Draft Greater Cambridge Local Plan for consultation

Vistry Group have previously made submissions as part of the Call for Sites for circa 300 dwellings and a rural business park. Our representation to the Preferred Options Consultation 2021 regarding the Land to North West of Balsham Road Linton, set out our response to the HELAA assessment, which dismissed the site primarily due to concerns about landscape impact. In our response, we addressed the concerns with additional technical information and evidence including an updated Landscape Technical Note and Opportunities and Constraints Plan, prepared by Barton Willmore, which clearly demonstrate that perceived landscape impacts can be addressed or mitigated, thereby substantiating the site's suitability and deliverability.
The Land North West of Balsham Road is located on the north-eastern side of Linton. It benefits from a very good relationship to the existing development boundary for Linton, as set out within the adopted Linton Proposals Map that forms part of the adopted Local Plan (2018). The site is boarded to the south-west by residential properties in Tower View, which are located off Balsham Road. Balsham Road abuts the southern boundary of the site with residential properties opposite the site’s southern boundary. To the west, is a green wedge which separates the site from a scrap metal yard. To the north, the site rises to the open countryside, and a water tower sits at the top of Rivey Hill. The site would be accessed from the south, onto Balsham Road, benefiting from good visibility in both directions. Linton is a substantial sized village with considerable services, categorised as a Minor Rural Centre in the adopted Local Plan 2018. There is capacity for Linton to provide an increased amount office space for local business, or start-up businesses from the village, or surrounding villages to work. The employment site would provide the opportunity for residents within the new housing on the site or within the existing village to have a premise for the start-up of new businesses and could include additional facilities such as a nursery and café. The proposed employment hub of 1 hectare is consistent with the size of the settlement.
Evidence demonstrates that Greater Cambridge is expected to accommodate substantially higher levels of employment and housing growth than currently planned for, supported by major national interventions including the Cambridge Growth Company, the proposed development corporation, and significant infrastructure investment. The Local Plan must therefore plan positively for a higher housing requirement, supported by a more diverse and resilient portfolio of sites capable of delivering early, sustained, and flexible supply throughout the plan period.
Small to Medium-scale, well-located opportunities such as this site in Balsham Road, Linton are essential to achieving the s. The site is uniquely positioned to capitalise on the transformative infrastructure and connectivity improvements associated with growth areas to the east and south of Cambridge. Crucially, Linton can deliver new homes at pace without reliance on complex, long-term strategic infrastructure, thereby reducing delivery risk and strengthening the overall housing trajectory.
Vistry therefore maintain that the allocation of Land North West of Balsham Road, Linton is necessary to ensure the Local Plan is effective, justified, and capable of meeting the full scale of housing need arising from Greater Cambridge’s economic potential. Its inclusion would enhance flexibility, improve deliverability, and support the Councils’ wider spatial, environmental, and sustainability objectives

Vistry are of the view that the Local Plan should be more ambitious in terms of job growth, targeting the creation of 90,900 jobs rather than the 73,300 proposed at draft Policy S/JH. It should equally plan to meet what the EHNU reports to be the associated need for circa 2,829 homes per annum, surpassing what should be viewed as only the ‘minimum’ need suggested by the standard method (2,295dpa). This would reflect paragraph 69 of the NPPF which sets out that the housing requirement may be higher than the identified housing need. Please see attached reps for more detail.

Vistry are supportive of the principle of the proposed development strategy and recognise that a range of sites will be required to deliver this strategy. Concern, however, is raised regarding how the proposed strategy has been interpreted into the allocations proposed. We highlight that the Plan is heavily reliant on allocations for large and complex sites, many of which will be dependent on the timely delivery of strategic infrastructure. Vistry consider the development strategy would be strengthened by the inclusion of a wider variety of site sizes and locations, particularly smaller and medium-scale sites in the rural areas, which can play an important role in maintaining delivery rates, providing flexibility within the housing trajectory, and reducing reliance on a small number of strategically constrained sites. There is a notable absence of sufficient small and medium-scale allocations in rural locations, for example Linton, despite the ability to deliver housing in a timely and effective manner.

The Settlement Hierarchy Study Update represents a proportionate review of the earlier assessment rather than a comprehensive reassessment of settlement roles and relationships between settlements. As such, it provides limited analysis of how committed and proposed growth, improved connectivity and changing functional relationships may influence the suitability of all settlements to accommodate additional development. For example Linton is well placed to benefit from, and contribute to, the Cambridge East allocation (Policy S/GF), and the future expansion of the Wellcome Genome Campus at Hinxton (Policy S/WGC), including the sustainability measures and infrastructure investment proposed as part of that wider growth location. These factors materially enhance the sustainability credentials of Linton and should be more fully recognised within the settlement hierarchy assessment.

