Draft Greater Cambridge Local Plan for consultation

On the Policies Map, the defined development extent at the northeastern edge of Melbourn should be amended to include Site Allocation S/RRA/CR, Land to the west of Cambridge Road, Melbourn within the village envelope.

Please see attached.

Vistry objects to Draft Policy S/DE (Defined development extents), specifically with reference to the defined development extent indicated on the Draft Policies Map at the northeastern edge of the village of Melbourn (Minor Rural Centre).

Local Plan Paragraph 2.131 sets out the purpose and intent of Draft Policy S/DE, as follows:
“This policy defines the boundaries of settlements for planning purposes.”

The Glossary (Consultation Document, page 719) states:
“Defined Development Extent (previously settlement boundary or development framework boundary): Define where policies for the built-up areas of settlements give way to the more restrictive policies for the countryside.”
Draft Policy S/DE is split into two parts:
- Policy S/DE(1) sets out the approach that will be taken in relation to land within defined development extents.
- Policy S/DE(2) sets out the approach that will be taken in relation to land outside of defined development extents.

This is a restrictive policy, which treats land outside of the defined development extents as ‘countryside’.
The defined development extent therefore forms a binary boundary between settlements and the countryside. Land is either in or out of the settlement.

Site Allocation S/RRA/CR, Land to the west of Cambridge Road, Melbourn, is identified on the Policies Map for development. We support this allocation (this is set out under Policy S/RRA/CR).

The Draft Policies Map shows the defined development extent in this part of Melbourn (the northeastern edge of the settlement) located between the TTP / Bruntwood Science Park and Site Allocation S/RRA/CR. Consequently, this indicates that Site Allocation S/RRA/CR sits outside of the village and within the countryside. This is not correct. The defined development extent should go around the outside of Site Allocation S/RRA/CR so that the Site is included within the settlement envelope.

The lineation currently shown on the Draft Policies Map is not consistent with the approach taken in respect of site allocations elsewhere in the Greater Cambridge Area. An example is Waterbeach New Town, where the defined development extent follows the outer edge of the site allocation. The defined development extent effectively represents the future edge of the settlement and creates a new defensible boundary for the plan period. This approach should be followed at the northeastern edge of Melbourn.

Vistry supports Draft Policy S/RRA (Site allocations in the rest of the rural area) in as far as it includes the allocation of Land west of Cambridge Road, Melbourn (Policy S/RRA/CR) as a well-located, sustainable and deliverable site.

Please see ATTACHED DOCUMENT and REPORT.

We support the allocation of the Site under Policy S/RRA/CR, but we have made some requested changes to the wording of the Policy.

The attached sets out the requested changes to the wording of Policy S/RRA/CR. These are set out as a Minimum Required Policy Amendment (retaining a Mixed Use Allocation), and a Preferred Policy Amendment (as a Housing Allocation).

Please see ATTACHED DOCUMENT and REPORT.

Vistry supports the allocation of this Site under Draft Policy S/RRA/CR: Land west of Cambridge Road, Melbourn. However, we request changes to the Draft Policy wording for accuracy and clarity.

The Site presents an opportunity to deliver homes in a Minor Rural Centre. The allocation of Land to the west of Cambridge Road, Melbourn makes an important contribution to this component of the spatial strategy through providing an opportunity to deliver affordable and market housing, thereby supporting economic growth in a sustainable location. Melbourn is classified as a Minor Rural Centre, is one of the most sustainable villages in Greater Cambridge and lies outside of the Cambridge Green Belt. The Site presents a prime opportunity to grow the village, sustaining existing services, delivering new facilities and infrastructure, supporting local shops and businesses and meeting local housing needs.

Vistry supports the allocation of S/RRA/CR, Land to the west of Cambridge Road, Melbourn. The Site is a sustainable location to deliver homes in a Minor Rural Centre.

The previous application and appeal process for residential development on the Site have established a clear and strong position that the Site is deliverable (achievable, available, suitable) and a sustainable location for development. There are no technical reasons for the site not to come forward for development and Vistry remains committed to working with the Local Planning Authority to develop a proposal that best supports the objectives of the Local Plan and its policies.

