Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Comment

Representation ID: 200456

Received: 23/01/2025

Respondent: Hill Residential Ltd (Hill)

Agent: Tor & Co

The SPD seeks to follow guidance in the PPG, in particular, paragraph 004 (23b-004-201901) which 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. Hill welcomes this approach and the SPD’s confirmation that 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.

Comment

Representation ID: 200457

Received: 23/01/2025

Respondent: Hill Residential Ltd (Hill)

Agent: Tor & Co

Hill has concern with the approach set out in paragraph 7.22 that the obligations for community facilities within large scale phased schemes could include temporary ‘meanwhile uses’. Hill recommend adding the following wording: “Where a need is identified planning obligations may be sought, subject to viability and in accordance with paragraph 58 of the NPPF, including: Meanwhile uses…”. This will ensure any obligations of this nature align with the requirements of national policy and are necessary, directly related to development and fair and reasonable in scale and kind

Comment

Representation ID: 200458

Received: 23/01/2025

Respondent: Hill Residential Ltd (Hill)

Agent: Tor & Co

The South Cambridgeshire Local Plan (2018) sets a standard of 111m2 per 1,000 people for contributions towards community facilities. This equates to 0.111m2 per person, so 1m2 would support 10 people (rounded up from 9.009). The cost of provision of a community facility is identified in the SPD as £4,020 per m2 and the maintenance cost is identified as £117.57 per m2 (it is unclear if this is per year or total cost, it is assumed to be the latter). Therefore, the total cost to provide 1m2 of community space is £4137.57, which would equate to £413.76 per person. For a 1-bed property with an assumed population of 1.23 people (average occupancy set out in Appendix A) this would give a contribution of £508.92. It is therefore unclear how the value of £789.63 set out in the table after paragraph 7.28 has been reached.

Comment

Representation ID: 200459

Received: 23/01/2025

Respondent: Hill Residential Ltd (Hill)

Agent: Tor & Co

It is suggested that this separate consideration of obligations for libraries be either moved to be included within Chapter 7: Community Facilities, or cross referenced in Chapter 7 for clarity.

Comment

Representation ID: 200460

Received: 23/01/2025

Respondent: Hill Residential Ltd (Hill)

Agent: Tor & Co

The South Cambridgeshire Local Plan (2018) Policy SC/4 ‘Meeting Community Needs’ includes provision for burials in the list of services and facilities to be provided, however there is no table or level of contributions / requirements set out within policy. In contrast, the draft SPD sets out requirements and contributions which were not tested as part of the Local Plan process. This could undermine the deliverability of the Local Plan, potentially impacting the ability for allocated sites to deliver policy compliant viable schemes, in conflict with paragraph 34 of the NPPF.

Comment

Representation ID: 200461

Received: 23/01/2025

Respondent: Hill Residential Ltd (Hill)

Agent: Tor & Co

Paragraph 13.8- It identifies that 1ha of cemetery can accommodate around 3,000 burial plots (3.33m2 required per plot). The SPD is not clear if one plot equates to one individual or if there could feasibly be several individuals within the one plot (cremations assumed). The table (following paragraph 13.9) setting out the burial space required per dwelling size, appears to be referencing the average occupancy per dwelling size (as set out in Appendix A), thus suggesting that 1 person requires 1m2. This does not seem correct in the context of the information presented in paragraphs 13.8 and 13.11 and the table following paragraph 13.11 which sets out the contributions by dwellings size.

Comment

Representation ID: 200462

Received: 23/01/2025

Respondent: Hill Residential Ltd (Hill)

Agent: Tor & Co

South Cambridgeshire Local Plan (2018) Policy SC/4, that in reflecting Planning Practice Guidance, the Council does not seek tariff style Section 106 contributions for general off site infrastructure improvements from sites under 10 dwellings (and which have a combined gross floor space of no more than 1,000m2). Many of the obligations set out in the draft SPD that relate to general off site infrastructure improvements set out, in some instances, that obligations will be sought from all residential developments, regardless of size. This should be reviewed and amended in line with the adopted local plan and the PPG.

Comment

Representation ID: 200463

Received: 23/01/2025

Respondent: Hill Residential Ltd (Hill)

Agent: Tor & Co

It would be useful to include an explanation of the different ‘capital costs’ (cost per m2) of open space land uses in the two areas as it surprising that the capital cost per m2 is so different between them. It is also noted that the ‘capital costs’ section of the SPD does not include the land value, and this is considered separately. This is a different approach from the adopted South Cambridgeshire Open Space SPD where the capital payments of off-site contributions appear to include the land value in the ‘per person’ cost.

Comment

Representation ID: 200464

Received: 23/01/2025

Respondent: Hill Residential Ltd (Hill)

Agent: Tor & Co

It is noted in paragraph 22.29 that in estimating the impact of a development on the registered patient population, an average household size of 2.4 people is identified. It is unclear why this value has been specified given the more detailed population by dwelling size (as set out in Appendix A) used in other chapters of the SPD. This should be reviewed and clarified.

Comment

Representation ID: 200465

Received: 23/01/2025

Respondent: Hill Residential Ltd (Hill)

Agent: Tor & Co

As a general point, it is suggested that all tables within the SPD be given identification numbers.