Greater Cambridge Local Plan: Proposed Submission

• Clarify that the required masterplan-led approach can be delivered at the planning application
stage through a concept plan, rather than requiring a separate masterplan approval process.
• Confirm that any masterplan submission is proportionate to the scale of development (circa 125
dwellings) and does not create an onerous pre-application requirement.
• Amend Criterion 1(g) to replace the broad term “active travel connections” with “pedestrian and
cycle connections”.
• Retain the policy's overall objective of promoting sustainable travel while providing greater clarity
and certainty for implementation.

Vistry supports the broad intent of Policy S/RRA/CR, which allocates the Site for residential
development, including a stated capacity for approximately 125 dwellings.
However, Vistry objects to the ambiguity of some of the draft wording, as follows:
The draft policy wording at sub-section 1 states that development proposals “must demonstrate” how
they will meet the requirements listed from (a) to (g). Hence, it is important that all criteria are explicit and
clear.
Criteria 1(a) requires that “through a masterplan led approach, the site must integrate with Melbourne’s
existing and proposed built form, including Melbourn Science Park”. Whilst we appreciate and agree with
the intent of integrating the proposed development with the existing built form of the village, the
requirement for a ‘masterplan led’ approach is considered to be ambiguous given the scale of
development proposed for the Site. The draft policy does not detail if involvement and approval from the
Council is required prior to the submission of an application. Vistry would typically undertake pre
application engagement with the Council, other statutory consultees (where relevant) and the local
community in advance of submitting a formal application for planning permission. However, we would
consider it onerous for the Applicant to be required to prepare and submit for approval a masterplan for
the Site, in advance of any application. This would be considered excessive for a site of circa 125
dwellings.
Vistry requests that point 1(a) of Policy S/RRA/CR is revised and reworded as follows:
“a) Through a masterplan led approach at application stage, including a concept plan to
include the principles of access, land use and landscape strategy, the site must integrate
with Melbourn’s existing and proposed built form, including Melbourn Science Park;”
Criteria 1(g) requires the provision of “active travel connections to the Melbourn Greenway, Melbourn
Science Park and the centre of the village.” Again, whilst supporting the intent of this limb of the policy, which is to promote sustainable and active travel use, we consider that the wording should be clearer.
‘Active travel’ could potentially include a wide range of travel modes, including horses or a variety of
wheeled forms. We are of the view that the existing local infrastructure adjacent to the Site provides
opportunities for promoting walking, running and cycling.
Vistry requests that point 1(g) of Policy S/RRA/CR is revised and reworded as follows:
“Provide active travel pedestrian and cycle connections to the Melbourn Greenway, Melbourn
Science Park and the centre of the village.”
Notwithstanding the above minor requested amendments to the wording of the draft policy, Vistry
supports the allocation of the Site for residential development to support the delivery of new housing
within the settlement of Melbourn.

The policy should be revised as per the above representation to ensure it is flexible and does not go beyond the requirements of Building Regulations

Vistry objects to Policy CC/SD.
The introduction of ‘where appropriate’ should be included into point 2 when introducing the criteria that
Sustainability Assessments should address. The policy needs to be sufficiently flexible to reflect the
range of development proposals anticipated to come forward in the Authority Area across the plan
period. It should be recognised that Sustainability Statements will be bespoke to the scheme they
support and as such it may not be necessary or appropriate to address all elements from (a)-(i). The inclusion of point 2(b) is considered onerous and goes beyond national policy requirements. Whilst
Vistry support the national objective to achieve net zero by 2050 it is not a statutory requirement within
either the Building Regulations or the NPPF (2026) for development proposals and local plans to achieve
net zero with regards to carbon emissions. This hence goes beyond national policy and standards and
may threaten the viability of development.
Vistry query the inclusion of point 2(f) (nature-based solutions) and note that if this is to be included then
the GCLP should provide further detail on what consists of a nature-based solution. At present the policy
is too loosely worded and does not define what is expected.
We also raise concern that the Viability Appraisal that accompanies the Regulation 19 Local Plan does
not incorporate sufficient consideration of the increased build costs of the extensive sustainability
requirements set out in 2(a)-(i).
At present the policy is not considered to be positively prepared and threatens to undermine the
deliverability of development and hence delivery of the objectively assessed needs of the Authority
across the plan period. Further, as outlined above the requirements set out in Policy CC/SD are
considered to exceed those set out in national policy, both from a plan making perspective within the
NPPF (2024) and development management perspective in considering the NDMPs within the NPPF
(2026).

