Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Comment

Representation ID: 200381

Received: 24/01/2025

Respondent: University of Cambridge

We do not consider that affordable workspace requirements, which will
have financial implications for schemes (in some cases significant), can be introduced through
an SPD. This is introducing a new policy which SPDs cannot do as set out in National Planning
Practice Guidance (Paragraph: 008 Reference ID: 61-008-20190315)

On a large scale employment development, 10% of space could equate to millions of pounds
worth of opportunity cost, with significant impacts on development deliverability.

This section of the SPD should be removed and if an affordable workspace policy is pursued,
it should be done so through the emerging Greater Cambridge Local Plan where its impact on
development viability can be evidenced.

Comment

Representation ID: 200382

Received: 24/01/2025

Respondent: University of Cambridge

Important for the SPD to recognise that new development cannot be required to make good existing deficits in provision. Paragraph 22.15 states that there are issues related to the general background population growth, the ageing population and an estate that is no longer fit for purpose. While these pressures are all valid, resolving them is not the responsibility of land owners or developers.

Paragraph 22.19 states that strategic-scale proposals may be required to contribute to acute, mental health or community health provision. These are strategic level services, funded at a National Level by the NHS. They do not meet the Regulation 122 tests of necessity and there
is caselaw which supports this position. Reference to these services should therefore be removed.

The typical approach to calculation of GP need is with respect to number of GPs rather than sqm. We acknowledge that the changes in service delivery methods may mean that sqm is a more useful metric in some cases. If demand is to be based on sqm, then the Integrated Care System should publish up to date data on the size of the existing estate so that the developer is able to undertake this assessment and so the overall approach is evidenced and transparent.

Average household size of 2.4 people set out in paragraph 22.29 is a useful starting point, there should be flexibility in the formula to consider population calculations for specialist housing or different housing typologies.

Comment

Representation ID: 200387

Received: 24/01/2025

Respondent: University of Cambridge

The average household size, and in particular the number of children per household, tends to
differ significantly between houses and flats. There are situations where good design and
setting can make flats relatively more attractive to families with children but on average the
trend applies across the UK. As such a distinction should be made between houses and flats
and this should be incorporated into the Appendix.

Comment

Representation ID: 200415

Received: 24/01/2025

Respondent: University of Cambridge

Paragraph 22.37 requires flexibility with respect to the potential mitigation strategy. We accept that some degree of flexibility is required but an obligation that does not have any restriction on where and how funds will be spent to ensure that they are directly related to the development does not meet the Regulation 122 tests.

Paragraph 22.40 confirms that the suggested sqm benchmark includes the full capital cost of
construction. It should however also state whether this includes site levelling and servicing,
which is often done by the developer ahead of land transfer and should be discounted from
any further capital contribution.

Paragraph 22.43 states that the service needs to be viable, and this could affect lease terms.
If a building is to be let to the NHS, then this space should pay a rent in accordance with the
district valuation. This should be made clear in the paragraph.

Comment

Representation ID: 200530

Received: 24/01/2025

Respondent: University of Cambridge

There is no source provided for many of the costs set out in the document and it would be helpful and transparent for this to be provided. The costs listed need to be explicit about what they include or exclude, for example fixtures, fittings and furniture, so that additional costs are not levied in addition if not required. This appears in some cases but not all.