Representation by Elizabeth Cotton
- Date submitted
- 18 July 2023
- Submitted by
- Members of the public/businesses
Project: Cambridge Waste Water Treatment Plant Applicant: Anglian Water Services Limited Relevant Representation of Ms Elizabeth Cotton of [REDACTED] Dear Sir/Madam, My representation is in three parts. The first is regarding the direct impact on my home and my family. The second part is a response to the application and reasons why this relocation should not go ahead. The third part is a detailed response to The Strategic Whole-Life Carbon Assessment (doc ref. 7.5.2) Project: Cambridge Waste Water Treatment Plant Applicant: Anglian Water Services Limited Relevant Representation of Ms Elizabeth Cotton of [REDACTED] I live with my husband Phil and our two adult children, [REDACTED], in our family home, [REDACTED]. The Property is a [REDACTED]. The Applicant has omitted our Property from the proposed order limits for the DCO. However, our Property is surrounded and enclosed by a substantial suite of Works for which consent is sought as part of the Project. The Applicant is expecting to use to our drive and the concrete areain front of the house (Parcel 21a and 21i) for construction, operation and maintenance of the Waterbeach pipeline and compounds; transfer tunnel and compounds; the outfall; and the ecological mitigation area. These Works are wholly inconsistent with our residential amenity. We refer the Examining Authority to Sheet 3 of the Works Plans which the Applicant has submitted as part of the Application. The Examining Authority will see from this plan that our Property and its shared access off Horningsea Road shall be: 1. adjacent two transfer tunnel and pipeline construction area compounds during the construction phase of the Project; 2. near significant pipeline construction access areas to facilitate construction vehicle access from the Horningsea Road to the construction compound areas, as well as substantial highway works at Junction 34 of the A14/Horningsea Road to facilitate the Project; 3. near the route of the underground transfer tunnel immediately adjacent; and 4. one of the closest residential properties to the outfall into The Cam. It is clear from this plan that the impact on our Property shall be severe. Notwithstanding the Applicant has chosen to omit it from the proposed Order Limits. We propose to take an active role in the forthcoming Examination to highlight the planning harm which would be caused by the Project, if it proceeds as currently proposed, to our Property and residential amenity. We will demonstrate that notwithstanding the assessments undertaken by the Applicant, that the Project shall have a significant and unacceptable impact on our residential amenity, and our family's personal well-being and quality of life. Over the short term that would be due to the substantial construction impacts of the Project. Over the medium to long term, that would be due to the Project's substantial operational impacts within the vicinity of our Property. We will demonstrate that the current suite of mitigation measures proposed by the Applicant will be insufficient to remove this planning harm. We will urge the Examining Authority to ensure that the DCO is amended in such a way as to ensure these impacts are mitigated appropriately and that we are suitably compensated by the Applicant for the long-term harm the Project poses to our residential amenity our home. A summary of the key points we will develop over the course of the forthcoming Examination are as follows below. Significant Impact on Residential Amenity The significant impact on the residential amenity of occupiers of our Property can be summarised as follows 1. Noise and vibration. We have not, as asserted by the Applicant at 3.2 in the Community Questionnaire (5.4.11.1) been approached as a stakeholder about the impact of construction noise and vibration. We both work from our Property. I am a musician with a recording studio. The noise and vibration from the transfer tunnel construction will be such that acoustic barriers will need to be erected around the shafts 4 and 5, and pre- and post-construction surveys will have to be made on the house to assess damage (5.2.13). We will be unable to work. 2. Visual Amenity. Our garden adjoins a meadow where the proposed transfer tunnel will pass. Views from our garden and the window and side door to the south west of our Property directly overlook meadow the meadow which will be destroyed by the construction of the transfer tunnel. Overall, our Property will be encircled and ensnared by the Project and have a significant conspicuous visual impact at our Property. As currently proposed, the Project completely fails to appropriately mitigate this impact which will be significant both during the day, and at night. In hours of darkness, the impact of construction lighting will create a further unacceptable, significant, impact on the residential amenity of our Property. 3. Construction and Operational Traffic. Our Property is next to Junction 34 of the A14 which would be impacted from the potential 492 additional daily vehicles, including 280HGVs and slurry lorries per day associated with the construction of the Project. This amounts to a huge increase in traffic movements, and is completely incompatible with our residential amenity and safe access to our Property for our family and visitors. 