Greater Cambridge Local Plan: Proposed Submission

Please see Section 3: Your Representation – the response fully sets out all suggest modifications and why they are necessary to make the GCLP sound.

a. Site Allocations – New Settlements - Policy S/NST: Northstowe New Town
Vistry supports the identification of Northstowe New Town in draft Policy S/NST for a community of approximately 10,180 homes, supported by a range of employment, retail, and community uses, served by the busway connecting Northstowe with Huntingdon, St Ives and Cambridge.
Northstowe Phase 3B represents an excellent opportunity for Greater Cambridge to meet its growth needs
through a highly sustainable location within proximity of public transport services and community facilities.
In particular, given the site’s proximity to Longstanton Park & Ride and Cambridgeshire Guided Busway, it
can deliver growth as part of a truly sustainable development with convenient, frequent and sustainable
connectivity to central Cambridge and other well-connected employment centres around Cambridgeshire.
This sustainable community will be embedded within a landscape setting and include a range of different
housing to meet local needs, supported by community infrastructure and sustainable transport connectivity.
The Outline planning permission (20/02142/OUT) for Phase 3B demonstrates that the site can sustainably
and successfully accommodate the scale of growth identified in the allocation.
Up to 1,000 new homes alongside a primary school and a mixed-use zone with retail, food and drink,
community, leisure, employment and residential uses, would provide a diverse range of housing and
accommodation to meet the needs of different groups within the community. Phase 3B would deliver a wide
a range of benefits that would support the creation of a sustainable, healthy and well-connected community
in Northstowe.
Whilst Vistry supports the continued allocation of the wider Northstowe New Town, we request amendments
to some of the requirements and wording of draft Policy S/NST, as follows:
• Point 2: “a site wide masterplan, prepared by the landowners / promoters in conjunction with the
Council and in consultation with the local community and other stakeholders…
… The masterplan should be agreed by the Council prior to the approval of any outline planning
applications (and may be subsequently updated by the landowners / promoters and agreed by the
Local Planning Authorities).”
• Point 5: “Among these will be a town centre supported by smaller local centres which could
includeing commercial and retail uses, employment uses and sports hub, sports pitches, mixed use
zones, a water park, open space and green corridors, incorporating active travel routes and
associated infrastructure works.
• Point 6: “The new town of Northstowe is allocated for mixed-use development, comprising:
a. Approximately 10,180 homes (delivering 6,201 homes within the plan period) in a wide range of
dwelling types and tenures including:
i. Affordable housing;
ii. 24 Permanent Gypsy and Traveller pitches located
outside but in close proximity to the site, meeting requirements of Policy H/GT;
iii. Community led homes and self/custom build homes; and
iv. Specialist accommodation (Use Class C2 and C3),
particularly for older people or those with disabilities;”

The proposed amendment to point 2 is to make clear that a site-wide masterplan is not expected to be
approved in advance of any phase gaining Reserved Matters consent, as this would be unnecessary with
elements of a masterplan being approved as part of Outline planning permissions, and if this was required
ahead of Reserved Matters then the delivery of different phases would be significantly delayed.
Point 5 revision is in order to clarify that not every local centre will have to include all of the facilities listed,
which would be undeliverable and unnecessary.
Point 6a requires Northstowe to provide 24 permanent Gypsy and Traveller pitches and approximately 850
units of specialist accommodation (Use Class C2 and C3). These requirements are not committed to or
consistent within the Phase 3B outline development description and are therefore introducing unnecessary
prescription and uncertainty, which could constrain the delivery of the approved development. The draft
policy wording risks undermining the effectiveness of the Northstowe New Town allocation and the draft
Local Plan, as the policy is not sufficiently flexible to support the implementation of the extant permissions
and would be inconsistent with national policy and guidance on positive plan-making and deliverability,
rendering the draft Local Plan not effectively prepared.
Similarly, these requirements should be removed from Policy S/DS (Development Strategy) as follows [Delete 2.95 and 2.102].

The requirement for 24 permanent Gypsy and Traveller pitches should be removed from the policy, given
that this requirement has not been demonstrated to be deliverable within the extant outline permissions. The
policy should therefore avoid establishing a prescriptive requirement for 24 pitches without evidence that
suitable and deliverable sites are available, whether within Northstowe or in close proximity to the
development. If retained in its current form, there is a risk that the requirement could conflict with the uses
and development already planned and consented at Northstowe, or result in delays to delivery, contrary to
national policy and guidance on positive plan-making and deliverability.
The requirement for 850 units of specialist accommodation should also be removed, as it introduces
unnecessary complexity and an additional layer of policy that undermines the clarity of the outline permissions. Phase 3B outline permission (20/02142/OUT) condition 53 already requires a minimum of 5% of residential dwellings within Reserved Matters areas to meet the M4(2) standard of The Building Regulations 2010. This is a significant level of specialist accommodation provision, and it is unclear if the draft policy takes account of this. Notwithstanding our view that the policy requirement should be removed,
this 5% requirement secured by the conditions could be included in policy for completeness (as outlined in
Policy H/SS below). Furthermore, the SA identifies the provision of specialist accommodation as contributing
to a significant positive housing effect for Northstowe, but does not explain whether the existing requirements
for accessible and adaptable homes secured through the outline permissions have been taken into account
in determining the additional quantum of specialist accommodation required, meaning the policy may be
mandating a far larger number of units of specialist accommodation across Northstowe. This should also be
considered alongside the draft Development Management policies, including Policy H/SS, which already
provides for accessible and adaptable homes through the M4(2) requirements, although we recommend
minor amendments to the current draft wording. The relationship between these existing requirements and
the policy S/NST requirement of 850 units of specialist accommodation is therefore unclear, and this
requirement should be removed so as to avoid introducing unnecessary complexity and uncertainty that
could compromise the delivery of housing in Northstowe. Vistry also wishes to raise concerns regarding the
wording of point 35, relating to the ‘Lifespan Validation Checklist’. As currently worded, it could lead to
duplication and documents being unnecessarily resubmitted at Reserved Matters stage (which are already
controlled by associated planning conditions on the Outline planning permission) This in turn could lead to
unnecessary delays in terms of expedient delivery of the latter phases of Northstowe New Town. Vistry
therefore requests the following wording amendment: “In addition to the requirements on the Validation
Checklist, the following will be required at the submission of an outline or major planning application,
excluding for Reserved Matters applications where the Outline planning permission already
specifies approval of these documents (including through associated planning conditions) …”

Notwithstanding the above minor requested amendments to the wording of the draft policy, Vistry strongly
supports the allocation of the Site for residential-led development, in supporting ongoing important delivery
of new housing and associated facilities. The following sections set out our response to other draft policies
in the Local Plan Regulation 19 document, focusing on areas of support as well as any soundness concerns
(warranting review and amendment prior to submission for Examination)
b. Vision
Vistry supports the overall vision of the Local Plan. This aligns with NPPF 2024 paragraph 15 to provide a
positive vision and a framework for meeting housing needs whilst addressing other economic, social and
environmental priorities. As part of this, the allocation of Northstowe New Town is required in order to support
the Council to deliver its draft Vision as outlined on pages 29-30 of the draft Plan. This is further supported
by the Council through its inclusion of the site within the key diagram at figure 4 as a retained site allocation.
It is considered that the proposals at Northstowe Phase 3B play an important role in achieving the vision,
including through the delivery of a new sustainable community which includes the provision of a wide range
of different homes (including in size, tenure and type), mixed uses, extensive open space and infrastructure,
such as improved connectivity to public transport and a new primary school.
c. Policy WS/NC: Meeting the needs of growing communities
Point 11 refers to the implementation of services and facilities in “early phases” of development. We raise
concern with the current drafted terminology, as ‘early phases’ is ambiguous and lacks clarity and clear
definition for developers on when ‘early phases’ is. We therefore suggest in order to ensure sufficient
flexibility, the policy should be reworded to adopt a case-by-case basis for the delivery of services and
facilities and allows the timing of infrastructure to be aligned with the cash-flow and peak debt of individual
developments. Appropriate mechanisms already exist for securing the delivery of such items in the form of
S106 agreements and conditions.
As currently worded the policy is ambiguous, creating uncertainty that will place an additional and
unwarranted adverse financial burden on development, challenging viability. We therefore contend the policy
is revised as set out below to ensure the Local Plan is justified.
“ … Implementation
11. The timing delivery of infrastructure, services and facilities will be determined on a case-by-case
basis. Phasing will be established through planning obligations or conditions, and this may include requirements for the use of meanwhile or temporary uses to ensure local needs can be supported until permanent facilities are delivered.”

d. Policy GP/QD: Achieving high-quality development
Vistry objects to point 2(h) of Policy GP/QD, which requires design to integrate security measures such as
‘Hostile Vehicle Mitigation’ which we understand relates to bollards, road blockers, traffic-management
schemes, and reinforced street furniture. Within the policy there is no guidance on where this is required
and as currently worded appears to apply this approach as a blanket across all development. This also
seems to be a duplication of point (d) which requires developments to “create safe open spaces and active
streets that design out crime and consider counter-terrorism protective security measures that are
proportionate to the building, street or place, particularly places with higher crowd densities.”
A separate Hostile Vehicle Mitigation requirement is therefore considered overly onerous, problematic and
does not take into account the specific circumstances, setting and contexts of individual developments and
can have an adverse effect on residential environments and public realm through the introduction of hard
landscape features and street clutter. To be effective and justified the policy should be reworded as below
to state that such design measures will only be required where necessary.
“1. Where necessary, development proposals will be expected to demonstrate how they have addressed
the following design principles and requirements:…"

Further, point 2(i) requires permeability of spaces and routes through development that must be supported
by hard and soft landscaping. Vistry raises concern of potential conflict between points g. (requiring Hostile
Vehicle Mitigation Measures) which often include bollards and barriers and point h., which notes landscape
design should enhance permeability. It is suggested a review of the policy and competing points raised by
points g and h/ d should be undertaken to ensure development remains deliverable and the requirements
placed on developers are clear. This would ensure the policy is effective and justified.
e. Policy GP/QP: Establishing high-quality landscape and public realm
Whilst Vistry supports the inclusion of high-quality landscape and public realm (as permitted for Northstowe
New Town under Outline planning permission ref (20/02142/OUT), Vistry wishes to raise concerns regarding
Policy GP/QP as currently drafted and advocates that the policy is revised to read as follows:
“1. Development proposals are required to deliver high quality landscape and public realm by: …
b) Enhancing connectivity: …
… VI. Parking should not reduce the functionality of open spaces, and if on-street parking is proposed, inset parking will be encouraged. An expanded footway will be
required for pedestrian movements when not occupied;”

As currently drafted, point 1(b)(vi) requires on-street parking to be inset which will necessitate an expanded
footway for pedestrian movements. We raise concern that this is an overly onerous requirement that goes
beyond design guidance such as the Manual for Streets. Such requirements represent an unnecessary
requirement and onerous land take of hard engineering features, creating additional unwarranted
infrastructure costs for development. Development proposals should be designed and developed with
regards to their contextual setting and determined in such respect as well. As such, development should not
be blanket required at a Local Plan level to provide inset parking where it may be wholly inappropriate.
The amendment detailed above would ensure the GCLP is both justified and reflective on national guidance
and policy.
f. Policy H/HM: Housing mix Vistry suggests that point 4 is revised as follows:
“Development proposals will be supported where a mix of housing types (e.g. houses, flats and bungalows)
are provided proportionally across all affordable tenures, taking account of the local character
and built form and up-to date evidence of affordable housing need. Where affordable provision is met or
exceeded a flexible, market led, approach to market provision will be supported.”

Point 4 sets out a requirement for proposals to be supported by a mix that takes into account local character,
built form and up-to-date evidence of housing need. However, HO8(3) of the NPPF (2026) notes where
affordable housing requirements are met or exceeded by a development proposal, then a flexible approach should be taken to the application of development plan requirements for the bedroom mix of market provision
– taking into account prevailing market conditions.
The suggested amendment reflects HO8(3) and explicitly states that up-to-date evidence will only be
required to inform the affordable housing mix provision. Also, Tables 7 and 8 should be revised to remove
the housing mix preference for market housing to maintain suitable flexibility.

g. Policy H/SS: Residential space standards
We also raise concern at the length of the draft policy, which is considered to unnecessarily repeat the
requirements of the NDSS. This risks making the policy too convoluted and difficult to navigate. We suggest
point 2 is removed in full as there is no need to repeat the standards; which may be updated during the
lifetime of the GCLP, and would thus render the point irrelevant.
Point 4(e) sets out the required standards for balconies. We consider that proposals should be designed
and determined on their own merits based on an appreciation of a site’s context and surroundings and the
policy should not be overly prescriptive. As such, we suggest that the policy is reworded to simply state:
“Provide balconies that are designed as integral elements of the building's architecture.

