Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
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Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Chapter 2: Approach to Planning Obligations
Representation ID: 200270
Received: 24/01/2025
Respondent: Abbey Properties Cambridgeshire Limited
The monitoring fees in paragraph 2.38 appear excessive with the potential for a 10 unit residential scheme to be faced with monitoring costs of £5,000 which would not be proportionate. Further justification should be provided for these costs - particularly in the context of the substantial planning application fee increases which are due to take place in April 2025.
The monitoring fees in paragraph 2.38 appear excessive with the potential for a 10 unit residential scheme to be faced with monitoring costs of £5,000 which would not be proportionate. Further justification should be provided for these costs - particularly in the context of the substantial planning application fee increases which are due to take place in April 2025.
Object
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Chapter 5: Green Infrastructure
Representation ID: 200271
Received: 24/01/2025
Respondent: Abbey Properties Cambridgeshire Limited
Paragraph 5.7 suggests that this would apply to all residential and commercial developments regardless of their scale. There is no stated commercial formula to work out the contribution. It seems excessive to also seek contributions from single or minor scale new dwellings and therefore the threshold should relate to major development. By introducing a S106 requirement for minor scale development this will slow up the planning process for those applications and potentially reduce delivery for small and medium sized developers.
Paragraph 5.7 suggests that this would apply to all residential and commercial developments regardless of their scale. There is no stated commercial formula to work out the contribution. It seems excessive to also seek contributions from single or minor scale new dwellings and therefore the threshold should relate to major development. By introducing a S106 requirement for minor scale development this will slow up the planning process for those applications and potentially reduce delivery for small and medium sized developers.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Chapter 4: Affordable Housing
Representation ID: 200272
Received: 24/01/2025
Respondent: Abbey Properties Cambridgeshire Limited
In relation to smaller scale major developments there is a significant issue presently around the delivery of Section 106 housing through registered providers (RP) with many sites unable to contract with an RP. Review mechanisms need to be considered and built in to S106 Agreements. I have attached the BHF Bid Farwell publication which sets the scene and suggests solutions. In order to deliver small and medium scale housing schemes flexibility is required.
In relation to smaller scale major developments there is a significant issue presently around the delivery of Section 106 housing through registered providers (RP) with many sites unable to contract with an RP. Review mechanisms need to be considered and built in to S106 Agreements. I have attached the BHF Bid Farwell publication which sets the scene and suggests solutions. In order to deliver small and medium scale housing schemes flexibility is required.
Object
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Chapter 7: Community Facilities
Representation ID: 200273
Received: 24/01/2025
Respondent: Abbey Properties Cambridgeshire Limited
The contribution is to be sought from all residential developments, mixed-use and major commercial developments. There is no stated formula for commercial developments. Applying a contribution to non-major housing schemes is considered to be inappropriate. This will delay planning applications and undermine delivery of schemes. The requirement should only apply to major housing proposals.
The contribution is to be sought from all residential developments, mixed-use and major commercial developments. There is no stated formula for commercial developments. Applying a contribution to non-major housing schemes is considered to be inappropriate. This will delay planning applications and undermine delivery of schemes. The requirement should only apply to major housing proposals.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Chapter 8: Social and Community Support Services
Representation ID: 200274
Received: 24/01/2025
Respondent: Abbey Properties Cambridgeshire Limited
The threshold for contributions is again relative to all residential development and there is no formula for residential or commercial proposals. It is noted that the draft Health Impact Assessment applies (in South Cambs) to a threshold of 20 + dwellings. This would be an appropriate level at which to potentially seek contributions. Otherwise smaller non-major housing schemes will face significant constraints to delivery owing to this and other financial contribution requirements.
The threshold for contributions is again relative to all residential development and there is no formula for residential or commercial proposals. It is noted that the draft Health Impact Assessment applies (in South Cambs) to a threshold of 20 + dwellings. This would be an appropriate level at which to potentially seek contributions. Otherwise smaller non-major housing schemes will face significant constraints to delivery owing to this and other financial contribution requirements.
