Draft Greater Cambridge Local Plan for consultation

Support

Representation ID: 210285

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Vistry and The Quy Estate support the requirement of draft Policy CC/NZ (2).

Comment

Representation ID: 210286

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

In relation to Part C, the policy states that “proposals must seek to maximise opportunities to generate on-site renewable energy to enable the development, where possible, to achieve all energy demands through onsite energy generation”. Vistry and The Quy Estate consider that further clarification is required as to what level and type of information would be expected to demonstrate compliance with this requirement. In particular, it is unclear how the phrase “where possible” will be interpreted in decision-making, or how site-specific constraints, design considerations and viability will be taken into account.

Object

Representation ID: 210287

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Vistry and The Quy Estate consider it to be extremely challenging for new dwellings to deploy sufficient renewable energy to meet all its energy demands on site, particularly given the substantial power requirement from Electric Vehicles (EV’). For an average semi-detached house, Vistry and The Quy Estate consider it reasonable to assume that a maximum of c 3-4 kWp of PV could be installed on the available roofspace for those homes that have optimum orientation (a number will not because they are To meet all energy demands on site would require c8 kWp of PV which simply cannot be provided on the roof space.

Vistry and The Quy Estate consider the draft policy to be undeliverable and request that it be amended to:

“Proposals should maximise the deployment of renewable energy where feasible and viable.”

Object

Representation ID: 210288

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Part D of draft Policy CC/NZ introduces the concept of an “Energy offset fund” to enable developers to make payments in lieu of failure to meet the energy and carbon standards. Vistry are concerned that the policy does not give any detail with respect to the cost of the fund and therefore do not believe this aspect of the draft Policy is sound and in accordance with Paragraph 59 of the NPPF which requires local plan policies to be accompanied by up-to-date viability assessments.

Comment

Representation ID: 210289

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

In relation to criterion 2 of the policy, Vistry and The Quy Estate consider that the practical and viability implications of the proposed standards should be carefully considered. In particular, the requirement for residential developments of 100 or more dwellings to achieve water usage of no more than “80 litres/person/day”, which the policy acknowledges will necessitate “some form of water reuse or recycling… with dual pipe systems for potable and non-potable water”, represents a significant uplift above current Building Regulations and typical industry practice.

Comment

Representation ID: 210290

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Paragraph 6.31 of The Topic Paper references a report (Shared Standards in Water Efficiency for Local Plans (June 2025) which has been prepared by several water companies and the Environment Agency. The Topic Paper (paragraph 6.32) states that a water efficiency standard of 85 l/p/d can be achieved without the use of greywater recycling and through the use of efficient fixtures and fittings. Vistry and The Quy Estate have reviewed the exact specific proposed and note that this is only achieved if a bath is not supplied, which is a basic necessity for the majority of homeowners, particularly those with children or the elderly. Vistry and The Quy Estate consider the 85 l/p/d to be extremely challenging with the solutions presented in the topic paper (without greywater recycling) still not sufficient to meet the draft Policy requirement of 80 l/p/d.

Greywater recycling is therefore necessary to meet the draft target and note that paragraph 6.29 of The Topic Paper estimates the cost of such a unit to be £4,000 with the Viability assessment allocating a cost of c.£6,000 per unit for the purchase of water efficiency equipment only. The Viability study does not make allowance for on-going maintenance costs which are anticipated to be significant, especially for greywater recycling systems.

Comment

Representation ID: 210291

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

When considered alongside the cumulative impact of other policy requirements relating to affordable housing, infrastructure contributions, design, energy efficiency and biodiversity net gain, this standard has the potential to materially affect development viability. The Councils will therefore need to ensure that an appropriate balance is struck between the ambition of the policy and the deliverability of development, supported by robust viability evidence.

Comment

Representation ID: 210292

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Vistry and The Quy Estate also note that the requirement for developments of fewer than 100 dwellings to achieve water usage of between 90 and 100 litres/person/day is more closely aligned with existing best practice and is likely to be more readily achievable without disproportionate cost implications. In this context, Vistry and The Quy Estate consider that the draft Policy should be amended to allow for greater flexibility as follows:

Amend draft Policy 2a and 2b to apply a target of 100 litres/person/ day to apply to all dwellings where practical and viable. The reliability of greywater systems apply to all homes regardless of the development size. The 100 l/p/d target is far more achievable and practical than the 80 l/p/d proposed in the draft Plan.

Comment

Representation ID: 210293

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

In respect of criterion 5, which requires all new dwellings with private outdoor amenity space to provide a water butt and prioritises the use of rainwater for outdoor irrigation, Vistry and The Quy Estate support the principle of encouraging rainwater harvesting. However, consideration should be given to how this requirement would be secured and monitored in practice, particularly in relation to long-term management, maintenance and enforcement. Clarification on the intended implementation mechanisms, would assist in ensuring the policy is applied consistently and effectively.

Object

Representation ID: 210294

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Vistry and The Quy Estate express concerns with the application of paragraph 6 of the policy. While it is reasonable to ensure that development is appropriately served by water and wastewater infrastructure, the policy as currently drafted risks placing an unreasonable and disproportionate evidential burden on applicants at the planning application stage.

The provision and timely upgrading of wastewater treatment and conveyancing infrastructure is a statutory responsibility of water companies, who are required to plan for and accommodate growth through the relevant regulatory and investment frameworks.