Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Comment

Representation ID: 200571

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

Regarding paragraph 2.26 it is not considered reasonable or unlawful to link contributions to the date of the committee resolution or the consultation date identifying the contribution amounts. It is requested that this sentence is removed from the SPD.

Comment

Representation ID: 200572

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

Paragraph 4.14 deals with BTR schemes. In the second bullet point it states "a minimum of 20% homes in BTR development of 10 or more will be required to be provided as Affordable to Private Rent. The Councils will seek to achieve a higher percentage than this wherever possible. A similar point is made in the fourth bullet point.

The SPD currently provides no guidance as to when and on what basis, a higher percentage may be sought.

Paragraph 4.21- The council should clarify that it will not seek nomination for BTR schemes but it will be the BTR provider.

Comment

Representation ID: 200573

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

Paragraph 7.18- states the starting point for the negotiation of faith space is 0.5 hectares of free or heavily discounted land per 3,000 dwellings. The evidence base for this dates back to 2008 and therefore we suggest that this in not likely to represent the most up to date guidance. It is also considered that this requirement should be based on on an identified level of need in a geographical area rather than an arbitrary requirement.

Paragraph 7.19- the terminology 'pump priming contributions' should be explained in the supporting text.

Paragraph 7.22- Is a broad requirement and there appears to be no evidence to support such an obligation. CLP policy 73 does not mention community support workers. Therefore, the necessity of this obligation should therefore be reviewed and justified against the criteria set out in Regulation 122.

Paragraph 7.23 - Regarding small grants schemes, it is considered that this is a broad requirement that may not be specific to mitigating the effects of a development on a particular site. Evidence for the planning obligation does not appear to be contained within adopted policy wording.

Paragraph 7.27- states the cost of providing and maintaining community facilities. It is unclear how these figures as well as community facilities by dwelling size table have been derived.

Comment

Representation ID: 200574

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

Regarding paragraph 9.8, it states that new housing development will have implications for the existing library provision they may require certain developer contributions. In the list of provisions that are given it is unclear whether the requirements are mutually exclusive. For example, if a new library building is provided, is the library fit out and new stock also required?

We request a greater narrative is provided on this matter to improve developer expectations and improve transparency.

Comment

Representation ID: 200575

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

Regarding paragraph 10.20, it is requested that the wording relating financial penalties and imposing a hold on development is deleted.

Paragraph 10.24 - There is a lack of transparency over how this cost will be calculated. In the case of one of the representors developments at Orchard Park, the County Council had to devise a bespoke calculation without any proper or rational policy basis or guidance. There is a need for more evidence around how these contributions will be sought.

Comment

Representation ID: 200576

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

In paragraph 11.12, it states that “other contributions may be sought towards temporary accommodation or school travel”.

This appears to be a “catch-all” clause and it has to be queried if this meets the reasonable tests within regulation 122. There needs to be evidence to support these potential obligations within the draft SPD.

Comment

Representation ID: 200577

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

Regarding Paragraph 12.12, the principle that a 1% public art value is not appropriate for setting budgets on large major sites is supported. It is not considered that such a contribution would, in any event, meet the Regulation 122 test as being necessary to make the development acceptable in planning terms and is not directly related to the development, therefore it cannot be considered reasonable. Furthermore, it is not possible to tell how the 1% gross development cost has been calculated therefore this fails the Regulation 122 test of being reasonably related in scale and kind to the development.

Comment

Representation ID: 200578

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

Regarding Paragraph 13.7, it is queried how the threshold of 200 dwellings was arrived at as it seems low.

In Paragraph 13.11, it provides the burial sites contributions by dwellings size, it is queried how these dwellings by size have been formulated and what evidence was used to calculate the cost. This needs to be fully evidenced as required by Regulation 122.

Comment

Representation ID: 200579

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

Regarding Paragraph 18.5, the draft SPD is vague on how contributions will be sought and this should be made much clearer. As, written, it is queried if the SPD meets the statutory tests. Unless the wording can be strengthened, the requirement should be deleted.

Comment

Representation ID: 200580

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

Regarding Paragraph 20.11, It is not clear what is being asked for here. A comparison to London is provided but London is a different marketplace with different rent levels, supply and demand. There does not appear to be a
local policy basis to ask for a contribution in relation to affordable workspace and therefore it is questioned whether the planning obligation meets the Regulation 122 tests.