Greater Cambridge Local Plan: Proposed Submission

To avoid uncertainty this policy should be clarified to include development which while not immediately along the river corridors is visible from them.

Target Policy/Section Policy BG/RC
Status: - Object - Not Sound . Justified and Consistent with National Policy but not Effective

Internal uncertainty within the Policy should be clarified. BG/RC 1 sets out requirements for ‘development along river corridors’. However the detail in the following subsections including the protection and enhancement of existing landscapes of river corridors, views to and from the river and enhanced access to, from and along river corridors for walking and cycling [BG/RC 1c, d and e] clearly applies to much wider areas than immediately along the river. ‘Along’ needs to be clarified

Target Policy/Section Policy S/CE/15 d; 16c; 17a iii
Status: Support. Sound – Effective, Justified and Consistent with National Policy
Development of Cambridge East will mean 8,000 new homes for which there will be a requirement to provide access to Open Green Space and connect to strategic green infrastructure beyond Cambridge East [15d], contribute to strategic scale green infrastructure associated with the Wicken Fen Vision [16c iii] and provide walking and wheeled connections linking to wider routes . S/CE 16c requires sensitive connection to Wicken Fen Vision.
This should include linking to the existing route used by walkers, cyclists and horse riders from the newly built footpath/cycleway exiting Marleigh on to High Ditch Road, connecting to the Wicken Fen Vision gateway at the east side of Honey Hill. Continuing from Honey Hill along Low Fen Drove Way and the Harcamlow Way to the River Cam corridor connects the Wicken Fen Vision gateway to the proposed Cam Valley Trail at Baits Bite Lock, enabling further connection to NEC and Waterbeach New Town while avoiding further pressure on the Quy Fen SSI. This is also in line with Policy BG/GI 4 (green infrastructure initiatives including the River Cam Corridor) and Policy BG/RC 1:
i: For the river Cam, supporting the delivery of a continuous Cam Valley Trail;
ii. Enhancing connections between the rivers and other green spaces.

Target Policy/Section Policy J/AL
Status: - Support. Sound – Effective, Justified and Consistent with National Policy

This policy protects the 94 hectares of land at Honey Hill, which is best and most versatile agricultural land, subject only to the unfunded DCO for the relocation of the CWWTP. As pressure for development of Greater Cambridge and risks to food security increase this policy needs to be robustly applied. This particularly applies to land on the edge of Cambridge such as Honey Hill which is of especial value as Green Belt.

This section should be amended to state that internal lighting should only operate within commercial buildings after dusk when activated by movement sensors.

Target Policy/Section Policy WS/HS Supporting Information para 6.83
Status: Object. Not Sound – not Effective.

Section 2 – the section does not prevent the unnecessary light pollution which is being caused by internal lighting in newly constructed commercial premises at NEC adjoining the River Cam corridor and affecting Green Belt land which at night should be dark areas, including Honey Hill.

Target Policy/Section: Policy S/AMC/NEC & Spatial Strategy for the Cambridge Urban Area (Paragraphs 2.56 to 2.59)
Status: Support – Sound (Justified / Consistent with National Policy)

While we object to some key aspects of the Spatial Strategy and Policy S/AMC/NEC we strongly support the designation of North East Cambridge as an Area of Major Change that retains the CWWTP in situ under Policy S/AMC/NEC [2.56]. This approach is justified and consistent with national policy, representing the most sustainable spatial choice for Greater Cambridge. Retaining the plant in situ avoids the “significant adverse effect” of generating 53,010 tonnes of construction carbon [ES Chapter 10] and protects 34 hectares of permanent Green Belt land (94.0 hectares within the total DCO Order Limits) at Honey Hill, which the DCO confirms would cause certain harm to openness.
Retaining the plant in situ acknowledges the Examining Authority's finding that there is no operational necessity for relocation. This policy shift aligns with NPPF Paragraph 152 regarding radical carbon reduction and NPPF Paragraph 147 by avoiding inappropriate Green Belt development when a sustainable, functional alternative exists on brownfield land.

Amend the Waterbeach New Town Infrastructure Strategy, Policy S/WNT, and the Detailed Water Cycle Study to remove the default requirement for a 5km pipeline transfer to Cambridge. The joint planning authorities must commission a fresh, independent, and comprehensive feasibility assessment of wastewater options for Waterbeach. This assessment must objectively evaluate the long-term carbon, capital, and operational costs of a local, low-carbon Water Recycling Centre (utilizing modern, space-efficient, and enclosed treatment technologies) versus the permanent 5km pumping-main strategy to the existing CWWTP, ensuring the most sustainable outcome is selected based on a complete technical fact-base rather than a default pumping main.