It is considered that point 4(g) should also be revised so that it does not introduce amenity space standards
that are unduly onerous and go beyond those within the Building Regulations. As such the policy should
reduce the minimum quantum of private external amenity space for ground floor apartments to 5m2. The
policy should therefore read as follows:
“Provide a minimum of 105m² private external amenity space for ground floor apartments (irrespective of
the number of bedrooms) immediately outside their living accommodation, with a minimum depth of
2500mm; and…”
Point 4(h) should be revised as follows to not unduly place unachievable requirements for private external
amenity space for apartments based on the number of bedrooms. The requirement for an additional 1m2
per additional bedroom goes beyond the requirements of the Building Regulations and hence should be
deleted from the draft policy in full.
“Provide a private external amenity space of 5 square metres for upper floor apartments through the use of a private balcony with a minimum depth of 1,500 millimetres and a minimum usable width of 3,000 millimetres.
Point 6 requires all new dwellings to be of M4(2) standard. This is considered onerous and again goes
beyond the requirements of the Building Regulations. Point 6 should hence be revised as follows to provide
for an appropriate amount of M4(2) compliant dwellings. We suggest 5% of the overall development being
of M4(2) standard is appropriate.
“All 5% of new build residential units (including residential annexes) must be designed to be accessible and
adaptable in accordance with the Building Regulations M4(2) standard.”
The draft policy should be revised as outlined above to ensure it is both justified and consistent with national
policy and guidance. In turn this will ensure residential development remains viable and is not subject to
unduly onerous requirements.

h. Policy H/CB: Self and custom build homes
Vistry suggests that draft Policy H/CB is revised to recognise site-specific circumstances with regards to the
requirement for self-build homes at individual sites. As such, the current ‘blanket’ approach to 5% self-build
being required as part of ‘any development’ is not supported (acknowledging this could cause issues with
wider site delivery). This would be inconsistent with the Self-build and Custom Housebuilding Act, which
focuses on demand registers, not quotas.
The specific types of housing schemes that are not appropriate should also be included in the wording. The
current wording of the draft 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 is considered to place an unnecessary and disproportionate burden on developers, particularly in higher-density schemes where viability and
deliverability is already constrained by the requirements of the draft Plan.
It should also be clarified how the requirement would be applied on multi-phase developments, and how the
policy would retain flexibility for strategic sites that are delivered over a long period of time (i.e. Northstowe
New Town).
We therefore request the policy wording is amended as per the below:
“1. Subject to viability, deliverability, and individual site circumstances, development proposals
including 20 or more dwellings must provide at least 5% of the new homes as serviced plots for custom and
self-build houses and/or serviced custom-build flats. Specific types of housing schemes such as flatted
developments and [any other scheme types] are not appropriate for custom and self-build homes and
are therefore excluded from this requirement.”

Please see Section 3: Your Representation – the response fully sets out all suggest modifications and why they are necessary to make the GCLP sound.

a. Site Allocations – New Settlements - Policy S/NST: Northstowe New Town
Vistry supports the identification of Northstowe New Town in draft Policy S/NST for a community of approximately 10,180 homes, supported by a range of employment, retail, and community uses, served by the busway connecting Northstowe with Huntingdon, St Ives and Cambridge.
Northstowe Phase 3B represents an excellent opportunity for Greater Cambridge to meet its growth needs
through a highly sustainable location within proximity of public transport services and community facilities.
In particular, given the site’s proximity to Longstanton Park & Ride and Cambridgeshire Guided Busway, it
can deliver growth as part of a truly sustainable development with convenient, frequent and sustainable
connectivity to central Cambridge and other well-connected employment centres around Cambridgeshire.
This sustainable community will be embedded within a landscape setting and include a range of different
housing to meet local needs, supported by community infrastructure and sustainable transport connectivity.
The Outline planning permission (20/02142/OUT) for Phase 3B demonstrates that the site can sustainably
and successfully accommodate the scale of growth identified in the allocation.
Up to 1,000 new homes alongside a primary school and a mixed-use zone with retail, food and drink,
community, leisure, employment and residential uses, would provide a diverse range of housing and
accommodation to meet the needs of different groups within the community. Phase 3B would deliver a wide
a range of benefits that would support the creation of a sustainable, healthy and well-connected community
in Northstowe.
Whilst Vistry supports the continued allocation of the wider Northstowe New Town, we request amendments
to some of the requirements and wording of draft Policy S/NST, as follows:
• Point 2: “a site wide masterplan, prepared by the landowners / promoters in conjunction with the
Council and in consultation with the local community and other stakeholders…
… The masterplan should be agreed by the Council prior to the approval of any outline planning
applications (and may be subsequently updated by the landowners / promoters and agreed by the
Local Planning Authorities).”
• Point 5: “Among these will be a town centre supported by smaller local centres which could
includeing commercial and retail uses, employment uses and sports hub, sports pitches, mixed use
zones, a water park, open space and green corridors, incorporating active travel routes and
associated infrastructure works.
• Point 6: “The new town of Northstowe is allocated for mixed-use development, comprising:
a. Approximately 10,180 homes (delivering 6,201 homes within the plan period) in a wide range of
dwelling types and tenures including:
i. Affordable housing;
ii. 24 Permanent Gypsy and Traveller pitches located
outside but in close proximity to the site, meeting requirements of Policy H/GT;
iii. Community led homes and self/custom build homes; and
iv. Specialist accommodation (Use Class C2 and C3),
particularly for older people or those with disabilities;”

The proposed amendment to point 2 is to make clear that a site-wide masterplan is not expected to be
approved in advance of any phase gaining Reserved Matters consent, as this would be unnecessary with
elements of a masterplan being approved as part of Outline planning permissions, and if this was required
ahead of Reserved Matters then the delivery of different phases would be significantly delayed.
Point 5 revision is in order to clarify that not every local centre will have to include all of the facilities listed,
which would be undeliverable and unnecessary.
Point 6a requires Northstowe to provide 24 permanent Gypsy and Traveller pitches and approximately 850
units of specialist accommodation (Use Class C2 and C3). These requirements are not committed to or
consistent within the Phase 3B outline development description and are therefore introducing unnecessary
prescription and uncertainty, which could constrain the delivery of the approved development. The draft
policy wording risks undermining the effectiveness of the Northstowe New Town allocation and the draft
Local Plan, as the policy is not sufficiently flexible to support the implementation of the extant permissions
and would be inconsistent with national policy and guidance on positive plan-making and deliverability,
rendering the draft Local Plan not effectively prepared.
Similarly, these requirements should be removed from Policy S/DS (Development Strategy) as follows [Delete 2.95 and 2.102].

The requirement for 24 permanent Gypsy and Traveller pitches should be removed from the policy, given
that this requirement has not been demonstrated to be deliverable within the extant outline permissions. The
policy should therefore avoid establishing a prescriptive requirement for 24 pitches without evidence that
suitable and deliverable sites are available, whether within Northstowe or in close proximity to the
development. If retained in its current form, there is a risk that the requirement could conflict with the uses
and development already planned and consented at Northstowe, or result in delays to delivery, contrary to
national policy and guidance on positive plan-making and deliverability.
The requirement for 850 units of specialist accommodation should also be removed, as it introduces
unnecessary complexity and an additional layer of policy that undermines the clarity of the outline permissions. Phase 3B outline permission (20/02142/OUT) condition 53 already requires a minimum of 5% of residential dwellings within Reserved Matters areas to meet the M4(2) standard of The Building Regulations 2010. This is a significant level of specialist accommodation provision, and it is unclear if the draft policy takes account of this. Notwithstanding our view that the policy requirement should be removed,
this 5% requirement secured by the conditions could be included in policy for completeness (as outlined in
Policy H/SS below). Furthermore, the SA identifies the provision of specialist accommodation as contributing
to a significant positive housing effect for Northstowe, but does not explain whether the existing requirements
for accessible and adaptable homes secured through the outline permissions have been taken into account
in determining the additional quantum of specialist accommodation required, meaning the policy may be
mandating a far larger number of units of specialist accommodation across Northstowe. This should also be
considered alongside the draft Development Management policies, including Policy H/SS, which already
provides for accessible and adaptable homes through the M4(2) requirements, although we recommend
minor amendments to the current draft wording. The relationship between these existing requirements and
the policy S/NST requirement of 850 units of specialist accommodation is therefore unclear, and this
requirement should be removed so as to avoid introducing unnecessary complexity and uncertainty that
could compromise the delivery of housing in Northstowe. Vistry also wishes to raise concerns regarding the
wording of point 35, relating to the ‘Lifespan Validation Checklist’. As currently worded, it could lead to
duplication and documents being unnecessarily resubmitted at Reserved Matters stage (which are already
controlled by associated planning conditions on the Outline planning permission) This in turn could lead to
unnecessary delays in terms of expedient delivery of the latter phases of Northstowe New Town. Vistry
therefore requests the following wording amendment: “In addition to the requirements on the Validation
Checklist, the following will be required at the submission of an outline or major planning application,
excluding for Reserved Matters applications where the Outline planning permission already
specifies approval of these documents (including through associated planning conditions) …”

Notwithstanding the above minor requested amendments to the wording of the draft policy, Vistry strongly
supports the allocation of the Site for residential-led development, in supporting ongoing important delivery
of new housing and associated facilities. The following sections set out our response to other draft policies
in the Local Plan Regulation 19 document, focusing on areas of support as well as any soundness concerns
(warranting review and amendment prior to submission for Examination)
b. Vision
Vistry supports the overall vision of the Local Plan. This aligns with NPPF 2024 paragraph 15 to provide a
positive vision and a framework for meeting housing needs whilst addressing other economic, social and
environmental priorities. As part of this, the allocation of Northstowe New Town is required in order to support
the Council to deliver its draft Vision as outlined on pages 29-30 of the draft Plan. This is further supported
by the Council through its inclusion of the site within the key diagram at figure 4 as a retained site allocation.
It is considered that the proposals at Northstowe Phase 3B play an important role in achieving the vision,
including through the delivery of a new sustainable community which includes the provision of a wide range
of different homes (including in size, tenure and type), mixed uses, extensive open space and infrastructure,
such as improved connectivity to public transport and a new primary school.
c. Policy WS/NC: Meeting the needs of growing communities
Point 11 refers to the implementation of services and facilities in “early phases” of development. We raise
concern with the current drafted terminology, as ‘early phases’ is ambiguous and lacks clarity and clear
definition for developers on when ‘early phases’ is. We therefore suggest in order to ensure sufficient
flexibility, the policy should be reworded to adopt a case-by-case basis for the delivery of services and
facilities and allows the timing of infrastructure to be aligned with the cash-flow and peak debt of individual
developments. Appropriate mechanisms already exist for securing the delivery of such items in the form of
S106 agreements and conditions.
As currently worded the policy is ambiguous, creating uncertainty that will place an additional and
unwarranted adverse financial burden on development, challenging viability. We therefore contend the policy
is revised as set out below to ensure the Local Plan is justified.
“ … Implementation
11. The timing delivery of infrastructure, services and facilities will be determined on a case-by-case
basis. Phasing will be established through planning obligations or conditions, and this may include requirements for the use of meanwhile or temporary uses to ensure local needs can be supported until permanent facilities are delivered.”

d. Policy GP/QD: Achieving high-quality development
Vistry objects to point 2(h) of Policy GP/QD, which requires design to integrate security measures such as
‘Hostile Vehicle Mitigation’ which we understand relates to bollards, road blockers, traffic-management
schemes, and reinforced street furniture. Within the policy there is no guidance on where this is required
and as currently worded appears to apply this approach as a blanket across all development. This also
seems to be a duplication of point (d) which requires developments to “create safe open spaces and active
streets that design out crime and consider counter-terrorism protective security measures that are
proportionate to the building, street or place, particularly places with higher crowd densities.”
A separate Hostile Vehicle Mitigation requirement is therefore considered overly onerous, problematic and
does not take into account the specific circumstances, setting and contexts of individual developments and
can have an adverse effect on residential environments and public realm through the introduction of hard
landscape features and street clutter. To be effective and justified the policy should be reworded as below
to state that such design measures will only be required where necessary.
“1. Where necessary, development proposals will be expected to demonstrate how they have addressed
the following design principles and requirements:…"

Further, point 2(i) requires permeability of spaces and routes through development that must be supported
by hard and soft landscaping. Vistry raises concern of potential conflict between points g. (requiring Hostile
Vehicle Mitigation Measures) which often include bollards and barriers and point h., which notes landscape
design should enhance permeability. It is suggested a review of the policy and competing points raised by
points g and h/ d should be undertaken to ensure development remains deliverable and the requirements
placed on developers are clear. This would ensure the policy is effective and justified.
e. Policy GP/QP: Establishing high-quality landscape and public realm
Whilst Vistry supports the inclusion of high-quality landscape and public realm (as permitted for Northstowe
New Town under Outline planning permission ref (20/02142/OUT), Vistry wishes to raise concerns regarding
Policy GP/QP as currently drafted and advocates that the policy is revised to read as follows:
“1. Development proposals are required to deliver high quality landscape and public realm by: …
b) Enhancing connectivity: …
… VI. Parking should not reduce the functionality of open spaces, and if on-street parking is proposed, inset parking will be encouraged. An expanded footway will be
required for pedestrian movements when not occupied;”

As currently drafted, point 1(b)(vi) requires on-street parking to be inset which will necessitate an expanded
footway for pedestrian movements. We raise concern that this is an overly onerous requirement that goes
beyond design guidance such as the Manual for Streets. Such requirements represent an unnecessary
requirement and onerous land take of hard engineering features, creating additional unwarranted
infrastructure costs for development. Development proposals should be designed and developed with
regards to their contextual setting and determined in such respect as well. As such, development should not
be blanket required at a Local Plan level to provide inset parking where it may be wholly inappropriate.
The amendment detailed above would ensure the GCLP is both justified and reflective on national guidance
and policy.
f. Policy H/HM: Housing mix Vistry suggests that point 4 is revised as follows:
“Development proposals will be supported where a mix of housing types (e.g. houses, flats and bungalows)
are provided proportionally across all affordable tenures, taking account of the local character
and built form and up-to date evidence of affordable housing need. Where affordable provision is met or
exceeded a flexible, market led, approach to market provision will be supported.”

