Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

This section of the SPD is based on Cambridge Local Plan Policies 10, 56 and 59 and South Cambridgeshire Local Plan Policy HQ1, along with their District Design Guide SPD. The SPD suggests that planning obligations will be sought from all development, and that S106 agreements could be used for a variety of on-site and off-site public realm improvements including improving footways, street furniture, lighting or removal of street clutter, applicants will also need to demonstrate that public realm measures are suitably managed in perpetuity.

The HBF considers that most public realm measures will be provided as the new residential development is provided and it is considered unlikely that further provision should be considered necessary. It is also considered that the Council should be working closely with the development industry to ensure that these public realm schemes are adopted and therefore there should not be any ongoing maintenance costs for these measures. Therefore, the HBF considers that this section of the SPD is not needed and should be deleted.

This section of the SPD is based on Cambridge Local Plan Policy 28 and 85, South Cambridgeshire Policy HQ1 and TI/8 and Cambridgeshire and Peterborough Minerals and Waste Local Plan Policy 14. The SPD suggests that planning obligations will be sought from all development, and that there is a cost to issue bins for new properties (£90 per dwelling), a cost in relation to the provision of refuse collection vehicles (£112 per dwelling) and a cost in relation to the provision of household recycling centres.

The HBF considers that it will be important to ensure that these requirements are viable and deliverable and do not prevent or stall delivery of homes.

This section of the SPD is based on Cambridge Local Plan Policy 85 and South Cambridgeshire Local Plan TI/8. The SPD suggests that planning obligations will be sought from all development, and that contributions will be dependent on the size and scale of the proposal. The HBF would query what evidence the Council have to support this proposal for funding for the emergency services, is there evidence of a capacity issue or a funding gap created by new development in the area.

This section of the SPD is based on a strategic objective in the Cambridge Local Plan to assist in the creation and maintenance of inclusive, environmentally sustainable communities, and text within the South Cambridgeshire Local plan to ensure that all new development provides or has access to a range of services and facilities that support healthy lifestyles and well-being for everyone. The SPD suggests that planning obligations will be sought from all residential development, with major developments encouraged to contribute towards the provision of skills and employment opportunities for local residents through the provision and implementation of an Employment and Skills Plan.

The HBF is concerned that there are no policies in either Plan in relation to this requirement, and therefore, this is not in line with the NPPF or the PPG. The HBF is also concerned that this means that this requirement has not been tested at examination and the impact of this requirement on the delivery of development has not been considered. The HBF considers that it is also unlikely that the impacts of this requirement have been considered in terms of viability.

Increasing the number of people working within the construction workforce, and the skills and diversity of this workforce, is a top priority for the HBF. The construction workforce is ageing, and is facing critical shortfalls in many trades, such as bricklaying and ground working. Our work in this area, is managed by the HBF's Home Building Skills Partnership (HBSP), we work closely with home builders, the supply chain companies and industry training bodies to address common challenges in recruiting and developing the workforce. The HBSP’s focus stretches beyond traditional training and upskilling to include equality, diversity and inclusion, and employee wellbeing initiatives. This is delivered under two core workstreams: talent attraction and skills and development. A genuine strategic approach is needed to improve the training of people in the construction trades. This includes an evaluation of the future skills needs of employers, and an evaluation of the quality of the training that is available through colleges. Without this essential basic assessment, any skills initiative devised by the Councils represents a waste of public and private resources. The HBF’s Home Building Skills Partnership would welcome the opportunity to discuss the construction skills needs of the area with the Council, this would likely be more beneficial than the currently proposed policy.

This section of the SPD is based on the Cambridge Local Plan Policies 5, 80 and 81, and South Cambridgeshire Local Plan Policy HQ/1 and TI/2. The SPD suggests that planning obligations may be sought from any development, and these may be sought on-site as part of the development works to secure new rights of way over the proposed development site or for the upgrade of existing routes. It also suggests that financial contributions may be appropriate where necessary to establish better links / connections between new and existing routes on site. The HBF is concerned about the lack of detail provided in relation to this requirement, it is not apparent under what circumstances developments may be required to establish better links to new and existing routes or to the wider network, or as to how long these new connections may expected to be and therefore what the costs may be.

This section of the SPD is based on Policy 75 and 85 of the Cambridge Local Plan and Policy SC/4 of the South Cambridgeshire Local Plan. The SPD suggests that planning obligations will be sought from residential development of all tenures. The SPD states that new residential development will be required to mitigate its impact on health infrastructure, and that the type of provision and associated financial contributions required will be determined on the needs generated by the development and the existing capacity of impacted health infrastructure. All major development will be required to assess their impact on primary health infrastructure within the health care catchment of the proposed development.

The HBF is concerned with the overly simplified assumption within this section of the SPD that new housing developments increase the total number of patients that need primary care in a localised area. This may not always be the case, this very much depends on where people are moving to and from and potentially the reason for the move. It may be that only a small number of households are actually moving from outside of the area, and therefore a simple calculation of the total population of the newly built homes may significantly over estimate the health requirements. The HBF is also concerned by the assumption in paragraph 22.28 which states that if the baseline position is that the existing primary care infrastructure does have capacity to accommodate the additional population growth caused by the development a contribution will be required. The HBF hopes this is a typographical error and it should be if the primary care infrastructure does not have capacity, otherwise the HBF considers this requirement highly inappropriate. As with other requirements the HBF remains concerns about the resources required to undertake this planning obligation, the resources required to identify the appropriate evidence, to undertake the calculation and to actually provide the provision. The HBF considers this has potential to significantly impact on the viability and deliverability of homes.

This section of the SPD then suggests that the previous sections of the SPD may not represent all of the possible planning obligations requirements that may be applicable to any individual development. It then lists some additional potential planning obligations these include community, sports or leisure or open space facilities; impacts on the historic environment; pollution, air quality, noise or odour mitigation measures; sustainable drainage systems; sustainable show homes; and digital infrastructure.

The HBF is concerned that there are further potential planning obligations that may be required from development, that are not detailed in this policy or the Plan. This does not make it straightforward for the development industry to factor these costs into their land purchases or their consideration of the costs of development. This lack of certainty can be a real issue for developers, and may lead to delays in development coming forward

This section of the SPD explains the Council’s approach to the delivery of affordable housing and expands on the policies in the Cambridge City Local Plan (Policy 45) and the South Cambridgeshire Local plan (Policy H10 and H11). The HBF notes that the SPD states that the affordable housing policies will apply to schemes for specialist housing (such as extra care, retirement homes, residential and / or nursing care, care suites, or smaller group homes. It also states that the affordable housing policies apply to Build to Rent schemes. The HBF considers that the viability of these requirements should be evidenced and ensured.

The SPD notes that the Local Plan policies do not set out an expected tenure split, however, the SPD will seek a tenure split that sees 75% of the 40% affordable housing requirement to be Affordable / Social Rent. And on sites above 15 homes at least 10% of that 75% is expected to be allocated for Social Rent. The HBF considers that it will be important to ensure that this proposed tenure split is viable and developable. It will also be important for the Councils to work closely with local registered providers to ensure that these requirements are in line with their plans in the area.

With regard to phased development paragraph 4.30 states “The Councils may require phased developments to submit a viability assessment if during any phase of the development, the amount of affordable housing being delivered during that phase decreases…” HBF do not disagree, but additional guidance should be added for completeness to address phased developments which provide increased affordable housing in an earlier phase to allow for a reduction in another.

The SPD suggests that the Council’s expectations on the affordable housing mix by bedrooms as a starting point, is set out in Tables 2 & 3 of Annex 2 of the Greater Cambridge Housing Strategy 2024-2029. The suggested mix is not included in the SPD, and it is not apparent how it will be kept up to date should new evidence from monitoring or a housing needs assessment indicates that these are no longer correct. HBF suggest a new paragraph is introduced stating that the suggested mix in Annex 2 of the Cambridge Housing Strategy will apply unless sufficient evidence demonstrates a different appropriate mix should be provided and that the mix will be agreed in consultation with the Local Planning Authority (LPA).