It is noted that paragraph 14.16 of the draft SPD requires that the delivery of outdoor playing pitches should be made with regard to the most recently adopted Greater Cambridge Playing Pitch Strategy and refers to an updated Greater Cambridge Playing Pitch Strategy being prepared to inform the Greater Cambridge Local Plan. In this regard, we would stress that this should not be used as means of changing policy requirements in advance of the new Local Plans being adopted. Until this is the case, it is important that the requirements of any Playing Pitch Strategy remain consistent with the policies and requirements in the Adopted Local Plans. As noted above, the PPG makes it clear that as SPDs do not form part of the development plan, they cannot introduce new planning policies into the development plan.

Paragraph 14.32 describes commuted maintenance fees “where the circumstances of a particular site require a contribution calculated on a longer period where there is sufficient justification.” We would emphasise that any financial contributions being sought need to be fully justified by supporting evidence provided within a Public Open Space Study or Open Space SPD.

With regard to the various formulas for calculating planning obligations in relation to public open space set out in Tables 14-1 to 14-16 we would again 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. Pigeon therefore consider that these should be deleted.

Endurance notes that the draft SPD proposes updated funding formulas for financial contributions towards Public Open Space based on the Council’s Infrastructure Costings Review (July 2025).

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.

Thank you for consulting Sport England on the revised comments regarding 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

As mentioned in our previous comments dated 24/01/2025 the 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 therefore reflective of those standards within the Cambridge Local Plan and South Cambridgeshire Local Plan so Sport England does not object to this.

On-site provision: Paragraph 14.16 of the SPD has been updated to acknowledge that an existing Playing Pitch Strategy is in progress to inform the Greater Cambridge Local Plan. This revision is supported.

Off-site provision: A footnote has been added noting that the cost estimates are based on the Infrastructure Costing Review – Greater Cambridge Planning Obligations SPD (July 2025). Sport England recommends using its Playing Pitch Calculator to determine costs, ensuring alignment with the 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, therefore in this instance, Sport England do not object.

At paragraph 15.6 the additional wording regarding the reference of the Indoor Sports Facility Strategy 2015-2031 is supported. Likewise, Sport England welcomes the inclusion of paragraph 15.16. You may wish to caveat this part of the SPD, to note that costs may be updated to reflect inflation in line with Sport England’s Facilities calculator.

Thank you for consulting Sport England on the revised comments regarding 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

As mentioned in our previous comments dated 24/01/2025 the 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 therefore reflective of those standards within the Cambridge Local Plan and South Cambridgeshire Local Plan so Sport England does not object to this.

On-site provision: Paragraph 14.16 of the SPD has been updated to acknowledge that an existing Playing Pitch Strategy is in progress to inform the Greater Cambridge Local Plan. This revision is supported.

Off-site provision: A footnote has been added noting that the cost estimates are based on the Infrastructure Costing Review – Greater Cambridge Planning Obligations SPD (July 2025). Sport England recommends using its Playing Pitch Calculator to determine costs, ensuring alignment with the 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, therefore in this instance, Sport England do not object.

At paragraph 15.6 the additional wording regarding the reference of the Indoor Sports Facility Strategy 2015-2031 is supported. Likewise, Sport England welcomes the inclusion of paragraph 15.16. You may wish to caveat this part of the SPD, to note that costs may be updated to reflect inflation in line with Sport England’s Facilities calculator.

Thank you for consulting Sport England on the revised comments regarding 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

As mentioned in our previous comments dated 24/01/2025 the 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 therefore reflective of those standards within the Cambridge Local Plan and South Cambridgeshire Local Plan so Sport England does not object to this.

On-site provision: Paragraph 14.16 of the SPD has been updated to acknowledge that an existing Playing Pitch Strategy is in progress to inform the Greater Cambridge Local Plan. This revision is supported.

Off-site provision: A footnote has been added noting that the cost estimates are based on the Infrastructure Costing Review – Greater Cambridge Planning Obligations SPD (July 2025). Sport England recommends using its Playing Pitch Calculator to determine costs, ensuring alignment with the 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, therefore in this instance, Sport England do not object.

At paragraph 15.6 the additional wording regarding the reference of the Indoor Sports Facility Strategy 2015-2031 is supported. Likewise, Sport England welcomes the inclusion of paragraph 15.16. You may wish to caveat this part of the SPD, to note that costs may be updated to reflect inflation in line with Sport England’s Facilities calculator.

See attached the comments from Linton Parish Council in relation to the GC Local Plan Supplementary Planning Document.

Thank you for consulting Sport England. Sport England e-mailed our response today at 16:21 to the above proposals. Following sending this we saw the additional information uploaded regarding the Greater Cambridge Planning Obligations- Costing Update Paper. Can you please ignore our previous comments and take into our account our comments below.

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

As mentioned in our previous comments dated 24/01/2025 the 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 therefore reflective of those standards within the Cambridge Local Plan and South Cambridgeshire Local Plan so Sport England does not object to this.

On-site provision: Paragraph 14.16 of the SPD has been updated to acknowledge that an existing Playing Pitch Strategy is in progress to inform the Greater Cambridge Local Plan. This revision is supported.

Off-site provision: A footnote has been added noting that the cost estimates are based on the Infrastructure Costing Review – Greater Cambridge Planning Obligations SPD (July 2025). Having reviewed that document it is noted that the capital (provision) costs for Outdoors Sports are derived from Sport England facility cost guidance (Quarter 3, 2024) and that maintenance costs for Outdoor Sports have been informed by Sport England lifecycle cost guidance. This is supported. You may wish to caveat this part of the SPD, to note that costs may be updated to reflect inflation in line with Sport England’s Facilities calculator.