Point 4 sets out a requirement for proposals to be supported by a mix that takes into account local character,
built form and up-to-date evidence of housing need. However, HO8(3) of the NPPF (2026) notes where
affordable housing requirements are met or exceeded by a development proposal, then a flexible approach should be taken to the application of development plan requirements for the bedroom mix of market provision
– taking into account prevailing market conditions.
The suggested amendment reflects HO8(3) and explicitly states that up-to-date evidence will only be
required to inform the affordable housing mix provision. Also, Tables 7 and 8 should be revised to remove
the housing mix preference for market housing to maintain suitable flexibility.

g. Policy H/SS: Residential space standards
We also raise concern at the length of the draft policy, which is considered to unnecessarily repeat the
requirements of the NDSS. This risks making the policy too convoluted and difficult to navigate. We suggest
point 2 is removed in full as there is no need to repeat the standards; which may be updated during the
lifetime of the GCLP, and would thus render the point irrelevant.
Point 4(e) sets out the required standards for balconies. We consider that proposals should be designed
and determined on their own merits based on an appreciation of a site’s context and surroundings and the
policy should not be overly prescriptive. As such, we suggest that the policy is reworded to simply state:
“Provide balconies that are designed as integral elements of the building's architecture.

It is considered that point 4(g) should also be revised so that it does not introduce amenity space standards
that are unduly onerous and go beyond those within the Building Regulations. As such the policy should
reduce the minimum quantum of private external amenity space for ground floor apartments to 5m2. The
policy should therefore read as follows:
“Provide a minimum of 105m² private external amenity space for ground floor apartments (irrespective of
the number of bedrooms) immediately outside their living accommodation, with a minimum depth of
2500mm; and…”
Point 4(h) should be revised as follows to not unduly place unachievable requirements for private external
amenity space for apartments based on the number of bedrooms. The requirement for an additional 1m2
per additional bedroom goes beyond the requirements of the Building Regulations and hence should be
deleted from the draft policy in full.
“Provide a private external amenity space of 5 square metres for upper floor apartments through the use of a private balcony with a minimum depth of 1,500 millimetres and a minimum usable width of 3,000 millimetres.
Point 6 requires all new dwellings to be of M4(2) standard. This is considered onerous and again goes
beyond the requirements of the Building Regulations. Point 6 should hence be revised as follows to provide
for an appropriate amount of M4(2) compliant dwellings. We suggest 5% of the overall development being
of M4(2) standard is appropriate.
“All 5% of new build residential units (including residential annexes) must be designed to be accessible and
adaptable in accordance with the Building Regulations M4(2) standard.”
The draft policy should be revised as outlined above to ensure it is both justified and consistent with national
policy and guidance. In turn this will ensure residential development remains viable and is not subject to
unduly onerous requirements.

h. Policy H/CB: Self and custom build homes
Vistry suggests that draft Policy H/CB is revised to recognise site-specific circumstances with regards to the
requirement for self-build homes at individual sites. As such, the current ‘blanket’ approach to 5% self-build
being required as part of ‘any development’ is not supported (acknowledging this could cause issues with
wider site delivery). This would be inconsistent with the Self-build and Custom Housebuilding Act, which
focuses on demand registers, not quotas.
The specific types of housing schemes that are not appropriate should also be included in the wording. The
current wording of the draft 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 is considered to place an unnecessary and disproportionate burden on developers, particularly in higher-density schemes where viability and
deliverability is already constrained by the requirements of the draft Plan.
It should also be clarified how the requirement would be applied on multi-phase developments, and how the
policy would retain flexibility for strategic sites that are delivered over a long period of time (i.e. Northstowe
New Town).
We therefore request the policy wording is amended as per the below:
“1. Subject to viability, deliverability, and individual site circumstances, development proposals
including 20 or more dwellings must provide at least 5% of the new homes as serviced plots for custom and
self-build houses and/or serviced custom-build flats. Specific types of housing schemes such as flatted
developments and [any other scheme types] are not appropriate for custom and self-build homes and
are therefore excluded from this requirement.”

Please see Section 3: Your Representation – the response fully sets out all suggest modifications and why they are necessary to make the GCLP sound.

a. Site Allocations – New Settlements - Policy S/NST: Northstowe New Town
Vistry supports the identification of Northstowe New Town in draft Policy S/NST for a community of approximately 10,180 homes, supported by a range of employment, retail, and community uses, served by the busway connecting Northstowe with Huntingdon, St Ives and Cambridge.
Northstowe Phase 3B represents an excellent opportunity for Greater Cambridge to meet its growth needs
through a highly sustainable location within proximity of public transport services and community facilities.
In particular, given the site’s proximity to Longstanton Park & Ride and Cambridgeshire Guided Busway, it
can deliver growth as part of a truly sustainable development with convenient, frequent and sustainable
connectivity to central Cambridge and other well-connected employment centres around Cambridgeshire.
This sustainable community will be embedded within a landscape setting and include a range of different
housing to meet local needs, supported by community infrastructure and sustainable transport connectivity.
The Outline planning permission (20/02142/OUT) for Phase 3B demonstrates that the site can sustainably
and successfully accommodate the scale of growth identified in the allocation.
Up to 1,000 new homes alongside a primary school and a mixed-use zone with retail, food and drink,
community, leisure, employment and residential uses, would provide a diverse range of housing and
accommodation to meet the needs of different groups within the community. Phase 3B would deliver a wide
a range of benefits that would support the creation of a sustainable, healthy and well-connected community
in Northstowe.
Whilst Vistry supports the continued allocation of the wider Northstowe New Town, we request amendments
to some of the requirements and wording of draft Policy S/NST, as follows:
• Point 2: “a site wide masterplan, prepared by the landowners / promoters in conjunction with the
Council and in consultation with the local community and other stakeholders…
… The masterplan should be agreed by the Council prior to the approval of any outline planning
applications (and may be subsequently updated by the landowners / promoters and agreed by the
Local Planning Authorities).”
• Point 5: “Among these will be a town centre supported by smaller local centres which could
includeing commercial and retail uses, employment uses and sports hub, sports pitches, mixed use
zones, a water park, open space and green corridors, incorporating active travel routes and
associated infrastructure works.
• Point 6: “The new town of Northstowe is allocated for mixed-use development, comprising:
a. Approximately 10,180 homes (delivering 6,201 homes within the plan period) in a wide range of
dwelling types and tenures including:
i. Affordable housing;
ii. 24 Permanent Gypsy and Traveller pitches located
outside but in close proximity to the site, meeting requirements of Policy H/GT;
iii. Community led homes and self/custom build homes; and
iv. Specialist accommodation (Use Class C2 and C3),
particularly for older people or those with disabilities;”

The proposed amendment to point 2 is to make clear that a site-wide masterplan is not expected to be
approved in advance of any phase gaining Reserved Matters consent, as this would be unnecessary with
elements of a masterplan being approved as part of Outline planning permissions, and if this was required
ahead of Reserved Matters then the delivery of different phases would be significantly delayed.
Point 5 revision is in order to clarify that not every local centre will have to include all of the facilities listed,
which would be undeliverable and unnecessary.
Point 6a requires Northstowe to provide 24 permanent Gypsy and Traveller pitches and approximately 850
units of specialist accommodation (Use Class C2 and C3). These requirements are not committed to or
consistent within the Phase 3B outline development description and are therefore introducing unnecessary
prescription and uncertainty, which could constrain the delivery of the approved development. The draft
policy wording risks undermining the effectiveness of the Northstowe New Town allocation and the draft
Local Plan, as the policy is not sufficiently flexible to support the implementation of the extant permissions
and would be inconsistent with national policy and guidance on positive plan-making and deliverability,
rendering the draft Local Plan not effectively prepared.
Similarly, these requirements should be removed from Policy S/DS (Development Strategy) as follows [Delete 2.95 and 2.102].

The requirement for 24 permanent Gypsy and Traveller pitches should be removed from the policy, given
that this requirement has not been demonstrated to be deliverable within the extant outline permissions. The
policy should therefore avoid establishing a prescriptive requirement for 24 pitches without evidence that
suitable and deliverable sites are available, whether within Northstowe or in close proximity to the
development. If retained in its current form, there is a risk that the requirement could conflict with the uses
and development already planned and consented at Northstowe, or result in delays to delivery, contrary to
national policy and guidance on positive plan-making and deliverability.
The requirement for 850 units of specialist accommodation should also be removed, as it introduces
unnecessary complexity and an additional layer of policy that undermines the clarity of the outline permissions. Phase 3B outline permission (20/02142/OUT) condition 53 already requires a minimum of 5% of residential dwellings within Reserved Matters areas to meet the M4(2) standard of The Building Regulations 2010. This is a significant level of specialist accommodation provision, and it is unclear if the draft policy takes account of this. Notwithstanding our view that the policy requirement should be removed,
this 5% requirement secured by the conditions could be included in policy for completeness (as outlined in
Policy H/SS below). Furthermore, the SA identifies the provision of specialist accommodation as contributing
to a significant positive housing effect for Northstowe, but does not explain whether the existing requirements
for accessible and adaptable homes secured through the outline permissions have been taken into account
in determining the additional quantum of specialist accommodation required, meaning the policy may be
mandating a far larger number of units of specialist accommodation across Northstowe. This should also be
considered alongside the draft Development Management policies, including Policy H/SS, which already
provides for accessible and adaptable homes through the M4(2) requirements, although we recommend
minor amendments to the current draft wording. The relationship between these existing requirements and
the policy S/NST requirement of 850 units of specialist accommodation is therefore unclear, and this
requirement should be removed so as to avoid introducing unnecessary complexity and uncertainty that
could compromise the delivery of housing in Northstowe. Vistry also wishes to raise concerns regarding the
wording of point 35, relating to the ‘Lifespan Validation Checklist’. As currently worded, it could lead to
duplication and documents being unnecessarily resubmitted at Reserved Matters stage (which are already
controlled by associated planning conditions on the Outline planning permission) This in turn could lead to
unnecessary delays in terms of expedient delivery of the latter phases of Northstowe New Town. Vistry
therefore requests the following wording amendment: “In addition to the requirements on the Validation
Checklist, the following will be required at the submission of an outline or major planning application,
excluding for Reserved Matters applications where the Outline planning permission already
specifies approval of these documents (including through associated planning conditions) …”

Notwithstanding the above minor requested amendments to the wording of the draft policy, Vistry strongly
supports the allocation of the Site for residential-led development, in supporting ongoing important delivery
of new housing and associated facilities. The following sections set out our response to other draft policies
in the Local Plan Regulation 19 document, focusing on areas of support as well as any soundness concerns
(warranting review and amendment prior to submission for Examination)
b. Vision
Vistry supports the overall vision of the Local Plan. This aligns with NPPF 2024 paragraph 15 to provide a
positive vision and a framework for meeting housing needs whilst addressing other economic, social and
environmental priorities. As part of this, the allocation of Northstowe New Town is required in order to support
the Council to deliver its draft Vision as outlined on pages 29-30 of the draft Plan. This is further supported
by the Council through its inclusion of the site within the key diagram at figure 4 as a retained site allocation.
It is considered that the proposals at Northstowe Phase 3B play an important role in achieving the vision,
including through the delivery of a new sustainable community which includes the provision of a wide range
of different homes (including in size, tenure and type), mixed uses, extensive open space and infrastructure,
such as improved connectivity to public transport and a new primary school.
c. Policy WS/NC: Meeting the needs of growing communities
Point 11 refers to the implementation of services and facilities in “early phases” of development. We raise
concern with the current drafted terminology, as ‘early phases’ is ambiguous and lacks clarity and clear
definition for developers on when ‘early phases’ is. We therefore suggest in order to ensure sufficient
flexibility, the policy should be reworded to adopt a case-by-case basis for the delivery of services and
facilities and allows the timing of infrastructure to be aligned with the cash-flow and peak debt of individual
developments. Appropriate mechanisms already exist for securing the delivery of such items in the form of
S106 agreements and conditions.
As currently worded the policy is ambiguous, creating uncertainty that will place an additional and
unwarranted adverse financial burden on development, challenging viability. We therefore contend the policy
is revised as set out below to ensure the Local Plan is justified.
“ … Implementation
11. The timing delivery of infrastructure, services and facilities will be determined on a case-by-case
basis. Phasing will be established through planning obligations or conditions, and this may include requirements for the use of meanwhile or temporary uses to ensure local needs can be supported until permanent facilities are delivered.”

d. Policy GP/QD: Achieving high-quality development
Vistry objects to point 2(h) of Policy GP/QD, which requires design to integrate security measures such as
‘Hostile Vehicle Mitigation’ which we understand relates to bollards, road blockers, traffic-management
schemes, and reinforced street furniture. Within the policy there is no guidance on where this is required
and as currently worded appears to apply this approach as a blanket across all development. This also
seems to be a duplication of point (d) which requires developments to “create safe open spaces and active
streets that design out crime and consider counter-terrorism protective security measures that are
proportionate to the building, street or place, particularly places with higher crowd densities.”
A separate Hostile Vehicle Mitigation requirement is therefore considered overly onerous, problematic and
does not take into account the specific circumstances, setting and contexts of individual developments and
can have an adverse effect on residential environments and public realm through the introduction of hard
landscape features and street clutter. To be effective and justified the policy should be reworded as below
to state that such design measures will only be required where necessary.
“1. Where necessary, development proposals will be expected to demonstrate how they have addressed
the following design principles and requirements:…"

Further, point 2(i) requires permeability of spaces and routes through development that must be supported
by hard and soft landscaping. Vistry raises concern of potential conflict between points g. (requiring Hostile
Vehicle Mitigation Measures) which often include bollards and barriers and point h., which notes landscape
design should enhance permeability. It is suggested a review of the policy and competing points raised by
points g and h/ d should be undertaken to ensure development remains deliverable and the requirements
placed on developers are clear. This would ensure the policy is effective and justified.
e. Policy GP/QP: Establishing high-quality landscape and public realm
Whilst Vistry supports the inclusion of high-quality landscape and public realm (as permitted for Northstowe
New Town under Outline planning permission ref (20/02142/OUT), Vistry wishes to raise concerns regarding
Policy GP/QP as currently drafted and advocates that the policy is revised to read as follows:
“1. Development proposals are required to deliver high quality landscape and public realm by: …
b) Enhancing connectivity: …
… VI. Parking should not reduce the functionality of open spaces, and if on-street parking is proposed, inset parking will be encouraged. An expanded footway will be
required for pedestrian movements when not occupied;”

As currently drafted, point 1(b)(vi) requires on-street parking to be inset which will necessitate an expanded
footway for pedestrian movements. We raise concern that this is an overly onerous requirement that goes
beyond design guidance such as the Manual for Streets. Such requirements represent an unnecessary
requirement and onerous land take of hard engineering features, creating additional unwarranted
infrastructure costs for development. Development proposals should be designed and developed with
regards to their contextual setting and determined in such respect as well. As such, development should not
be blanket required at a Local Plan level to provide inset parking where it may be wholly inappropriate.
The amendment detailed above would ensure the GCLP is both justified and reflective on national guidance
and policy.
f. Policy H/HM: Housing mix Vistry suggests that point 4 is revised as follows:
“Development proposals will be supported where a mix of housing types (e.g. houses, flats and bungalows)
are provided proportionally across all affordable tenures, taking account of the local character
and built form and up-to date evidence of affordable housing need. Where affordable provision is met or
exceeded a flexible, market led, approach to market provision will be supported.”

