Waterbeach New Town SPD

"Cambridge Without Incineration Residents Group Comment on Draft SPD for Waterbeach New Town. CBWIN is a group of several thousand local residents concerned about sustainable waste management solutions for Waterbeach and Cambridge as a whole. We formed when an application for a giant waste incinerator was proposed in 2017 for Cambridge. We are not activists or politicians, just ordinary professional people trying to ensure our health, environment and democracy are protected, and truly innovative solutions to waste are adopted.

This development and the combined developments of Urban and Civic and RLWE will produce enormous amounts of household, commercial and building and demolition waste. U+C plans show early indications of 3 energy from waste plants on the barracks site (no further specifics provided which is alarming in itself). Cambs County Council have rejected a massive waste incinerator proposal (thankfully) and we are in an intense climate of awareness of the limitation and negative environmental impact of a number of waste solutions that until now (including incineration) were considered 'good'. Incineration and energy from waste is a very toxic subject, and there are fast falling away EU legislations, impact of Brexit, forthcoming incineration taxation and emerging innovative technologies (e.g. UK plants that can recycle nappies and sanitary waste instead of landfilling it or burning it) in a zero-carbon way. We are concerned that the SPD offers no limits to the types of waste management that could be applied for by the developers or external companies. The SPD must contain restrictions on the building of anything except the EU's top 3 energy from waste solutions- this will allow for innovative technology to be included as technologies supersede each other over the years and displace older dirtier technologies (as anaerobic digestion has done to incineration in the EU waste management hierarchy in the last 5years). This will ensure a development that stays abreast of waste innovation and employs the most advanced technology of the time when the time comes to building. Especially given the dense population that will live there and the enormous effect that tens of thousands of houses, residents nd workers will have on air quality.
We note also that there is no provision for an area air quality management plan. What calculation can SCDC make with the lives of people who may live on this new development: especially children and unborn babies who we know are the most vulnerable population to air pollution? Scientific consensus is clear- air pollution impacts the most vulnerable in society (older people, infants, and unborn babies, and those with pre-existing chronic health conditions).
https://www.rcplondon.ac.uk/projects/outputs/every-breath-we-take-lifelong-impact-airpollution

-The Annual Report of Chief Medical Officer on Health Impacts of Air Pollution 'Health Impacts of All Pollution - what do we know?' Dame Sally Davies "Air pollution is not just environmental issue, government need to bring in tougher standards to tackle toxic air. Air pollution is thought to cause and contribute to as many as 40,000 deaths a year in the UK already, especially among vulnerable people such as those with existing respiratory problems, and young children, whose health can be permanently damaged by exposure to the pollutants at a young age" The government's air quality plan has been condemned as so poor as to be unlawful by the high court.
Addressing pollution is therefore disease prevention. Pollution should be recognised for what it is - a significant cause of non-communicable diseases like cardiovascular disease, cancer and asthma" https://www.airqualitynews.com/2018/03/02/chief-medical-officer-calls-tougher-airpollution-standards/

-Joint Parliamentary Committees Report on Air Quality - unprecedented guidance that directs and shapes existing local City and County Council and SCDC air quality management plans: all of which have objectives to reduce not increase air pollution

"Air pollution cuts short an estimated 40,000 lives across the country each year, costing the UK an annual £20 billion. Children, the elderly, and those with existing medical conditions are at the greatest risk. The UN special rapporteur recently said he was "alarmed that despite repeated judicial instruction, the UK government continues to flout its duty to ensure adequate air quality and protect the rights to life and health of its citizens. It has violated its obligations" ... The Government cannot continue to put public health at risk" https://publications.parliament.uk/pa/cm201719/cmselect/cmenvfru/433/433.pdf https://wintoncentre.maths.cam.ac.uk/news/does-air-pollution-kill-40000-peopleeach-year-uk


- Current UK Air Quality Directive: "Fine particulate matter (PM2.5) is responsible for significant negative impacts on health. Furthermore, there is yet no identifiable threshold below which PM2.5 would not pose a risk. As such, this pollutant should not be regulated in the same way as other air pollutants. The approach should aim at a general reduction of concentrations in them urban background to ensure that large sections of the population benefit from improved air quality. However, to ensure a minimum degree of health protection everywhere, that approach should be combined with a limit value, which is to be preceded in a first stage by a target value."

Underpinned by the current EU Ambient Air Quality Directive (2008/50/EC) which sets legally binding limit values for concentrations of major air pollutants that impact public health, such as particulate matter (PM10 and PM2.5) and nitrogen dioxide (NO2). The directive also sets limit values for a range of other pollutants that waste incinerators produce. https://uk-air.defra.gov.uk/air-pollution/uk-eu-policy-context


- COMEAP Committee on the medical effects of air pollution 2009 "Results of large cohort studies suggest that the effect of long-term exposure to air pollution on mortality is most closely associated with ambient levels of fine particulate matter (PM2.5) and that there is no evidence for a threshold below which effects would not be expected."

Recognising the significant impact that poor air quality can have on health, the Public Health Outcomes Framework includes an indicator relating to fine particulate matter (PM2.5). At its heart, the indicator for air pollution is about raising awareness of the effect of air pollution on public health. It is intended to encourage promotion of the need for local, regional and national actions to
reduce air pollution. This is intended to enable Directors of Public Health to prioritise action on air quality in their local area to help reduce the health burden from air pollution.

https://www.gov.uk/government/groups/committee-on-the-medical-effects-ofair-pollutants-comeap


- DEFRA's Local Air Quality Management Policy Guidance 2016.
"The impact of exposure to particulate matter pollution (PM2.5) is estimated to influence mortality equivalent to nearly 29,000 deaths in the UK. Improving air quality will also reduce damage to water quality, biodiversity and crops. Oxides of Nitrogen can contribute to eutrophication of waterways affecting aquatic life. They can react in the atmosphere with volatile organic compounds to create ground level ozone which damages crops as well as having its own health impacts. Tackling air pollution is a priority for Government. As PM2.5 is a pollutant for which there is no recognised safe level" https://laqm.defra.gov.uk/documents/LAQM-PG16-April-16-v1.pdf



The residential population, building impact and working population and high levels of traffic and a wider A10 carrying highly polluting vehicles, will undoubtedly cause huge carbon footprint and forever increase the ultra-fine particulate composition of the air here and not in a good way. The SPD must include the need NOW for an AQMA and management plan. It would be negligent to leave this until building begins and air quality deteriorates. Air quality will deteriorate, no question about it, so SCDC and Cambridgeshire CCG should as a duty of care to the people who live here now and those who will move to the new development, establish an AQMA to mitigate as much as possible the impact on air quality, and ensure that innovative technologies are employed at every angle of development to minimise air pollution.