Revise the policy to account for targets that are consistent with the Building Regulations and
national policy and guidance.

The requirement for new development to achieve net zero operational emissions is considered onerous
and goes beyond the requirements of the Building Regulations. In addition, the requirement of achieving
net zero in all new development has not been given due consideration in terms of viability within the
Viability Report and hence threatens to challenge the deliverability of residential development across the
Authority Area.
Further, with regards to Part A (Space Heating) the requirement for dwellings to achieve a space heating
demand of 15-20kwH per meter squared per year accords with the Climate Change Committees, LETI
Net Zero definition and Passivhaus standard – which are higher than other national standards and hence
place unrealistic and onerous expectations on developers.
With regard to Part B (Total Energy Use Intensity, EUI), the EUI targets are split between uses. For
residential dwellings, the targets are set at 35 kWh per meter squared per year which is aligned with
LETI Net Zero definition and the National Grid Future Energy Scenarios. The policy once again goes
above and beyond national standards.
It is also understood that the Building Regulations Part L 2025 Update/Future Homes Standard is due to
include specific EUI targets once published. As EUI targets will be published in this legislation, it is
suggested they are removed to ensure that local plan policy complies with NPPF 2026 Policy PM13
(Setting Standards) and the now withdrawn PPG 1, which states that planning policies should not
replicate matters already addressed by Building Regulations. Whilst it is acknowledged the GCLP will be
examined against the NPPF (2024), the introduction of PM13 within the NPPF (2026) establishes a clear
direction from national government that standards within local plans should not exceed national
expectations unless fully evidenced. To ensure the GCLP continues to be consistent with national policy
and is positively prepared, it is advised the policy is revised accordingly to take account of the now
adopted position with regards to setting standards.
Furthermore, the table below compares the 2025 and 2040 EUI targets set out in the UK Net Zero
Carbon Buildings Standard and demonstrates that the EUI requirements exceed existing targets, with no
flexibility to allow dwellings to benefit from a transitional period ahead of 2040. Use
Draft Local Plan
2025 EUI Target
2040 EUI Target
Dwellings (Flats) 35 kWh/sqm/year 40 kWh/sqm/year 35 kWh/sqm/year
Dwellings
35 kWh/sqm/year 45 kWh/sqm/year 35 kWh/sqm/year
Table 1. EUI Targets in UKNZCBS versus draft local plan.
As a consequence of the above considerations we request the draft policy is removed from the GCLP in
full. At present the policy is not considered to be either justified nor in line with national policy and hence
cannot be considered sound.

• Delete Point 4(b) (zero discharge requirement for rainfall up to 5mm).
• Delete Point 4(e) (requirement for all hard surfaces to be permeable wherever practicable).
• Reword Point 4(f) to read: 'The Authority will encourage the integration of green / brown roofs
into developments with flat roofs where appropriate and viable.'
• Delete Point 6(a) entirely to remove unlawful proof of wastewater infrastructure capacity burdens
on applicants.