Point 4 sets out a requirement for proposals to be supported by a mix that takes into account local character,
built form and up-to-date evidence of housing need. However, HO8(3) of the NPPF (2026) notes where
affordable housing requirements are met or exceeded by a development proposal, then a flexible approach should be taken to the application of development plan requirements for the bedroom mix of market provision
– taking into account prevailing market conditions.
The suggested amendment reflects HO8(3) and explicitly states that up-to-date evidence will only be
required to inform the affordable housing mix provision. Also, Tables 7 and 8 should be revised to remove
the housing mix preference for market housing to maintain suitable flexibility.

g. Policy H/SS: Residential space standards
We also raise concern at the length of the draft policy, which is considered to unnecessarily repeat the
requirements of the NDSS. This risks making the policy too convoluted and difficult to navigate. We suggest
point 2 is removed in full as there is no need to repeat the standards; which may be updated during the
lifetime of the GCLP, and would thus render the point irrelevant.
Point 4(e) sets out the required standards for balconies. We consider that proposals should be designed
and determined on their own merits based on an appreciation of a site’s context and surroundings and the
policy should not be overly prescriptive. As such, we suggest that the policy is reworded to simply state:
“Provide balconies that are designed as integral elements of the building's architecture.

It is considered that point 4(g) should also be revised so that it does not introduce amenity space standards
that are unduly onerous and go beyond those within the Building Regulations. As such the policy should
reduce the minimum quantum of private external amenity space for ground floor apartments to 5m2. The
policy should therefore read as follows:
“Provide a minimum of 105m² private external amenity space for ground floor apartments (irrespective of
the number of bedrooms) immediately outside their living accommodation, with a minimum depth of
2500mm; and…”
Point 4(h) should be revised as follows to not unduly place unachievable requirements for private external
amenity space for apartments based on the number of bedrooms. The requirement for an additional 1m2
per additional bedroom goes beyond the requirements of the Building Regulations and hence should be
deleted from the draft policy in full.
“Provide a private external amenity space of 5 square metres for upper floor apartments through the use of a private balcony with a minimum depth of 1,500 millimetres and a minimum usable width of 3,000 millimetres.
Point 6 requires all new dwellings to be of M4(2) standard. This is considered onerous and again goes
beyond the requirements of the Building Regulations. Point 6 should hence be revised as follows to provide
for an appropriate amount of M4(2) compliant dwellings. We suggest 5% of the overall development being
of M4(2) standard is appropriate.
“All 5% of new build residential units (including residential annexes) must be designed to be accessible and
adaptable in accordance with the Building Regulations M4(2) standard.”
The draft policy should be revised as outlined above to ensure it is both justified and consistent with national
policy and guidance. In turn this will ensure residential development remains viable and is not subject to
unduly onerous requirements.

h. Policy H/CB: Self and custom build homes
Vistry suggests that draft Policy H/CB is revised to recognise site-specific circumstances with regards to the
requirement for self-build homes at individual sites. As such, the current ‘blanket’ approach to 5% self-build
being required as part of ‘any development’ is not supported (acknowledging this could cause issues with
wider site delivery). This would be inconsistent with the Self-build and Custom Housebuilding Act, which
focuses on demand registers, not quotas.
The specific types of housing schemes that are not appropriate should also be included in the wording. The
current wording of the draft 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 is considered to place an unnecessary and disproportionate burden on developers, particularly in higher-density schemes where viability and
deliverability is already constrained by the requirements of the draft Plan.
It should also be clarified how the requirement would be applied on multi-phase developments, and how the
policy would retain flexibility for strategic sites that are delivered over a long period of time (i.e. Northstowe
New Town).
We therefore request the policy wording is amended as per the below:
“1. Subject to viability, deliverability, and individual site circumstances, development proposals
including 20 or more dwellings must provide at least 5% of the new homes as serviced plots for custom and
self-build houses and/or serviced custom-build flats. Specific types of housing schemes such as flatted
developments and [any other scheme types] are not appropriate for custom and self-build homes and
are therefore excluded from this requirement.”

Please see Section 3: Your Representation – the response fully sets out all suggest modifications and why they are necessary to make the GCLP sound.

a. Site Allocations – New Settlements - Policy S/NST: Northstowe New Town
Vistry supports the identification of Northstowe New Town in draft Policy S/NST for a community of approximately 10,180 homes, supported by a range of employment, retail, and community uses, served by the busway connecting Northstowe with Huntingdon, St Ives and Cambridge.
Northstowe Phase 3B represents an excellent opportunity for Greater Cambridge to meet its growth needs
through a highly sustainable location within proximity of public transport services and community facilities.
In particular, given the site’s proximity to Longstanton Park & Ride and Cambridgeshire Guided Busway, it
can deliver growth as part of a truly sustainable development with convenient, frequent and sustainable
connectivity to central Cambridge and other well-connected employment centres around Cambridgeshire.
This sustainable community will be embedded within a landscape setting and include a range of different
housing to meet local needs, supported by community infrastructure and sustainable transport connectivity.
The Outline planning permission (20/02142/OUT) for Phase 3B demonstrates that the site can sustainably
and successfully accommodate the scale of growth identified in the allocation.
Up to 1,000 new homes alongside a primary school and a mixed-use zone with retail, food and drink,
community, leisure, employment and residential uses, would provide a diverse range of housing and
accommodation to meet the needs of different groups within the community. Phase 3B would deliver a wide
a range of benefits that would support the creation of a sustainable, healthy and well-connected community
in Northstowe.
Whilst Vistry supports the continued allocation of the wider Northstowe New Town, we request amendments
to some of the requirements and wording of draft Policy S/NST, as follows:
• Point 2: “a site wide masterplan, prepared by the landowners / promoters in conjunction with the
Council and in consultation with the local community and other stakeholders…
… The masterplan should be agreed by the Council prior to the approval of any outline planning
applications (and may be subsequently updated by the landowners / promoters and agreed by the
Local Planning Authorities).”
• Point 5: “Among these will be a town centre supported by smaller local centres which could
includeing commercial and retail uses, employment uses and sports hub, sports pitches, mixed use
zones, a water park, open space and green corridors, incorporating active travel routes and
associated infrastructure works.
• Point 6: “The new town of Northstowe is allocated for mixed-use development, comprising:
a. Approximately 10,180 homes (delivering 6,201 homes within the plan period) in a wide range of
dwelling types and tenures including:
i. Affordable housing;
ii. 24 Permanent Gypsy and Traveller pitches located
outside but in close proximity to the site, meeting requirements of Policy H/GT;
iii. Community led homes and self/custom build homes; and
iv. Specialist accommodation (Use Class C2 and C3),
particularly for older people or those with disabilities;”

The proposed amendment to point 2 is to make clear that a site-wide masterplan is not expected to be
approved in advance of any phase gaining Reserved Matters consent, as this would be unnecessary with
elements of a masterplan being approved as part of Outline planning permissions, and if this was required
ahead of Reserved Matters then the delivery of different phases would be significantly delayed.
Point 5 revision is in order to clarify that not every local centre will have to include all of the facilities listed,
which would be undeliverable and unnecessary.
Point 6a requires Northstowe to provide 24 permanent Gypsy and Traveller pitches and approximately 850
units of specialist accommodation (Use Class C2 and C3). These requirements are not committed to or
consistent within the Phase 3B outline development description and are therefore introducing unnecessary
prescription and uncertainty, which could constrain the delivery of the approved development. The draft
policy wording risks undermining the effectiveness of the Northstowe New Town allocation and the draft
Local Plan, as the policy is not sufficiently flexible to support the implementation of the extant permissions
and would be inconsistent with national policy and guidance on positive plan-making and deliverability,
rendering the draft Local Plan not effectively prepared.
Similarly, these requirements should be removed from Policy S/DS (Development Strategy) as follows [Delete 2.95 and 2.102].

The requirement for 24 permanent Gypsy and Traveller pitches should be removed from the policy, given
that this requirement has not been demonstrated to be deliverable within the extant outline permissions. The
policy should therefore avoid establishing a prescriptive requirement for 24 pitches without evidence that
suitable and deliverable sites are available, whether within Northstowe or in close proximity to the
development. If retained in its current form, there is a risk that the requirement could conflict with the uses
and development already planned and consented at Northstowe, or result in delays to delivery, contrary to
national policy and guidance on positive plan-making and deliverability.
The requirement for 850 units of specialist accommodation should also be removed, as it introduces
unnecessary complexity and an additional layer of policy that undermines the clarity of the outline permissions. Phase 3B outline permission (20/02142/OUT) condition 53 already requires a minimum of 5% of residential dwellings within Reserved Matters areas to meet the M4(2) standard of The Building Regulations 2010. This is a significant level of specialist accommodation provision, and it is unclear if the draft policy takes account of this. Notwithstanding our view that the policy requirement should be removed,
this 5% requirement secured by the conditions could be included in policy for completeness (as outlined in
Policy H/SS below). Furthermore, the SA identifies the provision of specialist accommodation as contributing
to a significant positive housing effect for Northstowe, but does not explain whether the existing requirements
for accessible and adaptable homes secured through the outline permissions have been taken into account
in determining the additional quantum of specialist accommodation required, meaning the policy may be
mandating a far larger number of units of specialist accommodation across Northstowe. This should also be
considered alongside the draft Development Management policies, including Policy H/SS, which already
provides for accessible and adaptable homes through the M4(2) requirements, although we recommend
minor amendments to the current draft wording. The relationship between these existing requirements and
the policy S/NST requirement of 850 units of specialist accommodation is therefore unclear, and this
requirement should be removed so as to avoid introducing unnecessary complexity and uncertainty that
could compromise the delivery of housing in Northstowe. Vistry also wishes to raise concerns regarding the
wording of point 35, relating to the ‘Lifespan Validation Checklist’. As currently worded, it could lead to
duplication and documents being unnecessarily resubmitted at Reserved Matters stage (which are already
controlled by associated planning conditions on the Outline planning permission) This in turn could lead to
unnecessary delays in terms of expedient delivery of the latter phases of Northstowe New Town. Vistry
therefore requests the following wording amendment: “In addition to the requirements on the Validation
Checklist, the following will be required at the submission of an outline or major planning application,
excluding for Reserved Matters applications where the Outline planning permission already
specifies approval of these documents (including through associated planning conditions) …”

Notwithstanding the above minor requested amendments to the wording of the draft policy, Vistry strongly
supports the allocation of the Site for residential-led development, in supporting ongoing important delivery
of new housing and associated facilities. The following sections set out our response to other draft policies
in the Local Plan Regulation 19 document, focusing on areas of support as well as any soundness concerns
(warranting review and amendment prior to submission for Examination)
b. Vision
Vistry supports the overall vision of the Local Plan. This aligns with NPPF 2024 paragraph 15 to provide a
positive vision and a framework for meeting housing needs whilst addressing other economic, social and
environmental priorities. As part of this, the allocation of Northstowe New Town is required in order to support
the Council to deliver its draft Vision as outlined on pages 29-30 of the draft Plan. This is further supported
by the Council through its inclusion of the site within the key diagram at figure 4 as a retained site allocation.
It is considered that the proposals at Northstowe Phase 3B play an important role in achieving the vision,
including through the delivery of a new sustainable community which includes the provision of a wide range
of different homes (including in size, tenure and type), mixed uses, extensive open space and infrastructure,
such as improved connectivity to public transport and a new primary school.
c. Policy WS/NC: Meeting the needs of growing communities
Point 11 refers to the implementation of services and facilities in “early phases” of development. We raise
concern with the current drafted terminology, as ‘early phases’ is ambiguous and lacks clarity and clear
definition for developers on when ‘early phases’ is. We therefore suggest in order to ensure sufficient
flexibility, the policy should be reworded to adopt a case-by-case basis for the delivery of services and
facilities and allows the timing of infrastructure to be aligned with the cash-flow and peak debt of individual
developments. Appropriate mechanisms already exist for securing the delivery of such items in the form of
S106 agreements and conditions.
As currently worded the policy is ambiguous, creating uncertainty that will place an additional and
unwarranted adverse financial burden on development, challenging viability. We therefore contend the policy
is revised as set out below to ensure the Local Plan is justified.
“ … Implementation
11. The timing delivery of infrastructure, services and facilities will be determined on a case-by-case
basis. Phasing will be established through planning obligations or conditions, and this may include requirements for the use of meanwhile or temporary uses to ensure local needs can be supported until permanent facilities are delivered.”

