Representation by Jennie Pratt
- Date submitted
- 11 July 2023
- Submitted by
- Members of the public/businesses
I object fundamentally to the claim that this is an NSIP, to the proposed relocation of the Cambridge WWTP, and to the site selected between Horningsea and Fen Ditton. This is a land grab, effectively house-building using the Green Belt. It is a scheme to exploit opportunities in the planning system which allow a sewage works to move on to Green Belt land where housing may not be built, for no other reason than to get it out of the way so that houses can be built on the existing site. 1 – This is not an NSIP. The proposed relocated WWTP does not meet the requirements of s29 to qualify as a NSIP. It is not new or additional capacity of over 500,000 pe, as envisaged by s29. Parliament deliberately chose to increase the pe requirement to 500,000 to ensure s29 did not apply to minor applications like this (see Hansard). This is merely the proposed relocation of an existing sewage works with a pe of less than 300,000 plus imported sludge , for a modest sized city. The court has not decided whether sludge imported from elsewhere does in fact count towards the pe requirement. The existing works are also functionally and operationally satisfactory, as stated by Anglian Water (AW), and following the upgrade in 2015 AW said it was future proofed for decades to come. This is not what Parliament intended to facilitate. The court in EFW Group Limited v Secretary of State for Business, Energy and Industrial Strategy [2021] has confirmed that a s35 Direction does not in itself make the application an NSIP. The presumption in favour of development does not apply; s105 does apply. 2 – Importation of sludge AW state an intention to import sludge in addition to that which is already treated at the existing site which will be included in the pe. Why? AW have not explained this choice satisfactorily. There are other sludge treatment plants elsewhere in the region - what is to stop the sludge being treated elsewhere, outside the Green Belt? The additional transportation of sludge by truck is not good for the environment. It could be just as cost efficient and better for the environment to treat it locally to where it is produced. 3 – Lack of ‘very special circumstances’ and failure to make the need case AW say that there is no operational need to move. AW have also said in 2006 that there is sufficient capacity on the existing site to build a replacement plant before decommissioning the existing WWTP. There is therefore no need to move in order to accommodate increased capacity requirements for development at Waterbeach and Cambridge. It appears that the options for keeping the WWTP on its existing site, including use less of the existing land, have not been properly considered. AW in conjunction with the promoters of the N E Cambridge development have very successfully built considerable ‘project momentum’ eg the HIF grant, s 35 Direction and progress on the emerging local plan, including involving school children in designing attractive aspects of the proposed ‘Hartree’ area at N E Cambridge. While this does raise the stakes, it does not amount to ‘very special circumstances’ which might justify sacrificing Cambridge Green Belt. Housing need in itself does not amount to ‘very special circumstances’. AW have not even shown satisfactorily that housing need does exist which would actually be met if the existing site were vacated, and which could not have been accommodated elsewhere while leaving the WWTP on its existing site. Specifically what housing need? Affordable housing may actually be needed but it never makes up the promised percentage of any development and the same pressures to make profit would apply here. Cambridge City Council has even marketed properties abroad which hardly indicates local need. Cambridge’s Green Belt should not be sacrificed for mere gain. It is still too soon for assessment of the impact of the developing changes in use of commercial premises arising from the increase in working from home since the end of the lockdowns. As reported to me, professional firms in Cambridge and wider E Anglia are considering using less of their premises and subletting, or not expanding. While space may be needed for laboratories it appears likely that use of both retail and office space will be reviewed and may well be released for redevelopment and change of use to residential. 4 – Consultation and Communication AW did not respect the spirit of the required consultation. Their initial reach was wholly inadequate and did not notify all those affected. The initial site section consultation was 51% (at least) against moving from the existing site but that was ignored. Many responded on paper – it is not clear that these are all reflected in AW’s summary. AW’s consultation website was appallingly difficult to use on each consultation, and it confused and put off a significant number of would-be respondents or limited what they managed to say - despite complaints to AW each time. AW have been undemocratic in their publicity giving the impression that this is a done deal and people’s views will make no difference. Splitting the WWTP relocation from the application for NECAAP has facilitated disinformation eg it enabled the promoters of NECAAP to omit mention of the plan to relocate the sewage works as a prerequisite, and that the chosen site is in the Green Belt. The two are inextricably linked and information about the proposed relocation should have