Not supported The area is described as a significant brownfield site. This is not correct as it is occupied by commercial buildings. It can only become brownfield if vacated by relocating the Cambridge Wastewater Treatment Plant to Honey Hill, an area of Green Belt, and therefore contrary to Policy GP/GB Protection and Enhancement of the Cambridge Green Belt. The policy also fails to take into account the changed working and living conditions resulting from the Covid 19 pandemic. The increased densification also appears to be contrary to Policy GP/GB. As the policy states that only 4000 dwellings will be accomplished during the local plan period, and there is no operational need to relocate the plant, the relocation of the plant and the consequential damage to the Green Belt, is not necessary and the North East Cambridge Area Action Plan and this policy should be reconsidered.
Greater Cambridge Shared Planning, in response to the CWWTP Scoping Report, has themselves stated they would like to clarify that the relocation of the Cambridge WWTP is not a “requirement” of the North-East Cambridge Area Action Plan and must not be referred to as such - see Page 6 https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/WW010003/WW010003-000028-WW010003%20-%20Scoping%20Opinion.pdf.
The housing development at North East Cambridge is not supported, a focus on employment growth in the area and improved sustainable public transport from within Cambridge City, Greater Cambridge and the wider region as an alternative is recommended.
The spatial options review supporting the existing Local Plan (2018) identified a medium growth approach to NEC that did not require the relocation of CWWTP. This focused principally on employment, 15,000 jobs with homes in the region of 200 close to the station area and outside of the 500m odour buffer zone. These employment targets without the relocation of CWWTP match those of S/NEC in the First Proposals. It is recommended this option is represented as an alternative policy.
·Cambridge Airport now presents as a realistic alternative for major housing development on brownfield. The site fares well in the Sustainability Assessment. It will have access to North East Cambridge employment via the new Chisholm Trail and is equal distance to the Science Park and Addenbrookes/Bio-Medical Campus.
Alternatives to meet the target of 4,000 housing supply in the plan period intended at NEC could be attained within a similar time period with forward planning and mixed development for example via: an additional 1,000 houses in plan period Cam Airport ; 2-3,000 homes Cambridge Bio-medical Campus; 1000 Areas of Major Change. These 3 sites in addition to New Settlements will also offer housing capacity beyond the plan period eg Cam Airport has a 7000 allocation to full build out and potential further allocations as indentified in S/CB & S/NS.
A case has been made under S/JH to reduce the housing Growth Option from Maximum + (11,500 additions required) to the Minimum (3000 additions required) or Medium range (8000 additions required). In the case of either of these alternative Growth Options being adopted the alternative site options above could absorb the additional housing target required and further housing beyond the plan period.
Focusing on Cambridge Airport as the alternative major housing development within Cambridge City boundary would remove the risks to the Aims & Vision of the Local Plan and contravention of Policies associated with the unprecedented high level of densification proposed and the necessity to relocate CWWTP to fulfill the S/NEC Policy into the Green Belt within Greater Cambridge.
The impact of large population increases in Greater Cambridge as a result of an unprecedented amount of new homes already in the pipeline, 30,000 + amounting to a 37% increase homes already existing in 2020, are yet to be known/tested and will not be known until mid-plan period and beyond. This high growth strategy may fail if sustainable solutions do not come to the fore in a timely way and the attractiveness of Cambridge for homes and business is eroded (CPIER 2018). The impact of this unprecedented high growth strategy already in progress and committed to needs to be evaluated before it is added to further, in the case of North East Cambridge with’ high densification housing at unprecedented levels for Cambridge’. The Aims of the Local Plan : ‘Wellbeing & Social inclusion’ and ‘Great Places’ are of particular relevance and at risk here.
Changes in working practices post COVID to home working and reduced daily commutes now widely recognised for a number of industries, particularly the tech industries, to be permanent. Thus, reduced CO2 emissions for existing and future forecast employees and reduced demand for housing close to work.
The CPIER (2018) report which informed the Densification strategy advises young people will still wish to be in a centre where they can physically group together, this may be so for those in their first 5 years of work but beyond this, high density living with restricted car use, home working opportunities and affordable housing in the wider region means living in high density housing is unlikely to remain attractive for those in stable relationships seeking family accommodation.
4,000 homes have been proposed for completion in the plan period (2041) at North East Cambridge, the first homes being available from 2030. 8,000 plus have been allocated to full build out beyond this. Inevitably supply will be determined by the developers. If the vision for North East Cambridge level of densification etc., proves not to be popular and sustainable solutions to support the 31,000 homes already committed and yet to be built are not delivered, these homes, including the promise of affordable homes, may not be built in a timely way or the infrastructure promised realised.
Concerns expressed about the level of demand for housing and sustainability of those proposed is most often placated with the assurance that every 5 years the housing supply, demand and need will be reviewed and adjustments made accordingly. However, in the case of North East Cambridge in order to pursue the S/NEC Policy, Anglian Water have been requested to relocate the existing fully operational waste water treatment plant. If their DCO application is successful, long before any of the above are known or review of the impact of the high growth housing targets for Greater Cambridge are realised, relocation will have taken place with significant negative impacts on another area of Greater Cambridge in the Green Belt. The effects of the relocation on the area surrounding the site identified by AW , Honey Hill, will jeopardise the Aims and Vision of the Local Plan and many Policies laid out in the First Proposals listed below will be compromised.
Pursuing housing development at scale in North East Cambridge as a result of the requirement of the relocation of CWWTP to fulfil the S/NEC Policy and the site selected by Anglian Water to do so, will require the introduction of an industrial plant into an area of open Green Belt , where development has been identified by the First Proposals’ Green Belt Study (2021) as bringing about ‘very high harm’. The area is within close proximity to three conservation areas and villages; green infrastructure and numerous historical assets. The historical setting of Cambridge will be impacted and there will significant negative environmental effects impacting on local residents and wider users of the area. The proposed relocation arising from the S/NEC Policy will be contrary to Policies:
o Bio-diversity & Green Spaces:
BG/GI ; BG/RC ; BG/PO ; BG/EO
o Great Places:
GP/LC ; GP/GB; GP/QP ; GP/HA
o Wellbeing & Social Inclusion:
WS/HS
o Climate Change:
CC/NZ – Carbon expenditure, emissions and embedded carbon to decommission fully operational CWWTP and decontaminate site and build new plant within 1 mile of existing inclusive of transfer tunnels, HGV traffic etc., should be factored into carbon cost of fulfilling S/NEC Policy
CC/CS – decommissioning and building a new Waste Water Treatment Plant on prime agricultural land as a means to fulfil S/NEC Policy is in contrary to CC/CS
The following Local Plan Vision & Aims will be jeopardised:
Bio-diversity and green spaces:
‘Increase and improve our network of habitats for wildlife, and green spaces for people, ensuring that development leaves the natural environment better than it was before.’
Wellbeing & Social Inclusion:
‘Help people in Greater Cambridge to lead healthier and happier lives, ensuring that everyone benefits from the development of new homes and jobs.’
Great Places:
‘Sustain the unique character of Cambridge and South Cambridgeshire, and complement it with beautiful and distinctive development, creating a place where people want to live, work and play.’
Infrastructure:
‘Plan for transport, water, energy and digital networks; and health, education and cultural facilities; in the right places and built at the right times to serve our growing communities.’