- The plan to develop a brown-field site in North-East Cambridge is leading to the imposition of a new sewage works on Green Belt land at Honey Hill; they are browning a Green Belt site in order to refresh a brown-field site! This is wrong and contradictory.
- £227m of taxpayers’ money is being granted to Anglian Water to allow the North-East Cambridge site can be fully developed; but there is no operational reason to move the works (which recently received a £21m upgrade1 ), and Central Government didn’t know – when it made its decision – that these funds would be used to despoil precious Green Belt land.
- Since that decision was made there have been changes that justify taking time-out to reconsider the fundamentals, eliminating the need to spend that £227m and saving the Green Belt from being blighted with digester towers, HGV traffic movements, and light pollution.
- Covid and Brexit may have reduced the pressure to over-develop North-East Cambridge; a less ambitious plan would remove the need to transplant the sewage works.
- Meanwhile, a “Call for Sites” in the emerging Greater Cambridge Local Plan has uncovered an alternative solution to future housing needs … at Cambridge Airport.
- All is not lost! There is an opportunity for local communities and politicians to stop the damage caused by these parallel plans – for North-East Cambridge and for the sewage works at Honey Hill – through emerging Greater Cambridge Local Plan.
It is incredible, a Brownfield site being put forward for housing development at the expense and ruin of high quality Green Belt. Anglian Water has selected a Site Area in the vicinity of Honey Hill as the place to relocate Cambridge Waste Water Treatment Plant (CWWTP). Anglian Water state they are working in partnership with councils to relocate in order to release the land of the existing CWWTP; ‘unlocking the potential’ for the regeneration of North East Cambridge creating employment and new homes2.
Planning policy encourages and endorses the use of Brownfield sites for housing development, in the first instance as a means to protect against the urbanisation and industrialisation of rural areas including and most particularly, designated Green Belt3 . In this case there are two planning proposals under development running in parallel: housing development at scale in North East Cambridge on the current site of Cambridge Waste Water Treatment Works, via the North East Cambridge Area Action Plan (NECAAP)4 and the re-siting of Cambridge Waste Water Treatment Plant (CWWTPR) to the Honey Hill area, via a Development Consent Order. The planning policy supporting the former, the use of Brownfield sites in the first instance to protect Green Belt, is contradicted by the latter i.e., the removal and industrialisation of high quality Green Belt. These two proposals as they stand cannot be considered or viewed independently, they are symbiotic, fused together; one cannot exist or happen without the other. Developing the Brownfield Site on the proposed scale has devastating consequences on this area of Green Belt.
However, Anglian Water spokespersons have stated that there is no operational reason or operational requirement for Anglian Water to move site, indeed when £21 million was invested in 2016, it was reported: ‘The recent 21m upgrade to Anglian Water’s water recycling centre in Cambridge not only future-proofed the site to serve residents for decades to come, but also secured its standing as the eastern region’s green energy generating giant’5. In addition, since the initiation of NECAAP and Anglian Water undertaking the process to identify a new site, an alternative option to accommodate the need for a principal housing development within Cambridge City has been identified within the emerging Greater Cambridge Local Plan at no cost to the Green Belt67.
A Call for Sites identified Option 2, Cambridge Airport as being available from 20286. This option both removes the need to destroy high quality Green Belt, and the need to over develop Cambridgeshire Villages. The latter often mooted as the only alternative to re-siting CWWTP.
In keeping with South Cambridgeshire District Council (SCDC) adopted Local Plan ( 2018) and original land area identified, regeneration of the area with mixed development in the North East Cambridge area could still be accommodated within Option 2 but on a less ambitious scale, such that the CWWTP could remain where it is. This would not exclude extending the area of North East Cambridge as per NECAAP to include the Science Park but would limit the amount of housing. It is of note, of those who participated in Anglian Water’s digital platform during their Phase 1 Public Consultation on Site Selection, 53% either did not support the relocation or strongly opposed the relocation8
High Quality Green Belt
There is no doubt about the quality of the Green Belt within the Site Area Anglian Water have selected including the environmental cost, impact on historical assets and loss of public amenity value should the re-siting of the CWWTP in the Honey Hill area be pursued. All aspects of which relate to the purpose of Green Belt9.
The Site Area identified for relocation of CWWTP in the vicinity of Honey Hill is extensive at 127ha10. The A14 shapes the southern boundary, it extends down from Honey Hill to the B1047, runs along the length of the B1047 then behind the conservation area, residences and village of Horningsea. The exact location of the plant within the Site Area is at this time unknown, but is extensive and comparable on the illustrative maps with the scale of the existing plant11. The plant area can be seen to be equivalent in size to the village of Horningsea and in such close proximity, likely to swamp it. The Site Area lies within land identified for the National Trust Wicken Fen Vision which will form the southern boundary on the edge of Cambridge and access gateway for residents of Cambridge City and surrounding Villages12. The Site Area is within reach and visible from an extensive network of Public Rights of Way, including National Walking and Cycle Ways and the River Cam corridor.
There are two SSSI’s in the surrounding area, Quy Fen and Wilbraham Fen, each of which have waterways that are at risk of contamination from the Plant13 and associated HGV traffic, of which 140 HGV vehicle movements are estimated a day14
The Site Area is within reach and visible from National Trust Land and their permitted footpaths around Quy Fen. The National Trust’s Anglesey Abbey and Grounds are within 1.2km of the Site Area, and are on Historic England’s’ register of Historic Parks and Gardens of special historic interest.
The Wicken Fen Vision12 is supported and endorsed throughout the council authorities and is recognised as a substantial and important contribution to green infrastructure in the area. It is included as a strategic element of green infrastructure in the adopted Local Plan for both South Cambridgeshire District Council (2018)15 and East Cambridge District Council (2015)16. It is identified as a target network area in the Cambridgeshire Green Infrastructure Strategy17.
The area has recently been identified by The Cambridge Nature Network18, referenced as Wicken Fen (South), as one of five Priority Network Areas encircling Cambridge to ‘create a network of interconnected habitats, natural greenspaces and accessible countryside , that will support a sustainable future for Cambridge.’ Further, it is stated it will assist towards Natural Cambridgeshire’s Doubling Nature aspirations19 and achieve the 30% land dedicated to nature required for a coherent and functioning ecological network within the Priority Areas18. It is anticipated the Cambridge Nature Network will inform the emerging Greater Cambridgeshire Local Development Plan (op.cit.) reflecting the most recent planning policy3 with an increased emphasis on green aspirations, green infrastructure and protection of Green Belt.
The Honey Hill area selected by Anglian Water lies in the Eastern Fen Edge LCA20. This area is low lying with wide open fen landscapes making it impossible to fully mitigate the visual impact of a large scale industrial development including a number of digester towers up to 26m high21. The area is noted for its tranquillity and good networks of public rights of way including national trails20. The Cambridge Green Belt Study (2002)22 references the villages of Fen Ditton, Horningsea and Stow cum Quy as forming part of a ‘necklace of villages’ separated by rural gaps on the edge of Cambridge that form an important aspect of the setting of the City of Cambridge and its fundamental rural character. The later Cambridge Inner Green Belt Study20 notes these villages as having retained their rural setting with a clear landscape separation between them and the City of Cambridge; the villages lit at night, but the landscape relatively dark. The 2015 Study concluded that it is unlikely any development within this sector could be accommodated without substantial harm to Green Belt purposes (op.cit.)
There are three conservation areas: Fen Ditton, Baits Bite Lock and Horningsea within 0.4-0.5km of the CWWTPR Site Area and a number of historic listed buildings within as little as 0.5-0.8km of the Site Area, including Biggin Abbey a Grade II* residential property. The drive way to the property, being on Horningsea Rd, lies within 200m of the Site Area, the property itself 0.5km distance. This, along with many listed buildings will be visual receptors of the Site Area which, contrary to planning policy will directly impact on the character, appearance and setting of these Historical Assets.
Within the Parishes of Fen Ditton, Horningsea and Stow cum Quy there are 78 listed buildings : 66 Grade II ; 11 Grade II* ; 1 Grade I all of which will be impacted in terms of change in landscape character and setting, themselves contributing to the quality of the Green Belt and purpose of protection23.
Historical Assets relating to ancient archaeology are known to be extensive in the area, remnants of Fleam Dyke for example exist on High Ditch Rd in the vicinity of a proposed new access route to the CWWTPR.
Anglian Water Site Selection Assessments
Green Belt Study
The Green Belt Study undertaken on behalf of Anglian Water to facilitate the site selection evaluates the Site Areas against the purposes of Green Belt as identified in National and Local Policy21. It concludes, using a scale of poor, fair and good, that Site 3 (Honey Hill area) is an area of Green Belt that makes a good contribution to the purposes of the Green Belt and that development on this site, in comparison with the two others under consideration at the time, would have… ‘the most adverse effects on landscape character, visual amenity and on the openness and purposes of the Green Belt.’(pg30 ) .
The CWWTPR Green Belt Study21 identifies in relation to the purpose of Green Belt the development of the site would : introduce large-scale development into a rural area; contribute to the unrestricted sprawl of large built-up areas, due to the absence of built development in this location; result in encroachment on the countryside due to the introduction of a large infrastructure feature into the countryside; reduce the landscape gap between Horningsea and Stow cum Quy; be apparent for Stow cum Quy, Lode, Horningsea and Fen Ditton, detracting from the rural setting of these historic villages each with a high proportion of historic buildings ; be close to protected landscapes and habitats; be in an area with a high recreational value, marked by the proximity to several SSSI sites PROW and the gardens of Anglesey Abbey which are on the Historic England’s’ register of Historic Parks and Gardens of special historic interest.
The Environmental Assessment undertaken on behalf of Anglian Water (CWWTPR Environmental Assessment 2021) to facilitate the site selection concludes:
‘ A development on Site 3 would result in the most widespread landscape and visual effects owing to the site location being in open and undeveloped countryside.’ B.2.51
‘The WWTP would lie in the National Trust’s Wicken Fen Vision area and would detract from the aims of the vision, a strategic element of green infrastructure on SCDC and East Cambridge District Council’s development plans. Lighting on the site would introduce a large lit area into an unlit area. Tranquillity in the area would be further reduced by increased activity and traffic generated by the operation of the site.’ B.2.49
‘….effects would arise from the introduction of a new WWTP with large scale structures up to 26m high, access roads, hard standing, fencing and lighting , into the rural landscape and existing views of farmland….tranquillity would be reduced by the increase in noise, activity and movement in the area….. Effects would be largely limited to 5km of the site.’ B.2.44
‘Visual Receptors in Stow cum Quy, Horningsea, at Biggin Abbey, on Horningsea RD and on many PRoW in the area wold have a clear or partially filtered views of the new structures.’ B.2.41
‘The scale and industrial appearance of the structures would be wholly uncharacteristic of the existing built development in an area which currently comprises small villages and isolated farmhouses.’ B.2.49
‘A large-scale new infrastructure development on site area 3 would result in a substantial change to the character of the rural landscape in this location.’ B.2.49
The NECAAP has been steaming ahead since the Adoption of the SCDC 2018 Local Plan, no doubt spurred on by the application for central government funding to facilitate the re-siting of Cambridge Waste Water Treatment Works. In 2019 the site area was extended to include Cambridge Science Park24 along with an ambitious housing target of 8,000 homes and the creation of 20,000 jobs via further development of office space in the Science Park area and new retail and leisure facilities25. Housing Infrastructure Funding (HIF) of £227 million was secured in 201925. Anglian Water have since been able to proceed with the process of identifying an alternative site via a site selection study, the final site announcement of Site 3 (Honey Hill area) was made in January 2021 along with the publication of supporting documents26. Identified as a development of national significance the planning process is via a Development Consent Order (DCO). The time-table for Anglian Water’s submission being Summer 202224.
Given the contradictions of these two planning proposals, the removal of Green Belt in order to build on Brownfield, there does seem to be a flaw in the planning process. At the time of the application for HIF funding and success of the application, it was not known by the Greater Cambridge Partnership or NECCAP where the site selection by Anglian Water would be, thus the whole consequences of an increased ambition of extending the NECCAP site area, higher housing and employment capacity were unknown. Further, the arrival and subsequent impact of COVID on the demands for office space, retail outlets and high density housing was not known, nor the outcome of BREXIT and potential impact on employment opportunities in Cambridge and subsequent future housing demand.
Despite the cost to the public purse (£227million HIF funding) to pursue the re-siting of the CWWTP, all the changes in circumstances above and remaining uncertainties, both planning processes are continuing at pace on their own tracks in parallel with no apparent pause, time for reflection and re-think. It would seem the fate of our Green Belt in the area of Honey Hill and the opportunities for further enhancement and development of green infrastructure above, is not in the hands of our local councils and policy makers but rests with independent examiners and the Secretary of State.
However, all is not lost. The emerging joint local plan, Greater Cambridge Local Plan does provide this opportunity through its Options appraisal and development process.
Emerging Greater Cambridge Local Plan
The Greater Cambridge Local Development Scheme and time-table was published in July 2020 and The Greater Cambridge Local Plan Development Strategy Options- Summary Report and supporting documents in November 2020. The latter presents a series of Development Options and scenarios to meet the projected housing needs of the Greater Cambridge area up to 2040. The development Options put forward have been tested against a series of criteria and reflect the most recent housing policy including the need for a flexible local plan that is able to respond to rapid change, is viable and reasonable.
‘For Local Plans, the identification and subsequent testing of strategic options through a Sustainability Appraisal is a central requirement of legislation and national policy , councils must ensure that all reasonable alternatives have been identified and that they are reasonable , realistic and relevant , taking into account the objectives and the geographical scope of the plan.’ Pg.1
The Greater Cambridge Local Plan Development Strategy Options (Nov 2020) report makes it clear:
‘At this stage the Councils have not reached any view on the preferred approach for the new Local Plan’ (pg. 1).
There are 2 Options presented as viable and timely i.e. within 5 years, to meet the requirement of a principal housing development within the City boundary: Option 1 , the North East Cambridge area, as per NECAAP and Option 2 , Cambridge City Airport. Both options also list the other as a supplement to the principal development i.e. In the event of Option 2 being chosen for the principal housing development, North East Cambridge could still be developed, but at a lesser scale, in that case preventing the need for the CWWTP to relocate and, based on the Site selected by Anglian Water, the consequential removal of Green Belt. Option 2 thus, reflecting the revised National Planning Policy Framework (NPPF)9 where the generation of green infrastructure and the enhancement and protection of existing Green Belt has greater emphasis in National Planning Policy.
At the time of the publication of the GCLP Development Strategy Options (Nov 2020) report it was known that Anglian Water had reduced the Site options for relocation down to three and that each of these was within a few miles of the existing plant and in the Green Belt. However, it was not known which of the three sites Anglian Water would select.
The next stage of the planning process for the emerging Greater Cambridge Local Plan is the development and production of a Preferred Option report for Public Consultation in summer/autumn 2021 (GCLP Development Scheme 2020).
The Greater Cambridge planning team will continue to collate evidence and undertake studies to inform the Preferred Option, this includes completion of a Heritage Impacts study (GCLP Development Strategy Options 2020).
‘The interim evidence studies and other evidence to be prepared will continue and feed into the next steps to develop the preferred approach in terms of the level of growth to plan for, and where development should be located, including the sites that should be chosen.’ Pg. 1
It is here that the opportunity to review the now known implications of the site selection of the Honey Hill area by Anglian Water for relocation can be fully digested and reviewed at a local level reflecting the current, most up-to date planning policy and the new circumstances for Cambridge, many of which, in the light of COVID and BREXIT, remain uncertain and or unknown.
The worst outcome of NECAAP would be to pursue the re-siting of CWWTP into the Green Belt in the Honey Hill area within the next few years, with all the cost to the public purse (£227million), the permanent cost to the environment , heritage assets and value of public amenity land as above, to find over the next 20 years the estimated employment opportunities, demands for office space and retail outlets are not realised and the anticipated scale of development and necessity for CWWTP to have moved are not realised.
The alternative that has arisen, to place the principal housing development on the Cambridge Airport site, in keeping with current national planning policy (NPFF 2019), enables flexibility and response to change over an extended period of time and the development of green infrastructure on the airport site. Further, this would be without the expense to the Green Belt, the inherent costs above and a reduced carbon expenditure as a result of the embedded carbon costs that would come about through de-commissioning of the existing CWWTP, decontamination of the land sufficient for housing and the building of a new plant inclusive of new access roads.
It is essential the two planning proposals NECAAP and the DCO for re-siting The Cambridge Waste Water Treatment Works are brought together at a local level via the emerging Greater Cambridge Local Plan in order that the now known consequences of NECAAP in its current form on our Green Belt can be reviewed in earnest, before decisions are made that will make permanent and irreversible changes within just a few years.
Jennie Conroy – Resident of Fen Ditton, Cambs
- “Water Briefings” trade journal 2014 https://www.waterbriefing.org/home/company-news/item/9110
- CWWTPR Stage 4 Main Report (2021) –
- National Planning Policy Framework (NPPF) (2019)
- North East Cambridge Area Action Plan (NECAAP):
- Environment Journal July (2016)
- Greater Cambridge Local Development Strategy Options (2020)
- Greater Cambridge Shared Planning – Call for Sites https://consultations.greatercambridgeplanning.org/form/40306
- CWWTPR Phase One Consultation Summary Report (2020) https://cwwtpr.com/wp-content/uploads/2020/11/CWWTPR-Phase-One-Consultation-Summary-Report.pdf
- National Planning Policy Framework (NPPF) (2019)
- CWWTPR Stage 4 Main Report 2021 https://cwwtpr.com/wp-content/uploads/2021/01/CWWTPR-Stage-4-Final-Site-Selection-Main-Report.pdf
- CWWTPR Phase One Consultation https://cwwtpr.com/wp-content/uploads/2020/07/Phase-one-consultation-leaflet.pdf
- National Trust Wicken Fen Vision (2009)
- CWWTPR Environmental Assessment (2021) https://cwwtpr.com/wp-content/uploads/2021/01/CWWTPR-Stage-4-Final-Site-Selection-Appendix-B-Environmental-assessment.pdf
- CWWTPR 2021-Site-Announcement-Webinars-FAQ-Summary Q1 Traffic and Transport section https://cwwtpr.com/wp-content/uploads/2021/03/CWWTPR-Site-Announcement-Webinars-FAQ-Summary.pdf
- South Cambridgeshire District Council (SCDC) Adopted Local Plan (2018)
- East Cambridge District Council Adopted Local Plan (2015)
- Cambridgeshire Green Infrastructure Strategy (2011)
- Cambridge Nature Network (March 2021)
- Natural Cambridgeshire (2019)
- Cambridge Inner Green Belt Study (2015)
- CWWTPR Green Belt Study 2020:
- Cambridge Green Belt Study (2002):
- South Cambridgeshire District Council Planning Maps:
- Greater Cambridge Local Development Scheme (GCLDS) 2020
- Draft North East Cambridge Area Action Plan (2020):
- CWWTPR Document Library : https://www.cwwtpr.com/document-library