Status: Object – Unsound (Not Justified by Proportionate Evidence)
Target Policy/Section: Waterbeach New Town Infrastructure Strategy, the October 2025 Greater Cambridge Detailed Water Cycle Study, and the July 2026 Detailed Water Cycle Study Wastewater Addendum

The wastewater treatment strategy for Waterbeach New Town is unsound because it is unjustified by up-to-date, proportionate evidence, contravening Paragraph 31 of the National Planning Policy Framework (NPPF). The October 2025 Greater Cambridge Detailed Water Cycle Study (WCS) and the July 2026 Wastewater Addendum continue to default to a strategy where wastewater from 11,000 homes is pumped via a 5km pipeline to Cambridge, treating this pumping main as a predetermined necessity [2.5.2]. This strategy is justified in paragraphs 2.2.6 and 2.2.7 of Anglian Water Services' CWWTPR DCO Planning Statement [REP1-049] by claiming that Cambridgeshire County Council "made it clear" that a local Water Recycling Centre (WRC) was not feasible, and that the Environment Agency (EA) advised that pumping was the "only feasible and deliverable option" [2.2.6]. However, these assertions do not align with the actual regulatory and pre-application records.
The actual Cambridgeshire County Council pre-application response (PR/S/5113/19/CW, dated 5 September 2019) shows that officers did not reject a local WRC on absolute technical grounds. Instead, they stated that Anglian Water Services' submission was "lacking in detail," failed to demonstrate a "robust methodology" or a sequential test, and was therefore "unclear" if the site could be supported "upon the basis of the limited information provided" [PR/S/5113/19/CW, Page 7]. Furthermore, County Council and EA communications reveal that Anglian Water Services sought an inordinately large land take of 15 to 20 hectares for a modest 30,000 population equivalent (PE) facility, a footprint size that was considered unjustified and created an artificial barrier to a local, sustainable WRC [33, 1.4.8]. The EA explicitly clarified in February 2019 that while they welcomed the pipeline as a "fall-back" option, they did not hold the developer or Anglian Water Services to that option. Pumping was selected as a default simply because the relevant parties neglected to produce the robust sequential testing and detailed technical Environmental Impact Assessment (EIA) for the local plant.
This failure to progress a local solution directly contradicts the 2014 Denny St Francis (now Waterbeach New Town) Water Cycle Study (WCS). This was a comprehensive, 244-page multi-disciplinary study commissioned by RLW Estates Ltd and conducted by Mott MacDonald (subsequently also commissioned by Anglian Water Services to produce many of its own CWWTPR DCO technical assessments). Unanimously endorsed by South Cambridgeshire District Council, Cambridgeshire County Council, the Environment Agency (EA), and Anglian Water Services, this study concluded that a new local WRC was the "most sustainable option" because it would "negate the requirement of considerable carbon and pumping costs of a transfer to Cambridge WRC".
Under the current Proposed Submission Plan, in the absence of the CWWTP relocation following the withdrawal of the Housing Infrastructure Fund (HIF) grant, the chosen strategy is to pump Waterbeach wastewater permanently to the existing open-air CWWTP WRC [2.5.2]. The CWWTPR Examining Authority’s (ExA) Report (12 July 2024) recommended that the Secretary of State refuse development consent for the relocation project. While the Secretary of State subsequently approved the DCO based on a high probability of housing delivery, the subsequent withdrawal of the HIF grant means the "Very Special Circumstances" (VSC) that overrode the Green Belt harm have collapsed [181, 2.57]. It is therefore highly questionable to assume that a pipeline designed to serve an operationally unnecessary relocation, which was recommended for refusal by the independent planning inspectors, and which is now unfunded and highly unlikely to happen remains a valid or justified solution.
In its representations to the draft regulation 18 Local Plan, Anglian Water is understood to have raised concerns regarding the capacity of the existing open CWWTP, which questions further the logic of pumping waste 5km uphill to a plant that Anglian Water has said to be capacity limited. Multiple reference sites exist that demonstrate modern well screened treatment facilities, in close proximity to housing, that have either been purpose built or consolidated on a compact footprint, many of which, due to the requirement to be near to a water source, are purposely designed to operate in a flood zone.
While Anglian Water Services has statutory pipe-laying powers under the Water Industry Act 1991, these operational powers do not excuse the joint planning authorities from their statutory duties under the NPPF to ensure that strategic infrastructure is justified by a robust, completed, and transparent assessment of sustainable alternatives. Defaulting to a permanent long-distance pumping main imposes an ongoing, energy-intensive pumping burden and carbon cost that has never been transparently appraised against a modern, enclosed, local Water Recycling Centre, ensuring that a high-carbon pumping pipeline is not accepted as a default outcome without a complete, evidence-based assessment of alternatives.

