Greater Cambridge Local Plan: Proposed Submission

Anglian Water is committed to enabling sustainable growth and continues to collaborate with Greater Cambridge Shared Planning Service, Government departments, and external stakeholders to find solutions to infrastructure capacity challenges. We are working to secure policy and regulatory change that allows water companies to better support growth, for example by allowing us to invest strategically to create new capacity ahead of growth materialising, and by changing charging rules to allow for developer contributions to new infrastructure. This is set out in Anglian Water’s ‘Blueprint for Growth’ on the nature of the growth challenge and offers a strategy for unlocking this at priority sites in the short to medium-term, alongside longer-term change.
Anglian Water has previously provided confirmation to Local Planning Authorities that following last year’s announcement that the Cambridge Waste Water Treatment Plan Relocation (CWWTPR) project would be paused, following the withdrawal of Housing Infrastructure Funding. Anglian Water is committed to supporting growth in Cambridge, which required backing a single solution that enables the rapid creation of additional capacity for growth. Anglian Water therefore confirmed it will not be progressing with the CWWTPR, and instead will focus on upgrading the existing site at Cambridge water recycling centre (WRC). Whilst Anglian Water has taken this decision, it remains the case that the DCO provides a five-year implementation period from the date the Order came into force on 23 April 2025.
Anglian Water continues to work closely with Defra’s Ministerial Water Delivery Taskforce, the Cambridge Water Scarcity Group, regulators and other stakeholders to resolve ongoing challenges around growth in our region recognising that Greater Cambridge is one of the areas of strategic national importance to the government's growth agenda. This includes working to bring forward a phased strategy to address dry weather flow capacity at the existing Cambridge WRC, so it has sufficient capacity to enable the delivery of current and future growth.
The Proposed Submission Plan Draft Statement of Common Ground Appendix 1: Sup SoCG (v): Delivery of growth - wastewater treatment, sets out the regular engagement between the key stakeholders and the actions being implemented/delivered, including reference to our approach to strategic sites (500+ homes) set out in our Strategic Sites Guidance Note and referenced in the letter from Minister Emma Hardy MP to Local Planning Authorities on 22nd May 2026. This provides confidence that wastewater capacity for growth in the emerging Plan can be accommodated if investment aligns with proposed growth.
The Competition and Markets Authority response provides some initial development funding to continue design of Phase 2 works at Cambridge WRC, and a mechanism to fund works at Cambridge WRC through Ofwat’s large scheme gated process and cost change process.
The Proposed Submission Plan Draft Statement of Common Ground Appendix 1: Appendix 1: Sup SoCG (iv): Delivery of growth – Water Supply also identifies agreement between the parties on coordination of water supply issues. Anglian Water is working with Cambridge Water to deliver a strategic pipeline between Grafham Reservoir and Cambridge to bring water into supply from 2032, and the Fens Reservoir, which will further increase supplies from 2036 (at the earliest).

As set out in our response to Policy S/JH: New jobs and homes, we consider the strategy is sound and will continue to work with key stakeholders to align infrastructure delivery with planned growth in the Greater Cambridge area, where a greater focus for growth is in new settlements. There are identified pathways to investing in growth at key water recycling centres to support already committed sites and new site allocations in the Local Plan, including Cambridge WRC and Uttons Drove WRC. This is set out in the Detailed Water Cycle Study Wastewater Addendum and the Proposed Submission Plan Draft Statement of Common Ground Appendix 1: Sup SoCG (v): Delivery of growth - wastewater treatment. Any further updates will be shared with the Greater Cambridge Shared Planning Service, at the point the SoCG is updated.
As outlined in the draft SoCG, Anglian Water is currently preparing the next iterations of our Drainage and Wastewater Management Plan (DWMP28) and Water Resources Management Plan (WRMP29) which will address the 25-year period 2030-2055, going beyond the local plan period to 2045. Throughout this process we will be engaging with local planning authorities to update and seek views on these plans and the growth scenario best aligned to our region. 
The DWMP will inform our investments in the next Business Plan (Price Review 2029 – PR29) for the Asset Management Period 2030-2035 (AMP9). The next DWMP must set out how we will manage and develop our drainage and sewerage systems to meet our obligations under Water Industry Act 1991. As with the WRMP, this includes understanding how to deal with challenges such as asset health, climate change and population growth. Using this information, we will conduct a risk assessment for three different timescales: the short- (5yr), medium- (15yr) and long-(25yr +) term. The outputs from these will allow us to develop ‘best value’ investment solutions to meet our obligations. Funding for these investments is dependent on Ofwat’s confirmation through our Business Plan submission.
It is noted that clause 2.a.i of the policy references North East Cambridge as a special policy area to enable the redevelopment and intensification of the area to “contribute to meeting Cambridge’s needs for office, research & development, and industrial uses, as well as new homes in appropriate parts of the site (including approximately 520 homes within the plan period) recognising that Cambridge Waste Water Treatment Plant is likely to remain on site”. Anglian Water is supportive of this approach which reflects our plans to focus investment at our existing Cambridge (Milton) WRC. Specific comments will be provided in response to Policy S/AMC/NEC North East Cambridge Area of Major Change.
For consistency and clarity in the Local Plan policy and supporting text, it might be easier to refer to the Cambridge Waste Water Treatment Plant Relocation DCO at Honey Hill as CWWTPR and the existing site at Milton, the Cambridge WRC or Cambridge (Milton) WRC.

