Greater Cambridge Local Plan: Proposed Submission

• Incorporate explicit minimum vehicular parking standards within the Local Plan.
• Define a clear development quantum threshold in Point 7 for 'large-scale major sites' to specify
when EV charging strategies are required.

The policy, and the GCLP as a whole, does not include any vehicular parking standards and rather
leaves this as a matter to be dealt with by the applicant through a “vision-led Transport Assessment”. We
raise concern that lack of guidance will lead to ambiguity and uncertainty on Authority requirements when
developing design of developments. This is likely to lead to delays during the determination process
where discrepancies are found between the applicant and Council’s previously unknown aspirations. We
consider that minimum parking standards should be provided by the Authority.
The inclusion of vehicular parking standards within the Local Plan would ensure it is justified and
consistent with national policy.
Point 7 refers to “large-scale major sites”. No definition of ‘large-scale’ is provided, leading to ambiguity
on where EV charging strategies will be required. It is therefore requested that the policy should set a
defined development quantum threshold where EV strategies should be required if this is even required
over and above Building Regulations.

• Delete Point 2(k) (mandatory commitment to Considerate Constructors Scheme).
• Delete Point 5(a) (separate LPA approval requirement for temporary haul roads).

Point 2(k) requires DMPs, CEMPs and DCEMPs to demonstrate commitment to a Considerate
Constructors Scheme or Considerate Contractors Scheme. This is considered overly onerous and goes
beyond the typical scope of such documents. It is requested that Point 2(k) is deleted from the draft
policy.
Point 5 in effect seeks the creation of a separate consenting regime for temporary haul roads, with 5(a)
introducing the requirement for them to be agreed by the Local Planning Authority. Vistry wishes to
identify that this is a matter to be addressed within a CEMP and the Authority should avoid introducing
any other unnecessary consenting regime for such roads. We therefore advocate point 5(a) is deleted
from the policy in full.

• Quantify the technical requirement for 'albedo' in Point 2(a)[i], or remove the term from the policy.
• Provide a clear, quantified definition for the requirement to 'minimise internal heat generation' in
Point 2(a)[iii].

With regards to “albedo” (2(a)[i]) it is requested this must be quantified to avoid ambiguity and
inconsistency when preparing applications for development proposals. Without quantification the
inclusion of “albedo” should be removed from the policy to avoid introducing an unnecessary and
undefined requirement for applicants to adhere to.
Further point 2(a)[iii] is considered too loosely worded with no clear definition of the requirements to
“minimise internal heat generation”. Without quantifying a requirement, the draft policy risks being
redundant and not providing clear guidance on the expectations of the Council with regards to internal
heat generation.
As currently worded the draft policy is not considered to be effective or justified and risks being
ambiguous and ineffective.

• Replace the dual water efficiency standards (80 l/p/d and 90 l/p/d) with a single, uniform
requirement of no more than 90 litres/person/day across all residential developments.
• Reword policy text to: 'Residential development must achieve a water usage of no more than 90
litres/person/day. To achieve this level, some form of water reuse or recycling will be necessary.
Proposals that seek to deliver levels of water usage below this level are encouraged.'
• Explicitly clarify that the requirement for water butts applies exclusively to new dwellinghouses,
excluding flats and apartments.

In the first instance it is unclear why different water efficiency standards have been set for developments
of 100+ and less than 100 dwellings. This is an arbitrary threshold and does not reflect the practical
operations of modern residential development. The size of a scheme is unlikely to have a bearing or
influence on the individual household usage of water, and nor should it. As currently worded this aspect
of the draft policy is considered unjustified and hence not sound.
Vistry recognises that Cambridge and the surrounding region is under water stress and the Cambridge
Water Scarcity Group, alongside other bodies, has been established to explore the delivery of solutions
to the constrained water supply in the region. This is evidenced in the Joint Statement on addressing
water scarcity in Greater Cambridge. We also recognise the proviso the NPPF (2026) makes that in
exceptional circumstances (including areas of water stress) there is reason to introduce consumption
standards greater than those prescribed by national policy or within the Building Regulations.
Notwithstanding this, it is considered that setting a different requirement for water consumption in
developments over 100 dwellings is overly onerous, unjustified and ultimately unenforceable during the
operational lifetime of developments. Internal water use is largely determined by occupant behaviour and
individual dwelling specifications, rather than the overall scale of a development. Residents cannot
reasonably be expected to use less water simply because they live in a larger scheme. Furthermore, we
consider the limitation of water consumption of 80/l/p/d may negatively impact customer experience and
reduce the desirability and marketability of new build dwellings. Such requirement would in effect prevent house builders from offering facilities such as baths, higher capacity washing machines and more
powerful showers.
The Council’s own evidence base notes there are still concerns on the legal implications of using
reclaimed water for domestic purpose which should they not be amended may have implications on the
policy’s effectiveness (Cambridge Area Water Supply Evidence, Addendum 2026).
While the draft policy states water reuse / recycling is subject to amendments in relevant legislation we
contend that until such point there is clarity and legislative backing on such matters the Authority should
not be seeking to require residential development to achieve 80/l/p/p/d, which is both unjustified and
unachievable.
As drafted, the policy risks being arbitrary and may fail the tests of justification and effectiveness. It
should either apply a consistent, evidence-based standard across all residential development or provide
clear evidence explaining why a higher requirement is appropriate only for larger schemes.
We hence advocate that a singular requirement of 90/l/p/d should be sought for new dwellings within
Greater Cambridge which would reflect both an ambitious target that reflects the water resource
challenges the Authority and facing and one which is both achievable and will not threaten the viability or
operational function of residential development in the Authority. We therefore suggest the following
amended wording:
a. Residential development must achieve a water usage of no more than 90
litres/person/day. To achieve this level, some form of water reuse or recycling will be
necessary. Proposals that seek to deliver levels of water usage below this level are
encouraged.
As currently drafted the policy requires all new dwellings to be provided by a water butt. We consider the
policy should be reworded to acknowledge this is unlikely to be feasible of flats / apartments and as such
should make explicit reference that water butts should only be required for new dwellinghouses.