DELIVERING HOMES TO MEET LOCAL NEED

The development of the Site could deliver numerous tangible social, economic and environmental benefits to Melbourn and the local area that meet the aims for the Local Plan. This includes:
- Delivering a range of housing, including affordable housing, to meet local housing need.
- Locating new residential development adjacent to one of the village’s largest employment sites, Melbourn Science Park, therefore a sustainable location for new housing to support local jobs and economic growth.
- Adjacent to Cambridge Road, the Site benefits from direct access to the Melbourn Greenway, a shared route for walkers, runners, cyclists and other active travel users. The Greenway will provide a direct connection from Melbourn into Cambridge (northwards) and into Royston (southwards).
- The Site is well located to promote sustainable transport options, including public transport via both the local bus network and Meldreth Railway Station.
- The delivery of a walking route which is easily accessible to local residents and employees in the village. This will create a new recreation asset for the village and provide a local walking opportunity for those that may have otherwise considered the need to travel to SSSIs for that activity, therefore protecting nearby SSSI’s from increased recreational pressure.
- The delivery of a pedestrian route from the west of the Site along ‘the Drift’ which links to Moat Lane. This will provide residents with enhanced pedestrian connectivity to the adjacent Science Park and Melbourn High Street, encouraging active travel modes within the village.
- Supporting the vitality of Melbourn’s community and economy, including local shops and services in this Minor Rural Centre.

EMPLOYMENT USE

Draft Policy S/RRA/CR includes specific reference to “8,000 square metres gross internal area of floorspace for employment uses” with the stated policy requirement that it “(a) any employment uses must be integrated with the existing Science Park”.

The Site lies directly adjacent to Melbourn Science Park and therefore geographically presents a suitable location to support the expansion of the existing campus if that was needed.

However, Melbourn Science Park has already expanded its footprint in recent years, with the TTP campus developed as a westward expansion of the original site. Additionally, Melbourn Science Park (Bruntwood Sci) benefits from a more recent planning permission which allows for an intensification of employment use within the original campus area. Hence, a substantial increase in employment floorspace has planning consent and is available to be built out within the Melbourn Science Park’s existing campus footprint. On this basis, it is highly unlikely that there will be a need or demand for further spatial expansion of the Melbourn Science Park in the foreseeable future.

There is no evidence of need for additional employment floorspace in Melbourn in the Local Plan or its accompanying documents.

Independent of the needs and capacity of the adjacent Melbourn Science Park, up-to-date evidence demonstrates that there is a good supply of employment land in the local area too. This representation is supported by an occupational report prepared by Bidwells Space Agency (please see ATTACHED REPORT), which provides an overview of the commercial property market in Melbourn and the surrounding villages, set within the wider Cambridge context. This concludes that there is no occupational need for any additional employment floorspace in the Melbourn area.

MIXED USE OR HOUSING ALLOCATION

We note that the Site Allocation is identified as “Mixed Use”.

Vistry is willing to accept the “Mixed Use” allocation and retain the possibility of including some employment floorspace within the development. However, evidence is clear that there is unlikely to be any demonstrable need or demand for employment space in this location during the plan period. By comparison, there is a strong need for new homes and the Site offers an ideal opportunity for early delivery within the plan period. Hence, if the “Mixed Use” allocation is retained as such then the wording of Policy S/RRA/CR and supporting text must be amended to provide increased flexibility, to support the prospects of the delivery of the Site Allocation and not create an unevidenced and unnecessary policy position to unduly constrained the site that could hinder the viability or deliverability of the site.

The draft policy wording says:
- “Capacity for approximately 120 homes and 8,000 square metres gross internal area of floorspace for employment uses.”

To account for the uncertainty on the need for employment space over the plan period in this locality, the policy wording must be changed to:
- Capacity for up to 8,000 square metres gross internal area of floorspace for employment uses, subject to the submission of evidence confirming a demonstrable need at the time of a planning application submission
- Capacity for around 120 homes if provided alongside 8,000 square metres gross internal area of floorspace for employment uses, or a greater number of homes if no or a lesser amount of employment floorspace is needed

Vistry would support the identification of the Site Allocation for “Housing” rather than “Mixed Use”. This approach would delete the Draft Policy S/RRA/CR references to employment use and the adjacent Melbourn Science Park.

LANDSCAPE SETTING AT THE EDGE OF SETTLEMENT

Vistry has objected to Draft Policy S/DE (Defined development extents), specifically with reference to the defined development extent indicated on the Draft Policies Map at the northeastern edge of the village of Melbourn (Minor Rural Centre). We consider that the defined development extent at the northeastern edge of Melbourn should be amended to include Site Allocation S/RRA/CR, Land to the west of Cambridge Road, Melbourn within the defined settlement envelope. The northeastern and northwestern boundaries of the Site would therefore become the new edge of settlement.

