Draft Greater Cambridge Local Plan for consultation

Amend Policy S/DS to acknowledge that S/NEC requires Green Belt release and apply the NPPF 148 sequential approach, including identification of Grey Belt land.

Policy S/DS – Development Strategy (Para 2.64, Green Belt approach)
Failure to Identify Grey Belt (Internal Policy Contradiction)

The plan is unsound as it is inconsistent with national policy (NPPF 36d) regarding the release of Green Belt land. The Draft Local Plan (Para 2.64) states the Councils do not need to identify Grey Belt land because they do not consider it necessary to release Green Belt to meet development needs, demonstrated by the exclusion of S/NEC from the housing trajectory. This is a direct contradiction of Policy S/NEC, which is "predicated on the relocation of the CWWTP". The made Development Consent Order (DCO) confirms this relocation requires a 34-hectare Green Belt land take. Under NPPF 148, when it is necessary to release Green Belt for development, plans must give priority to previously developed land and then consider the Grey Belt. By claiming "no Green Belt release" while promoting a strategy that mandates a 34-hectare take, the Councils are bypassing the mandatory prioritisation of Grey Belt land, violating NPPF Paragraph 148 and PPG Green Belt (Ref ID: 64-002-20250225).

Amend Policy S/NEC to demonstrate that it is the most sustainable option, explicitly addressing hydrological risks to Stow-cum-Quy Fen SSSI and reasonable alternatives.

Policy S/NEC (Sustainability and Environmental Impacts)
Hydrological Harm and Sustainability Objectives

The plan fails to reflect the environmental "costs" identified during the Development Consent Order (DCO) examination process, rendering it unjustified. The Examining Authority’s (ExA) Recommendation Report dated 12 July 2024 identified potential "significant adverse effects" on the Stow-cum-Quy Fen SSSI due to hydrological changes and recreational pressure enabled by the relocation. While the DCO includes a Water Quality Monitoring Plan, the Minerals and Waste Plan (Policy 1) requires developments to be guided by "sustainable solutions". If on-site consolidation (which avoids these hydrological risks to the Fen) is technically feasible as suggested by DCO Examination reference REP1-171, then the current relocation strategy is not the most sustainable spatial option and fails to comply with NPPF 11.

Remove references implying the relocation is “essential infrastructure” and reassess the Green Belt harm as enabling development for housing.

Policy S/NEC (Green Belt justification / infrastructure status)

The plan fails the consistency test (NPPF 36d) by incorrectly categorising the Cambridge Waste Water Treatment Plant (CWWTP) relocation as "essential infrastructure" to avoid standard Green Belt scrutiny. The Examining Authority’s (ExA) Recommendation Report dated 12 July 2024 explicitly states that the Proposed Development does not directly deliver housing. Both the ExA and the Secretary of State’s (SoS) Decision Letter of 8th April 2025, acknowledge the relocation is a "facilitating act" or "enabling development" rather than an operational necessity. Because the relocation is solely proposed to unlock the North East Cambridge (NEC) site for housing, the Local Plan must judge the Green Belt impact as it would any other housing-led development. This creates a direct conflict with Policy S/DS (Para 2.64), where the Councils state that development needs alone do not justify Green Belt release. The Councils cannot deflect the "very great negative weight" of Green Belt harm by pointing to a separate Development Consent Order (DCO) process when the SoS confirms that the DCO was only approved based on consequential housing benefits, which the Councils have now excluded from their housing trajectory due to funding uncertainty.

