Object
Draft North East Cambridge Area Action Plan
Representation ID: 56013
Received: 05/10/2020
Respondent: Endurance Estates
Agent: Barton Willmore
General comment on overall approach to SA and SEA in defining the project/implementation of the plan:
Related to our comments on the SA/SEA process, we note that the Draft Habitats Regulation Assessment (HRA) does not consider the effects of relocating the WwTW as part of the same land use plan. This is confirmed at paragraph 4.7 of the HRA, which states that “[a]ny development resulting from the NECAAP would take place within the boundary of North East Cambridge”.
In addition, the HRA does not assess the relocation of the WwTW “in combination” with the NECAAP as an “other plan or project” (in accordance with guidance set out in the 2018 document, Managing Natura 2000 Sites).
We would also question the reliance that the HRA places on the HRAs that have been carried out for other local plans. This is for two reasons. Firstly, we are concerned that there is a significant disparity in terms of what was assessed in the local plan HRAs and what is now being proposed in the NECAAP; the relevant local plan policies did not include the quantum of development that is currently set out in the Draft NECAAP. Secondly, some of these other HRA documents referenced predate significant recent European Union case law on this subject (e.g. People Over Wind and Holohan). As a result, these documents may potentially not be compliant with up-to-date principles. At the very least, the NECAAP HRA should provide reasons as to why the assessments relied upon are considered to be robust.
We consider that the HRA for the NECAPP should consider the likely significant effects of the relocation of the WwTW, if it is not part of the Plan itself, then in combination as an “other plan or project”. The WwTW is a project that cannot be considered insignificant in scale, which is intrinsically linked with the proposed development of the NECAAP. The effects on European sites of the relocation of the WwTW need to be properly considered in combination with the NECAAP proposals.