Representation by The Federation of Cambridge Residents Associations (FeCRA) (The Federation of Cambridge Residents Associations (FeCRA))
- Date submitted
- 30 June 2023
- Submitted by
- Non-statutory organisations
Dear Sir/Madam, Anglian Water’s DCO application to relocate the sewage works I am writing on behalf of the Federation of Cambridge Residents Associations’ ( FeCRA) to register as an IP and to object to Anglian Water’s DCO application to relocate the Cambridge Waste Water Treatment Plant FeCRA’s primary grounds for objection to moving the Waste Water Treatment Plant from its Current site in NE Cambridge to Honey Hill . We are very concerned about the threat to a Principle Chalk Aquifer which the proposed development will sit on and potentially contaminate. There is no operational need to move the treatment works. Anglian Water have confirmed this. The design does not appear to be technically better than the current plant. The current site is more than adequate for at least another 30 years and could be upgraded at far less cost. The existing treatment works at Milton is effective and has spare capacity. It was upgraded only recently, at a cost of £21 million in 2015, in order to support planned development in Cambridge and the surrounding area until 2050 and is being vacated only to enable redevelopment. We understand that the Milton Plant is currently only running at approximately 50% capacity. The CO2 cost embedded in the new structure and emitted in demolition and construction is sizable. Residents are concerned about the huge carbon cost of the demolition and move and replacing operational sewage works They challenge the carbon expenditure involved in decommissioning and decontamination of the current site when they say there should be a presumption in favour of retrofitting and reusing existing buildings ( see House of Commons Environmental Audit Committee 2022). There is little evidence to support the statements in PEI Carbon as AW has stated it will defer sharing the data on the cumulative environmental effects of the relocation project, stating that the carbon cost of this will be counted in the redevelopment plan for NE Cambridge for the re-development of the existing site and other relevant projects. These relevant projects have not been described. Known water shortage and drought concerns of this region The Environment Agency is not now (June 2023) approving new housing developments in Cambridge/South Cambridgeshire on the basis that there is insufficient water supply. The moving of a sewage works to Green Belt land in order to release brownfield land for yet more house building will simply exacerbate the water shortage. Droughts are increasingly common in the Cambridgeshire region. Loss of green belt land and arable farmland contrary to national planning policies Many residents question why the works are being moved, given the united opposition of local communities, the huge impact on attractive Green Belt, the odour, the loss of prime agricultural farmland at a time when there is huge national concern about food security. Anglian Water confirms that the loss of agricultural land will be permanent. No exceptional circumstances have been demonstrated for the loss of green spaces and the impact on openness and other purposes of Green Belt policy. Residents question how this complies with NPPF, South Cambs District Council Local Plan 2018 and Greater Cambridge Emerging Local Plan and the aspirations to protect and improve green spaces and the Wicken Fen Vision There has been a failure to consider a full range of alternative sites including the feasibility of the retention of the existing site . Impact on sites of special scientific interest and in particular Quy Fen There are a number of SSSI’s close to the site which could be affected by its construction and operation: Brackland Rough, Cam Washes, Cherry Hinton Pit, Chippenham Fen and Snailawell Poors Fen (a RAMSAR site), Devils Dyke, Felan Dyke, Fulbourn Fen, Gog Magog Golf course, Great Wilbraham Common, Histon Road, Roman Road, Snailwell Meadows, Stow-cum-Quy Fen, Upware South Pit and Wicken Fen, which is another RAMSAR site. Anglian Water recognises the likelihood that the surface water originating at the works at the Honey Hill site will drain towards Quy Waters protected waterbody and could contaminate it. Yet it has ignored the fact that contaminated groundwater in the chalk aquifer beneath the site could pollute these other receptors and protected rights (local well users), as well as other parts of the surface water drainage network. Impact on the high quality of the world famous historical setting of the River Cam landscape and its wildlife and the medieval Cam conservation villages The scheme places no value on the historical setting of the Cam landscape or on the rights of the wildlife and nature of the River Cam corridor yet nature and our climate are in crisis. There are huge concerns about habitat loss and the rights of nature. This scheme also places no value on the economic and well-being value of this world famous Cam landscape and the effect on the approach to listed buildings Policy 7: The River Cam of the Cambridge Local plan 2018 states: Development proposals along the River Cam corridor should: 1. Include an assessment of views of the river and a demonstration that the proposed design of the development has taken account of the assessment in enhancing views to and from the river; 2. Preserve and enhance the unique physical, natural, historically and culturally distinctive landscape of the River Cam; 3. Raise, where possible, the quality of the river, adjacent open spaces and the integrity of the built environment in terms of its impact, location, scale, design and form; 4. Propose,where possible and appropriate to context, enhancement of the natural resources of the River Cam and offer opportunities for re- naturalisation of the river; enable, where possible, opportunities for greater public access to the River Cam; and 5 take account of and support, as appropriate, the tourism and recreational facilities associated with the river. This scheme robs attractive East Cambridgeshire River Cam villages in conservation areas of their green belt and medieval river landscape setting. Ugliness and odours This unnecessary scheme to relocate an operational sewage works, with its ugliness and odours doesn't just rob Cambridge and East Cambs villages of the River Cam green belt it also robs local schools, residences and businesses of economic opportunity, nature and recreational access. It impacts the Wicken Fen Vision which correlates with Policy 7 and the obligation to protect Green Belt land which is specifically designed to preserve the historic character of Cambridge and its green belt setting and the River Cam. Ugliness of the design and the impact of a huge industrial site on the approach from the east to historic Cambridge impacts the approach to the historic city of Cambridge The proposal will introduce an ugly industrial structure the size of Wembley Stadium, which will be visible not only from within the local area but across the flat Fen landscape to the north and from the chalk hills to the south. The scale and industrial design is inappropriate in such a lovely rural river setting. The ugliness and industrialisation the scheme creates impacts the amenity value of public rights of way and permissive ways and creates industrialisation north of the A14.