S/NEC: North east Cambridge

NEC development is predicated on the move of the Waste Water plant. This was voted for by city and south Cambs councillors without due regard to its possible destination. This move was deemed to be a nationally significant infrastructure project and the decision as to its location was handed over to an unelected entity Anglian Water. This company has nominated Honey Hill as its location in prestige green belt. This destruction of green belt is not shown on your map and you have the cheek to say that we should enjoy increased open spaces and increased biodiversity while Anglian Water are destroying this area. They propose to pour millions of tons of concrete have hundreds of truck movements a day. And you don’t have the guts to admit it. Talk about Greenwash Blah Blah Blah!

Object to parts of the policy. 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 relocation depends on a successful DCO and therefore this policy cannot come into effect if the application fails. The policy should consider a " Plan B" with fewer dwellings, less commercial especially as 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, it's not necessary and the North East Cambridge Area Action Plan and this policy should be reconsidered.

The North East Cambridge development is, as you state, 'predicated on the relocation of the existing Waste Water Treatment Works, a process being led by Anglian Water'. The relocation is totally unnecessary according to Anglian Water therefore the current Waste Water Treatment Works (WWTW) site is not a Brown Field Site. The proposed WWTW relocation to Honey Hill in the Green Belt itself is at odds with the Councils own policies. The cost of £227million is a scandalous amount of taxpayers money to produce a bogus brown field site.

This seems a sensible idea, as the bus and rail network are convenient for use.

Whilst the North East Cambridge site is clearly key to meeting the targeted number of homes by offering 3900 homes, care needs to be taken to ensure that, given the site's proximity to Cambridge North station, that it does not become another area housing largely London commuters and not addressing the housing need relating to local jobs. The area around Cambridge's main railway station, which has been developed heavily in recent years, appears to have become a very seedy area largely filled with small flats and inhabited by those with no ties to the area and jobs in London. High priced flats are supported by London salaries, but do little to address local housing needs. The same mistakes need to be avoided with this site

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.’

We agree with the proposals.

(Education) Based on the housing mix that has informed the North East Cambridge Area Action Plan, the development is expected to generate approximately 1,362 early years’ children, 790 primary-aged pupils (3.8FE) and 205 secondary-aged children (1.4FE). This would require delivery of up to two primary schools on site, both with early years’ provision. Additional sites would also need to be allocated and marketed for full day care provision. This is partly to ensure sufficient EY places, which could not be provided on the school sites alone, but also to promote choice of type of EY provision for families who are not entitled to funded childcare but still wish to access provision. At this stage, it is for illustrative purposes only. The Council will not be able to confirm its education requirements, land and contributions until later in the planning process when the housing mix is finalised.
The Council remains committed to working in collaboration with South Cambridgeshire District Council and Cambridge City Council during the Area Action Plan making process and is supportive of the view that the detailed planning framework containing site specific policies will be of equal status to those in the Local Plan once adopted.
The policy states that formal sports facilities will be largely delivered off-site. Whilst the Council does not object to this approach, it would insist that school playing fields are located on-site to ensure that high-quality PE curriculum can be delivered without the requirement to travel.

(Minerals and Waste) No comments – covered in Area Action Plan Statement of Common Ground.

The Wildlife Trust acknowledges that the NE Cambridge allocation has the potential to be a sustainable new quarter for Cambridge, however the Area Action Plan has fundamentally failed to provide for the strategic greenspace that the new population will require, with its woeful open space proposals. The Local Plan HRA identifies the need to provide Suitable Alternative Natural Greenspaces and not rely on existing provision such as Milton Country Park which is full. It is essential that this policy and the AAP provide for sufficient strategic natural greenspace, which would also benefit other nearby communities with deficiencies in natural greenspace.

Greater Cambridge is reliant on 8,350 new homes being provided at North-East Cambridge under Policy S/NEC. This is a significant level of housing to be provided on a brownfield site, part of which is contaminated and comprises a sewage works. There are likely to be significant costs associated with remediating the site and potential time delays on bringing development forward on the site. It is considered that the Council should look at providing more of a range of smaller and medium sites that have the ability to come forward at a faster rate than strategic sites of this size.

