Greater Cambridge Local Plan Preferred Options

Representation ID: 58153

Received: 12/12/2021

Respondent: Mr Matthew Asplin

Representation Summary:

SA chapter 5.4 states that WWTW relocation will be added later as ‘in-combination effects’.
Chapter 5C discounts options that retain the WWTW onsite yet excludes its relocation.
Policy S/NEC and corresponding relocation is contrary to a wide range of Policies, including: GP/LC,GP/LC,GP/GB,GP/HA,BG/GI,BG/RC,BG/EO,BG/PO,J/AL,WS/HS,CC/NZ,CC/CS. This includes capital carbon of rebuilding at a Green Belt location identified as causing ‘Very High Harm’.
The assessments relating to NEC (S/NEC) don't consider the effects of WWTW relocation and therefore provide an imbalanced assessment.
Suggest WWTW relocation is included for a balanced view. Alternatively, remove S/NEC from the SA until a pending balanced assessment. See notes.

Full text:

Unfortunately, despite the substantial assessment, the SA does not appear to consider all the relevant factors and as a consequence a number of the findings and in turn the Appraisal, appear incomplete or inaccurate.
Para 3.8 notes that the Assessment is not prepared in isolation and highlights the necessity of identifying the relationships between the Local Plan and other plans, policies and programmes so that any potential links can be built upon and any inconsistencies and constraints addressed.
Para 3.17 references the National Planning Policy Framework, that Local Plans should contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.
SA Chapter 5.4 states that issues such as the Waste Water Treatment Plant relocation will be included at a later issue of the Local Plan to address ‘in-combination effects’.
Chapter 5C considers and discounts options that retain the Waste Water Treatment Works on site yet includes no consideration of its relocation and the corresponding impact on Local Plan Policies.
Policy S/NEC references the Waste Water Treatment Works Relocation and based on 5C would appear to suggest that relocation is a dependency of Policy S/NEC.
While the investigation into relocation is being led by Anglian Water under a different Development Consent Order process, Policy S/NEC and the corresponding relocation is contrary to a wide range of Policies in the Local Plan First Proposal, including: GP/LC, GP/LC, GP/GB, GP/HA, BG/GI, BG/RC, BG/EO, BG/PO, J/AL, WS/HS, CC/NZ, CC/CS. This includes the capital carbon associated with rebuilding a fully operational treatment works at a Green Belt location identified in the 2021 Green Belt Study as having ‘Very High Harm’.
Consequently, the assessments relating to North East Cambridge (S/NEC) do not consider the effects of Waste Water Treatment Plant relocation and therefore provide an unrealistic and imbalanced assessment.
It is understood that the Environmental Impact Assessment Scoping Report for the Waste Water Relocation investigation has been submitted and the Planning Inspector has issued a scoping opinion. Consequently, sufficient information should exist for this to be included within the assessment.
The SA already makes provision within the scoring system for ‘?’ variations and contains a section on pages 43 & 44 addressing Problems Encountered and includes disclaimers relating to aspects of technical detail or mitigation.
It is therefore suggested that the effects of relocation of the Waste Water Treatment Works are included fully within the SA to provide a balanced view. Alternatively, North East Cambridge Policy S/NEC should be omitted from the SA completely until a comprehensive and balanced assessment can be made.