Amend clause 13:
In very exceptional circumstances a slightly larger development (not more than about 8 dwellings) may be permitted where this would lead to the sustainable recycling of a brownfield site bringing positive overall benefit to the settlement, provided that adequate infrastructure is available or can be made available as a result of the development.

Anglian Water is generally supportive of the approach set out in the policy, and the provisions setting out the parameters for growth in each settlement category. It is noted that for Cambridge, Towns and Rural Centres the policy is clear that development should come forward (without any limit imposed) "provided that adequate services, facilities, and infrastructure are available or can be made available as a result of the development". However, this same requirement is not included for growth at smaller settlements including Minor Rural Centres, Group Villages, and Infill Villages.
Anglian Water requests that this qualifying statement to demonstrate that adequate infrastructure is available, should be applied to all the settlement categories within the settlement hierarchy, so development proposals clearly address infrastructure capacity - this includes wastewater treatment capacity in the network and the receiving WRC (as evidenced by the Stage 2 Detailed Water Cycle Study). For small Infill Villages such as Tadlow where we have WRCs with a descriptive permit i.e. Descriptive Works - our position statement indicates that we will object to proposals that seek to connect to our network unless the developer can demonstrate there is sufficient capacity at the works, or an onsite solution such as a package treatment plant is approved. As the policy makes provision for slightly larger developments (not more than 8 dwellings) in Infill Villages, we would suggest that similar to Group Villages, clause 13 should require that adequate infrastructure is, or can be made available.
https://www.anglianwater.co.uk/siteassets/developers/new-content/p--c/descriptive-works-position-statement-march-2025.pdf

Anglian Water supports the policy requirement 1.c to ensure that there is the necessary infrastructure to support the development within defined settlement extents. Whilst this should be equally applicable to developments outside defined settlement extents, we are satisfied that these developments must be supported by other policies in the plan.
The policy does not specifically reference the delivery of utility services /infrastructure in the countryside, which would include critical water and wastewater infrastructure to serve existing and future communities. Our infrastructure, by its very nature is often located on the edge of settlements or in the countryside, but we consider that our proposals can be clearly justified as developments “which need to be located in the countryside” (clause 2.c).

Anglian Water agrees with the supporting text (paragraph 3.1.41), that the policy must be considered in conjunction with Policy AMC/NEC: North East Cambridge, which designates a wider area, including this site, as an Area of Major Change. Policy AMC/NEC requires development proposals to apply the Agent of Change principle in terms of the impacts and risks associated with the odour zone for Cambridge WRC and ensure it will not result in unacceptable amenity issues for occupiers of the proposed development.

Anglian Water supports this strategic allocation policy for Areas of Major Change within Cambridge, which requires that the necessary infrastructure to support the development has been secured – including temporary provision were appropriate. This aligns with our Strategic Sites Guidance Note which may provide for temporary connections to our network to enable initial phases to come forward, until a strategic point of connection is provided. We consider that this is appropriately reinforced by the requirement of a phasing strategy to be in place where the phased provision of infrastructure is required - this is consistent with Policy I/ID.
We agree with clause 4, that the redevelopment of these areas of major change, should protect existing assets including ‘water management’. We welcome the amendment to the supporting text explaining what this term encompasses, in terms of SuDS features and watercourses.

