Pigeon considers that paragraph 7.10 should be updated with regard to the types of developments from which funding will be sought. The current wording proposed that ‘all new residential’ development would be eligible and it is accepted that this reflects the requirements of and is consistent with Policy SC/4 and SC/6 of the South Cambridgeshire Local Plan and Policy 85 of the Cambridge Local Plan. However there doesn’t appear to be a clear policy or evidential basis to justify that all major commercial developments in South Cambridgeshire should be required to make provision for community facilities to meet the needs arising from the development.

Moreover, to ensure consistency with the statutory tests it is necessary to demonstrate need. As such it is considered that, only where there is a demonstrable need can provision / a financial contribution be requested. This need should be identified, directly related to the development and justified by the LPA. In this context, Policy SC/2 Health Impact Assessment require developers to submit Health Impact Assessments of varying scales dependent on the scale of residential development and/or commercial floorspace proposed. The assessments are required to consider community related impacts in accordance with the Screening Matrix set out in the Councils related SPD. It is considered that, in the absence of any other clear evidence, it is only developments that are to be subject to a HIA and where the HIA demonstrates significant community impacts which require mitigation where such a requirement could reasonably be justified.

As stated above Planning obligations “assist in mitigating the impact of unacceptable development to make it acceptable in planning terms.” Planning obligations may only constitute a reason for granting planning permission if they meet the statutory test that they are necessary to make the development acceptable in planning terms as set out in Regulation 122 of the CIL Regulations and as policy tests in the National Planning Policy Framework.

Furthermore, with regard to the various formulas for calculating planning obligations in relation to Community Facilities set out in Table 7-1 we would stress that Paragraph 23b-004-20190901 emphasises that it is not appropriate for plan-makers to set out new formulaic approaches to planning obligations in supplementary planning documents as they would not be subject to examination. These should therefore be removed.

Endurance notes that the draft SPD proposes a number of new or updated funding formulas for financial contributions towards Community Services.

Endurance is concerned that these have not been tested in the round to ensure that the cumulative effect of the proposed contributions does not compromise the viability of development. It is noted that the Infrastructure Costings Review on which the new formulas are based has been produced to support the emerging Greater Cambridge Local Plan and Endurance therefore question its appropriateness as a basis for justifying increases in development contributions at this time, ahead of the adoption of the new Local Plan.

We would highlight that, according to the PPG (Paragraph: 004 Reference ID: 23b-004-20190901), it is inappropriate for plan-makers to establish new formulaic approaches to planning obligations in supplementary planning documents or supporting evidence base documents, as these would not undergo examination and the effect on site viability and delivery cannot be considered in the round. We therefore question the Councils’ approach in seeking to undertake major changes to planning obligations funding requirements through this SPD and consider that the proposed approach within the draft SPD would not meet the statutory tests within Regulation 122

Accordingly, to remedy this, the Councils should either delay the publication of the SPD until the new Greater Cambridge Local Plan has been adopted or at the very least remove these new formulaic funding requirements from the SPD.

This representation has been prepared on behalf of Wrenbridge Land Limited (hereafter ‘Wrenbridge’) in
response to the Greater Cambridge Planning Obligation Supplementary Planning Document (SPD)
consultation closing 17 October 2025.

Wrenbridge has delivered several successful commercial schemes across Greater Cambridge including
recently at Lockton House, with other recent permissions at Clarendon House and Mercers Row.

Wrenbridge also maintain future land interests for developments across Greater Cambridge, they are
therefore well placed to provide a response to the draft SPD, particularly in relation to commercial
development and obligations.

Consultation Response

Below sets out our consultation response structured by the relevant chapters within the consultation
document.

This feedback is set out with the Community Infrastructure Levy 122 statutory tests in mind, which state
obligations can only be sought where they meet the following tests:
• Necessary to make the development acceptable in planning terms;
• Directly related to the development;
• Fairly and reasonably related in scale and kind to the development.
This test is also enshrined in paragraph 58 of the National Planning Policy Framework.

