Cambridge is a city with a rich historic environment and yet is experiencing sustained pressure for rapid growth which may threaten the very features that make this city so unique and special. It is important that development appropriately mitigates for any harm to the historic environment and the SPD provides an appropriate vehicle and context for this

Historic England therefore welcomes the preparation of an SPD for Planning Obligations. We have previously commented on the first draft of this document in January 2025 (see letter submitted by e-mail on 23rd January 2025). Please refer to our earlier comments – we will not repeat the advice here but our comments still stand.

We appreciate your recent response to our earlier comments. We do consider this a missed opportunity and would recommend that further consideration is given to how the historic environment may be more appropriately referenced in the final version of the SPD as set out to you in our previous response.

We continue to recommend a more detailed section on the Historic Environment in the SPD. Whilst we appreciate that obligations may vary between sites, that is the case for other topic areas such as the natural environment.

We note a recent example of a draft SPD in London currently out for consultation which sets out a clear strategy S106 in relation to the Historic Environment Planning Obligations Supplementary Planning Document which you may find helpful in considering how to reference this in your SPD.

In particular, we recommend that your SPD should include a section of when heritage requirements would be sought.

The SPD should also set out examples of what sort of obligations might be required including:

• Repairing, restoring or looking after historic buildings and places – including listed buildings, scheduled monuments, historic parks and gardens, and locally listed buildings.
• Putting up heritage information panels or boards to help people understand the history of a place.
• Opening up historic sites to the public more often, such as through open days or special events.
• Improving signs and directions to help people find and learn about historic places.
• Creating, updating and implementing Conservation Management Plans to guide how historic sites are cared for.
• Sharing information about local history with the public – for example, with new residents, schools, or community groups.
• sustainability improvements for historic buildings
• measures for preservation or investigation, recording and recovery of archaeological remains and sites
• display of archaeological sites

Furthermore, the SPD should include a section on addressing Heritage at Risk.

In addition, the SPD should state that heritage requirements may be identified either through Heritage Impact Assessments for the Local Plan (in which case the requirements should be include in Plan policy) or through the Planning application process.

Involvement of Council Conservation and Archaeological Staff
We advise that the conservation and archaeological staff of the Council are involved in the preparation of the SPD and its assessment. They are best placed to advise on local historic environment issues and priorities, as well as identifying opportunities for securing wider benefits for the future conservation and management of heritage assets within the local authority area.

This section of the draft SPD indicates that the previous sections may not encompass all potential planning obligations that could apply to any given development. It lists additional possible obligations, including community, sports, leisure, or open space facilities; impacts on the historic environment; pollution, air quality, noise, or odour mitigation measures; sustainable drainage systems; sustainable show homes; and digital infrastructure.

Pigeon has concerns with the possibility of further planning obligations that are not specified in this SPD. This lack of clarity and uncertainty complicates the development industry’s ability to account for these costs in their land purchases or development cost considerations. Such a lack of clarity can pose significant challenges for developers and may result in delays in bringing developments forward. Further clarity should be provided, otherwise the section should be deleted.

Thank you for consulting the LLFA on the Draft Planning Obligations Supplementary Planning Document.

The LLFA have reviewed the Draft Planning Obligations Supplementary Planning Document and have the following comments:

We consider it important that the SPD clearly recognises flood risk and surface water management as essential infrastructure, with obligations used where necessary to secure delivery, phasing and long-term maintenance of Sustainable Drainage Systems (SuDS).

-The reference to Cambridge Local Plan Policy 31 & 32 and South Cambridgeshire Local Plan Policy CC/8 and CC/9 is supported by the LLFA. South Cambridgeshire Local Plan Policy CC/7 may also be relevant as it covers the importance of managing water quality in new developments using SuDS.

-The Cambridgeshire Flood and Water Supplementary
Planning Guidance (SPD) is adopted by South Cambridgeshire District Council and promotes the use of SuDS to mimic natural drainage within new developments and it is therefore great to see this mentioned within the SPD.

-Cambridgeshire County Councils Surface Water Planning Guidance also provides technical guidance for developers.

Should you wish to further discuss any of the above comments, please do not hesitate to contact us.

Thank you for consulting the LLFA on the Draft Planning Obligations Supplementary Planning Document.

The LLFA have reviewed the Draft Planning Obligations Supplementary Planning Document and have the following comments:

We consider it important that the SPD clearly recognises flood risk and surface water management as essential infrastructure, with obligations used where necessary to secure delivery, phasing and long-term maintenance of Sustainable Drainage Systems (SuDS).

-The reference to Cambridge Local Plan Policy 31 & 32 and South Cambridgeshire Local Plan Policy CC/8 and CC/9 is supported by the LLFA. South Cambridgeshire Local Plan Policy CC/7 may also be relevant as it covers the importance of managing water quality in new developments using SuDS.

-The Cambridgeshire Flood and Water Supplementary
Planning Guidance (SPD) is adopted by South Cambridgeshire District Council and promotes the use of SuDS to mimic natural drainage within new developments and it is therefore great to see this mentioned within the SPD.

-Cambridgeshire County Councils Surface Water Planning Guidance also provides technical guidance for developers.

Should you wish to further discuss any of the above comments, please do not hesitate to contact us.

Thank you for consulting the LLFA on the Draft Planning Obligations Supplementary Planning Document.

The LLFA have reviewed the Draft Planning Obligations Supplementary Planning Document and have the following comments:

We consider it important that the SPD clearly recognises flood risk and surface water management as essential infrastructure, with obligations used where necessary to secure delivery, phasing and long-term maintenance of Sustainable Drainage Systems (SuDS).

-The reference to Cambridge Local Plan Policy 31 & 32 and South Cambridgeshire Local Plan Policy CC/8 and CC/9 is supported by the LLFA. South Cambridgeshire Local Plan Policy CC/7 may also be relevant as it covers the importance of managing water quality in new developments using SuDS.

-The Cambridgeshire Flood and Water Supplementary
Planning Guidance (SPD) is adopted by South Cambridgeshire District Council and promotes the use of SuDS to mimic natural drainage within new developments and it is therefore great to see this mentioned within the SPD.

-Cambridgeshire County Councils Surface Water Planning Guidance also provides technical guidance for developers.

Should you wish to further discuss any of the above comments, please do not hesitate to contact us.

Thank you for consulting the LLFA on the Draft Planning Obligations Supplementary Planning Document.

The LLFA have reviewed the Draft Planning Obligations Supplementary Planning Document and have the following comments:

We consider it important that the SPD clearly recognises flood risk and surface water management as essential infrastructure, with obligations used where necessary to secure delivery, phasing and long-term maintenance of Sustainable Drainage Systems (SuDS).

-The reference to Cambridge Local Plan Policy 31 & 32 and South Cambridgeshire Local Plan Policy CC/8 and CC/9 is supported by the LLFA. South Cambridgeshire Local Plan Policy CC/7 may also be relevant as it covers the importance of managing water quality in new developments using SuDS.

-The Cambridgeshire Flood and Water Supplementary
Planning Guidance (SPD) is adopted by South Cambridgeshire District Council and promotes the use of SuDS to mimic natural drainage within new developments and it is therefore great to see this mentioned within the SPD.

-Cambridgeshire County Councils Surface Water Planning Guidance also provides technical guidance for developers.

Should you wish to further discuss any of the above comments, please do not hesitate to contact us.