Greater Cambridge is reliant on 8,350 new homes being provided at North-East Cambridge under Policy S/NEC. This is a significant level of housing to be provided on a brownfield site, part of which is contaminated and comprises a sewage works. There are likely to be significant costs associated with remediating the site and potential time delays on bringing development forward on the site. It is considered that the Council should look at providing more of a range of smaller and medium sites that have the ability to come forward at a faster rate than strategic sites of this size.

Huntingdonshire District Council’s response to the North East Cambridge Development was submitted as part of the North East Cambridge Area Action Plan consultations.

Careful consideration will have to be given to the timing of delivery in relation to the relocation of the WasteWater Treatment Works and whether this will slow delivery on site.

Huntingdonshire District Council would like assurance that the Councils have additional sites to meet their housing need if delivery slows as a result of the relocation of the WasteWater Treatment Works to ensure that additional demands are not placed on the wider housing market due to under delivery within Greater Cambridge.

We question the deliverability and viability of 4,000 homes being delivered from this allocation within the plan period given the reliance on the relocation of the sewage treatment works and also the remediation which will be required as part of any development proposal. This allocation may cause the plan to be vulnerable to challenge at Examination stage.

Do not support creating a brownfield site here in order to cram houses/flats next the A14. Unsustainable location because the demolition of an operational sewage plant is not being included in the sustainability assessment, nor is the carbon cost of relocating and building the sewage plant on Green Belt a short distance away. Support medium growth approach to NEC which did not include CWWTPR. NECAAP lack meaningful open space - 27ha in thin corridors. Moreover, it involves destroying an area of Green Belt which acts as an important buffer between ancient settlements and new developments of Marleigh and the Airport.

Please see attached letter.

In our response to the Area Action Plan consultation for North East Cambridge in 2019, the department suggested that a D1 use (now F1) of the type and specialism described would be complementary to the high tech science park and the university, while fitting well within the proposed residential-led mixed use development. The location close to the new railway station was considered highly suitable for CMS, given the larger-than-local catchment area for the school and the need to encourage sustainable travel choices. We requested that a site be allocated for a school within the larger mixed use allocation.

We note that the proposed policy direction for Policy S/NEC includes schools among the necessary infrastructure to be provided. As well as providing new school places directly linked to the need from housing growth, the councils should have regard to the NPPF requirement to allow for sufficient choice of school places, giving great weight to the need to widen choice in education (para 94). CMS would be instrumental in diversifying educational opportunities for this new community, the rest of Cambridge and the wider sub-region. The local education authority, Cambridgeshire County Council, has provided the attached letter of support, and confirmed they would also consider supporting alternative sites for CMS provided they are equally accessible by public transport and offer equally good connectivity for students travelling from a wide area. If a site for CMS within the NEC allocation were secured, the department would work closely with the councils to ensure the development accorded with the NEC Trip Budget, making sustainable transport the most attractive option for students and staff.

This is far too dense a site. The better option is the airfield site which has one owner and no existing infrastructure. North East Cambridge should remain an industrial site. The airfield can be developed with real green space as in the Trumpington area.

This is a very naive project because:-

This many jobs and houses on the site will generate an enormous increase in traffic because people living here will not necessarily work here and people who work here will come from elsewhere. They will not all be walking or cycling to work.

Property on this site will attract investors and people who commute to London.

There is no proper open space on this site. The plan measures this by adding up grass verges not proper open land. The open space recommended is on the other side of the A14.

Not supported. WWTP site not surplus brownfield without relocation of WWTP to Greenbelt contrary to national policy and Policy GP/GB . No operational need to relocate WWTP.
GCSP response to CWWTP Scoping Report: relocation WWTP is not a “requirement” of the NECAAP and must not be referred to as such .
Local Plan should not rely on housing which can only come from a major Greenbelt release.
Proposed relocation relied on S/NEC Policy contrary to Policies: BG/GI BG/RC,BG/PO,BG/EO, GP/LC,GP/GB,GP/QP,GP/HA,WS/HSCC/NZ,CC/NS

The balance between dwellings and job opportunities has be improved but we are still unconvinced that the plans are practical

The assumption that the dwellings will be occupied by people working locally for a development arising over many years. Many may move their originally but records show most people now work for several employers in a career and with many job opportunities in the local area it is unrealistic to expect over time that all residents will work in the local businesses. This assumption ignores that two people in a partnership may choose the location to suit the locality of one partner with the other working elsewhere.

