Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Comment

Representation ID: 200348

Received: 24/01/2025

Respondent: Vistry Strategic Land

Agent: Turley

It is essential that the preparation of this SPD should not fetter or obstruct in any way, the ability of the Local Plan to support sustainable development over the plan period. More fundamentally, we note that the SPD seeks to establish new policy requirements and expectations which are not contained within adopted Development Plan Documents.

This SPD should only provide more detailed advice or guidance on policies in the adopted Local Plans. The SPD should not, as appears to be the case in some circumstances, seek to amend or change the requirements of the adopted Local Plans.

Comment

Representation ID: 200357

Received: 24/01/2025

Respondent: Vistry Strategic Land

Agent: Turley

As we have indicated above, the SPD is seemingly seeking to introduce additional obligations on new developments which were not taken account of at the Local Plan stage. While we highlight specific contributions later in these representations, we note the Councils’ starting point will be that planning applications are viable given the viability assessment work undertaken at the Local Plan stage. However, it is noted that the SPD consultation document has not been subject to any viability assessment, or if it has been this assessment has not been made public alongside the consultation.

The lack of viability assessment raises concerns around the delivery of existing allocations and other future development being considered under the adopted policies; particularly where additional contributions, or existing obligations which have had new requirements and / or additional information required to support an application could impact the viability of schemes currently being planned for.

Comment

Representation ID: 200358

Received: 24/01/2025

Respondent: Vistry Strategic Land

Agent: Turley

Neither Council has adopted a Community Infrastructure Levy (CIL) charging schedule, although both have previously consulted on one. Paragraphs 1.18-1.19 of the SPD highlight that the Councils are continuing to review whether CIL should be introduced to support the delivery of the emerging Greater Cambridge Local Plan. If a CIL is introduced, we note that this should not duplicate existing obligations. We reserve the right to comment further on CIL matters if this progresses and we note that future CIL requirements could have further viability implications alongside those highlighted above.

Comment

Representation ID: 200359

Received: 24/01/2025

Respondent: Vistry Strategic Land

Agent: Turley

The SPD presents a contribution table. While this appears to relate to South Cambridgeshire only, the structure of the SPD’s supporting text would make it appear that the contribution could cover both authority areas based on the sub-heading format set out in the SPD. While the supporting text of the SPD does not imply this, it is not explicit in confirming the approach and the way the information presented is somewhat unclear. We suggest that the Councils review how this is presented and confirm that the contribution calculation is only required within South Cambridgeshire.

Comment

Representation ID: 200360

Received: 24/01/2025

Respondent: Vistry Strategic Land

Agent: Turley

We note that the SPD sets out a requirement for applications of more than 200 dwellings to provide detailed assessments and strategies on community needs. This is a policy requirement in South Cambridgeshire within Policy SC/4, however the SPD extends this to Cambridge where a similar policy requirement does not exist.

The estimated costs appear to be based on the following (extracted from paragraphs 7.26-7.28 of the SPD):
• The South Cambridgeshire Local Plan 2018 sets a standard of 111m2 per 1000 population.
• The cost of providing community centres is £4,020 per m2 as a starting point for calculating developer contributions
• The cost associated with maintaining (utilities, decoration, services, etc) community facilities is £117.57 per m2.

Aside from the first point, the SPD has not set out the source of these costs and whether the costs indicated are representative of both Councils’ areas where construction costs and land values may vary between the two. It is noted that other contributions (such as the Indoor Sport contribution commented below) do differentiate between the two areas. Moreover, while the South Cambridgeshire Local Plan does set a quantum of floorspace required, it does not set out how this would translate to how a potential contribution would be calculated and therefore would not have been subject to viability testing.

Comment

Representation ID: 200361

Received: 24/01/2025

Respondent: Vistry Strategic Land

Agent: Turley

The SPD sets out the amount of burial space per dwelling:

While there is some evidence presented to support this, the Constitutional Affairs Select Committee Eighth Report 2006 cited is somewhat dated and the Councils should consider whether there is any up-to-date evidence to support the figures stated. In addition, there is no evidence to support the stated statistic that each hectare of a cemetery can accommodate around 3000 burial plots. Therefore, while we do not object to the principle of the obligation itself, the amount of space identified needs to be evidenced.

In terms of contributions, the SPD proposes that smaller developments should provide a contribution where a need is identified in consultation with the Parish Council. Paragraph 13.11 states:

The cost of acquiring new land for burials is around £240,000 per hectare and the cost of preparing that land for burials is £100,000 per hectare meaning a contribution of £34 per m2 of burial space or £113.22 per each plot.

The Councils should clarify the evidence underpinning these estimated costs and whether there is a cost difference between the two authority areas.

Comment

Representation ID: 200362

Received: 24/01/2025

Respondent: Vistry Strategic Land

Agent: Turley

It is acknowledged that both Local Plans set out requirements for either the provision of on-site public open space, or an equivalent off-site contribution. It is also noted that the SPD does provide a detailed breakdown of costs and different costs per authority have been set out. However, the capital costs set out need to be evidenced and viability tested by the authorities.

Comment

Representation ID: 200363

Received: 24/01/2025

Respondent: Vistry Strategic Land

Agent: Turley

In terms of off-site contributions, the SPD does provide different levels of contribution per authority area and cites the Sport England Facilities Calculator in estimating the costs of a contribution. However, we highlight that the figures quoted need to be viability tested.

Comment

Representation ID: 200364

Received: 24/01/2025

Respondent: Vistry Strategic Land

Agent: Turley

Section 22 of the SPD sets out the requirements for Healthcare obligations and contributions. The main cost identified is primary care infrastructure. While detailed costs are provided within the SPD, we highlight that these costs have the potential to be significant for larger developments and need to be viability tested.

Comment

Representation ID: 200365

Received: 24/01/2025

Respondent: Vistry Strategic Land

Agent: Turley

It is clear that the Council have not tested the viability implications of the additional requirements the SPD seeks to introduce and we are concerned about the impact that the SPD will have for existing planned for development. There are also several proposed obligations / contributions where it is not clear if the Councils have tested whether there are differences between the two authority areas. Overall, we are concerned that the document is lacking in detail and failing to provide detailed information around costings as highlighted.