Sustainability Appraisal

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Comment

Draft North East Cambridge Area Action Plan

Representation ID: 52306

Received: 05/09/2020

Respondent: Mrs Catherine Martin

Representation Summary:

I think it is totally wrong to move the sewage works to a greenfield site in order to build ‘sustainable’ housing. This is simply wrecking a green belt/greenfield site & creating more carbon by the move & construction process. This is not sustainable. The Honey Hill site is particularly sensitive- proximity to an SSSI and a rare haven for wildlife. Wildlife is being pushed to the brink. This is so short sighted. Why can’t you upgrade the plant at the current site? In the light of COVID and more home working, do we really need more commercial premises?

Full text:

I think it is totally wrong to move the sewage works to a greenfield site in order to build ‘sustainable’ housing. This is simply wrecking a green belt/greenfield site & creating more carbon by the move & construction process. This is not sustainable. The Honey Hill site is particularly sensitive- proximity to an SSSI and a rare haven for wildlife. Wildlife is being pushed to the brink. This is so short sighted. Why can’t you upgrade the plant at the current site? In the light of COVID and more home working, do we really need more commercial premises?

Comment

Draft North East Cambridge Area Action Plan

Representation ID: 56009

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

Natural England welcomes the Sustainability Appraisal Final Report (July 2020) prepared by LUC.
This appears to generally accord with the requirements of the Planning and Compulsory Purchase Act
2004 and the Strategic Environmental Assessment (SEA) Regulations. The SA seeks to address the
effects of the AAP on key aspects of the natural environment including designated sites,
biodiversity, landscape, green infrastructure, water and air quality and climate change. The
assessment and recommendations / mitigation will need to be updated as the AAP policies evolve and
to take into account the findings and mitigation recommendations of the outstanding environmental
assessments and further revised HRA.

We agree that the NECAAP is likely to make substantial contribution to meeting the considerable
local housing and employment needs and the Plan has a strong focus on moving towards net zero
carbon emissions. Whilst the AAP is expected to result in overall significant positive effects
against the majority of SA objectives, negative effects are identified for air quality, pollution
greenhouse gas emissions due to increased energy and vehicle use to some extent, even if this is
substantially lower per person than the surrounding area. The SA highlights the risk of significant
negative effects on air quality particularly along the A14 Corridor, in combination with other
developments to the north and east of Cambridge, if the trip budgets which the AAP seeks to achieve
are exceeded in practice.

Natural England notes the potential for significant cumulative negative effects on protected
habitats and species based on the findings of the HRA, noting that these are uncertain pending the
requirement for further work to assess potential recreational pressure, air quality and
water-related impacts. The SA will need to be updated with the findings and recommendations of
these further assessments in due course. Mitigation measures will need to be detailed in the AAP
and their delivery secured through robust policies.

Whilst we generally support the findings of the SA our advice is that negative / uncertain effects
on protected habitats and species, including Milton Road Hedgerows City Wildlife Site and
Bramblefields LNR should not be deferred to the ‘detailed proposals’ stage. Any potential risks to
these sites, including indirect effects to any statutorily designated sites, should be assessed
through the SA and any adverse impacts appropriately mitigated, through Plan policies.

We note that the SA has omitted consideration of impacts to Chippenham Fen Ramsar site and to
the National Trust’s Wicken Fen Vision Area.

Attachments:

Object

Draft North East Cambridge Area Action Plan

Representation ID: 56012

Received: 05/10/2020

Respondent: Endurance Estates

Agent: Mr Andrew Winter

Representation Summary:

General comment on overall approach to SA and SEA in defining the project/implementation of the plan:

Chapter 4 of the Sustainability Appraisal (SA) considers the reasonable alternatives for the project and at paragraph 4.3 acknowledges that all options necessitate the relocation of the wastewater treatment works (WwTW) and the AAP has been prepared with the assumption that the WwTW will be relocated.

The Environmental (Assessment of Plans and Programmes) Regulations 2004 make clear that a Strategic Environmental Assessment (SEA) should identify, describe and evaluate the likely significant effects on the environment in respect of implementing the plan and all reasonable alternatives. The site of relocation for the WwTW is yet to be determined and the SA/SEA defers assessment of its environmental effects to the Development Consent Order (DCO) process. However, we would question the robustness of this approach given the relocation of the WwTW forms an intrinsic part of the current development proposals for North East Cambridge (NEC) and therefore implementing the plan in its current form. The Draft NECAAP cannot be implemented as currently proposed without the relocation of the WwTW and all options presented in the SA/SEA require its relocation; hence, the environmental effects of the relocation should be assessed.