The breakdown of this assumption means more travelling into the NEECAP area for work, and given the availability of affordable housing , even with the new developments, may not be on the two public transport links and so increase the car volumes on the already at capacity Milton Road section from the A15 junction

Furthermore, the expectation of a halving of the incoming vehicles peak time demands for the Cambridge Science Park is not credible.

The provision of informal open space (especially as Milton Country Park has been declared to be already fully utilised and so not available to be counted for NEECAP) and even more the lack of serious formal space, such as not even a single football pitch)

All of which indicates a need to further scale back the expectations for new housing and jobs within NEECAP. This alters to balance of the Plan

The housing development is not supported.The requirement of CWWTP relocation to the Green Belt to fulfill the housing targets of S/NEC is contrary to the Aims and Vision of the Local Plan,National and Local Planning Policies. Building Houses on a brownfield site released only by moving a fully operational future proofed CWWTP into the Green Belt, at the request of Council for AW to seek a viable alternative location, is one step from building houses in the Green Belt. There is no provision for development in the Green Belt in the existing or emerging Local Plan. Viable alternatives exist.

This has the potential to be a showcase development if done right. The plan should permit bold use of the space to create a high-density dwelling development with plenty of green space (of varied kinds) and recreational / entertainment facilities. The co-location of retail and dwelling provision should be used to enhance vibrancy.

There is a glaring omission from the plan. There is no mention of the CWWTPR moving to Green Belt.
The move to Green Belt is proposed as a necessity to unlock a brownfield site on which to build a level of housing/office and retail space that is claimed to be needed (according to dubious figures produced before the global pandemic when working and living patterns were very different than they are now). There is a regulatory requirement that the public and all consultees have sufficient information about any significant effects of the Local Plan in order to make a judgement.

There is a regulatory requirement that the public and all consultees have sufficient information about any significant effects of the Local Plan in order to make a judgement. Omitting the relocation of the CWWTP to Green Belt does not allow for a fully informed judgement.
Anglian Water is required to obtain a Development Consent Order (DCO) to see project through. Horningsea Parish Council believes that Councils are hiding behind the DCO. Horningsea Parish Council believes the public has the right to know why it is being expected to give up Green Belt (high grade agricultural land with important recreational value).

It would be interesting to learn how many dwellings in Cambridge are a) student accommodation and b) vacant investment properties (L Frazer did say she'd find out how many weren't paying Council Tax to try to get an idea of this, don't think we as a Parish Council ever received this info). If either of these figures are significant and/ or increasing I believe the Local Plan should consider ways to restrict both moving forward. If investors and colleges snap up a high % of property within Cambridge then that pushes residents out & drives the need to build more.

This Policy is not supported.
As previously noted by GCSP prior to this First Proposal, no allocation was made at North East Cambridge due to uncertainty of the Waste Water Treatment relocation, which recognises that housing and jobs for the plan period and beyond are not dependent upon S/NEC.
The public cost in terms of finance and Green belt loss to relocate a fully operational and future proofed Waste Water Treatment Works is not justified at this time, post COVID 19 when the effects on housing and jobs remains unclear. The DCO decision is not due for a considerable time, yet S/NEC is still included prior to the outcome which appears premature.
The residential over densification is not appropriate at this location when considering the consequential effects, which do not appear to be included within the First Proposals document, alongside the other options available for housing and jobs within the plan period and beyond.
Policy S/NEC conflicts with the following policies, which also does not appear to be referenced in the First Proposals and therefore fails to provide a balanced view on proposed land use as required by the NPPF:
GP/LC: Protection and Enhancement of Landscape Character
GP/LC: Protection and enhancement of landscape character
GP/GB: Protection and enhancement of the Cambridge Green Belt
GP/HA: Conservation and enhancement of heritage assets
BG/GI: Green Infrastructure
BG/RC: River Corridors
BG/EO: Providing and enhancing open spaces
BG/PO: Protecting open spaces
J/AL: Protecting the best agricultural land
WS/HS: Pollution, Health and Safety
CC/NZ: Net Zero carbon buildings
CC/CS: Supporting land-based Carbon sequestration

Concern that the route for a road into Chesterton Fen across the railway should be planned in to the NECambridge plans so that it can be provided when Network Rail accept they have to close the Fen Road crossing.
NECambridge is now to provide the full informal open space on site, but it is not clear where the formal sports provision will be sited. Milton is still below the required acreage for sports pitches for its own population, and cannot be expected to absorb this population too. 
What provision is there for Cemetery space for NECambridge? This is bound up with governance questions. Milton provides a cemetery for its ratepayers. The City has the crematorium and burial ground there. If Milton is to have a liability then we need to have funding in the S106. 
Milton Country Park is taking too many visitors already, more informal recreation space is needed near Cambridge.