Point 4(b) requires development to result in no discharge from a developed site for rainfall depths up to
5mm of any rainfall event. This blanket required is considered onerous and does not reflect the individual
nature of different sites where topography, solid soil composition and infiltration rates all affect discharge
rates. Furthermore, this requirement goes beyond that set out within the SuDS Manual (2015) which is
considered the most up to date and reliable guidance with regards to SuDS. As currently worded the
draft policy hence risks being both unjustified and inconsistent with national policy. It is hence
recommended that point 4(b) is deleted from Policy CC/IW.
Point 4(e) requires all hard surfaces to be permeable wherever practicable. Vistry wishes to highlight the
considerable build costs such a requirement will have and needs to be reflected within the Local Plan
Viability Assessment. Such a requirement could threaten the viability of residential development and as
such is considered unjustified and not sound as currently worded. It is suggested point 4(e) is deleted
from the policy as currently drafted.
Point 4(f) requires all flat roofs to be either green or brown. This blanket requirement goes beyond the
requirements of the Building Regulations and is hence considered overly onerous to apply such
requirement in all conditions where it may not be viable, appropriate or achievable. 4(f) is hence
considered unjustified as currently worded. We suggest the policy should be reworded to express the
desirability for flat roofs to be green / brown but not required. Our suggested rewording of 4f is as below:
a. The Authority will encourage the integration of green / brown roofs into developments
with flat roofs where appropriate and viable.
Point 6(a) as currently worded sets out that development must demonstrate there is capacity for
wastewater treatment and adequate wastewater conveyancing infrastructure to serve the whole
development, or an agreement is in place to ensure the provision of necessary infrastructure prior to the
occupation of development. Vistry considers that this requirement is in direct contradiction of the duties
bestowed on Anglian Water under S37 and 94 of the Water Industry Act (1991) and in essence would
circumvent Anglian Water’s statutory requirement to service new development and ensure there is
wastewater capacity.
It is not sound for the Authority to ask developers to demonstrate capacity which is subject to other
regulatory regimes and beyond the control of a prospective applicant and is consequently inappropriate
to include a policy in the GCLP requiring an applicant to assess capacity or otherwise of the water
company to provide connections. As worded in the draft policy, this represents an attempt to place duty
on applicants for things they are not legally responsible for.
As currently worded 6(a) has the potential to prevent development from being delivered, should Anglian
Water object or refuse to agree to infrastructure delivery and hence undermines the deliverability of the
entire GCLP. The policy as currently worded is hence unjustified, not consistent with national policy and
threatens the soundness of the GCLP. We therefore request that 6(a) is deleted entirely from the policy.

• Define clear parameters and boundaries in Point 1 regarding embodied carbon reduction
expectations.
• Reword Point 2 to encourage building retention/renovation while deleting detailed justification
sub-points (a)–(d) to align with Class B Permitted Development rights.
• Delete Point 2(d) entirely so embodied carbon is weighed within the normal planning balance
rather than acting as a strict requirement.

Point 1 requires all development proposals to “proportionately” take opportunities to reduce the
development’s embodied carbon content. As currently worded the policy is considered too vague and
does not set any clear defined parameters or boundaries for schemes to meet. Without clear boundaries,
it is unclear if this policy requirement will threaten the viability of development.
Point 2 requires any proposals that involve demolition to be accompanied by full justification for
demolition. This requirement does not reflect the provisions made under The Town and Country Planning
(General Permitted Development (England) Order 2015 which under Class B sets out the Permitted
Development rights for demolition of a building. Requiring full justification for demolition of a building to
be provided would hence be inconsistent with the legislative procedure for building demolition set out
within Class B. As currently worded, the draft policy is hence considered unjustified and inconsistent with
national policy. It is hence recommended that Point 2 is reworded to promote the retention, reuse and
renovation of existing buildings where possible, but remove the detailed justification requirements set out
in sub points a-d, allowing development proposals to come forward and demolition justified on their own
merit. This would allow embodied carbon to be taken into the planning balance in the same manner in
which other material considerations are.
Furthermore, Point 2(d) requires proposals for demolition and construction of a new building to deliver
significant benefits that outweigh carbon savings that would arise from the building being repaired or
reused. In isolation this requirement is considered onerous we argue carbon savings should not be the
only determining factor in determining the acceptability of demolition and redevelopment of a site.
Embodied carbon and carbon savings is a material consideration and should be factored into the
planning balance as with any other material consideration for example the safety of the building, the
economic viability of renewing a building or its contribute to the environment. Further it is noted the policy
as currently worded goes beyond the requirements with regards to carbon and development as set out in
the NPPF (2026). For the purposes of determining application proposals Policy CC2 (Mitigation of
climate change) states substantial weight should be given to the benefits of improving the energy efficiency of existing buildings and the use of renewable carbon sources. CC2 does not, nor does it
anywhere else in the NPPF (2026) require that development only be approved where benefits would
outweigh the carbon savings. It is hence considered the policy as currently worded is materially
inconsistent with NPPF (2026) and would hence only be afforded limited weight in the determination of
future applications.
Point 2d should hence be deleted from the policy in full.

• Delete Policy CC/CS or significantly revise Part 7 to read: '7. The demonstration of meaningful
carbon sequestration where there is a significant net gain within a proposal through nature based
solutions will be a material consideration in the decision-making process.'