d. Policy GP/QD: Achieving high-quality development
Vistry objects to point 2(h) of Policy GP/QD, which requires design to integrate security measures such as
‘Hostile Vehicle Mitigation’ which we understand relates to bollards, road blockers, traffic-management
schemes, and reinforced street furniture. Within the policy there is no guidance on where this is required
and as currently worded appears to apply this approach as a blanket across all development. This also
seems to be a duplication of point (d) which requires developments to “create safe open spaces and active
streets that design out crime and consider counter-terrorism protective security measures that are
proportionate to the building, street or place, particularly places with higher crowd densities.”
A separate Hostile Vehicle Mitigation requirement is therefore considered overly onerous, problematic and
does not take into account the specific circumstances, setting and contexts of individual developments and
can have an adverse effect on residential environments and public realm through the introduction of hard
landscape features and street clutter. To be effective and justified the policy should be reworded as below
to state that such design measures will only be required where necessary.
“1. Where necessary, development proposals will be expected to demonstrate how they have addressed
the following design principles and requirements:…"

Further, point 2(i) requires permeability of spaces and routes through development that must be supported
by hard and soft landscaping. Vistry raises concern of potential conflict between points g. (requiring Hostile
Vehicle Mitigation Measures) which often include bollards and barriers and point h., which notes landscape
design should enhance permeability. It is suggested a review of the policy and competing points raised by
points g and h/ d should be undertaken to ensure development remains deliverable and the requirements
placed on developers are clear. This would ensure the policy is effective and justified.
e. Policy GP/QP: Establishing high-quality landscape and public realm
Whilst Vistry supports the inclusion of high-quality landscape and public realm (as permitted for Northstowe
New Town under Outline planning permission ref (20/02142/OUT), Vistry wishes to raise concerns regarding
Policy GP/QP as currently drafted and advocates that the policy is revised to read as follows:
“1. Development proposals are required to deliver high quality landscape and public realm by: …
b) Enhancing connectivity: …
… VI. Parking should not reduce the functionality of open spaces, and if on-street parking is proposed, inset parking will be encouraged. An expanded footway will be
required for pedestrian movements when not occupied;”

As currently drafted, point 1(b)(vi) requires on-street parking to be inset which will necessitate an expanded
footway for pedestrian movements. We raise concern that this is an overly onerous requirement that goes
beyond design guidance such as the Manual for Streets. Such requirements represent an unnecessary
requirement and onerous land take of hard engineering features, creating additional unwarranted
infrastructure costs for development. Development proposals should be designed and developed with
regards to their contextual setting and determined in such respect as well. As such, development should not
be blanket required at a Local Plan level to provide inset parking where it may be wholly inappropriate.
The amendment detailed above would ensure the GCLP is both justified and reflective on national guidance
and policy.
f. Policy H/HM: Housing mix Vistry suggests that point 4 is revised as follows:
“Development proposals will be supported where a mix of housing types (e.g. houses, flats and bungalows)
are provided proportionally across all affordable tenures, taking account of the local character
and built form and up-to date evidence of affordable housing need. Where affordable provision is met or
exceeded a flexible, market led, approach to market provision will be supported.”

Point 4 sets out a requirement for proposals to be supported by a mix that takes into account local character,
built form and up-to-date evidence of housing need. However, HO8(3) of the NPPF (2026) notes where
affordable housing requirements are met or exceeded by a development proposal, then a flexible approach should be taken to the application of development plan requirements for the bedroom mix of market provision
– taking into account prevailing market conditions.
The suggested amendment reflects HO8(3) and explicitly states that up-to-date evidence will only be
required to inform the affordable housing mix provision. Also, Tables 7 and 8 should be revised to remove
the housing mix preference for market housing to maintain suitable flexibility.

g. Policy H/SS: Residential space standards
We also raise concern at the length of the draft policy, which is considered to unnecessarily repeat the
requirements of the NDSS. This risks making the policy too convoluted and difficult to navigate. We suggest
point 2 is removed in full as there is no need to repeat the standards; which may be updated during the
lifetime of the GCLP, and would thus render the point irrelevant.
Point 4(e) sets out the required standards for balconies. We consider that proposals should be designed
and determined on their own merits based on an appreciation of a site’s context and surroundings and the
policy should not be overly prescriptive. As such, we suggest that the policy is reworded to simply state:
“Provide balconies that are designed as integral elements of the building's architecture.

It is considered that point 4(g) should also be revised so that it does not introduce amenity space standards
that are unduly onerous and go beyond those within the Building Regulations. As such the policy should
reduce the minimum quantum of private external amenity space for ground floor apartments to 5m2. The
policy should therefore read as follows:
“Provide a minimum of 105m² private external amenity space for ground floor apartments (irrespective of
the number of bedrooms) immediately outside their living accommodation, with a minimum depth of
2500mm; and…”
Point 4(h) should be revised as follows to not unduly place unachievable requirements for private external
amenity space for apartments based on the number of bedrooms. The requirement for an additional 1m2
per additional bedroom goes beyond the requirements of the Building Regulations and hence should be
deleted from the draft policy in full.
“Provide a private external amenity space of 5 square metres for upper floor apartments through the use of a private balcony with a minimum depth of 1,500 millimetres and a minimum usable width of 3,000 millimetres.
Point 6 requires all new dwellings to be of M4(2) standard. This is considered onerous and again goes
beyond the requirements of the Building Regulations. Point 6 should hence be revised as follows to provide
for an appropriate amount of M4(2) compliant dwellings. We suggest 5% of the overall development being
of M4(2) standard is appropriate.
“All 5% of new build residential units (including residential annexes) must be designed to be accessible and
adaptable in accordance with the Building Regulations M4(2) standard.”
The draft policy should be revised as outlined above to ensure it is both justified and consistent with national
policy and guidance. In turn this will ensure residential development remains viable and is not subject to
unduly onerous requirements.

h. Policy H/CB: Self and custom build homes
Vistry suggests that draft Policy H/CB is revised to recognise site-specific circumstances with regards to the
requirement for self-build homes at individual sites. As such, the current ‘blanket’ approach to 5% self-build
being required as part of ‘any development’ is not supported (acknowledging this could cause issues with
wider site delivery). This would be inconsistent with the Self-build and Custom Housebuilding Act, which
focuses on demand registers, not quotas.
The specific types of housing schemes that are not appropriate should also be included in the wording. The
current wording of the draft 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 is considered to place an unnecessary and disproportionate burden on developers, particularly in higher-density schemes where viability and
deliverability is already constrained by the requirements of the draft Plan.
It should also be clarified how the requirement would be applied on multi-phase developments, and how the
policy would retain flexibility for strategic sites that are delivered over a long period of time (i.e. Northstowe
New Town).
We therefore request the policy wording is amended as per the below:
“1. Subject to viability, deliverability, and individual site circumstances, development proposals
including 20 or more dwellings must provide at least 5% of the new homes as serviced plots for custom and
self-build houses and/or serviced custom-build flats. Specific types of housing schemes such as flatted
developments and [any other scheme types] are not appropriate for custom and self-build homes and
are therefore excluded from this requirement.”

Please see Section 3: Your Representation – the response fully sets out all suggest modifications and why they are necessary to make the GCLP sound.

a. Site Allocations – New Settlements - Policy S/NST: Northstowe New Town
Vistry supports the identification of Northstowe New Town in draft Policy S/NST for a community of approximately 10,180 homes, supported by a range of employment, retail, and community uses, served by the busway connecting Northstowe with Huntingdon, St Ives and Cambridge.
Northstowe Phase 3B represents an excellent opportunity for Greater Cambridge to meet its growth needs
through a highly sustainable location within proximity of public transport services and community facilities.
In particular, given the site’s proximity to Longstanton Park & Ride and Cambridgeshire Guided Busway, it
can deliver growth as part of a truly sustainable development with convenient, frequent and sustainable
connectivity to central Cambridge and other well-connected employment centres around Cambridgeshire.
This sustainable community will be embedded within a landscape setting and include a range of different
housing to meet local needs, supported by community infrastructure and sustainable transport connectivity.
The Outline planning permission (20/02142/OUT) for Phase 3B demonstrates that the site can sustainably
and successfully accommodate the scale of growth identified in the allocation.
Up to 1,000 new homes alongside a primary school and a mixed-use zone with retail, food and drink,
community, leisure, employment and residential uses, would provide a diverse range of housing and
accommodation to meet the needs of different groups within the community. Phase 3B would deliver a wide
a range of benefits that would support the creation of a sustainable, healthy and well-connected community
in Northstowe.
Whilst Vistry supports the continued allocation of the wider Northstowe New Town, we request amendments
to some of the requirements and wording of draft Policy S/NST, as follows:
• Point 2: “a site wide masterplan, prepared by the landowners / promoters in conjunction with the
Council and in consultation with the local community and other stakeholders…
… The masterplan should be agreed by the Council prior to the approval of any outline planning
applications (and may be subsequently updated by the landowners / promoters and agreed by the
Local Planning Authorities).”
• Point 5: “Among these will be a town centre supported by smaller local centres which could
includeing commercial and retail uses, employment uses and sports hub, sports pitches, mixed use
zones, a water park, open space and green corridors, incorporating active travel routes and
associated infrastructure works.
• Point 6: “The new town of Northstowe is allocated for mixed-use development, comprising:
a. Approximately 10,180 homes (delivering 6,201 homes within the plan period) in a wide range of
dwelling types and tenures including:
i. Affordable housing;
ii. 24 Permanent Gypsy and Traveller pitches located
outside but in close proximity to the site, meeting requirements of Policy H/GT;
iii. Community led homes and self/custom build homes; and
iv. Specialist accommodation (Use Class C2 and C3),
particularly for older people or those with disabilities;”

The proposed amendment to point 2 is to make clear that a site-wide masterplan is not expected to be
approved in advance of any phase gaining Reserved Matters consent, as this would be unnecessary with
elements of a masterplan being approved as part of Outline planning permissions, and if this was required
ahead of Reserved Matters then the delivery of different phases would be significantly delayed.
Point 5 revision is in order to clarify that not every local centre will have to include all of the facilities listed,
which would be undeliverable and unnecessary.
Point 6a requires Northstowe to provide 24 permanent Gypsy and Traveller pitches and approximately 850
units of specialist accommodation (Use Class C2 and C3). These requirements are not committed to or
consistent within the Phase 3B outline development description and are therefore introducing unnecessary
prescription and uncertainty, which could constrain the delivery of the approved development. The draft
policy wording risks undermining the effectiveness of the Northstowe New Town allocation and the draft
Local Plan, as the policy is not sufficiently flexible to support the implementation of the extant permissions
and would be inconsistent with national policy and guidance on positive plan-making and deliverability,
rendering the draft Local Plan not effectively prepared.
Similarly, these requirements should be removed from Policy S/DS (Development Strategy) as follows [Delete 2.95 and 2.102].

