Infrastructure and developer contributions
Question ID 1
Do you agree with the suggested policy approach towards infrastructure and developer contributions, as set out above in ID 1 'Infrastructure and developer contributions'? If not please suggest how it could be amended.
120 comments
| Theme | Summary |
| Strong support for infrastructure-first approach | A dominant theme is positive support for the suggested policy approach to infrastructure and developer contributions, with repeated calls for schools, healthcare, transport, utilities and community facilities to be delivered before or alongside housing development, rather than years afterwards. |
| Developers should fund required infrastructure | Many respondents argue that developers should fully fund the infrastructure needed to mitigate the impacts of their development, including roads, schools, healthcare, utilities, flood mitigation and green infrastructure, rather than relying on Council funding. |
| Healthcare infrastructure as essential provision | A very strong and detailed theme is the need to explicitly include healthcare infrastructure (GPs, dentists, primary care) within policy approach ID1, with calls for close working with the NHS and Integrated Care Boards and for developer contributions to fund capacity increases. |
| Education provision and school capacity | Respondents repeatedly stress the need for adequate school places and land for expansion, with concern that education provision often lags behind housing growth. Support is expressed for using Section 106 legal agreements to ringfence education funding. |
| Transport, highways and sustainable travel | Strong emphasis is placed on improving highways capacity, junctions, public transport, cycling and walking networks, with calls for clear phasing and future-proofing of the Strategic Road Network. |
| Water, sewerage and utilities capacity | Many responses highlight concerns about water supply, wastewater treatment, sewerage capacity and flooding, with support for requiring developers to fund necessary upgrades and for stronger engagement with utility providers. |
| Green and blue infrastructure | Respondents emphasise that green and blue infrastructure (open space, woodland, Sustainable Drainage Systems (SuDS), waterways) should be treated as essential infrastructure, not optional extras, with funding secured through developer contributions. |
| Community and social infrastructure | Strong support exists for recognising community halls, village centres, youth facilities and social infrastructure as priority infrastructure items, with phased delivery alongside housing. |
| Emergency services and safety infrastructure | Some respondents request explicit recognition of police, fire and ambulance infrastructure as eligible for developer contributions, citing national policy and appeal decisions. |
| Enforcement, monitoring and delivery mechanisms | There is widespread concern that developer obligations are not always delivered. Respondents call for stronger enforcement, monitoring, escrow-style arrangements and upfront payments to ensure commitments are honoured. |
| Viability, flexibility and CIL tests | Developers and industry bodies emphasise that contributions must be viability-tested, proportionate and compliant with Community Infrastructure Levy (CIL) Regulation 122, warning that excessive burdens could undermine deliverability. |
| Infrastructure Delivery Plan (IDP) | Strong support is expressed for a robust, settlement-by-settlement Infrastructure Delivery Plan to identify existing deficiencies, future requirements, costs, funding sources and phasing. |
| Digital infrastructure and broadband | Some respondents highlight the importance of high-quality digital infrastructure, including fibre broadband, while others caution against requirements exceeding Building Regulations. |
Question ID 2
Should developer contributions only apply to major developments? How should 'major development' be defined?
81 comments
| Theme | Summary |
| Strong opposition to limiting contributions to major developments only | The dominant theme is strong opposition to restricting developer contributions solely to major developments. Many respondents argue that smaller schemes can have significant cumulative impacts, particularly in villages and rural areas, and should contribute proportionately. |
| Support for contributions from all development sizes (proportionate approach) | A very large number of respondents support applying developer contributions to all developments, subject to proportionality and viability, often advocating a sliding scale to avoid discouraging small schemes. |
| Cumulative impacts of small developments | Respondents repeatedly highlight that multiple small developments can collectively place greater strain on infrastructure than a single large scheme, especially in rural settlements with limited services and capacity. |
| Support for National Planning Policy Framework (NPPF) definition of major development | Some respondents support retaining the national definition of major development as set out in the National Planning Policy Framework and Development Management Procedure Order (DMPO), arguing this provides clarity and consistency across the planning system. |
| Alternative thresholds suggested (lower or higher) | A range of alternative thresholds are proposed, including contributions from developments of 2–5 dwellings, 10 dwellings, 15–20 dwellings, or conversely only very large schemes of 100+ homes, reflecting divergent views on proportionality and viability. |
| Houses in Multiple Occupation (HMOs) and non-standard development types | Several respondents argue that Houses in Multiple Occupation (HMOs) and other high-occupancy uses should be treated as major development for infrastructure purposes due to their intensified impacts. |
| Local application of contributions | Strong support exists for ensuring that developer contributions are spent locally in the communities affected by development, rather than pooled more widely, to maintain public confidence and transparency. |
| Viability, evidence and flexibility | Developers and professional respondents stress that any lowering of thresholds must be justified by robust evidence and viability testing, warning that overly onerous requirements could impact housing delivery and land supply. |
| Infrastructure types to be included | Respondents identify a wide range of infrastructure that should be covered by contributions, including healthcare, education, highways, cycling and walking routes, green space, drainage, biodiversity net gain and emergency services. |
Question ID 3
Do you agree that developers/ operators should pay the full cost of infrastructure required to deliver their sites?
