Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 210234

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Vistry and The Quy Estate 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. A fixed requirement of 20% clearly represents a strong aspiration and it will be important to understand its overall viability implications particularly when considered alongside the cumulative impact of other plan policies. It is therefore important this requirement is considered on a site-specific basis and assessed alongside the cumulative impact of other plan policies as site capacity and viability work progresses.

Support

Representation ID: 210235

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Vistry and The Quy Estate 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.

Comment

Representation ID: 210236

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

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, in order to ensure that development is not unnecessarily constrained.

Comment

Representation ID: 210237

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Paragraph 4 of the policy states that “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, it is considered that the policy would benefit from further wording directing readers to supporting paragraph 5.37 which goes into further detail as to what constitutes a 'Greening Factor', including how it is calculated and the types of green infrastructure that contribute towards it, in order to avoid ambiguity and ensure consistent application in decision-making.

Comment

Representation ID: 210238

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

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.

In particular, paragraph 6 states that development “will not be permitted which involves felling, significant surgery, and potential root damage to trees of amenity value, unless otherwise approved by the Local Planning Authority”, but does not clearly acknowledge that tree removal may in some circumstances be necessary due to factors such as disease, age, structural condition or safety concerns, or where the benefits of development demonstrably outweigh the harm arising from tree loss.

Comment

Representation ID: 210239

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Vistry and The Quy Estate also note that paragraph 3 of the policy sets out detailed submission requirements, including the need for an Arboricultural Impact Assessment, Tree Protection Plan and/or Hedgerow Survey. It is considered that these requirements would be more appropriately addressed through the Local Plan validation requirements.

Comment

Representation ID: 210240

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Paragraph 7 of the policy states that development proposals “should maintain a buffer zone of at least 15 metres” from ancient woodland, ancient and veteran trees and ancient hedgerows, but then goes on to state that “the size and type of buffer zone will vary depending on the scale, type and impact of the development”. As currently drafted, this appears contradictory and could lead to uncertainty in interpretation. The policy would benefit from clarification as to whether the 15 metre buffer represents a fixed minimum or a guideline that is subject to variation based on site-specific circumstances.

Comment

Representation ID: 210241

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Concern is raised in respect of paragraph 2 of the policy, which states that development proposals should retain or reinstate “a buffer zone of at least 15 metres from the watercourse bank top, or 10 metres from a ditch bank top,” within which “no development shall be permitted except for domestic extensions, soft landscaping, small amenity areas, or proposals where it is necessary for the nature and function of the development”. While the principle of buffer zones is supported, Vistry and The Quy Estate consider that further clarity is required either within the policy wording or supporting text to ensure consistent interpretation and application across sites.

In particular, the policy would benefit from clarification as to whether the buffer requirement applies consistently to both sides of a watercourse in all circumstances, or whether a more flexible, site-specific approach may be appropriate depending on the nature of the watercourse, surrounding land uses and environmental constraints.

Comment

Representation ID: 210242

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

Vistry and The Quy Estate note that the policy states that the Councils are “exploring the potential to require” a range of quantitative standards for major residential development, including Accessible Green Space, children’s play and youth space, food growing and allotments, and outdoor sports provision. While the intent to establish clear standards is supported in principle, the policy currently lacks sufficient clarity as to how these emerging requirements will be applied in practice. In particular, the absence of confirmed standards creates uncertainty for site capacity assumptions, viability testing and the assessment of proposed allocations across the plan as a whole.

Comment

Representation ID: 210243

Received: 30/01/2026

Respondent: Vistry Group

Agent: Turley

It is important that the policy provides greater clarity and flexibility, particularly in acknowledging that the scale, type and location of open space provision should be informed by site-specific circumstances, existing local provision and identified gaps in accessible greenspace. Flexibility should be retained to allow for an appropriate balance between on-site provision and off-site contributions, having regard to the nature of the development, local opportunities and constraints, and relevant national guidance, including Natural England’s Accessible Natural Greenspace Standards.