Draft Greater Cambridge Local Plan for consultation

•Please remove the embedded glossary/definition snippets from the final version; they interrupt sentences and cause confusion. They have not helped stakeholders in responding to the Consultation.

•There is very little evidence for the anticipation of 73,300 additional jobs in Great Cambridge between 2024 and 2045. More detail needs to be given on how this is likely to be achieved, i.e. does this rely on Central or Local Government investment or is it dependent on Greater Cambridge growing organically. There are barriers to both of these; Central government has not committed to extra funding for Cambridge and existing companies are drawing down planned expansion due to a number of factors including US tariffs, use of AI and increased employment costs, e.g. Global pharmaceutical companies moving their expansion to the US rather than in the UK.

•The plan to deliver around 13,464 homes by 2045 is ambitious. The difference between the number of homes planned in the 2018 adopted local plans and those of the current plan is about 10,000, and provides an unnecessarily large buffer.

•However, in identifying sites that would deliver these extra homes, the allocation for the regeneration of North East Cambridge (NEC) has been retained despite the lack of Central Government funding for the relocation of Cambridge Waste Water Treatment Plant.



•Allocations concentrate on large strategic sites (NEC, Cambridge East, Waterbeach, Cambourne and Grange Farm). Some smaller-scale proposals in HELAA/site-allocation have been assessed but rejected (or remain unallocated). Therefore, housing supply numbers needs clarity because of the divergence between ‘policy allocations’ vs. ‘promoted but not allocated’ sites. The Councils should not over-count speculative sites in supply forecasts. Equally they should not underestimate the importance of small sites and in-fills in their calculations; such sites would be in established areas and therefore offer a more “community” feel. .

•These calculations have been used in this Reg 18 draft plan; the councils should avoid adding large allocations to the Reg 19 version for submission in 2026 and should clarify and justify if/where this happens. This is necessary because of changes likely due to the tenuous proposals for NEC

•The allocations document(s) retain the allocation for the regeneration of North East Cambridge (NEC) — but explicitly note that “the Government … will not be funding the relocation of the Cambridge Waste Water Treatment Plant (CWWTP)”. Prediction of housing numbers in Greater Cambridge should not rely on the residential component of NEC unless the councils can specify how costs of more than £400 million can be met and who the funding partners might be. Inclusion of the housing allocation of NEC is confusing and responders reading only the summary in this draft may under- or over-estimate the scale of NEC development that the Local Plan is counting on for housing/employment supply. The final Local Plan should not include NEC development in its calculation of housing and employment supply.

•It is especially important that, if the housing component of NEC is taken out of the final calculations, any large-scale development proposals to make up the deficit should not be on Green Belt.

•The summary does not list specific technical/design requirements for NEC, e.g. trip budgets, low-speed primary streets <20 mph, car-free zones near hubs, integration with surrounding neighbourhoods, mitigation for A14 noise.

•Policy S/DS (p61/62) demonstrates that for the objectively assessed housing need of 48,195, there are already allocations of 51,328, representing 6.5% headroom, without allocations at North East Cambridge and only including very low contributions from the call for sites activity, the supply for which is extensive. This limits the justification for relocation of the CWWTW to the green belt, as recommended for Refusal by the Planning Inspector.

•Policy S/NEC does not guarantee delivery ― several critical dependencies and conditionalities are made explicit. The redevelopment is predicated on relocation of the current Cambridge Waste Water Treatment Plant (CWWTP). Without that, much of the housing potential (especially the 5,500 homes on the CWWTP site and 500 homes on the Cambridge business Park, Milton Road) is uncertain; the latter because the developers, Crown Estate, have now conceded that 70% of the Business Park is within the odour zone of the current WWTP. The policy states that the allocation is retained on the basis that “alternative funding may be found.” No examples are given of the source of this alternative funding or its timelines. The scale, type and amount of development must therefore remain subject to refined master-planning and further engagement with partners ahead of the “Proposed Submission” version of the Local Plan (expected 2026). However, no reliance should be placed on the council's ability to relocate the Cambridge Waste Water CWWTP and the residential component of Hartree and of Cambridge Business Park ,Milton Road should not be included in prediction of housing numbers.

