Representation by Baroness Janet Cohen of Pimlico
- Date submitted
- 19 July 2023
- Submitted by
- Members of the public/businesses
I object to Anglian Water’s application for a new Waste Water Treatment Plant at Honey Hill and ask the Inspector to reject it on grounds set out below. Background Anglian Water’s proposal is not because it needs to move its current sewage plant for operational reasons from its suburban site in North-East Cambridge. It does not need to move. It has plenty of capacity. The City Council saw an opportunity to build homes on the site as part of its local North East Area Action Plan (NECAAP) and was promised central Government funds to cover the cost to Anglian Water of moving since Anglian Water could not fund a move in advance of need through the regulatory process. Objections My objections and the grounds for rejection of the application are: 1. Legal and Procedural The project should not have qualified as a Nationally Significant Infrastructure Project (NSIP) as a waste water treatment proposal. It arguably achieved this status only because it had already been accepted by the Housing Infrastructure Fund (HIF) in February 2019. NSIP status should be irrelevant in assessing the merits/demerits of the proposal to move the plant and select Honey Hill for the new plant. Freedom of Information; for example, Homes England refused access to information legitimately requested for independent assessment of the arrangements and extent of central Government funding. The Inspector should over-ride any such failures to provide information on the principles we have recently seen applied by the High Court. When the Feasibility Studies were carried out for selection of a new site for the plant, remaining on the current site was not included as a comparator. Failure to include this as a baseline since there was no operational need to move, is a fundamental error in assessment. The Housing Infrastructure Business case and the Anglian Water DCO Alternatives documents allude to consideration of staying on the current site, but the reviews have not been published so it is impossible to assess the quality of any analysis. 2. Use of taxpayers’ funds and value for money When growth requires Anglian Water to move the plant to fulfil its statutory obligations [i.e. when it is out of capacity], it would fall within the Regulatory Review and would have to be funded by Anglian Water itself and its customers. This makes use of taxpayers’ monies to fund the move when it is not operationally necessary highly questionable. Current and prospective pressures on Government funding also make it questionable whether this project is now a good use of taxpayers’ funds, even if this seemed reasonable when the application for central Government support was made. Further, it must be doubtful whether it is value for money to compensate Anglian Water to allow housing development rather than support the City Council to build affordable housing elsewhere, which might well be at a lower cost. Since a General Election is due no later than January 2024, the Inspector should seek advice on whether the Department responsible can fetter the decision rights of the next Government by committing funds. 3. Growth The region has the potential for rapid growth, but Anglian Water’s proposal has not been effectively integrated into how best to achieve this in terms of natural resources, hubs for employment, housing and new infrastructure including water and sewage. The Department for Levelling Up’s recent suggestion for building 250,000 new homes by 2040, very substantially above existing proposals, is evidence that plans aren’t settled enough for a firm basis for investment. Employment in the Cambridge area is polycentric with many commuters having to cross or go round the city to employment on one of the other sides of the city, outside the centre. This means that a major housing scheme in the inner suburbs increasing congestion inside the city may not be best use of the land, particularly since it lies on the “wrong” side of the incoming A10 for access to the A14 necessitating significant financial support for roadworks. If more of the employment growth happens in other major towns in the region, priorities for waste management may shift and road infrastructure costs may be lower. 4. Water and sewage viability It is uncertain whether the region has enough water for extraction to meet current housing proposals, let alone further developments, in and around Cambridge itself. The Inspector handling the appeal against a refusal to grant permission for development of land north of Cambridge North Station, which like Anglian Water’s current site, is within Cambridge’s NECAAP, held a round table discussion, at which it became clear that developments are stalled because of the environmental impact of water scarcity and slow progress on mitigations. The Environment Agency and Natural England, who were present, have stated that: “… waterbodies on the Rivers Cam and Granta are already impacted by abstraction and on the basis of the evidence it is predicted that any increase in abstraction (including servicing this development will result in the increase the existing pressure [sic] and extend its impact to include abstraction from other water bodies utilised by Cambridge Water.” (Environment Agency) “NE are not confident that water can be supplied to new developments without risking further deterioration to water dependent SSSIs and supporting habitats.” (Natural England) The outcome of the further work currently in hand could determine the shape and extent of the area’s housing developments and hence, by extension, the needs for waste management as well as water resources. Were this further work to affect the viability of using Anglian Water’s current site for housing or for using it as the same level of density as planned, it would clearly require fundamental review of the proposal. According to DEFRA, the Principal Chalk Aquifer under Honey Hill is at high risk of groundwater contamination and makes the site unsuitable for construction of this sort of structure. Chalk aquifers are of great significance for water resource management in the region, as well as a unique feature of the English landscape, and require protection. It is unclear whether Anglian Water has a regional sewage management plan that will meet standards and that building the new plant at Honey Hill is the best use of its scarce management resources – the Regulator has assessed Anglian Water as one of the two worst service providers in the industry. From the area’s point of view, improving its performance dramatically should its over-riding priority. 5. Other environmental issues and the choice of Honey Hill Honey Hill is in the Green Belt. Any new construction on Green Belt land should be against clear rules approved by Parliament, not by piecemeal breaches determined locally. For Cambridge to attract the international investment needed for growth it has to remain an attractive place for people coming from as far afield as Seattle to Frankfurt to want to work, which means sustaining green space, particularly in the face of climate change. The impact on the Conservation Areas of Fen Ditton and Horningsea; Honey Hill is a recognised recreational area Northeast of the A14. The impact on Quy Fen, a Site of Special Scientific Interest (SSSI), which backs on to Honey Hill. The Office for Environmental Protection gave evidence on 4 July 2023 to a House of Lords Committee that: “… Regrettably, what government must now do will take some time … It has an environmental improvement plan, but it needs a delivery plan underneath it for each of its goals. One of its biggest and most immediately pressing goals relates to halting species decline, and central to that plan are the SSSIs. You will know, because you have heard evidence on it, about the poor condition of those.” Impact on other environmental and historic features of the fenland, such as the Dykes and Wicken Fen. Constructing a new plant with a high carbon content in advance of need adds to climate change. Alternative sites for a new plant If the Inspector is minded to reject the application to build at Honey Hill but has received and can make public reliable evidence to support the case for Anglian Water moving from its current site, there are alternative sites within convenient reach of the city, two of which Anglian Water considered. Both sites lie in a triangle of land between Milton, Histon and Landbeach just north of the A14 and just west of the A10, the main road from Ely to Cambridge. Milton, Histon and Landbeach are all larger villages than Horningsea and objected to these options. However, the area immediately north of the A14 and west of the A10 is already more heavily developed, with the Milton Park and Ride, and the City’s Recycling Site at Milton. It would be a more natural area for further development than the Honey Hill area. An updated and public feasibility study would also allow us to understand the relative costs of moving to different sites and hence the relative subsidy required from public funds if the move is to be made in advance of need. Anglian Water’s application gives the estimated cost for Honey Hill as £227m. However, a figure of £167m for a plant north of the A14 at Milton [i.e. close to the A10] was made available by the City Council in response to a Freedom of Information request. This is a material difference, with several potential explanations: e.g. costs may be truly different between sites or there may be excess headroom in Anglian Water’s estimate, which would not be in the public interest. Design If the Inspector were minded to approve the application, he should assess whether the design minimizes the impact on the area, as local architects have suggested it does not and that it could be improved. Baroness Janet Cohen of Pimlico 19 July 2023 [redacted]