The scale and high density of housing development at North East Cambridge is not supported

Greater Cambridge Shared Planning specifies that neither the Local Plan nor NECAAP require the relocation of CWWTP ie neither is dependent on it (Ref. Page 6 Appendix 2 PINS Scoping Opinion - GCP's response to Scoping Report - https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/WW010003/WW010003-000028-WW010003%20-%20Scoping%20Opinion.pdf

The housing development allocated to S/NEC is reliant upon the relocation of CWWTP to the Green Belt

There is no existing or emerging  Local Plan allocation or justification for development of the Green Belt to accommodate or fulfil S/NEC

There is no operational requirement for AW to relocate to the Green Belt, the existing site was future proofed in 2016 and has capacity to accommodate the scale of development presented in the emerging Local Plan and beyond.  The single driver for relocation is at the request of Cambridge City Council to seek a viable alternative site for CWWTP in order to release a brownfield site for housing development . This interdependency cannot be separated in consideration of the effect of S/NEC Policy.

S/NEC policy is one step away from housing development on the Green Belt with no allocation or examination in a Local Plan, it is dependent on it.

S/NEC should be removed from the Local Plan until after the DCO outcome or an alternative presented that is attainable without relying on the relocation of CWWTP and can be examined under the usual Local Plan Sustainability Appraisal.

A medium level of redevelopment (Option2) of NEC was identified as deliverable without relocation of CWWTP in the AAP Options Consultation 2014. This included a forecast of 15,000 jobs matching  those now allocated in S/NEC and  440 homes.     

The  4,000 homes  allocated to S/NEC in the plan period to 2041  could be reallocated elsewhere within the City boundary eg an additional 1,000 Cam Airport ; 1-2,000 Cam Bio-Medical Campus; 1,000 identified Areas of Major Change.

The balance to full build out of NECAAP beyond the plan period could be accommodated by Cambridge Airport (up to 7,000 allocated to full build out) and further allocations eg as identified in S/CB & S/NS at which time planned sustainable transport developments will be in place addressing Carbon emissions for work journeys.

If DCO successful counted houses  gained counted as ‘windfall’ in plan period

A case can be made on the basis of sustainability eg unknown water resource; impact of COVID  on home working,  preferred housing locations and demand for office space for a reduced Growth Option to Medium or Minimum. In either case this would reduce the requirement of additional housing in the plan period by at least 2,500 determining 1500 only of the 4,000 homes allocated to S/NEC requiring re-allocation amongst other sites.

All emerging Local Plans are required to be flexible, in addition, during the plan period 5 year reviews protect from over or under development. However, in the case of S/NEC the housing allocation is driving the DCO process and there is no flexibility. If successful, within 2 years only despite neither the Local Plan or NECAAP requiring it or there being any allocation of Green Belt been made in a Local Plan, relocation of AW to the Green Belt will go ahead with all the environmental consequences associated with it. 

S/NEC, as presented in the Local Plan, is not flexible and the environmental effects as a result of the requirement of the relocation to fulfil it are contrary to the Aims and Vision of the Local Plan and environmental Policies GP/GB; BG/GI ; BG/RC ; BG/PO ; BG/EO.

The development targets for housing in Greater Cambridge are over ambitious in the plan period and bring a high level of risk to Greater Cambridge and the Vision and Aims of the Local Plan .

The Medium plus Growth Option is not supported, a Minimum or Medium Growth Option is recommended requiring an additional 3,000 homes (rounded & incl 10% buffer) and Medium Option an additional 8,500 homes (rounded & inlc 10% buffer). [figures pg.84 of the SA and pg.42 of Development Strategy Topic Paper]

The development strategy of Densification is not supported; greater focus on bringing sustainable transport initiatives to the fore from outside the Greater Cambridge Area for example improved rail links, Newmarket /Ipswich line are recommended for example

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 is recommended.