Otherwise, it will be a wonderful place to spend time outdoors inhaling invisible microplastics and ultra-fine particulates produced by companies, services and vehicles who have been allowed to pollute freely by a local council who didn't exercise their duty to protect air quality.
We remind SCDC of their obligations to protect air quality:
A 2014 report by Public Health England and DEFRA "Estimating Local Mortality Burdens Associated with Particulate Air Pollution" showed that locally PM2.5 fine particulate air pollution was linked to annual effects on mortality across Cambridgeshire.
Attributable deaths Associated years of life lost Cambridgeshire 257 2762 Sth Cambs 57 611 Cambridge 47 468 East Cambs 33 378 Fenland 54 562
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_da ta/file/332854/PHE_CRCE_010.pdf (pg 14)
Current levels of particulate air pollution in Cambridgeshire, already have a significant impact on the life expectancy and health status of the population. Is it acceptable to support an SPD that potentially will drive up the numbers above? Is it acceptable to turn a blind eye to increasing fine particle risk because we can't see or feel it, or because developers can't quite quantify the risk and don't have a responsibility for it? Is it acceptable to do this by building an enormous proposed residential housing development?
Cambridgeshire County Council and South Cambs District Council, under the UK are part of the member state of the EU and as such is required to comply with legally binding limit values for ambient concentrations of various air pollutants including PM 2.5, PM10 and NO2. Local authorities are required under local air quality management (LAQM) to identify areas where national objectives for various air pollutants are exceeded or at risk of being exceeded and develop action plans to reduce air pollution to work towards meeting these objectives. Cambridge City air quality has been deemed 'poor' which triggered the acclaimed launch of the 2018-2023 AQAP. The potential cumulative health impacts of fugitive emissions of thousands of additional vehicles on the A10, carbon footprint of the many new businesses and houses proposed and services over time, make for many unaccounted-for variables the should be subject to an AQMA for NO2 and PM10. For example, the proximity of the proposed school to the A10 is likely to subject pupils and staff to high levels of pollution with implications for future illness.
There is now very strong evidence on the significant contribution of transport emissions to air pollution in urban area DEFRA's Local Air Quality Management Policy Guidance (PG16) 2016. Draft 2018 guidance is even stronger on this matter. The CCG Health and Wellbeing Board or CCG Director of Public Health have not assessed the application in the context of air quality and the LAQM or the CCG JSNA on Air Quality: The SPD fails to mention how the planned new town will help achieve the new City and County Air Quality Action Plans or the Cambridgeshire Green Infrastructure Strategy or support the Milton AQMAP. These projects are designed to drive joint working to help shape and coordinate delivery of green infrastructure in the county, to provide social, environmental and economic benefits now and in the future. The objectives include: Mitigating and adapting to climate change, supporting healthy living and wellbeing, and critically, Improving air quality in central Cambridge and beyond. https://www.airqualitynews.com/2018/03/13/cambridge-outlines-air-quality-action-plan/

It is imperative that Cambridge City Council, The Greater Cambridgeshire Partnership AQAP, CCG Director of Public Health are invited to consider seriously the SPD and respective development applications that are setting with SCDC- they must be consulted formally to ensure the SPD meets the criteria for air quality as set out by the above leading UK authorities.
Furthermore, DEFRA and the Public Health Outcomes Framework have issued clear guidance on the expectations of local authorities and Health and Wellbeing Boards regarding air quality:
Roles and responsibilities of CCC and SCDC under Public Health Outcomes Framework: 7.8 Local Authorities are expected to work towards reducing emissions and concentrations of PM2.5 in their local area
7.14 Local authorities in England should work closely with local Directors of Public Health and 'Health and Wellbeing' boards. Working in partnership will increase support for measures to improve air quality, with co-benefits for all. Examples of joined-up working include: Directors of Public Health To ensure the Joint Strategic Needs Assessment has up to date information on air quality impacts on the population To work closely with local authority health and air quality officers - e.g. have regular update meetings on key, emerging issues and sign off on ASRs and Action Plans Local https://consult.defra.gov.uk/communications/laqm_changes/supporting_documents/LAQM% 20Policy%20Guidance%202016.pdf

Roles and responsibilities of CCC and SCDC under Defra 2015 - Draft plans to improve air quality in the UK 4.3.2. 106 "New infrastructure and other developments need to be sensitively planned to ensure they do not add to, or cause, significant additional air quality issues. 109. "Local authority planning policies should sustain compliance with and contribute towards meeting limit values for pollutants, which includes NO2, considering the presence of Air Quality Management Areas, and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should also ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan.

111. "To support the National Planning Policy Framework, we have published Planning Practice Guidance on air quality which provides guiding principles on how planning decisions should take account of the impact of new development on air quality. " 112. "Local plans, prepared by local councils working with their local communities are key to delivering sustainable development. They inform individual decisions on the location of new development. In making decisions on planning applications local planning authorities consider whether what is proposed is sustainable development, in line with the Framework and supporting guidance and any local action to improve air quality and mitigation measures proposed as part of the development in question. " 113. "England and Wales have a bespoke planning system for major infrastructure projects introduced through the 2008 Planning Act - the Nationally Significant Infrastructure Planning (NSIP) regime. In England the regime is subject to strict consideration of air quality requirements. Accordingly, decisions on projects are required to consider air quality impacts over wider areas which are likely to be affected, as well as areas in the near vicinity of a scheme." 118. "When preparing strategies for future growth and allocating land for particular uses, local planning authorities should consider the effects which proposed developments may have on air quality, as well as the effects that air quality in an area would have on the acceptable future use of land. In doing so, development plan strategies and policies should be compatible with strategies and policies contained in regional transport plans, road traffic reduction reports, and air quality management plans." 119. "When determining planning applications, statutory air quality objectives, together with the results of air quality reviews and assessments and any air quality management plans or area action plans should be taken into account
and local planning authorities should work closely with pollution control authorities when considering applications." https://tinyurl.com/q9jtdmj

