Greater Cambridge Local Plan: Proposed Submission

Anglian Water welcomes the clarity in the supporting text (5.63) to the policy regarding the provision of new trees and ensuring site layouts are compatible with existing or planned underground utilities such as sewers.

Anglian Water welcomes the addition of ‘essential infrastructure’ in relation to specific development that may be necessary within riparian buffer zones (clause 2) and further explanation in the supporting text (paragraph 5.74).

Anglian Water supports the policy section regarding environmental nuisance/pollution and the agent of change principle. We consider that this provides a robust approach to managing development proposals for sensitive uses, including residential development, near our water recycling centres or sewer pumping stations, to ensure such proposals do not put at risk the operation of our existing infrastructure, and that the Agent of Change Principle will apply.  
Our assets such as water recycling centres and pumping stations can be a source of odour and noise that may impact on sensitive receptors such as in proposed residential developments - we have developed guidance and a policy position on asset encroachment which can be found on our website. https://www.anglianwater.co.uk/developing/our-services/planning--capacity/asset-encroachment
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 sewer 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 a 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 Cambridgeshire and Peterborough Minerals and Waste Local Plan, Policy 16, also refers to consultation areas (CAS) around water recycling areas to ensure development will not prejudice the existing or future use of the area, and a presumption against allowing development that would comprise buildings regularly occupied by people or land for regular community use.
Our water recycling centres are generally long-established uses within an area, and whilst there cannot be a simple presumption against all development, building close to these operational wastewater sites may not always be in the best interests of people who would have to live or work there in the future.

Anglian Water is supportive of the amendment to this policy to ensure new development supports the climate emergency response (1.c.i) to include the term 'operation' as new buildings using less energy and potable water are a factor of its operation rather than delivery or maintenance.

Anglian Water welcomes the amendment to clause 2.m to ensure the layout and design of development incorporates functional needs including access to utilities. Our existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing sewerage assets should be sited within highways or public open space. If this is not possible a formal application to divert Anglian Water’s existing assets may be required.

v. Provision of public art will be required on all major development proposals and will make a significant contribution towards the appearance of the scheme. Exemptions will only apply in exceptional circumstances where it can be reasonably justified. Public art should be developed through partnerships between the developer and the Local Planning Authorities, in consultation with the local community and art consultants where appropriate to the scheme.

Anglian Water is supportive of the inclusion of 1.c responding to climate change with multifunctional green and blue infrastructure as one of the key factors to achieving high-quality development with surface water management and SuDS integrated through nature-based design.
Clause 1.d.v requires the provision of public art on all major development proposals and paragraph 7.50 states that "all forms of major development are required to make provision for public art". Anglian Water objects to this policy requirement and would request that this clause should be more specific to the types of major developments that most appropriately apply to this clause or set out that exceptionally exemptions may apply where there are compelling reasons to justify this.
We do not consider that the provision of public art should apply to major utilities infrastructure as amenity and landscape matters relating to our new utility infrastructure are addressed through identified mitigation measures following technical assessment such as new landscaping and do not require public art to ameliorate impacts. Our investments use public money funded through customer bills, and additional provision of, or contributions to, public art would not be considered value for money. Most of our above ground infrastructure such as water recycling centres (or extensions thereof), pumping stations, water treatment works, and service reservoirs are not in locations which are routinely visited by or indeed often seen by the public. They are operational areas with strict security requirements and are generally located on the edge of, or outside settlements. Further, Anglian Water provides essential wastewater and water supply infrastructure, including underground assets such as sewers and water supply pipelines. Funding for new infrastructure outlined in our Business Plans, is agreed with Ofwat our economic regulator, under specific financial metrics methodology, which sets the parameters for spending. We have raised similar concerns in our representations to the Greater Cambridge Planning Obligations SPD.
Whilst paragraph 7.51 of the supporting text sets out that exemptions may apply where public art requirements do not meet the tests for planning obligations in paragraph 58 of the NPPF, this means that water companies and other utilities providers would have to specifically make the case for this in each planning application, when the policy should provide the clarity sought.

Amendments are sought to the policy title and an additional clause: Policy I/SI: Safeguarding and supporting important infrastructure
“…11. The Council will support the planning and delivery of strategic infrastructure including Fens Reservoir and associated water infrastructure. Proposals that are within areas potentially affected by proposed strategic infrastructure, including Fens Reservoir and its associated water infrastructure (comprising treated water pipelines and associated service reservoir) must demonstrate that they have had regard to the latest proposal information, and be designed, located and phased so as not to prejudice the delivery, operation or future expansion of the project.”