Policy requirement (b) set out in Draft Policy S/RRA/CR makes reference to the Site Allocation’s boundaries facing the rural setting. Whilst noting that this should be corrected to refer to the northeast and northwest of the Site, we acknowledge that these frontages will require sensitive landscape treatment taking into account views from the countryside towards the village. We can reassure Officers that all necessary and relevant landscape assessment and landscape design technical work will be undertaken as part of the preparation of a future planning application, to inform the proposals for the Site.

HERITAGE CONSIDERATIONS

Policy requirement (c) under Draft Policy S/RRA/CR makes explicit reference to “nearby Grade II listed buildings and Melbourn Conservation Area”. This is unnecessary given this relates to a wider site context and there are general Development Management policies that will appropriately and properly consider heritage matters as part of any planning application for the site.

We note that the Site’s HELAA Assessment (Reference 40490) states as follows regarding the Historic Environment: “Development of the site would have either a neutral or positive impact, but importantly not have a detrimental impact on any designated or non-designated heritage assets.”

On this basis and taking account of the distance between the Site Allocation and the Melbourn Conservation Area and nearest Listed Assets, there is no reason why heritage matters are identified in the wording of the Draft Policy. Any future planning application would include for a consideration of the Site’s context, including archaeological and heritage matters. But there are no exceptional built heritage considerations that merit highlighting in the Policy so we request that these references should be deleted.

POLICY AMENDMENTS

Please see ATTACHED DOCUMENT. We have set out requested changes to the wording of Policy S/RRA/CR. These are set out as a Minimum Required Policy Amendment (retaining a Mixed Use Allocation), and a Preferred Policy Amendment (as a Housing Allocation).

We request the addition of the words “where appropriate” when listing the range of issues to address in sustainability statements, to provide the flexibility intended here.

We support the intent of Draft Policy CC/SD.

We support CC/SD(2) which applies a proportionate approach to sustainability statements. However, we request the addition of the words “where appropriate” when listing the range of issues to address in sustainability statements, to provide the flexibility intended here.

With respect to the content of the Sustainability Statement, Vistry believe that the list of content described in paragraph 2 will need to be amended to reflect the final approved policies post examination which may include the need to remove the requirement for ‘net zero carbon’ should the proposed NPPF changes be implemented.

At CC/DC(1) the word “should” would be more appropriate.

Matters relating to overheating risk, ventilation and internal environmental performance are already comprehensively addressed through the Building Regulations (part O) and associated guidance and should be deleted from this Policy.

We support the intent of Draft Policy CC/DC.

However, we object to the word “must” at CC/DC(1) as this creates a requirement leaving little to no discretion for decision makers. The word “should” would be more appropriate, setting out an expectation unless justified otherwise, which aids decision makers in reaching a balanced judgement.

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 considers that this part of the Policy duplicates other legislation and should be deleted.

Please see above changes. There should be greater clarity between requirements and aspirations.

We object to Draft Policy CC/NZ.

The Draft Policy goes beyond existing sustainability standards for planning, without consideration for impacts on viability and deliverability.

Whilst we welcome the ambition to ensure that all buildings help to meet zero-carbon targets, there needs to be greater flexibility within the policy wording. There should also be clarity regarding what is required and what is aspirational.

With regard to CC/NZ(A), all new dwellings are expected to achieve a space heating demand of 15-20 kwH per metre squared per year. This figure is in line with Climate Change Committee, LETI Net Zero definition and Passivhaus standard, which are higher than other national standards and therefore placing unrealistic expectations on developers.

With regard to CC/NZ(B), the EUI targets are split between uses. For residential dwellings, the targets are set at 35 kWh per metre squared per year which is aligned with LETI Net Zero definition and the National Grid Future Energy Scenarios. Again, the policy goes above and beyond national standards.

It is also understood that the Building Regulations Part L 2025 Update/Future Homes Standard is due to include specific EUI targets once published. As EUI targets will be published in this legislation, it is suggested they are removed from Policy CC/NZ to ensure that the draft policy complies with the Consultation Draft NPPF (2025) Policy PM13 (Setting Standards) and the now withdrawn PPG, which states that planning policies should not replicate matters already addressed by Building Regulations.

The Policy should be clear regarding requirements and aspirations. The word 'must' should be replaced by 'should' to allow for appropriate flexibility. Draft Policy 2a and 2b should be amended to apply a target of 100 litres/person/ day to apply to all dwellings where practical and viable. Any site/development size threshold should be deleted.

We object to the proposed wording of Policy CC/WE.

Draft Policy CC/WE goes beyond national and industry guidance, mandating rainwater or greywater harvesting on all major developments, which will not always be appropriate or deliverable. National policy promotes proportionate, context-led approaches to water efficiency.