The SPD as it currently stands, underestimates (totally ignores in fact) the impact on air quality from the numerous sources that will contribute during the build and long term. Local council air quality action plans and EU air quality directives strongly stipulate importance of reducing in fine particulate air pollution and improving air quality. The SPD relates to a proposed new town that will INCREASE fine particulate pollution in Waterbeach and the Fen Edge.
The expert scientific community have serious concerns about practices that increase production of ambient ultra-fine particles, regardless of the size of the contribution they make to air pollution. Expert health and regulatory organisations demand an absolute need to reduce ultra-fine particulate air pollution and prevent practices that increase it. The fact is creating new towns produces emissions which contribute to air pollution. Developers and councils may argue the toss about significance, but they cannot conclusively claim that air pollution is not contributed to: Emissions modelling is a best guess but has not even been quoted in the proposed SPD. Assuming 'safety' in absence of known assessments raises very serious questions.

SCDC as well as CCC as the planning authorities should commission truly independent reviews by accredited experts to produce an analysis that can be understood by all. These should form part of the SPD and public consultation. If such reports are not produced, or that reports confirm unacceptable or unknown health issues, the SPD should be considered not fit for purpose. "

"Cambridge Without Incineration Residents Group Comment on Draft SPD for Waterbeach New Town. CBWIN is a group of several thousand local residents concerned about sustainable waste management solutions for Waterbeach and Cambridge as a whole. We formed when an application for a giant waste incinerator was proposed in 2017 for Cambridge. We are not activists or politicians, just ordinary professional people trying to ensure our health, environment and democracy are protected, and truly innovative solutions to waste are adopted.

This development and the combined developments of Urban and Civic and RLWE will produce enormous amounts of household, commercial and building and demolition waste. U+C plans show early indications of 3 energy from waste plants on the barracks site (no further specifics provided which is alarming in itself). Cambs County Council have rejected a massive waste incinerator proposal (thankfully) and we are in an intense climate of awareness of the limitation and negative environmental impact of a number of waste solutions that until now (including incineration) were considered 'good'. Incineration and energy from waste is a very toxic subject, and there are fast falling away EU legislations, impact of Brexit, forthcoming incineration taxation and emerging innovative technologies (e.g. UK plants that can recycle nappies and sanitary waste instead of landfilling it or burning it) in a zero-carbon way. We are concerned that the SPD offers no limits to the types of waste management that could be applied for by the developers or external companies. The SPD must contain restrictions on the building of anything except the EU's top 3 energy from waste solutions- this will allow for innovative technology to be included as technologies supersede each other over the years and displace older dirtier technologies (as anaerobic digestion has done to incineration in the EU waste management hierarchy in the last 5years). This will ensure a development that stays abreast of waste innovation and employs the most advanced technology of the time when the time comes to building. Especially given the dense population that will live there and the enormous effect that tens of thousands of houses, residents nd workers will have on air quality.
We note also that there is no provision for an area air quality management plan. What calculation can SCDC make with the lives of people who may live on this new development: especially children and unborn babies who we know are the most vulnerable population to air pollution? Scientific consensus is clear- air pollution impacts the most vulnerable in society (older people, infants, and unborn babies, and those with pre-existing chronic health conditions).
https://www.rcplondon.ac.uk/projects/outputs/every-breath-we-take-lifelong-impact-airpollution

-The Annual Report of Chief Medical Officer on Health Impacts of Air Pollution 'Health Impacts of All Pollution - what do we know?' Dame Sally Davies "Air pollution is not just environmental issue, government need to bring in tougher standards to tackle toxic air. Air pollution is thought to cause and contribute to as many as 40,000 deaths a year in the UK already, especially among vulnerable people such as those with existing respiratory problems, and young children, whose health can be permanently damaged by exposure to the pollutants at a young age" The government's air quality plan has been condemned as so poor as to be unlawful by the high court.
Addressing pollution is therefore disease prevention. Pollution should be recognised for what it is - a significant cause of non-communicable diseases like cardiovascular disease, cancer and asthma" https://www.airqualitynews.com/2018/03/02/chief-medical-officer-calls-tougher-airpollution-standards/

-Joint Parliamentary Committees Report on Air Quality - unprecedented guidance that directs and shapes existing local City and County Council and SCDC air quality management plans: all of which have objectives to reduce not increase air pollution

"Air pollution cuts short an estimated 40,000 lives across the country each year, costing the UK an annual £20 billion. Children, the elderly, and those with existing medical conditions are at the greatest risk. The UN special rapporteur recently said he was "alarmed that despite repeated judicial instruction, the UK government continues to flout its duty to ensure adequate air quality and protect the rights to life and health of its citizens. It has violated its obligations" ... The Government cannot continue to put public health at risk" https://publications.parliament.uk/pa/cm201719/cmselect/cmenvfru/433/433.pdf https://wintoncentre.maths.cam.ac.uk/news/does-air-pollution-kill-40000-peopleeach-year-uk


- Current UK Air Quality Directive: "Fine particulate matter (PM2.5) is responsible for significant negative impacts on health. Furthermore, there is yet no identifiable threshold below which PM2.5 would not pose a risk. As such, this pollutant should not be regulated in the same way as other air pollutants. The approach should aim at a general reduction of concentrations in them urban background to ensure that large sections of the population benefit from improved air quality. However, to ensure a minimum degree of health protection everywhere, that approach should be combined with a limit value, which is to be preceded in a first stage by a target value."

Underpinned by the current EU Ambient Air Quality Directive (2008/50/EC) which sets legally binding limit values for concentrations of major air pollutants that impact public health, such as particulate matter (PM10 and PM2.5) and nitrogen dioxide (NO2). The directive also sets limit values for a range of other pollutants that waste incinerators produce. https://uk-air.defra.gov.uk/air-pollution/uk-eu-policy-context


- COMEAP Committee on the medical effects of air pollution 2009 "Results of large cohort studies suggest that the effect of long-term exposure to air pollution on mortality is most closely associated with ambient levels of fine particulate matter (PM2.5) and that there is no evidence for a threshold below which effects would not be expected."

