Greater Cambridge Local Plan: Proposed Submission

Additional housing allocations will be required within the Local Plan to serve delivery in the first 10 years
to ensure the monitoring framework remains robust and fit for purpose.
One such site that would be suitable to consider as a deliverable site within the Rest of the Rural Area is
Land to the south of Station Road, Harston (HELAA 2026 Ref: 115742). Harston is considered a suitable
location for further residential development to support an existing rural community. The site is considered
to represent a sustainable location for development which will help to meet the housing needs of Greater
Cambridge in Local Plan period. Land to the south of Station Road, Harston (HELAA 2026 Ref: 115742)
will ensure a balanced, diverse and varied supply of housing stock to provide resilience to the Authority’s
supply over the forthcoming plan period, especially during the first 10 years of the plan period.

Jesus College object to Policy S/MO. The policy is unsound as it is not effective.
The draft policy sets out an 8-point mechanism with further details in Appendix E for dealing with under
delivery of housing allocations in the plan. The policy requires the two Councils to monitor the
implementation and performance of the Local Plan against the monitoring indicators set out in the
monitoring framework, set out in Appendix E: Monitoring Framework. However, results will be reported
on annually which is not reactive enough to deal with under delivery. This is clearly illustrated by the
current number of speculative planning applications and appeals taking place in the authority area
because the current adopted local plan allocations are not delivering in a timely manner. The policy
states –
‘If, through monitoring, it appears that policies and allocations are not being achieved, the following
mechanisms will be triggered:
  a. Review of housing and employment land supply and allocations;
  b. Action to bring forward sites for development, wherever possible in partnership with landowners and
developers;
  c. Action to bring forward development on previously developed land;
  d. Action to secure the timely provision of infrastructure;
  e. Review of all, or relevant parts of, the Local Plan;
  f. Review Development Management processes; or
  g. Consider undertaking cooperation with other local authorities, including through duty to cooperate. ’
The above mechanisms will not lead to housing delivery in a timely manner as proven by current
applications and appeals. Thus, the GCLP should allocate a number of sustainable and deliverable
housing sites in the local plan to serve delivery in the first 10 years of the Plan due to the envisaged lack
of delivery on the very large allocations in the Plan which require significant infrastructure to deliver them.

The Important Countryside Frontage designation affecting land south of Station Road, Harston should be removed.

Jesus College object to Policy GP/LC. The policy is unsound as it is not justified.
Part 2 of the Policy states that “Important Countryside Frontages (ICFs) are identified on the Policies
Map and are in villages where land with a strong countryside character either:
a. Penetrates or sweeps into the built-up area providing a significant connection between the built
environment and the surrounding rural area; and
b. Provides an important rural break between two nearby but detached parts of a defined development
extent.”

Part 3 of the Policy then states that “Planning permission for development will be refused if it would
compromise these ICF purposes.”

An extract of the Policies Map as it relates to Land south of Station Road, Harston is shown in the attached representation letter.

Jesus College do not consider the Important Countryside Frontage designation to the south of Station
Road in Harston is justified. The existing two-metre tall evergreen hedge along the length of the Station
Road frontage can be retained and managed as part of any development proposal, with the exception of
two small sections to be removed in order to accommodate access. This hedge already acts as a natural
barrier to the countryside frontage and the loose grain of development and low density proposed will also
enable views of the open countryside beyond to be retained from Station Road. As such, residential
development on Land to the south of Station Road, Harston could be brought forward without
compromising the purposes of Important Countryside Frontages, in terms of ‘providing a significant
connection between the built environment and the surrounding rural area’ and ‘providing an important
rural break’.

In order to overcome the issues highlighted within these representations and progress a sound Local
Plan, it will be necessary to:
i. Reassess the plan period supply and the deliverable supply to account for the fact that only
specific sites rather than a windfall allowance can be included in years 1-5 as set out in
paragraph 72a of the NPPF.
ii. Remove sites from the plan period supply where the evidence demonstrates that there is no
intention to bring these forward for residential uses.
iii. Reassess the plan period supply and the deliverable supply to reflect realistic delivery rates at
Northstowe, Cambridge East (airport) and Waterbeach New Town.
iv. Complete the Housing Land Supply Evidence templates of the Planning Inspectorate for each of
these sites included in the deliverable supply, and if necessary, adjust the supply accordingly
including for example where there is no evidence that completions will be achieved.
Having undertaken the preceding work as required by national policy and guidance, it is inevitably the
case that the supply of the GCLP falls very substantially short of providing for a sufficient supply, given
that even with the benefit of the doubt there is:
i. A supply of at most 46,687 homes over the plan period in response to the proposed insufficient
housing requirement of 49,068 homes and the economic need for at least 59,409 homes
identified by the CPCA and
ii. A deliverable supply of at most 11,005 homes over the period 2028-33 in response to the
requirement for either 12,472, 13,562, 15,974 or 18,665 homes depending on whether the
housing requirement reflects economic needs and whether the Liverpool or Sedgefield approach
is applied.
As such, in order to be found sound the GCLP will need to identify additional allocations to deliver a
substantial number of additional homes including to:
i. Meet the economic need for at least 59,409 homes as identified by the CPCA – this requires the
identification of additional allocations which will deliver 12,722 homes over the plan period
without any allowance for headroom.
ii. Provide sufficient headroom (20%) to ensure that the full objectively assessed need is met as
required by paragraphs 11 and 23 of the NPPF – this requires the identification of additional allocations which will deliver 10,996 more homes over the plan period to meet even the
proposed insufficient housing requirement or 24,604 homes to meet the economic need with a
20% headroom.
iii. Provide for a sufficient supply of specific deliverable sites as required by paragraph 72 of the
NPPF – this requires the identification of additional allocations to deliver either 1,467, 2,557,
4,969 or 7,660 more homes from 2028-33 depending on whether the proposed insufficient
housing requirement or a requirement which supports economic growth is found sound and
whether the Liverpool or Sedgefield approach is supported.
The scale of the insufficiency of the supply in the GCLP is truly exceptional by reference to that which
has arisen in other Local Plans. As such, significant additional work will be required prior to the
submission of the GCLP to identify the necessary additional allocations in order for the GCLP to be found
sound.
One such site that would be suitable to consider as a deliverable site within the Rest of the Rural Area is
Land to the south of Station Road, Harston (HELAA 2026 Ref: 115742). Harston is considered a suitable
location for further residential development to support an existing rural community. The site is considered
to represent a sustainable location for development which will help to meet the housing needs of Greater
Cambridge in Local Plan period. With the right design, including a suitable layout and design concept,
the proposed development on the site could be accommodated without having a significant impact on the
surrounding landscape setting.

Paragraph 1.6 of the Sustainability Appraisal (2026) (‘SA’) states ‘Developing options for a plan is an
iterative process, involving a number of consultations with stakeholders and the public. The SA process
can help to identify where there may be other ‘reasonable alternatives’ to the options being considered
for the policies to be included in a plan.’ These options are explained and their effects summarised in
Chapter 4 of the full SA report.
Paragraph 2.10 of the SA states ‘The SA findings are not the only factors taken into account when
determining a preferred option to take forward in a plan. Indeed, there will often be an equal number of
positive or negative effects identified for each option, such that it is not possible to ‘rank’ them based on
sustainability performance in order to select a preferred option. Factors such as public opinion,
deliverability and conformity with national policy will also be taken into account by plan makers when
selecting preferred options for their plan.
It is clear is that the proposed Development Strategy underpinning the Regulation 19 Local Plan is not a
sufficiently robust development strategy which positively plans for housing delivery in the first 10 years or
so of the plan period. This is because the strategy relies very heavily on the deliverability of two very
large strategic sites at Cambourne North and Grange Farm, between them accounting for 5,100
dwellings in the plan period, which are very likely to be delayed due to the significant infrastructure
required to deliver the housing numbers. Indeed, in a site-specific sense, Grange Farm represents a late
allocation entry (due to the Cambridge Waste Water Treatment Works de-allocation) jumping the Green
Belt into open countryside. As such, Grange Farm has poor public transport connectivity beyond the A1
and senior councillors have expressed concerns about the potentially very high number of car-generated
trips expected due to the divorced nature of site from the planned Travel Hub south of Babraham village.
The Infrastructure Delivery Plan states a ‘Shuttle / commuter services connecting Grange Farm to nearby
campuses and railway stations will be essential’ to service this site. It is further noted the Housing
Delivery Study Addendum (2026) identifies Phase 2 of CSET is essential for the delivery of Grange Farm
(3.2.66). It notes that the timescales for delivery and phasing of CSET are still being discussed and that
the conclusion of these discussions will dictate when a full site build-out to align with typical assumptions
can be achieved. It is therefore considered the Development Strategy as currently proposed relies
significantly on assumptions on the timely delivery of infrastructure which given the ongoing difficulties
with the delivery of Cambourne to Cambridge (C2C) is high risk.

In order to overcome the issues highlighted in this representation and progress a sound Local Plan, it will
be necessary to utilise more optimistic and realistic figures for job and housing numbers and include
explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound
and inconsistent with national policy objectives to support sustainable economic growth and productivity

Jesus College object to Policy S/JH. The policy is unsound as it is not positively prepared, not justified,
not effective and inconsistent with national policy.

In terms of the policy context, paragraph 69 of the NPPF (2024) is clear that Authorities need to plan for
higher levels of growth than the Standard Method requirement to reflect growth ambitions linked to
economic development and infrastructure investment. Furthermore, paragraph 86(d) of the NPPF (2024)
confirms that planning policies should seek to address potential barriers to investment, such as
inadequate infrastructure, services or housing, or a poor environment. The draft Plan does not do this.
This need for growth is evidenced by national, regional and authority level investment in infrastructure
including the new Cambridge South Railway Station providing direct connectivity between Cambridge Biomedical Campus (CBC) and London, the granting of the Cambourne to Cambridge busway and
progression of Cambridge South East Transport (CSET) to inquiry later this year. In a national context,
the commitment to East West Rail establishes the area as one benefiting from continued investment in
major transport infrastructure. Growth envisioned by Government is set to be realised and delivered by
the Greater Cambridge Development Corporation set to deliver infrastructure first growth. We contend in
order to ensure the Plan is found sound the unique nature of Cambridge and its projected capacity for
growth must be realised within the emerging Local Plan.

The fact that the GCLP is not planning for the level of growth necessary to support the economic
ambitions of the Local Growth Plan, which align with the economic objectives of the government is
underlined by the fact that the Employment and Housing Needs Update (EHNU) (2026) does not even
consider the Oxford Cambridge Arc or the Local Growth Plan. Instead, it has been developed on the
basis of standard economic forecasts which are inevitably trend-based and so do not account for
economic potential of the area as is necessary to align with local and national economic ambitions. The
EHNU draws its conclusions and jobs and housing needs from the ‘central growth’ scenario with the
‘higher growth scenario’ dismissed. However, it is noted the EHNU notes that the higher scenario could
be achieved with step change in investment.

Rightly the EHNU draws a relationship between job growth and housing need, on the basis that greater
job growth in the region will generate a derived demand for housing, creating an interdependency
between the two. The ‘central growth scenario,’ as outlined within the EHNU, builds in assumptions of
slower periods of growth, contractions, and economic shocks. Inherently both the number of jobs and
homes proposed within the Proposed Submission Plan are conservative rather than reflective of the full
growth potential of the Greater Cambridge economy.

With the advent of the Greater Cambridge Development Corporation (backed by £400 million of central
government funding) and renewed commitment to delivery of growth in the Oxford – Cambridge Growth
Corridor there is clear rationale for the Authority to reasonably adopt the high growth scenario.
Furthermore whilst the Authority have met their identified needs for housing via the Standard Method it is
acknowledged the Standard Method does not take into account the specific growth agenda and focus on
Cambridge as an area of ‘supercharged growth’.

It is evident that committed and future infrastructure projects in Greater Cambridge continue to confirm
Cambridge’s position as an area capable of supporting and delivering high growth. Within this context
Cambridge remains a priority of the incumbent Labour government to deliver ‘supercharged growth’. The
Employment and Housing Needs Update acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby
growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in
Cambridge and would support the Government’s direction of travel. It is therefore important to recognise
that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision
to the proposed policy wording.

We also note the Regulation 18 version of the emerging Local Plan required 2,463 dwellings per annum
to deliver employment growth of 66,000 jobs compared to the Regulation 19 version which required
delivery of 2,292 dwellings per annum to deliver 73,200 jobs across the plan period; representing a
decrease in housing delivery whilst reflecting an increase in job creation. The EHNU reasons this in
stating the fact that average household sizes are now larger, leading to an increase in people of working
age and more in-commuting which reduces the number of local people required to fill jobs created. We
raise concern this is an unsustainable approach to development strategy and reflects a local housing
market where many young people are unable to move out of their family homes and move closer to or
within Cambridge where jobs are located at key existing and development employment centres such as
CB1, Cambridge Biomedical Campus and Cambridge Science Park. We advocate the Plan needs to address the affordability of housing within Greater Cambridge by planning for increased growth and
supply to reflect growing demand rather than embed the issue of increasing household size.
In doing so and making provision for increased housing stock in Greater Cambridge in sustainable
locations would ensure the Local Plan promotes more suitable patterns of travel as required by
paragraph 111 of the NPPF (2024) using planning polices to minimise the length of and journeys
required for employment.

In order to overcome the issues highlighted in this representation and progress a sound Local Plan, it will
be necessary to utilise more optimistic and realistic figures for job and housing numbers and include
explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound
and inconsistent with national policy objectives to support sustainable economic growth and productivity.

Jesus College object to Policy S/DS: Development Strategy. The policy is unsound as it is not consistent
with national policy.
As referred to in representations to Policy S/JH, the identified needs in the Plan are considered too
conservative and do not reflect the growth agenda in national, regional and local contexts mandated by
the incumbent Labour Government. With the advent of the Greater Cambridge Development Corporation
(backed by £400 million of central government funding) and renewed commitment to delivery of growth in
the Oxford – Cambridge Growth Corridor there is clear rationale for the Authority to reasonably adopt the
high growth scenario. Collectively, it remains apparent therefore that the Government have a continued
agenda to deliver high levels of growth within Greater Cambridge and as such more optimistic and
realistic figures for job and housing numbers are needed to support sustainable economic growth and
productivity.
Furthermore, the development strategy relies too heavily on large allocations which in turn risks a lack of
delivery in the first 10 years of the Plan due to the significant infrastructure required to service the very
large allocations. This problem is highlighted in paragraph 2.76 of the Plan where the text acknowledges
that it must ‘ensure a deliverable plan but which is reliant on a significant level of infrastructure’. Senior
Councillors at Cabinet have also expressed their concerns to officers that this strategy is a risky one to
adopt.
In particular, the Plan relies on two very large allocations set out under 2(c) i Cambourne North (2550
dwellings in plan period) and 2(c) ii Grange Farm (2550 dwellings in the plan period) which relies on
significant infrastructure (namely Cambourne Railway Station to be delivered as part of East West Rail
and CSET respectively) coming forward in a timely manner to service these two large strategic sites.
Further ambiguity is compounded at paragraph 2.80 of the Plan to the strategy as the Cambridge
Wastewater Treatment Works still makes an appearance as a potential development site even though
Government funding for the project has been cancelled by Government.

Part 6 (a) should be deleted from the policy.