We question the use if the word “must” within the Policy as this creates a requirement leaving little to no discretion for decision makers. The word “should” would be more appropriate, setting out an expectation unless justified otherwise, which aids decision makers in reaching a balanced judgement.

With regard to potable water, the policy applies a stricter internal water-use requirement to developments of over 100 dwellings. While the aim of reducing water consumption is supported, it is unclear why development size alone justifies a higher standard. Internal water use is largely determined by occupant behaviour and individual dwelling specifications, rather than the overall scale of a development. Residents cannot reasonably be expected to use less water simply because they live in a larger scheme.

In this context, Vistry considers 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 applies 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 GCLP.

As drafted, the Policy risks being arbitrary and may fail the tests of justification and effectiveness. It should either apply a consistent, evidence-based standard across all residential development or provide clear evidence explaining why a higher requirement is appropriate only for larger schemes.

The Policy wording should be revised to allow for flexibility, proposing a requirement to 'aim to achieve a 20% biodiversity net gain, with a minimum of 10% to be achieved'.

We object to Policy BG/BG.

The national statutory requirement to deliver a minimum 10% Biodiversity Net Gain (BNG) already provides a robust, outcome-based mechanism for securing ecological enhancement.

Draft Policy BG/BG seeks to uplift the mandatory minimum to 20% BNG for major development in Greater Cambridge. This is considered unsound, as it is not adequately justified and is inconsistent with national legislation and guidance.

The national BNG framework provides clarity and certainty for plan-making and decision-taking. Any local requirement exceeding the statutory minimum must therefore be clearly justified, flexible, and grounded in site-specific ecological capacity and viability. The approach set out is not supported by a robust evidence base and does not sufficiently demonstrate that it is proportionate or deliverable.

A drafted, Policy BG/BG risks undermining policy certainty by imposing a fixed uplift beyond the national framework without adequate justification. Any additional BNG delivered above the mandatory 10% requirement should be treated as a material benefit in the planning balance, rather than being expected a mandatory policy requirement.
In this regard, Vistry suggests that the policy wording would benefit from greater flexibility. In particular, the requirement could be framed so that development is required to “aim to achieve a 20% biodiversity net gain, with a minimum of 10% to be achieved”.

The existing requirement for a minimum 10% Biodiversity Net Gain (BNG) is a sufficient mechanism for ecological enhancement, and the proposed tree canopy requirement would duplicate this without justification. We consider that the Policy should be deleted.

Vistry supports the overall objective of the policy to increase tree canopy cover and enhance the quality and resilience of the treescape across Greater Cambridge.

However, the statutory requirement to deliver a minimum 10% Biodiversity Net Gain already provides a robust, outcome-based mechanism for securing ecological enhancement. This framework is flexible, evidence-led and capable of responding to site-specific circumstances. The proposed tree canopy requirement appears to duplicate or cut across the BNG regime, without sufficient justification, and risks prioritising a single ecological metric over a balanced planning judgement with respect to trees within a development site.

The requirement for major development to demonstrate a minimum of 30% tree canopy cover on site risks introducing an inflexible and prescriptive constraint that could undermine development capacity, density and viability. As such, it is not aligned with national planning policy or with the Government’s stated ambition for growth. We suggest that flexibility should be clearly and consistently applied throughout the Policy.

The Draft Policy and supporting text state that canopy cover should be calculated using a Council-approved calculator or metric. However, neither the policy itself nor the Biodiversity and Green Spaces Topic Paper identify what calculator or methodology is intended to be used. In the absence of a defined and agreed approach, the policy lacks clarity and certainty.

In the Greater Cambridge context, where sites are often constrained and development viability is already heavily influenced by multiple policy requirements, the introduction of a fixed canopy cover threshold risks placing an additional and unjustified burden on development. This could compromise scheme deliverability and, in turn, the ability of the Local Plan to be implemented as intended.

The Policy should be deleted or substantially modified. There should be no mandatory requirement for self-build.

We object to Draft Policy H/CB.

We object to the proposed mandatory requirement for 5% self-build homes as part of any development. Such a blanket approach across all developments is unjustified and self-build provision should only be sought on sites where there is a demonstrable need. This would be inconsistent with the Self-build and Custom Housebuilding Act, which focuses on demand registers, not quotas.

The current wording of the policy requires that even flatted developments must provide 5% custom-build units. While the supporting text clarifies that self-build flats would be delivered as custom-finish units, these are often already incorporated by developers as part of standard delivery models. As such, the requirement does not result in any meaningful additional benefit but instead places an unnecessary and disproportionate burden on developers.