•As Government funding, i.e. Housing Infrastructure funding has been withdrawn for the proposed CWWTP relocation, including development of the site in the draft local plan is disingenuous. There is no guarantee of further funding and there is no indication of a possible relocation site, given that the proposed relocation costs escalated from £227 million to more than £400 million.

•In their LIRs to CWWTPR Examining Authority and to Sec. of State DEFRA, CCC and SCDC explained that relocation of the CWWTP had deliberately not been included or relied on in the adopted 2018 Local Plan, because it wasn’t viable or deliverable in the absence of funding, and to include it and/or any development that depended upon it, therefore, would have been unsound: ‘a policy requiring its relocation would not have been sound’. The Councils then described the subsequent award of HIF funding as a game changer that would overcome the ‘viability constraint’. This game changer phrase was repeated by Steve Reed when he granted consent in April 2025. So, given that funding has now been withdrawn and no alternative has been found, the soundness and viability positions have therefore reverted to the same ones that were applied in 2018, and the draft Local Plan should not include any development that depends on relocation of the CWWTP, including those proposed for Cambridge Business Park, where a large number would be within the odour zone.

•Policy S/DS (p61/62) demonstrates that for the objectively assessed housing need of 48,195, there are already allocations of 51,328, representing 6.5% headroom, without allocations at North East Cambridge and only including very low contributions from the call for sites activity, the supply for which is extensive. This limits the justification for relocation of the CWWTW to the green belt, as recommended for Refusal by the Planning Inspector.

•The feasibility studies for NEC (then Cambridge Northern Fringe East) set out in para 3.34 of the Adopted South Cambridgeshire District Council 2018 local plan and 3.35 in the Cambridge City Council 2018 Local Plan, have never been properly completed and evidenced:
3.34 / 3.35: Exploration of the viability and feasibility of redevelopment of the Cambridge Water Recycling Centre within Cambridge City to provide a new treatment works facility either elsewhere or on the current site subject to its scale will be undertaken as part of the feasibility investigations in drawing up the AAP. If a reduced footprint were to be achieved on the current site this could release valuable land to enable a wider range of uses. Residential development could
be an option subject to appropriate ground conditions, contamination issues, amenity and air quality.

•In the light of the recommendation of refusal, the lack of funding and the lack of evidenced feasibility studies, the emerging Local Plan should retain the requirement for the feasibility studies mandated in the current adopted Local Plans but never completed.

•Policy S/DS, para 2.64 states 'we do not consider that our development needs alone provide the ‘exceptional circumstances’ required in national policy to justify removing land from the Green Belt'. Further para 2.66 states that the release of green belt land is limited to two sites but fails to clearly state the green belt take that would be required by the CWWTW relocation despite the allocation for NEC in the draft plan.

•The policy lists “safeguarded uses”, i.e. Waste Transfer Station, Railheads, Cowley Road Bus Depot, which must be maintained unless relocation is secured, and separately notes that relocation of the CWWTP is required to unlock the full development potential. The interplay of safeguarded uses and relocation requirements needs to be clarified on how safeguarded uses constrain deliverability or phasing.

•The policy reiterates uncertainty about delivering “a significant amount of housing within the plan period” given the funding decision. For the plan to be robust, the relationship between NEC delivery assumptions and the plan’s housing supply/trajectory should be transparent.

•In the housing trajectory / five-year supply it is unclear whether NEC’s full capacity is included in the plan period totals, and if not, how the plan compensates for that risk. If the NEC numbers are assumptions contingent on relocation funding this should be clarified. The planned housing total is 8,350 of which 5,500 units are planned for the CWWTP site. This is a significant number, which if the plant is not relocated, will impact the overall housing supply in the Local Plan. It should be removed from the Reg 19 version.

•The proposed relocation site was on Honey Hill, an area located between the villages of Fen Ditton and Horningsea. This area is agricultural land in Green Belt and is not included as an area for development in the Draft Local Plan and should continue to be protected. The draft Plan does not indicate where the CWWTP relocation site might be located should funding become available.

