Greater Cambridge Local Plan: Proposed Submission

Amend the Spatial Strategy for the Cambridge Urban Area (Paragraphs 2.56 to 2.59) and Policy S/AMC/NEC to remove all reference to the ’preferred vision’ and any strategic reliance, predication, and housing-capacity assumptions associated with the future relocation of the CWWTP. The Spatial Strategy should say clearly that it is ‘highly unlikely that funding will ever be available for relocation of the CWWTP’ and that if it ever is confirmed, the Council would need to review the NEC Policy and subject any changes to further consultation and, if necessary, to adopt an amendment to the Local Plan, after further Examination

Target Policy/Section: S/DS Policy S/AMC/NEC (North East Cambridge) & Supporting Information Spatial Strategy for the Cambridge Urban Area (Paragraphs 2.56 to 2.59)
Status: Object – Unsound (Ineffective)

Policy S/DS Policy (S/AMC/NEC and its Spatial Strategy for the Cambridge Urban Area) is unsound because it fails the Effectiveness test set out in the National Planning Policy Framework (NPPF) Paragraph 36(c) .
Policy S/AMC/NEC designates North East Cambridge (NEC) as an "Area of Major Change" with the existing CWWTP retained in situ and strengthens protections for the Cowley Road Industrial Area and Aggregates Sites. This effectively rules NEC out as ever being a strategic housing allocation. Further, viable commercial permissions have already been submitted or granted which are reducing the space for housing and supporting the pre-HIF grant vision of mixed employment-led development for this area.
However the Spatial Strategy for the Cambridge Urban Area (Paragraphs 2.56 to 2.59) is confusing and inconsistent with the Policy. The text continues to refer to the Councils’ ’preferred vision’ should funding become available for the relocation of the CWWTP. Reference to this ’preferred vision’ should be removed because:
a) It is misleading as there is no adopted ‘preferred vision’ .
b) Without sufficient funding the DCO for the relocation of the CWWTP could not have been granted. No current source of funding exists and no alternative source of funding is identified. The ‘preferred vision’ in the Spatial Strategy is therefore not deliverable and would be unsound.
c) Following the August 2025 withdrawal of the Housing Infrastructure Fund (HIF) grant, the housing trajectory has been revised, and NEC housing is no longer required to meet the district's housing needs. Mixed housing and commercial development can and is proceeding with the CWWTP in situ as set out in the Policy.
The project cost growth of the CWWTP relocation has increased enormously since the original business case was approved. The base costs of the relocation project have escalated significantly beyond the original "short tunnel" estimate of £167m, which including additional contingency formed the initial £227m Housing Infrastructure Grant that was used to justify the DCO application, as shown in the CWWTPR Funding Statement [REP6-002, 264]. In autumn 2025 the overall costs were estimated by the Councils in to be in excess of £400m and funding support up to £700m was requested. No new source of funding is identified to support the ‘preferred vision’.
The Councils' own December 2023 Local Impact Report (LIR) (Paragraph 6.104) submitted to the CWWTPR DCO Examination and to the Sec of State DEFRA stated that: “A plan that was dependent upon an allocation, which it was not possible to show is deliverable or alternatively sought to require the site occupant to leave, would ultimately not be found sound.” Furthermore, the LIR notes at Paragraph 6.26 that the CWWTP relocation was excluded from the adopted 2018 Local Plans precisely because it was not 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.”
While the Policy does not include development at NEC which depends on the relocation, the Spatial Strategy continues to refer to the speculative ‘preferred vision’, which is confusing, contradicts the Councils' own established soundness thresholds and fails the Effectiveness test (NPPF Paragraph 36c, 186). The Regulation 19 Plan put forward to the Sec of State for approval should not include speculative alternatives but should set out only the Councils’ plan which is deliverable over the Plan period.
The Spatial Strategy should say clearly that it is ‘highly unlikely that funding will ever be available for relocation of the CWWTP’ and that if it ever is confirmed, the Council would need to review the NEC Policy and subject any changes to further consultation and, if necessary, to adopt an amendment to the Local Plan, after further Examination.

Remove all reference in Policy S/AMC/NEC to the meaningless ‘preferred vision’ to relocate the CWWTP as there is no adopted ‘preferred vision’ and it is not viable or deliverable following the withdrawal of the Housing Infrastructure Funding grant. The Policies Map will then be consistent with the Spatial Strategy and compliant with the Councils' own Local Impact Report 2023 para 6.104 .