As indicated in our response to Policy S/DS: Development Strategy Anglian Water is supportive of the policy approach to designate North East Cambridge (NEC) as an Area of Major Change, following the withdrawal of funding for a new water recycling centre permitted through the CWWTPR Development Consent Order (DCO), and our subsequent decision to invest in our existing Cambridge WRC site. Whilst Anglian Water has taken this decision, it remains the case that the DCO provides a five-year implementation period from the date the Order came into force on 23 April 2025. Accordingly, the authorised development allows commencement at any point within this period, after which the consent will have been lawfully implemented.
Paragraph 3.1.83 refers to uncertainty around the future operations of the Cambridge Waste Water Treatment Plant (Cambridge WRC); however, we have confirmed our intention to continue to invest at the site, so this would remove uncertainty for the Local Plan and the NEC area of major change providing funding is secured through the relevant mechanisms identified earlier in our response.
We support the policy section relating to context, which sets out the long-established industrial uses in the North East Cambridge area including wastewater treatment at our Cambridge (Milton) WRC. The policy requirements to ensure that proposals do not conflict with ongoing sensitive uses, must apply the ‘agent of change’ principle, and not prejudice safeguarded uses are similarly supported. We also welcome the reference to our sewer pumping stations within the site to ensure these are taken into account in any development proposals.
Anglian Water will use a risk assessment process to consider any planning application within 400 metres of a water recycling centre or within 15 metres of a recycled water pumping station. We may decide to increase the size of this ‘consultation zone’ if the treatment works serves a population greater than 50,000 people. While the results of the assessment will not decide the outcome of any planning application, it will inform potential developers and provide planning officers and elected councillors with evidence based findings to help inform their planning decisions
The policy section referring to Lifespan is also supported in terms of ensuring development proposals do not impede the continued us of the Cambridge WRC, and all major development proposals are supported by detailed phasing and infrastructure strategies to enable the timely delivery of necessary infrastructure.

Include the following clause:
Utilise opportunities for greening in the public realm to create habitat and contribute to sustainable urban drainage.

The public realm improvement areas should also offer the opportunity to achieve betterment in terms of surface water risk management, through provision of sustainable drainage systems (SuDS). Such measures are not implicit in the policy nor in most of the subsequent PRIA site-specific policies, and we consider this should be positively expressed in this overarching policy. For example, Policy S/PRIA/MR: Mill Road, clause 2.d. requires: Utilise greening in the public realm to create habitat and contribute to sustainable urban drainage – this should be equally applicable to all public realm improvement areas.

Include the following clauses under the Resources section of the policy:
As part of the design, consider innovative approaches to incorporating low-sustainable water management, including greywater recycling, rainwater harvesting, and sustainable drainage systems (SuDS), informed by preparation of an Integrated Water Management plan and Water Cycle Strategy.

Provide appropriate provision for and design of foul drainage and sewage disposal, to be explored and identified through a foul drainage strategy to be prepared by the applicant, in line with the Climate and Sustainability Innovation Delivery Plan.

Anglian Water is supportive of the policy requirement to prepare a site wide masterplan in conjunction with all key stakeholders and the local community. This provides an opportunity for us to engage on infrastructure delivery and phasing and will also encourage landowners/site promoters to raise relevant enquiries with us regarding connections to our network.
Resources:
Anglian Water supports the requirement to integrate SuDS and flood mitigation measures as both functional and amenity features. We consider that this complements Policy CC/WE Water Efficiency in New Developments – where some form of water reuse or recycling will be necessary. However it would be helpful to specify requirements for ‘low-sustainable water management’ including rainwater harvesting and greywater recycling.
The policy clearly sets out that conditions will be necessary to limit first occupations of new dwellings to ensure the Grafham Transfer water supply intervention (Grafham to Cambridge pipeline) becomes operational (clause 23). However, it does not require similar conditions might be necessary to ensure that phased infrastructure plans to increase capacity at Cambridge WRC are also operational prior to occupation. We conclude that Policy CC/IW will apply to all development proposals in demonstrating there is capacity for wastewater treatment and adequate wastewater conveyancing infrastructure to serve the whole development, or an agreement is in place with the relevant service provider to ensure the provision of the necessary infrastructure prior to the occupation of the development.
The policy does not refer to a requirement for a foul drainage strategy to demonstrate capacity is available or can be made available in the wastewater network and receiving water recycling centre to accommodate growth, aligned with a phasing plan. This is inconsistent with other policies in the plan for significant growth such as Cambourne North, Grange Farm and Cambridge Biomedical Campus which all require a foul drainage strategy or infrastructure delivery strategy to ensure timely and efficient delivery without overburdening existing services.
Recognising some sites already have the benefit of planning consent, considering the total quantum of growth proposed at Cambridge East the policy requirements should be consistent with those for Cambourne North and Grange Farm in respect of water management and wastewater disposal.

Anglian Water is supportive of the policy requirement to prepare a site wide masterplan in conjunction with all key stakeholders and the local community. This provides an opportunity for us to engage on infrastructure delivery and phasing and will also encourage landowners/site promoters to raise relevant enquiries with us regarding connections to our network.
Anglian Water supports the Resources section of the policy which required the use of innovative approaches to water management on site including SuDS, water reuse and natural systems to help address flood risk, including surface water, foul drainage and sewage disposal, and maximise the sustainability of the Campus.
We welcome reference to the preparation of an Infrastructure Delivery Strategy in clause 27, to ensure their timely and efficient delivery. We consider that the strategy will include all infrastructure required to support the delivery of further phases of the campus, including wastewater infrastructure. This is further reinforced by clause 31.e.