4. Odour. We note the Applicant has chosen not to allocate our Property an odour receptor ID. Our immediate neighbours on both sides have IDs. We are extremely concerned that odour from the Project shall pose a detrimental impact on our residential amenity. 5. Severance of Property. The rights of way to access neighbours in Red House Close and Fen Ditton and Cambridge (established over 20 years) and Milton surgery and supermarket along footpath leading to Baits Bite will be removed as a consequence of the Works. Further, as a consequence of shafts 4 and 5 of th e transfer tunnel being located in fields to front and to the side of our Property, our ability to access local town and village amenities on foot and cycle will be removed. This will sever access from our home to neighbours and nearby amenities. 6. Dust. We are concerned about the impact of dust and emissions created by the Project on our residential amenity. The individual and cumulative effect of the impacts set out above will have a significant impact on the [REDACTED] of occupiers of our Property. Already out [REDACTED] of the proposed Project. My [REDCATED] if the development consent order is granted for the Project in its current form. Listed Building Our Property, [REDACTED]. Our Property has no foundation and has an underground cellar and is vulnerable. We are extremely concerned that the Applicant has failed to appropriately assess and mitigate the impact of the proposed Project on the fabric of this heritage asset, both during the construction and operational phases of the Project. The Applicant asserts that the Project shall have a ‘lower end of less than substantial’ impact on the setting of our Property. We disagree. We will bring evidence to demonstrate that the Project will have an unacceptable impact on the setting of the listed Property. The high heritage value of [REDACTED] will be severely blighted by invasive construction impacts (e.g. noise, views and artificial light-spill) and new built development. We wish to bring to the attention of the Examining Authority and the Applicant that our Property has been mistakenly referenced. [REDACTED] is referred to as HEO40 throughout the application documentation but is referenced as HEO33 in the Gazetteer of Assets (5.4.13.2) Engagement with the Applicant It is a severe disappointment that the Applicant has had little contact with us during the pre-application period. We did receive a letter from the local planning authority, Cambridge City Council, in December 2021 about a related application to drill exploratory boreholes in the field in front of us. However, this was only because the work had overrun and consequently, a planning application had to be sought, and it was in this regard that we first met with the Applicant’s representatives from Savills. Otherwise the Applicant has completely failed to engage up until that point and consult with us in any meaningful way. We initiated the conversation about vents ourselves, nothing was volunteered. The applicant has not fully discussed with us the proposed Works and their short and long-term impacts on our quality of life and the residential amenity of our home. They have certainly taken no formal note of our business, as stated in 3.2 of document 5.4.11.1 Without prejudice to our significant reservations about the appropriateness of the proposed Project, we invite the Examining Authority to closely examine its impact on our Property. We invite the Examining Authority to ensure that the Applicant appropriately assess and mitigate the significant impacts which the Project will have on our residential amenity and Property. These impacts we believe currently amount to clear planning harm. We will request the Examining Authority closely examine the impacts on our Property and our residential amenity, and provide us with adequate opportunity to put our case during the forthcoming Examination. Additionally, we would take the opportunity in this Relevant Representation to invite the Applicant to engage with us appropriately. Through the auspices of the Examining Authority we invite the Applicant into our home to discuss, reflect on and appropriately assess the significant negative impacts which the Project shall have on our residential amenity and our Property, briefly summarised in this Relevant Representation. These impacts will not be minimal, nor at a level which is remotely acceptable. These impacts are all the more ironic and glaring due to our Property having a septic tank, and not being connected to the public sewer system operated by the Applicant. In short, the Examining Authority should note that the Applicant is seeking to saddle our Property and family with severe planning harm without our Property even benefiting from the asserted benefits to the wastewater system the Applicant believes the Project shall provide. This is wholly inequitable and unacceptable. The Examining Authority will wish to note that at the current time, for the reasons set out in this Relevant Representation, our family has no option but to object to the grant of the proposed development consent order for the Project. Part 2 The damaging effects on health have already been widely felt by the community as evidenced by the campaign that has been mounted, donations that have been raised, protest choirs that have been assembled. The damage to our physical and mental health in the future will be significant, not insignificant as stated in 5.1. The negative impact of relocating the sewage plant on local people, on the landscape, on biodiversity and on climate change