Target Policy/Section: Policies Map & Spatial Strategy for the Cambridge Urban Area (Paragraphs 2.56 to 2.59)
Status: Object – Unsound (Not Justified / Inconsistent with National Policy)

The Policies Map is unsound because it is unjustified and inconsistent with national policy, failing to comply with Paragraph 23 of the National Planning Policy Framework (NPPF). Despite the introduction of Policy S/AMC/NEC assuming an in-situ plant, the Spatial Strategy for the Cambridge Urban Area (Paragraphs 2.56 to 2.59) continues to refer to the "preferred vision" of relocating the CWWTP to Honey Hill in the Green Belt [2.58]. This is meaningless as there is no adopted ‘preferred vision’.
Further, while the Policies Map highlights the strategic redevelopment boundary and anticipated development "benefits" of the North East Cambridge regeneration, it entirely omits the corresponding physical and spatial "costs" of the infrastructure upon which this ‘vision’ is predicated.
The Cambridge Waste Water Treatment Plant Relocation (CWWTPR) Development Consent Order (DCO) would permit relocation of the CWWTP from NEC to Honey Hill requiring a permanent land take of 34 hectares for the operational facility within a total of 94.0 hectares of Green Belt land directly affected within the DCO Order Limits. Table 4.1 of the Greater Cambridge Green Belt Assessment (GCGBA) (July 2026), identifies Parcel OA2, including Honey Hill, as having a GCGBA and GCGBA 2026 Review harm rating, for release of this parcel from the Green Belt, of ‘Very High’. The CWWTPR Examining Authority’s (ExA) Report and the Secretary of State for Defra's DCO Decision Letter (6 June 2025) confirm that this project constitutes "inappropriate development" causing harm to Green Belt openness. NPPF Paragraph 23 requires all land-use designations and strategic infrastructure requirements to be illustrated on the policies map.
Suppressing the significant Green Belt land take required for the relocation while continuing to include the ‘preferred vision’ in the Spatial Strategy is inconsistent and makes the Policies Map misleading and non-compliant.

Amend Policy S/AMC/NEC to carry over formally the requirement of Adopted 2018 Policy SS/4 to commission and publish a fresh, independent, and comprehensive feasibility study. This study must model the physical consolidation of the CWWTP on its current site utilizing modern enclosure technology, advanced odour scrubbers, and space-efficient wastewater treatment processes, demonstrating achievable footprint reduction and odour reduction in order to maximise effective use of brownfield land released at the CWWTP site for housing and commercial use, while preserving Green Belt.
The policy should focus on a plan-led approach to the sustainable intensification of existing employment sites and explore the delivery of mixed-use development, including new housing opportunities enabled by modern in-situ odour mitigation and footprint consolidation of the CWWTP

Target Policy/Section: Policy S/AMC/NEC & Evidence Base (Odour and Feasibility)
Status: Object – Unsound (Not Justified by Proportionate Evidence)

Policy S/AMC/NEC is unsound because its restrictive approach to development on the North East Cambridge site is not justified by up-to-date, proportionate evidence, contravening National Planning Policy Framework (NPPF) Paragraph 31 and Paragraph 32. Adopted Policy SS/4 of the 2018 Local Plan required comprehensive feasibility investigations into redevelopment "either elsewhere or on the current site." Instead of conducting a genuine, transparent study into modern on-site consolidation and enclosure, the Councils have dismissed the potential for on-site footprint reduction and odour control, thereby severely limiting the prospect of delivering housing and commercial development closer to the existing facility. They have relied on the outdated 2018 Odournet study, which purely modelled the existing open-air configuration of the plant.
The Save Honey Hill (SHH) Community Group provided substantial evidence to the CWWTPR DCO Public Inquiry (within Representation REP1-171) demonstrating that modern, enclosed wastewater recycling facilities can successfully coexist with dense residential development. For example, the Thames Water upgrade of the Deephams Sewage Treatment Works (STW), a facility with a population equivalent four times larger than Cambridge, reduced its land footprint by one-third and eliminated 99% of odour while remaining fully operational on-site.
Furthermore, the existing CWWTP site layout contains extensive areas of redundant, disused plant, specifically disused Streams A and C (as identified in Odournet 2020 and site layouts). This demonstrates that substantial land-freeing footprint reductions can be achieved on the existing site. By failing to consider an improved, modern, enclosed, and space-efficient facility, and failing to carry over the feasibility requirements of Adopted Policy SS/4, the Councils lack the proportionate evidence required to justify these restrictive "stay out" zones. The Policy misses the opportunity to encourage consolidation and odour reduction so as to maximise the effective use of brownfield land for housing and commercial development.