Jesus College object to Policy CC/IW. The policy is unsound as it is not justified.
Part 6a of the policy states development must demonstrate that there is capacity for waste water
treatment and adequate wastewater conveyancing infrastructure to support the whole development.
Jesus College does not consider this approach to be sound on the basis that water infrastructure
providers have a legal requirement to provide the necessary infrastructure to meet the needs of Greater
Cambridge’s current and future population and that it should not be for house builders and other
developers to address the failings of water companies to upgrade infrastructure.
When considering water and wastewater capacity it must be recognised that water companies are
subject to statutory duties under S37 and 94 of the Water Industry Act 1991 (WIA 1991). Section 37 of
the Act, set out below, imposes a statutory duty on all water companies to provide and maintain
adequate infrastructure and potable water supplies.
“S37 General duty to maintain water supply system etc. (1) It shall be the duty of every water
undertaker to develop and maintain an efficient and economical system of water supply within its
area and to ensure that all such arrangements have been made— (a) for providing supplies of
water to premises in that area and for making such supplies available to persons who demand
them; and (b) for maintaining, improving, and extending the water undertaker’s water mains and
other pipes, as are necessary for securing that the undertaker is and continues to be able to
meet its obligations under this Part. (2) The duty of a water undertaker under this section shall be
enforceable under section 18 above— (a) by the Secretary of State; or (b) with the consent of or
in accordance with a general authorisation given by the Secretary of State, by the Director.”
Section 106 of the WIA 1991 confers the power to connect to a public sewer. Section 106(1) states that
the owner of any premises or the owner of any private sewer which drains premises, shall be entitled to
have its drains or sewer communicate with the public sewer of any sewerage undertaker and therefore
discharge foul water and surface water from those premises or that private sewer. Specifically, in relation
to wastewater, the Supreme Court considered this matter in 2009 – see Barratt versus Welsh Water
[2009] UKSC 13. Paragraph 23 of the decision is salient. Given its importance in the context of
wastewater it is recited in full below:
“The right to connect to a public sewer afforded by section 106 of the 1991 Act and its
predecessors has been described as an “absolute right”. The sewerage undertaker cannot
refuse to permit the connection on the ground that the additional discharge into the system will
overload it. The burden of dealing with the consequences of this additional discharge falls
directly upon the undertaker and the consequent expense is shared by all who pay sewerage
charges to the undertaker. Thus, in Ainley v Kirkheaton Local Board (1891) 60 LJ (Ch) 734
Stirling J held that the exercise of the right of an owner of property to discharge into a public
sewer conferred by section 21 of the 1875 Act could not be prevented by the local authority on
the ground that the discharge was creating a nuisance. It was for the local authority to ensure
that what was discharged into their sewer was freed from all foul matter before it flowed out into
any natural watercourse.”
Consequently, it is inappropriate to include a policy in the local plan requiring all development proposals
to demonstrate that there is capacity for wastewater treatment and adequate wastewater conveyancing
infrastructure to serve the whole development. It is agreed that there must be sufficient water capacity
and wastewater infrastructure to serve new development but it is the responsibility of water companies,
working with local authorities and the Environment Agency, to plan for the future demand for water
services relating to the development requirements proposed in local plans, not applicants. If the water company is unable to support the development needed in Greater Cambridgeshire, this needs to be
disclosed in the Water Resource Management Plan.
In terms of wastewater treatment, Paragraph 201 of the National Planning Policy Framework (NPPF)
(2024) states that the focus of planning policies and decisions should be on whether proposed
development is an acceptable use of land, rather than the control of processes or emissions (where
these are subject to separate pollution control regimes). Therefore, whilst the Plan should contain
policies aimed at ensuring that wastewater capacity is not put under undue pressure, planning decisions
should assume that these regimes will operate effectively. As such, Part 6 (a) should be deleted from the
policy.

Policy BG/BG should be amended to align with national mandatory requirements of 10% BNG. The
requirement should therefore be amended so that applicants can be “encouraged” to achieve the 20%
target, rather than "must” achieve it. This approach ensure the policy remains aligned with national
requirements whilst being effective and deliverable.

Jesus College supports the objective of enhancing biodiversity; however, objects to Criterion 2 due to its
requirements exceeding the nationally mandated 10% requirement, lack of sufficient flexibility and
likelihood of adversely affecting the viability and deliverability of development. An overly prescriptive
numerical approach to planning assessments erodes the ability to undertake a planning balance and
ensure that a scheme is designed in the round as most appropriate for that development in that context.
Criterion 2 states that all major development must deliver a minimum of 20% biodiversity net gain (BNG)
to be provided on-site where feasible, or off-site only where onsite opportunities have been evidenced to
be exhausted. This requirement exceeds the nationally mandatory position of 10% BNG requirement and
has not been sufficiently justified.
This blanket requirement for 20% BNG fails to account for sites that are located on constrained site
where opportunities for on-site BNG provision may be limited. As drafted, the policy provides insufficient
flexibility to account for these site specific constraints. Requiring a minimum of 20% BNG in all
circumstances is therefore overly prescriptive and risks imposing additional costs that could affect
viability and deliverability of development.
The policy should therefore be amended to align with national mandatory requirements of 10% BNG. The
requirement should therefore be amended so that applicants can be “encouraged” to achieve the 20%
target, rather than "must” achieve it. This approach ensure the policy remains aligned with national
requirements whilst being effective and deliverable.

Policy BG/UGF should be amended to state that ‘all policies should include the latest version of...’ and a
viability clause is added such as ‘Where it can be demonstrated that achieving the target UGF score is
not financially viable or technically feasible, a lower score may be accepted.'