Recognising the significant impact that poor air quality can have on health, the Public Health Outcomes Framework includes an indicator relating to fine particulate matter (PM2.5). At its heart, the indicator for air pollution is about raising awareness of the effect of air pollution on public health. It is intended to encourage promotion of the need for local, regional and national actions to
reduce air pollution. This is intended to enable Directors of Public Health to prioritise action on air quality in their local area to help reduce the health burden from air pollution.

https://www.gov.uk/government/groups/committee-on-the-medical-effects-ofair-pollutants-comeap


- DEFRA's Local Air Quality Management Policy Guidance 2016.
"The impact of exposure to particulate matter pollution (PM2.5) is estimated to influence mortality equivalent to nearly 29,000 deaths in the UK. Improving air quality will also reduce damage to water quality, biodiversity and crops. Oxides of Nitrogen can contribute to eutrophication of waterways affecting aquatic life. They can react in the atmosphere with volatile organic compounds to create ground level ozone which damages crops as well as having its own health impacts. Tackling air pollution is a priority for Government. As PM2.5 is a pollutant for which there is no recognised safe level" https://laqm.defra.gov.uk/documents/LAQM-PG16-April-16-v1.pdf



The residential population, building impact and working population and high levels of traffic and a wider A10 carrying highly polluting vehicles, will undoubtedly cause huge carbon footprint and forever increase the ultra-fine particulate composition of the air here and not in a good way. The SPD must include the need NOW for an AQMA and management plan. It would be negligent to leave this until building begins and air quality deteriorates. Air quality will deteriorate, no question about it, so SCDC and Cambridgeshire CCG should as a duty of care to the people who live here now and those who will move to the new development, establish an AQMA to mitigate as much as possible the impact on air quality, and ensure that innovative technologies are employed at every angle of development to minimise air pollution.

Otherwise, it will be a wonderful place to spend time outdoors inhaling invisible microplastics and ultra-fine particulates produced by companies, services and vehicles who have been allowed to pollute freely by a local council who didn't exercise their duty to protect air quality.
We remind SCDC of their obligations to protect air quality:
A 2014 report by Public Health England and DEFRA "Estimating Local Mortality Burdens Associated with Particulate Air Pollution" showed that locally PM2.5 fine particulate air pollution was linked to annual effects on mortality across Cambridgeshire.
Attributable deaths Associated years of life lost Cambridgeshire 257 2762 Sth Cambs 57 611 Cambridge 47 468 East Cambs 33 378 Fenland 54 562
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_da ta/file/332854/PHE_CRCE_010.pdf (pg 14)
Current levels of particulate air pollution in Cambridgeshire, already have a significant impact on the life expectancy and health status of the population. Is it acceptable to support an SPD that potentially will drive up the numbers above? Is it acceptable to turn a blind eye to increasing fine particle risk because we can't see or feel it, or because developers can't quite quantify the risk and don't have a responsibility for it? Is it acceptable to do this by building an enormous proposed residential housing development?
Cambridgeshire County Council and South Cambs District Council, under the UK are part of the member state of the EU and as such is required to comply with legally binding limit values for ambient concentrations of various air pollutants including PM 2.5, PM10 and NO2. Local authorities are required under local air quality management (LAQM) to identify areas where national objectives for various air pollutants are exceeded or at risk of being exceeded and develop action plans to reduce air pollution to work towards meeting these objectives. Cambridge City air quality has been deemed 'poor' which triggered the acclaimed launch of the 2018-2023 AQAP. The potential cumulative health impacts of fugitive emissions of thousands of additional vehicles on the A10, carbon footprint of the many new businesses and houses proposed and services over time, make for many unaccounted-for variables the should be subject to an AQMA for NO2 and PM10. For example, the proximity of the proposed school to the A10 is likely to subject pupils and staff to high levels of pollution with implications for future illness.
There is now very strong evidence on the significant contribution of transport emissions to air pollution in urban area DEFRA's Local Air Quality Management Policy Guidance (PG16) 2016. Draft 2018 guidance is even stronger on this matter. The CCG Health and Wellbeing Board or CCG Director of Public Health have not assessed the application in the context of air quality and the LAQM or the CCG JSNA on Air Quality: The SPD fails to mention how the planned new town will help achieve the new City and County Air Quality Action Plans or the Cambridgeshire Green Infrastructure Strategy or support the Milton AQMAP. These projects are designed to drive joint working to help shape and coordinate delivery of green infrastructure in the county, to provide social, environmental and economic benefits now and in the future. The objectives include: Mitigating and adapting to climate change, supporting healthy living and wellbeing, and critically, Improving air quality in central Cambridge and beyond. https://www.airqualitynews.com/2018/03/13/cambridge-outlines-air-quality-action-plan/

It is imperative that Cambridge City Council, The Greater Cambridgeshire Partnership AQAP, CCG Director of Public Health are invited to consider seriously the SPD and respective development applications that are setting with SCDC- they must be consulted formally to ensure the SPD meets the criteria for air quality as set out by the above leading UK authorities.
Furthermore, DEFRA and the Public Health Outcomes Framework have issued clear guidance on the expectations of local authorities and Health and Wellbeing Boards regarding air quality:
Roles and responsibilities of CCC and SCDC under Public Health Outcomes Framework: 7.8 Local Authorities are expected to work towards reducing emissions and concentrations of PM2.5 in their local area
7.14 Local authorities in England should work closely with local Directors of Public Health and 'Health and Wellbeing' boards. Working in partnership will increase support for measures to improve air quality, with co-benefits for all. Examples of joined-up working include: Directors of Public Health To ensure the Joint Strategic Needs Assessment has up to date information on air quality impacts on the population To work closely with local authority health and air quality officers - e.g. have regular update meetings on key, emerging issues and sign off on ASRs and Action Plans Local https://consult.defra.gov.uk/communications/laqm_changes/supporting_documents/LAQM% 20Policy%20Guidance%202016.pdf

Roles and responsibilities of CCC and SCDC under Defra 2015 - Draft plans to improve air quality in the UK 4.3.2. 106 "New infrastructure and other developments need to be sensitively planned to ensure they do not add to, or cause, significant additional air quality issues. 109. "Local authority planning policies should sustain compliance with and contribute towards meeting limit values for pollutants, which includes NO2, considering the presence of Air Quality Management Areas, and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should also ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan.

