Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Comment

Representation ID: 200366

Received: 24/01/2025

Respondent: University of Cambridge

Overall, the use of “per bedroom” obligations is unhelpful. There is a significant difference between the population yield per bedroom for different tenures and types of housing; and even more so for specific specialist housing that could be associated with the University, its students
and workers. There is some acknowledgement of this in the draft but a clear statement should be included to this effect.

In general, it is more appropriate to have a per population estimate of demand – which can be adapted to the specific circumstances of a development.

Comment

Representation ID: 200367

Received: 24/01/2025

Respondent: University of Cambridge

Paragraph 2.50 states that viability appraisals should follow a recognised UK professional standard, such as the RICS Red Book. The SPG should instead signpost to Planning Practice Guidance on Viability, as they are specifically designed to address the unique context of planning decisions.

Paragraph 2.54 makes clear the expectation that viability discussions must be concluded to the satisfaction of the LPA before any meaningful negotiations between the applicant and the LPA can commence, and similar expectations are set out in paragraph 4.32. The need for early engagement during the pre-application stage is acknowledged and encouraged, to allow for
matters on housing and viability to be progressed as far as is reasonably practical. However, recognising that there may be matters unresolved / subject to change, this should not prevent an application from being submitted.

Comment

Representation ID: 200368

Received: 24/01/2025

Respondent: University of Cambridge

Paragraph 7.22 states that funding for Community Workers could be required. While we
understand that for very large developments a community co-ordination role can be valuable
as part of the stewardship strategy in early phases; the paragraph then goes on to suggest this
role could include youth workers or health workers.

While a community co-ordinator may indirectly have some role to play in supporting young
people or the health of the community, the specific role of a youth worker or health worker is
specialist and quite different from a general community development role – and is not a
planning matter. This is raised again in paragraph 8.13 – the funding of mental health, domestic
violence prevention etc are not planning matters and it is not practical or appropriate for those
services to be delivered by or funded by an individual development/developer. These references should be removed from the SPD

Comment

Representation ID: 200369

Received: 24/01/2025

Respondent: University of Cambridge

Paragraph 9.8 should acknowledge the role of the Council in running library facilities. While it
may be appropriate in some contexts for a developer to provide a library building, it should not
be incumbent on that developer, or the volunteer time of the new community, to be made to
run that facility. A library space or service should only be required as a planning obligation
where there is demonstrable need and where there are strategies in place to maintain it, that
do not require a long term commitment from the developer to do so.

Comment

Representation ID: 200370

Received: 24/01/2025

Respondent: University of Cambridge

In relation to paragraph 10.20 (Vehicular Trip Budget) and the reference to “a financial penalty”,
more clarity is needed on how these penalties are calculated and applied to provide certainty
for those bringing developments forward.

Comment

Representation ID: 200371

Received: 24/01/2025

Respondent: University of Cambridge

Paragraph 11.9 states that child yield will be assessed against catchment capacities not school
rolls – we are unclear on the distinction in this context. Further clarification is needed on the
intended methodology.

To be in line with Government Guidance (Department for Education, June 2014. Building
Bulletin 103: area guidelines for mainstream schools, pages 3 and 36), paragraph 11.14 should
confirm that schools which divert from the standard site sizes may be considered on
constrained sites or where other planning considerations need to be taken into account.

Comment

Representation ID: 200372

Received: 24/01/2025

Respondent: University of Cambridge

Whilst paragraph 14.41 is helpful in establishing the principle that some types of home have
different child yields/population profiles, we consider the text should go further to include a
general principle that provision for children in particular can be adjusted if the specialist nature
of the housing indicates a significantly lower child yield per bedroom is likely.

Comment

Representation ID: 200373

Received: 24/01/2025

Respondent: University of Cambridge

The figures within paragraphs 17.15 and 17.16 need to be double checked. The difference
between £114 and £80 is £64, not the £112 quoted. Also, it should be confirmed if this is a
one-off payment. Finally, clarity should also be provided as to how this applies where an
underground bin system is in place.

The contributions set out in paragraph 17.21 in relation to Household Recycling Centres
requires further definition as to the basis for any financial contributions and what these amounts
could be.

Comment

Representation ID: 200379

Received: 24/01/2025

Respondent: University of Cambridge

The chapter is too vague with respect to the nature and scale of potential contributions. For
very large scale development physical provision of infrastructure, such as ambulance or fire
stations may meet the Community Infrastructure Levy Regulations 2010 (as amended)
Regulation 122 tests (where a costed project plan is provided) but the general funding of
emergency services (requests for revenue funding of any type, or, for example, police
cars/uniforms) are not acceptable uses of planning obligations. This text needs to be revisited.

Comment

Representation ID: 200380

Received: 24/01/2025

Respondent: University of Cambridge

Paragraph 19.10 refers to having Skills and Employment Plans approved 3 months prior to the
implementation/commencement of development. This is a very early trigger and if everything
else was in place for development to begin (i.e. the discharge of relevant planning
conditions/obligations), we see no reason why a development should be delayed by a further
3 months. This will harm the delivery of schemes. The trigger for approval should relate to the
commencement of development or any other suitable trigger as agreed on a case by case
basis through planning application discussions. The text should be amended to reflect this.

Within paragraph 19.16, the requirement for 1 apprenticeship per 1,000 sqm of employment
space could be appropriate for a higher employment density uses such as office or retail, but
is not likely to be achievable for lower density uses such as logistics, datacentres,
manufacturing etc. A variation for lower density uses should be reflected in the text.