Alternatively, if the Council do not consider it appropriate to amend Policy I/SI it is requested that there is a standalone policy to reflect the significance of the project. The following wording is suggested:

Proposed Fens Reservoir and Associated Water Infrastructure Policy
“The Council will support the planning and delivery of strategic infrastructure that contributes to sustainable growth, resilience and improved water infrastructure within South Cambridgeshire. Where strategic infrastructure proposals are not yet fully defined, development proposals will be required to demonstrate that they have had regard to the latest available proposal information and to avoid prejudicing the delivery, or operation of strategic infrastructure. This includes but is not limited to proposed Fens Reservoir and associated water infrastructure.
A proposal that includes land within an area potentially affected by proposed strategic infrastructure must:
a. demonstrate that it has had regard to the latest proposal information;
b. be designed, located and phased so as not to prejudice the delivery, operation or future expansion of strategic infrastructure;
Where necessary and proportionate to avoid prejudicing the delivery of strategic infrastructure, planning conditions or obligations may be used to secure appropriate mitigation, phasing or design measures. Planning permission may be refused for development that would compromise the implementation of strategic or nationally significant water infrastructure.”

As the Greater Cambridge Shared Planning Service are aware, the Fens Reservoir is a project of national significance for new water resources, which will provide water supply to Anglian Water and Cambridge Water customers. The reservoir will be determined under the Planning Act 2008 as a Development Consent Order.
The need for the reservoir was established in our Water Resources Management Plan 2020-2045 (WRMP19) and taken forward in our most recent Water Resources Management Plan for 2025-2050 (WRMP24), and Cambridge Water’s final WRMP together with other interim strategic supply options including potable water transfer interconnectors to support the long-term supply demand balance for water resources across our region; providing drought resilience and environmental protection.
It is welcomed that paragraph 1.10 of the draft Local Plan continues to recognise the importance of the Fens Reservoir, stating that the proposed reservoir ‘will play a vital role in securing long-term water supply and resilience for the region.’ However, paragraph 1.10 currently states that the Fens Reservoir is planned to be operational between 2035 and 2037. As set out in Anglian Water’s previous representations, and in Anglian Water’s Phase 3 Consultation material, it is anticipated that the Fens Reservoir would be operational in 2036 at the earliest (this is also referenced in the Proposed Submission Plan Draft Statement of Common Ground Appendix 1: Appendix 1: Sup SoCG (iv): Delivery of growth – Water Supply). Accordingly, it is requested that the wording of paragraph 1.10 is amended to reflect this anticipated delivery timeframe.
It is similarly welcomed that the Fens Reservoir is referenced within the Water Supply section of the emerging draft Local Plan. Paragraph 2.78 states that ‘the Fens Reservoir will further increase supplies from the mid 2030’s’. For consistency with the anticipated delivery timeframe set out above, it is requested that this wording is amended to state that the Fens Reservoir is anticipated to be operational in 2036 at the earliest.
The Fens Reservoir
The Fens Reservoir is being progressed through the formal regulatory process established by the Regulators’ Alliance for Progressing Infrastructure Development (RAPID) gated process, recognising the need to plan long term for our region's future water needs.
The Fens Reservoir will be located to the north of Chatteris. It will take surplus water when it is available in the environment and store it until it is needed by customers. The Reservoir itself is located in Fenland District, but elements of the transfer corridor and associated infrastructure will be located in South Cambridgeshire District as described below.
The preferred route of the associated water infrastructure (comprising treated water pipelines and associated service reservoir) runs through the northwestern part of South Cambridgeshire,
Strategic water infrastructure, specifically the proposed Fens Reservoirs is a key initiative designed to improve water quality, treatment and supply and support long term water resilience across the district. The Fens Reservoir proposal will not only help to meet the region’s water supply needs for the future and may provide opportunities for recreation and leisure, subject to the outcome of ongoing design, assessment, consultation and consenting processes. The precise land requirements for the proposed Reservoir and any associated infrastructure remain subject to ongoing options appraisal, environmental assessment, consultation and the relevant consenting processes.
Development proposals within areas potentially affected by the Reservoir proposals should demonstrate that they have had regard to the latest available project information, so that such development proposals do not prejudice the delivery of strategic water infrastructure. Therefore, it is requested that Policy I/SI (Safeguarding Important Infrastructure) is amended to include Fens Reservoir at point 11 of this policy to recognise the significance of this project. It is also requested that the policy title is amended, the following wording is suggested in the modification below.

Anglian Water supports the policy requirements to ensure that infrastructure capacity is available or can be made available in time to serve the development, including the submission of a phasing strategy to align with the timing of additional infrastructure investment. We agree that a Utilities Statement should support this to provide details including foul and surface water drainage and details of any engagement and agreements made. We encourage developers to undertake early engagement with Anglian Water including the submission of pre-planning enquiries to establish sustainable points of connection to our combined, surface water, and foul drainage networks, and capacity at our WRCs. We provide detailed information on our website on how developers can apply for these assessments based on those which best suits the development.