Greater Cambridge Local Plan – 2021 Consultation

Here are the Save Honey Hill groups condensed notes on our full response to the Greater Cambridge Local Plan 2021 Consultation. You may find this useful in forming your response.

If you do not have time to do a full response, then you can also complete a quick questionaire.

Closing date Monday 13th December

1. Policy GP/GB Protection and Enhancement of the Cambridge Green Belt

The relocation of the CWWTP to Honey Hill is contrary to Policy BG/PO: Protecting open spaces (p183 pf Greater Cambridge Local Plan First Proposals) which states that a Local Green Space is required to be demonstrably special to a local community and hold a particular local significance. Honey Hill is important to the local communities of north east Cambridge, Horningsea and Fen Ditton where it is used for recreational purposes by walkers, runners, cyclists and equestrians and is good quality agricultural land with rich mixture of fauna.
Honey Hill is flat fenland close to the SSSI at Quy Fen and therefore the relocation of the CWWTP will change that character.

2. Policy S/CE: Cambridge East

The delivery of only 2,900 homes out of the proposed 7,000 by 2041 appears lacking in ambition. Of those 2,900 homes preference should be given to affordable and social housing to ensure housing available for the employment mix proposed. The council should support Marshall Holdings to bring forward their relocation of airside activities to Cranfield Airport to release brownfield land for housing and employment development, especially that of affordable housing which is a priority in this part of Cambridge. The mix of employment uses needs to be scrutinised in the light of post-Covid working and living conditions.
It will be important to retain the individual character of Teversham village and prevent encroachment on the Green Belt. The maintenance of the green corridor widening out at Teversham to provide a green separation as adopted in the 2010 Local Plan must be retained. The proposal for relocating Cambridge Waste Water Treatment Plant to an area of unspoiled Green Belt at Homey Hill between the villages of Horningsea and Fen Ditton does not accord with the policy’s intention to provide additional wildlife habitat as part of Eastern Fens green infrastructure initiative. It is also contrary to Policy GP/GB
The policy proposals should not depend on complete integration with or extension to the proposed North East Cambridge Area Action plan which predicates on the relocation of Cambridge Waste Water Treatment Plant to an area of Green Belt at Honey Hill which is the subject of a Development Consent Order.
It is recommended a more ambitious target of 4,000 homes during the plan period . This could be achieved with forward planning prior to Marshalls final departure. Ensuring protection and a green separation of dwellings from Teversham village is important. Opportunities to link cycle ways across Coldhams Common, through the airport and out towards National Cycle route No.11 & National Trails eg Harcamlow Way should be fully optimised as part of the development plan – Enabling safe foot-cycle access to SSSI Quy Fen; SSSI Wilbraham Fen and wider network of surrounding PRoW’s.

3. Policy S/NEC: North East Cambridge P54

Not supported. The area is described as a significant brownfield site. This is not correct as it is occupied by commercial buildings. It can only become brownfield if vacated by relocating the Cambridge Wastewater Treatment Plant to Honey Hill, an area of green belt, and therefore contrary to Policy GP/GB Protection and Enhancement of the Cambridge Green Belt. The policy also fails to take into account the changed working and living conditions resulting from the Covid 19 pandemic. The increased densification also appears to be contrary to Policy GP/GB. As the policy states that only 4000 dwellings will be accomplished during the local plan period, and there is no operational need to relocate the plant, the relocation of the plant and the consequential damage to the Green Belt, it’s not necessary and the North East Cambridge Area Action Plan and this policy should be reconsidered.
Greater Cambridge Shared Planning, in response to the CWWTP Scoping Report, has stated they would like to clarify that the relocation of the Cambridge WWTP is not a “requirement” of the North-East Cambridge Area Action Plan and must not be referred to as such Page 6 Scoping Opinion.
– Cambridge Airport now presents as a realistic alternative for major housing development on brownfield
– A case has been made under S/JH to reduce the housing Growth Option from Maximum + (11,500 additions required) to the Minimum (3000 additions required) or Medium range (8000 additions required)
– Pursuing housing development at scale in North East Cambridge as a result of the requirement of the relocation of CWWTP to fulfil the S/NEC Policy and the site selected by Anglian Water to do so, will require the introduction of an industrial plant into an area of open Green Belt , where development has been identified by the First Proposals’ Green Belt Study (2021) as bringing about ‘very high harm’. The area is within close proximity to three conservation areas and villages; green infrastructure and numerous historical assets. The historical setting of Cambridge will be impacted and there will significant negative environmental effects impacting on local residents and wider users of the area. The proposed relocation arising from the S/NEC Policy will be contrary to Policies:

Climate Change:

CC/NZ – Carbon expenditure, emissions, and embedded carbon to decommission a fully operational CWWTP and decontaminate site and build new plant within 1 mile of existing inclusive of transfer tunnels, HGV traffic etc., should be factored into carbon cost of fulfilling S/NEC Policy
CC/CS – decommissioning and building a new Waste Water Treatment Plant on prime agricultural land as a means to fulfil S/NEC Policy is in contrary to CC/CS

4. Policy S/SB: Settlement boundaries P50

The Local Plan (LP) states that it will include settlement boundaries around settlements, identifying areas that are considered to be part of the settlement for planning purposes. However, it fails to include, or refer to the area between Fen Ditton and Horningsea known as Honey Hill despite the fact that building a commercial development there extends the building capacity of North East Cambridge as described in the proposed North East Cambridge Area Action Plan.

5. S/JH: new jobs and homes P24

Assessment of housing and employment needs were made before Brexit and before the Covid-19 pandemic. We suggest that these should be re-assessed. Housing aspirations have changed and major conurbations are no longer so attractive. The impact on carbon expenditure, water use and flood risk due to ground cover should be assessed in the light of climate change.
Policy S/JH: New Jobs & Homes
The development targets for housing in Greater Cambridge are over ambitious in the plan period and bring a high level of risk to Greater Cambridge and the Vision and Aims of the Local Plan .
Minimum or Medium Growth Option can be justified on the grounds of:
This high growth strategy may fail if sustainable solutions do not come to the fore in a timely way and the attractiveness of Cambridge for homes and business is eroded. The impact of this unprecedented high growth strategy already in progress and committed to needs to be evaluated before it is added to further. The Aims of the Local Plan : ‘Wellbeing & Social inclusion’ and ‘Great Places’ are of particular relevance and at risk here.
Changes in working practices post COVID to home working and reduced daily commutes now widely recognised for a number of industries, particularly the tech industries, to be permanent. Thus, reduced CO2 emissions for existing and future forecast employees and reduced demand for housing close to work.

6. Policy S/EOC: Other existing allocations on the edge of Cambridge P94

Policy needs clarifying. While Policy S/CE Cambridge East is shown on the map (page 94) there is no reference to the either the housing or employment afforded by S/CE in the descriptions. It is important to include these developments to prevent encroachment on the Green Belt and to retain the individual character of Teversham village.

7. Policy S/LAC: Land allocations in Cambridge P70

Agree in principle

8. Policy CC/NZ: Net zero carbon new buildings P145

Agree in principle. However, the policy direction is towards taking into account the whole-life carbon emissions which are defined as emissions associated with constructing buildings. This needs to be expanded to include the carbon emissions associated with decontamination and demolition of existing buildings on the site, such as at the current Cambridge Waste Water Treatment Plant. This should include the carbon expenditure of Heavy Commercial Vehicles (HCVs) used to transport demolished building materials and the disposal of such materials with their embodied carbon.
Carbon expenditure, emissions and embedded carbon to decommission fully operational CWWTP and decontaminate site and build new plant within 1 mile of existing inclusive of transfer tunnels, HGV traffic etc., should be factored into carbon expenditure associated with fulfillment of S/NEC Policy

9. Policy CC/DC Designing for a changing climate P152

This policy sets out to to take account of changing climate, such as heat waves and flash flood, when designing developments but refers only to new dwellings for low overheating risk. It should be expanded to include large industrial developments such as the Waste Water Treatment Plant proposal to relocate to Honey Hill, especially the office block and visitor centre. More detail is needed to ensure such commercial developments do not suffer from or contribute to flood risk after prolonged periods of rain or flash flooding and their operation does not contribute to released heat production.

10. Policy WS/MU: Meanwhile uses during long term redevelopments P196

Endorse in part. Care must be taken to prevent meanwhile use on sites proposed on Green Belt while waiting for consents. Such use would be incursion into the Green Belt and contrary to Policy GP/GB Protection and Enhancement of the Cambridge Green Belt.

11. Policy GP/HA: Conservation and enhancement of heritage assets p218

Relocation of CWWTP to Green Belt is in contravention of this policy. Views within and out of conservation areas (Horningsea, Quy and Fen Ditton) will be damaged.
Greater Cambridge Green Infrastructure Opportunity Mapping Baseline Report (Land Use Consultants) November 2020 (greatercambridgeplanning.org)
Fig 6.2, Cultural Heritage, p46 – this map shows conservation areas and listed buildings encircling the proposed site of the CWWTP on the pristine Green Belt between Fen Ditton, Stow cum Quy and Horningsea.
These include: Biggin Abbey, Baits Bite, Anglesey Abbey.
Size of the development, height of the development, industrial nature of the development dwarfs heritage assets. Impact intensified by open nature of the landscape between the conservation areas.
While the assessment documents, along with the initial baseline study, offer a methodical approach to the assessment, they are fundamentally flawed as they do not consider the consequential land take required for relocation of the Waste Water Treatment Plant (WWTP) currently proposed for the Green Belt.
In order to deliver the intent of the Local Plan in considering land allocation, use and forward planning these assessments should be reconsidered taking into account the consequential Green Belt land take associated with the North East Cambridge development / WWTP relocation and re-classified accordingly.

12. Policy CC/FM: Flooding and integrated water management 155

Agree with this Policy.

13. Policy CC/RE: Renewable energy projects and infrastructure p158

Agree in principle.

14. Policy CC/CE: Reducing waste and supporting the circular economy p161

Agree in principle. Should include detail on how to how to reduce the impact of carbon footprint of HGVs.

15. Policy CC/CS: Supporting land-based carbon sequestration p164

The proposed CWWTP relocation, has not been included in Policy S/EOC: Other existing allocations on the edge of Cambridge.
Fulfilment of S/NEC Policy is contrary to this: decommissioning a fully operational and future proofed CWWTP and relocating to prime agricultural land.

16. Policy BG/GI: Green infrastructure p172

Figure 54 shows a map of proposed strategic green infrastructure initiatives. Area 4 is described as Enhancement of the eastern fens. This appears to contradict the proposed CWWTP relocation to part of that area. The policy needs clarification as it requires all new development to help deliver or contribute to support delivery of the green infrastructure strategic initiative objectives. Just putting a development on an area of green belt contradicts this principle.

17. Policy BG/PO: Protecting open spaces p183

Agree with this policy in principle. However, the achievement of Policy S/NEC: North East Cambridge, appears to contradict this policy as the development on Cambridge North East Area is predicated on the relocation of the Cambridge Waste Water Treatment Plant to an area of Green Belt.
Supported: Note: Fulfilment of S/NEC Policy through relocation of CWWTP to the Green Belt is contrary to this Policy

18. Sustainability Assessment

Sustainability Assessment – Comments
The single driver behind Anglian Water (AW) pursuing a relocation of the CWWTP is the request from the joint Councils for AW to test a viable alternative site to fulfil the Councils’ vision for North East Cambridge as represented in the area action plan NECAAP, adopted by Council into the emerging Greater Cambridge Local Plan First Proposals Policy S/NEC. Both plans have been developed with the assumption CWWTP will relocate, but neither are dependent on it (S Kelly Nov 2021). Despite this, neither the SA nor SEA in either plan identify or assess the significant effects the relocation will have on the site identified by AW as a ‘viable’ alternative within the Greater Cambridge area.
The existing CWWTP underwent extensive investment in 2016, at the time it was described by the Environment Journal (2016) as being future proofed for decades to come and to have secured its position as the eastern region’s green energy generating giant; it has capacity to absorb the housing targets of both the existing and emerging Local Plan including Waterbeach Newtown. This fact, that there is no operational need for CWWTP to relocate even with the ambitious housing targets of these Local Plans, has meant AW are dependent on external funding, in this case £227m of public money via HIFF. Joint Councils supported the HIFF application and thus the principle of relocation of the CWWTP to enable the fulfilment of the vision for NECAAP, however this was before AW undertook identifying and concluded on a ‘viable’ site selection.
The site identified by AW is an area subject to the emerging Local Plan in the Cambridge Green Belt; identified in the supporting Green Belt Study (2021) as an area of high sensitivity where development would have ‘very high harm’ to Green Belt purpose. This ‘very high harm’ is attributed to the area not least because of the openness of the Green Belt but also the contribution three adjacent Conservation Areas, historical assets, and medieval villages within them make to the Historical Setting of Cambridge. Significant Green Infrastructure also identified in the emerging Local Plan will be impacted by the relocation including: the River Cam Corridor; SSSI sites; registered Historical House and Gardens; extensive PRoW network; National Trust Wicken Fen Vision.
Since the site selection for relocation by AW there has been no public consultation on the consequences or environmental effects of the Councils pursuing NECAAP /S/NEC in the context of the relocation to Honey Hill, nor has any alternative vision for NECAAP been presented in the emerging Local Plan First Proposals.

19. Vision & Aims pg20

Fully support vision and aims. However, under Infrastructure there should be emphasis on serving the existing community as clearly there are established deficits , for example new sustainable transport systems to assist known commuters, not purely for future growth eg ‘Plan for transport, water, energy and digital networks; and health, education and cultural facilities; in the right places and built at the right times to serve both our existing and growing communities. ‘

20. How Much Development and Where – General Comments

The development targets for housing in Greater Cambridge are over ambitious in the plan period and bring a high level of risk to Greater Cambridge and the Vision and Aims of the Local Plan.

21. Policy S/DS: Development Strategy pg 29

• The development strategy of Densification is not supported
• A greater focus on bringing sustainable transport initiatives to the fore from outside the Greater Cambridge Area within the plan period, for example in addition to East West rail, improved rail links eg Newmarket /Ipswich line are recommended and good services to the Market Towns in the Region.
• Increase in home working will benefit local communities (levelling out) far from ‘dormitory towns’, with good transport networks for the odd commute day and more affordable housing, the wider region could benefit from Cambridge’s economic growth with working populations employed in Greater Cambridge but in the main remaining ‘local’.
• Pursuing housing development at North East Cambridge as a result of the relocation site selected by Anglian Water in the Green Belt and within close proximity to Conservation Areas etc. is contrary to Policies: listed under ‘Bio-diversity & Green Spaces’; Great Places to Live’; Wellbeing & Inclusion.’ And is a high-risk strategy. See comments under S/NEC.
The case has been made for an alternative Minimum or Medium Growth Option in section S/JH. If adopted, it is recommended the additional homes (Min 3000; Medium 8,000) required in the Plan Period could be accommodated by Cambridge Airport with forward planning and mixed development to assist build out rates (4000) and the Bio-Medical Campus (up to 4000) without the need for housing at North East Cambridge. In addition, areas identified for Major change within the City boundary S/AMC may also bring opportunities for housing within the plan period and beyond assisting with requirements of a 5 year land supply. Cambridge airport with an allocation of 7000 to full build out will also be able to offer homes beyond the plan period. The Bio-Medical Campus has been identified for growth but has not had housing nos. allocated housing development could be achieved here within the plan period with a mixed development and forward planning(S/CBC).

23. Policy S/SH: Settlement Hierarchy pg47

Not Supported.
• It is recommended Limits could be specified in line with the Windfall allowance calculated. The Vision & Aims of the Local Plan are at risk should there be no limit on the size and scale of schemes brought forward and approved.

24. Policy GP/LC: Protection and enhancement of landscape character P209

The intent of Policy GP/LC is supported in general. However, this does not appear to be reflected throughout the draft Local Plan due to the failure to consider the consequential impact of the North East Cambridge Development on the Green Belt and corresponding Landscape Character Areas as a result of relocation of the Waste Water Treatment Plant (WWTP).
The supporting Landscape character Assessment chapter 6A covering the Fen Ditton Fen Edge Chalklands Landscape character Area includes within its Specific Landscape Guidelines to ‘Ensure development is in keeping with the open, rural character’.
The proposed WWTP relocation would result in a major industrial plant located in Landscape Character Area 6A, including towers currently planned to be up to 20m-26m high surrounded by a circular bund and fencing on top with a combined height of circa 11m, in an area classified as Fen Edge Chalklands. This is clearly in breach of Policy NH/2 of the 2018 South Cambridgeshire Adopted Local Plan and presumably its proposed successor, Policy GP/LC.

25. Policy J/AL: Protecting the best Agricultural land p235

Agree in principle but requires clarification in related areas of the emerging Local Plan.
The proposed policy captures the importance of restricting development which could lead to the irreversible loss of the best agricultural land (Grades 1, 2 or 3a) and is reinforced by the concerns raised in response to the First Conversation, regarding carbon sequestration, biodiversity, and our ability to meet our food growing needs.

26. H/HD: Housing density pg 271

Not supported: mistakes have been made in the past with very High-Density housing, typically achieved though ‘high rise’ with very limited Green Infrastructure. The impact on existing communities with a multiple increase in population size in such a small City as Cambridge (just 5 miles in diameter) is yet to be tested and could prove to be a major strategy error. If Cambridge loses ‘what is good to live here’(and visit) , the economic objectives may not be met as companies and people go elsewhere. This is of particular relevance to the size and scale of S/NEC / NECAAP

27. I/ST: Sustainable transport and connectivity 304

General Support – however a far more ambitious approach to GCP in partnership with Combined Authority providing innovative and sustainable transport to the wider community including Market Towns to enable sustainable commuting into Greater Cambridge is recommended. Large developments next to places of work in such a small area as Cambridge will have environmental and health and well- being costs to existing communities and may in itself prove an ill-advised strategy in the longer term for Greater Cambridge. The Ox-Cam Arc project, new transport systems home working etc., within this plan period could provide less high-risk solutions to the benefit of the economy of our Market Towns and should be pursued more creatively and robustly, Cambridge growing economy to the benefit of the wider region. The policy to reduce CO2 emissions by principally putting very high numbers of people at unprecedented levels next to work areas given the small scale of Greater Cambridge/Cambridge City lacks in the period to 2041 is not fulfilling or making use of the promise of large-scale public funding for transport infrastructure to support the commitment made by joint councils to these unprecedented high levels of growth. What makes Cambridge attractive and in part what drives the economy is at risk (CPIER 2018)

28. BG/RC: River Corridors pg 180

Supported: Note: Note Fulfilment of S/NEC Policy will impact on River Cam corridor landscape from new housing developments on NEC site and relocation of CWWTP to Honey Hill, both partnership developments will be highly visible from the River Cam Corridor.

30. BG/EO: Providing and enhancing open spaces pg 185

Supported: Note: Fulfilment of S/NEC Policy through relocation of CWWTP to the Green Belt is contrary to this Policy

31. WS/HS: Pollution, health and safety pg 201

Supported. Note- fulfilment of S/NEC Policy through the relocation of CWWTP to Honey Hill is contrary to this policy: the relocation will lead to adverse effects e.g., odour to residents and users of open space: even if ‘negligible odour levels’ are attained on site boundary these levels of 1.5 are still experienced by 50% of people and will extend beyond site boundary/odour map contours depending on wind conditions etc.
This also applies to Noise and Vibration