•There needs to be clarity on which uses must stay in place unless relocated and what that means for phasing and viability. There are contradictions between the ’safeguarded uses’ and the ‘relocation required to unlock potential’ sentences.

•More information should be given on what has changed since the NECAAP proposals, summarising what the NEC policy retains from the previously proposed Action Plan, e.g. the funding decision, and where new/updated requirements exist. This needs to be included if this policy remains in the final version of the local plan at submission.

•NEC envisages complex phasing over many years, with multiple landowners and uses to relocate or intensify. Without early delivery of key “unlocking” infrastructure (waste-waterworks relocation, noise barrier by A14, energy/water/transport upgrades), incremental development is likely two become piecemeal, fragmented or delayed — undermining the “comprehensive, coordinated, design-led” vision.

•NEC is expected to be largely low-car use, with walking / cycling / public transport prioritised. but the area is currently constrained: severance by major roads (A14), railway lines, legacy infrastructure, noise, barrier effects. Without substantial investment in public transport, active travel links, mobility hubs, and traffic mitigation, there is a significant risk of congestion, pollution, air-quality problems, or heavy car-use creeping back — undermining sustainability ambitions.

•The broader Local Plan acknowledges challenges: sustainable water supply (chalk aquifer issues), energy demand increases, biodiversity commitments, climate-adaptation. NEC would put heavy demands on water, energy, sewage.

•NEC would be set to deliver mid- to high-density development with taller buildings at certain locations. But in a historic and environmentally sensitive city like Cambridge, intensification risks conflict with objectives to protect heritage, landscape character, biodiversity, open space and “sense of place” — especially if densities, building heights, transport loads, population, and traffic grow faster or more intensively than planned. Although the plan tries to balance this (heritage, skyline, open space, green infrastructure, blue corridors) market pressures resulting in overdevelopment is likely.

•Waterbeach New Town (WNT) is an existing “new settlement” allocation carried over from the 2018 adopted Local Plan, now re-stated under the GCLP via the “existing new settlements” policy group. contributing up to ~11,000 dwellings.

•This “capacity” may overstate what can realistically be delivered by 2045, especially given the need for phased infrastructure (station relocation, access roads, utilities, community facilities) and the complexity of mixing uses, heritage, landscape, green infrastructure. If delivery lags, the overall housing target could be at risk.

•The policy relies on timely delivery of major enabling infrastructure: a relocated railway station, new access roads from A10, transport hub, improved public transport, sustainable drainage / green-blue network, plus community infrastructure (schools, health, leisure). The relocation of the railway station has already been delayed because of lack of funding by developers despite their commitment at Supplementary Planning Document stage. There appears to have been a lack of due diligence in calculating the cost of relocation and the developer’s ability to fund it. It should not be necessary for central government to meet the costs.

•The Local Plan should therefore include an update on which key targets have been met, their timelines and financial viability. There is a danger that residential development may outpace delivery of such infrastructure — which could lead to substandard living conditions (traffic, deprivation of services, congestion, overburdened utilities).

•While the policy requires “temporary facilities / meanwhile uses” during early phases to support new residents, that is a softer commitment and may not guarantee the same quality of service as a fully developed town

•The new town’s road access strategy relies heavily on the A10 (two access points: Northern and Southern). The Southern access junction must be configured to discourage rat-running through neighbouring villages e.g. via Horningsea — but that depends on detailed highway design, enforcement, and broader network upgrades.

•The traffic generated by up to 11,000 homes plus employment, retail and other activity will be substantial. If public transport improvements, active travel uptake, and multi-modal hub don’t deliver as planned, there is a real risk of increased private car usage — undermining the GCLP’s low-carbon transport ambitions. Impact on the existing road and rail network, particularly on the A10 / A14 junction, may be significant and requires careful mitigation; yet such improvements often run over a long timeframe.

