Representation by National Trust (National Trust)
- Date submitted
- 19 July 2023
- Submitted by
- Non-statutory organisations
The National Trust wishes to register as an interested party in respect of the application for a Development Consent Order (DCO) for the Cambridge Waste Water Treatment Plant Relocation (CWWTPR). The National Trust has significant land holdings in the locality of proposed CWWTPR site. The Trust owns Anglesey Abbey (a Grade I Listed Building set within a Grade II* Registered Park and Garden and an estate which extends to over 46ha) which lies approximately 2.4km to the northeast of the proposed development site. In addition, the Trust owns and manages approximately 800ha of land at Wicken Fen which lies approximately 7.5km north, northeast of the proposed development site. A significant area of this land forms Wicken Fen National Nature Reserve (NNR) and is designated as Wicken Fen Site of Special Scientific Interest (SSSI), and internationally designated as part of the Fenland Special Area for Conservation (SAC) and Fenland Ramsar site. A map of National Trust’s land ownership can be provided. Beyond its own landholdings, the Trust has an interest in the extensive area of land in the corridor between the River Cam and the B1102 stretching from the A14 in the south to Wicken village in the north. This land is recognised as the “Wicken Fen 100 Year Vision Area” and the Trust, working with partners and landowners, has a long-term ambition to see this 53 square kilometre area managed for nature conservation with improved public access for recreation, community engagement and learning. A map of the Wicken Fen Vision Area taken from the National Trust’s Wicken Fen Vision document can be provided. Areas of Interest Having appraised the submitted DCO documents, our areas of interest are: 1. Principle of Development and Green Belt Impact The National Trust recognises the challenges related to population growth, housing delivery and climate change in the East of England and the need to supply, treat and recycle water. Greater Cambridge Shared Planning (Cambridge City Council and South Cambridgeshire District Council) has been working on a new Local Plan (the Greater Cambridge Local plan) since 2019. The most recent public consultation (First Proposals, Preferred Options) was held in 2021. The latest update to the Local Development Scheme indicates that, following further public consultation, the Proposed Submission Plan will not be submitted for examination until Summer/Autumn 2025. It is currently unclear how many new homes will be required over the new Local Plan period. However, there is clearly an interdependency between this application and emerging proposals for the redevelopment of the existing wastewater treatment site in Milton. It is clear from documents prepared by Greater Cambridge Shared Planning that the regeneration of northeast Cambridge has been a long-held ambition for the Councils. The relocation of the wastewater treatment plant would enable the development of a new district in northeast Cambridge, delivering 8,350 homes, 15,000 new jobs and a wide range of community, cultural and open space facilities. However, it is noted that Greater Cambridge Shared Planning will not commit to including the site within the draft Local Plan or adopt the North East Cambridge Area Action Plan (NECAAP) until such time that a Development Consent Order is granted for the relocation of the Waste Water Treatment Plant. It is also noted that the proposed site is not allocated in the National Policy Statement (NPS) for Waste Water or the Minerals and Waste Local Plan. Furthermore, it is not identified in the Environment Agency’s National Environment Programme (NEP). It is also stated in the application documents that there is no operational need or requirement to replace the existing waste water treatment plant. The National Trust support the delivery of new development through a plan-led system and support the development of brownfield land in sustainable locations. However, in this case there is no adopted planning policy at national or local level which provides clear policy support for the relocation of the existing waste water treatment plant at Milton to an alternative site to enable development proposals to be realised. Whilst the proposal would release a brownfield site at Milton for redevelopment, the proposed new facility would also result in the development of a greenfield site within the Cambridge Green Belt and the loss of best and most versatile agricultural land. As identified in the Waste Water NPS these types of infrastructure project are likely to comprise “inappropriate development” and therefore there is a presumption against them as they are by definition harmful to the Green Belt. The NPS makes it clear that “very special circumstances will not exist unless the harm by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. A Green Belt Impact Assessment of the proposed development has been undertaken and concludes that, after mitigation, the Proposed Development would result in the loss of land which makes a strong contribution to two of the Green Belt purposes and would have a moderate impact on adjacent Green Belt land as a result of its encroachment into the countryside. The Applicant accepts that the proposed development would constitute inappropriate development and is promoting the application on the grounds that the very special circumstances required to justify the granting of the DCO are demonstrated. It states that the harm would be outweighed by the need for the proposed development and the substantial public benefits it will deliver. The National Trust’s position on development in the Green Belt is that it must be carefully managed, and speculative development is not appropriate. We acknowledge that there are some limited circumstances where development is acceptable, or where very special circumstances are clearly demonstrated which might outweigh harm to the Green Belt. Whether the very special circumstances put forward by the Applicant justify the grant of development consent will be a matter for the Secretary of State. 