Planning Obligations and Affordable Housing SPD

RE: PLANNING OBLIGATIONS & AFFORDABLE HOUSING SUPPLEMENTARY PLANNING
DOCUMENT CONSULTATION
Dear Sir/Madam,
This letter provides Gladman Developments Ltd (Gladman) response to the draft Planning
Obligations and Affordable Housing Supplementary Planning Document (SPD) under Parts 12
and 13 of the Town and Country Planning Regulations (Local Planning) (England) 2012. This brief
response seeks to highlight points for consideration.
Education Provision
At point 4.94 of the Planning Obligations & Affordable Housing SPD:
‘Where the on-site provision is required to support a new site allocation the council will expect
the developer to provide the land for the facility and either design and build the provision to the
satisfaction of the council or make a financial contribution to the council so that it may arrange
for the construction and development of the required facility.’
This is consistent with the approach taken through the adopted Local Plan’s viability
assessments. For example, Site AL8 (Land East of Chichester) is required by policy to provide a
neighbourhood centre inclusive of a primary school. The viability calculations within the Local
Plans evidence base do not consider a construction cost for a primary school or neighbourhood
centre, it is instead captured through S106 costs under the Infrastructure Delivery Plan.
However, within the adopted Local Plan, the policy wording for Site A8 does not make the
distinction between provision of land and financial contributions. But states that the IDP and
Infrastructure Business Plan (IBP) should be referred to.
The IDP January 2023 P32 states:
It is the responsibility of the council as the Local Planning Authority to ensure land is allocated
for education provision. Therefore, mitigation for land and contributions should be clearly set
out in Local Plan policy requirements and allocations for school sites will be expected to be free
from constraints and provided full serviced at nil value.
It is considered that there should have been further clarity within the policy wording of the
adopted Local Plan, it appears the Draft SPD is seeking to correct this.
Trigger Points
At point 5.1 of the Planning Obligations & Affordable Housing SPD, wording around trigger points
are suggested, one of these is worded as follows:
‘Upon or prior to substantial completion of the development’
For clarity it is suggested that a quantifiable figure be used instead.
Gladman hopes you have found these representations helpful and constructive. If you have any
questions do not hesitate to contact me or one of the Gladman team.

RE: PLANNING OBLIGATIONS & AFFORDABLE HOUSING SUPPLEMENTARY PLANNING
DOCUMENT CONSULTATION
Dear Sir/Madam,
This letter provides Gladman Developments Ltd (Gladman) response to the draft Planning
Obligations and Affordable Housing Supplementary Planning Document (SPD) under Parts 12
and 13 of the Town and Country Planning Regulations (Local Planning) (England) 2012. This brief
response seeks to highlight points for consideration.
Education Provision
At point 4.94 of the Planning Obligations & Affordable Housing SPD:
‘Where the on-site provision is required to support a new site allocation the council will expect
the developer to provide the land for the facility and either design and build the provision to the
satisfaction of the council or make a financial contribution to the council so that it may arrange
for the construction and development of the required facility.’
This is consistent with the approach taken through the adopted Local Plan’s viability
assessments. For example, Site AL8 (Land East of Chichester) is required by policy to provide a
neighbourhood centre inclusive of a primary school. The viability calculations within the Local
Plans evidence base do not consider a construction cost for a primary school or neighbourhood
centre, it is instead captured through S106 costs under the Infrastructure Delivery Plan.
However, within the adopted Local Plan, the policy wording for Site A8 does not make the
distinction between provision of land and financial contributions. But states that the IDP and
Infrastructure Business Plan (IBP) should be referred to.
The IDP January 2023 P32 states:
It is the responsibility of the council as the Local Planning Authority to ensure land is allocated
for education provision. Therefore, mitigation for land and contributions should be clearly set
out in Local Plan policy requirements and allocations for school sites will be expected to be free
from constraints and provided full serviced at nil value.
It is considered that there should have been further clarity within the policy wording of the
adopted Local Plan, it appears the Draft SPD is seeking to correct this.
Trigger Points
At point 5.1 of the Planning Obligations & Affordable Housing SPD, wording around trigger points
are suggested, one of these is worded as follows:
‘Upon or prior to substantial completion of the development’
For clarity it is suggested that a quantifiable figure be used instead.
Gladman hopes you have found these representations helpful and constructive. If you have any
questions do not hesitate to contact me or one of the Gladman team.