Regarding "Obligations to support local employment and skills" without high quality infrastructure, many businesses will be unable to operate in such areas. The majority of businesses today require high quality stable electricity and broadband. Without these services, there will be little uptake.

When looking at supporting local employment, parking will still be a requirement for workers, suppliers, contractors and customers. Because a business is employing locally does not provide an excuse not to supply parking.

Pigeon considers that the requirement for new residential development in particular to contribute towards local employment and skills has no clear or justified policy or evidential basis. Paragraphs 19.2 and 19.3 of the SPD refer to generic objectives and policies within the respective Local Plans that provide no clear link with employment or the economy and do not provide an appropriate policy basis or justification for the obligations being sought.

Pigeon is therefore concerned that the Councils appear to be introducing new policy approaches which go beyond the requirements of the adopted Development Plan contrary to the PPG. Moreover, the link between residential developments and the need for them to support local employment and skills is not clear with no clear and direct impacts on local employment arising from such developments.

As such, it is considered that the proposed approach within the draft SPD would not meet the statutory and policy tests within Regulation 122 and the NPPF. Accordingly, all references to residential development should therefore be removed from this chapter.

Endurance is concerned that the requirement for residential developments to contribute towards Local Employment & Skills goes beyond the requirements of the adopted Development Plan.

Endurance considers that there is insufficient policy support to justify the use of planning obligations for this purpose and is concerned that the Councils appear to be introducing new policy approaches which go beyond the requirements of the adopted Development Plan contrary to the PPG and are not justified. It is considered that the proposed approach within the draft SPD would not meet the statutory and policy tests within Regulation 122 and the NPPF.

I would suggest some consideration around the use of 'Employment and Skills Plan' in the singular within the context of large developments. To get to the required level of practical, actionable, planning it will require multiple plans (or method statements). In effect, a plan (each aligned to the same framework) from each of the main contractors who while have been allocated KPIs to meet.

These plans are guided by and contribute towards the overall employment and skills strategy of the development. I think it is important to describe how the responsibility should shared/divided across the development with multiple plans aligned via the strategy, employer requirements/tender process and then ongoing collaboration.

Ahead of clause 19.10 the document speaks about 'encouraged' then in 19.10 it reads like there might be instances in which it is prescribed as part of the s106 obligations. It would be good to have clarity in the policy document on any deciding or qualifying factors as to whether it will be a requirement or encouraged?

I would suggest some consideration around the use of 'Employment and Skills Plan' in the singular within the context of large developments. To get to the required level of practical, actionable, planning it will require multiple plans (or method statements). In effect, a plan (each aligned to the same framework) from each of the main contractors who while have been allocated KPIs to meet.

These plans are guided by and contribute towards the overall employment and skills strategy of the development. I think it is important to describe how the responsibility should shared/divided across the development with multiple plans aligned via the strategy, employer requirements/tender process and then ongoing collaboration.

Ahead of clause 19.10 the document speaks about 'encouraged' then in 19.10 it reads like there might be instances in which it is prescribed as part of the s106 obligations. It would be good to have clarity in the policy document on any deciding or qualifying factors as to whether it will be a requirement or encouraged?

I would suggest some consideration around the use of 'Employment and Skills Plan' in the singular within the context of large developments. To get to the required level of practical, actionable, planning it will require multiple plans (or method statements). In effect, a plan (each aligned to the same framework) from each of the main contractors who while have been allocated KPIs to meet.

These plans are guided by and contribute towards the overall employment and skills strategy of the development. I think it is important to describe how the responsibility should shared/divided across the development with multiple plans aligned via the strategy, employer requirements/tender process and then ongoing collaboration.

Ahead of clause 19.10 the document speaks about 'encouraged' then in 19.10 it reads like there might be instances in which it is prescribed as part of the s106 obligations. It would be good to have clarity in the policy document on any deciding or qualifying factors as to whether it will be a requirement or encouraged?

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