Amend Policy S/AMC/NEC (Criterion 10 and Supporting Paragraph 10) to remove the presumption that residential use is "unsuitable" within the safeguarded Consultation Area. Replace this with a plan-led policy requirement that mandates the joint planning authorities and Anglian Water Services to deliver a coordinated, co-funded programme of odour reduction and selective enclosure at source at the existing CWWTP, ensuring compliance with MWLP Policy 16 and the core principles of NPPF Paragraph 193.

Target Policy/Section: Policy S/AMC/NEC (Criterion 10 and Supporting Paragraph 10) & Minerals and Waste Local Plan (MWLP) Policy 16
Status: Object – Unsound (Inconsistent with National Policy / Ineffective)

Policy S/AMC/NEC is unsound because its approach to odour management is internally inconsistent, ineffective, and conflicts with Policy 16 of the Cambridgeshire and Peterborough Minerals and Waste Local Plan (MWLP) 2021. Policy S/AMC/NEC (Criterion 10 and Supporting Paragraph 10) treats the existing Waste Water Treatment Safeguarding Area as a de facto "stay out zone" or "exclusion zone," stating that residential development is "unlikely to be suitable" within the 3 unit odour contour. This directly overrides MWLP Policy 16, which defines the safeguarded area as a "Consultation Area" where development will be permitted provided it is demonstrated that the proposed use will not result in unacceptable amenity issues.

Furthermore, the Plan is unclear as to the application of the "Agent of Change" principle (NPPF Paragraph 193) Supporting paragraph 10 requires individual, fragmented downstream residential developers to bear the sole burden of mitigating odour. Because South Cambridgeshire District Council, Cambridge City Council, and Anglian Water Services are joint landowners and coordinated promoters of this strategic site, the mitigation of odour must be addressed through a coordinated, plan-led framework. Expecting individual parcel developers to manage odour from a major open-air municipal plant is completely unviable. To comply with MWLP Policy 16 and NPPF Paragraph 193, the policy must mandate a plan-led, co-funded program to enclose and mitigate odour at source at the existing facility, unlocking 35 hectares of strategic brownfield land for housing.

Target Policy/Section: Policy I/SI (Safeguarding important infrastructure), Supporting Paragraph 10.59, and the Policies Map
Status: Support – Sound (Justified and Consistent with the Development Plan)

We strongly support Policy I/SI and the associated Policies Map as drafted because they correctly omit any infrastructure safeguarding or Consultation Area designations for the proposed Cambridge Waste Water Treatment Plant Relocation (CWWTPR) site at Honey Hill.
In its Regulation 18/19 representations, Anglian Water Services has requested that the joint planning authorities amend Policy I/SI to safeguard the Honey Hill site. We consider that the Councils' decision to refuse this request is entirely sound, justified, and consistent with the wider statutory development plan framework for the following reasons:
1. Absence of Operational Need: Infrastructure safeguarding under Policy I/SI is designed to protect essential infrastructure with a proven operational or national need. Both the Examining Authority’s Report and the Secretary of State’s CWWTPR DCO Decision Letter (6 June 2025) legally confirmed that there is no operational need or environmental requirement to relocate the existing plant; the relocation is a highly discretionary "facilitating act" to enable housing. Since the withdrawal of the Housing Infrastructure Fund (HIF) grant has made that housing delivery "uncertain" [2.57, 175], sterilising 94.0 hectares of Green Belt land within the DCO Order Limits through a speculative local safeguarding policy would be unjustified.
2. Redundancy and Existing Safeguarding: As explicitly identified in Supporting Paragraph 10.59, the Local Plan must be read in conjunction with the Cambridgeshire and Peterborough Minerals and Waste Local Plan (MWLP) 2021. Under MWLP Policy 16, the existing CWWTP is already fully safeguarded. Because the region's operational wastewater infrastructure capacity is already statutorily protected, safeguarding a second, duplicate 94.0-hectare site in the Green Belt for an unfunded, discretionary project is unnecessary and would introduce duplicate and conflicting safeguarding policies across the Development Plan.
The Councils should maintain Policy I/SI, Supporting Paragraph 10.59, and the Policies Map as proposed, and formally refuse Anglian Water Services' request to safeguard the CWWTP relocation site at Honey Hill. This will ensure the Plan remains internally consistent, avoids redundant double-safeguarding, and protects the Green Belt in accordance with NPPF Chapter 13.