•GCLP emphasises climate change, sustainable water supply, and water stress (notably for chalk aquifers and chalk-stream ecosystems) as a major concern. WNT’s 11,000 homes plus associated employment, retail, community demand will significantly increase water, sewage, energy, drainage needs, placing pressure on local water supply, ground water levels, wastewater treatment etc. Although WNT policy calls for green/blue infrastructure, sustainable drainage and retention of watercourses/woodlands/wetlands, the scale of development raises a risk that the environmental gains are eroded under cumulative demand.

•The policy seeks to respect heritage (e.g. Denny Abbey, old barracks features) and fen-edge landscape, maintain view corridors and rural-edge character. But accommodating up to 11,000 homes in a fen-edge / rural-edge context may pose tension: pressure for higher densities, more compact development, potentially reducing open spaces, eroding rural-edge character, increasing “urbanisation” spill-over. Without strict adherence to design controls and careful phasing, there is a risk that the “distinctive fen-edge identity” and the sense of settlement separation (with buffer “Strategic Enhancement Area”) could be gradually diminished, especially as further housing demand arises post-2045.

•The policy mandates long-term management plans for open spaces, community buildings, unadopted roads, parking enforcement etc. But long-term stewardship of large-scale new towns is challenging — historically many “new towns” suffer from fragmented governance, piecemeal development, inconsistent community identity, and long lags before social cohesion / services catch up.

•Following the withdrawal of Government funding for the relocation of the Cambridge Wastewater Treatment Works, fundamental questions remain about how wastewater treatment will now be provided for Waterbeach New Town - and whether it is still appropriate to progress a tunnel or pipeline from Waterbeach to Milton, via Honey Hill. A pipeline which requires pumping under the River Cam, travelling south for 2 miles and pumping back under the river to the Milton works.

•It appears that the Waterbeach pipeline proposal has never been robustly tested against alternative options, risking the selection of a less sustainable, higher-impact solution that would commit to pumping wastewater upstream well into the future, increasing upstream river loads for future flood events.

•Paragraphs 2.2.6/2.2.7 of The Planning Statement, (PINS reference AS-166) submitted by Anglian Water to the Planning Inspectorate within its DCO application refers, appears selective and excludes the full facts. It is notable that the DCO was recommended for refusal by the Planning Inspector.

• A local Waterbeach WRC has long been identified as the most sustainable / preferred option, including:
o 22/01/2014 - Anglian Water / Environment Agency Joint position Statement
o 2/12/2014 - Mott MacDonald Water Cycle Study prepared for RLW Estates (endorsed by Anglian Water, The Environment Agency, Cambridgeshire County Council, South Cambridgeshire District Council, Waterbeach Drainage Board).
o February 2017 – Peter Brett Associates – Flood Risk Assessment-Waterbeach Newtown

•Activities in support of the ‘then emerging Local Plan’ consultations Feb/Mar 2017, leading to the 2018 Adopted Local Plan and current Waterbeach Allocation:
o Feb 2017 - South Cambridgeshire District Council – SC6/SCDC, Examination into the Soundness of the South Cambridgeshire Local Plan, Matter SC6 – New Settlements (Formalises the 2014 Joint Position Statement and Water Cycle Study)
o Feb 2017 - South Cambridgeshire Local Plan Examination: Matter SC6A Appendices - Waterbeach New Town - RLW submission (including land allocations for WRC and 2014 Water Cycle Study at Appendix 12)
o Mar 2018 - Statement of common Ground RD/SCG/510 Between Urban and civic, RLW Estates Ltd and SCDC Main Matter SC6A Strategic Sites: Policy SS/5 Waterbeach (includes timeframe for the new Waterbeach WRC)
o Mar 2018 – Anglian Water Services Limited - Waterbeach Position statement, Issued in support of Local Plan review to clarify the position and respond to the Planning Inspectors questions.
o May 2018 - Waterbeach New Town East Outline Planning Application - Planning and Delivery Statement. Prepared by Boyer on behalf of RLW Estates – Includes the strategy agreed with Anglian Water for the Waterbeach WRC in line with the original 2014 Water Cycle Study (paras 7.120-7.122).