Part 7 requires all major development proposals to seek opportunities to enhance carbon sequestration
potential of their proposals through green infrastructure or new habitat creation. In taking the definition of
‘major development’ (Appendix E: Glossary) which aligns within that set out within the Town and Country
Planning (Development Management Procedure) (England) Order 2015 this requirement is considered
very onerous. The requirements set out within CC/CS go beyond any provisions set out within the NPPF
(2026) NDMPs and as such we consider is unnecessary and unjustified.
In addition to the wealth of other polices within the draft Local Plan that deal with green infrastructure,
biodiversity net gain and open space it is unclear why this policy Is necessary. We therefore advocate
the policy should be deleted or significantly revised to read as follows:
7.
The demonstration of meaningful carbon sequestration where there is a
significant net gain within a proposal through nature based solutions will be a
material consideration in the decision-making process.

• Amend Policy BG/BG to remove the 20% BNG requirement for major developments, reducing
the requirement to the statutory 10% BNG threshold under the Environment Act 2021.

The proposed requirement to uplift the mandatory minimum to 20% BNG for major development is
considered unsound, as it is not adequately justified and is inconsistent with national policy.
The uplift is not supported by a robust evidence base and does not sufficiently demonstrate that it is
proportionate or deliverable across all sites. It is unclear if a 20% BNG requirement has been factored
into the Viability Assessment which has the potential to significantly increase development costs and
render development unviable.
The Environment Act (2021) provides a clear statutory framework for the delivery of 10% BNG on
qualifying development. 20% BNG as proposed by policy BG/BG is considered an unnecessary
additional requirement going beyond the statutory requirement which has been fully evidenced.
As the Council will be aware, the NPPF (2026) indicates that the only time where it may be appropriate to
seek more than 10% BNG through local policy relates to allocations, and even then, only where this is
clearly evidenced and justified. This is a clear direction of travel with regard to BNG that there should not
be general requirements for development to deliver beyond the 10% required by the Environment Act.
Further there appears to be no evidence within the Evidence Base demonstrating the exceptional
circumstances required to justify a 20% BNG requirement, nor has the Authority demonstrated within the
Viability Assessment that 20% BNG is achievable and will retain viability of development when taking into
account all the other associated costs of development including additional standards which the draft Plan
seeks.
It is hence recommended that the policy is amended to only require qualifying developments (as defined
by the Environment Act, 2021) to achieve 10% BNG.

• Delete Point 2 of Policy BG/GI, removing the standalone requirement for major developments to
submit separate Green Infrastructure Plans and GI Statements.

Clarification is sought on the details required by a ‘Green Infrastructure Plan’ and Statement and whether
or not this would form part of a Design and Access Statement (DAS). As currently worded the
requirement is too vague and it is not clear what these deliverables would achieve that is not already
secured through the submission of a DAS.
Furthermore, we note a Green Infrastructure Plan or equivalent document is not listed within the
Information Requirements set out in Annex C of the NPPF (2026). We therefore advocate this
requirement for all major development is unjustified and inconsistent with national policy and hence Point
2 should be deleted from the policy.

• Delete Policy BG/UGF in full from the GCLP

We consider the achievement of 10% BNG secured via the Environment Act (2021) to be an appropriate
measure to achieve developments which deliver an appropriate amount of environmental and ecological
enhancements. Vistry query whether the urban greening factor has been taken into account within the
Viability Assessment or practically within developments, with the concern that establishing a new
mandatory requirement for a factor of 0.4 may be both inappropriate and render development unviable
(particularly when this is in addition to the other extensive environmental and sustainability requirements
set out within the emerging GCLP) and or undeliverable. At present this additional requirement risks rendering residential development undeliverable and or
unviable and hence we consider the draft policy to be unjustified and inconsistent with national policy. We hence advocate that Policy BG/UGF is deleted from the GCLP.

• Amend Point 6 of Policy BG/TC to read: '6. Development which includes the planting of trees
and/or hedgerows should ensure their long-term maintenance, which will be secured via
planning conditions and/or obligations as appropriate.'

Specifically, we raise concern with point 6 as currently worded which requires that development “must
contribute” to the maintenance of planted trees and hedgerows. We consider that maintenance is already
secured where appropriate by Landscape Management and Maintenance Plans which can be secured
via condition where appropriate. This is often monitored and secured via a management company, with
no “contribution” required.
We suggest the following amended wording:
6.
Development which includes the planting of trees and/or hedgerows should
ensure their long-term maintenance, which will be secured via planning conditions
and/or obligations as appropriate.