Object
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Chapter 9: Libraries and Lifelong Learning
Representation ID: 200275
Received: 24/01/2025
Respondent: Abbey Properties Cambridgeshire Limited
The approach appears to relate to all scales of residential development which is inappropriate in our view. There is also no formula or indication of the level of contribution that may be sought. Seeking contributions from non-major housing schemes will delay the determination of applications and undermine delivery.
The approach appears to relate to all scales of residential development which is inappropriate in our view. There is also no formula or indication of the level of contribution that may be sought. Seeking contributions from non-major housing schemes will delay the determination of applications and undermine delivery.
Object
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Chapter 13: Burial Space
Representation ID: 200276
Received: 24/01/2025
Respondent: Abbey Properties Cambridgeshire Limited
This contribution is inappropriate in all regards. There can be no direct correlation between new development and burials: for instance it is very possible that burials would take place in other locations - i.e. alongside other family members. The requirement to deliver new burial grounds within large new strategic locations is supported. Adding yet a further contribution to small housing schemes is inappropriate. The correlation between the figures is not clear particularly given the likely percentage of cremations.
This contribution is inappropriate in all regards. There can be no direct correlation between new development and burials: for instance it is very possible that burials would take place in other locations - i.e. alongside other family members. The requirement to deliver new burial grounds within large new strategic locations is supported. Adding yet a further contribution to small housing schemes is inappropriate. The correlation between the figures is not clear particularly given the likely percentage of cremations.
Object
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Chapter 14: Public Open Space
Representation ID: 200294
Received: 24/01/2025
Respondent: Abbey Properties Cambridgeshire Limited
The contributions should apply to major housing developments only. The scale of the contributions for minor housing developments will be significant and is likely to deter development from taking place. The scale of the contributions would severely impact the viability of new developments and, for those schemes that do proceed, would be likely to increase the sale or rental costs.
The contributions should apply to major housing developments only. The scale of the contributions for minor housing developments will be significant and is likely to deter development from taking place. The scale of the contributions would severely impact the viability of new developments and, for those schemes that do proceed, would be likely to increase the sale or rental costs.
Object
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Chapter 15: Indoor Sports, including Swimming
Representation ID: 200301
Received: 24/01/2025
Respondent: Abbey Properties Cambridgeshire Limited
These contributions appear to be a 'double dip' as the home occupier then has to pay to use the new or improved facilities. These facilities are commercial enterprises as it is not a developers fault if the facility has not been improved or extended. There may be some justification for contributions from larger strategic scale schemes. This would further jeopardise small and medium scale developments.
These contributions appear to be a 'double dip' as the home occupier then has to pay to use the new or improved facilities. These facilities are commercial enterprises as it is not a developers fault if the facility has not been improved or extended. There may be some justification for contributions from larger strategic scale schemes. This would further jeopardise small and medium scale developments.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Chapter 18: Emergency Services
Representation ID: 200302
Received: 24/01/2025
Respondent: Abbey Properties Cambridgeshire Limited
Please consider two High Court decisions were The University Hospitals of Leicester NHS Trust, R (On the Application Of) v Harborough District Council [2023] EWHC 263 (Admin) (“the Leicester NHS Trust”) and Worcestershire Acute Hospitals NHS Trust, R (On the Application Of) v Malvern Hills District Council & Ors [2023] EWHC 1995 (Admin) (“the Worcestershire NHS Trust”). Both suggest that NHS S106 contributions are not lawful.
Please consider two High Court decisions were The University Hospitals of Leicester NHS Trust, R (On the Application Of) v Harborough District Council [2023] EWHC 263 (Admin) (“the Leicester NHS Trust”) and Worcestershire Acute Hospitals NHS Trust, R (On the Application Of) v Malvern Hills District Council & Ors [2023] EWHC 1995 (Admin) (“the Worcestershire NHS Trust”). Both suggest that NHS S106 contributions are not lawful.