Amend Policy S/WNT and Policy CC/IW to require a comprehensive, independent assessment of the long-term whole-life carbon and operational energy costs of the pipeline transfer strategy (including permanent pumping to the existing CWWTP) versus a local, low-carbon, modern, enclosed wastewater treatment facility. The policy must state that no final wastewater strategy for Waterbeach New Town will be approved unless it is demonstrated to be the most sustainable, lowest-carbon long-term option in accordance with the carbon reduction mandates of NPPF Paragraph 152 and MWLP Policy 1.

Status: Object – Unsound (Not Justified and Inconsistent with National Policy)
Target Policy/Section: Waterbeach New Town Infrastructure Strategy, the October 2025 Greater Cambridge Detailed Water Cycle Study, the July 2026 Wastewater Addendum, and the Policies Map
Main Response:
The wastewater treatment strategy for Waterbeach New Town is unsound because it is unjustified and inconsistent with national policy, contravening Paragraph 152 of the National Planning Policy Framework (NPPF) regarding reductions in greenhouse gas emissions and Policy 1 of the Cambridgeshire and Peterborough Minerals and Waste Local Plan (MWLP) 2021. Paragraph 2.2.7 of Anglian Water Services' CWWTPR DCO Planning Statement [REP1-049] asserts that the pipeline to Cambridge brings "operational efficiencies, capital cost efficiencies and carbon emissions reductions" compared to a local plant [2.2.7]. However, this claim directly conflicts with the 2014 Denny St Francis (now Waterbeach New Town) Water Cycle Study (WCS), a comprehensive 244-page report commissioned by RLW Estates Ltd and conducted by Mott MacDonald (subsequently commissioned by Anglian Water Services to produce many of its own CWWTPR DCO technical assessments). Unanimously endorsed by South Cambridgeshire District Council, Cambridgeshire County Council, the Environment Agency, and Anglian Water Services, this study concluded that a new local WRC was the "most sustainable option" because it would "negate the requirement of considerable carbon and pumping costs of a transfer to Cambridge WRC".
This pipeline strategy introduces a highly unsustainable, dual-track risk depending on the outcome of the CWWTP relocation:
1. If the relocation to Honey Hill proceeds: The made CWWTPR DCO confirms that the southern section of the Waterbeach pipeline (Work No. 36) is designed to be redundant and decommissioned as soon as the relocated plant is operational [7.4.8]. Proposing the construction of multi-million-pound "throwaway" infrastructure intended for immediate destruction represents an indefensible waste of embedded carbon, materials, and capital, violating MWLP Policy 1. This is particularly so given that it is highly unlikely that funding will ever be available for the relocation of the CWWTP so the housing will not be built which was the sole reason why the Secretary of State over-rode the recommendation of the CWWTPR Examining Authority’s recommendation to refuse development consent for the relocation project. So the entire justification for this redundant, carbon-intensive infrastructure remains fundamentally flawed.
2. If the relocation does not proceed: The pipeline remains a permanent, high-carbon, energy-intensive pumping main conveying wastewater 5km to the existing open-air CWWTP [2.5.2]. Pumping permanently over this distance represents an ongoing operational carbon and energy penalty that is not justified by the evidence.
While Anglian Water Services has statutory pipe-laying powers under the Water Industry Act 1991, these operational powers do not excuse the joint planning authorities from their planning duties under the NPPF to ensure that strategic infrastructure is justified by a robust, completed, and transparent assessment of sustainable alternatives. Defaulting to a pipeline without a complete, transparent assessment of the long-term whole-life carbon costs of permanent pumping to Cambridge versus a local, enclosed treatment facility fails to ensure a sustainable development strategy. To meet soundness and climate change obligations under NPPF Paragraph 152, the Local Plan must not accept this pipeline as a default outcome without a transparent, evidence-based appraisal of alternatives.

Greater Cambridge Green Belt Assessment Review 2026 (GCGBA 2026) needs to be corrected.
The Development Site boundary shown on Figure 4.10 of the GCGBA needs to show the correct CWWTP DCO Scheme Order Limits plan

Target Document: Greater Cambridge Green Belt Assessment Review 2026
Status: Object - Unsound as incorrect

We strongly support Policy S/GB which is Sound. However there is an error in its Supporting Document: Greater Cambridge Green Belt Assessment Review 2026 (GCGBA 2026) which needs to be corrected.
The DCO relating to the unfunded relocation of the CWWTP is correctly listed as a new extant permission. However the Development Site boundary shown on Figure 4.10 of the GCGBA does not match the DCO Scheme Order Limits plan which is 4.1 LOCATION AND SCHEME ORDER LIMITS PLAN REGULATION 5(2)(o)00001-100006-CAMEST-ZZZ-LAY-Z-9816 REVC02
(https://nsip-documents.planninginspectorate.gov.uk/published-documents/WW010003-001283-4.1%20Location%20and%20Scheme%20Order%20Limits%20Plan%20%E2%80%93%20change%20request.pdf)