Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

This response is submitted by Trinity College, Cambridge, as the freehold owners and custodians of Cambridge Science Park. Development at Cambridge Science Park has funded significant improvements to the infrastructure of the area over the last 50 years to enable the Science Park to succeed and grow and will continue to do so.
It is accepted and understood that planning proposals should mitigate their transport impacts. Mitigation may be through planning obligations to deliver financial contributions or through the delivery of physical infrastructure as may be required to mitigate a development’s impacts. As set out within paragraph 1.24 of the draft Greater Cambridge Planning Obligations Supplementary Planning Document (“ draft SPD”) any obligations needs to meet all of the CiL Regulation 122 tests: to be necessary, directly related to the development and fairly and reasonably related in scale and kind to the development. Planning obligations by virtue of the requirements of Regulation 122 must directly relate to the development as set out within individual planning applications.
Support is given to the inclusion of paragraph 1.26 in the draft planning obligations SPD which states that (emphasis added):
1.26 The National Planning Practice Guidance (NPPG) provides further advice on the nature of planning obligations especially at paragraphs 001 Reference ID: 23b-001-20190315 to 006 Reference ID: 23b-006-20190901. In particular, paragraph 004 (23b-004-201901) states that policies on planning obligations should be informed by evidence and that it is not appropriate to set out formulaic approaches to planning obligations in supplementary planning documents. This SPD follows this guidance. Each application is to be assessed on its merits and only those obligations necessary to make the development acceptable in planning terms will be requested. While formulae are used for certain types of infrastructure, this is intended to provide an indication of the level and/or cost of an obligation to inform negotiations specific to a development proposal.
Paragraph 10.24 in the draft SPD confirms that where a financial contribution is sought towards strategic transport improvements, the amount payable will be determined on the basis of the cost of the transport infrastructure and the trips from the development that would use the transport infrastructure.
In parallel to the emerging SPD the County Highway Authority, at its 16 January 2025 ‘Environment and Green Investment Committee’, endorsed its own prepared ‘Transport Position Statement’ for the emerging North East Cambridge Area Action Plan (NECAAP).
At the time of writing the adoption of the NECAAP is yet to be determined, and therefore the up-to-date development plan for Cambridge Science Park is the South Cambridgeshire Local Plan (2018). The draft Planning Obligations SPD confirms that this is the Local Plan basis for the area and policy basis for the draft SPD. Cambridge Science Park is identified within the adopted proposals map under policy E/1 which is shown within Inset 16 of the Adopted Proposals Map 2018. The adopted plan does not identify Cambridge Science Park falling within the proposed area action plan boundary, nor the SS/4 Policy Area. The County Highway Authority’s Transport Position Statement is not based on up-to-date policies in accordance with paragraph 59 of the NPPF 2024.
The County Highway Authority’s Transport Position Statement has not been subject to public consultation and none of the background evidence documents to support its content and conclusion are included for scrutiny. Members of the North East Cambridge Transport Task and Finish Group, and members of the North East Cambridge IDP Group have repeatedly requested this information.
In addition, at the time of presentation to members, officers still awaited Counsel Opinion on the principles in the position statement. The Transport Position Statement covering report makes implied reference to the Brookgate Appeal at paragraph 3.3, ‘where the previous position statement was questioned’. However, the report to members does not make clear to members that the conclusions in paragraph 15 of the Secretary of States decision, and at 4.11 of the Inspectors Recommendation remain unchanged today:
4.11 The appellant considers the NECAAP attracts very limited weight, whilst SCDC considers it attracts limited weight. The evidence base that has informed the emerging plan includes a number of inconsistencies between the various documents. More significantly, the NECAAP is predicated on the relocation of the CWWTW to Green Belt land. This is subject to a considerable number of objections, including from the local community. Consequently, there is no certainty that Development Consent will be granted for the relocation of CWWTW. In the light of this, together with the early stage the NECAAP has reached, and the outstanding objections, I agree with the appellant, that the NECAAP and its evidence base should attract very limited weight.
On the 16th January when the Transport Position Statement was presented to County Council members, the DCO was, (and remains) yet to be decided and the NECAAP has not been subject to any further consultation.
The Transport Position Statement seeks to provide a basis for pooling developer obligations in order to fund the strategic transport infrastructure required for a wide area. Unlike Section 106 planning obligations, CIL provides infrastructure to support the development of an area, not to make individual planning applications acceptable in planning terms. CIL specifically breaks the link between a specific development site and the provision of infrastructure and thus provides greater flexibility for delivery of infrastructure when and where it is needed.
The draft SPD at paragraphs 1.18 and 1.19 confirms that the Council’s are continuing to review whether a CIL should be introduced to support the implementation and delivery of the emerging Greater Cambridge Local Plan. In accordance with the requirements, the evidence base for a CIL charging schedule is examined in public prior to the adoption of a levy, and at present there are elements of the transport evidence base that are subject to outstanding questions. This representation reserves opinion as to whether or not there should be a CIL in place for the NECAAP area, however if a charging schedule were to be introduced for the area it should be subject to due process and the evidence base subject to examination.
For these reasons, an objection is lodged to any suggested or implied link between the non-consulted and non-evidenced Transport Position Statement and the emerging updated Greater Cambridge Planning Obligations SPD.