Amend Policy S/NEC to acknowledge the absence of presumption of need under Section 105 and require a fresh alternatives assessment before claiming exceptional circumstances

Policy S/NEC (Exceptional Circumstances justification)
Soundness – Absence of "Presumption of Need" and Discretionary Choice

Policy S/NEC is unjustified because the DCO process confirmed there is no operational justification or presumption of need for the relocation, the consent for which was determined under Section 105. This makes the move a discretionary local choice, not a mandate. Consequently, the Councils must meet the high evidentiary bar of NPPF 147 by examining all reasonable alternatives. Following the August 2025 HIF funding withdrawal, the previous dismissal of on-site consolidation is no longer valid, and a fresh feasibility study is required to prove relocation remains the most sustainable spatial option

Align Policy S/NEC with the Councils’ previous position to the SoS or explain how housing needs are met without NEC

Policy S/NEC – Conflict in Council Green Belt Justification to the SoS

The Council letters submitted to the Secretary of State (SoS) in February 2025 supporting the decision to relocate the Cambridge Waste Water Treatment Plant (CWWTP) appear to be in conflict with the current draft Greater Cambridge Local Plan (December 2025).
The 20th February 2025 letters presented the CWWTP relocation as the only viable way to meet housing needs without releasing land from the Green Belt. The Councils stated that if the relocation were not approved, they would "inevitably" need to allocate Edge of Cambridge Green Belt sites or new settlements.
The December 2025 Draft Local Plan creates a logical contradiction: it acknowledges that the relocation is now "uncertain" and has removed the Hartree homes from the trajectory, yet it continues to conclude that general development needs do not justify "exceptional circumstances" for Green Belt release. This conflicts with their previous testimony that the loss of these homes would mandate Green Belt intrusion. The possible use of Grey Belt land, rather than valuable Green Belt, has not yet been tested.

Amend Policy W/BE to reassess the wastewater strategy using proportionate evidence, including a local treatment option consistent with the 2014 WCS.

Soundness – Justification and Evidence Base (The Waterbeach Pipeline vs. 2014 WCS)
Detailed Submission:
The draft Local Plan is unsound as it fails the Justified test (NPPF 36b); it relies on a wastewater strategy for Waterbeach that is not supported by "proportionate evidence" as required by NPPF Paragraph 32. The Plan’s approach to Waterbeach growth is set out in the October 2025 Greater Cambridge Integrated Water Management Study - Detailed Water Cycle Study, published as part of the Draft Local Plan - Regulation 18 consultation (December 2025 - January 2026) through the implementation of the Waterbeach-to-Cambridge pipeline. Anglian Water’s (AW) Development Consent Order (DCO) Planning Statement (DCO Examination reference REP1-049) confirms there is “insufficient capacity within the current network” to accommodate the 11,000 homes planned for Waterbeach New Town without this connection.
However, the evidence base used to justify this high-carbon pipeline over more sustainable local alternatives is misleading. In paragraphs 2.2.6 and 2.2.7 of its DCO Planning Statement (REP1-049), AW claims that Cambridgeshire County Council (CCoC) "made it clear" that a local plant was not feasible and that the Environment Agency (EA) advised a pipeline was the "only feasible and deliverable option". This is directly contradicted by the actual regulatory records:
• CCC Pre-application Response (PR/S/5113/19/CW): CCoC did not reject a local plant on technical grounds; rather, they stated it was "unclear" if the site could be supported because the information submitted by the relevant parties was "lacking in detail" and failed to demonstrate a "robust methodology" or sequential test.
• Environment Agency Evidence: The EA explicitly stated in February 2019 that while they welcomed the pipeline as a "fall-back," the "EA does not hold the developer or AW to going with that option".
The technical assessments required to progress a local solution for waste water treatment, which the 2014 Water Cycle Study (WCS), supported by Anglian Water, the Environment Agency, South Cambridgeshire District Council and Cambridgeshire County Council as key stakeholders, endorsed as the "most sustainable option", remained unproduced in the five years following that study. While the developers (Urban & Civic and RLW) supported design work until 2019, the failure of the statutory undertaker and site promoters to provide regulators with a robust assessment of the local works has resulted in the selection of a 5km pumping main that incurs "considerable carbon and pumping costs" and includes a southern section (Work No. 36) designed to be "redundant" and decommissioned in short timescales.
A strategy that defaults to wasteful infrastructure because relevant parties neglected to produce the necessary evidence for a more sustainable alternative is not justified and fails the presumption in favour of sustainable development under NPPF Paragraph 11.