Vistry support the vision and objectives for Grange Farm, which is intended to be a new settlement serving the needs of existing and future communities, at the heart of the Rural Southern cluster, within which Linton sits. Importantly, the delivery of Grange Farm would also generate wider sustainability and infrastructure benefits that extend beyond the allocation itself. In particular, the proposed public transport, active travel improvements and the concentration of services and facilities would materially enhance the sustainability of surrounding areas, including locations such as Linton. The proximity of Linton to Grange Farm means that it would be well placed to benefit from, and contribute to, the new services, employment opportunities and sustainable movement networks introduced through the Grange Farm development, further strengthening the case for additional growth in this location.Vistry note, however, that the comprehensive delivery of Grange Farm remains dependent on significant infrastructure interventions and funding arrangements that are not yet fully resolved. In this context, it is essential that the Local Plan does not rely disproportionately on new settlements to meet housing delivery requirements within the early and middle stages of the plan period. Medium-scale, well located sites such as Balsham Road, Linton are capable of coming forward without reliance on the relocation of existing development or other strategic infrastructure and can therefore play a critical role in supporting the housing trajectory and ensuring delivery against the plan’s timescales.
3.33 The allocation of the site at Balsham Road, Linton would therefore provide important flexibility and resilience within the development strategy, helping to ensure the delivery of an appropriate and effective quantum of housing to support the wider aspirations of the Plan up to 2045, particularly in the event of delivery delays on large allocations and new settlements.

Vistry have concerns regarding the prescriptive nature of part 3 of the policy, which states that “all new dwellings shall be designed to benefit from cross ventilation where possible, and take passive, design-led approaches to reducing excess solar gain.” While the intent of this requirement is understood, matters relating to overheating risk, ventilation and internal environmental performance are already comprehensively addressed through the Building Regulations (part O) and associated guidance. Vistry consider that this Policy should be deleted to reduce reporting and administration associated with the Draft Plan.

Vistry note the Government is progressing the Future Homes Standard which is intended to deliver highly energy-efficient, low-carbon homes through Building Regulations at a national level. This will ensure new homes produce significantly lower carbon emissions than current standards, supporting the transition to net zero. Delivering these requirements through Building Regulations, rather than through locally specific standards, provides certainty to the development industry. As the Government is proposing to change legislation to prevent local authorities from setting standards above Building Regulations draft policy CC/ NZ may need to be amended or deleted. Please see attached detailed reps for further comment.

Vistry note that policy continues to require development to achieve a minimum 20% biodiversity net gain, which exceeds the mandatory requirement set out in the Environment Act 2021. While Vistry support the ambition to secure significant biodiversity enhancements through development, however, a fixed requirement of 20% represents a high aspiration and viability implications of all the Plan requirements need to be considered collectively if this continues to be pursued. The implications of this requirement are considered on a site-specific basis and assessed alongside the cumulative impact of other plan policies through the plan’s site capacity and viability work progresses.
Vistry also support the policy’s recognition that on-site delivery of biodiversity net gain may not always be achievable. Paragraph 3 of the policy appropriately states that, where on-site options have been exhausted to the satisfaction of the Local Planning Authority, biodiversity net gain may be delivered off-site through registered habitat banks, bespoke schemes or statutory biodiversity credits. This flexible approach is welcomed, as it reflects the overarching objective of biodiversity net gain, which is to leave the natural environment in a measurably better condition than before development takes place.
3.36 However, while the policy states that the Local Planning Authority “will encourage delivery of replacement habitat” within Local Nature Recovery Strategy priority areas, it is important to recognise that the availability of suitable credits within the Plan area cannot be guaranteed. In circumstances where sufficient local credits are not available, applicants should retain the ability to secure biodiversity net gain through alternative registered schemes elsewhere, to ensure that development is not unnecessarily constrained.

Vistry support the objectives of this policy in securing high quality green/blue infrastructure. In particular, paragraph 4 of the policy states “all major residential development proposals, or proposals that are predominantly residentially led, must meet a minimum Greening Factor of 0.4”
While the principle of requiring a minimum level of greening is supported to avoid ambiguity and ensure consistency in decision-making. the policy would benefit from further wording directing readers to supporting paragraph 5.37 which goes into detail as to what constitutes a 'Greening Factor', including how it is calculated and the types of green infrastructure that contribute towards it.

Vistry support the overall objective of the policy to increase tree canopy cover and enhance the quality and resilience of the treescape across Greater Cambridge. However, while the policy appropriately allows for flexibility where a scheme can demonstrate “significant ecological, historical, landscape or operational reasons to justify a canopy cover of less than 30% on site”, it is considered that this flexibility should be more clearly and consistently applied throughout the policy.