Draft Greater Cambridge Planning Obligations Supplementary Planning Document re-consultation - 2025

Paragraph 1.2 of the Introduction notes that:

“The purpose of the Planning Obligations Supplementary Planning Document (SPD) is to provide supplementary planning guidance in support of the Policy 85: Infrastructure delivery, planning obligations and the Community Infrastructure Levy of the Cambridge City Local Plan 2018 and Policy TI/8: Infrastructure and New Developments of the South Cambridgeshire Local Plan 2018.”

Accordingly, it is important the SPD is consistent with the wider policy framework provided by the adopted Plans and does not seek to introduce new policies or unduly undermine the deliverability of planned development in accordance with PPG Paragraph ID: 61-008-20190315.

Endurance is concerned that there are a number of areas where the Councils appear to be introducing new policy approaches which go beyond the requirements of the adopted Development Plan, contrary to Planning Practice Guidance. This includes:

• An aspirational target for 20% BNG (Chapter 6) that is not supported by adopted policies.
• Financial contributions towards Social and Community Support Services (Chapter 8).
• Financial contributions towards Burial Space (Chapter 13)
• A requirement for residential developments to contribute towards Local Employment & Skills (Chapter 19)
• A requirement for large commercial developments to provide affordable workspace (Chapter 20)

Endurance considers that there is insufficient policy support to justify the use of planning obligations for these services 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. 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.

Endurance notes that the draft SPD proposes a number of new or updated funding formulas for financial contributions towards various infrastructure or services potentially impacted by new development and which are based on the Council’s Infrastructure Costings Review (July 2025). These include formulas for calculating:

• Off-site provision of Natural Greenspace within South Cambridgeshire (Chapter 5),
• Community Services (Chapter 7),
• Burial Space (Chapter 13)
• Public Open Space (Chapter 14); and,
• Indoor Sport (Chapter 16).

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.

Endurance is concerned that the aspirational target for 20% BNG goes beyond the requirements of the adopted Development Plan, contrary to Planning Practice Guidance.

Endurance considers that there is insufficient policy support to justify the use of planning obligations for these services 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. 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.

Endurance notes that the draft SPD proposes a number of new or updated funding formulas for financial contributions towards Community Services.

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.

Endurance is concerned that the requirement for financial contributions towards Social and Community Support Services goes beyond the requirements of the adopted Development Plan, contrary to the PPG.

Endurance considers that there is insufficient policy support to justify the use of planning obligations for these services 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. 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.

Endurance is concerned that the requirement for Financial contributions towards Burial Space goes beyond the requirements of the adopted Development Plan, contrary to Planning Practice Guidance.

Endurance considers that there is insufficient policy support to justify the use of planning obligations for these services 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. 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.

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.

Endurance notes that the draft SPD proposes an updated funding formula for financial contributions towards Indoor Sport which is 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.

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.

Endurance is concerned that there the requirement for large commercial developments to provide affordable workspace 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.