111. "To support the National Planning Policy Framework, we have published Planning Practice Guidance on air quality which provides guiding principles on how planning decisions should take account of the impact of new development on air quality. " 112. "Local plans, prepared by local councils working with their local communities are key to delivering sustainable development. They inform individual decisions on the location of new development. In making decisions on planning applications local planning authorities consider whether what is proposed is sustainable development, in line with the Framework and supporting guidance and any local action to improve air quality and mitigation measures proposed as part of the development in question. " 113. "England and Wales have a bespoke planning system for major infrastructure projects introduced through the 2008 Planning Act - the Nationally Significant Infrastructure Planning (NSIP) regime. In England the regime is subject to strict consideration of air quality requirements. Accordingly, decisions on projects are required to consider air quality impacts over wider areas which are likely to be affected, as well as areas in the near vicinity of a scheme." 118. "When preparing strategies for future growth and allocating land for particular uses, local planning authorities should consider the effects which proposed developments may have on air quality, as well as the effects that air quality in an area would have on the acceptable future use of land. In doing so, development plan strategies and policies should be compatible with strategies and policies contained in regional transport plans, road traffic reduction reports, and air quality management plans." 119. "When determining planning applications, statutory air quality objectives, together with the results of air quality reviews and assessments and any air quality management plans or area action plans should be taken into account
and local planning authorities should work closely with pollution control authorities when considering applications." https://tinyurl.com/q9jtdmj

The SPD as it currently stands, underestimates (totally ignores in fact) the impact on air quality from the numerous sources that will contribute during the build and long term. Local council air quality action plans and EU air quality directives strongly stipulate importance of reducing in fine particulate air pollution and improving air quality. The SPD relates to a proposed new town that will INCREASE fine particulate pollution in Waterbeach and the Fen Edge.
The expert scientific community have serious concerns about practices that increase production of ambient ultra-fine particles, regardless of the size of the contribution they make to air pollution. Expert health and regulatory organisations demand an absolute need to reduce ultra-fine particulate air pollution and prevent practices that increase it. The fact is creating new towns produces emissions which contribute to air pollution. Developers and councils may argue the toss about significance, but they cannot conclusively claim that air pollution is not contributed to: Emissions modelling is a best guess but has not even been quoted in the proposed SPD. Assuming 'safety' in absence of known assessments raises very serious questions.

SCDC as well as CCC as the planning authorities should commission truly independent reviews by accredited experts to produce an analysis that can be understood by all. These should form part of the SPD and public consultation. If such reports are not produced, or that reports confirm unacceptable or unknown health issues, the SPD should be considered not fit for purpose. "

"Cambridge Without Incineration Residents Group Comment on Draft SPD for Waterbeach New Town. CBWIN is a group of several thousand local residents concerned about sustainable waste management solutions for Waterbeach and Cambridge as a whole. We formed when an application for a giant waste incinerator was proposed in 2017 for Cambridge. We are not activists or politicians, just ordinary professional people trying to ensure our health, environment and democracy are protected, and truly innovative solutions to waste are adopted.

This development and the combined developments of Urban and Civic and RLWE will produce enormous amounts of household, commercial and building and demolition waste. U+C plans show early indications of 3 energy from waste plants on the barracks site (no further specifics provided which is alarming in itself). Cambs County Council have rejected a massive waste incinerator proposal (thankfully) and we are in an intense climate of awareness of the limitation and negative environmental impact of a number of waste solutions that until now (including incineration) were considered 'good'. Incineration and energy from waste is a very toxic subject, and there are fast falling away EU legislations, impact of Brexit, forthcoming incineration taxation and emerging innovative technologies (e.g. UK plants that can recycle nappies and sanitary waste instead of landfilling it or burning it) in a zero-carbon way. We are concerned that the SPD offers no limits to the types of waste management that could be applied for by the developers or external companies. The SPD must contain restrictions on the building of anything except the EU's top 3 energy from waste solutions- this will allow for innovative technology to be included as technologies supersede each other over the years and displace older dirtier technologies (as anaerobic digestion has done to incineration in the EU waste management hierarchy in the last 5years). This will ensure a development that stays abreast of waste innovation and employs the most advanced technology of the time when the time comes to building. Especially given the dense population that will live there and the enormous effect that tens of thousands of houses, residents nd workers will have on air quality.
We note also that there is no provision for an area air quality management plan. What calculation can SCDC make with the lives of people who may live on this new development: especially children and unborn babies who we know are the most vulnerable population to air pollution? Scientific consensus is clear- air pollution impacts the most vulnerable in society (older people, infants, and unborn babies, and those with pre-existing chronic health conditions).
https://www.rcplondon.ac.uk/projects/outputs/every-breath-we-take-lifelong-impact-airpollution

-The Annual Report of Chief Medical Officer on Health Impacts of Air Pollution 'Health Impacts of All Pollution - what do we know?' Dame Sally Davies "Air pollution is not just environmental issue, government need to bring in tougher standards to tackle toxic air. Air pollution is thought to cause and contribute to as many as 40,000 deaths a year in the UK already, especially among vulnerable people such as those with existing respiratory problems, and young children, whose health can be permanently damaged by exposure to the pollutants at a young age" The government's air quality plan has been condemned as so poor as to be unlawful by the high court.
Addressing pollution is therefore disease prevention. Pollution should be recognised for what it is - a significant cause of non-communicable diseases like cardiovascular disease, cancer and asthma" https://www.airqualitynews.com/2018/03/02/chief-medical-officer-calls-tougher-airpollution-standards/

-Joint Parliamentary Committees Report on Air Quality - unprecedented guidance that directs and shapes existing local City and County Council and SCDC air quality management plans: all of which have objectives to reduce not increase air pollution

"Air pollution cuts short an estimated 40,000 lives across the country each year, costing the UK an annual £20 billion. Children, the elderly, and those with existing medical conditions are at the greatest risk. The UN special rapporteur recently said he was "alarmed that despite repeated judicial instruction, the UK government continues to flout its duty to ensure adequate air quality and protect the rights to life and health of its citizens. It has violated its obligations" ... The Government cannot continue to put public health at risk" https://publications.parliament.uk/pa/cm201719/cmselect/cmenvfru/433/433.pdf https://wintoncentre.maths.cam.ac.uk/news/does-air-pollution-kill-40000-peopleeach-year-uk


- Current UK Air Quality Directive: "Fine particulate matter (PM2.5) is responsible for significant negative impacts on health. Furthermore, there is yet no identifiable threshold below which PM2.5 would not pose a risk. As such, this pollutant should not be regulated in the same way as other air pollutants. The approach should aim at a general reduction of concentrations in them urban background to ensure that large sections of the population benefit from improved air quality. However, to ensure a minimum degree of health protection everywhere, that approach should be combined with a limit value, which is to be preceded in a first stage by a target value."

Underpinned by the current EU Ambient Air Quality Directive (2008/50/EC) which sets legally binding limit values for concentrations of major air pollutants that impact public health, such as particulate matter (PM10 and PM2.5) and nitrogen dioxide (NO2). The directive also sets limit values for a range of other pollutants that waste incinerators produce. https://uk-air.defra.gov.uk/air-pollution/uk-eu-policy-context


- COMEAP Committee on the medical effects of air pollution 2009 "Results of large cohort studies suggest that the effect of long-term exposure to air pollution on mortality is most closely associated with ambient levels of fine particulate matter (PM2.5) and that there is no evidence for a threshold below which effects would not be expected."

Recognising the significant impact that poor air quality can have on health, the Public Health Outcomes Framework includes an indicator relating to fine particulate matter (PM2.5). At its heart, the indicator for air pollution is about raising awareness of the effect of air pollution on public health. It is intended to encourage promotion of the need for local, regional and national actions to
reduce air pollution. This is intended to enable Directors of Public Health to prioritise action on air quality in their local area to help reduce the health burden from air pollution.

https://www.gov.uk/government/groups/committee-on-the-medical-effects-ofair-pollutants-comeap


- DEFRA's Local Air Quality Management Policy Guidance 2016.
"The impact of exposure to particulate matter pollution (PM2.5) is estimated to influence mortality equivalent to nearly 29,000 deaths in the UK. Improving air quality will also reduce damage to water quality, biodiversity and crops. Oxides of Nitrogen can contribute to eutrophication of waterways affecting aquatic life. They can react in the atmosphere with volatile organic compounds to create ground level ozone which damages crops as well as having its own health impacts. Tackling air pollution is a priority for Government. As PM2.5 is a pollutant for which there is no recognised safe level" https://laqm.defra.gov.uk/documents/LAQM-PG16-April-16-v1.pdf



The residential population, building impact and working population and high levels of traffic and a wider A10 carrying highly polluting vehicles, will undoubtedly cause huge carbon footprint and forever increase the ultra-fine particulate composition of the air here and not in a good way. The SPD must include the need NOW for an AQMA and management plan. It would be negligent to leave this until building begins and air quality deteriorates. Air quality will deteriorate, no question about it, so SCDC and Cambridgeshire CCG should as a duty of care to the people who live here now and those who will move to the new development, establish an AQMA to mitigate as much as possible the impact on air quality, and ensure that innovative technologies are employed at every angle of development to minimise air pollution.

Otherwise, it will be a wonderful place to spend time outdoors inhaling invisible microplastics and ultra-fine particulates produced by companies, services and vehicles who have been allowed to pollute freely by a local council who didn't exercise their duty to protect air quality.
We remind SCDC of their obligations to protect air quality:
A 2014 report by Public Health England and DEFRA "Estimating Local Mortality Burdens Associated with Particulate Air Pollution" showed that locally PM2.5 fine particulate air pollution was linked to annual effects on mortality across Cambridgeshire.
Attributable deaths Associated years of life lost Cambridgeshire 257 2762 Sth Cambs 57 611 Cambridge 47 468 East Cambs 33 378 Fenland 54 562
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_da ta/file/332854/PHE_CRCE_010.pdf (pg 14)
Current levels of particulate air pollution in Cambridgeshire, already have a significant impact on the life expectancy and health status of the population. Is it acceptable to support an SPD that potentially will drive up the numbers above? Is it acceptable to turn a blind eye to increasing fine particle risk because we can't see or feel it, or because developers can't quite quantify the risk and don't have a responsibility for it? Is it acceptable to do this by building an enormous proposed residential housing development?
Cambridgeshire County Council and South Cambs District Council, under the UK are part of the member state of the EU and as such is required to comply with legally binding limit values for ambient concentrations of various air pollutants including PM 2.5, PM10 and NO2. Local authorities are required under local air quality management (LAQM) to identify areas where national objectives for various air pollutants are exceeded or at risk of being exceeded and develop action plans to reduce air pollution to work towards meeting these objectives. Cambridge City air quality has been deemed 'poor' which triggered the acclaimed launch of the 2018-2023 AQAP. The potential cumulative health impacts of fugitive emissions of thousands of additional vehicles on the A10, carbon footprint of the many new businesses and houses proposed and services over time, make for many unaccounted-for variables the should be subject to an AQMA for NO2 and PM10. For example, the proximity of the proposed school to the A10 is likely to subject pupils and staff to high levels of pollution with implications for future illness.
There is now very strong evidence on the significant contribution of transport emissions to air pollution in urban area DEFRA's Local Air Quality Management Policy Guidance (PG16) 2016. Draft 2018 guidance is even stronger on this matter. The CCG Health and Wellbeing Board or CCG Director of Public Health have not assessed the application in the context of air quality and the LAQM or the CCG JSNA on Air Quality: The SPD fails to mention how the planned new town will help achieve the new City and County Air Quality Action Plans or the Cambridgeshire Green Infrastructure Strategy or support the Milton AQMAP. These projects are designed to drive joint working to help shape and coordinate delivery of green infrastructure in the county, to provide social, environmental and economic benefits now and in the future. The objectives include: Mitigating and adapting to climate change, supporting healthy living and wellbeing, and critically, Improving air quality in central Cambridge and beyond. https://www.airqualitynews.com/2018/03/13/cambridge-outlines-air-quality-action-plan/

It is imperative that Cambridge City Council, The Greater Cambridgeshire Partnership AQAP, CCG Director of Public Health are invited to consider seriously the SPD and respective development applications that are setting with SCDC- they must be consulted formally to ensure the SPD meets the criteria for air quality as set out by the above leading UK authorities.
Furthermore, DEFRA and the Public Health Outcomes Framework have issued clear guidance on the expectations of local authorities and Health and Wellbeing Boards regarding air quality:
Roles and responsibilities of CCC and SCDC under Public Health Outcomes Framework: 7.8 Local Authorities are expected to work towards reducing emissions and concentrations of PM2.5 in their local area
7.14 Local authorities in England should work closely with local Directors of Public Health and 'Health and Wellbeing' boards. Working in partnership will increase support for measures to improve air quality, with co-benefits for all. Examples of joined-up working include: Directors of Public Health To ensure the Joint Strategic Needs Assessment has up to date information on air quality impacts on the population To work closely with local authority health and air quality officers - e.g. have regular update meetings on key, emerging issues and sign off on ASRs and Action Plans Local https://consult.defra.gov.uk/communications/laqm_changes/supporting_documents/LAQM% 20Policy%20Guidance%202016.pdf

Roles and responsibilities of CCC and SCDC under Defra 2015 - Draft plans to improve air quality in the UK 4.3.2. 106 "New infrastructure and other developments need to be sensitively planned to ensure they do not add to, or cause, significant additional air quality issues. 109. "Local authority planning policies should sustain compliance with and contribute towards meeting limit values for pollutants, which includes NO2, considering the presence of Air Quality Management Areas, and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should also ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan.

111. "To support the National Planning Policy Framework, we have published Planning Practice Guidance on air quality which provides guiding principles on how planning decisions should take account of the impact of new development on air quality. " 112. "Local plans, prepared by local councils working with their local communities are key to delivering sustainable development. They inform individual decisions on the location of new development. In making decisions on planning applications local planning authorities consider whether what is proposed is sustainable development, in line with the Framework and supporting guidance and any local action to improve air quality and mitigation measures proposed as part of the development in question. " 113. "England and Wales have a bespoke planning system for major infrastructure projects introduced through the 2008 Planning Act - the Nationally Significant Infrastructure Planning (NSIP) regime. In England the regime is subject to strict consideration of air quality requirements. Accordingly, decisions on projects are required to consider air quality impacts over wider areas which are likely to be affected, as well as areas in the near vicinity of a scheme." 118. "When preparing strategies for future growth and allocating land for particular uses, local planning authorities should consider the effects which proposed developments may have on air quality, as well as the effects that air quality in an area would have on the acceptable future use of land. In doing so, development plan strategies and policies should be compatible with strategies and policies contained in regional transport plans, road traffic reduction reports, and air quality management plans." 119. "When determining planning applications, statutory air quality objectives, together with the results of air quality reviews and assessments and any air quality management plans or area action plans should be taken into account
and local planning authorities should work closely with pollution control authorities when considering applications." https://tinyurl.com/q9jtdmj

The SPD as it currently stands, underestimates (totally ignores in fact) the impact on air quality from the numerous sources that will contribute during the build and long term. Local council air quality action plans and EU air quality directives strongly stipulate importance of reducing in fine particulate air pollution and improving air quality. The SPD relates to a proposed new town that will INCREASE fine particulate pollution in Waterbeach and the Fen Edge.
The expert scientific community have serious concerns about practices that increase production of ambient ultra-fine particles, regardless of the size of the contribution they make to air pollution. Expert health and regulatory organisations demand an absolute need to reduce ultra-fine particulate air pollution and prevent practices that increase it. The fact is creating new towns produces emissions which contribute to air pollution. Developers and councils may argue the toss about significance, but they cannot conclusively claim that air pollution is not contributed to: Emissions modelling is a best guess but has not even been quoted in the proposed SPD. Assuming 'safety' in absence of known assessments raises very serious questions.

SCDC as well as CCC as the planning authorities should commission truly independent reviews by accredited experts to produce an analysis that can be understood by all. These should form part of the SPD and public consultation. If such reports are not produced, or that reports confirm unacceptable or unknown health issues, the SPD should be considered not fit for purpose. "

The vision in the SPD (p30-31) is for Waterbeach as "an environmentally sustainable new town, where it is easy for people to make the transition to a low carbon lifestyle. This means making the best use of energy, water and other natural resources, securing radical reductions in carbon emissions, minimising the environmental impact and being capable of adapting to the impacts of climate change"
This vision is aligned with Policy SS/6 of the newly adopted S Cambs local plan which specifies that Waterbeach New Town "will deliver an example of excellence in sustainable development and healthier living".
We support this.
However, we are objecting to the SPD on the grounds that it needs to demonstrate much more ambition, particularly with regard to energy efficiency and decarbonisation, if it is to come close to delivering on either the policy or the vision.
Much more ambition on energy efficiency and decarbonisation
This policy requirement to deliver excellence in sustainable development has become even more important than it was when the local plan was drafted because of the increasing urgency of addressing climate change. This is given force by the following legislation and policies.
National requirements: The UK's legally binding Climate Act, requires the UK to achieve a reduction in Carbon emissions of at least 80% by 2050. This is a challenging target and likely to be made even more challenging shortly, given the legally binding commitments of the 2015 Paris Agreement, and the recent IPCC report on how we can achieve a global temperature rise of no more than 1.5C. On 15 October 2018 the government officially asked the Committee on Climate Change to advise on whether to set a Net Zero target. Insiders say that it is considered likely that the CCC will advise that the UK should set a net zero target for somewhere between 2045 and 2050. As the construction of Waterbeach New Town won't be fully built until shortly before this, if it is to demonstrate "excellence in sustainable development" must pay serious attention to achieving Net Zero carbon emissions in use and in construction.
The National Planning Policy Framework of July 2018 (para 48) says that "the planning system should support the transition to a low carbon future in a changing climate" and that it should help "shape places in ways that contribute to radical reductions in greenhouse gases" [our emphasis] Simply specifying Building regulations energy efficiency is not contributing to a "radical reduction in greenhouse gases"
The newly adopted S Cambs local plan specifies that Waterbeach New Town "will deliver an example of excellence in sustainable development and healthier living" and specifies (4.10) "high levels of energy efficiency". When the S Cambs local plan was prepared it's authors may have been in doubt whether they had the power to require higher standards than building regs. However, in clarification of the July 2018 NPPF the government confirmed that local councils do have the power to require this. https://www.ukgbc.org/news/government-confirms-local-authorities-can-set-energy-standards-beyond-part-l-in-nppf/
Energy Efficiency
If Waterbeach New Town is to meet the requirements of the S Cambs local plan to deliver an example of excellence in sustainable development, it is wholly inadequate to specify that homes are built to building regs + 10% carbon reduction due to onsite Renewable Energy. We also note multiple loopholes allowing developers to wriggle out of their responsibilities.
The SPD should specify that all new homes should be Net Zero carbon emissions in operation by 2030. At a very minimum, the required should at least match, and preferably exceed the standards set by other developments. For example:
* Greater Manchester committed on 21st March 2018 to the introduction of a zero carbon standard for all new homes and buildings in the updated GM Spatial Framework
* Eddington required all homes to be CSE Code 5
* Cambridge City and S Cambs are now a joint planning authority. At a very minimum, the Waterbeach SPD should meet the standards specified in policy 28 of the Cambridge City Local plan, which specifies carbon emissions 44% better than 2006 building regs (ie 19% better than current regs) or what used to be known as CSE Code 4 . Note that Code 4 was commonly used as a standard for Social Housing, so this standard supports aspirations to provide affordable and social housing

Further detailed Guidance for local authorities on achieving sustainability in new homes is given by the UKGBC https://www.ukgbc.org/wp-content/uploads/2018/09/Driving-sustainability-in-new-homes-UKGBC-resource-Sept-2018-1.pdf
Cambridge Carbon Footprint knows from running Open Eco Homes http://openecohomes.org for 9 years that there is widespread, keen local interest in energy-efficient, sustainable homes: 3,800 people have made detailed tours of eco-homes, many in South Cambs. The huge majority of visitors are inspired to make their own home-energy improvements.
Our volunteers have thermal-imaged new homes with defective insulation and others with acute over-heating in the summer. It's imperative to avoid building new homes that will soon need retrofitting to meet the increasing necessity for climate change mitigation and adaption. Getting this right at the beginning for a small extra cost will save much bigger expenditure later.
Decarbonisation
Rather than just requiring developers to "think about" providing smart energy systems, Smart Energy systems should be mandatory. The provision and smart management of significant quantities of on-site renewables and storage will be vital for delivering an attractive place to live well before 2030. Given the limited grid capacity in the area, this is already urgent, and it is only likely to become more important as electric vehicles, electric space heating and heat pumps become more common.
Regular review of targets
As Waterbeach will take 25 years to build, we are calling for regular reviews (say every 5 years) to allow targets to be increased in line with government policy, the advice of the Committee on Climate Change and science-based targets for how to achieve the necessary reduction in carbon emissions.
Mitigating climate related Risks
Even if we all act to reduce Carbon emission as fast as is technically possible, we will face increasingly significant risks from our changing climate. To somewhat mitigate these risks for the inhabitants of Waterbeach, the SPD should set firm standards to require developers avoid overheating during heatwaves, particularly in single aspect south facing flats (for example by providing shading, solar control glazing and through ventilation)
Flood risk also needs serious attention, particularly in the high-risk areas to the Eastern part of the development, which includes the strategically important areas surrounding the train stations (current and new).

Size and timing of development.
11,000 homes is NOT appropriate,the current village and surrounding infrastructure will not cope with that many.

Heights of development.
Maximum height of two storeys.

More open space nearer existing village.
Yes,we were promised Bannold Rd. wouldn't be built on and look what's happening!

Impact on the fenland environment.
Not adequately addressed,Short Drove development and proposed station relocation will use up valuable farm land and wildlife habitat.

I don't agree with the railway station being relocated irrespective of the new town becoming larger than the existing village.

The A10 must be upgraded before any development is started as it's already overcrowded and extra development traffic will bring it to a standstill especially at peak times.

Construction traffic must be banned from using the village,it's already painful with the ongoing development in Bannold Rd,the surface of the road has been wrecked.

Size and timing of development.
11,000 homes is NOT appropriate,the current village and surrounding infrastructure will not cope with that many.

Heights of development.
Maximum height of two storeys.

More open space nearer existing village.
Yes,we were promised Bannold Rd. wouldn't be built on and look what's happening!

Impact on the fenland environment.
Not adequately addressed,Short Drove development and proposed station relocation will use up valuable farm land and wildlife habitat.

I don't agree with the railway station being relocated irrespective of the new town becoming larger than the existing village.

The A10 must be upgraded before any development is started as it's already overcrowded and extra development traffic will bring it to a standstill especially at peak times.

Construction traffic must be banned from using the village,it's already painful with the ongoing development in Bannold Rd,the surface of the road has been wrecked.

Size and timing of development.
11,000 homes is NOT appropriate,the current village and surrounding infrastructure will not cope with that many.

Heights of development.
Maximum height of two storeys.

More open space nearer existing village.
Yes,we were promised Bannold Rd. wouldn't be built on and look what's happening!

Impact on the fenland environment.
Not adequately addressed,Short Drove development and proposed station relocation will use up valuable farm land and wildlife habitat.

I don't agree with the railway station being relocated irrespective of the new town becoming larger than the existing village.

The A10 must be upgraded before any development is started as it's already overcrowded and extra development traffic will bring it to a standstill especially at peak times.

Construction traffic must be banned from using the village,it's already painful with the ongoing development in Bannold Rd,the surface of the road has been wrecked.

Size and timing of development.
11,000 homes is NOT appropriate,the current village and surrounding infrastructure will not cope with that many.

Heights of development.
Maximum height of two storeys.

More open space nearer existing village.
Yes,we were promised Bannold Rd. wouldn't be built on and look what's happening!

Impact on the fenland environment.
Not adequately addressed,Short Drove development and proposed station relocation will use up valuable farm land and wildlife habitat.

I don't agree with the railway station being relocated irrespective of the new town becoming larger than the existing village.

The A10 must be upgraded before any development is started as it's already overcrowded and extra development traffic will bring it to a standstill especially at peak times.

Construction traffic must be banned from using the village,it's already painful with the ongoing development in Bannold Rd,the surface of the road has been wrecked.

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