•Communications demonstrate the lack of progress made by Anglian Water with the agreed plan to relocate the Waterbeach WRC:
o The Environment Agency raised multiple comments against Planning Application S/059/17OL.
o The Pre-Application Response from Cambridgeshire County Council (PR/S/5113/19/CW, 5 September 2019) raised important questions regarding the assessment information provided by Anglian Water
o Both organisations questioned why Anglian Water required 15/20 Hectares for a new Waterbeach site, which significantly impacts the assessment
o The site comparison information does not appear to have been formally published by Anglian Water which would allow stakeholders to review same.

•The pipeline proposal emerged as a fallback, not a preferred strategy. Before committing to decades of energy-intensive upstream pumping, with its environmental impacts, a full and proper review of all viable options must be undertaken for the provision of wastewater treatment for Waterbeach and Waterbeach New Town including that of AW’s own successful practice at their Great Dunmow facility.

•The Greater Cambridge Integrated Water Management Study-Detailed Water Study - Stantec October 2025 (GCSP Local Plan Reg18 - Infrastructure Evidence base) addresses Waterbeach Water Recycling Centre (WRC) within para 4.12.32, including reference to the environmental drivers, but makes no reference to the earlier 2014 Water Cycle Study which defined the most sustainable approach to Waterbeach WRC.
o The Local Plan recommendations within the Stantec Executive Summary (p3) include offering betterment….by reducing flood risk downstream. This appears to conflict with a suggested Waterbeach pipeline that pumps waste upstream and then discharges to the River Cam, increasing downstream flood risk.

• The success of Waterbeach as a “real community” with its own identity, rather than a commuter dormitory or over-stretched suburb, depends heavily on consistent delivery of community infrastructure, civic facilities, green spaces, and effective governance — factors often vulnerable to market pressures or shifting priorities.

•There are multiple interdependent risks in this policy including airport operational constraints, transport/trip-budget enforceability, green-corridor boundary uncertainty, water/wastewater and fenland flood/drainage issues, phasing governance and heritage/aviation safeguarding and the actions taken to address these should be clarified.

•The Policy explicitly says parts of Cambridge East (Marleigh, Springstead) can proceed while the airport remains operational, but the full comprehensive development of the airport site is dependent on it becoming available for development. The policy retains the allocation for the whole area while accepting that some parts cannot be developed until the airport changes status. The LP still refers to Marshalls Aerospace relocating to Cranfield while this was reported as cancelled earlier in 2025. No other site for the relocation has been suggested.

•The Policy requires the eastern approach to be “sensitive to local townscape, landscape, strategic views, dynamic views and heritage assets, including the rural setting of the Teversham corridor.” But the policy then also allows masterplan-led change to the current Green Corridor (including potential development within it if “very special circumstances” and compensatory widening elsewhere are demonstrated). This ambiguity needs to be addressed.

•Without precise, binding tests for what constitutes “very special circumstances” and what compensatory measures are acceptable, there is scope for ad-hoc compromise that harms Teversham’s rural setting and strategic views. The Local Plan Summary emphasises protecting setting and landscape; the policy’s wording is therefore ambiguous and could be interpreted in ways that weaken protection.

•The policy introduces an indicative vehicular ‘trip budget’ and a “monitor and manage” approach to ensure sustainable transport outcomes. It states the budget will be refined as evidence progresses. However, “monitor and manage” requires considerable resources and a willingness by developers and councils to frequently and regularly examine data and adjust as necessary. There is a cost implication in this. The trip budget is crucial to preventing over-burdening of the network, but (a) an indicative budget is not the same as a binding limit; (b) monitoring/management without enforceable penalties or clear triggers is unlikely to prevent overshoot; (c) detailed modelling must capture cumulative effects (A14/A11/A1303/East West Rail interactions). The Draft Local Plan Summary requires developments to make active/public transport the natural choice — this will fail unless the trip budget is binding, transparent, and tied to meaningful triggers (e.g., occupation caps, contribution/stop-work triggers if targets are missed).

