Category: CWWTPR

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Pressure mounts to halt dislocated NECAAP

North East Cambridge development plans come under fire from local campaign groups

Increasingly, more groups and Councillors are expressing their concerns about the overdevelopment of Cambridge, including the planned relocation of the sewage works to Honey Hill. Much concern has also been voiced about the draft Local Plan and the implications of the North East Cambridge Area Action Plan (NECAAP) redevelopment and housing (planned for the current sewage works site) and the environmental and general impact the overdevelopment of Cambridge will have on all of our lives.

“creative carbon accounting”

Green Party city councillor, Hannah Copley, has accused local authorities of “creative carbon accounting” in development plans for North East Cambridge1. Like us, Cllr Copley believes moving the sewage works is unnecessary and that the environmental consequences of doing so have not been properly assessed. Cllr Copley, who represents Abbey Ward, said: – “The North East Cambridge development can only go ahead if the sewage works moves, and the sewage works is only moving so that the land can be developed. These two projects are intrinsically linked…We need to include the entire lifetime carbon emissions of the destruction, rebuilding and relocation of the new sewage works”. She questions “The completely unnecessary destruction and rebuilding of the waste water treatment works, and the loss of Green Belt land… The Cambridge Green Belt is being dismantled piece by piece”2

“Many residents are shocked at the level of growth proposed…and the plan’s failure to consider the overall environmental capacity and climate change impact and the effect on the historic environment (built and natural) in a holistic way”

In response to the Local plan, Friends of the Earth, has accused the councils of “hypocrisy” … who “on the one hand spout bland platitudes about cutting carbon dioxide emissions and on the other, countenance further pouring of concrete, building of roads for ever increasing traffic levels and continual gnawing away at the Green Belt in a Local Plan that has anything but good wishes towards anything local”3. Wendy Blythe of FeCRA states “Many residents are shocked at the level of growth proposed…and the plan’s failure to consider the overall environmental capacity and climate change impact and the effect on the historic environment (built and natural) in a holistic way”.4 CPRE and Friends of the Cam have raised their concerns about the lack of water and space to support the level of housing growth suggested in the Local plan. CamDEAG warns “Cambridge is being exploited for financial gain”. Concern has also been expressed about flood risk and food supply5

“You’re introducing another 18,000 people to an area and the assumption is that they will go elsewhere for their cultural and leisure facilities.”

In the Cambridge Independent Newspaper6, Independent Cambridge City Councillor, Sam Davies, expresses her concern about the density of housing proposed and the lack of leisure and social amenity space on the NECAAP development, planned for the existing sewage works site in Milton. “You’re introducing another 18,000 people to an area and the assumption is that they will go elsewhere for their cultural and leisure facilities.” It is widely acknowledged that Milton Road is already at capacity and there is concern about the impact the increase in population in this area will have on our roads7. James Littlewood, Chief executive of Cambridge Past Present and Future, has expressed concerns about the potential impact of thousands of future residents on Milton Country Park. He has told councillors that not enough open space is allocated for future residents8. Councillor Anna Bradnam has also expressed her concerns over lack of sports and Faith facilities and a cemetery9

Concern has also been expressed by our MP Lucy Frazer10 and Councillors Claire Daunton11 and Anna Bradnam about access to the proposed new sewage works site at Honey Hill. All favour option three, a dedicated service from the layby on the A14 to the site. Anglian Water prefers Option 1, on Horningsea Road.

 

Glossary: –

  • NECAAP – North East Cambridge Area Action Plan
  • CPRE – Campaign for the Protection of Rural England
  • FeCRA – Federation of Cambridge Residents’ Associations
  • CamDEAG – The Cambridge Doughnut Economics Action Group

 