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, therefore in this instance, Sport England do not object.

At paragraph 15.6 the additional wording regarding the reference of the Indoor Sports Facility Strategy 2015-2031 is supported. Likewise, Sport England welcomes the inclusion of paragraph 15.16. You may wish to caveat this part of the SPD, to note that costs may be updated to reflect inflation in line with Sport England’s Facilities calculator.

If you could please confirm receipt of this e-mail that would be appreciated.

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.

Thank you for consulting Sport England. Sport England e-mailed our response today at 16:21 to the above proposals. Following sending this we saw the additional information uploaded regarding the Greater Cambridge Planning Obligations- Costing Update Paper. Can you please ignore our previous comments and take into our account our comments below.

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

As mentioned in our previous comments dated 24/01/2025 the 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 therefore reflective of those standards within the Cambridge Local Plan and South Cambridgeshire Local Plan so Sport England does not object to this.

On-site provision: Paragraph 14.16 of the SPD has been updated to acknowledge that an existing Playing Pitch Strategy is in progress to inform the Greater Cambridge Local Plan. This revision is supported.

Off-site provision: A footnote has been added noting that the cost estimates are based on the Infrastructure Costing Review – Greater Cambridge Planning Obligations SPD (July 2025). Having reviewed that document it is noted that the capital (provision) costs for Outdoors Sports are derived from Sport England facility cost guidance (Quarter 3, 2024) and that maintenance costs for Outdoor Sports have been informed by Sport England lifecycle cost guidance. This is supported. You may wish to caveat this part of the SPD, to note that costs may be updated to reflect inflation in line with Sport England’s Facilities calculator.

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, therefore in this instance, Sport England do not object.

At paragraph 15.6 the additional wording regarding the reference of the Indoor Sports Facility Strategy 2015-2031 is supported. Likewise, Sport England welcomes the inclusion of paragraph 15.16. You may wish to caveat this part of the SPD, to note that costs may be updated to reflect inflation in line with Sport England’s Facilities calculator.

If you could please confirm receipt of this e-mail that would be appreciated.

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.

Thank you for consulting Sport England. Sport England e-mailed our response today at 16:21 to the above proposals. Following sending this we saw the additional information uploaded regarding the Greater Cambridge Planning Obligations- Costing Update Paper. Can you please ignore our previous comments and take into our account our comments below.

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

As mentioned in our previous comments dated 24/01/2025 the 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 therefore reflective of those standards within the Cambridge Local Plan and South Cambridgeshire Local Plan so Sport England does not object to this.

On-site provision: Paragraph 14.16 of the SPD has been updated to acknowledge that an existing Playing Pitch Strategy is in progress to inform the Greater Cambridge Local Plan. This revision is supported.

Off-site provision: A footnote has been added noting that the cost estimates are based on the Infrastructure Costing Review – Greater Cambridge Planning Obligations SPD (July 2025). Having reviewed that document it is noted that the capital (provision) costs for Outdoors Sports are derived from Sport England facility cost guidance (Quarter 3, 2024) and that maintenance costs for Outdoor Sports have been informed by Sport England lifecycle cost guidance. This is supported. You may wish to caveat this part of the SPD, to note that costs may be updated to reflect inflation in line with Sport England’s Facilities calculator.

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, therefore in this instance, Sport England do not object.

At paragraph 15.6 the additional wording regarding the reference of the Indoor Sports Facility Strategy 2015-2031 is supported. Likewise, Sport England welcomes the inclusion of paragraph 15.16. You may wish to caveat this part of the SPD, to note that costs may be updated to reflect inflation in line with Sport England’s Facilities calculator.

If you could please confirm receipt of this e-mail that would be appreciated.

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.

Thank you for consulting Sport England. Sport England e-mailed our response today at 16:21 to the above proposals. Following sending this we saw the additional information uploaded regarding the Greater Cambridge Planning Obligations- Costing Update Paper. Can you please ignore our previous comments and take into our account our comments below.

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

As mentioned in our previous comments dated 24/01/2025 the 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 therefore reflective of those standards within the Cambridge Local Plan and South Cambridgeshire Local Plan so Sport England does not object to this.

On-site provision: Paragraph 14.16 of the SPD has been updated to acknowledge that an existing Playing Pitch Strategy is in progress to inform the Greater Cambridge Local Plan. This revision is supported.

Off-site provision: A footnote has been added noting that the cost estimates are based on the Infrastructure Costing Review – Greater Cambridge Planning Obligations SPD (July 2025). Having reviewed that document it is noted that the capital (provision) costs for Outdoors Sports are derived from Sport England facility cost guidance (Quarter 3, 2024) and that maintenance costs for Outdoor Sports have been informed by Sport England lifecycle cost guidance. This is supported. You may wish to caveat this part of the SPD, to note that costs may be updated to reflect inflation in line with Sport England’s Facilities calculator.

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, therefore in this instance, Sport England do not object.

At paragraph 15.6 the additional wording regarding the reference of the Indoor Sports Facility Strategy 2015-2031 is supported. Likewise, Sport England welcomes the inclusion of paragraph 15.16. You may wish to caveat this part of the SPD, to note that costs may be updated to reflect inflation in line with Sport England’s Facilities calculator.

If you could please confirm receipt of this e-mail that would be appreciated.

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.

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.