Amend Policy to reflect that the pipeline is discretionary, not required, and to test more sustainable local alternatives in line with NPPF 11.

Inconsistency in Infrastructure Need

he plan is inconsistent with national policy because it relies on a discretionary infrastructure choice rather than a demonstrated need. The Examining Authority (ExA) Report confirmed the DCO was determined under Section 105, meaning there is no presumption of need. The Applicant admitted there is no operational need to relocate the CWWTP or to pump Waterbeach waste water to Cambridge, as the existing Cambridge plant could be upgraded to handle growth. The 2014 Water Cycle Study (WCS) had already established that a local Water Recycling Centre (WRC) would provide "betterment" for the River Cam and the local community. By promoting a pipeline justified solely by "facilitating" a relocation that is now unfunded and uncertain, the Councils are endorsing a strategy that fails to meet the "Exceptional Circumstances" established by the Secretary of State’s Decision Letter and contrary to NPPF paragraph 11, as more sustainable alternatives (local treatment) exist.

Amend Policy to reflect that the pipeline is discretionary, not required, and to test more sustainable local alternatives in line with NPPF 11.

Soundness – Inconsistency in Infrastructure Need (Section 105)

The plan is inconsistent with national policy because it relies on a discretionary infrastructure choice rather than a demonstrated need. The Examining Authority (ExA) Report confirmed the DCO was determined under Section 105, meaning there is no presumption of need. The Applicant admitted there is no operational need to relocate the CWWTP or to pump Waterbeach waste water to Cambridge, as the existing Cambridge plant could be upgraded to handle growth. The 2014 Water Cycle Study (WCS) had already established that a local Water Recycling Centre (WRC) would provide "betterment" for the River Cam and the local community. By promoting a pipeline justified solely by "facilitating" a relocation that is now unfunded and uncertain, the Councils are endorsing a strategy that fails to meet the "Exceptional Circumstances" established by the Secretary of State’s Decision Letter and contrary to NPPF paragraph 11, as more sustainable alternatives (local treatment) exist

Amend Policy and associated maps to transparently identify redundancy, sustainability impacts and carbon costs of the Waterbeach pipeline.

Transparency and Map Inconsistencies (NPPF 23)

The Policies Map and associated infrastructure plans are unsound under NPPF Paragraph 23, which requires a "clear strategy" and transparent identification of land-use designations. The plan identifies the Waterbeach to Cambridge pipeline within its infrastructure documents but fails to acknowledge that the 2014 Water Cycle Study (WCS) found this specific infrastructure to be less sustainable than a local plant. Furthermore, the map suppresses the fact that the Waterbeach Pipeline South element (Work No. 36) becomes "redundant" and must be decommissioned once a new works is operational. Building multi-million-pound infrastructure that is intended to be redundant from the outset is the antithesis of the "Sustainable Development" objective in NPPF Paragraph 11 and Minerals and Waste Plan Policy 1.

Amend Policy S/NEC to clarify that odour contours are Consultation Areas (MWLP Policy 16), not exclusion zones, and require site-specific mitigation assessment.

Inconsistency in Odour Zone Interpretation ("Stay Out" Zone)

The plan fails the consistency test (NPPF 36d) because the Councils are treating the Waste Water Treatment Safeguarding Area as an "exclusion zone" or "stay out zone" rather than the "Consultation Area" (CA) defined in MWLP Policy 16. Policy 16 explicitly states that development within a CA will be permitted where it is demonstrated that the use will not result in unacceptable amenity issues or prejudice the operation of the plant. However, the technical note, dated 20th May 2021, published by Greater Cambridge Shared Planning (GCSP) overrides this by stating that new high-sensitivity receptors (residential) are "unlikely to be suitable even with mitigation" within the 3 unit (C98,ouE/m3) contour. This restrictive interpretation effectively blocks the redevelopment of 35 hectares of strategic brownfield land without the site-specific assessment of mitigation potential (such as enclosure) required by MWLP Policies 11 and 16 and CLP Policy 36 and contradicts the feasibilities studies mandated under Adopted Local Plan 2018 policy SS/4.