been published much more widely across Cambridge and surroundings. Many in Cambridge, including those who come out to the area of the proposed relocation site for recreation, are not aware that the proposed new development at NECAAP is predicated on moving the sewage works to this area nor that they have only until 19th July to inform PINS of their comments and objections. AW’s literature, site maps and photographs regarding the proposed relocation appear deliberately to make it difficult for the general public to realise exactly where the site is, including the extreme proximity to Grade 2* Biggin Abbey and the much-visited village of Horningsea. For instance the drawing 4.1 Location and Scheme Order Limits Plan Regulation 5 (2) (o) sent with the s56 notice on 6 June 2023 clearly marks and names Waterbeach, Milton and Cambridge but there is no assistance given to identify the two communities most affected ie Horningsea and Fen Ditton which are not named at all. 5 – Significant risk of harm to the Principal Chalk Aquifer Due to the presence of the Principal Chalk Aquifer under the proposed site it should never be developed at all. DEFRA assess the proposed site as being at high risk of ground water contamination. While the technology exists to build below ground without damaging the aquifer, there is no guarantee that in practice it will be used correctly to protect the Aquifer and there is a local example at Northstowe of accidental damage apparently being caused during construction. Also technology is also very expensive and the cost is more than AW may be willing to pay – initially they did not plan to build the digesters etc below ground at all. The reality of construction work is that risk of damage occurring is very high in practice, both initially and in future. Water is such a precious and scarce resource in E Anglia. Cambridge has been blessed with this Aquifer and we should make every effort to protect it. We should not put it at risk as a by-product of a scheme to make profit out of the existing WWTP site. 6 – Visual/design/landscape Due to the inability to build below ground, any structure on the proposed site, which is slightly raised ground, will be visible for miles around across the flat fen landscape. That landscape in itself has merit and is worth protecting. Indeed this location is coveted by the National Trust to complete its Wicken Fen vision. Due to the position beside the A14, the relocated WWTP would be a landmark. Whereas the purpose of the Green Belt was to protect the character of Cambridge, the relocated WWTP would do the opposite. There has been no decision that the character of Cambridge is any less important. It still requires protection, particularly from a proposal of this nature which will be so out of keeping and inappropriate. It is not possible to disguise a WWTP structure at 26m high most of which must be built above ground, whatever shape or colour it is. The suggested planting of trees is likely to have a very low success rate, from local experience. The rainfall at Horningsea is low even for East Anglia, and from personal and local experience trees establish and grow very slowly and mortality is high even where active care continues after 5 years. Planting on made ground on a slope will be even less likely to succeed. Very few native trees reach the necessary height even in favourable conditions and after many years; none would begin to do so in 15 years. The WWTP as designed, with or without the suggested Bund which itself is inappropriate for this landscape (the Devil’s Dyke is linear not circular), at approximately 26m high will be highly visible from public and permissive paths and buildings both north and south of the new WWTP including as yet unbuilt development at Marleigh and the airport, plus existing north Cambridge. As above, I do not believe that most of north Cambridge has been made aware of this in consultation, nowhere does the comparison appear to have been made with the existing works which could be and are part built below ground because the geology is suited to this. From my discussions the general public appears to expect that the new WWTP will be as invisible as the existing works which is a misapprehension AW have allowed to continue, through the limited range of consultation. 7 Harm to Heritage Assets and to the Green Belt. While harm to Heritage Assets is stated to be less than substantial, it is nevertheless harm. It is not clear that the degree of cumulative harm has been adequately assessed. The worst affected may be historically important Grade 2* Biggin Abbey, the tree-lined avenue to which starts directly across the road from Low Fen Drove. There will be intervisibility with the relocated WWTP which cannot be avoided without altering the landscape and planting in a way which is itself in appropriate. Horningsea contains a significant number of Grade 2 listed buildings, and its church is Grade 1. Fen Ditton likewise has many Grade 2 listed buildings. The setting for both villages will be permanently and significantly degraded. Both villages are conservation areas as is Baits Bite Lock and all of these have been cherished by the residents in keeping with the Green Belt and are accordingly very popular as amenity destinations including for cyclists, walkers and horse riders using local and long distance paths, boaters, campers/caravanners and visitors from Cambridge and further afield. The relocation of the WWTP to the proposed site in the middle of this is completely counter to