Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

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Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Chapter 1: Introduction

Representation ID: 200311

Received: 24/01/2025

Respondent: Home Builders Federation

Representation Summary:

HBF is concerned about the use of this SPD to introduce additional financial burdens on a planning application. As they do not form part of the development plan, they cannot introduce new planning policies into the development plan.

The HBF is also concerned that this SPD is being introduced without the full consultation and examination that would have been given during the examination process, as would be befitting a new policy approach. PPG is clear that it is not appropriate for plan-makers to set out new formulaic approaches to planning document, as these would not be subject to examination.

The HBF considers that greater flexibility should be included within the SPD, this may include in relation to viability, scale of evidence required.

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Chapter 4: Affordable Housing

Representation ID: 200312

Received: 24/01/2025

Respondent: Home Builders Federation

Representation Summary:

The SPD states that the affordable housing policies will apply to schemes for specialist housing (such as extra care, retirement homes, residential and / or nursing care, care suites). It also states that the affordable housing policies apply to Build to Rent schemes. The viability of these requirements should be evidenced and ensured.

The LP policies does not set out a tenure split, however the SPD does. it is important to ensure that this proposed tenure split is viable and developable. It will also be important for the Councils to work closely with local registered providers to ensure that these requirements are in line with their plan in the area.

Paragraph 4.3- additional guidance should be added for completeness to address phased developments which provide increase affordable housing in an earlier phase.

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Chapter 6: Biodiversity

Representation ID: 200313

Received: 24/01/2025

Respondent: Home Builders Federation

Representation Summary:

Regarding Paragraph 6.8. HBF would suggest that it is made clear that development achieving 10% will be considered as providing a positive contribution to biodiversity and will be supported by the Council.

Paragraph 6.8 lists some of the exemptions for BNG on new developments. If the Council are to set out exemptions, then the full list set out in legislation should be included in the SPD.

In particular the Council should amend paragraph 6.24 which suggests that without a S106 agreement is in place BNG conditions will not be discharged. Clearly if a conservation covenant is in place than a S106 agreement is not required in order to discharge that condition.

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Chapter 7: Community Facilities

Representation ID: 200314

Received: 24/01/2025

Respondent: Home Builders Federation

Representation Summary:

It is important that the Council has robust evidence to demonstrate that the contributions proposed in this SPD are necessary and directly related to the development. The HBF considers that in order for this policy to function it will be important that the Council has detailed evidence about the community facilities that are already available in the Greater Cambridge area, and their current capacity to meet local community needs. The HBF also considers that if provision is provided on-site, for one form of community facility that the Council will not seek provision for further facilities.

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Chapter 8: Social and Community Support Services

Representation ID: 200315

Received: 24/01/2025

Respondent: Home Builders Federation

Representation Summary:

The SPD states that all new residential development, are to make adequate provision for health care, community and social facilities. It goes on to state that proposals for sites of 200 or more dwellings are required to provide detailed assessments and strategies regarding community needs and how they will be met.

The HBF considers that where a need is identified it will be crucial that this is discussed with the developer of the site affected at the earliest possible time to ensure that this can be built into costs associated with the development. The HBF considers that without further information in relation to potential costs for this requirement that there is potential for this to significant impacts on the viability of development, including in terms of land use and other impacts, not just direct financial costs.

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Chapter 9: Libraries and Lifelong Learning

Representation ID: 200316

Received: 24/01/2025

Respondent: Home Builders Federation

Representation Summary:

This section of the SPD suggests that applicants should set out the details of the number of dwellings or expected population arising from the new development. It then suggests that the Cambridgeshire County Council Planning Obligations Strategy sets the County’s approach to securing contributions. This information is not actually set out in the SPD, and it is not evident whether these figures are to be updated or indexed, or what justification there is, that these are still appropriate. Based on the link in the SPD the contributions appear to range from £28.92 per head of population increase to £97, and are based on the consultation draft Planning Obligations Strategy from 2016. The HBF would question if it is appropriate for life-long learning to be funded through residential development.

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Chapter 11: Education

Representation ID: 200317

Received: 24/01/2025

Respondent: Home Builders Federation

Representation Summary:

The HBF notes that the PPG and GOV.UK provided guidance on how residential development can support education. The HBF questions whether there is any need for this section of the SPD particularly as it doesn’t actually contain the calculation information, and this has to be drawn from other documents and evidence. The SPD also doesn’t contain any up-to-date information as to the Council’s consideration of existing or planned school capacity.

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Chapter 13: Burial Space

Representation ID: 200318

Received: 24/01/2025

Respondent: Home Builders Federation

Representation Summary:

The SPD suggests that planning obligations will be sought from residential development. It suggests that proposals for over 200 dwellings should be accompanied by assessments of need and strategies regarding how the need will be addressed. It also provides a contribution to cost per dwelling based on number of bedrooms, these range from £139.26 for a 1-bed dwelling to £369.10 for a 4+bed dwelling.

The HBF is concerned that the viability of these costs has not be considered, and whilst the South Cambridgeshire Local Plan includes a reference to burial space the same cannot be said for Cambridge Local Plan, therefore this policy requirement has not been test and examined in public as required by the NPPF and PPG.

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Chapter 14: Public Open Space

Representation ID: 200319

Received: 24/01/2025

Respondent: Home Builders Federation

Representation Summary:

This SPD suggests that obligations will be sought from residential developments, it sets out the costs by dwelling size including capital costs and maintenance costs, these are slightly different for Cambridge and South Cambridgeshire.

The home building industry are used to providing public open space as part of development or as contributions where appropriate. However, it will be important to ensure that these requirements are viable and deliverable and do not prevent or stall delivery of homes.

Comment

Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Chapter 15: Indoor Sports, including Swimming

Representation ID: 200320

Received: 24/01/2025

Respondent: Home Builders Federation

Representation Summary:

This section is based on Cambridge Local Plan Policy 68 and South Cambridgeshire Local Plan Policy SC/4. This SPD suggests that planning obligations will be sought from all residential development, it suggests that on-site provision is only likely to be required in the largest forms of development. Off-site contributions will be guided by the Sports England Facilities Calculator, and the SPD sets out a contribution per house based on the number of bedrooms, with slightly differing costs in Cambridge and South Cambridgeshire but ranging from £276.75 to £769.36 for swimming contributions and £227.55 to £726.98 for Indoors Sports Hall contributions.

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