Draft Greater Cambridge Local Plan for consultation

Vistry recognise the importance of delivering high quality and accessible open spaces as an integral part of new development and support the overarching objective of Policy BG/EO to ensure that development “addresses the open space needs it generates”, secured through an appropriate mix of on-site provision and/or financial contributions for off-site provision, enhancement and management. Vistry's proposals at Balsham Road, Linton would deliver open space opportunities and green infrastructure, and Vistry would welcome ongoing engagement with the Councils, key stakeholders and the local community to ensure that provision responds effectively to local needs and aspirations.

Vistry support the objectives of the policy and the Council’s proposed approach to creating healthy new developments. The site at Balsham Road, Linton will meet daily needs within walking distance to the services and facilities in Linton, encouraging active travel. This would reduce reliance on the private car, promote social interaction and contribute positively to both environmental quality and residents’ physical and mental health. The proposed development would make a positive contribution to nature and deliver long-term health and wellbeing benefits for future residents.

Vistry support the overall aspirations of the policy. However, Vistry consider that minor clarification is required in relation to the requirements set out in paragraph 4 of the policy. The policy states that proposals for residential developments of “200 or more dwellings (or groups of smaller sites which cumulatively exceed this figure)” must be informed by detailed assessments of community needs and include strategies demonstrating engagement with local communities and stakeholders. It is unclear whether this requirement is intended to be addressed through existing submission documents, such as a Statement of Community Involvement or Statement of Community Engagement, or whether it represents an additional and separate requirement. Clarification on this point would assist in ensuring the policy is applied consistently and proportionately.
3.56 The policy further states that “developments of sufficient scale to generate the need for new on-site facilities will be required to do so, unless it can be demonstrated that there would be advantages in off-site delivery.” While Vistry support the principle of providing appropriate community infrastructure, it is important that this requirement is applied flexibly and takes full account of site-specific circumstances, including viability considerations and the capacity of existing or planned off-site facilities. In some cases, off-site provision or financial contributions may represent a more effective and sustainable means of meeting community needs, particularly where developments are well integrated with existing settlements.

Vistry support the vision of the proposed policy. However, Vistry wish to reiterate the point made in response to Policy GP/PP that it is important the policy is applied proportionately, with detailed matters assessed at the reserved matters stage and clear design principles established at outline planning application stage where appropriate.

Vistry support the overall principles of the policy. Although, Vistry consider that the policy should be applied with sufficient flexibility, recognising that prevailing local densities are not always an appropriate to the location, particularly where sites are well located or benefit from strong accessibility. In such circumstances, higher densities may be both suitable and sustainable and should be assessed on their individual merits rather than constrained by surrounding built form that may no longer reflect the most efficient or appropriate use of land.

Vistry support the principles of the policy and recognise the importance of protecting and enhancing landscape character. However, it is essential that the policy is applied in a balanced manner to ensure that it does not excessively constrain the delivery of much-needed housing in sustainable locations.
The policy requires that development must “protect and enhance the setting of Cambridge within the landscape by strengthening the well-defined, vegetated edges of the city and by protecting and enhancing the green corridors which extend into the city and along the River Cam corridor.” While this objective is supported in principle, Vistry consider that the assessment of landscape setting and contribution should be undertaken on a site-specific, case by case basis, having regard to the existing condition and character of the land concerned.
In this respect, it should be recognised that not all land within the wider landscape setting of Cambridge currently makes a meaningful contribution to its character or special qualities. Where development proposals are capable of delivering landscape enhancement, strengthening green infrastructure and reinforcing defensible settlement edges, they can positively contribute to the objectives of the policy while also supporting the wider growth strategy.

Vistry support the intent of the policy. However, it is considered that the reference within the policy to proposals being supported by a Heritage Impact Assessment would be more appropriately addressed through the Council's validation requirements, rather than forming part of the policy wording itself.
In addition, while the policy states that “The Local Planning Authorities will balance the need for development with the conservation, enhancement and enjoyment of the historic environment”, wording does not reflect the structured approach required by the NPPF. It is therefore recommended that the policy is refined to explicitly reflect this test.

Vistry support the overall vision and objectives of the proposed policy. Although, it is noted that the principles set out within the policy closely mirror those contained within Policy GP/HE. The policy would benefit from being combined with Policy GP/HE.

The policy states that “planning permission will not be granted for development which would lead to the irreversible loss of Grades 1, 2 or 3a agricultural land unless” specific criteria are met. Vistry acknowledge the importance of protecting the best and most versatile agricultural land, however, it is important that the weight attached to the loss of such land is proportionate and evidence led. In addition, the context of agricultural land is also important to consider in respect of viability.
The Natural England Guide to assessing development proposals on agricultural land (2021) clarifies how impacts on agricultural land quality should be considered in decision-making. The guidance identifies that consultation with Natural England is only required where development would result in the loss of 20 hectares or more of best and most versatile agricultural land, as set out under Schedule 4(y) of the Town and Country Planning (Development Management Procedure) (England) Order 2015. This threshold provides a clear indication of the scale at which the loss of high quality agricultural land is considered significant in planning terms. Accordingly, the application of the policy should reflect both the scale of any proposed loss and the wider planning balance, including housing need, sustainability, deliverability and the availability of alternative sites. Where the loss of best and most versatile agricultural land is limited in extent and outweighed by the benefits of development, including the delivery of much-needed housing in sustainable locations, the policy should allow for a balanced and proportionate assessment rather than operating as an absolute constraint.

Vistry recognise the importance of delivering affordable housing, particularly in areas such as Greater Cambridge which continue to experience acute levels of need and affordability pressure. The objective of the policy to secure a mix of affordable housing tenures as part of new development is therefore supported in principle.
Vistry note the conclusions of the Local Plan Viability Assessment (2025), which states that “based on the assumptions, appraisals and sensitivity analyses contained herein, the proposed Local Plan policies do not undermine the viability of development on the whole within Greater Cambridge.” Notwithstanding this conclusion, it is important that the Councils continue to review viability as the Plan progresses.
3.74 In seeking to deliver the affordable housing tenures identified within the policy, it is important that the Councils allocate a sufficient number of sites of varying sizes, types and locations across the District. In particular, the inclusion of an appropriate proportion of medium to large size sites will be critical to ensuring that affordable housing is delivered consistently and within the Plan period. Sites, including those promoted by Vistry, present clear opportunities to deliver a broad mix of tenures and a variety of affordable housing sizes and types as part of well-designed, mixed and balanced communities.
Paragraph 6 of the policy states that “within major developments for housing, the new affordable homes must be dispersed in small groups or clusters.” While the principle of tenure integration is supported, further clarification is required as to what constitutes “small groups or clusters” in practice.