Representation by Charles Richard Chappell Jones
- Date submitted
- 27 June 2023
- Submitted by
- Members of the public/businesses
I object to the submitted proposals for the proposed relocation of the Cambridge Wastewater Treatment Works and I wish to be allowed to make a written submission. I will avoid duplicating points made by our Parish Council and by the Save Honey Hill community action group. My objections can be separated into four categories: 1) Principle of moving the works into the Green Belt at the proposed site 3 at Honey Hill 2) Lack of consideration of the merit of upgrading the existing works to achieve the same treatment objectives 3) Insufficient mitigation in the event that the move to this site is accepted 4) Lack of transparency about financing 1 Principle of moving the works into the Green Belt at the proposed site 3 at Honey Hill The Green Belt provides a worthwhile and necessary function to preserve the setting of Cambridge in general and the character of Fen Ditton in particular. The Green Belt in the segment east of the River Cam and north of the A1303 Newmarket forms a prominent green lung converging onto Ditton Meadows and Stourbridge Common from the open country of the Wicken Fen vision. Although the A14 interrupts this green lung, it also gives high visibility of the historic city of Cambridge on the approach from the east. Planting a sewage works at the proposed site north of the A14 will negate this function of the Green Belt in an especially visible way by building on 22 ha of agricultural land and moving industrial scale wastewater and sludge treatment structures to it. Moving Anglian Water’s company office for non-operational staff to this site is a particularly egregious proposal since the stated objective of vacating the Cowley Rd site is to support further office building amongst other land uses within the North East Cambridge Area Action Plan. The Green Belt also supports agriculture on the arable areas of the site and a rich and varied wildlife with some rare and endangered species in the non-farmed areas. The loss of 22ha to an industrial site and a further 70ha for mitigation overturns the current function of this land and its functioning ecology. I object to the degree of consideration given to alternative sites not least because Site 3 had been pre-selected in the 2006-10 era. I suspect a long tunnel alternative to a location outside the Green Belt was ruled out too early on. The lack of weight given to preserving the Chalk aquifer contrasts with the extra weight given to the ‘development potential’ assigned to Site 2. The tortuous tunnel route shown for Site 2 was simply shown without any justification given. Other tunnel design factors (inc, gradient, thickness and diameter) skew Anglian Water’s cost and carbon footprint assessments without much discussion, presentation of feasibility reports or follow up. I think it is sophistry to try and justify a move into the Green Belt on the basis of the number of houses to be provided on the vacated site but hiding behind the emerging Local Plan and NECAAAP processes to determine how many houses are needed and how many could be developed on the vacated space. I believe this should be examined in this Inquiry. I fully support the Save Honey Hill community action group and its objections to the principle of this move. 2 Lack of consideration of the merit of upgrading the existing works to achieve the same treatment objectives I believe the large majority (>50%) of respondees wanting the works to remain on the existing site was under- reported by Anglian Water in their write up of their first consultation because they did not enumerate many returned written responses from the Abbey Ward and a wider area. The question of remaining at Cowley Road did not appear directly in later consultations. The obvious advantages of retention include the reduction in cost and carbon footprint if existing assets are used and upgraded and new assets are then not needed such as a full set of concrete tanks, tunnels, grid connections and an outfall into the River Cam. I consider that expanding the use of the existing site and assets would require better odour containment than is present at the existing works to avoid occasional nuisance impacts in Fen Ditton, Chesterton and Milton. However, with better containment and design it could be that the size of the buffer zone around Cowley Road works be evaluated on its merits in this Inquiry since if the current policy is relevant to greenfield sites, it may not so relevant to works in urban settings. Deephams and Eastbourne works being two that demonstrate the scope for housing being much closer than 400m with appropriate design. 3 Insufficient mitigation in the event that the move to this site is accepted I am concerned that the proposed mitigation is insufficient. Several key items such as organising traffic, upgrading odour control and ecological management rely on future assessment and work to mitigate initial shortfalls. The bund height of 5m proposed in the submitted design and previous consultation is 2 m lower than suggested in the first two consultations. Anglian Water now place great reliance on trees and a 3m high hedge for screening. The total width of structures rising above the bund itself is considerable and would be likely to be highly visible, especially at night and in winter; increasing the bund height would reduce the number of structures sticking up and the residual height and longitudinal exposure against the sky. Minor adjustments to ground lowering inside the bund could be one way to generate the excavated material needed to raise the bund. The proposed design risks water pollution in the Black Ditch and Quy Fen and this could be easily remedied. The transfer of Waterbeach WWTW to the existing works without examination of the impact on the River Cam is wrong and would exacerbate the current excess of actual DWF over permitted DWF. I appreciate this is an issue for the Environment Agency to determine but I believe it should be examined within this Inquiry. I consider some additional mitigation would need to be incorporated if the site is accepted. Where mitigation is to be finalised at a later date, I consider some formal commitments are necessary. I would like to expand on the mitigation I think is needed in a written submission. 4 Lack of transparency about financing I consider that the proposed CWWTPRP includes some betterment and some enlargement compared to the existing WWTW and these are not readily identified or quantified in the Anglian Water submission. This lack of transparency could lead to underinvestment in necessary mitigation if a move is accepted. Recent data suggest the land value of a vacated site at Cowley Road would be of the order of several hundred million pounds. Since at least 50% of this amount would have to be returned to the regulated business, the costs for betterment and enlargement should be separately identified from the cost of purely relocating - the oft-quoted purpose of the HIF grant. I understand that Anglian Water have confirmed that the cost of the Waterbeach pipeline is to be entirely funded separately from the HIF grant but suggest that the Inquiry considers if the quantum of treatment needed for this extra influent might also be funded by the regulated business and not the HIF grant.