Representation by The Asplin Family (The Asplin Family)
- Date submitted
- 16 July 2023
- Submitted by
- Members of the public/businesses
Cambridge Waste Water Treatment Plant Relocation Planning Inspectorate Project Reference: WW010003 Relevant Representation: The Asplin Family objections 16th July 2023 1) The Anglian Water proposal confirms that there is no operational need to relocate the existing works and there is no Water Industry National Environment Programme or national infrastructure requirement to relocate. 2) Other options exist for North East Cambridge that can provide equal or greater growth and economic value in a sustainable way. Therefore, when combined with the lack of operational need to relocate the existing works, the proposed programme cannot possibly be considered to be Nationally Significant. In this context, references to the Planning Policy Statement for Waste Water and population capacity equivalents of 500,000 or more (as yet unpublished or tested) are moot. 3) The Anglian Water relocation need case is understood to be entirely based on the development of North East Cambridge, yet the Greater Cambridge Shared Planning Scoping Opinion response confirms that 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”. This suggests that other options are available for the development of North East Cambridge. 4) Conversely, thirty nine of the Anglian Water application documents include a statement referencing the requirement to relocate as enabling the long held or long-standing desire of Cambridge City Council and South Cambridgeshire District Council to develop North East Cambridge. 5) There is a notable shortage of available property in Cambridge for science and technology, such as laboratories and space for innovation and knowledge-intensive R&D, which has significant potential for North East Cambridge to contribute to economic growth. NEC is well connected for such property and accords with the existing science park and transport connections, such as Cambridge North station. This can still be combined with a substantial level of housing, alongside other options that exist for housing supply, without incursion into the Green Belt. 6) The adopted 2018 Local Plans contain a requirement for feasibility investigations in drawing up the Area Action Plan. No such studies have been completed since adoption of the Local Plans, yet the draft Regulation 18 NECAAP stated they are now complete. This is also reflected in the Anglian Water Planning Statement and S35 request, which is incorrect and misleading. 7) The emerging Greater Cambridge Local Plan - First Proposals Sustainability Appraisal – October 2021 (p197) contains the Alternative Option C, of “retaining a consolidated Waste Water Treatment Works on site as either an indoors or outdoors facility”, which has also not been appraised. No evidence appears to have been published to formalise this exclusion. 8) In multiple documents retention on site is dismissed due to a 400 meter zone around the works (incorrectly stated in the Housing Infrastructure Fund Business Case as 600m), within which a risk assessment would be required, that is capable of being addressed by the First Proposals Sustainability Appraisal – October 2021 alternative option C of an indoor or outdoor facility, not yet considered. 9) The “Chronology of the feasibility investigations of redevelopment of the Cambridge Waste Water Treatment Plant”, issued retrospectively by Greater Cambridge Shared Services in June 2021, does not properly address the requirement for feasibility studies or the potential for the development of North East Cambridge with the works remaining on site. The Chronology, rather focusses on outdated studies with the primary objective of full housing development, is incomplete, and should be subjected to scrutiny. 10) The Site Selection and Alternatives document 5.2.3 alludes to co-location having been considered on the existing site, as does the Housing Infrastructure Business Case, but no information has been formally published. 11) The existing site is circa 40 Hectares, approaching twice the size of the proposed facility of 22 Hectares and has sufficient space for consolidation, with substantial space currently taken up by redundant equipment. 12) The National Planning Policy Framework expects all reasonable options to be assessed before land is released from the Green Belt. This has clearly not been carried out. 13) Delivery of comprehensive feasibility studies investigating the retention of the plant on the existing site, or the non-Green Belt alternatives for relocation, appears to conflict with the stated intentions of the stakeholders and NECAAP landowners and therefore could be a limiting factor in the provision of appropriate feasibility studies that properly investigate and report the available options. 14) Cambridge and Waterbeach currently have separate treatment plants and observe the proximity principle. The Planning Permission for Waterbeach New Town was also predicated on the proximity principle and provision of a separate treatment facility. No assessment or corresponding formal report appears to have been published which properly assesses the options for the new Waterbeach facility or the decisions to co locate the works at the proposed site. Similarly, no information has been published or included regarding lorry imports to the Cambridge Plant from the wider region and their continued suitability. 