Policy 25: Environmental Protection

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Support

Draft North East Cambridge Area Action Plan

Representation ID: 54452

Received: 05/10/2020

Respondent: Orchard Street Investment Management

Agent: Turley

Representation Summary:

The provisions of this policy are supported, and particularly those set out in criterion (e) which refers to no unreasonable restrictions on existing business operations and facilities. Existing businesses and uses should not be prejudiced nor penalised by the introduction of new uses. All new developments should be required to demonstrate that existing uses and their operation can be protected for the long term. The G L Hearn evidence based study Mixed Use Development: Overcoming barriers to delivery at North East Cambridge makes reference to the need for new development to mitigate impacts such as noise effects from current land uses in line with the ‘agent of change’ principle introduced through the NPPF 2018.

Full text:

The provisions of this policy are supported, and particularly those set out in criterion (e) which refers to no unreasonable restrictions on existing business operations and facilities. Existing businesses and uses should not be prejudiced nor penalised by the introduction of new uses. All new developments should be required to demonstrate that existing uses and their operation can be protected for the long term. The G L Hearn evidence based study Mixed Use Development: Overcoming barriers to delivery at North East Cambridge makes reference to the need for new development to mitigate impacts such as noise effects from current land uses in line with the ‘agent of change’ principle introduced through the NPPF 2018.

Object

Draft North East Cambridge Area Action Plan

Representation ID: 55470

Received: 27/09/2020

Respondent: Mr Matthew Asplin

Representation Summary:

The policy advises that

Prior to commencement of development a comprehensive site wide Contaminated Land Phase 1
– Desk Top Study / Preliminary Risk Assessment of the entire area shall be undertaken and
completed.

This is a source of concern as the draft plan recognises the potential for contamination of the
current waste water treatment site. This would indicate that no phase 1 Desk top study or risk
analysis has been completed thus far, let alone an in depth risk assessment. Should this not be a
pre-cursor, without which budgets and financial forecasts could well be flawed and potentially
impact viability and/or affordable housing content?

Despite acknowledgment within the plan of the potential for contamination, at the same time it is
proposed to relocate the current waste water treatment works to a green belt location, one of
which is sited over a High Vulnerability Principle Aquifer (source Anglian Water Stage-3-Fine-
Screening-Appendix-F-Contaminated-Land-Appraisal).

Page 32 advises that the feasibility studies relating to relocation of the treatment works are now
complete and relocation off-site is the option moving forward. This would have to question the
depth and therefore integrity of the evaluation.

Attachments:

Object

Draft North East Cambridge Area Action Plan

Representation ID: 55471

Received: 27/09/2020

Respondent: Mr Matthew Asplin

Representation Summary:

Policy 25 outlines the concerns regarding environmental impacts such as noise, odour and other operational impacts and how these can be mitigated during development.

By discharging responsibility for relocation of the treatment plant to a commercial organisation for which cost will be a primary driver, it is likely that this will result in a revised location that will remain close to the existing waste water connections and just move these environmental impacts to a green belt location and alternative nearby communities on the city edge.

Furthermore, this is likely to then define the planning future for the preferred location. Again, this might be a 'means to an end' for the Draft Action Plan, but does not appear to be an integrated planning solution for the future.

Attachments:

Object

Draft North East Cambridge Area Action Plan

Representation ID: 55700

Received: 02/10/2020

Respondent: St John's College

Agent: Savills

Representation Summary:

The requirement to fully consider all environmental impacts to ensure that the future health, quality of life, amenity and the natural environment is supported.

Pre-application discussions with the Greater Cambridge Shared Planning Service to determine the individual submission requirements for impact assessments as stated should not be required. Guidance should clearly set this out.

There are concerns that the Cambridge City Council’s Technical note of the interpretation of Planning Applications in the vicinity of Cambridge Water Recycling Centre (October 2018) carried out by Odournet is not a robust evidence base on which to make decisions – see the Assessment of the impact of odour from Cambridge Water Recycling Centre on St John's Innovation Park Masterplan Phase 1 submitted as part of applications 20/03523/FUL and 20/03524/FUL.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Representation ID: 55751

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Representation Summary:

Neutral:
The Arup Odour Report concluded that overall the range of evidence available from
all the various reported modelling studies, as well as the Arup study, indicate that
odour levels on the proposed development site would be below the levels generally
considered to have a low risk of adverse odour impacts. The report was based on a
further, more detailed odour analysis of the potential for odours at the development
site at Cambridge North in response to the Odournet report. Anglian Water
collaborated with Arup in terms of inputting into the report and agreed with the
methodology adopted within the report.
The conclusions of the Arup Odour Report are as follows:
“A qualitative Source Pathway Receptor assessment concludes that the proposed
development site would have a Low to Moderate risk of adverse odour impacts.
This is because the development site is more than 400-800m from the more
odorous parts of CWRC meaning odours which allows for dispersion and hence
dilution of the odours released.
Overall the range of evidence available from all the various reported modelling
studies and this study indicate that odour levels on the proposed development site
would be below the levels generally considered to have a low risk of adverse odour
impacts. The only exception is the Odournet study which appears to have made
some very pessimistic assumptions and the results can only be replicated by nearly
doubling the measured odour emission rates on site.
The evidence from modelling studies is further supported by the evidence form the
Source, Pathway, Receptor qualitative approach and the sensory assessments.
Odour complaints are received at a frequency of once a year (and some are
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received in areas where all studies would suggest that there is a risk of adverse
odour impacts) and the evidence from sniff testing is consistent with the modelling
studies undertaken by Arup, Anglian Water and CERC”
A number of reports have been commissioned on the potential for odour in
connection with the CWRC, all of which have reached consistent findings as the
Arup Odour Report detailed above, with the exception of the Odournet Report
which has far higher readings.
The evidence from these reports collectively is clear and this allows the LPA to
confidently take informed decisions.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Representation ID: 55853