is not justified, as Anglian Water fails to establish a need or overriding benefit to the community. The number of responses would have been even greater if the role of the Planning Inspectorate in deciding the outcome had, sadly, not been undermined. By frequently failing to explain that the development of the ‘core site’ of North East Cambridge Area Action Plan is dependent on the success of their application, Anglian Water has unfortunately misled the public, with sponsored adverts that look like proper articles in the local press; through a project called Cambridge Curiosity and Imagination; through the rebranding of the core site after suffragist mayor Eva Hartree; by co-hosting stalls at Strawberry Fair and Arbury Fair; and all the while making no mention of the dependence of the project on a decision by the Secretary of State. Nor is the promise of funding from HIF a reason to approve the plan. Public money should not be paid to a private water company who, according to April 2023 National Policy statement (see below for further comments), must only be applying to build new infrastructure when there is a need, in order to meet future demands for sewage management. The plan does not meet the criteria for social value as outlined in the Social Value Act 2012, as there is no tangible benefit to the community that will, in varying degrees of severity, be affected by noise pollution, light pollution, odour pollution, pollution from increased traffic and groundwater pollution (it will be located above a principal chalk aquifer) and with the increased danger to young children attending the primary school who will have to navigate a much bigger and busier new junction to get to school. There is no doubt that the community’s sense of place and well-being will be significantly negatively impacted. There is no overall environmental benefit. The Wicken Fen Vision will have to be cancelled, a plan to extend the UK’s most species-rich nature reserve because, according to the National Trust, it is currently too small and isolated to guarantee the survival of its rare and numerous species. The UK is one of the most nature-depleted countries in the world and the Environmental Audit Committee’s 2021 report asserts that measures must be taken to counter this collapse. Anglian Water’s claim that their plan to put a sewage plant next to the nature reserve is better for biodiversity with its ‘mosaic of new habitat’ (7.7: 4.10.17) than the Wicken Fen Vision is plainly not true. The harm to Green Belt is significant. The big open sky, for which the Fens is famous, surrounding the historic city of Cambridge, and contributing to its setting as a nationally-significant historical asset, will be destroyed by unsightly digesters that cannot be sunk into the ground because of the nature of the soil. The attempt to turn the new plant into something akin to a hill fortress is not in keeping with the landscape because there are no hills in the Fens and the landscape is defined by its flatness. The mitigation that Anglian Water proposes in the circulated documentation is a full double-page spread of a picture of thorny, leafless brambles that we could hope to enjoy in 15 years’ time, with descriptions of increasing recreational possibilities that will have positive effects on our health. There are already rights of way established through this countryside where one can walk without the odour of a sewage plant. The loss of vegetation and wildlife, the presence of a large scale permanently lit waste-water infrastructure on Green Belt, in conservation areas, over a chalk aquifer, next to a primary school, a large new effluence discharge outfall structure on the river Cam ruining the river for rowers, walkers, and killing wildlife, the huge increase in road traffic, not to mention enduring three years of construction and all at a massive carbon cost (see above) make this project one that should be rejected. The Strategic Whole-Life Carbon Assessment (doc ref. 7.5.2) is a crucial document in the application, aiming to demonstrate the environmental benefit of relocating the WWTP. However, it has not been assessed by independent experts in the field of carbon counting. The document lacks a detailed breakdown of figures and fails to quantify emissions from the demolition of the existing plant and the remediation of the site, which should have been considered (see Chapter 10, 2.4.4). Consequently, the assessment does not adequately evaluate the whole-life carbon impact of the relocation. It also attempts to minimize the immediate carbon cost of the relocation by offsetting it against hypothetical future savings. There is a missing graph, and inconsistencies in calculations (see Aspect 3 graphs for commuting for both conservative and optimistic scenarios). As recognised by the government's Nationally Determined Contribution to reduce greenhouse gases 68% before 2030 and Cambridge City Council's strategy to achieve net-zero emissions by 2030, it is in the immediate future, first and foremost, when we must be reducing emissions. The emissions resulting from demolition, decontamination, tunnel construction, new junctions, additional slurry lorries, and construction of the new plant would have an immediate and significant impact. These emissions cannot be offset by potential future gains 57 years from now. The breakdown for Aspect 1 (WWTP) over the time frames. 