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

Ref: PH/JL/ITL17310-011

Date: 17 October 2025


Introduction
1.1 The Greater Cambridge Partnership (GCP) have prepared a Supplementary Planning Document (SPD) that details the approach the councils (South Cambridgeshire District Council and Cambridge City Council) will take on planning obligations for new developments. An initial version of this document was previously consulted on in late 2024, which has been updated based on comments collected during that consultation.
1.2 The stated aim of this SPD is “to provide greater clarity on the process and expectations around planning obligations with the objective of speeding up the planning process.” Once adopted, it will replace the Cambridge City Council Planning Obligations Strategy SPD 2010.
1.3 As stated within the draft SPD, “It is unlawful for a planning obligation to be taken into account when determining a planning application for a development, or any part of a development, if the obligation does not meet all of the following test:
• Necessary to make the development acceptable in planning terms;
• Directly related to the development; and
• Fairly and reasonably related in scale and kind to the development.
1.4 One of the hopes of this SPD is that it ensures that negotiations on planning obligations are fair, open and reasonable. Furthermore, it states that sites developed in phases will be considered in their totality and seek to match the infrastructure provision required to the pace of the development. This phasing will also apply to financial contributions sought in S106.
1.5 i-Transport represents Martin Grant Homes (MGH), who control long-standing options for development to the North of the A428 and have been promoting a strategic development of some 5,500 homes, extensive employment, infrastructure and open space in this area, called North Cambourne. This Representation looks to give feedback on the Chapter 10: Transport and Highways section of the draft SPD.
Trip Budgets & Monitoring
1.6 The policy looks to move away from the ‘predict and provide’ approach and towards a ‘decide and provide' approach. This accords with the vision-led approach advocated in the NPPF. One of measures stated for controlling transport impacts created by new developments is called a vehicular trip budget.
1.7 There is limited detail provided on what planning situations will require a vehicular trip budget and what these budgets will look like. One element of concern on the information provided is that “Should the monitoring demonstrate that the forecast trips have exceeded the agreed vehicular trip budget, then a financial penalty, hold on future development or a revised schedule of further transport or travel planning interventions will likely be triggered.”
1.8 It is not clear whether the vehicular trip budget will be applied dogmatically, and if, for example monitoring suggests that vehicular trips are at 101 in the peak hour against an agreed budget of 100 whether such an incursion will lead to penalties. While it is stated that the level of penalty will reflect the level of breach, a ‘common sense’ approach of allowing for leeway within the figures should be implemented, as monitoring and modelling undertaken during the planning application are not perfect methods of calculating how users of new development will interact with said development.
1.9 It is unknown whether the monitoring will only consider peak hour traffic or whether the entire day will be taken into account. If for example, a development was in breach of budget for just one hour of the day, while the rest of the day was under budget, would that count as a breach, or would it be taken in the context that the rest of the day is operating well and that a level of variation is expected and thus is not considered a breach.
1.10 Clarification is needed on how the vehicular trip budget figure will be reached and the extent of monitoring required to ensure that it is not breached. If monitoring takes the form of yearly TRICS SAM Surveys for example, they will only represent a singular day which while helpful for getting an idea of the general modal share, does not account for variations in daily life that might lead to temporary changes in travel patterns.
Penalties
1.10.1 A further concern is how the penalty system accords with the CIL planning obligation tests. It is the view of i-Transport that a vehicular trip budget and the use of penalties is likely to fail these tests as follows:
Necessary to make the development acceptable in planning terms;
1.10.1.1 Penalties must go towards specific improvements to make the development acceptable. Will these improvements be in addition to ones already delivered? If so, these measures will need to be included within the S106 agreement and therefore should be delivered? If not, then this will fail the first test as they were not necessary to make the development acceptable.
Directly related to the development
1.10.1.2 It is not clear how these penalties will be spent once collected. If they are to go towards a general pot of funding, this obligation will fail the second test of being directly relevant to the development.
Fairly and reasonably related in scale and kind to the development.
1.10.1.3 There is no detail on the scale of the penalties and how they will be calculated. If it is simply based on the number of trips exceeding the trip budget this will not meet the test. As this could lead to a development of 10 dwellings exceeding its trip budget by 1 trip paying the same as a development of 1,000 dwellings exceeding it’s trip budget by the same amount.
1.10.1.4 It is also not clear how a penalty will ensure that the proposed development goes back under budget. If a breach is minor and thus the penalty is minor to reflect this, what can practically be done to ensure that measures will be effective. It does not seem proportional or fair for a development to be entirely responsible for transport infrastructure and service improvements to influence the travel behaviour beyond what is agreed within Travel Plans, S106 and S278 agreements which are written in line with the CIL tests.
1.11 There is a lack of clarity regarding timescales of interventions. It is stated that measures should “ensure appropriate and immediate action is taken to remedy the breach.” This is unclear in its definition in “action”. If for example, the deemed appropriate action is the implementation of a new cycle path between the development and a nearby trip attractor, this is likely to take longer than a year to implement and will cause disruption while it is being undertaken. This will have impacts on travel patterns (likely for the worse) and thus by the time the next monitoring period comes around (a year later) the development is likely to still be in breach despite taking the appropriate action. Would further penalties be incurred as a result?
1.12 Without far more clarity of how trip budgets and penalties would work in practice it is a concern that it could incentivise a return to the ‘predict and provide’ approach that the GCP is looking to move away from. Further, rather than speeding up the planning process it is likely to require more lengthy discussion and negotiation to agree trip budgets, penalties and the associated s106 provisions.
1.13 Substantially more detail is needed to understand:
• How such an approach would work in practice?
• How the monitoring would be undertaken and at what scale?
• What the unintended consequences would be? and
• Whether such an obligation complies with the tests set out in national policy.
1.13.1 It is the view of i-Transport and MGH that this element of the SPD needs to be significantly reworked or removed.