Representation by Frederick William Hyde
- Date submitted
- 18 July 2023
- Submitted by
- Members of the public/businesses
Dear Sirs I am writing to object to the proposed relocation of the Milton WWTP. I have family connections to the area. My father was raised in Barton, Cambridgeshire and my aunt lives at [Redacted]. I am therefore very familiar with the area and have for the past two years been employed by a firm which specialises in planning communications. I have worked to bring forward successful Nationally Significant Infrastructure Project (NSIP) applications across England, and have managed statutory consultations for residential and logistical projects. I object to this application for the following reasons: 1) Anglian Water has stated on record that the proposed relocation of the Milton WWTP, is not operationally necessary. The existing site at Milton has undergone a recent upgrade. It is currently at 50% capacity and will be able to meet forecast demand for the next several decades. 2) The creation of a brownfield site through the relocation of the Milton WWTP is not necessary to meet the demand for housing created by the North East Cambridge Area Action Plan (NECAAP). Calls for sites have yielded alternative offers of land with sufficient capacity to accommodate the number of houses proposed for the Milton site. 3) The proposed site of the £227M WWTP is on Green Belt land and fails to adhere to the conditions set out in the National Policy Planning Framework (NPPF) for development on the Green Belt. The NPPF Section 12, para 137, states that “before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined all other reasonable options for meetings its identified need for development. This will be assessed through the examination of its strategic policies, which will take into account the preceding paragraph and whether the strategy makes as much use of possible suitable brownfield sites and underutilised land.” As stated above, calls for sites have yielded alternative offers of land with sufficient capacity to accommodate the number of houses proposed for the Milton site. 4) Much of the Green Belt land within the proposed site is Grade 2 and 3a, best and most versatile agricultural land. Significant weight is given to protecting such land from development by the NPPF, paragraphs 170 and 171, note 53. 5) The proposed Milton WWTP fails to demonstrate the social value required of a development of this scale. The Public Services (Social Value) Act 2012 calls for all public sector commissioning to factor in economic, social, and environmental well-being in connection with public services contracts; and for connected purposes. I am not convinced that the development of Green Belt site when alternatives can be found represents sufficient regard for this legislation. 6) The Honey Hill site falls within the National Trust’s Wicken Fen Vision. Wicken Fen is a site of Special Scientific Interest and is of major local and national importance. 7) The relocation of the Milton WWTP is not in keeping with industry best practice. Water and utility companies are increasingly opting to upgrade existing WWTP sites and install more modern equipment, instead of relocating the sites elsewhere. A recent example is United Utilities’ upgrade of its WWTP in Blackburn, Lancashire, to include Nereda wastewater treatment technology. The Blackburn WWTP is now among the largest purpose-built Nereda process plants in Europe and follows the upgrading of three similar United Utilities WWTPs in Kendal, Morecambe, and Failsworth. More information can be found here. 8) The relocation of the Milton WWTP would require sewage to be pumped uphill from the existing Milton site to the new Honey Hill site, which would be energy-intensive and not in keeping with industry best practice, which champions sustainability and the move towards Net Zero. In all drainage design, engineers rely as far as is practically possible on gravity to deliver effluent to WWTPs or surface water to watercourses. Pumping drainage would require an unnecessarily high energy usage for the duration of the WWTP’s lifespan. None of this would be required were the WWTP to remain at Milton. I therefore object to Anglian Water’s proposals for the Honey Hill WWTP and urge you to reject this planning application. Kind regards, Frederick Hyde