Chapter 7: Community Facilities

The need for all major commercial development to provide or contribute towards community facilities is
unclear (introduced at paragraph 7.10). Paragraph 7.13 goes onto explain that commercial
developments of greater than 5,000m2 will be required to ‘consider’ how the needs of workers and
visitors will be met in relation to social and leisure facilities. If the need is not met via existing or new onsite
facilities and contribution will be sought to address the impact.

It is not clear whether at paragraph 7.13 ‘existing or new on site-facilities’ means existing facilities on-site
or whether this can include a review of existing facilities within the general area. The paragraph should
be re-written to clarify this point. It could be re-written to state: If the need cannot be met through
existing facilities on-site, in the surrounding area or new on-site facilities […]’. This provides the
necessary clarification, with the pre-application process used to agree the scope of review ahead of a
planning submission.

However, should the ‘existing’ wording relate solely to on-site facilities then the following feedback is
provided.

It is not a sound approach to require all commercial developments of greater than 5,000m2 provide new
on-site facilities if they do not benefit from existing facilities. New commercial development may support
existing community facilities in their wider area by helping ensure their viability (ie: new customers for
existing public houses).

Chapter 14: Public Open Space & Chapter 15: Indoor Sports, Including Swimming

The same comments are made on these sections as for chapter 7 above. The reference to ‘existing’ in
paragraph 14.8 and 15.5 should be made clearer, that it also refers to a review of provision within the
wider area.

Chapter 20: Planning Obligations to Support Affordable Workspace

It is important to set out the purpose of SPDs in terms of decision making. The National Planning Policy
Framework defines them as:
‘Documents which add further detail to the policies in the development plan. They can be used to provide
further guidance for development on specific sites, or on particular issues, such as design.
Supplementary planning documents are capable of being a material consideration in planning decisions
but are not part of the development plan.’

The key strand of this is that SPDs add further details to policies in the development plan. They should
not be used to create in effect create new policies that have not been through the scrutiny of the Local
Plan process.

This is further elaborated upon in the Plan-Making Planning Practice Guidance and also add that they
should not add unnecessarily to the financial burden of development. Whilst The Town and Country
Planning (Local Planning) (England) Regulations 2012 at Part 4, Regulation 8, Limb (3) states that SPDs
must not conflict with the adopted development plan.
This is important to draw out as the Council acknowledge at paragraph 20.4, neither development plan
contain policies relating to affordable workspace.

The introduction of such an obligation or potential requirement may have a significant impact on the
viability of commercial developments across Greater Cambridge, which has not been subject the scrutiny
of Local Plan Examination. Nor does it appear any in-depth evidence has been prepared to support the
10% of floorspace aspiration including viability assessments, rather the Council has lifted a similar
approach from the London Plan.

Until such time as a future policy is subject to a fully evidenced approach that is scrutinised via the Local
Plan process, we believe that this chapter should be removed from the SPD entirely. The SPD can then
be updated in the future in this regard (if necessary) once a new Local Plan is adopted.

If you have any questions, please do not hesitate to get in touch.

This representation has been prepared on behalf of Wrenbridge Land Limited (hereafter ‘Wrenbridge’) in
response to the Greater Cambridge Planning Obligation Supplementary Planning Document (SPD)
consultation closing 17 October 2025.

Wrenbridge has delivered several successful commercial schemes across Greater Cambridge including
recently at Lockton House, with other recent permissions at Clarendon House and Mercers Row.

Wrenbridge also maintain future land interests for developments across Greater Cambridge, they are
therefore well placed to provide a response to the draft SPD, particularly in relation to commercial
development and obligations.

Consultation Response

Below sets out our consultation response structured by the relevant chapters within the consultation
document.

This feedback is set out with the Community Infrastructure Levy 122 statutory tests in mind, which state
obligations can only be sought where they meet the following tests:
• Necessary to make the development acceptable in planning terms;
• Directly related to the development;
• Fairly and reasonably related in scale and kind to the development.
This test is also enshrined in paragraph 58 of the National Planning Policy Framework.

Chapter 7: Community Facilities

The need for all major commercial development to provide or contribute towards community facilities is
unclear (introduced at paragraph 7.10). Paragraph 7.13 goes onto explain that commercial
developments of greater than 5,000m2 will be required to ‘consider’ how the needs of workers and
visitors will be met in relation to social and leisure facilities. If the need is not met via existing or new onsite
facilities and contribution will be sought to address the impact.