Policy S/JH (supporting housing trajectory)
Status: Support – Sound (Effective / Justified)


We strongly support the housing trajectory evidenced in Policy S/JH and its supporting Development Strategy Topic Paper (2026), which demonstrates that Greater Cambridge’s housing needs can be fully met within the plan period with only 425 homes on the NEC site. The Plan identifies 6.5% housing supply headroom above the objectively assessed need and confirms there are no ‘exceptional circumstances’ for Green Belt release for housing anywhere around Cambridge, proving that the relocation of the CWWTP is not required as part of a sound Local Plan.

Maintain the existing restrictive policy approach to development in the countryside and Green Belt under Policy S/DS and Policy S/GB, ensuring any utility infrastructure proposal continues to meet the highest threshold of national policy tests .

Target Policy/Section: Policy S/DS (and Policy S/GB) & Response to Anglian Water
Status: Object – Unsound (Inconsistent with National Policy)

We object to Anglian Water’s request to amend the Plan to include a policy "positively supporting" the delivery of essential utilities infrastructure in the countryside/Green Belt. While the intention of the proposal may be for minor works, this could create a local presumption in favour of above ground infrastructure works in the Green Belt which would conflict with the strict “Very Special Circumstances” test required by NPPF Paragraph 147 and the requirement to demonstrate that no other suitable sites are available.
AW's suggestion that it is now facing capacity constraints cannot be used to weaken countryside protections.

Amend the Spatial Strategy for the Cambridge Urban Area, Policy S/AMC/NEC, and the supporting evidence base to resolve these transitional contradictions. The Councils must formally delete all fallback references to future relocation (including Paragraph 2.58 and Site Allocations Paragraph 2.10). The Sustainability Appraisal and Water Cycle Study Wastewater Addendum must be updated to remove all water quality, carbon, and spatial assumptions that depend on a relocated plant, establishing a true, independent "in-situ" baseline.

Target Policy/Section: Spatial Strategy for the Cambridge Urban Area (Paragraphs 2.56 to 2.59), Policy S/AMC/NEC, the July 2026 Sustainability Appraisal, the July 2026 Site Allocations Topic Paper, and the July 2026 Detailed Water Cycle Study Wastewater Addendum.
Status: Object – Unsound (Internally Inconsistent and Ineffective)

The Proposed Submission Local Plan is unsound because it contains residual policy and technical contradictions regarding the CWWTP left over from the transitional shift from a relocation-dependent strategy to the current "in-situ" baseline under Policy S/AMC/NEC. These are confusing. The Plan also refers to the "preferred vision" of future relocation which is incorrect and misleading – there is no adopted ‘preferred vision’. In the interests of arriving at a robust and consistent plan, these conflicting and misleading elements must be resolved to satisfy the Justified (NPPF 36b) and Effective (NPPF 36c) soundness tests.
While the Plan correctly adapts to the August 2025 Housing Infrastructure Fund withdrawal by assuming an in-situ CWWTP under Policy S/AMC/NEC, several key supporting documents and technical models continue to refer to the "preferred vision" of future relocation:
1. Policy Fallback (Para 2.58): The draft Plan text explicitly retains the relocation as an active strategic contingency, stating the Councils "would seek to deliver the previous preferred vision... should funding again become available" but without the necessary plan content addressing this contingency.
2. Site Allocations Topic Paper (Para 2.10): Paragraph 2.10 explicitly states that the Waste Water Safeguarding Area restrictions will remain "unless there is a significant change in circumstances around the funding prospects for the CWWTP relocation project." This treats the in-situ designation as a temporary placeholder rather than a permanent planning baseline.
3. Water Cycle Study Wastewater Addendum (July 2026): Section 5.8.1 continues to model the river water quality benefits of the relocated plant’s ultra-low phosphorous permit to justify the Plan's overall environmental performance. This prompted the Environment Agency in Comment EA5 to object, stating they were "unclear as to why the reference to the proposed new WWTW has been left in... given that the funding for the relocation has been withdrawn."
4. Sustainability Appraisal Option Structure (July 2026): This treats options assuming an in-situ plant (e.g., 9b and 10b) merely as "variants" of the default relocation options, carrying forward the Green Belt relocation as the preferred strategic benchmark.
The presence of this 'dual-track' confusion is openly conceded in Paragraph 2.58, which states that the Councils are deferring a 'refined position' to a 'later plan-making stage'. This is a procedural error. Under NPPF Paragraph 15, local plans must provide a clear, positive framework and certainty. Publishing a Proposed Submission Plan that contains residual, contradictory relocation assumptions, and admitting in the text that a cohesive strategy has not yet been refined, conflicts with the NPPF requirements. The joint planning authorities cannot defer soundness to a later stage; the Plan must be justified and effective now. In accordance with SCDC and CCC’s own December 2023 Local Impact Report (Paragraph 6.104), which warns that a plan dependent on an undeliverable allocation “would ultimately not be found sound,” the joint planning authorities must resolve these transitional conflicts to ensure a single, clear, and deliverable strategic pathway.

