plan and South Cambridgeshire Local Plan.

Sport England welcomes the inclusion of paragraph 15.10, which advises an update of the study is being undertaken. Sport England advises that the following text, highlighted in red below, should be added as a caveat following paragraph 15.15.

‘The costs of contributions are guided by the Sport England Facilities Calculator and may be subject to change’.

Sport England Final Comments

Sport England advises that the draft Playing Pitch Strategy and Built Facility Strategy should be completed and formally adopted, ideally before the publication of the SPD. This approach will ensure that the costs detailed in the SPD are founded on a robust and up to date evidence base for indoor and outdoor sports. Subsequently, the strategies would inform set out the necessary extent of playing pitches and other sports facilities required to address demand.

Sport England trusts the above is of assistance. If you have any questions or would like any further advice, please do not hesitate to contact me.

Kind Regards,

Clare Howe

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.

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

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.

Please find attached a letter from CBC Ltd setting out our support for proposals raised by CUH in relation to S106.

Please find attached a letter from CBC Ltd setting out our support for proposals raised by CUH in relation to S106.