There are many things to commend in the environmental aspirations for this development but disappointingly the provision on natural greenspace is not one of them.

The amount of informal green space meets the minimum amount required by the council’s policies but two thirds of this is provided on a business park, described on p26 of the NECAAP Open Spaces Report as “these green spaces aren’t perceived as being accessible to the wider public”. Would you want to visit a business park for your leisure and recreation? It should be noted that the green space on the business park already exists, so it is not new space.

Only a third of the green space is provided in conjunction with the housing. Most of this is provided as linear green space or pocket parks, in other words small areas of green space that are loomed over by high-rise buildings. There is one larger park but the size of this is not provided in any of the documents. Extrapolating from the plans, we estimate this to be around 3.5 ha in size. Fig 20 in the AAP report includes an infographic which aims to compare the amount of open space in the AAP with other Cambridge parks, the comparison is misleading because the parks which are used for comparison are just that, parks. A better comparison would be the main park proposed for the new development. At 3.5ha this is small in comparison to the other parks, given that it is to cater for 16,000 people.

At a bare minimum the proposals for the AAP might possibly just provide for the day-day open space needs of the new residents: play space for children, somewhere to walk the dog or kick a ball about. But what it won’t do is provide the kind of green spaces that people in high density developments need access to – which is large natural greenspace: somewhere they can go for a long walk or run, experience nature, and escape the pressures of urban life.

There is of course somewhere for them to do that, it is Milton Country Park and a subway is proposed under the A14 so that residents can get to it. And that is exactly where the 16,000 people will go. That would be great if it were not for the fact that the Country Park is already at capacity and cannot cope with 16,000 more visitors.

In the hundreds of pages of text for the NECAAP there is almost no mention of Milton Country Park at all, let alone of it meeting the needs of the development. There has been no assessment of whether the country park has the capacity to cope and what mitigation might be required to enable it to do so. We could see no requirement for S106 contributions to support the park to cope only this rather vague paragraph on p54 of the NECAAP Open Spaces & Recreation Topic Paper:
"There is a need to build in community resilience and capacity into the existing open space provision for NEC. Alongside any on-site provision, opportunities to use S106 contributions outside the city on large-scale green infrastructure should be considered. This will avoid pressure building up on existing parks, open spaces and cycleways, which might otherwise lose their biodiversity and other qualities. For example, undertaking negotiations for specific S106 contributions, for growth sites straddling the Cambridge/South Cambridgeshire boundary. These could explore opportunities for improving existing or creating new parks beyond the city which are easily accessible by foot and cycle, in order to avoid over-investment in, and over-use of popular or environmentally sensitive sites."

Natural England’s Accessible Natural Greenspace Standards would require the NECAAP development to have a large 100 hectare site of accessible natural greenspace within 5km. Especially as this development is to be largely car free. But there isn’t one. To make matters worse, the north of Cambridge will also see 20,000 people at Northstowe and 22,000 at Waterbeach. Where will these 58,000 people go to meet their green space needs?

This is an area which has been highlighted in the Green Infrastructure evidence base for the Local Plan as already suffering from a deficit of green infrastructure and recreational pressure. This report highlights North East Cambridge to Waterbeach as a priority area for green infrastructure with its enhancement marked as of ‘critical importance’.

The only option for providing that critical greenspace is through the North East AAP and therefore it is essential that s106 contributions are secured towards this.

Failure to do so will result in increased recreational pressure on European Protected Sites/ Habitats Directive (ie Wicken Fen Special Area of Conservation). Please see our response to the Local Plan Habitats Regulations Assessment.

The timescale of NEC providing housing before Marshalls is wrong.

- Marshall’s have committed to passing over a vacant site by 2030
- Supposedly the construction of NEC will start in 2028.

However, construction on a mostly “green" site (the airport), is a lot more predictable than construction on an old sewage works.

Demolition of CWWTP is going to be done after the developers take possession post 2028 (see p2-53 Anglian Water's EIA Scoping Report).

So a strong argument that housebuilding on Marshall's will start before NEC where the developer will undoubtedly find many unpleasant surprises before starting building.

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