81 comments
| Theme | Summary |
| Strong support for developers paying the full cost of infrastructure | A clear majority of respondents support the principle that developers should pay the full cost of infrastructure required to deliver their sites, arguing that communities and existing taxpayers should not subsidise private development. |
| Infrastructure must include social, green and environmental provision | Many respondents stress that infrastructure should be defined broadly to include schools, healthcare, transport, utilities, green space, Sustainable Drainage Systems (SuDS), biodiversity net gain, habitat protection and environmental mitigation, not just roads. |
| Accountability, enforcement and long-term maintenance | Strong concern is expressed about failures to deliver promised infrastructure. Respondents call for stronger enforcement of Section 106 legal agreements, deadlines for road adoption, quality assurance of reinstatements, and long-term maintenance contributions. |
| Opposition to burden falling on existing taxpayers | A recurring theme is that existing residents, councils and public services should not bear the cost of infrastructure needed for new development, particularly given developer profits and ongoing council tax receipts from new homes. |
| Shared or strategic infrastructure – proportional contributions | Some respondents accept the principle of developer funding but argue that where infrastructure serves multiple sites or wider areas, costs should be shared proportionately rather than borne by a single development. |
| Viability concerns and flexibility | Developers, landowners and industry bodies caution that requiring full infrastructure costs in all cases could undermine viability and delivery. They emphasise the need for viability testing and flexibility where infrastructure is not site-specific. |
| Role of statutory providers and public sector investment | Several respondents argue that statutory providers such as the National Health Service (NHS) and water companies have their own investment responsibilities and should not expect developers to fund core service provision such as doctors or reservoirs. |
| Existing mechanisms already secure full costs (S106 and CIL) | Some representations state that existing mechanisms, including Section 106 legal agreements and the Community Infrastructure Levy (CIL), already ensure that developers pay the full cost of infrastructure required to deliver development. |
| Clarification sought on responsibility and delivery | A small number of respondents ask for clearer identification of who is responsible for ensuring infrastructure is delivered and maintained, particularly where commitments appear not to have been fulfilled. |
Question ID 4
In the event of viability being an issue how could the new Local Plan prioritise the provision of infrastructure across the borough and/ or on a settlement-by-settlement basis?
44 comments
| Theme | Summary |
| Place-based / settlement-by-settlement and parish involvement | Strong support for a locally responsive approach, with infrastructure priorities set on a settlement-by-settlement basis and developed in close collaboration with town and parish councils. |
| Infrastructure Delivery Plan (IDP) / CIL targeting | Frequent calls for the use of an Infrastructure Delivery Plan linked to Place Plans to provide transparency and ensure Community Infrastructure Levy (CIL) and other developer contributions are effectively targeted and pooled. |
| Essential / site-specific infrastructure first | Respondents emphasised that essential enabling infrastructure – particularly transport, education, health and utilities – should be prioritised to support development, often ahead of other policy requirements. |
| Prioritisation order of infrastructure types | Several responses proposed explicit hierarchies for infrastructure delivery, typically placing strategic transport, education and health provision ahead of utilities, affordable housing and other community facilities. |
| Affordable housing trade-offs / flexibility | A number of comments accepted that flexibility in affordable housing contributions or tenure mix may be necessary to ensure delivery of critical infrastructure, while others cautioned against affordable housing being disproportionately reduced. |
| Not viable – do not develop | Some respondents took a firm position that development should not proceed where infrastructure cannot be viably delivered, questioning the rationale for schemes that fail viability tests. |
| Green & blue infrastructure / biodiversity | Some comments highlighted the importance of green and blue infrastructure, biodiversity and flood resilience, arguing these should be treated as essential infrastructure rather than optional enhancements. |
| Viability assessment, transparency & funding | A small number of responses stressed the need for robust, transparent and independently reviewed viability assessments, alongside proactive pursuit of regional or national funding opportunities. |
| Existing infrastructure capacity prioritisation | Some respondents suggested prioritising growth in locations already well served by infrastructure, rather than directing development to areas requiring significant new investment. |
| External models / precedents | One response suggested learning from established models or approaches used successfully in other areas to address similar infrastructure and viability challenges. |
Please note: this summary contains content generated by Artificial Intelligence (AI). AI generated content has been reviewed by the author for accuracy and edited/revised where necessary. The author takes individual responsibility for this content.