•The Policy keeps current Green Corridor boundaries for now, but allows future alteration after the masterplan / plan review and suggests compensatory widening where development is located in the corridor. This approach risks incremental erosion of protection. The Local Plan Summary strongly frames green infrastructure and protection of Cambridge setting as priorities; the policy’s “may amount to very special circumstances” language leaves room for inconsistent application and politicised trade-offs causing further erosion of the Green Belt. Decision-makers need clear tests for compensation (where, how measured, ecological value equivalent?) and a transparent process for any corridor change.

•Airport safeguarding (aviation safety, noise, heights) is not explicit enough. The policy’s current phrasing does not clearly set out how aerodrome safeguarding, Civil Aviation Authority (CAA) consultation, noise contours, and obstacle limitation surfaces will limit location/density/design. Without this clarity there is risk of speculative applications and later abortive redesign when aviation constraints are applied.

•The policy references landscape framework, country park linking to Wicken Fen Vision and future refinement — but large-scale development on fen-edge soils raises complex SUDs, biodiversity and water resource challenges.

•Marleigh and Springstead have permissions and are progressing; Policy S/CE includes them as early deliverable parts of the wider allocation. There is a danger of conflating consented capacity (deliverable) with policy capacity (contingent). The Local Plan Summary requires realistic housing supply accounting — the plan must make clear which dwellings are certain in the plan period and which are contingent on airport availability / infrastructure triggers. Ambiguity here risks overstating the plan’s five-year and plan-period supply.

•The final plan before submission should include a phase by phase deliverability table showing which homes are deliverable now/near term versus contingent, i.e. dependent on airport availability, major strategic infrastructure and other tests.

Amend or delete Policy S/NEC so it is no longer predicated on an unfunded and uncertain CWWTP relocation; alternatively defer the allocation until funding and delivery are secured.

Soundness – Effectiveness and Deliverability (Policy S/NEC)
Policy S/NEC fails the Effectiveness test (NPPF 36c). The policy is explicitly “predicated on the relocation of the CWWTP”. However, the Secretary of State’s (SoS) Decision Letter of 8th April 2025 confirms that the "Very Special Circumstances" justifying Green Belt harm were based on the "highly likely" delivery of thousands of homes enabled by £277m in Housing Infrastructure Fund (HIF) funding. Following the August 2025 withdrawal of this funding, the Councils admit there is “uncertainty as to whether the effective delivery... can be realised”. Since the SoS overruled the Inspector’s recommendation for refusal primarily because of these consequential housing benefits, the absence of funding removes the very basis of the project’s justification. A strategy relying on speculative, unfunded infrastructure is not "deliverable over the plan period" as required by NPPF Paragraph 36.

Amend Policy S/NEC and the Policies Map to explicitly identify and justify the 34ha Green Belt land take required for the CWWTP relocation.

Policy S/NEC (and associated Policies Map designation)
Policies Map Inconsistency and Transparency
The Policies Map is unsound because it is not justified or consistent with national policy (NPPF 23). The map identifies the S/NEC allocation but omits the Cambridge Waste Water Treatment Plant (CWWTP) relocation site, which the made Development Consent Order (DCO) confirms requires 34 hectares of Green Belt land. The Secretary of State’s (SoS) Decision Letter of 8th April 2025 and Examining Authority’s (ExA) Report dated 12 July 2024, both identify this relocation as “inappropriate development” causing “moderate harm” to Green Belt openness. By mapping the urban regeneration "benefits" while suppressing the confirmed infrastructure "cost" to the Green Belt, the map provides a misleading spatial vision. Under NPPF Paragraph 23, all land-use designations must be identified to provide a clear and transparent strategy.

Amend Policy S/DS to resolve the internal contradiction with Policy S/NEC by clarifying whether development needs can, in fact, justify Green Belt harm in this instance.

Policy S/DS – Development Strategy (Para 2.64)
Green Belt Policy Contradiction (Policy S/DS - The "Needs" Paradox)

The plan contains a fundamental internal contradiction, violating NPPF 36(d). Policy S/DS (Para 2.64) states that the Councils do not consider that development needs alone justify removing land from the Green Belt. However, the Anglian Water Planning Statement (Development Consent Order Examination reference REP1-049 and the Examining Authority’s (ExA) Report dated 12 July 2024 confirm there is no operational need for the relocation; it is proposed solely to enable housing. Therefore, the “Very Special Circumstances” (VSC) used to justify Green Belt harm are based entirely on meeting development needs—a justification the Councils explicitly reject elsewhere in the plan. This selective and inconsistent application of the NPPF 145 exceptional circumstances test renders the plan unsound.