It is not clear whether at paragraph 7.13 ‘existing or new on site-facilities’ means existing facilities on-site
or whether this can include a review of existing facilities within the general area. The paragraph should
be re-written to clarify this point. It could be re-written to state: If the need cannot be met through
existing facilities on-site, in the surrounding area or new on-site facilities […]’. This provides the
necessary clarification, with the pre-application process used to agree the scope of review ahead of a
planning submission.

However, should the ‘existing’ wording relate solely to on-site facilities then the following feedback is
provided.

It is not a sound approach to require all commercial developments of greater than 5,000m2 provide new
on-site facilities if they do not benefit from existing facilities. New commercial development may support
existing community facilities in their wider area by helping ensure their viability (ie: new customers for
existing public houses).

Chapter 14: Public Open Space & Chapter 15: Indoor Sports, Including Swimming

The same comments are made on these sections as for chapter 7 above. The reference to ‘existing’ in
paragraph 14.8 and 15.5 should be made clearer, that it also refers to a review of provision within the
wider area.

Chapter 20: Planning Obligations to Support Affordable Workspace

It is important to set out the purpose of SPDs in terms of decision making. The National Planning Policy
Framework defines them as:
‘Documents which add further detail to the policies in the development plan. They can be used to provide
further guidance for development on specific sites, or on particular issues, such as design.
Supplementary planning documents are capable of being a material consideration in planning decisions
but are not part of the development plan.’

The key strand of this is that SPDs add further details to policies in the development plan. They should
not be used to create in effect create new policies that have not been through the scrutiny of the Local
Plan process.

This is further elaborated upon in the Plan-Making Planning Practice Guidance and also add that they
should not add unnecessarily to the financial burden of development. Whilst The Town and Country
Planning (Local Planning) (England) Regulations 2012 at Part 4, Regulation 8, Limb (3) states that SPDs
must not conflict with the adopted development plan.
This is important to draw out as the Council acknowledge at paragraph 20.4, neither development plan
contain policies relating to affordable workspace.

The introduction of such an obligation or potential requirement may have a significant impact on the
viability of commercial developments across Greater Cambridge, which has not been subject the scrutiny
of Local Plan Examination. Nor does it appear any in-depth evidence has been prepared to support the
10% of floorspace aspiration including viability assessments, rather the Council has lifted a similar
approach from the London Plan.

Until such time as a future policy is subject to a fully evidenced approach that is scrutinised via the Local
Plan process, we believe that this chapter should be removed from the SPD entirely. The SPD can then
be updated in the future in this regard (if necessary) once a new Local Plan is adopted.

If you have any questions, please do not hesitate to get in touch.

This representation has been prepared on behalf of Wrenbridge Land Limited (hereafter ‘Wrenbridge’) in
response to the Greater Cambridge Planning Obligation Supplementary Planning Document (SPD)
consultation closing 17 October 2025.

Wrenbridge has delivered several successful commercial schemes across Greater Cambridge including
recently at Lockton House, with other recent permissions at Clarendon House and Mercers Row.

Wrenbridge also maintain future land interests for developments across Greater Cambridge, they are
therefore well placed to provide a response to the draft SPD, particularly in relation to commercial
development and obligations.

Consultation Response

Below sets out our consultation response structured by the relevant chapters within the consultation
document.

This feedback is set out with the Community Infrastructure Levy 122 statutory tests in mind, which state
obligations can only be sought where they meet the following tests:
• Necessary to make the development acceptable in planning terms;
• Directly related to the development;
• Fairly and reasonably related in scale and kind to the development.
This test is also enshrined in paragraph 58 of the National Planning Policy Framework.

Chapter 7: Community Facilities

The need for all major commercial development to provide or contribute towards community facilities is
unclear (introduced at paragraph 7.10). Paragraph 7.13 goes onto explain that commercial
developments of greater than 5,000m2 will be required to ‘consider’ how the needs of workers and
visitors will be met in relation to social and leisure facilities. If the need is not met via existing or new onsite
facilities and contribution will be sought to address the impact.

