Paragraphs 18.6 of the draft SPD confirms that all the emergency services referred to in the preceding sections are currently operating at capacity. It then goes on to confirm that, as a result, the growth planned for Greater Cambridge will place additional demand on all emergency services through an increase in the prevention, protection and response activities. On this basis, paragraph 18.7 concludes that the additional demand placed on service capacity would require new infrastructure and facilities to be provided to mitigate impacts appropriately.

Pigeon considers that the link between the increase in population arising from new development and the increased demand for police and fire services in particular is unclear. It is considered that the draft SPD does not set out clear justification to fully demonstrate the need for all developments to contribute towards new emergency services and that without this, developments would otherwise be unacceptable. As such there is currently insufficient justification to meet the statutory and policy tests in Regulation 122 and the NPPF respectively.

Whilst further justification should be provided within the draft SPD it should be stressed that, in responding to individual applications, emergency services providers will need to clearly set out the necessary justification that any financial contributions or other planning obligations sought meet the statutory and policy tests in Regulation 122 and the NPPF.

Please find attached representation submitted on behalf of our client, Vistry Strategic Land and Major Projects, regarding the draft Planning Obligations SPD.