Greater Cambridge Local Plan: Proposed Submission

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 available the Council would need to amend the NEC Policy and
subject it to further consultation and Local Plan Examination.

Representations 1) to 24) are a common view shared between Fen Ditton Parish Council (FDPC)
and Save Honey Hill (SHH), a community group.

1) Policy S/AMC/NEC & Spatial Strategy (Paras 2.56–2.59) – Deliverability and Effectiveness

Target Policy/Section: S/DS Policy S/AMC/NEC (North East Cambridge) & Spatial Strategy for the
Cambridge Urban Area (Paragraphs 2.56 to 2.59)

Policy S/AMC/NEC (Spatial Strategy) is unsound because it fails the Effectiveness test set out in the
National Planning Policy Framework (NPPF) Paragraph 36(c) [36c].

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.
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) [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 available the Council would need to amend the NEC
Policy and subject it to further consultation and Local Plan Examination.

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 .

Representations 1) to 24) are a common view shared between Fen Ditton Parish Council (FDPC) and Save Honey Hill (SHH), a community group.

2) Policies Map & Policy S/AMC/NEC – Spatial Transparency

Target Policy/Section: Policies Map & Spatial Strategy for the Cambridge Urban Area (Paragraphs
2.56 to 2.59)

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.

Change Requested:
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.

Representations 1) to 24) are a common view shared between Fen Ditton Parish Council (FDPC) and Save Honey Hill (SHH), a community group.

5) Policy S/AMC/NEC & Evidence Base – Odour and Feasibility
Target Policy/Section: Policy S/AMC/NEC & Evidence Base (Odour and Feasibility)

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.

24) Spatial Strategy, Policy S/AMC/NEC, & Evidence Base – Residual Transitional Inconsistencies
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.

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 [36b, 36c].
While the Plan correctly adapts to the August 2025 Housing Infrastructure Fund (HIF) 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 (WCS) 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 (EA) 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 (SA) Option Structure (July 2026): The SA 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.

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.

6) Policy S/AMC/NEC (Criterion 10 / Para 10) & Minerals and Waste Policy 16

Target Policy/Section: Policy S/AMC/NEC (Criterion 10 and Supporting Paragraph 10) & Minerals and
Waste Local Plan (MWLP) Policy 16

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" (CA) 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.

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.

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 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.

Representations 1) to 24) are a common view shared between Fen Ditton Parish Council (FDPC) and Save Honey Hill (SHH), a community group.

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 multidisciplinary
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.

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

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.

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.

Target Policy/Section: Policy I/SI (Safeguarding important infrastructure), Supporting Paragraph 10.59, and the Policies Map

Main Response: 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.

Representations 1) to 24) are a common view shared between Fen Ditton Parish Council (FDPC) and Save Honey Hill (SHH), a community group.

20) Policy S/AMC/NEC: Support for Retention of CWWTP In-SituTarget Policy/Section: Policy S/AMC/NEC & Spatial Strategy for the Cambridge Urban Area
(Paragraphs 2.56 to 2.59)

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 hectares within the total DCO Order Limits) at Honey Hill, which the made DCO confirms would
cause certain harm to openness.
Retaining the plant 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.

Representations 1) to 24) are a common view shared between Fen Ditton Parish Council (FDPC) and Save Honey Hill (SHH), a community group.

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 [2.57]. 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.

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) [36c].

Representations 1) to 24) are a common view shared between Fen Ditton Parish Council (FDPC) and Save Honey Hill (SHH), a community group.

22) Policy CC/IW (Wastewater) & Developer Capacity Accountability Target Policy/Section: Policy CC/IW (Criterion 6(a) / Supporting Text)

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 capacity exists before occupation 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.

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 .

Representations 1) to 24) are a common view shared between Fen Ditton Parish Council (FDPC) and Save Honey Hill (SHH), a community group.

23) Policy S/DS (Development Strategy) & Countryside Utility Exception Refusal
Target Policy/Section: Policy S/DS (and Policy S/GB) & Response to Anglian Water

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.