It is not clear whether at paragraph 7.13 ‘existing or new on site-facilities’ means existing facilities on-site
or whether this can include a review of existing facilities within the general area. The paragraph should
be re-written to clarify this point. It could be re-written to state: If the need cannot be met through
existing facilities on-site, in the surrounding area or new on-site facilities […]’. This provides the
necessary clarification, with the pre-application process used to agree the scope of review ahead of a
planning submission.

However, should the ‘existing’ wording relate solely to on-site facilities then the following feedback is
provided.

It is not a sound approach to require all commercial developments of greater than 5,000m2 provide new
on-site facilities if they do not benefit from existing facilities. New commercial development may support
existing community facilities in their wider area by helping ensure their viability (ie: new customers for
existing public houses).

Chapter 14: Public Open Space & Chapter 15: Indoor Sports, Including Swimming

The same comments are made on these sections as for chapter 7 above. The reference to ‘existing’ in
paragraph 14.8 and 15.5 should be made clearer, that it also refers to a review of provision within the
wider area.

Chapter 20: Planning Obligations to Support Affordable Workspace

It is important to set out the purpose of SPDs in terms of decision making. The National Planning Policy
Framework defines them as:
‘Documents which add further detail to the policies in the development plan. They can be used to provide
further guidance for development on specific sites, or on particular issues, such as design.
Supplementary planning documents are capable of being a material consideration in planning decisions
but are not part of the development plan.’

The key strand of this is that SPDs add further details to policies in the development plan. They should
not be used to create in effect create new policies that have not been through the scrutiny of the Local
Plan process.

This is further elaborated upon in the Plan-Making Planning Practice Guidance and also add that they
should not add unnecessarily to the financial burden of development. Whilst The Town and Country
Planning (Local Planning) (England) Regulations 2012 at Part 4, Regulation 8, Limb (3) states that SPDs
must not conflict with the adopted development plan.
This is important to draw out as the Council acknowledge at paragraph 20.4, neither development plan
contain policies relating to affordable workspace.

The introduction of such an obligation or potential requirement may have a significant impact on the
viability of commercial developments across Greater Cambridge, which has not been subject the scrutiny
of Local Plan Examination. Nor does it appear any in-depth evidence has been prepared to support the
10% of floorspace aspiration including viability assessments, rather the Council has lifted a similar
approach from the London Plan.

Until such time as a future policy is subject to a fully evidenced approach that is scrutinised via the Local
Plan process, we believe that this chapter should be removed from the SPD entirely. The SPD can then
be updated in the future in this regard (if necessary) once a new Local Plan is adopted.

If you have any questions, please do not hesitate to get in touch.

1) Page 45- para 6.12- Chapter 6 Biodiversity
Reference should be made to the local needs/characteristics of the local area /informed by the LNRS Cambridgeshire (2025).

2)Para 6.13- ‘Adequate ecological information’- reference the LNRS is needed

3)Para. 6.15- Habitat Surveys- local Biodiversity Audits should be referred to ( for example Gamlingay Local Biodiversity Audit – (in draft 2025).

4)Para 7.9- Page 50 Also should reference Neighbourhood Plans in terms of community facility needs and infrastructure.

5)Page 63 Para 10.11 Other relevant transport strategies- reference needed to local Neighbourhood Plans (i.e. GAM8 policy in Gamlingay Neighbourhood Plan specifically relates to active travel infrastructure)

6) Page 77 para. 13.6- Should reference that developers should seek early engagement with the ‘Local Burial Authority’ concerning needs for burial space. This reference should encompass both town and parish councils and district councils who have this remit.

7) General comment- Page 118 para 21.5 keeping important local village PROWs open throughout build programmes is essential for keeping local facilities accessible to their residents. Resources should be made available for temporary diversions to be in place at all times.

8)Page 122- para.22.10 – reference is made to both Gamlingay and Bassingbourn GP practices. Please develop a clear protocol what happens in these areas with regard to providing healthcare infrastructure. There needs to be a clear alternative approach and clarification here, to ensure these communities do not lose out. What is the procedure in these areas?