Retain Criterion 6(a) in Policy CC/IW as proposed, ensuring developers remain responsible for demonstrating that sufficient wastewater capacity exists before development is occupied, in accordance with the Effectiveness test (NPPF 36c) .

Target Policy/Section: Policy CC/IW (Criterion 6(a) / Supporting Text)
Status: Object/Comment – Unsound (Ineffective)

We object to Anglian Water’s Regulation 18/19 request to delete Criterion 6(a) of Policy CC/IW, which requires developers to demonstrate wastewater capacity prior to occupation. AW seeks to shift this responsibility entirely to its own statutory duties. This would reduce the transparency and effectiveness of the planning system.
Developers must remain responsible for demonstrating that their specific proposals—particularly large-scale sites like Waterbeach or NEC—will not result in environmental detriment due to capacity lags. The wastewater lifecycle planning for Waterbeach New Town, from the original 2014 Water Cycle Study to the current day WCS 2025 / WCS 2026 pipeline proposal, provides clear documentary evidence of what can happen when the process breaks down. Consequently, developers must remain responsible for proving that capacity exists before occupation in order to prevent major environmental or SSSI harm.
AW's suggestion, having asserted on an ongoing basis that it does not need to relocate for operational needs, that it is now facing “capacity constraints” that have been “exacerbated by the withdrawal of funding”, makes it even more critical that the Plan maintains the requirement for site-specific capacity evidence before development proceeds.

Target Policy/Section Policy S/GB – Support
Status: Sound – Effective, Justified and Consistent with National Policy

Policy S/GB reconfirms the protection for land in Cambridge’s Green Belt. The fundamental aim of national Green Belt policy is to prevent urban sprawl by keeping land permanently open [NPPF para 142]. As pressure for development of Greater Cambridge increases this policy needs to be robustly applied. This particularly applies to Green Belt land on the edge of Cambridge which would now prevent expansion.
The Cambridge Waste Water Treatment Plant Relocation (CWWTPR) Development Consent Order (DCO) would permit relocation of the CWWTP from NEC to Honey Hill requiring a permanent land take of 34 hectares for the operational facility within a total of 94.0 hectares of Green Belt land directly affected within the DCO Order Limits. Table 4.1 of the Greater Cambridge Green Belt Assessment (GCGBA) (July 2026), identifies Parcel OA2, including Honey Hill, as having a GCGBA and GCGBA 2026 Review harm rating, for release of this parcel from the Green Belt, of ‘Very High’. The CWWTPR Examining Authority’s (ExA) Report and the Secretary of State for Defra's DCO Decision Letter (6 June 2025) confirm that this project constitutes "inappropriate development" causing harm to Green Belt openness. The DCO exists but the CWWTP relocation is unfunded and therefore unviable, and its rationale is now superseded as the NEC area is being developed with mixed housing and commercial development with the existing CWWTP in situ. The area within Parcel OA2, including the 94 hectares at Honey Hill within the DCO Order Limits, as assessed by the GCGBA 2026 strongly contributes to NPPG purpose d and is therefore outside the definition of Grey Belt. Outwith the existing DCO permission this Policy protects the Green Belt land at Honey Hill from inappropriate development.