The requirement for 24 permanent Gypsy and Traveller pitches should be removed from the policy, given
that this requirement has not been demonstrated to be deliverable within the extant outline permissions. The
policy should therefore avoid establishing a prescriptive requirement for 24 pitches without evidence that
suitable and deliverable sites are available, whether within Northstowe or in close proximity to the
development. If retained in its current form, there is a risk that the requirement could conflict with the uses
and development already planned and consented at Northstowe, or result in delays to delivery, contrary to
national policy and guidance on positive plan-making and deliverability.
The requirement for 850 units of specialist accommodation should also be removed, as it introduces
unnecessary complexity and an additional layer of policy that undermines the clarity of the outline permissions. Phase 3B outline permission (20/02142/OUT) condition 53 already requires a minimum of 5% of residential dwellings within Reserved Matters areas to meet the M4(2) standard of The Building Regulations 2010. This is a significant level of specialist accommodation provision, and it is unclear if the draft policy takes account of this. Notwithstanding our view that the policy requirement should be removed,
this 5% requirement secured by the conditions could be included in policy for completeness (as outlined in
Policy H/SS below). Furthermore, the SA identifies the provision of specialist accommodation as contributing
to a significant positive housing effect for Northstowe, but does not explain whether the existing requirements
for accessible and adaptable homes secured through the outline permissions have been taken into account
in determining the additional quantum of specialist accommodation required, meaning the policy may be
mandating a far larger number of units of specialist accommodation across Northstowe. This should also be
considered alongside the draft Development Management policies, including Policy H/SS, which already
provides for accessible and adaptable homes through the M4(2) requirements, although we recommend
minor amendments to the current draft wording. The relationship between these existing requirements and
the policy S/NST requirement of 850 units of specialist accommodation is therefore unclear, and this
requirement should be removed so as to avoid introducing unnecessary complexity and uncertainty that
could compromise the delivery of housing in Northstowe. Vistry also wishes to raise concerns regarding the
wording of point 35, relating to the ‘Lifespan Validation Checklist’. As currently worded, it could lead to
duplication and documents being unnecessarily resubmitted at Reserved Matters stage (which are already
controlled by associated planning conditions on the Outline planning permission) This in turn could lead to
unnecessary delays in terms of expedient delivery of the latter phases of Northstowe New Town. Vistry
therefore requests the following wording amendment: “In addition to the requirements on the Validation
Checklist, the following will be required at the submission of an outline or major planning application,
excluding for Reserved Matters applications where the Outline planning permission already
specifies approval of these documents (including through associated planning conditions) …”

Notwithstanding the above minor requested amendments to the wording of the draft policy, Vistry strongly
supports the allocation of the Site for residential-led development, in supporting ongoing important delivery
of new housing and associated facilities. The following sections set out our response to other draft policies
in the Local Plan Regulation 19 document, focusing on areas of support as well as any soundness concerns
(warranting review and amendment prior to submission for Examination)
b. Vision
Vistry supports the overall vision of the Local Plan. This aligns with NPPF 2024 paragraph 15 to provide a
positive vision and a framework for meeting housing needs whilst addressing other economic, social and
environmental priorities. As part of this, the allocation of Northstowe New Town is required in order to support
the Council to deliver its draft Vision as outlined on pages 29-30 of the draft Plan. This is further supported
by the Council through its inclusion of the site within the key diagram at figure 4 as a retained site allocation.
It is considered that the proposals at Northstowe Phase 3B play an important role in achieving the vision,
including through the delivery of a new sustainable community which includes the provision of a wide range
of different homes (including in size, tenure and type), mixed uses, extensive open space and infrastructure,
such as improved connectivity to public transport and a new primary school.
c. Policy WS/NC: Meeting the needs of growing communities
Point 11 refers to the implementation of services and facilities in “early phases” of development. We raise
concern with the current drafted terminology, as ‘early phases’ is ambiguous and lacks clarity and clear
definition for developers on when ‘early phases’ is. We therefore suggest in order to ensure sufficient
flexibility, the policy should be reworded to adopt a case-by-case basis for the delivery of services and
facilities and allows the timing of infrastructure to be aligned with the cash-flow and peak debt of individual
developments. Appropriate mechanisms already exist for securing the delivery of such items in the form of
S106 agreements and conditions.
As currently worded the policy is ambiguous, creating uncertainty that will place an additional and
unwarranted adverse financial burden on development, challenging viability. We therefore contend the policy
is revised as set out below to ensure the Local Plan is justified.
“ … Implementation
11. The timing delivery of infrastructure, services and facilities will be determined on a case-by-case
basis. Phasing will be established through planning obligations or conditions, and this may include requirements for the use of meanwhile or temporary uses to ensure local needs can be supported until permanent facilities are delivered.”

d. Policy GP/QD: Achieving high-quality development
Vistry objects to point 2(h) of Policy GP/QD, which requires design to integrate security measures such as
‘Hostile Vehicle Mitigation’ which we understand relates to bollards, road blockers, traffic-management
schemes, and reinforced street furniture. Within the policy there is no guidance on where this is required
and as currently worded appears to apply this approach as a blanket across all development. This also
seems to be a duplication of point (d) which requires developments to “create safe open spaces and active
streets that design out crime and consider counter-terrorism protective security measures that are
proportionate to the building, street or place, particularly places with higher crowd densities.”
A separate Hostile Vehicle Mitigation requirement is therefore considered overly onerous, problematic and
does not take into account the specific circumstances, setting and contexts of individual developments and
can have an adverse effect on residential environments and public realm through the introduction of hard
landscape features and street clutter. To be effective and justified the policy should be reworded as below
to state that such design measures will only be required where necessary.
“1. Where necessary, development proposals will be expected to demonstrate how they have addressed
the following design principles and requirements:…"

Further, point 2(i) requires permeability of spaces and routes through development that must be supported
by hard and soft landscaping. Vistry raises concern of potential conflict between points g. (requiring Hostile
Vehicle Mitigation Measures) which often include bollards and barriers and point h., which notes landscape
design should enhance permeability. It is suggested a review of the policy and competing points raised by
points g and h/ d should be undertaken to ensure development remains deliverable and the requirements
placed on developers are clear. This would ensure the policy is effective and justified.
e. Policy GP/QP: Establishing high-quality landscape and public realm
Whilst Vistry supports the inclusion of high-quality landscape and public realm (as permitted for Northstowe
New Town under Outline planning permission ref (20/02142/OUT), Vistry wishes to raise concerns regarding
Policy GP/QP as currently drafted and advocates that the policy is revised to read as follows:
“1. Development proposals are required to deliver high quality landscape and public realm by: …
b) Enhancing connectivity: …
… VI. Parking should not reduce the functionality of open spaces, and if on-street parking is proposed, inset parking will be encouraged. An expanded footway will be
required for pedestrian movements when not occupied;”

As currently drafted, point 1(b)(vi) requires on-street parking to be inset which will necessitate an expanded
footway for pedestrian movements. We raise concern that this is an overly onerous requirement that goes
beyond design guidance such as the Manual for Streets. Such requirements represent an unnecessary
requirement and onerous land take of hard engineering features, creating additional unwarranted
infrastructure costs for development. Development proposals should be designed and developed with
regards to their contextual setting and determined in such respect as well. As such, development should not
be blanket required at a Local Plan level to provide inset parking where it may be wholly inappropriate.
The amendment detailed above would ensure the GCLP is both justified and reflective on national guidance
and policy.
f. Policy H/HM: Housing mix Vistry suggests that point 4 is revised as follows:
“Development proposals will be supported where a mix of housing types (e.g. houses, flats and bungalows)
are provided proportionally across all affordable tenures, taking account of the local character
and built form and up-to date evidence of affordable housing need. Where affordable provision is met or
exceeded a flexible, market led, approach to market provision will be supported.”

Point 4 sets out a requirement for proposals to be supported by a mix that takes into account local character,
built form and up-to-date evidence of housing need. However, HO8(3) of the NPPF (2026) notes where
affordable housing requirements are met or exceeded by a development proposal, then a flexible approach should be taken to the application of development plan requirements for the bedroom mix of market provision
– taking into account prevailing market conditions.
The suggested amendment reflects HO8(3) and explicitly states that up-to-date evidence will only be
required to inform the affordable housing mix provision. Also, Tables 7 and 8 should be revised to remove
the housing mix preference for market housing to maintain suitable flexibility.

g. Policy H/SS: Residential space standards
We also raise concern at the length of the draft policy, which is considered to unnecessarily repeat the
requirements of the NDSS. This risks making the policy too convoluted and difficult to navigate. We suggest
point 2 is removed in full as there is no need to repeat the standards; which may be updated during the
lifetime of the GCLP, and would thus render the point irrelevant.
Point 4(e) sets out the required standards for balconies. We consider that proposals should be designed
and determined on their own merits based on an appreciation of a site’s context and surroundings and the
policy should not be overly prescriptive. As such, we suggest that the policy is reworded to simply state:
“Provide balconies that are designed as integral elements of the building's architecture.

It is considered that point 4(g) should also be revised so that it does not introduce amenity space standards
that are unduly onerous and go beyond those within the Building Regulations. As such the policy should
reduce the minimum quantum of private external amenity space for ground floor apartments to 5m2. The
policy should therefore read as follows:
“Provide a minimum of 105m² private external amenity space for ground floor apartments (irrespective of
the number of bedrooms) immediately outside their living accommodation, with a minimum depth of
2500mm; and…”
Point 4(h) should be revised as follows to not unduly place unachievable requirements for private external
amenity space for apartments based on the number of bedrooms. The requirement for an additional 1m2
per additional bedroom goes beyond the requirements of the Building Regulations and hence should be
deleted from the draft policy in full.
“Provide a private external amenity space of 5 square metres for upper floor apartments through the use of a private balcony with a minimum depth of 1,500 millimetres and a minimum usable width of 3,000 millimetres.
Point 6 requires all new dwellings to be of M4(2) standard. This is considered onerous and again goes
beyond the requirements of the Building Regulations. Point 6 should hence be revised as follows to provide
for an appropriate amount of M4(2) compliant dwellings. We suggest 5% of the overall development being
of M4(2) standard is appropriate.
“All 5% of new build residential units (including residential annexes) must be designed to be accessible and
adaptable in accordance with the Building Regulations M4(2) standard.”
The draft policy should be revised as outlined above to ensure it is both justified and consistent with national
policy and guidance. In turn this will ensure residential development remains viable and is not subject to
unduly onerous requirements.

h. Policy H/CB: Self and custom build homes
Vistry suggests that draft Policy H/CB is revised to recognise site-specific circumstances with regards to the
requirement for self-build homes at individual sites. As such, the current ‘blanket’ approach to 5% self-build
being required as part of ‘any development’ is not supported (acknowledging this could cause issues with
wider site delivery). This would be inconsistent with the Self-build and Custom Housebuilding Act, which
focuses on demand registers, not quotas.
The specific types of housing schemes that are not appropriate should also be included in the wording. The
current wording of the draft 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 is considered to place an unnecessary and disproportionate burden on developers, particularly in higher-density schemes where viability and
deliverability is already constrained by the requirements of the draft Plan.
It should also be clarified how the requirement would be applied on multi-phase developments, and how the
policy would retain flexibility for strategic sites that are delivered over a long period of time (i.e. Northstowe
New Town).
We therefore request the policy wording is amended as per the below:
“1. Subject to viability, deliverability, and individual site circumstances, development proposals
including 20 or more dwellings must provide at least 5% of the new homes as serviced plots for custom and
self-build houses and/or serviced custom-build flats. Specific types of housing schemes such as flatted
developments and [any other scheme types] are not appropriate for custom and self-build homes and
are therefore excluded from this requirement.”

Please see Section 3: Your Representation – the response fully sets out all suggest modifications and why they are necessary to make the GCLP sound.

a. Site Allocations – New Settlements - Policy S/NST: Northstowe New Town
Vistry supports the identification of Northstowe New Town in draft Policy S/NST for a community of approximately 10,180 homes, supported by a range of employment, retail, and community uses, served by the busway connecting Northstowe with Huntingdon, St Ives and Cambridge.
Northstowe Phase 3B represents an excellent opportunity for Greater Cambridge to meet its growth needs
through a highly sustainable location within proximity of public transport services and community facilities.
In particular, given the site’s proximity to Longstanton Park & Ride and Cambridgeshire Guided Busway, it
can deliver growth as part of a truly sustainable development with convenient, frequent and sustainable
connectivity to central Cambridge and other well-connected employment centres around Cambridgeshire.
This sustainable community will be embedded within a landscape setting and include a range of different
housing to meet local needs, supported by community infrastructure and sustainable transport connectivity.
The Outline planning permission (20/02142/OUT) for Phase 3B demonstrates that the site can sustainably
and successfully accommodate the scale of growth identified in the allocation.
Up to 1,000 new homes alongside a primary school and a mixed-use zone with retail, food and drink,
community, leisure, employment and residential uses, would provide a diverse range of housing and
accommodation to meet the needs of different groups within the community. Phase 3B would deliver a wide
a range of benefits that would support the creation of a sustainable, healthy and well-connected community
in Northstowe.
Whilst Vistry supports the continued allocation of the wider Northstowe New Town, we request amendments
to some of the requirements and wording of draft Policy S/NST, as follows:
• Point 2: “a site wide masterplan, prepared by the landowners / promoters in conjunction with the
Council and in consultation with the local community and other stakeholders…
… The masterplan should be agreed by the Council prior to the approval of any outline planning
applications (and may be subsequently updated by the landowners / promoters and agreed by the
Local Planning Authorities).”
• Point 5: “Among these will be a town centre supported by smaller local centres which could
includeing commercial and retail uses, employment uses and sports hub, sports pitches, mixed use
zones, a water park, open space and green corridors, incorporating active travel routes and
associated infrastructure works.
• Point 6: “The new town of Northstowe is allocated for mixed-use development, comprising:
a. Approximately 10,180 homes (delivering 6,201 homes within the plan period) in a wide range of
dwelling types and tenures including:
i. Affordable housing;
ii. 24 Permanent Gypsy and Traveller pitches located
outside but in close proximity to the site, meeting requirements of Policy H/GT;
iii. Community led homes and self/custom build homes; and
iv. Specialist accommodation (Use Class C2 and C3),
particularly for older people or those with disabilities;”

The proposed amendment to point 2 is to make clear that a site-wide masterplan is not expected to be
approved in advance of any phase gaining Reserved Matters consent, as this would be unnecessary with
elements of a masterplan being approved as part of Outline planning permissions, and if this was required
ahead of Reserved Matters then the delivery of different phases would be significantly delayed.
Point 5 revision is in order to clarify that not every local centre will have to include all of the facilities listed,
which would be undeliverable and unnecessary.
Point 6a requires Northstowe to provide 24 permanent Gypsy and Traveller pitches and approximately 850
units of specialist accommodation (Use Class C2 and C3). These requirements are not committed to or
consistent within the Phase 3B outline development description and are therefore introducing unnecessary
prescription and uncertainty, which could constrain the delivery of the approved development. The draft
policy wording risks undermining the effectiveness of the Northstowe New Town allocation and the draft
Local Plan, as the policy is not sufficiently flexible to support the implementation of the extant permissions
and would be inconsistent with national policy and guidance on positive plan-making and deliverability,
rendering the draft Local Plan not effectively prepared.
Similarly, these requirements should be removed from Policy S/DS (Development Strategy) as follows [Delete 2.95 and 2.102].

