Representation by Tristram Riley-Smith
- Date submitted
- 18 July 2023
- Submitted by
- Members of the public/businesses
Introduction. I am a long-term resident of Fen Ditton (30 years). My home is closer to the existing Waste Recycling Centre (WRC) at Cowley Rd than the proposed site on Honey Hill. The prevailing wind also means that I experience odour from existing plant periodically; this is highly unlikely to happen if the plant was relocated. However, I object to the relocation because it represents inappropriate development on the Green Belt, where the harm caused to the purposes of Cambridge’s Green Belt eclipses any potential benefits. I have studied the documents submitted by Anglian Water (the Applicant) that present arguments for relocating the WRC to Honey Hill. My conclusion is that the grounds for approving this relocation appear very weak and should be rejected. My main objections are based on an absence of justifiable need and evidence of high harm to the Green Belt. I set out my main arguments below. 1. There is no operational or strategic justification for relocation. 1A. This is not a Nationally Significant Infrastructure Project and the Applicant has acknowledged that in the absence of consent for this DCO project, Cambridge and Waterbeach’s combined and growing waste water recycling needs will need to be served at the existing Cambridge WWTP. 1B. Neither Cambridge City Council nor South Cambs District Council Local Plans contain policies that require or explicitly support relocation of the Cambridge WRC or identify a suitable site for that relocation. 1C. The proposal is not compliant with Minerals & Waste Local Plan which contains no policy or specific reference to any relocation of the Cambridge WRC. 2. The proposal runs counter to key policies in the National Planning Policy Framework (NPPF) and the adopted plans of Local Planning Authorities, in relation to harm to Green Belt. 2A. The Applicant accepts that the PD is inappropriate development in the Green Belt. 2B. Relevant Green Belt policy tests have not been met especially in justifying why the benefit of development outweighs harm to the fundamental aim of the Green Belt which is about urban containment (encapsulated in para 137 of NPPF: “The policy is ….keeping land permanently open. The essential characteristics of Green Belts are their openness and permanence”. 2C. The Applicant uses the Greater Cambridge Green Belt Assessment undertaken by Land Use Consultants (LUC) in 2021 as its point-of-reference for the assessment of harm to the Green Belt (in its document 7.5.3). LUC rates the potential harm for the area in question as ‘very high’ (the highest rating). 2D. The Applicant has overlooked a second, important assessment undertaken in 2002 by Land Design Associates (LDA). The Applicant includes this “Cambridge Green Belt Study” in its list of references at the end of 7.5.3 - as “SCDC. (2002)” - but surprisingly makes no reference to it in its text. 2Di. This Study is regarded as a seminal document in the production of “South Cambs Adopted Local Plan”, with a web-page dedicated to it under the heading of “Stages in the preparation of the Local Plan 2018” (see https://www.scambs.gov.uk/planning/local-plan-and-neighbourhood-planning/the-adopted-development-plan/stages-in-the-preparation-of-the-local-plan-2018/cambridge-green-belt-study-september-2002/). “We appointed LDA,” the South Cambs webpage states, “to undertake this study to assess the contribution that the eastern sector of the Green Belt makes to the overall purposes of the Cambridge Green Belt. … This study … describes and illustrates the factors that contribute to the setting and special character of Cambridge. It then focuses on the qualities to be safeguarded to preserve this setting and special character.” 2Dii. The Study highlights “a circle of inner necklace villages, which are shown on drawing number 1641LP/07. These are villages that, due to their close proximity to Cambridge, play a particularly important role in the immediate setting of the city.” (p59). These villages include three settlements most affected by the relocation of the WWTP: Horningsea, Fen Ditton and Stow-cum-Quy. In fact, one of the green line-and-arrow symbols used on the drawing to denote “open countryside separating inner necklace villages and these villages and Cambridge” passes directly through the site of proposed development. [A separate drawing, 1641LP/14, includes this open countryside under “Special Qualities to be Safeguarded”]. 2Diii. The Study also describes the “Eastern Fen Edge” as one of four local landscape character areas that “play the greatest role in contributing to the special quality of Cambridge as a city set in a rural landscape.” This is “an important part of the setting and special character of East Cambridge and should be preserved. … It is important that this character is conserved.” (7.4.14-15) It is clear from drawing number 1641LP/05 that this Eastern Fen Edge includes the Honey Hill area where the proposed Waste Water Treatment Plant (WWTP) would be located. 2E. This landscape is distinctively open, with tree belts, hedgerows and reed-fringed ditches creating a mosaic effect that would be substantially altered by the proposed development. The Applicant has argued (at para 6.1.6 of its document 7.5.3) that the proposal will cause only “moderate harm” to this tract of Green Belt. This needs to be challenged, because the insertion of a quasi-industrial WWTP into this location can only cause great harm to the purposes of the Green Belt. 2Ei. The proposed design and layout does nothing to mitigate the impact, introducing a round hillfort structure on the flat, open countryside of the Eastern Fen Edge, with industrial structures rising above. When odour, noise, traffic movement and light pollution is added to the equation, the damage to the Green Belt will be excessive, visible from long distances including local villages and heritage sites (such as Biggin Abbey). Conclusion. In its Planning Statement, (4.8.44) the Applicant argues that very special circumstances exist that outweigh any harm caused by the development. These arguments fail to persuade. This Application should be rejected because of the absence of a credible need (see “1” above)) combined with strong evidence of substantial harm that would be caused to Green Belt Purposes (see “2” above).