1,2 and 3 is missing, and its absence is noteworthy. Furthermore, the document states that these time period breakdowns do not account for the decarbonisation of the grid. The document, first of all, does not factor in the need for air conditioners for the homes on the Core Site where the sewage plant is currently located. Because of noise and pollution from the major roads, the windows of the homes will have to be kept closed. The document states that relocating the sewage plant would result in significantly higher carbon emissions compared to modernizing the existing plant. It is unclear whether these figures include emissions from the demolition and remediation and when they would occur. All the detailed breakdowns for housing and commuting consider the mid-point scenario: as explained on p8 ‘this central estimate, given that it is the middle ground between the two extreme scenarios, is largely used to present comparisons in this report’. By extension, it is also the mid-point scenario that must surely therefore also be considered for Aspect 1, WWTP. It is interesting to note that all the comparisons between counterfactual and proposed for Aspect 2 and 3 are in terms of increases, apart from the comparison for Aspect 1, the WWTP. 74% fewer carbon emissions if the plant is not relocated, is the same as saying nearly 400% increase in carbon emissions if it is relocated. In fact, on p14, the graphs indicate that under the mid-point scenario even the operational carbon cost over 60 years for an upgraded plant at Cowley Road will be less than the operational carbon of the proposed new plant – 8k rather than 13k. Although that 13k figure must be wrong. According to Mott Macdonald’s report on the carbon costs of different tunnel lengths, used to justify choosing Honey Hill as a location, site area L (Honey Hill) operational carbon cost of the transfer tunnel alone would be 21,382 over 18 years. The document justifies the absence of counterfactual data for zero carbon policies in Aspect 1 (WWTP) by stating ‘Giving funding limitations it is unrealistic to retrofit the WWTP to a high level, i.e.biomethane production’. It should not be the case that a private water company will only aspire to the highest environmental standards if the government pays them to do so. It should not be the government's responsibility to fund the improvement of water companies' environmental standards. Setting such a precedent would not be a good thing. The reason for larger and less dense homes in the proposed hypothetical counterfactual location is unclear. Assuming at least 600 houses could be built in North East Cambridge, (or more if the development was geared towards housing rather than growth and WWTP improved its odour management), the total number of houses in the area would be 8,350 minus 600+, and the homes could also be of a similar size and density. During the most crucial period, Period 1 (2026-2042), the carbon emissions for commuting remain the same in both the counterfactual and proposed scenarios. The carbon cost difference for housing between the scenarios is 0.1M for Period 1. However, considering the potential number of homes that could be built in North East Cambridge if the WWTP remained in its current location (at least 600 homes, representing 7% of the total), this 0.1M carbon saving for housing should be reduced by 7%, resulting in only a saving of 93,000. These adjustments indicate that the immediate impact of greenhouse gas emissions resulting from the relocation is far from negligible and is, in fact, greater than the savings made, and that is without quantifying the carbon cost of the demolition. It is unacceptable that the full carbon cost associated with this relocation has not been declared in the application. The April 2023 National Policy statement specifies that Anglian Water must demonstrate the "need" for the project to meet future demands for water and sewage management resulting from a growing population. However, there is no mention of the need to build infrastructure to facilitate economic growth in the area. Economic growth could be considered a side benefit of the new infrastructure but cannot serve as the sole justification. The National Policy primarily focuses on addressing and managing the pressures on water supply caused by population growth, preventing unsustainable abstractions of valuable chalks streams, and enhancing resilience to drought, which is a major concern in the East of England. A waste water infrastructure should not directly contribute to increasing these pressures. A future-proofed water resource already exists to accommodate planned growth, and if necessary, it can be upgraded with much less environmental impact than relocating the sewage plant. The current site of the WWTP is not the most sustainable location for housing due to the carbon emissions associated with the relocation. The strategic whole-life carbon assessment (doc ref. 7.5.2) fails to prove otherwise. Both Cambridge City Council and South Cambridgeshire District Council have explicitly stated that the relocation is not a requirement. The comments in the policy regarding minimizing damage to biodiversity are relevant to the "need for new infrastructure," which does not apply to WWTPR. Since there is no operational need, and the local councils do not require it, there is no justification for moving this recently upgraded sewage plant, which can be upgraded even more to respond to population growth, and there is certainly no exceptional circumstance to justify the harmful development of Green Belt land. Elizabeth Cotton