15) The NECAAP and Greater Cambridge emerging Local Plan are understood to both be on hold pending the outcome of the DCO. While the Anglian Water DCO determination is clearly a separate process to that of plan preparation, these draft plans include proposals based on relocation of the existing works but with no corresponding reference to the proposed relocation site. 16) Neither the current adopted 2018 Local Plans, the Greater Cambridge emerging Local Plan, nor the NECAAP include provision for Green Belt release for relocation of the existing plant. 17) Multiple references are made to the brownfield status of North East Cambridge, which will only become so if the existing operational works is relocated, yet there is little context or corresponding reference to the Green Belt cost. 18) Statutory consultations for the North East Cambridge Area Action Plan have not yet taken place. Significant concerns have been raised regarding the height and density of the proposed development and lack of green space, relying on an overpopulation of existing green spaces. There is no guarantee that the broader NECAAP site will be available for development. 19) The North East Area Action Plan proposes a housing and employment programme that can be delivered by alternative solutions. Consequently, the ‘very special circumstances’ have not been sufficiently demonstrated by Anglian Water to justify a major industrial incursion into the Green Belt. 20) The Anglian Water assessment of the Green Belt at the proposed location does not accord with the Greater Cambridge Green Belt Assessment or previous Local Planning Authority assessments which recognise the importance of the Green Belt purposes at this location. 21) The proposed development would establish a new precedent for the development of Green Belt north of the A14 and would impact the character and setting of Cambridge which should be protected. 22) The resulting harm is not outweighed by the requirement to relocate, or the corresponding NEC development, both of which can be delivered by alternative means. 23) The Anglian Water site selection is flawed. Development of the existing site has not been included as a comparator within the process. Multiple examples exist of modern treatment works being developed in close proximity to other developments, including housing. 24) The primary criteria used by Anglian Water for site selection during fine screening was cost, citing in order; Affordability, Impact on communities, Green Belt and Carbon. However, no non-Green Belt options have been included in the final selection, preventing assessment of this option. 25) The proposed site is just over a mile away from the existing location and is also close to the city edge. The stakeholders appear to be seeking the cheapest solution to move the problem, unlike the Peacehaven development in Brighton which provides an optimum long term integrated solution to the area’s needs. 26) The proposed site is above an important aquifer and is elevated compared to the surrounding land, with the least natural cover compared to sites 1 and 2. Anglian Water is proposing not to sink the tallest structures into the ground. The reasons include cost and geological grounds, raising questions regarding suitability of the fenland site selected. 27) The resulting visual impact of industrial development is inappropriate for the proposed location. 28) The Anglian Water technical specification is understood from the site selection documents to be budget driven. Anglian Water has stated that site 3 would require less odour mitigation activity and that similar technology will be used to the existing plant, therefore appears to be seeking the cheapest option rather than a robust infrastructure provision for the future. 29) Corresponding concerns also exist regarding available budget and ability to deliver an appropriate facility. The Anglian Water Funding Statement, document 7.5, is misleading and wrongly states the original cost estimate for the proposed WWTP location as being £227m, which was the estimate for a completely different location East of Waterbeach. 30) The Odour ES document 5.2.18 Chapter 1.4 Consultation, Table 1-3 Scoping ID 3.14.7 suggests that the assessment and assumptions used to inform the modelling demonstrate how a worst-case scenario has been reflected. This does not appear to have been the case for the abnormal operations adjudged by qualitative assessment, which have the potential for the most offensive odours, or consider all scenarios in Table 2-11 Maximum design Envelope parameters (Rochdale) for odour quality assessment. 31) Anglian Water track record on management of odour via an Odour Management Plan (OMP) has been shown to be poor, with little by way of prompt corrective action, especially where capital expenditure is required, adding to the ground swell for relocation of the existing plant. The draft OMP should include formal commitments to corrective actions and a suitable escalation path. 32) Anglian Water has been involved in discussions regarding relocation of the WWTP over a significant timeframe, prior to proposals in the consultation draft 2006 Cambridgeshire and Peterborough Minerals and Waste Local Plan. It is unclear to what extent this was considered when the existing plant was ‘future proofed’ in 2014/2015, along with the potential for consolidation on site. 33) Section 4.13 of the Non-technical summary volume 5.1 only appears to address the standard operational odour impacts measured by contour plot and excludes impacts relating to abnormal operations adjudged by the qualitative assessment. 34) With regards to Statutory Nuisance Statement Document 7.13 and Draft Development Consent Order (Document 2.1) Part 2, Principle Powers clause 9 (1) (d). The facility proposed is a brand new development, a significant proportion of which is proposed to be funded by the tax payer as set out in the Funding Statement. For avoidance of doubt the statutory nuisances set out in Statement 7.13 can all be reasonably avoided therefore no defence should be granted to proceedings under draft DCO clause 9 (1) (d). 35) Proposals for adding new pedestrian and cycle routes around the site appear to introduce conflicts in respect of odour. The proposal suggests a level of amenity will be provided through visitor provisions, such as visitor boards etc., typically associated with medium sensitivity receptors but the classification of potential footpath users as low sensitivity receptors assumes no amenity and recreational value of the paths proposed. 36) The Noise and Vibration Assessment states that the plant will be running 24 hour and contains night time plant operation results (Table 4-24) and daytime operational traffic results (Table 4-25) but does not appear to include night time operational traffic noise for which the differential to night-time baseline noise is more significant. Night-time movements are referenced in the Traffic and Transport document (5.2.19) to be 30% of HGV movements based on the existing plant. The Noise Assessment (document 5.2.17) should be completed to include night time operational traffic, or if already included should be made clearer. 37) The Baseline Noise Report 5.4.17.2 is incomplete and has sections missing. 38) No information appears to be provided in either the Lighting Design Strategy or the Lighting Assessment Report for the workshop. 39) As shown by the consultation responses, significant support continues to be present for a direct access from the A14. Numerous precedents exist of services roads and combined A/B junctions on dual carriageways. No information has been published from the reviews of option 3 prior to its exclusion, other than high level outcomes. 40) The intention regarding staff numbers at the proposed plant is unclear. The Project Description and Transport Plan suggest proposed staff numbers will approximately double at 38 with the draft DCO schedule 14 requesting a maximum of 70 parking spaces, despite having only circa 20 staff at the existing plant for a similar capacity. The capacity is understood not to increase significantly in phase 2 so this does not appear a like for like application. Anglian Water should clarify its intentions in this regard. 41) There is a general expectation that design and building practices will improve over time and it is positive that innovation will be applied to optimise the design and reduce the corresponding capital carbon cost accordingly. Alignment of construction cost to a 2010 baseline seems to have little relevance other than as an attempt to try and show the significant capital carbon cost of the proposed construction in a better light. Perhaps if a year 2006 baseline were selected this may assist with the remaining 22% required to achieve the 70% target. 42) No drawings have been provided to allow comparison of the 2010 carbon baseline design. 43) The Anglian Water consultation process and more specifically how the results have been summarised and presented, has not met the minimum statutory requirement. For a single phase 3 (statutory phase 2) consultation respondent ID checked, the reported results in Document 6.1.2 only show 3 consolidated comments yet the corresponding consultation response was extensive and provided responses to many important issues which have not been correctly summarised or reported. 44) There are inconsistencies and conflicts between submission documents. For example the limits of deviation shown in Design Plan document 4.10 do not match those in the Draft DCO Schedule 14 – Parameters. 45) The flexibility requested via the Rochdale envelope, instead of leaving a level of flexibility within controlled parameters, suggests the proposal is immature. 46) The proposed relocation is having a damaging effect on the mental health of local residents. 47) The Housing Infrastructure Business Case is misleading in a number of areas. The Anglian Water S35 application is also misleading and makes reference to the HIF fund award, amongst other things, as a justification for its national significance. 48) The Anglian Water DCO application in turn suggests that the presence of both the HIF award and the S35 determination demonstrate a National significance, both of which should be subjected to close scrutiny. 49) As a consequence, Anglian Water is being fully funded by the taxpayer and in turn local residents, to allow employment of an extensive range of consultants to promote incursion into the Green Belt for a property development venture. 50) Despite the use of professional consultants, the Anglian Water application has repeatedly been shown to contain significant errors. 51) It is daunting for Individuals or local groups to be able to address the magnitude of documentation and cannot hope to identify all errors, particularly those that could have lasting impacts on the local community. Consequently, many local residents who have justifiable concerns regarding the proposals have already been worn down.