The requirement for 24 permanent Gypsy and Traveller pitches should be removed from the policy, given
that this requirement has not been demonstrated to be deliverable within the extant outline permissions. The
policy should therefore avoid establishing a prescriptive requirement for 24 pitches without evidence that
suitable and deliverable sites are available, whether within Northstowe or in close proximity to the
development. If retained in its current form, there is a risk that the requirement could conflict with the uses
and development already planned and consented at Northstowe, or result in delays to delivery, contrary to
national policy and guidance on positive plan-making and deliverability.
The requirement for 850 units of specialist accommodation should also be removed, as it introduces
unnecessary complexity and an additional layer of policy that undermines the clarity of the outline permissions. Phase 3B outline permission (20/02142/OUT) condition 53 already requires a minimum of 5% of residential dwellings within Reserved Matters areas to meet the M4(2) standard of The Building Regulations 2010. This is a significant level of specialist accommodation provision, and it is unclear if the draft policy takes account of this. Notwithstanding our view that the policy requirement should be removed,
this 5% requirement secured by the conditions could be included in policy for completeness (as outlined in
Policy H/SS below). Furthermore, the SA identifies the provision of specialist accommodation as contributing
to a significant positive housing effect for Northstowe, but does not explain whether the existing requirements
for accessible and adaptable homes secured through the outline permissions have been taken into account
in determining the additional quantum of specialist accommodation required, meaning the policy may be
mandating a far larger number of units of specialist accommodation across Northstowe. This should also be
considered alongside the draft Development Management policies, including Policy H/SS, which already
provides for accessible and adaptable homes through the M4(2) requirements, although we recommend
minor amendments to the current draft wording. The relationship between these existing requirements and
the policy S/NST requirement of 850 units of specialist accommodation is therefore unclear, and this
requirement should be removed so as to avoid introducing unnecessary complexity and uncertainty that
could compromise the delivery of housing in Northstowe. Vistry also wishes to raise concerns regarding the
wording of point 35, relating to the ‘Lifespan Validation Checklist’. As currently worded, it could lead to
duplication and documents being unnecessarily resubmitted at Reserved Matters stage (which are already
controlled by associated planning conditions on the Outline planning permission) This in turn could lead to
unnecessary delays in terms of expedient delivery of the latter phases of Northstowe New Town. Vistry
therefore requests the following wording amendment: “In addition to the requirements on the Validation
Checklist, the following will be required at the submission of an outline or major planning application,
excluding for Reserved Matters applications where the Outline planning permission already
specifies approval of these documents (including through associated planning conditions) …”

Notwithstanding the above minor requested amendments to the wording of the draft policy, Vistry strongly
supports the allocation of the Site for residential-led development, in supporting ongoing important delivery
of new housing and associated facilities. The following sections set out our response to other draft policies
in the Local Plan Regulation 19 document, focusing on areas of support as well as any soundness concerns
(warranting review and amendment prior to submission for Examination)
b. Vision
Vistry supports the overall vision of the Local Plan. This aligns with NPPF 2024 paragraph 15 to provide a
positive vision and a framework for meeting housing needs whilst addressing other economic, social and
environmental priorities. As part of this, the allocation of Northstowe New Town is required in order to support
the Council to deliver its draft Vision as outlined on pages 29-30 of the draft Plan. This is further supported
by the Council through its inclusion of the site within the key diagram at figure 4 as a retained site allocation.
It is considered that the proposals at Northstowe Phase 3B play an important role in achieving the vision,
including through the delivery of a new sustainable community which includes the provision of a wide range
of different homes (including in size, tenure and type), mixed uses, extensive open space and infrastructure,
such as improved connectivity to public transport and a new primary school.
c. Policy WS/NC: Meeting the needs of growing communities
Point 11 refers to the implementation of services and facilities in “early phases” of development. We raise
concern with the current drafted terminology, as ‘early phases’ is ambiguous and lacks clarity and clear
definition for developers on when ‘early phases’ is. We therefore suggest in order to ensure sufficient
flexibility, the policy should be reworded to adopt a case-by-case basis for the delivery of services and
facilities and allows the timing of infrastructure to be aligned with the cash-flow and peak debt of individual
developments. Appropriate mechanisms already exist for securing the delivery of such items in the form of
S106 agreements and conditions.
As currently worded the policy is ambiguous, creating uncertainty that will place an additional and
unwarranted adverse financial burden on development, challenging viability. We therefore contend the policy
is revised as set out below to ensure the Local Plan is justified.
“ … Implementation
11. The timing delivery of infrastructure, services and facilities will be determined on a case-by-case
basis. Phasing will be established through planning obligations or conditions, and this may include requirements for the use of meanwhile or temporary uses to ensure local needs can be supported until permanent facilities are delivered.”

d. Policy GP/QD: Achieving high-quality development
Vistry objects to point 2(h) of Policy GP/QD, which requires design to integrate security measures such as
‘Hostile Vehicle Mitigation’ which we understand relates to bollards, road blockers, traffic-management
schemes, and reinforced street furniture. Within the policy there is no guidance on where this is required
and as currently worded appears to apply this approach as a blanket across all development. This also
seems to be a duplication of point (d) which requires developments to “create safe open spaces and active
streets that design out crime and consider counter-terrorism protective security measures that are
proportionate to the building, street or place, particularly places with higher crowd densities.”
A separate Hostile Vehicle Mitigation requirement is therefore considered overly onerous, problematic and
does not take into account the specific circumstances, setting and contexts of individual developments and
can have an adverse effect on residential environments and public realm through the introduction of hard
landscape features and street clutter. To be effective and justified the policy should be reworded as below
to state that such design measures will only be required where necessary.
“1. Where necessary, development proposals will be expected to demonstrate how they have addressed
the following design principles and requirements:…"

Further, point 2(i) requires permeability of spaces and routes through development that must be supported
by hard and soft landscaping. Vistry raises concern of potential conflict between points g. (requiring Hostile
Vehicle Mitigation Measures) which often include bollards and barriers and point h., which notes landscape
design should enhance permeability. It is suggested a review of the policy and competing points raised by
points g and h/ d should be undertaken to ensure development remains deliverable and the requirements
placed on developers are clear. This would ensure the policy is effective and justified.
e. Policy GP/QP: Establishing high-quality landscape and public realm
Whilst Vistry supports the inclusion of high-quality landscape and public realm (as permitted for Northstowe
New Town under Outline planning permission ref (20/02142/OUT), Vistry wishes to raise concerns regarding
Policy GP/QP as currently drafted and advocates that the policy is revised to read as follows:
“1. Development proposals are required to deliver high quality landscape and public realm by: …
b) Enhancing connectivity: …
… VI. Parking should not reduce the functionality of open spaces, and if on-street parking is proposed, inset parking will be encouraged. An expanded footway will be
required for pedestrian movements when not occupied;”

As currently drafted, point 1(b)(vi) requires on-street parking to be inset which will necessitate an expanded
footway for pedestrian movements. We raise concern that this is an overly onerous requirement that goes
beyond design guidance such as the Manual for Streets. Such requirements represent an unnecessary
requirement and onerous land take of hard engineering features, creating additional unwarranted
infrastructure costs for development. Development proposals should be designed and developed with
regards to their contextual setting and determined in such respect as well. As such, development should not
be blanket required at a Local Plan level to provide inset parking where it may be wholly inappropriate.
The amendment detailed above would ensure the GCLP is both justified and reflective on national guidance
and policy.
f. Policy H/HM: Housing mix Vistry suggests that point 4 is revised as follows:
“Development proposals will be supported where a mix of housing types (e.g. houses, flats and bungalows)
are provided proportionally across all affordable tenures, taking account of the local character
and built form and up-to date evidence of affordable housing need. Where affordable provision is met or
exceeded a flexible, market led, approach to market provision will be supported.”

Point 4 sets out a requirement for proposals to be supported by a mix that takes into account local character,
built form and up-to-date evidence of housing need. However, HO8(3) of the NPPF (2026) notes where
affordable housing requirements are met or exceeded by a development proposal, then a flexible approach should be taken to the application of development plan requirements for the bedroom mix of market provision
– taking into account prevailing market conditions.
The suggested amendment reflects HO8(3) and explicitly states that up-to-date evidence will only be
required to inform the affordable housing mix provision. Also, Tables 7 and 8 should be revised to remove
the housing mix preference for market housing to maintain suitable flexibility.

g. Policy H/SS: Residential space standards
We also raise concern at the length of the draft policy, which is considered to unnecessarily repeat the
requirements of the NDSS. This risks making the policy too convoluted and difficult to navigate. We suggest
point 2 is removed in full as there is no need to repeat the standards; which may be updated during the
lifetime of the GCLP, and would thus render the point irrelevant.
Point 4(e) sets out the required standards for balconies. We consider that proposals should be designed
and determined on their own merits based on an appreciation of a site’s context and surroundings and the
policy should not be overly prescriptive. As such, we suggest that the policy is reworded to simply state:
“Provide balconies that are designed as integral elements of the building's architecture.

It is considered that point 4(g) should also be revised so that it does not introduce amenity space standards
that are unduly onerous and go beyond those within the Building Regulations. As such the policy should
reduce the minimum quantum of private external amenity space for ground floor apartments to 5m2. The
policy should therefore read as follows:
“Provide a minimum of 105m² private external amenity space for ground floor apartments (irrespective of
the number of bedrooms) immediately outside their living accommodation, with a minimum depth of
2500mm; and…”
Point 4(h) should be revised as follows to not unduly place unachievable requirements for private external
amenity space for apartments based on the number of bedrooms. The requirement for an additional 1m2
per additional bedroom goes beyond the requirements of the Building Regulations and hence should be
deleted from the draft policy in full.
“Provide a private external amenity space of 5 square metres for upper floor apartments through the use of a private balcony with a minimum depth of 1,500 millimetres and a minimum usable width of 3,000 millimetres.
Point 6 requires all new dwellings to be of M4(2) standard. This is considered onerous and again goes
beyond the requirements of the Building Regulations. Point 6 should hence be revised as follows to provide
for an appropriate amount of M4(2) compliant dwellings. We suggest 5% of the overall development being
of M4(2) standard is appropriate.
“All 5% of new build residential units (including residential annexes) must be designed to be accessible and
adaptable in accordance with the Building Regulations M4(2) standard.”
The draft policy should be revised as outlined above to ensure it is both justified and consistent with national
policy and guidance. In turn this will ensure residential development remains viable and is not subject to
unduly onerous requirements.

h. Policy H/CB: Self and custom build homes
Vistry suggests that draft Policy H/CB is revised to recognise site-specific circumstances with regards to the
requirement for self-build homes at individual sites. As such, the current ‘blanket’ approach to 5% self-build
being required as part of ‘any development’ is not supported (acknowledging this could cause issues with
wider site delivery). This would be inconsistent with the Self-build and Custom Housebuilding Act, which
focuses on demand registers, not quotas.
The specific types of housing schemes that are not appropriate should also be included in the wording. The
current wording of the draft 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 is considered to place an unnecessary and disproportionate burden on developers, particularly in higher-density schemes where viability and
deliverability is already constrained by the requirements of the draft Plan.
It should also be clarified how the requirement would be applied on multi-phase developments, and how the
policy would retain flexibility for strategic sites that are delivered over a long period of time (i.e. Northstowe
New Town).
We therefore request the policy wording is amended as per the below:
“1. Subject to viability, deliverability, and individual site circumstances, development proposals
including 20 or more dwellings must provide at least 5% of the new homes as serviced plots for custom and
self-build houses and/or serviced custom-build flats. Specific types of housing schemes such as flatted
developments and [any other scheme types] are not appropriate for custom and self-build homes and
are therefore excluded from this requirement.”

Please see Section 3: Your Representation – the response fully sets out all suggest modifications and why they are necessary to make the GCLP sound.

a. Site Allocations – New Settlements - Policy S/NST: Northstowe New Town
Vistry supports the identification of Northstowe New Town in draft Policy S/NST for a community of approximately 10,180 homes, supported by a range of employment, retail, and community uses, served by the busway connecting Northstowe with Huntingdon, St Ives and Cambridge.
Northstowe Phase 3B represents an excellent opportunity for Greater Cambridge to meet its growth needs
through a highly sustainable location within proximity of public transport services and community facilities.
In particular, given the site’s proximity to Longstanton Park & Ride and Cambridgeshire Guided Busway, it
can deliver growth as part of a truly sustainable development with convenient, frequent and sustainable
connectivity to central Cambridge and other well-connected employment centres around Cambridgeshire.
This sustainable community will be embedded within a landscape setting and include a range of different
housing to meet local needs, supported by community infrastructure and sustainable transport connectivity.
The Outline planning permission (20/02142/OUT) for Phase 3B demonstrates that the site can sustainably
and successfully accommodate the scale of growth identified in the allocation.
Up to 1,000 new homes alongside a primary school and a mixed-use zone with retail, food and drink,
community, leisure, employment and residential uses, would provide a diverse range of housing and
accommodation to meet the needs of different groups within the community. Phase 3B would deliver a wide
a range of benefits that would support the creation of a sustainable, healthy and well-connected community
in Northstowe.
Whilst Vistry supports the continued allocation of the wider Northstowe New Town, we request amendments
to some of the requirements and wording of draft Policy S/NST, as follows:
• Point 2: “a site wide masterplan, prepared by the landowners / promoters in conjunction with the
Council and in consultation with the local community and other stakeholders…
… The masterplan should be agreed by the Council prior to the approval of any outline planning
applications (and may be subsequently updated by the landowners / promoters and agreed by the
Local Planning Authorities).”
• Point 5: “Among these will be a town centre supported by smaller local centres which could
includeing commercial and retail uses, employment uses and sports hub, sports pitches, mixed use
zones, a water park, open space and green corridors, incorporating active travel routes and
associated infrastructure works.
• Point 6: “The new town of Northstowe is allocated for mixed-use development, comprising:
a. Approximately 10,180 homes (delivering 6,201 homes within the plan period) in a wide range of
dwelling types and tenures including:
i. Affordable housing;
ii. 24 Permanent Gypsy and Traveller pitches located
outside but in close proximity to the site, meeting requirements of Policy H/GT;
iii. Community led homes and self/custom build homes; and
iv. Specialist accommodation (Use Class C2 and C3),
particularly for older people or those with disabilities;”

The proposed amendment to point 2 is to make clear that a site-wide masterplan is not expected to be
approved in advance of any phase gaining Reserved Matters consent, as this would be unnecessary with
elements of a masterplan being approved as part of Outline planning permissions, and if this was required
ahead of Reserved Matters then the delivery of different phases would be significantly delayed.
Point 5 revision is in order to clarify that not every local centre will have to include all of the facilities listed,
which would be undeliverable and unnecessary.
Point 6a requires Northstowe to provide 24 permanent Gypsy and Traveller pitches and approximately 850
units of specialist accommodation (Use Class C2 and C3). These requirements are not committed to or
consistent within the Phase 3B outline development description and are therefore introducing unnecessary
prescription and uncertainty, which could constrain the delivery of the approved development. The draft
policy wording risks undermining the effectiveness of the Northstowe New Town allocation and the draft
Local Plan, as the policy is not sufficiently flexible to support the implementation of the extant permissions
and would be inconsistent with national policy and guidance on positive plan-making and deliverability,
rendering the draft Local Plan not effectively prepared.
Similarly, these requirements should be removed from Policy S/DS (Development Strategy) as follows [Delete 2.95 and 2.102].

The requirement for 24 permanent Gypsy and Traveller pitches should be removed from the policy, given
that this requirement has not been demonstrated to be deliverable within the extant outline permissions. The
policy should therefore avoid establishing a prescriptive requirement for 24 pitches without evidence that
suitable and deliverable sites are available, whether within Northstowe or in close proximity to the
development. If retained in its current form, there is a risk that the requirement could conflict with the uses
and development already planned and consented at Northstowe, or result in delays to delivery, contrary to
national policy and guidance on positive plan-making and deliverability.
The requirement for 850 units of specialist accommodation should also be removed, as it introduces
unnecessary complexity and an additional layer of policy that undermines the clarity of the outline permissions. Phase 3B outline permission (20/02142/OUT) condition 53 already requires a minimum of 5% of residential dwellings within Reserved Matters areas to meet the M4(2) standard of The Building Regulations 2010. This is a significant level of specialist accommodation provision, and it is unclear if the draft policy takes account of this. Notwithstanding our view that the policy requirement should be removed,
this 5% requirement secured by the conditions could be included in policy for completeness (as outlined in
Policy H/SS below). Furthermore, the SA identifies the provision of specialist accommodation as contributing
to a significant positive housing effect for Northstowe, but does not explain whether the existing requirements
for accessible and adaptable homes secured through the outline permissions have been taken into account
in determining the additional quantum of specialist accommodation required, meaning the policy may be
mandating a far larger number of units of specialist accommodation across Northstowe. This should also be
considered alongside the draft Development Management policies, including Policy H/SS, which already
provides for accessible and adaptable homes through the M4(2) requirements, although we recommend
minor amendments to the current draft wording. The relationship between these existing requirements and
the policy S/NST requirement of 850 units of specialist accommodation is therefore unclear, and this
requirement should be removed so as to avoid introducing unnecessary complexity and uncertainty that
could compromise the delivery of housing in Northstowe. Vistry also wishes to raise concerns regarding the
wording of point 35, relating to the ‘Lifespan Validation Checklist’. As currently worded, it could lead to
duplication and documents being unnecessarily resubmitted at Reserved Matters stage (which are already
controlled by associated planning conditions on the Outline planning permission) This in turn could lead to
unnecessary delays in terms of expedient delivery of the latter phases of Northstowe New Town. Vistry
therefore requests the following wording amendment: “In addition to the requirements on the Validation
Checklist, the following will be required at the submission of an outline or major planning application,
excluding for Reserved Matters applications where the Outline planning permission already
specifies approval of these documents (including through associated planning conditions) …”

Notwithstanding the above minor requested amendments to the wording of the draft policy, Vistry strongly
supports the allocation of the Site for residential-led development, in supporting ongoing important delivery
of new housing and associated facilities. The following sections set out our response to other draft policies
in the Local Plan Regulation 19 document, focusing on areas of support as well as any soundness concerns
(warranting review and amendment prior to submission for Examination)
b. Vision
Vistry supports the overall vision of the Local Plan. This aligns with NPPF 2024 paragraph 15 to provide a
positive vision and a framework for meeting housing needs whilst addressing other economic, social and
environmental priorities. As part of this, the allocation of Northstowe New Town is required in order to support
the Council to deliver its draft Vision as outlined on pages 29-30 of the draft Plan. This is further supported
by the Council through its inclusion of the site within the key diagram at figure 4 as a retained site allocation.
It is considered that the proposals at Northstowe Phase 3B play an important role in achieving the vision,
including through the delivery of a new sustainable community which includes the provision of a wide range
of different homes (including in size, tenure and type), mixed uses, extensive open space and infrastructure,
such as improved connectivity to public transport and a new primary school.
c. Policy WS/NC: Meeting the needs of growing communities
Point 11 refers to the implementation of services and facilities in “early phases” of development. We raise
concern with the current drafted terminology, as ‘early phases’ is ambiguous and lacks clarity and clear
definition for developers on when ‘early phases’ is. We therefore suggest in order to ensure sufficient
flexibility, the policy should be reworded to adopt a case-by-case basis for the delivery of services and
facilities and allows the timing of infrastructure to be aligned with the cash-flow and peak debt of individual
developments. Appropriate mechanisms already exist for securing the delivery of such items in the form of
S106 agreements and conditions.
As currently worded the policy is ambiguous, creating uncertainty that will place an additional and
unwarranted adverse financial burden on development, challenging viability. We therefore contend the policy
is revised as set out below to ensure the Local Plan is justified.
“ … Implementation
11. The timing delivery of infrastructure, services and facilities will be determined on a case-by-case
basis. Phasing will be established through planning obligations or conditions, and this may include requirements for the use of meanwhile or temporary uses to ensure local needs can be supported until permanent facilities are delivered.”

d. Policy GP/QD: Achieving high-quality development
Vistry objects to point 2(h) of Policy GP/QD, which requires design to integrate security measures such as
‘Hostile Vehicle Mitigation’ which we understand relates to bollards, road blockers, traffic-management
schemes, and reinforced street furniture. Within the policy there is no guidance on where this is required
and as currently worded appears to apply this approach as a blanket across all development. This also
seems to be a duplication of point (d) which requires developments to “create safe open spaces and active
streets that design out crime and consider counter-terrorism protective security measures that are
proportionate to the building, street or place, particularly places with higher crowd densities.”
A separate Hostile Vehicle Mitigation requirement is therefore considered overly onerous, problematic and
does not take into account the specific circumstances, setting and contexts of individual developments and
can have an adverse effect on residential environments and public realm through the introduction of hard
landscape features and street clutter. To be effective and justified the policy should be reworded as below
to state that such design measures will only be required where necessary.
“1. Where necessary, development proposals will be expected to demonstrate how they have addressed
the following design principles and requirements:…"

Further, point 2(i) requires permeability of spaces and routes through development that must be supported
by hard and soft landscaping. Vistry raises concern of potential conflict between points g. (requiring Hostile
Vehicle Mitigation Measures) which often include bollards and barriers and point h., which notes landscape
design should enhance permeability. It is suggested a review of the policy and competing points raised by
points g and h/ d should be undertaken to ensure development remains deliverable and the requirements
placed on developers are clear. This would ensure the policy is effective and justified.
e. Policy GP/QP: Establishing high-quality landscape and public realm
Whilst Vistry supports the inclusion of high-quality landscape and public realm (as permitted for Northstowe
New Town under Outline planning permission ref (20/02142/OUT), Vistry wishes to raise concerns regarding
Policy GP/QP as currently drafted and advocates that the policy is revised to read as follows:
“1. Development proposals are required to deliver high quality landscape and public realm by: …
b) Enhancing connectivity: …
… VI. Parking should not reduce the functionality of open spaces, and if on-street parking is proposed, inset parking will be encouraged. An expanded footway will be
required for pedestrian movements when not occupied;”

As currently drafted, point 1(b)(vi) requires on-street parking to be inset which will necessitate an expanded
footway for pedestrian movements. We raise concern that this is an overly onerous requirement that goes
beyond design guidance such as the Manual for Streets. Such requirements represent an unnecessary
requirement and onerous land take of hard engineering features, creating additional unwarranted
infrastructure costs for development. Development proposals should be designed and developed with
regards to their contextual setting and determined in such respect as well. As such, development should not
be blanket required at a Local Plan level to provide inset parking where it may be wholly inappropriate.
The amendment detailed above would ensure the GCLP is both justified and reflective on national guidance
and policy.
f. Policy H/HM: Housing mix Vistry suggests that point 4 is revised as follows:
“Development proposals will be supported where a mix of housing types (e.g. houses, flats and bungalows)
are provided proportionally across all affordable tenures, taking account of the local character
and built form and up-to date evidence of affordable housing need. Where affordable provision is met or
exceeded a flexible, market led, approach to market provision will be supported.”

Point 4 sets out a requirement for proposals to be supported by a mix that takes into account local character,
built form and up-to-date evidence of housing need. However, HO8(3) of the NPPF (2026) notes where
affordable housing requirements are met or exceeded by a development proposal, then a flexible approach should be taken to the application of development plan requirements for the bedroom mix of market provision
– taking into account prevailing market conditions.
The suggested amendment reflects HO8(3) and explicitly states that up-to-date evidence will only be
required to inform the affordable housing mix provision. Also, Tables 7 and 8 should be revised to remove
the housing mix preference for market housing to maintain suitable flexibility.

g. Policy H/SS: Residential space standards
We also raise concern at the length of the draft policy, which is considered to unnecessarily repeat the
requirements of the NDSS. This risks making the policy too convoluted and difficult to navigate. We suggest
point 2 is removed in full as there is no need to repeat the standards; which may be updated during the
lifetime of the GCLP, and would thus render the point irrelevant.
Point 4(e) sets out the required standards for balconies. We consider that proposals should be designed
and determined on their own merits based on an appreciation of a site’s context and surroundings and the
policy should not be overly prescriptive. As such, we suggest that the policy is reworded to simply state:
“Provide balconies that are designed as integral elements of the building's architecture.

It is considered that point 4(g) should also be revised so that it does not introduce amenity space standards
that are unduly onerous and go beyond those within the Building Regulations. As such the policy should
reduce the minimum quantum of private external amenity space for ground floor apartments to 5m2. The
policy should therefore read as follows:
“Provide a minimum of 105m² private external amenity space for ground floor apartments (irrespective of
the number of bedrooms) immediately outside their living accommodation, with a minimum depth of
2500mm; and…”
Point 4(h) should be revised as follows to not unduly place unachievable requirements for private external
amenity space for apartments based on the number of bedrooms. The requirement for an additional 1m2
per additional bedroom goes beyond the requirements of the Building Regulations and hence should be
deleted from the draft policy in full.
“Provide a private external amenity space of 5 square metres for upper floor apartments through the use of a private balcony with a minimum depth of 1,500 millimetres and a minimum usable width of 3,000 millimetres.
Point 6 requires all new dwellings to be of M4(2) standard. This is considered onerous and again goes
beyond the requirements of the Building Regulations. Point 6 should hence be revised as follows to provide
for an appropriate amount of M4(2) compliant dwellings. We suggest 5% of the overall development being
of M4(2) standard is appropriate.
“All 5% of new build residential units (including residential annexes) must be designed to be accessible and
adaptable in accordance with the Building Regulations M4(2) standard.”
The draft policy should be revised as outlined above to ensure it is both justified and consistent with national
policy and guidance. In turn this will ensure residential development remains viable and is not subject to
unduly onerous requirements.

h. Policy H/CB: Self and custom build homes
Vistry suggests that draft Policy H/CB is revised to recognise site-specific circumstances with regards to the
requirement for self-build homes at individual sites. As such, the current ‘blanket’ approach to 5% self-build
being required as part of ‘any development’ is not supported (acknowledging this could cause issues with
wider site delivery). This would be inconsistent with the Self-build and Custom Housebuilding Act, which
focuses on demand registers, not quotas.
The specific types of housing schemes that are not appropriate should also be included in the wording. The
current wording of the draft 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 is considered to place an unnecessary and disproportionate burden on developers, particularly in higher-density schemes where viability and
deliverability is already constrained by the requirements of the draft Plan.
It should also be clarified how the requirement would be applied on multi-phase developments, and how the
policy would retain flexibility for strategic sites that are delivered over a long period of time (i.e. Northstowe
New Town).
We therefore request the policy wording is amended as per the below:
“1. Subject to viability, deliverability, and individual site circumstances, development proposals
including 20 or more dwellings must provide at least 5% of the new homes as serviced plots for custom and
self-build houses and/or serviced custom-build flats. Specific types of housing schemes such as flatted
developments and [any other scheme types] are not appropriate for custom and self-build homes and
are therefore excluded from this requirement.”