Greater Cambridge Local Plan Preferred Options

Agree with this Policy. It is of particular relevance to the proposed NECAAP proposals (Policy S/NEC) in the areas of highest density, i.e. 300/ha in the central areas, where appropriate SUDS will be needed and the large hard surface areas need to be permeable.
Regarding stormwater management parliament recently put a duty of Sewage Companies to reduce the storm overflows. Major developments, including their highways, should have dedicated separate road, roof and land drains run through balancing /attenuation ponds SUDS methods. as some recent new developments have not been affected by the recent stricture, CWWTP will need to build bigger storage and design it for future more intense rainfall. The stormwater in storage should then be fed back through the works after the storm has finished.

Agree in principle. Suggest that Section 4vii needs to be expanded to include that not only visual impacts must be mitigated but also auditory, especially for wind energy.

Agree in principle. Should include how the removal and transport of materials from demolition and remediation works should be included in the CEMP to reduce the impact of carbon footprint of HCVs.

Agree in principle. This policy protects existing carbon sinks from development and is in line with Policy GP/GB Protection and Enhancement of the Cambridge Green Belt. Because of these two policies it is inappropriate that the development on an existing carbon sink, i.e. the proposed CWWTP relocation on Green Belt at Honey Hill, has not been included in Policy S/EOC: Other existing allocations on the edge of Cambridge.
Note: Fulfilment of S/NEC Policy is contrary to this: decommissioning a fully operational and future proofed CWWTP and relocating to prime agricultural land.

Figure 54 shows a map of proposed strategic green infrastructure initiatives. Area 4 is described as Enhancement of the eastern fens. This appears to contradict the proposed CWWTP relocation to part of that area. The policy needs clarification as it requires all new development to help deliver or contribute to support delivery of the green infrastructure strategic initiative objectives. Just putting a development on an area of green belt contradicts this principle.

Aree with this policy in principle. However, the achievement of Policy S/NEC: North East Cambridge, appears to contradict this policy as the development on Cambridge North East Area is predicated on the relocation of the Cambridge Waste Water Treatment Plant to an area of Green Belt.
Note: Fulfilment of S/NEC Policy through relocation of CWWTP to the Green Belt is contrary to this Policy

The inclusion of North East Cambridge area Action Plan (NECAAP) in the Local Plan and the recent announcement of its Regulation 19 Proposed Submission appears premature (S. Kelly report to JLPAG). The AAP is predicated on the proposed relocation of Cambridge Waste Water Treatment Plant (CWWTPR), for which the Development Consent Order (DCO) process is still in the pre-application stage. Given that the CWWTP DCO application is unlikely to be submitted until late 2022 or early 2023, the proposed Regulation 19 submission of the Area Action Plan and its inclusion here in the Local Plan is premature. Resources are being used inappropriately and prematurely when the consultation on CWWTPR is not scheduled until February 2022 and the councils are deferring any formal public consultation on NECAAP until after the DCO.

The single driver behind Anglian Water (AW) pursuing a relocation of the CWWTP is the request from the joint Councils for AW to test a viable alternative site to fulfil the Councils’ vision for North East Cambridge as represented  in the area action plan NECAAP, adopted by Council into the emerging Greater Cambridge Local Plan First Proposals Policy S/NEC . Both plans have been developed with the assumption CWWTP will relocate, but neither are dependent on it (S Kelly Nov 2021).  Despite this, neither the SA nor SEA in either plan identify or assess the significant effects the relocation will have on the site identified by AW as a ‘viable’ alternative within the Greater Cambridge area.  

The existing CWWTP underwent extensive investment in 2016, at the time it was described by the Environment Journal (2016) as being  future proofed for decades to come and to have secured its position as the eastern region’s green energy generating giant; it has capacity to absorb the  housing targets of both the existing and emerging Local Plan including Waterbeach Newtown.  This fact, that there is no operational need for CWWTP to relocate even with the ambitious housing targets of these Local Plans, has meant AW are dependent on external funding,  in this case £227m of public money via HIFF.  Joint Councils supported the HIFF application and thus the principle of relocation of the CWWTP to enable the fulfilment of the vision for NECAAP, however this was before AW undertook identifying and concluded on a ‘viable’ site selection.

The site identified by AW is an area subject to the emerging Local Plan in the Cambridge Green Belt;  identified in the supporting Green Belt Study (2021) as an area of high sensitivity where development would have ‘very high harm’ to Green Belt purpose.  This ‘very high harm’ is attributed to the area not least because of the openness of the Green Belt but also the contribution three adjacent Conservation Areas, historical assets and medieval villages within them make to the Historical Setting of Cambridge. Significant Green Infrastructure also identified in the emerging Local Plan will be impacted by the relocation including: the River Cam Corridor; SSSI sites;  registered Historical House and Gardens; extensive PRoW network ; National Trust Wicken Fen Vision.