Jesus College supports the objectives of this policy but objects to its current wording. There is an
inherent policy contradiction within Policy BG/UGF which notes in part 1 that ‘all policies must include the
latest version of....’, whilst the supporting information at Paragraph 5.46 states that ‘Major development
proposals should contribute to the greening of Greater Cambridge by including urban greening’
(emphasis added). An objection is made to the use of ‘must’ within the policy wording and respectfully
request that the Inspector amend this to ‘should’ in order to accord with the supporting text. An overly
prescriptive numerical approach to planning assessments erodes the ability to undertake a planning
balance and ensure that a scheme is designed in the round as most appropriate for that development in
that context.
The policy also fails to reflect site specific circumstances through the omission of a viability clause, which
is required to ensure that sustainable development is always possible in the right locations. The policy
should encourage developers to achieve the identified standards whilst taking account of site-specific
circumstances, technical feasibility and viability considerations.
Jesus College therefore recommend that Policy BG/UGF is amended to state that ‘all policies should
include the latest version of...’ and a viability clause is added such as ‘Where it can be demonstrated that
achieving the target UGF score is not financially viable or technically feasible, a lower score may be
accepted.’

Please refer to attached document.

Criterion 4 of Policy BG/EO should be amended to delete 'and' from part a, and include the following in part b: Where site constraints or urban location render point a unfeasible and undeliverable, provide delivery of roof terraces, roof gardens, courtyards and other forms of amenity space at an appropriate scale to the development

Jesus College principally supports the objective of providing and enhancing open space. However, it
objects to the policy as drafted as it fails to adequately recognise the specific characteristics of
commercial development across Greater Cambridge.
Criterion 4 requires all commercial developments exceeding 2,000 sqm GIA to provide open space
equivalent to 2.0 hectares per 1,000 employees. This requirement is overly prescriptive and risks
undermining the efficient use of employment land. The 2,000 sqm threshold is low, and the blanket
requirement for 20 sqm of open space per employee is unlikely to be appropriate across all development
types and locations. In particular, schemes in more constrained and urban locations may struggle to
meet the requirement without comprising the efficient use of land, creating an efficient layout and
achieving development viability.
For example, the policy does not sufficiently recognise the range of open space solutions that may be
appropriate in commercial environments including roof terraces, roof gardens, courtyards and other
forms of amenity space that can contribute to employee wellbeing and reduce any demand arising to
existing public opens from the occupation of new commercial floorspace.
The policy also provides limited clarity on how the requirement would apply to phased developments or
future phases within larger employment campuses. This creates uncertainty for applicants and makes
site planning, masterplanning and viability assessments more challenging.
The cumulative effect of these requirements risks placing an unnecessary burden on commercial
development, contrary to the objective of supporting sustainable economic growth across Greater
Cambridge.

Proposed changes to the policy text are outlined in the attached letter, including an additional clause to
Crieterion 1, stating ‘where there is a demonstrable need, and it is viable and deliverable to do so.’
Deletion of crieterion 6 and 9 is proposed.
Reference in criterion 11 to assessing phasing of delivery on a case-by-case basis is proposed.

Jesus College objects to Policy WS/NC as drafted on the grounds that it places disproportionate
obligations on commercial development, lacks certainty regarding the scale of infrastructure
requirements, and will likely adversely affect development viability and deliverability of commercial
developments to come forward.
Criterion 2 requires employment development of more than 5,000sqm to be informed by detailed
assessments of community needs and strategies to address those needs. The policy provides insufficient
certainty regarding the extent and scale of contributions that may be required, making it difficult to accurately assess development costs, viability and deliverability of development proposals. This
represents a particular challenge when deciding to enter into the planning process; planning policy
should give a high degree of certainty to assess a site pre-planning.
Criterion 6 is particularly onerous in requiring contributions towards community and cultural facilities
based on prescribed floorspace standards, alongside the submission of Community and Cultural Plans.
The policy fails to recognise existing community, cultural and recreational facilities already provided with
many commercial and employment developments. Furthermore, it does not adequately justify why
commercial proposals should be expected to deliver such significant social infrastructure. Employees do
not generate demand for local community and cultural facilities in the same way as residential
developments.
Criterion 7 and 9 similarly place unreasonable expectation on commercial developments to provide or
contribute toward sports and recreational facilities. The policy does not adequately account for existing
provision or whether a development proposal would generate a demonstrable need for additional
facilities. Any requirement for on-site provision or financial contributions should be evidence-based,
proportionate and directly related to the impacts arising from the development.
Criterion 11 requires services and facilities to be delivered during the "early phases" of development.
This lacks clarity and provides limited certainty for the timing as to when infrastructure and facilities
would be expected to come forward. To ensure the policy remains flexible, it is recommended that the
policy should allow the timing of delivery to be determined on a case-by-case basis, taking into account
the scale and phasing of the development.