There was previously a scenario which included an on-site ‘bio-bubble’ as part of the NEC development, as an alternative to finding an off-site relocation site for the WwTW. However, we cannot find any evidence of this scenario being assessed in the SA, or a clear rationale for why this option has now been discounted. We also note that Anglian Water is recently quoted as stating that the “relocation project is not an operational necessity” (https://www.cambridge-news.co.uk/news/cambridge-news/moving-sewage-plant-could-devastating-18842331). We are of the view that the on-site reconfiguration and upgrading of the WwTW is a reasonable alternative (on the basis that it is considered that this could attain the Councils’ policy objectives) which should therefore be assessed through the SA/SEA process and in any event rationale should be given for why this previously considered alternative has apparently been discounted.

The issue of the WwTW assessment was raised within the Environment Agency’s response to the consultation on the Interim SA for the NECAAP Issues and Options (2019), where it gave the following advice:

“This [the WwTW] is most likely to be the biggest direct and indirect water impact of all, and is a highly significant impact in any event, pre-mitigation. Our advice is very clearly that the impact of relocation is potentially highly significant, and that it falls to be appraised as an impact arising from the plan. It also features cumulative effects with other projects, such as Waterbeach New Town, The SEA/SA should address this.”

In response to this, the current draft SA/SEA says that relocation options will be considered through the DCO process and that the SA covers the context of the WwTW’s relocation and the mechanism by which the effects of the relocation will be assessed.

At the most basic level, Regulation 12 of the 2004 Regulations require the SEA to consider the likely significant effects on the environment resulting from the implementation of the plan or project. The implementation of the current draft NECAAP necessarily involves, at some stage, the relocation of the WwTW, as it actively plans to develop land on which it is currently located rather than considering any option to develop around a reconfigured WwTW site. We note a difference in approach to the relocation of the WwTW when compared with the off-site relocation of the Veolia Waste Transfer Station. At paragraph 4.334 of the SA it is stated that, as the relocation site is outside of the AAP boundary and no relation is known then uncertainty is added to the scoring in the assessment. We also question why the Councils have departed from the position that was taken in the November 2014 Interim Sustainability Appraisal report (paragraph 4.3.6, page 37), which stated that the impacts of the relocation on sustainability objectives were uncertain – as it would depend on the location and nature of the site, with potential indirect and cumulative effects needing to be considered in more detail, should the relocation of the WwTW be taken forward. All options now presented look to take the relocation option forward, but this work has not yet been undertaken.

Additionally, we would question why the SA/SEA does not commit to the provision of a new WwTW and provision for sufficient sewage treatment works and wastewater capacity to cope with the additional demand that will arise from implementation of the Plan. There appears to be no such commitment within the current version of the NECAAP, which suggests a key component of the programme has been deferred for consideration at a later date which could represent a legal deficiency. The HRA (paragraph 5.6) recommends that policy wording is strengthened to ensure the NECAAP commits to the provision of a new WRC and that there is provision for appropriate upgrades and improvements to cope with the additional demand that will arise from development from the plan. We cannot see how this is possible in light of the draft SA/SEA’s approach, which seeks to disengage itself from the relocated WwTW with continued reference to the DCO process. The DCO process will be subject to the EIA Regulations but this would not inform the AAP. The AAP should therefore be assessed under SA/SEA to include the relocation of the WwTW as an intrinsic part of the plan in order to be legally compliant.

Attachments:

Object

Draft North East Cambridge Area Action Plan

Representation ID: 56013

Received: 05/10/2020

Respondent: Endurance Estates

Agent: Mr Andrew Winter

Representation Summary:

General comment on overall approach to SA and SEA in defining the project/implementation of the plan:

Related to our comments on the SA/SEA process, we note that the Draft Habitats Regulation Assessment (HRA) does not consider the effects of relocating the WwTW as part of the same land use plan. This is confirmed at paragraph 4.7 of the HRA, which states that “[a]ny development resulting from the NECAAP would take place within the boundary of North East Cambridge”.

In addition, the HRA does not assess the relocation of the WwTW “in combination” with the NECAAP as an “other plan or project” (in accordance with guidance set out in the 2018 document, Managing Natura 2000 Sites).

We would also question the reliance that the HRA places on the HRAs that have been carried out for other local plans. This is for two reasons. Firstly, we are concerned that there is a significant disparity in terms of what was assessed in the local plan HRAs and what is now being proposed in the NECAAP; the relevant local plan policies did not include the quantum of development that is currently set out in the Draft NECAAP. Secondly, some of these other HRA documents referenced predate significant recent European Union case law on this subject (e.g. People Over Wind and Holohan). As a result, these documents may potentially not be compliant with up-to-date principles. At the very least, the NECAAP HRA should provide reasons as to why the assessments relied upon are considered to be robust.

We consider that the HRA for the NECAPP should consider the likely significant effects of the relocation of the WwTW, if it is not part of the Plan itself, then in combination as an “other plan or project”. The WwTW is a project that cannot be considered insignificant in scale, which is intrinsically linked with the proposed development of the NECAAP. The effects on European sites of the relocation of the WwTW need to be properly considered in combination with the NECAAP proposals.

Attachments: