Greater Cambridge Local Plan: Proposed Submission

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/developers to raise relevant enquiries with us regarding connections to our network.
Anglian Water supports clause 12, to ensure that the Eddington development continues to utilise surface water run-off/SuDS attenuation to supply non-potable water reuse in new homes. Eddington continues to demonstrate how water smart communities can be delivered – aligning with the findings of the Enabling Water Smart Communities project EWSC One-Pagers — EWSC.
The policy references 100% recycled water for homes however, we believe this should refer to the 100% water reuse for non-potable uses in new homes (e.g. to flush toilets and outdoor use), to reduce potable water demands.

For consistency and clarity include in the Resources section of the policy:
• Demonstrate 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.

Anglian Water recognises the strategic significance of this allocation to align with the proposed East West Rail station - a catalyst for sustainable growth around key transport hubs, including the proposed Cambourne to Cambridge busway, which aligns with government priorities for growth. The quantum of development, which will be delivered beyond the lifetime of the plan, will need to be appropriately phased to align with delivery of supporting infrastructure.
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/developers to raise relevant enquiries with us regarding wastewater treatment infrastructure required to support delivery of the new settlement.
Clause 12.c. vii requires sewage treatment facilities to serve the needs of the development, including upgrading existing local facilities where required. We support the need for sewerage treatment facilities to be provided. We consider this is a relatively broad requirement that will assist with delivering the necessary wastewater infrastructure to facilitate growth at Cambourne North. In terms of upgrading local facilities, Anglian Water is unable to accept developer contributions to upgrade our WRCs, and the infrastructure charge paid by developers to connect to our network is used to help reinforce our sewer networks as investment schemes are identified. Developers are encouraged to engage with Anglian Water at an early stage on wastewater infrastructure capacity and sustainable points of connection. This will identify infrastructure requirements needed to support delivery. Subject to the outcome of these assessments, developers will be liable for costs for any conveyance to an identified sustainable point of connection to our network and may be required to deliver on-site sewer pumping stations.
Nature: We support the strong framework for delivering and integrating green and blue infrastructure to important multi-functional benefits, including for water management, mitigating flood risk and enhancing biodiversity.
Resources: We support clauses 40 to 42 of this section of the policy for comprehensive management of surface water run-off and provision of foul drainage strategy as part of the Cambourne North Sustainability Strategy. We agree that the preparation of a Sustainability Strategy sets out the key expectations for delivering a climate resilient community and will minimise resource use. However, the policy is not consistent with the new settlement Grange Farm allocation policy which specifically requires 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. We recommend a similar clause is included in the Cambourne North allocation policy.
The policy clearly sets out that conditions are likely to be necessary to limit first occupations of new dwellings to ensure the Grafham Transfer water supply intervention (Grafham to Cambridge pipeline) becomes operational (clause 44). However, it does not state that similar conditions might be necessary to ensure that phased infrastructure plans to increase capacity at Uttons Drove 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.

Resources: We support clauses 26-28 of this section of the policy for innovative water management and resource use (informed by an Integrated Water Management Plan and Water Cycle Study), and provision of foul drainage strategy as part of the Climate and Sustainability Innovation Plan. It is not outlined how the Climate and Sustainability Innovation and Delivery Plan is different to the Cambourne North Sustainability Strategy and whether any difference is intended, beyond the terminology.
We agree that there needs to be scope for wastewater infrastructure provision to be explored further – options for connection to Sawston WRC or an onsite WRC are referenced in the IDP and WCS Addendum and reflect our previous submission to the Local Plan. However, if an on-site water recycling centre is considered to be feasible, sufficient land would need to be provided with a suitable encroachment buffer to avoid odour impacts on sensitive receptors.
The policy clearly sets out that conditions are likely to be necessary to limit first occupations of new dwellings to ensure the Grafham Transfer water supply intervention (Grafham to Cambridge pipeline) becomes operational (clause 44). However, it does not state that similar conditions might be necessary to ensure that phased infrastructure plans to increase capacity at Sawston 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.

Amend the following clause:
K. Development must not preclude any construction of or route of the Fens Reservoir Pipeline to accommodate water infrastructure for the region in consultation with Anglian Water.

The proposed allocation comprises approximately 24.58 hectares of land to the south of Cambridge Services. The allocation provides capacity for approximately 90,000 sq m (GIA) of Class B2 (General Industrial) or Class B8 (Storage and Distribution) floorspace, with approximately 150 lorry parking spaces and associated supporting facilities.
At present, the allocation continues to overlap with the proposed pipeline corridor and preferred engineering route for the Fens Reservoir Pipeline, as identified through Anglian Water's Phase 3 Consultation and Regulation 18 representations. The design refinement process will be ongoing as the Fens Reservoir scheme progresses. Anglian Water welcome continued dialogue and engagement with Greater Cambridge Shared Planning Service as there is concern that if the employment allocation was to come forward ahead of the Fens Reservoir, this would reduce flexibility to adjust the alignment of the pipeline and also make its construction more complex due to the requirement to cross the A14. Furthermore, new receptors would be introduced in close proximity to the construction works which would need to be taken into consideration and additional mitigation may be required.
Following Anglian Water's Local Plan Regulation 18 representations made earlier this year, the following clause has been added to the draft allocation policy:
K. Development must not preclude any construction of or route of the Grafham Pipeline to accommodate water infrastructure for the region in consultation with Anglian Water.
Anglian Water welcomes the inclusion of a specific sub-policy requirement relating to the protection of strategic water infrastructure. However, it appears that there may have been confusion as the Grafham Pipeline runs further to the south of the allocation and does not overlap. It is requested that part K of the policy should be amended to refer to the Fens Reservoir Pipeline instead.
Anglian Water does not object in principle to the proposed allocation and will continue to refine its proposals. However, given the current overlap between the it is important that the policy wording requires the future developer to engage with Anglian Water from the outset to agree the design and layout in order to ensure the two developments are compatible including their construction phasing, alongside agreeing appropriate easements and access for long term maintenance.
Anglian Water welcomes continued discussion with the Council to ensure that the strategic water infrastructure and employment allocation can be progressed in a coordinated manner.

Amend the following clause:
G. Development must not preclude any construction of, or route for, the Fens Reservoir Pipeline to accommodate water infrastructure for the region, in consultation with Anglian Water.

The proposed allocation comprises approximately 2.11 hectares of land at Buckingway Business Park, Swavesey, with capacity for approximately 10,000 sqm (GIA) of Class B2 (General Industrial) or Class B8 (Storage and Distribution) floorspace development.
The allocation is adjacent to the preferred route of the Fens Reservoir Pipeline. As noted above, the design refinement process for the Fens Reservoir Pipeline remains ongoing, and the pipeline alignment may be subject to change. Any changes to the alignment could therefore have implications for the allocation as the proposals progress.
Following Anglian Water's Local Plan Regulation 18 representations made earlier this year, the following clause has been added to the draft allocation policy:
G. Development must not preclude any construction of, or route for, the Grafham Pipeline to accommodate water infrastructure for the region, in consultation with Anglian Water.
Anglian Water welcomes the inclusion of a specific sub-policy requirement relating to the protection of strategic water infrastructure. However, it appears that there may have been confusion as the Grafham Pipeline runs further to the south of the allocation and does not overlap. It is requested that part G of the policy should be amended to refer to the Fens Reservoir Pipeline instead.
It is acknowledged that the proposed allocation does not currently overlap with the identified Fens Reservoir Pipeline buffer zone. Accordingly, Anglian Water does not object to the allocation in principle. Nevertheless, given the proximity of the allocation to the proposed pipeline and the ongoing design refinement process, it is important that the Local Plan appropriately recognises the relationship between the two projects.

Anglian Water fully supports the policy requirements to ensure sustainable and resilient development embeds the principles of climate change mitigation and adaptation. We agree that a Sustainability Statement should be submitted to demonstrate how these policy requirements have been met, and these may be supported by separate assessments or strategies including flood risk assessments, surface water drainage strategies and foul drainage strategies.
The inclusion of integrated water management, nature-based design solutions and circular economy fully align with the sustainable use of water resources, that contribute towards "Enabling Water Smart Communities" www.ewsc.org.uk . The EWSC project promotes and provides evidence to support integrated water management initiatives that provide alternative ways to sustainably manage water in housing, reduce flood risk and improve water quality - helping to support people and nature to thrive together.

Anglian Water strongly supports the policy requirement for tighter water efficiency standards in new development that can help make development across the district more water efficient and allow sustainable growth, whilst longer term water supply solutions are being developed/implemented. As well as managing risks to the environment, tighter water efficiency measures may also reduce the need for water companies to restrict supply for non-domestic growth, alongside other initiatives. The implementation of tighter water efficiency standards will also help to reduce the operational and capital carbon required to heat water in the home, deliver infrastructure, and pump and treat wastewater flows from new development.
The Detailed Water Cycle Study (2025) references the Shared Standards for Water Efficiency in Local Plans (published in June 2025) which set out a collaborative and collective approach by Anglian Water, Cambridge Water, Essex & Suffolk Water, Affinity Water, the Environment Agency and Natural England, with the full endorsement of Water Resources East (WRE) as part of strengthening the Regional Water Resources Plan for Eastern England. It recommends that Local Planning Authorities (LPAs) include tighter water efficiency standards in Local Plan policies to support a clean and sustainable supply of water - essential for growth and nature recovery.

After Clause 3 insert:
All surface and foul water flows must be separated. Under no circumstances will surface water be permitted to discharge into a separate foul sewer or to a combined sewer system via a new connection.

Anglian Water welcomes the approach to integrated water management in clauses 1 and 2. This supports the delivery of water smart communities where water is an integral part of good place-making and essential for the delivery of wider outcomes, through the multi-functional benefits that can be achieved by SuDS as part of green and blue infrastructure networks.
Sustainable Drainage Systems (SuDS): Anglian Water supports the requirement for developers to demonstrate how the surface water drainage hierarchy has been applied - this is an essential pre-requisite to Anglian Water accepting a surface water drainage strategy together with agreement by the Lead Local Flood Authority (LLFA). If the LLFA are satisfied that, based upon evidence, no other option is feasible then a connection point may be made to the surface water sewer at a rate agreed with LLFA, subject to there being existing capacity or the provision of network reinforcement to accommodate the flow. We require all surface water and foul flows to be separated, and we will not accept new surface water connections to a combined sewer, and it should be clear that no surface water will be permitted to the foul sewer.
We agree that the design and implementation of SuDS must be in line with the National Standards for SuDS – this guidance is clear that surface water shall not discharge to the foul sewer.
Water Quality: Anglian Water fully supports the policy requirements to demonstrate that there is capacity in our wastewater network and receiving WRC to accommodate development proposals, set out in clause 6. Development proposals will also need to secure a sustainable point of connection to our surface water, foul or combined network. We identify the need for sustainable points of connection into our network by using a complexity matrix that assesses factors such as pollution risks and CSO spills, surcharges of our network, existing flood potential and excess surface water flooding. Where a sustainable point of connection is identified, this will be reflected in our planning responses with a request that the sustainable point of connection is specified in a recommended planning condition.

Anglian Water supports the policy requirements to manage flood risk from all sources. We identified specific areas that were particularly at risk from sustained groundwater flooding following the significant extreme weather events during the autumn and winter of 2023/24. We therefore agree with clause 5.e where sites may require a Flood Risk Assessment if the land is subject to other sources of flooding, and development would introduce a use of higher flood risk vulnerability.
We particularly welcome clauses 1.e and 1g that ensure existing flood and surface water management assets are not adversely impacted by proposals and betterment must be provided on previously developed sites. It is essential for the effective management of our operational risk that we ensure the risk posed from surface water drainage is clearly understood and taken into account by developers. We support the reference to Anglian Water in the supporting text (4.43) and the need for early consultation with the responsible bodies for flood risk.

Major residential, employment or mixed-use development must provide a minimum 20% biodiversity net gain (BNG), (unless exempt under the Environment Act 2021), to be provided on-site where this is feasible and effective, or off-site where onsite options for BNG have been evidenced to be exhausted as agreed with the relevant Local Planning Authority (LPA).

Or the policy is amended to enable certain exemptions to apply to the 20% BNG requirement where it is demonstrated to be unfeasible to deliver 20% BNG due to the nature of the development (i.e. strategic water pipelines where land is reinstated and 10% BNG is also provided).

Anglian Water repeats concerns raised at the previous Local Plan consultation (Preferred Options) stage, regarding the proposed 20% Biodiversity Net Gain (BNG) requirement for major development set out in clause 2 of the policy. Whilst we recognise the intention behind targeting a higher net gain requirement then the mandatory 10%, to align with the Cambridgeshire Doubling Nature vision, we are concerned that applying the new target to Anglian Water developments would not achieve the intended outcomes.
BNG requirements cannot be met onsite for projects where Anglian Water is not the landowner as 30-year habitat management cannot be guaranteed. For example, linear pipeline schemes, such as the one being planned between Grafham and Cambridge, frequently cross multiple landownerships. These projects often have minimal impact on biodiversity, but when the full length of a scheme is considered, statutory BNG requirements (10%) are already significant. In cases where Anglian Water is the landowner, scope for achieving BNG onsite is limited by the needs of site operations and the need to consider future infrastructure upgrades.  Consequently, Anglian Water’s development projects do not reflect the cost assumptions made in the Greater Cambridge Draft Local Plan Viability Assessment, which only assesses costs against residential and commercial development on brownfield and greenfield sites. Whilst 20% may be viable for other development types where onsite BNG is feasible (such as new housing allocations), it does not reflect the realities of delivering water infrastructure projects.
The additional BNG units required under this proposal, would need to be sourced offsite, increasing costs to our customers and extending the timelines to deliver new water infrastructure. This additional burden does not consider the significant biodiversity and nature recovery benefits being delivered by our proposed infrastructure upgrades and WINEP schemes in AMP8 – which will help to deliver sustainable growth and improve the ecological quality of catchments and aligns with the Government’s 25 Year Environment Plan ambitions and wider agenda.
We request that the Council reconsiders the impact of 20% BNG for all major development types, and the impacts this requirement would have on the timely delivery of essential infrastructure to support the Council’s growth ambitions. We suggest that essential major infrastructure projects, where there is no scope for BNG onsite should be exempt from the 20% BNG requirement for major development, so that only the mandatory 10% BNG requirement would apply.