  1. Written question to City Council Planning & Transport Scrutiny Committee, 114th Jan 2022 [↩]
  2. Cambridge Independent Jan 12-Jan 18 2022 p9 [↩]
  3. Cambridge Friends of the Earth Facebook page [↩]
  4. https://www.fecra.org.uk/update-14th-december-2021/ [↩]
  5. Cambridge Independent Jan 5-Jan 11 2022 p9 [↩]
  6. Cambridge Independent Newspaper Jan 12th to 18th [↩]
  7. https://www.cambridgeindependent.co.uk/news/new-north-east-cambridge-district-to-have-no-pool-or-sports-9235120/ [↩]
  8. https://www.cambridgeindependent.co.uk/news/8-350-home-north-east-cambridge-plan-will-protect-villages-a-9234459/ [↩]
  9. https://www.cambridgeindependent.co.uk/news/8-350-home-north-east-cambridge-plan-will-protect-villages-a-9234459/ [↩]
  10. https://www.lucyfrazer.org.uk/news/update-cambridge-waste-water-treatment-plant [↩]
  11. Lib Dem Flyer, November 2021 [↩]
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Anglian Water Phase 3 Consultation coming soon – get involved!

sunset over diggers.

A lot has been going on in the last couple of months but now we have reached a very important stage.

Phase 3 Consultation

Everything Save Honey Hill does is aimed at derailing the application to relocate the plant to Green Belt at Honey Hill. Anglian Water has scheduled the Phase 3 Consultation for mid- to late-February. It will run for 8 weeks and all residents will have the chance to comment. Those comments will go to the Planning Inspectors; it is a real chance to get over to them our objections and, if the application is agreed, to lessen the effects on our communities.

So look out for a leaflet from Save Honey Hill telling you what we consider are the important issues and please do complete the consultation when Anglian Water delivers their leaflets (you will be able to do it online or on their form). They will contact 10,600 properties so there is a good opportunity to make our voices heard.

North East Cambridge Area Action Plan

We have tried to influence decisions on plans for North East Cambridge because that is the reason Anglian Water and Councils want the plant to move. We have attended meetings at SCDC and Cambridge City Council, written letters to councillors, Government ministers and MPs, been quoted in local newspapers and generally made a nuisance of ourselves. We think the decision by both councils to approve the proposals for NECAAP is premature; there won’t be a public consultation on it until after the Planning Inspector has decided on the sewage works relocation.

Engagement with Anglian Water

We are also in discussion with Anglian Water at their Community Working Group meetings alongside representatives of the four Parish Councils. Although our aim is to stop the relocation completely, we want to influence the best design if it happens. This includes odour control, screening and maintenance of the trees used, size and location of the stacks, carbon footprint, light pollution and impact on the villages. One of the main concerns is the site access. Option 3 is our preferred access for both permanent and construction traffic as a dedicated service road from the layby on the northern carriageway of the A14 between Junctions 34 and 35 will have less impact on traffic flow and the pedestrian and cycle path on Horningsea Road and less risk to children going to school. If Option 1, Junction of A14 with Horningsea Road, is chosen, then Option 1B is preferable as being less disruptive to traffic and hopefully less likely to encourage HGVs to use the village roads of Fen Ditton and Horningsea.

Next steps

Everyone can help by completing the Consultation when Anglian Water publishes it. State your objections and let Anglian Water and the Planning Inspector know what you think must happen to make the plant less of a huge industrial blot on our landscape.

Our website (and this blog post) will be updated with direct links to the consultation when it is publishes.

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Press Release: Anglian Water’s decision to put access for the proposed Sewage Treatment plant on Horningsea Rd..


To coincide with Anglian Water’s announcement on the access it has chosen to its proposed relocated Waste Water and Sewage Treatment Plant at Honey Hill, between Quy, Horningsea, Teversham and Fen Ditton.

Save Honey Hill is deeply disappointed in Anglian Water’s decision to choose Junction 34 of the A14 with Horningsea Road as the access for the proposed new sewage works despite unanimous support from all bodies consulted to go with the option of a dedicated road from the lay-by on the north side of the A14.

Our District and County Councillors, Parish Councillors and Member of Parliament all rejected the options of access from Horningsea Road and High Ditch Road.

Save Honey Hill objects to the access from Horningsea Road because:

  • it goes against Anglian Water’s professed intention of giving priority to the concerns of ‘host parishes’
  • ignoring this opinion makes the process of consultation appear to be a sham
  • the rationale for rejecting this option, as set out now, was never fully explained during the
    consultation
  • the road between Horningsea and Fen Ditton is a minor rural route (C210) which is already
    dangerously over loaded. To its load, this proposal would add all the traffic generated by 3-4 years of massive construction plus all the daily traffic in operation, including nearly two hundred trucks per day, carrying sewage sludge (from other plants) or the by-products of sludge, in and out of the works
  • there is a weight restriction on this road which, both during construction and operation, AW would be allowed to ignore
  • this plant, a piece of nationally significant infrastructure serving a population of over a quarter of a million, ought to be linked directly to an arterial road and not inflict its access or impose its presence unnecessarily on adjacent village routes
  • throughout the design process, as it has progressed, AW has ignored the possibility of pursuing an ideal design – so, for instance, the possibility of building a new plant beyond the Green Belt, where neither the setting of the City nor that of some of its necklace villages are harmed, has not been explored. In the same way, independent access is readily disregarded as a clearly widely preferred possibility
  • the A14, at the point where the access could be formed, at present accommodates a very long lay-by which is heavily used by HGV drivers taking a break. These drivers must slow down to enter the lay-by and pull out slowly and sharply to leave it. If this arrangement is considered acceptable, then an on and off pair of filtering slip roads solely dedicated to serving the plant would form a safe substitute. The engineering at this point is easy and economical with the road and the adjoining land being at the same level
  • such an access would be restricted entirely to traffic generated by the plant – so it would be little used when compared with standard A road junctions. There are examples of such limited access points serving maintenance and emergency traffic off the M11 north of Bishop Stortford and serving the new bio-fuel plant outside Baldock on the A505.

    • Save Honey Hill objections are against the relocation of the City’s Waste Water Treatment Plant in principle. However, they also insist that if it is to be sited at Honey Hill the impact on the communities affected should be absolutely minimised.

    Save Honey Hill 10/12/2021

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    Questions for Anglian Water on Jeremy Sallis’s Hot Seat Q&A

    Anglian Water are guests on the BBC Radio Cambridgshire Jeremy Sallis show on Monday 15th November between 10 and The Save Honey Hill group collated some questions from members and residents of the villages surrounding the proposed site of the relocated sewage works. The questions were emailed well in advance of the show. If they are answered then we will attempt to put Anglian Water’s reply here.

    Update. The Anglian Water Hot Seat Q&A was postponed due to COVID. 

    Here are the questions:

    Taking into account a motion passed by the House of Lords to place a new legal duty on water companies to ‘take all reasonable steps’ to prevent sewage discharges and the fact that the UK has some of the most polluted rivers in Europe, it would be expected that Anglian Water will design a 21st Century solution to avoid this problem. As they are hoping to build a brand new plant, it will need to be able to cope with greater rainfall, probably a larger site, with wetlands and reed beds. Not a small 22 hectare site surrounded by a bund. Will Anglian Water reconsider the design at Honey Hill due to public anger at the present low standards of water treatment?

    Horningsea resident.

    What does Anglian Water say about the fact that councillors have said that rather than being asked to move by Cambridge City and South Cambs District Councils, the relocation is of its choosing? If this is true, how then does it qualify as a Nationally Significant Infrastructure Project when Cambridge already has a fully-functioning sewage works and sludge treatment facility?

    Horningsea resident and Save Honey Hill campaigner.

    Is it good use of nearly a quarter of a billion pounds of taxpayer’s money (£227m) and precious Green Belt, replacing a sewage works with capacity till 2050 with a new sewage works with capacity till 2050?

    Horningsea resident and Save Honey Hill campaigner.

    What budget would be required to provide an appropriate long term solution for the City’s waste water and sludge treatment, instead of the cheapest solution with a move just a few fields along to a Green Belt location still on the edge of the city?

    Horningsea resident.

    Is it correct that the proposed plant relocation to a Green Belt location on the city edge is planned to have 146 HGV movements a day, including waste sludge being imported from as far away as Huntingdon and Ely? This doesn’t seem a very environmentally friendly solution for a new build!

    Horningsea resident.

    The carbon footprint of decommissioning the existing sewage works, building a new sewage works on Green Belt and then decontaminating the existing site ready for new building work, will be huge. Why is this being greenwashed?

    Fen Ditton resident.

    Given all the new housing planned for the area and that the chosen site of Honey Hill is still pretty much on the city’s boundary like the existing site, has Anglian Water been ambitious enough in its site selection? –

    Teversham resident.

    Given the huge amount of money already spent on this project before building has even begun, where will the rest of the money come from if the build exceeds its budget?

    Horningsea resident.

    When will we see the report of the Phase Two Consultation? It is important that we can view everyone’s comments before we go into the Regulation 19 Consultation in February 2022

    Save Honey Hill

    The proposed entrance for construction will be on Horningsea Road, a small but busy country road with a weight limit banning HGVs because it is considered unsuitable. It is also a cycling route well used by both school children going to Fen Ditton Primary School and other cyclists commuting in to town. What steps will Anglian Water take to ensure that my daughter (and the many other school children using this route) does not have to share her bike ride with these horrendous vehicles? When she arrives at school, how will she be protected from the dust and noise pollution from the construction works?

    Horningsea resident.

    What support is Anglian Water providing for the well-being and mental health of local residents who could not have reasonably expected this plant to move to the Green Belt near their homes? What compensation will be provided by AW for those who can demonstrate they have been affected as a result?

    Horningsea resident.

    How is it right that AW is receiving a fund of nearly a quarter of a billion pounds of public money to relocate a fully-functioning sewage works which was upgraded at a cost of approx. £22 million in 2015 (to future proof it!), when its Haslingfield plant, which discharged raw sewage 49 times in 2020, is being ignored?

    Horningsea resident.

    How does this move, which could be argued as unnecessary, help to address the climate emergency declared by the City and South Cambridgeshire councils when there are already sufficient housing allocations available elsewhere? Doesn’t this seem madness?

    Fen Ditton resident.

    Are the current site investigations being undertaken by Anglian Water all being funded through the £227 million Housing Infrastructure Fund grant, paid for by our taxes, including all the expert consultants who are putting together a significant case at great expense to obtain permission to re-build a fully operational plant in the Green Belt?

    Fen Ditton resident.

    Why has Anglian Water not made available for scrutiny their feasibility studies of alternative sites for their relocated Cambridge waste water treatment plant?

    Fen Ditton resident.

    Why were the shortlisted three sites so close to the existing Cowley Rd site? Why do we not know how much more it would have cost to have had a site which did not harm the setting of Cambridge and its necklace villages nor create a large ‘no-go area’ in the Green Belt close to where the city wants people to live, or a site where it might have been possible to partially sink the tallest structures?

    Fen Ditton resident.

    In order to qualify for government funding for the relocation, did Anglian Water have to produce a cheap proposal, never giving the community the option of a better or more ideal solution to consider?

    Fen Ditton resident.

    How strongly is Anglian Water pushing for a dedicated access off the A14 to the new proposed waste water treatment plant?

    Quy resident.

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    Greater Cambridge Local Plan First Proposals – North East Cambridge : What about the Green Belt?

    As reported in the Cambridge Independent1 the joint Council Leadership is promoting the new Greater Cambridge Local Plan First Proposals as having green credentials and an emphasis on protecting the Green Belt that surrounds Cambridge and the historical villages within it. The villages themselves and Green Belt designation has been identified in multiple Green Belt Studies commissioned by the joint Councils over the years as being essential to maintaining the character of Cambridge City. As specified by Lead Member for Planning on South Cambridgeshire District Council, Cllr. Hawkins2:

    “The Green Belt is a vital tool for protecting the unique setting of Cambridge City as well as protecting our villages from urban sprawl whilst maintaining their character and providing green corridors for bio diversity…It is only possible to make changes to the Green Belt if there is very strong evidence to justify it….”

    Many of the villages in the Green Belt and the historical listed buildings within them, have an additional layer of protection in being designated Conservation Areas. Planning protection of Conservation Areas extends beyond the specific boundary and includes adjacent land where a proposed development would have a detrimental impact on the setting, character and appearance of the Conservation Area.
    Despite the declarations of our Council Leadership there is a clear omission in the Greater Cambridge Local Plan First Proposals.

    The Local Plan nor the supporting Strategic Environmental Assessment address the direct consequences of the housing proposals for North East Cambridge, namely the relocation of Cambridge Waste Water Treatment Plant (CWWTP) into the Cambridge Green Belt.

    The proposed site for the relocation is in the Honey Hill area, within just 1.5km of the existing plant and 0.5km of three conservation areas: Fen Ditton, Baits Bite Lock and Horningsea. The proposed plant will be visible from all these areas which include multiple footpaths, national trails and other high quality public amenity land. This location jeopardises the National Trust’s Wicken Fen Vision, the area being the intended southern public access for the extended Fen Area, now to be within the odour zone of the proposed relocated CWWTP3.

    All conversations or implied meaning in reports that the relocation of CWWTP is to do with anything other than the Cambridge City and South Cambridge District joint Councils desire to build houses on the existing site and adjacent land are red herrings or smoke screens.

    There has been no reference to any requirement to increase capacity in Anglian Water’s public funding or planning application to date. Indeed, it is due to there being ‘no operational need to relocate’ that Anglian Water are legally unable to raise finance or charge its customers to cover the costs of building a replacement facility and applied instead for £227 million of public money to do so456.

    In 2016, £21 million was invested in the existing plant and was stated as having future-proofed the plant ‘for decades to come’. The Environmental Journal heralded the upgrade as ‘securing its standing as the eastern region’s green energy generating plant’78.

    Anglian Water in their letter to the Secretary of State seeking a Development Consent Order (DCO) state the operating capacity of the existing site has a population equivalent of 548,000 and that the proposed relocated site will operate at the same capacity9.

    The capacity of the integrated CWWTP has a population equivalent of 548,000……..
    The CWWTPR will operate at the same capacity as the existing CWWTP.

    Current plans to extend the CWWTP catchment area for waste water to include Waterbeach New Town, in the absence of the relocation, will be absorbed by the existing site creating, in Anglian Waters’ words, ‘significant embodied carbon reductions and operational efficiency.’

    The increased employment opportunities arising out of the proposed plans for North East Cambridge (NEC/NECAAP) are also not attributable to the relocation of CWWTP to the Green Belt. The figure of 15,000 jobs specified in the Greater Cambridge Local Plan First Proposals are the same as those identified in the Issues and Options Consultation (2014) informing the existing South Cambridgeshire District Council (SCDC) Local Plan (2018)10 without the requirement of the CWWTP relocation. As the market requires, new office buildings and R&D facilities in the area within the Cambridge Science Park, St John’s Innovation Centre and Cambridge Business Park will continue as at present.

    The implications of the relocation of CWWTP for the benefit of housing development on carbon expenditure is huge, including embedded carbon and carbon emissions.

    Carbon expenditure in the relocation, to fulfil the Councils’ desire to build houses on the existing site, should be calculated and off set against any carbon efficiencies declared to be gained in a new plant and assessed against the Local Plan policy on Carbon Expenditure/Omissions.

    Carbon expenditure will include: the decommissioning of a fully operational and future-proofed plant within just 1.5km of the existing one; the decontamination of land to make it fit for housing; the construction of an entirely new plant in undeveloped land; extensive tunnelling to carry waste that feeds into the existing plant across the river, up the hill to the new one and back again to the River Cam; and construction traffic over a four year period.

    There is a regulatory requirement that the Strategic Environmental Assessment (SEA) used to inform the direction of the Local Plan must set out the likely significant effects of implementing the plan, that authorities and the public are given an effective opportunity to express their opinion and that the report includes information that may be required to do so11

    The omission of the relocation of CWWTP as a direct consequence of the Councils’ housing development plans for North East Cambridge in the SEA does not enable our elected Council representatives or the residents of Cambridge City or South Cambridge District to effectively and objectively assess the effects of the Local Plan on the Green Belt or other related Local Plan policies.

    Notably, without inclusion of the proposed CWWTP relocation site in the Local Plan, the Councils are not fulfilling regulatory requirements and the planning proposals for North East Cambridge cannot be measured on a par with other development proposals in the Local Plan.

    Anglian Water are pursuing a national planning pathway (Development Consent Order, DCO) for the relocation; timing of the Greater Cambridge Local Plan strategy accounts for this.

    If the DCO planning process is put forward by the joint Councils as a reason not to include the effects the housing proposals for North East Cambridge will have on the Green Belt, and it is not to be assessed against the Local Plan policies on a par with other proposed developments, then the proposals for North East Cambridge should be removed from the Local Plan until such time as they can.

    Jennie Conroy
    Resident of Fen Ditton
    On behalf of Save Honey Hill Campaign – 25-09-2021

    1. 1st September 2021 https://www.cambridgeindependent.co.uk/news/interactive-map-see-the-sites-where-nearly-49-000-new-homes-9214197/ [↩]
    2. Cambridge Independent, 2nd September 2021 https://www.cambridgeindependent.co.uk/news/anthony-browne-mp-condemns-49-000-home-greater-cambridge-loc-9214388/ [↩]
    3. National Trust Wicken Fen Vision (2009)
      https://nt.global.ssl.fastly.net/wicken-fen-nature-reserve/documents/wicken-fen-vision-strategy-document.pdf [↩]
    4. letter from Environment Agency 22 March 2019 to GCP – “CNFAAP Issues and Options Consultation”. p2 [↩]
    5. https://cwwtpr.com/wp-content/uploads/2020/11/CWWTPR-Phase-One-Consultation-Summary-Report.pdf [↩]
    6. HIF Award of £227 to unlock 9000 homes – Chancellors Autumn 2020 Statement/Spending Review p38 [↩]
    7. Environment Journal July (2016)
      https://environmentjournal.online/articles/cambridges-water-recycling-centre-looks-future/ [↩]
    8. “Water Briefings” trade journal 2014 https://www.waterbriefing.org/home/company-news/item/9110 [↩]
    9. Request for Direction by the Secretary of State pursuant to Section 35 of the Planning Act2008 – The Cambridge Waste Water Treatment Plant Relocation Project 1st Dec 2020 [↩]
    10. South Cambridgeshire District Council (SCDC) Adopted Local Plan (2018)
      https://www.scambs.gov.uk/media/17087/south-cambridgeshire-adopted-local-plan.pdf [↩]
    11. Greater Cambridge Local Plan:
      First Proposals
      Sustainability Appraisal       [↩]
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    Save Honey Hill’s response to the Phase 2 Consultation

    Here is the official response from the Save Honey Hill group to the Phase Two consultation of the Cambridge Waste Water Treatment Plant Relocation proposal (CWWTPR). The response has been sent to Anglian Water and they have confirmed receipt.

    The consultation ends tomorrow, but it’s not too late to add feedback. Even if you have submitted a response using Anglian Water’s form, they will still accept emails and letters. Anglian Water have confirmed these will be counted and accepted. Their interactive map will also be accepting comments and “likes” up until the end of tomorrow. It only takes a few minutes to go like comments you agree with. It only takes a few minutes more to enter comments about various parts of the proposal.

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    Water and sewerage companies in England: environmental performance report for 2019

    If you think the UK’s water companies can be trusted to manage greenbelt and protect chalk streams and drinking water aquifers from pollution, then read this report from the Environment Agency published last year on pollution incidents from water companies (Anglian Water and Thames Water were responsible for over 50% of such incidents).

    Then read how Southern Water have just been fined £90 million for years of deliberately disposing of billions of litres of raw untreated sewage into the sea off the North Kent and Hampshire coastlines, to avoid paying costs of upgrading infrastructure.

    He said the company had a history of criminal activity for its “previous and persistent pollution of the environment”. It had 168 previous offences and cautions but had ignored these and not altered its behaviour. “There is no evidence the company took any notice of the penalties imposed or the remarks of the courts. Its offending simply continued,” he said.

    Finally why not look at DEFRA’s Magic Maps website that shows the risk of groundwater contamination below where Anglian Water are intending to relocate the Sewage Works.

    HoneyHill MagicMapsGroundwaterVunerability

    Worried?