Since the site selection for relocation by AW there has been no public consultation on the consequences or environmental effects of the Councils pursuing NECAAP /S/NEC  in the context of the relocation to Honey Hill, nor has any alternative vision for NECAAP been presented in the emerging Local Plan First Proposals. This is despite it being clear the relocation as proposed will be contrary to numerous Policies laid out in the emerging Local Plan First Proposals and in the case of densification the CPIER report (2018), which informs the high growth objectives of the emerging Local Plan, stating that to sustain high economic growth, development needs to be sensitive to maintaining one of the key attractions to Cambridge, that is the pleasant environment. The latter not only being the Historic City Centre but its setting including the historic Green Belt (the first nationally to be established) and the necklace of villages within it.

The assessment of the effects of NECAAP/S/NEC Policy have been deferred to AW and the DCO planning process with the assertion that as the relocation is a separate planning process   ‘it is therefore not a project or proposal within the scope of the emerging Greater Cambridge Local Plan or AAP to influence.’  (S Kelly Nov 2021). This position seems quite extraordinary ; including NECAAP/S/NEC in the Local Plan First Proposals but excluding sufficient or significant information about the effects of the fulfilment of the Policy for effective public consultation at Reg 18 in itself is contrary to the principals and regulations of the SA/SEA, will influence the Consultation and could be construed as effecting bias. This anomaly is further exacerbated given that neither the emerging Local Plan nor NECAAP are dependent on the relocation (S Kelly Nov 2021).

If it is regulatory to exclude reference / identification of the site selected for relocation or subjecting the full effect of NECAAP to the SA/SEA within the emerging Local Plan, it is recommended in the interest of an informed and fair public consultation NECAAP is excluded from the Local Plan until after the outcome of the DCO is known and that an alternative is presented in the emerging Local Plan that can be subject to SA/SEA and an informed, evidence based public consultation at Reg 18.


Refs:
S Kelly Nov 2021 : NECAAP : Proposed Submission (Reg 19) Report to Joint Local Planning Advisory Group
Environmental Journal July 2026 : https://environmentjournal.online/articles/cambridges-water-recycling-centre-looks-future/

Visions and Aims
Fully support vision and aims. However, under Infrastructure there should be emphasis on serving the existing community as clearly there are established deficits , for example new sustainable transport systems to assist known  commuters, not purely for future growth eg ‘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 both our existing and growing communities. ‘

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.

The development strategy of Densification is not supported. This strategy puts the Aims & Objectives of the Local Plan at risk. : ‘Wellbeing & Social inclusion’ and ‘Great Places’ are of particular relevance here for both existing and growth populations here. As stated in the CPIER report (2018) if Cambridge does not remain an attractive place to live , the high levels of economic growth aspired to may fail.

A greater focus on bringing sustainable transport initiatives to the fore from outside the Greater Cambridge Area within the plan period, for example in addition to East West rail, improved rail links eg Newmarket /Ipswich line are recommended and good services to the Market Towns in the Region. The latter will assist both existing employees/commuters and new, reducing CO2 emissions (key aim of densification strategy) .  Increase in home working  will benefit local communities (levelling out) far from ‘dormitory towns’, with good transport networks for the odd commute day and more affordable housing, the wider region could benefit from Cambridge’s economic growth with working populations employed in Greater Cambridge but in the main remaining ‘local’.

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, a 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 and seeking family accommodation.

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 of existing homes 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. 

The housing development at North East Cambridge is not supported, a focus on employment growth in the area, services to support commuters and improved sustainable public transport from within Cambridge City, Greater Cambridge and the wider region to bring employees in is recommended as an alternative.

Pursuing housing development at North East Cambridge as a result of the relocation site selected by Anglian Water in the Green Belt and within close proximity to Conservation Areas etc. is contrary to Policies: listed under ‘Bio-diversity & Green Spaces’; Great Places to Live’; Wellbeing & Inclusion.’ And is a high risk strategy. See comments under S/NEC.

The case has been made for an alternative Minimum or Medium Growth Option in section S/JH. If adopted it is recommended the additional homes (Min 3000; Medium 8,000) required in the Plan Period could be ·         accommodated by Cambridge Airport with forward planning and mixed development to assist build out rates (4000) and the Bio-Medical Campus (up to 4000) without the need for housing at North East Cambridge. In addition,  areas identified for Major change within the City boundary S/AMC may also bring opportunities for housing within  the plan period and beyond assisting with requirements of a 5 year land supply.  Cambridge airport with an allocation of 7000 to full build out will also be able to offer homes beyond the plan period. The Bio-Medical Campus has been identified for growth but has not had housing no’s. allocated ; housing development  could be achieved here within the plan period with a mixed development and forward planning(S/CBC).