Greater Cambridge Local Plan: Proposed Submission

• Replace ‘food growing space’ with ‘allotments’ throughout policy BG/EO

Vistry specifically objects to the terminology of ”food growing space” which is used within the draft policy.
This is not defined and as such is not clear what the Authority is seeking in terms of food growing space
provision. To ensure the GCLP is positively prepared and in line with national policy, the term should bereplaced with ‘allotments’ which is industry standard and the terminology used within the NPPF (2026) as
opposed to food growing space. In altering the wording to ‘allotment’ would ensure the policy is
consistent in terms of its request and terminology within the NPPF (2026).

• Remove the duplicated requirement for a community Needs Assessment, as it is already
covered by Policy BG/EO.
• Delete the requirement for developers to identify and address community needs, which should
be informed by the Local Plan and Infrastructure Delivery Plan.
• Clarify that community facility contributions will not be double-counted through both CIL and
Section 106 obligations.
• Amend Point 7 so residential development may contribute to sports facilities where justified,
proportionate, and appropriate to the scale and location of development.
• Remove reliance on untested sports facility strategies that are not part of the examined evidence
base.
• Replace the reference to delivery in “early phases” with a flexible, case-by-case approach linked
to development phasing and viability.
• Revise the policy to reduce ambiguity, improve certainty, and ensure development viability is not
adversely affected.

With regards to point 4 we object to the repetition of the requirement for the submission of a Needs
Assessment for residential sites over 200 dwellings, which is also set out in in Policy BG/EO. This
repetition is considered unnecessary and should be removed to ensure the Local Plan is concise and
avoid undue repetition.
Point 4 states that proposals for residential developments of 200 or more dwellings (or multiple smaller
sites that cumulatively exceed this threshold), as well as employment developments over 5,000 m², must
be informed by detailed assessments of community needs and include strategies to address those
needs. It is understood that these assessments should be prepared by the Authority as part of their Local
Plan and associated Infrastructure Delivery Plan, and the responsibility should not fall on developers to
determine which community needs a development should meet and introduces significant uncertainty.
Point 5 states that developments that do not generate an onsite demand for indoor and outdoor
community and cultural facilities will be required to contribute to offsite provision via CiL. It is noted as of
September 2026, CiL has not yet been adopted with examination scheduled for Q4 2026.
Notwithstanding this point, it is not clear that contributions via CiL to such facilities have been accounted
for within the Viability Assessment. Vistry hence raises query as to whether such contributions will also
be sought for via S106 obligations as well. There should be no double-counting of provision across CIL
and S106.
Point 7 sets out that residential development must contribute towards indoor and outdoor sports facility
informed by needs identified in the Indoor Sports Facility Strategy, Playing Pitch Strategy, and Outdoor
Courts and Rinks Strategy or any successor document. We raise concern with this, given it is understood
the aforementioned documents are not subject to any scrutiny, formal review and are understood to not
comprise the evidence base that will support the emerging GCLP through Examination. As such, the
identified required contributions within these documents may be unjustified and not reflect an evidenced
approach to identifying needs for such facilities generated by developments and introduce future
obligations which have not been financially tested. We hence request that point 7 is reworded to read as
follows:
“7. Residential development may contribute towards both indoor and outdoor sports facilities including
ancillary uses such as changing facilities appropriate to the scale and location of the development and
where justified and which could include provision off-site via financial contributions towards publicly
accessible provision.”
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. Therefore, the policy should be reworded to this effect.
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 above to ensure the Local Plan is justified.

• Reword Point 7 to read: 'Where appropriate, major and minor planning applications will be
required to submit an Air Quality Assessment.'
• Define and clarify the exact scope and parameters of 'minimise' in Point 8.

Point 7 requires all major and minor planning applications to submit an Air Quality Statement. Such
sweeping application requirement is considered onerous and does not take into account the individual
circumstance, scale and effects of development proposals. The draft policy as worded is hence not
justified. Vistry requests that the policy should be reworded to read as follows:
1. Where appropriate major and minor planning applications will be required to submit an
Air Quality Assessment.
Point 8 requires major development proposes to “minimise” emissions. Clarity is sought on what
‘minimise’ means and the extent to which will be sought by the Council. To ensure the policy is justified
and effective further details on what is expected of development proposals should be provided and
thereafter tested.

• Reword Point 2(h) to state that Hostile Vehicle Mitigation (HVM) measures are required only
'where appropriate', backed by clear guidance.
• Review and resolve internal policy conflicts between HVM barrier mandates (Point 2h) and site
permeability requirements (Point 2i).

Point 2(h) requires design to integrate security measures such as Hostile Vehicle Mitigation. Within the
policy there is no guidance on where this will require and as currently worded appears to apply this
approach as a blanket across development. This is considered problematic and does not take into
account the specific circumstances, setting and contexts of individual developments and can have an
adverse effect on a residential environment through the introduction of hard landscape features within
developments. To be effective and justified the policy should be reworded to state that such design
measures will be required where appropriate and should provide further guidance on what measures are
envisioned.
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 should be undertaken to ensure development remains deliverable and the
requirements placed on developers is clear. This would ensure the policy is effective and justified.

Amend Point 1(b)(vi) to read: '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’

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 land and
onerous land take, 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.
We hence advocate that the policy is revised to read as follows:
I.
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;
The amendment detailed above would ensure the GCLP is both justified and reflective on national
guidance and policy.

• Remove or amend the word “must” in Part 2(b) to avoid imposing an absolute requirement.
• Introduce more proportionate wording that allows for balanced planning judgement.
• Ensure the policy reflects the statutory approach of weighing heritage impacts against public
benefits and site-specific circumstances.
• Align the policy with the National Development Management Policies (NDMPs) and NPPF (2026)
heritage provisions.
• Ensure consistency with statutory duties relating to heritage assets.
• Avoid policy wording that could unnecessarily constrain high-quality and sustainable
development.
• Revise the policy so it reflects a balanced, justified and nationally compliant approach to heritage
decision-making.

Part 2(b) is overly prescriptive and not fully consistent with national policy or the statutory framework for
decision-making in the historic environment. The use of the word “must” risks precluding high-quality,
sustainable development by implying an absolute requirement to conserve or enhance heritage assets in
all circumstances, rather than allowing for a balanced planning judgement.
National policy and legislation require decision-makers to have special regard to the desirability of
preserving heritage assets, while weighing this against the scale of harm, site context and public
benefits.
Policy GP/HE should therefore be amended to adopt more proportionate wording that reflects this
balanced approach, consistent with the NDMPs set out within NPPF (2026), notably HE5 – HE10 and
statutory duties.

• Amend Point 4 so that up-to-date housing need evidence applies exclusively to affordable
housing mix.
• Remove market housing mix preferences from Tables 7 and 8.
• Align policy with NPPF (2026) HO8(3) to support a flexible, market-led approach for market
housing when affordable obligations are met.

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.
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.
We hence contend that point 4 is revised to explicitly state up-to-date evidence will only be required to
inform the affordable housing mix provision and Tables 7 and 8 are revised to remove the housing mix
preference for market housing. The policy should also be revised to reflect HO8(3) and state where
affordable provision is met or exceeded a flexible, market led, approach to market provision will be
supported.

• Amend Point 1 so NDSS compliance applies exclusively to affordable housing.
• Delete Point 2 (repetition of NDSS standards) entirely.
• Reword Point 4(e) to: 'Provide balconies that are designed as integral elements of the building's
architecture.'
• Amend Point 4(g) to reduce minimum private amenity space for ground floor apartments to 5m².
• Delete Point 4(h) (extra 1m² amenity space per additional bedroom).
• Amend Point 6 to mandate Building Regulations M4(2) standards for 10% of dwellings rather
than 100%.

Point 1 requires all new residential units to meet the Nationally Described Space Standards (NDSS). This
requirement goes beyond Building Regulations and Vistry raises concern this removes the opportunity
for individual requirements and preferences to be accommodated as residential units are built.
Particularly with regards to private dwelling provision, Vistry has sought to meet prospective buyers
requirements and desires, which do not always align with the NDSS. As such it is recommended the draft
policy is revised to state that only affordable provision must achieve the NDSS.
We also raise concern at the length of the draft policy, which unnecessarily repeats 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 rendering the point
irrelevant during the lifetime of the GCLP.
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. As
such the policy should be reworded to simply state:
a. Provide balconies that are designed as integral elements of the building's
architecture;
Point 4(g) should 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:
g. Provide a minimum of 5m² 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; or
Point 4(h) should be revised as 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.
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 to provide for an
appropriate amount of M4(2) compliant dwellings. We suggest 10% of the overall development being of
M4(2) standard is appropriate.
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.

• Remove the mandatory 5% self/custom build plot quota across major sites, replacing it with a
demand-led approach based on local self-build registers.
• Exclude flatted and higher-density residential developments from custom-build requirements.

We object to the mandatory requirement for 5% self-build homes as part of any development. Such a
blanket approach across all developments is unjustified and self-build provision should only be sought on
sites where there is a demonstrable need. This would be inconsistent with the Self-build and Custom
Housebuilding Act, which focuses on demand registers, not quotas.
The current wording of the 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 places an unnecessary
and disproportionate burden on developers, particularly in higher-density schemes where viability and
deliverability already constrained by the requirements of the draft Plan.

• Amend Point 4 of Policy I/ST to explicitly define the development threshold/quantum for what
constitutes a 'larger development'.

Point 4 refers to developers of “larger developments”. This terminology is inconsistent and provides no
clarity on what qualifies as a ‘larger development’ leaving this open to interpretation. To ensure
consistency the policy should explicitly define a threshold for what will be considered ‘larger
development’.
This will ensure the policy is effective, clear and sound.