the planning approach for the area and will change its character dramatically by the introduction of industrialisation of an extreme and completely inappropriate type. Horningsea and Biggin Abbey will both be dwarfed in size by the proposed WWTP, the area of which is huge by comparison. The proximity of Horningsea is not obvious from the AW plans and diagrams and the village will be dominated by the view especially at the south end. The noise, traffic and alterations to the A14 junction will all negatively impact the conservation areas. The existing dark area will be lit at night even if kept to a low level. . The Greater Cambridge Green Belt Assessment (LUC 2021) identified the impact of development into the proposed site as causing overall Very High Harm. AW’s own assessment reduced the impact to Moderate however the methodology used by AW may not be consistent with that of the Greater Cambridge Green Belt Assessment in paying attention to the detail, and AW’s application does not appear to show a satisfactory analysis of the reasons for the difference. There will be significant permanent degradation of the contribution which the remaining Green Belt land around the proposed site makes to the purposes of the Cambridge Green Belt. This is not reflected in the AW assessment. 8 Mental Health and Well being As above, the amenity value of the area including the proposed site is currently relatively high. Milton Country Park is at capacity and development including Marleigh will lead to increased pressure for green space for amenity in order to promote well-being and preserve mental health. The area of the proposed site was ‘discovered’ by many from north Cambridge during the Covid period and remains popular for its peace and rural nature. The Horningsea area includes a disproportionate number of beneficial outside venues – moorings, garden centre, caravan/and camping site, village hall with green (hired most summer weekends), long distance way etc. Mental health is becoming a serious issue and the proposed site and the surrounding area should be preserved for its benefits to the wellbeing of local people and the many visitors. The more that development increases around Cambridge, the more crucial it is to preserve and protect high quality green space such as this. 9 Odour We are told that the smell from the relocated WWTP will be negligible. We are also told that the technology is basically the same as at the existing WWTP. Currently, there are days when it is disgusting to stand outside in Tesco’s carpark at Milton. When I have contacted AW about this I have generally been told that the cause is that the sludge has been stirred up. I am very concerned that AW are proposing to import sludge and increase the quantity, and that there will be frequent opportunities for extremely unpleasant odour. It is not acceptable to tell the residents of an area which currently has no such smell, and where generally any smell is of cut grass, that there will not often be unpleasant smells. Most residents expect to spend a significant part of their time outside in their gardens – in contrast with the current site which is largely business parks. There are also a number of commercial and not for profit enterprises close to the proposed site which depend on it being pleasant to be outside. The wind frequently comes from the south when the temperature rises – given how close Horningsea is to the proposed site that may also be when the smell from the WWTP is most noticeable. 10 Carbon and waste AW have consistently washed their hands of the waste of embedded existing energy and resource in the existing WWTP, apparently having written it off over the years. But it is still in use and there is no operational reason to leave the existing WWTP site. It is the most appalling waste in a world where resources are at a premium and the cost of materials is rising, to demolish a perfectly good WWTP and build a whole new one a mile up the road using an enormous amount of concrete, one of the most environmentally damaging materials. To add significantly to the carbon being released into the environment for no good reason when society is so worried about the possible impact on the climate is seen by many as criminal. The HIF Grant is taxpayers’ money and many of us wish our funds could be applied to do something which would be of genuine help to the community, not to fund a totally unnecessary move of the WWTP. 11 – Traffic over the A14 Bridge, B1047/C210. Highways England were not able to consider alternative proposals for access/exit involving the A14 as they were told that the option of using the A14 bridge is viable. I do not agree that this has been adequately thought through. This is a 2 lane bridge, with a tight right turn off the bridge to the A14 – will construction traffic and sludge HGVs really be able to use it? AW expect sludge imports to rise considerably although there is not adequate detail to check this. If they do, that means a much higher level of traffic, possibly 10 HGVs an hour, on to what has been a peaceful rural site with a C road access, across a bridge which is used by (amongst others) children and parents on foot and bicycle on their way to/from primary school. This should be avoided if at all possible. Is this really a viable access/exit point for the relocated works? The proposed road layout is urban/industrial park in style and is not appropriate for a rural setting – the proposed traffic it will serve simply should not be accessing and exiting there.