Greater Cambridge Local Plan: Proposed Submission

We consider that SA objective 10: Water “To achieve sustainable water resource management and enhance the quality of Greater Cambridge’s waters” is not a sound objective, given the lack of evidence confirming that adequate water supplies can be found to “to serve new growth for the lifetime of the development in a changing climate without negatively impacting on the environment”.

In relation to the vital need to ensure a sustainable water supply for both the residents of Greater Cambridge and the nature, environment and agriculture that supports them, we consider that the Plan cannot be considered Sound, since SA Objective 10 in relation to the development proposed in the Plan, is neither
• Effective (i.e. deliverable over the plan period) nor
• Justified (i.e. an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence).

The Sustainability Assessment (SA), the Statement of Common Ground, the Plan itself, and the supporting evidence relating to water (the 2025 evidence report and the 2026 Addendum) provide numerous examples of the fact that, as the SA itself words it (Para 2.48) “… there are known challenges with water supply in terms of sustainable abstraction and also with water recycling capacity”. Throughout these documents there are continual references to the uncertainty of whether water supplies can be found to meet the proposed level of growth. Policy 28 of the Plan requires all new development to meet the minimum standards of water efficiency to address the severe water stress within the area and has set a target for water consumption of 110 litres per person per day, but there is no evidence to suggest that this will be feasible. The Plan may provide “the potential” to secure long term sustainable development but this will require that “all new development implement water efficiency standards, and that the phasing of new development is in line with any implementation timescales for any new strategic schemes that water companies might require”. Recent history suggests that such requirements are very difficult to meet, and no new evidence is provided that this will be possible.

Paragraph 4.93 states that solutions are being developed to enable developments to proceed if appropriately phased in line with the new water supply options, but it is unclear how this would be implemented, given the very slow progress being made to identify water supply options. Paragraph 4.95 similarly raised in its statement “If waste water treatment and water recycling infrastructure is not expanded or enhanced to deal with the increase in wastewater, there is the potential for significant effects in relation to water quality within waterbodies in Greater Cambridge, and in particular those designated as SACs, SPAs and Ramsar sites, as highlighted by the HRA Report for the GCLP (2026).“ The lack of clarity about the future of wastewater treatment raises a huge question mark over this section of the SA.

Paragraphs 5.34 and 5.46 further emphasise and explain why ‘Significant negative uncertain effects’ are expected for SA objective 10: Water, and we fully agree with this explanation which is based on good independent research. However, beyond reference to new water supply options being developed, there is nothing to suggest that there is clear road map for mitigating these ‘significant negative uncertain effects’. We could provide many other examples of where the documentation supporting the draft Local Plan, rather than providing good evidence, actually emphasises uncertainty.

Particular concern arises from the failure of the Water Scarcity Group to produce any reports or information on the research that they were charged to undertake to identify future solutions. These include mechanisms such as water efficiency appliances in buildings, agricultural reservoirs, water credits, and others. Without reports from the WSG, which was mandated explicitly with identifying solutions that could reduce the uncertainty, we can only conclude that this is indeed an intractable problem. Many of general policies on the environment and climate change are a major improvement on the previous Local Plan. However, the uncertainty about future water supplies means that the implementation process needs reviewing, given the proposed intensity of development in this water-starved area. Full transparency and independent review of the research undertaken to find solutions for water solutions is urgently needed.