Update Policy S/NEC and supporting text to reflect the changed planning balance following HIF withdrawal and remove reliance on speculative housing benefits.

Policy S/NEC (supporting text: delivery, funding and timing)
Shift in the Planning Balance (Policy S/NEC-Section 105 and Funding)

The Secretary of State’s (SoS) Decision Letter of 8th April 2025 confirms the Cambridge Waste Water Treatment Plant (CWWTP) relocation was determined under Section 105 of the Planning Act 2008, meaning there is no presumption of need ascribed by a National Policy Statement. The SoS overruled the Examining Authority’s recommendation for refusal by affording "very great positive weight" to the "highly likely" delivery of homes enabled by Housing Infrastructure Fund (HIF) funding. However, the Councils' own Topic Paper and Draft Plan now admit the delivery of these homes is "uncertain" following the August 2025 funding withdrawal, and they have consequently removed the Hartree component from the plan period trajectory. Consequently, the "Very Special Circumstances" (VSC) required by NPPF 147 have collapsed. Under NPPF Paragraph 11, plans must be sustainable. Currently, the harm to the Green Belt (confirmed as "moderate" and "inappropriate") is certain, but the benefits (housing) are now speculative and unfunded. The Local Plan cannot be considered "sound" or "effective" if it relies on a spatial strategy where the environmental "cost" is fixed but the enabling "benefit" has been deferred indefinitely.

Require a new, published feasibility study into on-site consolidation of the CWWTP before concluding relocation is necessary.

Policy S/NEC (Justification / Evidence Base)

Soundness – Justified Evidence Base (Policy S/NEC - Feasibility Studies)
Detailed Submission:
The plan fails the Justified test (NPPF 36b) as it lacks the “proportionate evidence” required by NPPF Paragraph 32. Policy SS/4 of the 2018 Adopted Local Plan mandated feasibility investigations into redevelopment “either elsewhere or on the current site”. The Examining Authority’s (ExA) Recommendation Report dated 12 July 2024 notes that a need for relocation was not demonstrated through the National Policy Statement for Waste Water (NPSWW) or adopted development plan policy. The Council’s “Chronology” is a retrospective summary and does not constitute the current, public investigation required to prove that on-site consolidation, which would spare the Green Belt, is unviable. In the absence of relocation funding, the failure to rigorously assess on-site consolidation as a “reasonable alternative” leaves the plan without a sound evidence base.

Replace reliance on outdated odour evidence with a feasibility assessment of a modern, enclosed facility in accordance with MWLP Policy 11(d).

Policy S/NEC (Justification / Evidence Base – Odour)
Soundness – Justified Evidence Base (Policy S/NEC - Feasibility and Odour)

The plan fails the Justified test (NPPF 36b) as it lacks the "proportionate evidence" required by NPPF 32. Policy SS/4 of the 2018 Adopted Plan mandated feasibility investigations into redevelopment "either elsewhere or on the current site". The Councils dismissed on-site consolidation using the October 2018 Odournet study, the December 2020 Olfasense Addendum Report and a Technical note, dated 20th May 2021, published by Greater Cambridge Shared Planning, which merely assessed the current open-tank plant. However, Policy 11(d) of the Minerals and Waste Local Plan 2021 specifically envisages the "enclosure of odorous processes" as a standard mitigation strategy. The report submitted as Development Consent Order (DCO) Examination reference REP1-171 highlighted that modern in-situ upgrades (e.g., Deephams and Riverside) have successfully consolidated footprints by a third and reduced odour by 99% while remaining operational. By failing to commission a feasibility study for a modernised, enclosed facility, the Councils have not "examined fully all other reasonable options" to spare the Green Belt as required by NPPF 147.