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

Representation Summary:

Policy 25 seeks to ensure that environmental impacts are considered for development at North East
Cambridge, and identifies criteria for development. As set out above, the existing waste recycling
transfer facility at the Veolia site off Cowley Road is expected to continue until a suitable and
viable alternative relocation site is identified. The operations associated with the waste
recycling transfer facility e.g. noise, odours and vehicle movements, could be incompatible with
new residential, commercial, town centre and community uses on neighbouring sites without
appropriate phasing and the effective relocation of Veolia’s operations. Therefore, the criteria in
Policy 25 relating to noise and air quality to be assessed as part of design and layout (criteria
c), new sensitive uses to be integrated with existing businesses (criteria d), and to avoid
unreasonable restrictions on existing business operations (criteria e) are supported.

Attachments:

Support

Draft North East Cambridge Area Action Plan

Representation ID: 55913

Received: 02/10/2020

Respondent: GCR Camprop Nine Ltd

Agent: Carter Jonas

Representation Summary:

Policy 25 seeks to ensure that environmental impacts are considered for development at North East
Cambridge, and identifies criteria for development. As set out in the Introduction, a number of
technical reports have been prepared in support of the current planning application for the
redevelopment of the site at 127-136 Cambridge Science Park. The assessments of the proposed
development demonstrate that there would be no significant adverse environmental impacts associated
with the redevelopment of the site. Therefore, the proposed redevelopment of the site would be consistent with Policy 25.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Representation ID: 55936

Received: 05/10/2020

Respondent: Ridgeons Timber & Builders Merchants and Turnstone Estates

Agent: Carter Jonas

Representation Summary:

Policy 25 seeks to ensure that environmental impacts are considered for development at North East Cambridge, and identifies criteria for development. The operations associated with a builders merchants could be incompatible with new residential uses on neighbouring sites. Therefore, the criteria in Policy 25 relating to noise and air quality to be assessed as part of
design and layout (criteria c), new sensitive uses to be integrated with existing businesses (criteria d), and to avoid unreasonable restrictions on existing business operations (criteria e) are supported.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Representation ID: 55959

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

We generally support this policy and its requirements to protect the natural environment.

Attachments:

Object

Draft North East Cambridge Area Action Plan

Representation ID: 56023

Received: 05/10/2020

Respondent: Endurance Estates

Agent: Barton Willmore

Representation Summary:

Draft Policy 25 requires development at NEC to fully consider environmental impacts to ensure that the future health, quality of life, amenity and the natural environment are fully considered. Policy Section (h) makes reference to a noise barrier along the A14, stating that it will be assessed and integrated into the overall masterplan.

Supporting text on the topic of noise acknowledges that:

“The A14 traffic noise has widespread prevalent adverse impacts across a
significant proportion of the Area Action Plan area. It is likely that a strategic site
environmental noise barrier close to the A14 will be the most effective option to
mitigate and reduce to a minimum adverse noise both internally and externally”.

In addition, a number of site-specific noise sources are identified including transport and industrial uses. As well as the WwTW, the Veolia Waste Transfer Station site lies in the heart of the NEC Action Area. This waste site is safeguarded in the adopted Minerals and Waste Local Plan. At the time of consultation, neither of the sites have a strategy for relocation off-site and represent major constraints to the proposed development.

Looking specifically at the issues of acoustics and vibration, the following conclusions can be drawn:

• The current proposals locate the most noise-sensitive uses, such as housing, on the east end of the site. The Land Use Plan (Figure 11) indicates that a high proportion of the proposed residential development will be sited close to the A14, although noise impacts from road and rail traffic will continue to be a long term issue in this area (as set out in the Noise Model and Mitigation Assessment, February 2020). By contrast, the Land Use Plan proposes the allocation of commercial and other less noise-sensitive uses further away. The proposed arrangement of land uses poses a significant challenge to design in terms of both façade requirements and ventilation / cooling.
• A better and more balanced design could be achieved through locating less noise sensitive uses along the perimeter of the site in taller buildings, which would in turn act as a screen to the lower residential buildings in the centre of the site, protecting them from the dominant noise sources. This would be beneficial for the ventilation and cooling strategies of the residential buildings, bringing them more in line with the Councils’ preferred natural ventilation approach. It would also provide quieter external amenity areas, promoting the wellbeing of the occupants.
• Vibration and structure-borne noise from trains to and from Cambridge North station and from the future CAM network does not seem to have been considered. Moving residential buildings away from these sources would prove successful in reducing the impact of vibration and structure-borne noise on the foundation design of the buildings.

The findings have an important bearing on the proposed layout of the NEC Area. There are fundamental implications for the Spatial Framework (Figure 10) and Land Use Plan (Figure 11), with a consequential effect on Draft Policy 1 and other elements of the Draft NECAAP. However, we consider that amenity issues such as noise and vibration are of utmost importance when planning and designing a high-quality new city district such as NEC.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Representation ID: 56160

Received: 05/10/2020

Respondent: U+I PLC.

Agent: We are Town

Representation Summary:

The policy refers to both ‘contaminated land’ and ‘land contamination’. It has been assumed that the latter term is
intended throughout rather than former which has a distinct and specific statutory significance for land designation under
EPA Part IIA.
g) It is unclear why these particular land uses are singled out - residential with private gardens are a more sensitive end
use (in respect to land contamination) and it would be a primary role of the Phase 2 and dependent assessments to
determine the suitability of any land for a particular end use.

Attachments: