SHH response to Local Plan: First Proposals public Consultation.

The public consultation run by Greater Cambridgeshire Shared Planning on the Local Plan ended on the 13th of December. The Local Plan (LP) is about all aspects of development in this area until 2041 and includes homes, jobs, biodiversity, infrastructure, wellbeing and social inclusion and climate change. The LP has been produced by Cambridge City Council and South Cambs District Council.

Here is the response from Save Honey Hill and other organisations.

Other organisations responses

SHH response to Local Plan 10 December 2021

ID: 56827
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: S/CE: Cambridge east
Summary:

Supported in main but policy proposals should not depend on complete integration with or extension to the proposed North East Cambridge Area Action plan. Recommend a more ambitious target of 4000 homes during plan period by forward planning prior to Marshalls’ departure. Retention of green corridor widening at Teversham provides green separation as adopted in the 2018 Local Plan. Cycle ways across Coldhams Common, through the airport & towards National Cycle route No.11 & National Trails e.g. Harcamlow Way, should be fully optimised to enable safe foot-cycle access to SSSI Quy Fen; SSSI Wilbraham Fen and wider network of PRoW’s.
Full Text:
Endorse in general the proposed policy direction especially to enable the development of the airport site. However, 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 4000 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 PRoWs

ID: 56834
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: GP/GB: Protection and enhancement of the Cambridge green belt
Summary:

Endorse the general principles of the policy but they are not reflected in the rest of the Local Plan which claims that only four areas of development have been taken out of Green Belt without referencing the relocation of Cambridge Waste Water Treatment Plant (CWWTP) to Honey Hill. That proposal is contrary to Policy BG/PO: Protecting open spaces (p183) 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 has been used for recreational purposes, as well as farming, for hundreds of years.
Full Text:
The objectives of the Policy:
preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre
maintain and enhance the quality of its setting
prevent communities in the environs of Cambridge from merging into one another and
with the city.
Endorse the general principles of the policy however they are not reflected in the rest of the Local Plan which claims that only four areas of development have been taken out of Green Belt without referencing the relocation of Cambridge Waste Water Treatment Plant (CWWTP) to Honey Hill. Relocating the CWWTP to Green Belt in order to create a brownfield site to develop housing for NECAAP does not meet these objectives above. The Green Belt Assessment 2021 considered that the Cambridge Green Belt Purposes of 2003 and their inclusion in subsequent Local Plans, including the 2018 LP, were still relevant and they were used to assess the potential harm of new development. However, this 2021 Local Plan fails to include the incursion in the Green Belt at Honey Hill in order to release a commercial site (Cambridge Waste Water Treatment Plant at Cowley Road) in order to produce a brownfield site on which to build housing, retail and offices.

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.
It is also contrary to Policy BG/EO: Providing and enhancing open spaces which states that open spaces are often fundamental to the character of the area. Honey Hill is flat fenland close to the SSSI at Quy Fen and therefore the relocation of the CWWTP will change that character.

ID: 56837
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: S/NEC: North east Cambridge
Summary:

The housing development at North East Cambridge is not supported, a focus on employment growth in the area and improved sustainable public transport from within Cambridge City, Greater Cambridge and the wider region as an alternative is recommended without the need to build a commercial development on Green Belt at Honey Hill. it is contrary to Policy GP/GB and the 2018 LP identified medium growth approach to NEC. The latest forecast for jobs in NEC has reduced to 15,000, requiring fewer homes which could be accommodated elsewhere.
Full Text:
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, is 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 themselves 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 – see Page 6 https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/WW010003/WW010003-000028-WW010003%20-%20Scoping%20Opinion.pdf.
The housing development at North East Cambridge is not supported, a focus on employment growth in the area and improved sustainable public transport from within Cambridge City, Greater Cambridge and the wider region as an alternative is recommended.
The spatial options review supporting the existing Local Plan (2018) identified a medium growth approach to NEC that did not require the relocation of CWWTP. This focused principally on employment, 15,000 jobs with homes in the region of 200 close to the station area and outside of the 500m odour buffer zone. These employment targets without the relocation of CWWTP match those of S/NEC in the First Proposals. It is recommended this option is represented as an alternative policy.
Cambridge Airport now presents as a realistic alternative for major housing development on brownfield. The site fares well in the Sustainability Assessment. It will have access to North East Cambridge employment via the new Chisholm Trail and is equal distance to the Science Park and Addenbrookes/Bio-Medical Campus.
Alternatives to meet the target of 4,000 housing supply in the plan period intended at NEC could be attained within a similar time period with forward planning and mixed development for example via: an additional 1,000 houses in plan period Cam Airport; 2-3,000 homes Cambridge Bio-medical Campus; 1000 Areas of Major Change. These 3 sites in addition to New Settlements will also offer housing capacity beyond the plan period e.g. Cam Airport has a 7000 allocation to full build out and potential further allocations as identified in S/CB & S/NS.
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). In the case of either of these alternative Growth Options being adopted the alternative site options above could absorb the additional housing target required and further housing beyond the plan period.
Focusing on Cambridge Airport as the alternative major housing development within Cambridge City boundary would remove the risks to the Aims & Vision of the Local Plan and contravention of Policies associated with the unprecedented high level of densification proposed and the necessity to relocate CWWTP to fulfil the S/NEC Policy into the Green Belt within Greater Cambridge.
The impact of large population increases in Greater Cambridge as a result of an unprecedented amount of new homes already in the pipeline, 30,000 + amounting to a 37% increase homes already existing in 2020, are yet to be known/tested and will not be known until mid-plan period and beyond. 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 (CPIER 2018). The impact of this unprecedented high growth strategy already in progress and committed to needs to be evaluated before it is added to further, in the case of North East Cambridge with high densification housing at unprecedented levels for Cambridge. 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.
The CPIER (2018) report which informed the Densification strategy advises young people will still wish to be in a centre where they can physically group together, this may be so for those in their first 5 years of work but beyond this, high density living with restricted car use, home working opportunities and affordable housing in the wider region means living in high density housing is unlikely to remain attractive for those in stable relationships seeking family accommodation.
4,000 homes have been proposed for completion in the plan period (2041) at North East Cambridge, the first homes being available from 2030. 8,000 plus have been allocated to full build out beyond this. Inevitably supply will be determined by the developers. If the vision for North East Cambridge level of densification etc., proves not to be popular and sustainable solutions to support the 31,000 homes already committed and yet to be built are not delivered, these homes, including the promise of affordable homes, may not be built in a timely way or the infrastructure promised realised.
Concerns expressed about the level of demand for housing and sustainability of those proposed is most often placated with the assurance that every 5 years the housing supply, demand and need will be reviewed and adjustments made accordingly. However, in the case of North East Cambridge in order to pursue the S/NEC Policy, Anglian Water have been requested to relocate the existing fully operational waste water treatment plant. If their DCO application is successful, long before any of the above are known or review of the impact of the high growth housing targets for Greater Cambridge are realised, relocation will have taken place with significant negative impacts on another area of Greater Cambridge in the Green Belt. The effects of the relocation on the area surrounding the site identified by AW , Honey Hill, will jeopardise the Aims and Vision of the Local Plan and many Policies laid out in the First Proposals listed below will be compromised.
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:
o Bio-diversity & Green Spaces:
BG/GI ; BG/RC ; BG/PO ; BG/EO
o Great Places:
GP/LC ; GP/GB; GP/QP ; GP/HA
o Wellbeing & Social Inclusion:
WS/HS

o Climate Change:
CC/NZ 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 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
The following Local Plan Vision & Aims will be jeopardised:
Bio-diversity and green spaces:
Increase and improve our network of habitats for wildlife, and green spaces for people, ensuring that development leaves the natural environment better than it was before.
Wellbeing & Social Inclusion:
Help people in Greater Cambridge to lead healthier and happier lives, ensuring that everyone benefits from the development of new homes and jobs.
Great Places:
Sustain the unique character of Cambridge and South Cambridgeshire, and complement it with beautiful and distinctive development, creating a place where people want to live, work and play.
Infrastructure:
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 our growing communities.

ID: 56850
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: S/SB: Settlement boundaries
Summary:

Object in parts as it fails to include the area known as Honey Hill where a large commercial development is plant (CWWTPR) and lacks detail on the point at which a new settlement boundary will be drawn which would allow for boundaries to be vague and subject to expedient drift.
Full Text:
Object to parts of this policy as being incomplete. 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.

Object also that the LP also states that where planned developments, such as new settlements, have reached sufficient certainty regarding their exact boundaries, new settlement boundaries will be drawn. This does not allow for a finite point at which that certainty is assessed and allows for “mission creep”. More careful wording is needed for this policy to prevent description of boundaries becoming vague. While the LP proposes that no development would be permitted outside settlement boundaries with exception, these exceptions include development supported by other policies in the plan. This would allow incursion in the Green Belt if it became expedient to enlarge a development already covered by other policies, such as Policy S/NEC: North East Cambridge.

ID: 56851
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: S/JH: New jobs and homes
Summary:

Not supported. Assessment of housing and employment needs were made before Brexit and before the Covid-19 pandemic, the latter causing a paradigm shift in working practices. 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. The high growth strategy may fail if sustainable solutions are not found quickly, negating the attraction for new and existing employers and employees of living and working in Cambridge.
Full Text:
Not supported. 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. It is recognised that personal and communal space, with access to green space, is necessary for mental and physical wellbeing.

It should also be recognised that Cambridge has a highly mobile work force, especially in the sciences and technology industries, where employees rarely stay at the same job for their whole working life. Skilled service professionals, e.g electricians, plumbers, are necessarily itinerant.

The impact on carbon expenditure, water use and flood risk due to ground cover should be assessed in the light of climate change.

The prediction of 2,111 homes produced per year is not going to have a major impact on Cambridge high house prices or the provision of social and affordable housing for the lower paid of the 58,500 jobs.

More investigation is needed on employment sites, especially office space, which has become available since the pandemic. These include office space at the Biomedical Hub at Addenbrookes Hospital Biomedical Hub, changes from retail to other use at the Grafton Centre Grafton Centre and the Dirac Building at St. John’s Innovation Park among many others.

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 .

The Medium plus Growth Option is not supported, a Minimum or Medium Growth Option is recommended requiring an additional 3,000 homes (rounded & incl 10% buffer) and Medium Option an additional 8,500 homes (rounded & including 10% buffer). [figures pg.84 of the SA and pg.42 of Development Strategy Topic Paper]
Minimum or Medium Growth Option can be justified on the grounds of:
1. Sustainability – where solutions to support both the existing population and housing already in plan are yet to be resolved (eg Water, Electricity, access to Health, Transport infrastructure)
2. The impact of large population increases in Greater Cambridge as a result of an unprecedented amount of new homes already in the pipeline, 30,000 + amounting to a 37% increase of existing homes in 2020, are yet to be known/tested and will not be known until mid-plan period and beyond. 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 (CPIER 2018). 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.
3. Changes in working practices post COVID to full or partial 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.

ID: 56855
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: S/LAC: Land allocations in Cambridge

Full Text:
Agree in principle with the exception of North East Cambridge site (see comments on Policy S/NEC). Wherever possible low carbon expenditure conversion should be employed rather than demolition and construction of existing buildings, e.g.Henry Giles House. Some downward revision of proposed total numbers of dwellings is needed in the light of post-Covid working practices and the need for recreational and personal space to support mental and physical well-being

ID: 56857
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: CC/NZ: Net zero carbon new buildings
Summary:

Agree in principle. Policy direction should not just include the whole-life carbon emissions, i.e. emissions associated with constructing buildings but expanded to include the carbon emissions associated with decontamination and demolition of existing buildings on the site, such as at the current CWWTP. Should include eventual demolition of the new building. Use only low carbon materials in construction, avoid those with high carbon expenditure in their manufacture, e.g. cement. 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.
Full Text:
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 and the eventual demolition of the new building, ensuring that low carbon materials are used in construction and avoiding those with high carbon expenditure in their manufacture, e.g. cement. 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 fulfilment of S/NEC Policy

ID: 56858
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: CC/DC: Designing for a changing climate
Summary:

Agree in principle but needs to be extended beyond residential to large industrial developments and effort made to convert existing buildings, such as shops.
Full Text:
Agree in principle. 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. Some existing retail buildings use a “heat barrier” to ensure their entrances are warm; this contributes to CO2 production, is expensive and adds to heat spill. New buildings should use alternative entrance methods to preserve heat and reduce CO2production, and where possible efforts should be made to adjust existing retail buildings. Tree cover as a cooling mechanism cannot be achieved quickly in large urban developments but grass cove, which contributes equally to CO2 absorption, has similar effects and green landscaping allows surface drainage. These also follow the Dasgupta principles of the economics of biodiversity https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/957292/Dasgupta_Review_-_Abridged_Version.pdf

ID: 56903
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: WS/MU: Meanwhile uses during long term redevelopments
Summary:

Endorse in part. Care must be taken to prevent meanwhile use on sites proposed on Green Belt while waiting for consents to prevent incursion into the Green Belt contrary to Policy GP/GB Protection and Enhancement of the Cambridge Green Belt and cause unjustified damage if applications fail.
Policy S/NEC North East Cambridge, consideration should be given to established businesses, including those on Nuffield Road, support should be given them to maintain businesses as long as possible and in finding a new site.
Concentrate meanwhile use on low carbon projects, minimal CO2 producing construction providing green space, vandalism proofed.
Full Text:
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 and could cause unjustified damage should the applications fail.
In the case of Policy S/NEC North East Cambridge, consideration should be given to established businesses, including those on Nuffield Road, which would vacate the site when development starts and support should be given them to maintain businesses as long as possible and in finding a new site.
Where possible meanwhile use should concentrate on low carbon use, minimal CO2 producing construction and where possible provide green space, adequately maintained to prevent vandalism.

ID: 56904
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: GP/HA: Conservation and enhancement of heritage assets
Summary:

The objective of the policy for development to demonstrate how it preserves or enhances the significance of the heritage assets of the Greater Cambridge, their setting and the wider townscape, including views into, within and out of conservation areas will be contravened by the requirement by Policy S/NEC North East Cambridge to relocate the Waste-Water Treatment plant to an area of Green Belt. Conservation areas and heritage sites will be compromised by the juxtaposition of a large industrial plant.
Full Text:
This policy states : ‘Development will be required to demonstrate how it preserves or enhances the significance of the heritage assets of the Greater Cambridge, their setting and the wider townscape, including views into, within and out of conservation areas.’
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. See ‘Greater Cambridge Green Infrastructure Opportunity Mapping: Baseline Report’, LUC/South Cambridgeshire District Council & Cambridge City Council , November 2020,
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.
Other heritage assets and conservation areas such as Biggin Abbey, Baits Bite bLock, Anglesey Abbey may have reduced enhancement due to odour and proximity of commercial development.
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.
The underpinning Strategic Heritage Impact Assessment considers 8 strategic spatial options across 3 potential growth levels:
https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021-08/StrategicHeritageImpactAssessment_GCLP_210831.pdf
The report clearly indicates development for the Green Belt spatial option to represent Moderate/High risk for the medium growth option and classifies this option among the least preferred.
The subsequent Impact Assessment Supplement which further refines study focus on the Medium growth level establishes a Preferred Options Spatial Strategy as being the best performing:https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021-08/StrategicHeritageImpactAssessmentSupplement_GCLP_210831.pdf
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.

ID: 56905
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: CC/FM: Flooding and integrated water management
Summary:

Agree with this Policy. It is of particular relevance to the proposed NECAAP proposals (Policy S/NEC) in the areas of highest density, i.e. 300/ha in the central areas, where appropriate SUDS will be needed and the large hard surface areas need to be permeable. Better stormwater management will be required.
Full Text:
Agree with this Policy. It is of particular relevance to the proposed NECAAP proposals (Policy S/NEC) in the areas of highest density, i.e. 300/ha in the central areas, where appropriate SUDS will be needed and the large hard surface areas need to be permeable.
Regarding stormwater management parliament recently put a duty of Sewage Companies to reduce the storm overflows. Major developments, including their highways, should have dedicated separate road, roof and land drains run through balancing /attenuation ponds SUDS methods. as some recent new developments have not been affected by the recent stricture, CWWTP will need to build bigger storage and design it for future more intense rainfall. The stormwater in storage should then be fed back through the works after the storm has finished.

ID: 57514
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: BG/GI: Green infrastructure
Summary:

N/A
Full Text:
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.

ID: 57517
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: BG/PO: Protecting open spaces
Summary:

N/A
Full Text:
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.
Note: Fulfilment of S/NEC Policy through relocation of CWWTP to the Green Belt is contrary to this Policy

ID: 57531
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: Sustainability Appraisal
Summary:

The inclusion of Policy S/NEC is premature and inappropriate as it is predicated on the relocation of Cambridge Waste Water Treatment Plant, the development Consent Order for which will not be examined until late 2022 or 2023 and consultation on NECAAP Regulation 19 proposals are deferred until after the DCO decision. 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.
Full Text:
The inclusion of North East Cambridge area Action Plan (NECAAP) in the Local Plan and the recent announcement of its Regulation 19 Proposed Submission appears premature (S. Kelly report to JLPAG). The AAP is predicated on the proposed relocation of Cambridge Waste Water Treatment Plant (CWWTPR), for which the Development Consent Order (DCO) process is still in the pre-application stage. Given that the CWWTP DCO application is unlikely to be submitted until late 2022 or early 2023, the proposed Regulation 19 submission of the Area Action Plan and its inclusion here in the Local Plan is premature. Resources are being used inappropriately and prematurely when the consultation on CWWTPR is not scheduled until February 2022 and the councils are deferring any formal public consultation on NECAAP until after the DCO.

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. This is despite it being clear the relocation as proposed will be contrary to numerous Policies laid out in the emerging Local Plan First Proposals and in the case of densification the CPIER report (2018), which informs the high growth objectives of the emerging Local Plan, stating that to sustain high economic growth, development needs to be sensitive to maintaining one of the key attractions to Cambridge, that is the pleasant environment. The latter not only being the Historic City Centre but its setting including the historic Green Belt (the first nationally to be established) and the necklace of villages within it.

The assessment of the effects of NECAAP/S/NEC Policy have been deferred to AW and the DCO planning process with the assertion that as the relocation is a separate planning process ‘it is therefore not a project or proposal within the scope of the emerging Greater Cambridge Local Plan or AAP to influence.’ (S Kelly Nov 2021). This position seems quite extraordinary; including NECAAP/S/NEC in the Local Plan First Proposals but excluding sufficient or significant information about the effects of the fulfilment of the Policy for effective public consultation at Reg 18 in itself is contrary to the principals and regulations of the SA/SEA, will influence the Consultation and could be construed as effecting bias. This anomaly is further exacerbated given that neither the emerging Local Plan nor NECAAP are dependent on the relocation (S Kelly Nov 2021).

If it is regulatory to exclude reference / identification of the site selected for relocation or subjecting the full effect of NECAAP to the SA/SEA within the emerging Local Plan, it is recommended in the interest of an informed and fair public consultation NECAAP is excluded from the Local Plan until after the outcome of the DCO is known and that an alternative is presented in the emerging Local Plan that can be subject to SA/SEA and an informed, evidence based public consultation at Reg 18.

Refs:
S Kelly Nov 2021 : NECAAP : Proposed Submission (Reg 19) Report to Joint Local Planning Advisory Group
Environmental Journal July 2026 : https://environmentjournal.online/articles/cambridges-water-recycling-centre-looks-future/

ID: 57538
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: STRATEGY
Summary:

N/A
Full Text:
Visions and Aims
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 e.g. ˜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.

ID: 57548
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: How much development and where?
Summary:

The scale and high density of housing development at North East Cambridge is not supported.
Greater Cambridge Shared Planning specifies that neither the Local Plan nor NECAAP require the relocation of CWWTP ie neither is dependent on it (Ref. Page 6 Appendix 2 PINS Scoping Opinion – GCP’s response to Scoping Report).
The housing development allocated to S/NEC is reliant upon the relocation of CWWTP to the Green Belt
There is no existing or emerging Local Plan allocation or justification for development of the Green Belt to accommodate or fulfil S/NEC. NECAAP Reg 19 Submission is premature and inappropriate.
Full Text:
The scale and high density of housing development at North East Cambridge is not supported

Greater Cambridge Shared Planning specifies that neither the Local Plan nor NECAAP require the relocation of CWWTP ie neither is dependent on it (Ref. Page 6 Appendix 2 PINS Scoping Opinion – GCP’s response to Scoping Report – https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/WW010003/WW010003-000028-WW010003%20-%20Scoping%20Opinion.pdf

The housing development allocated to S/NEC is reliant upon the relocation of CWWTP to the Green Belt

There is no existing or emerging Local Plan allocation or justification for development of the Green Belt to accommodate or fulfil S/NEC

There is no operational requirement for AW to relocate to the Green Belt, the existing site was future proofed in 2016 and has capacity to accommodate the scale of development presented in the emerging Local Plan and beyond. The single driver for relocation is at the request of Cambridge City Council to seek a viable alternative site for CWWTP in order to release a brownfield site for housing development. This interdependency cannot be separated in consideration of the effect of S/NEC Policy.

S/NEC policy is one step away from housing development on the Green Belt with no allocation or examination in a Local Plan, it is dependent on it.

S/NEC should be removed from the Local Plan until after the DCO outcome or an alternative presented that is attainable without relying on the relocation of CWWTP and can be examined under the usual Local Plan Sustainability Appraisal.

A medium level of redevelopment (Option2) of NEC was identified as deliverable without relocation of CWWTP in the AAP Options Consultation 2014. This included a forecast of 15,000 jobs matching those now allocated in S/NEC and 440 homes.

The 4,000 homes allocated to S/NEC in the plan period to 2041 could be reallocated elsewhere within the City boundary eg an additional 1,000 Cam Airport ; 1-2,000 Cam Bio-Medical Campus; 1,000 identified Areas of Major Change.

The balance to full build out of NECAAP beyond the plan period could be accommodated by Cambridge Airport (up to 7,000 allocated to full build out) and further allocations eg as identified in S/CB & S/NS at which time planned sustainable transport developments will be in place addressing Carbon emissions for work journeys.

If DCO successful counted houses gained counted as ‘windfall’ in plan period

A case can be made on the basis of sustainability eg unknown water resource; impact of COVID on home working, preferred housing locations and demand for office space for a reduced Growth Option to Medium or Minimum. In either case this would reduce the requirement of additional housing in the plan period by at least 2,500 determining 1500 only of the 4,000 homes allocated to S/NEC requiring re-allocation amongst other sites.

All emerging Local Plans are required to be flexible, in addition, during the plan period 5 year reviews protect from over or under development. However, in the case of S/NEC the housing allocation is driving the DCO process and there is no flexibility. If successful, within 2 years only despite neither the Local Plan or NECAAP requiring it or there being any allocation of Green Belt been made in a Local Plan, relocation of AW to the Green Belt will go ahead with all the environmental consequences associated with it.

S/NEC, as presented in the Local Plan, is not flexible and the environmental effects as a result of the requirement of the relocation to fulfil it are contrary to the Aims and Vision of the Local Plan and environmental Policies GP/GB; BG/GI ; BG/RC ; BG/PO ; BG/EO.

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 .

The Medium plus Growth Option is not supported, a Minimum or Medium Growth Option is recommended requiring an additional 3,000 homes (rounded & incl 10% buffer) and Medium Option an additional 8,500 homes (rounded & incl. 10% buffer). [figures pg.84 of the SA and pg.42 of Development Strategy Topic Paper]

The development strategy of Densification is not supported; greater focus on bringing sustainable transport initiatives to the fore from outside the Greater Cambridge Area for example improved rail links, Newmarket /Ipswich line are recommended for example

The housing development at North East Cambridge is not supported, a focus on employment growth in the area and improved sustainable public transport from within Cambridge City, Greater Cambridge and the wider region is recommended.

ID: 57551
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: S/DS: Development strategy
Summary:

The development strategy of Densification is not supported. This strategy puts the Aims & Objectives of the Local Plan at risk: ˜Wellbeing & Social inclusion and ˜Great Places” are of particular relevance here for both existing and growth populations here. As stated in the CPIER report (2018) if Cambridge does not remain an attractive place to live, the high levels of economic growth aspired to may fail. Sustainable transport initiatives are needed in the Greater Cambridge Area to assist commuting both in and out of Cambridge with its high level of job mobility.
Full Text:
The development strategy of Densification is not supported. This strategy puts the Aims & Objectives of the Local Plan at risk: ˜Wellbeing & Social inclusion” and ˜Great Places” are of particular relevance here for both existing and growth populations here. As stated in the CPIER report (2018) if Cambridge does not remain an attractive place to live , the high levels of economic growth aspired to may fail.

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. The latter will assist both existing employees/commuters and new, reducing CO2 emissions (key aim of densification strategy). 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.

The CPIER (2018) report which informed the Densification strategy advises young people will still wish to be in a centre where they can physically group together, this may be so for those in their first 5 years of work but, beyond this high density living, with restricted car use, at home working opportunities and affordable housing in the wider region means living in high density housing is unlikely to remain attractive for those in stable relationships and seeking family accommodation.

The impact of large population increases in Greater Cambridge as a result of an unprecedented amount of new homes already in the pipeline, 30,000 + amounting to a 37% increase of existing homes in 2020, are yet to be known/tested and will not be known until mid-plan period and beyond. 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 (CPIER 2018). The impact of this unprecedented high growth strategy already in progress and committed to needs to be evaluated before it is added to further, in the case of North East Cambridge, with high densification housing at unprecedented levels for Cambridge. The Aims of the Local Plan :˜Wellbeing & Social inclusion” and ˜Great Places” are of particular relevance and at risk here.

The housing development at North East Cambridge is not supported, a focus on employment growth in the area, services to support commuters and improved sustainable public transport from within Cambridge City, Greater Cambridge and the wider region to bring employees in is recommended as an alternative.

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 numbers allocated; housing development could be achieved here within the plan period with a mixed development and forward planning(S/CBC).

ID: 57553
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: S/SH: Settlement hierarchy
Summary:

Not supported. The size of individual developments should be subject to limits until the effects of unprecedented growth already in the pipeline can be evaluated in relation to provision of utilities, health care, education, transport, carbon expenditure and climate change. Limits could be specified in line with the Windfall allowance calculated.
Full Text:
Not Supported.

It is recommended limits are placed on the individual scheme size of developments in Cambridge, Town and Rural Centre’s until such time as the unprecedented amount of growth in Greater Cambridge already in the pipeline (a 37% increase in homes from those existing in 2020) can be evaluated and the realisation of sustainable solutions eg Water, Electricity , health provision, access to education etc. ; new sustainable public transport infrastructure are known/resolved.

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.

An intensified and creative approach to sustainable transport options, use / improvement of existing rail networks/services for example, is recommended to address the CO2 objectives more so, than simply squeezing greater numbers of people into Greater Cambridge. The Aims of the Local Plan: ‘Wellbeing & Social inclusion’ and ‘Great Places’ are of particular relevance and at risk here. As the CPIER (2018) report states high levels of economic growth will not be achieved if the good things about Cambridge are lost.

ID: 57556
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: GP/LC: Protection and enhancement of landscape character
Summary:

GP/LC supported in general. but its aims are not reflected throughout the draft Local Plan due to failure to consider the consequential impact of the NECAAP on Green Belt and corresponding Landscape Character Areas as a result of relocation of the Waste Water Treatment Plant.
If the . emerging Greater Cambridge Local Plan is to retain an appropriate level of credibility, the consequential effects of the proposed NECAAP and corresponding CWWTPR should be considered within the Local Plan to assess the impacts under policy GP/LC and included in the Greater Cambridge Strategic Heritage Impact Assessment (2021) Policy GP/HA.
Full Text:
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 policy direction proposes to “Respect, retain or enhance local landscape character” (as set out in the Greater Cambridge Landscape Character Assessment) https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021-08/LandscapeCharacterAssessment_GCLP_210831_Part_A.pdf

The policy is understood to be required as the Local Plan needs to ensure the varied character of different parts of the area is properly considered in planning decisions. Developments should respond to the local landscape character and take opportunities for enhancement.
Responses to the First Conversation highlighted we should require developments to be in keeping with the landscape, informed by Landscape Character Assessments. We should include policies which seek to protect sensitive and valued landscapes.
Policy NH/2 of the Adopted 2018 South Cambridgeshire Local Plan states that: ‘Development will only be permitted where it respects and retains, or enhances the local character and distinctiveness of the local landscape and of the individual National Character Area in which is it located.
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 26m high surrounded by a circular bund and fencing on top with a combined height of circa 11 m, 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.

If the current emerging Greater Cambridge Local Plan is to retain an appropriate level of credibility, the consequential effects of the proposed North East Cambridge development and corresponding WWTP relocation should be considered within the Local Plan to fully assess the impacts under policy GP/LC and be included in the Greater Cambridge Strategic Heritage Impact Assessment (2021) under Policy GP/HA.

ID: 57560
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: J/AL: Protecting the best agricultural land
Summary:

Agree in principle but is negated by the requirement to relocate the CWWTP to facilitate the development of NECAAP. The emerging Local Plan should support the principle of adopted Policy NH/3 by clearly identifying the corresponding agricultural land and Green Belt cost that would require allocation in the Local Plan as a consequence of the proposed North East Cambridge development to allow a comprehensive assessment to be made.
Full Text:
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.
The proposed policy is understood to follow Policy NH/3: Protecting Agricultural Land, in the current adopted South Cambridgeshire Local Plan 2018. Section 1a. of adopted Policy NH/3 states:
Planning permission will not be granted for development which would lead to the irreversible loss of Grades 1, 2 or 3a agricultural land unless:
a. Land is allocated for development in the Local Plan;
Clearly, it would be inappropriate to allocate agricultural land in the Local Plan for developments that are still under investigation, such as the proposed Waste Water Treatment Plant relocation. However, in the context of the proposed North East Cambridge development, the emerging Local Plan should support the principle of adopted Policy NH/3 by clearly identifying the corresponding agricultural land and Green Belt cost that would require allocation in the Local Plan as a consequence of the proposed North East Cambridge development to allow a comprehensive assessment to be made.

ID: 57564
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: H/HD: Housing density
Summary:

N/A
Full Text:
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 Policy S/NEC (NECAAP).

ID: 57567
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: I/ST: Sustainable transport and connectivity
Summary:

More innovative and ambitious approach needed for sustainable transport to support commuting within and without the GCP area and should recognise the effects of home working.
Full Text:
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 larger-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)

ID: 57577
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: BG/RC: River Corridors
Summary:

N/A
Full Text:
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.

ID: 57578
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: WS/HS: Pollution, health and safety
Summary:

N/A
Full Text:
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

ID: 57508
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: CC/CE: Reducing waste and supporting the circular economy
Summary:

N/A
Full Text:
Agree in principle. Should include how the removal and transport of materials from demolition and remediation works should be included in the CEMP to reduce the impact of carbon footprint of HCVs.

ID: 56910
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: CC/RE: Renewable energy projects and infrastructure
Summary:

N/A
Full Text:
Agree in principle. Suggest that Section 4vii needs to be expanded to include that not only visual impacts must be mitigated but also auditory, especially for wind energy.

ID: 57511
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: CC/CS: Supporting land-based carbon sequestration
Summary:

N/A
Full Text:
Agree in principle. This policy protects existing carbon sinks from development and is in line with Policy GP/GB Protection and Enhancement of the Cambridge Green Belt. Because of these two policies it is inappropriate that the development on an existing carbon sink, i.e. the proposed CWWTP relocation on Green Belt at Honey Hill, has not been included in Policy S/EOC: Other existing allocations on the edge of Cambridge.
Note: Fulfilment of S/NEC Policy is contrary to this: decommissioning a fully operational and future proofed CWWTP and relocating to prime agricultural land.

ID: 57783
Type: Comment
Document: Greater Cambridge Local Plan Preferred Options
Section: S/EOC: Other existing allocations on the edge of Cambridge
Summary:

N/A
Full Text:
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.

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