2. Landscape ad Ecology The site falls within the Wicken Fen Vision Area which was launched in 1999 in order to increase the nature reserve around Wicken Fen creating a diverse landscape for wildlife and people over an area of 53 square kilometres, expanding southwards towards the edge of Cambridge. The proposed development will remove scope to restore land at this location back to semi natural habitat in the conventional sense, but it is recognised that the development is planned to provide at least 20% Biodiversity Net Gain. The submitted Landscape, Ecological and Recreational Management Plan (LERMP, Application Document Reference: 5.4.8.14), and Environmental Statement recognises the Wicken Fen Vision and considers compatibility and alignment with the Vision in terms of habitat creation within development boundary. However, proposals are very limited as the geographical focus of the LERMP is on the immediate area around the proposed WWTP, not the entire project area. The Landscape Masterplan proposals should extend beyond the development boundaries and meaningfully contribute to ecological restoration and enhancement in the southern area of the Wicken Fen Vision area as well as providing enhanced recreational access opportunities and access to nature. At present ecological enhancement beyond the development site and at landscape scale is limited and should be explored further in the context of the Wicken Fen Vision objectives. Given the scale and significance of this development as a Nationally Significant Infrastructure Project, the proposed development of a greenfield site and the location of the site in the Green Belt and the Wicken Fen Vision Area, the Trust considers that the proposed development should be contributing significantly more towards the Local Nature Recovery Strategy and strategic Green Infrastructure initiatives, to benefit people, nature and climate. There are opportunities in the wider area to provide better access for multiple users and deliver landscape scale enhancements working in partnership with other Conservation partners. It is disappointing that Applicant is not proposing anything more significant beyond the site’s boundaries. 3. Hydrology/Hydrogeology The National Trust’s interests relate to concerns relating to impacts on our sites arising from: • Drainage from Site • Temporary dewatering in the West Melbury Marly Chalk Formation at the site • Treated effluent discharge The National Trust notes that the Applicant’s Habitats Regulations Assessment Screening Repot concludes no likely significant effect for Wicken Fen Ramsar/Fenland SAC on the basis that no hydrological impact is expected. Anglesey Abbey County Wildlife Site (CWS) was also scoped out as the Applicant considered that there were no hydrological or ecological pathways to the site. Our concerns relate to surface water and groundwater drainage from the application site. We are concerned that there are possible pathways between the site and Wicken Fen Ramsar/Fenland SAC and Anglesey Abbey CWS. We have concerns related to the proposed dewatering of the site, the high permeability in the bedrock and the potential for works and operations associated with the development to transmit pollution to groundwater. The Trust wishes to ensure that appropriate monitoring of water levels and water quality is in place before construction, during construction and during operation. On & off-site monitoring is required to determine impacts on sensitive receptors, including potential pathways to impact our sites. Advice should be sought from statutory advisers on the above matters. 4. Access and Recreation The National Trust notes the proposals for a new section of Bridleway to the northeast of the WWTP, as part of a 9.3km circular route (as shown in Figures 3.12 and 3.13 of the LERMP). The National Trust is generally supportive of the proposals for enhanced recreational connections and public access through new paths and green space. Enhancing public access aligns with the Wicken Fen Vision which aims to provide a varied for visitors to explore with benefits for health, well-being and community engagement. The proposed new bridleway access is welcomed, and a new pedestrian route will result in two circular walks, improving recreational opportunities for local residents and visitors. However, the proposed bridleway does not connect well to Anglesey Abbey and does not provide a direct route. This is likely to create conflict as the most direct and obvious route to Anglesey Abbey is to continue along the dismantled railway (not shown on submitted plans) in a north easterly direction, but this is on private land. During pre-application discussions the National Trust requested that Anglian Water explore the possibility of extending the new bridleway along the dismantled railway route to make this connection to Anglesey Abbey and is disappointed that this cannot be achieved. The proposed new bridleway and circular route also runs very close to and will facilitate access to Stow-Cum-Quy Fen SSSI (not owned by the National Trust but within the Wicken Fen Vision area) and beyond that to Anglesey Abbey. The Trust is aware that Stow-Cum-Quy Fen SSSI is already under significant visitor pressure. We recognise that an uplift in recreational use of the area could have negative implications on sensitive designated sites through increased disturbance, damage, contamination, etc and also impact on the surrounding public rights of way. The impacts of this application must be considered cumulatively with uplift in recreational use of the area associated with the proposed housing growth which will be delivered through the existing and emerging Local Plan, including the housing which will be enabled by the proposed development. The Trust considers that the impacts on the SSSI and surrounding area have not been adequately assessed. The assessment is missing robust baseline visitor surveys, a recreational impact assessment, and a recreational management strategy, including appropriate mitigation measures.