Draft North East Cambridge Area Action Plan

Comment

Representation ID: 55846

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

The comprehensive approach towards development and regeneration at North East Cambridge is broadly
supported. However, a comprehensive approach must include the following: appropriate phasing of
redevelopment sites to ensure that proposed uses are compatible with existing business operations
on adjacent sites and in close proximity, including the existing waste recycling transfer facility
off Cowley Road; ‘meanwhile’ uses that are appropriate and compatible with existing business
operations on adjacent sites; and, the successful relocation of the existing waste recycling
transfer facility to a suitable alternative site within close proximity of Cambridge.

Comment

Representation ID: 55847

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

Figure 21 shows building heights for the proposed business space (B1) and housing at the Veolia
site off Cowley Road of between 5 to 6 storeys and a maximum of 8 storeys. The proposed uses on the
neighbouring areas also include tall buildings.

The proposed uses and the building heights for the Veolia site are supported, and these higher
value uses are necessary to enable the existing waste recycling transfer facility to be relocated
off site, otherwise relocation would not be viable.

In addition, the phasing of redevelopment will be important in order to ensure that tall buildings
are compatible with existing uses e.g. waste recycling transfer facility such like Veolia that
might remain in operation if an alternative site is not identified. It is unlikely that effective
temporary noise mitigation measures could be provided within the proposed residential buildings to
address
the noise generated by activities associated with the existing waste recycling transfer facility.

Comment

Representation ID: 55848

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

The inclusion of additional social, community and cultural facilities within the North East
Cambridge area is supported.

Comment

Representation ID: 55849

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

The inclusion of additional shops and local services, including a new district centre, within the
North East Cambridge area is supported. However, these uses need to be delivered in locations
reflective of the land value generated where that it is necessary to facilitate release of land.
Lower value uses should not be proposed on the Veolia site.

Comment

Representation ID: 55850

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

Policy 23 seeks to ensure a comprehensive and coordinated approach to development and
regeneration at North East Cambridge, which is broadly supported. Policy 23 requires
applications for major development to successfully integrate with the surrounding area and to
successfully mitigate environmental constraints – see criteria c(ii) and c(vii). It is anticipated that
the land currently occupied by the Veolia waste recycling facility would be redeveloped for
business (B1) and housing with the adjacent land redeveloped for business and town centre uses
and housing. The proposed buildings on the site would be up to a maximum of 8 storeys, and on
the neighbouring land the buildings would be up to a maximum of 13 storeys high. However, it is
expected that the existing waste recycling transfer facility would continue to operate for a
temporary period or indefinitely if a suitable alternative relocation site is not identified. Therefore,
an appropriate phasing of redevelopment sites must be provided to ensure that proposed uses
are compatible with existing business operations on adjacent sites and in close proximity,
including for the existing waste recycling transfer facility off Cowley Road, in order to avoid
potential noise and residential impacts. However, as outlined above the existing Veolia operation
will only relocate if they can make the land viable.

Comment

Representation ID: 55851

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

It is proposed in Policy 26 that the existing waste recycling transfer facility off Cowley Road would
be relocated off site, but at this stage no suitable and viable alternative relocation site is
identified. Veolia would be affected by the redevelopment of its existing site, and would welcome
discussions with the Council to find a suitable alternative viable site from which it can operate a
waste recycling transfer facility and release of value from their existing site to facilitate any move.
It would not be necessary or appropriate for compulsory purchase to be used because the Veolia
site could be redeveloped in conjunction with Cambridge City Council for the proposed business
and housing uses, and designed to meet the policy requirements specified in the AAP.

Comment

Representation ID: 55852

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

It is proposed in Policy 26 that the existing waste recycling transfer facility off Cowley Road would
be relocated off site, but at this stage no suitable and viable alternative relocation site is
identified. Veolia intends to remain operating the waste recycling transfer facility until a suitable
and viable alterative relocation site has been identified and approved. It is anticipated in the North
East Cambridge AAP that the land currently occupied by Veolia would be redeveloped for
business (B1) and housing uses; the retention of the existing waste recycling transfer facility at
the existing site is not an option.
Criteria (b) of Policy 24b requires engagement with affected occupiers and tenants where
relocation of existing businesses is proposed as part of development at North East Cambridge.
Veolia would be affected by the redevelopment of its existing site, and would welcome
discussions with the Council to find a suitable alternative site from which it can operate a waste
recycling transfer facility. It is disappointing that, given Veolia is a key relocation site (albeit small
scale), that they have not been invited to participate in the masterplanning workshops for the
wider AAP area that have taken place to date. This engagement with existing land owners and
users is an important part of the process and is identified within the Sustainability Appraisal.
Given the failure to engage on this site, the legitimacy of the outcomes from these workshops
could be challenged. Criteria (c) of Policy 24b sets out a sequential approach to the re-provision
of existing uses. Veolia is an existing established business, and a replacement facility should be
located within or close to Cambridge in order to avoid the unnecessary transportation of recycling
waste and material. As set out in the response to Policy 26, it appears that the policy
requirements for a replacement facility might be difficult to achieve on a suitable alternative site
without assistance and support from the Council to enable Veolia to relocate its existing
operations in a viable manner.

Comment

Representation ID: 55853

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

Policy 25 seeks to ensure that environmental impacts are considered for development at North East
Cambridge, and identifies criteria for development. As set out above, the existing waste recycling
transfer facility at the Veolia site off Cowley Road is expected to continue until a suitable and
viable alternative relocation site is identified. The operations associated with the waste
recycling transfer facility e.g. noise, odours and vehicle movements, could be incompatible with
new residential, commercial, town centre and community uses on neighbouring sites without
appropriate phasing and the effective relocation of Veolia’s operations. Therefore, the criteria in
Policy 25 relating to noise and air quality to be assessed as part of design and layout (criteria
c), new sensitive uses to be integrated with existing businesses (criteria d), and to avoid
unreasonable restrictions on existing business operations (criteria e) are supported.

Comment

Representation ID: 55855

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

It is stated in Policy 26 that “the safeguarded Veolia Waste Recycling Transfer Station should be
relocated off-site. This would need to be undertaken in collaboration with the Local Minerals and
Waste Authority and is a pre-requisite to future sensitive development coming forward on
surrounding plots”. It is anticipated in the AAP that the land currently occupied by the Veolia
waste recycling facility would be redeveloped for business and housing uses. However, as
explained below, the adopted and emerging Minerals & Waste Local Plans seek to safeguard the
existing waste recycling transfer facility in its current location, it appears that the policy
requirements for a replacement facility might be difficult to achieve on a suitable alternative site,
and at this stage no alternative site for the relocation of Veolia’s operations have been identified.
The relevant policies of the adopted and emerging Minerals & Waste Local Plan are identified
below, as are the relevant policies of the adopted Cambridge and South Cambridgeshire Local
Plans.
The Veolia site is safeguarded as a waste recycling transfer station in the adopted and emerging
Minerals & Waste Local Plans, and as such it is anticipated that the existing facility would be
retained on site, relocation is not anticipated and no alternative/replacement sites are identified.
Policy CS18: Waste Management Proposals Outside Allocated Areas of the Minerals and Waste
Core Strategy Development Plan Document (adopted July 2011) states:
“Proposals for waste management development outside allocated areas will be considered
favourably where :-
• this is consistent with the spatial strategy for waste management, and
• it can be demonstrated that they will contribute towards sustainable waste management,
moving waste up the waste hierarchy
Waste recovery and recycling facilities may be permitted where they are:
a. for on-site management of waste
b. on land identified for general industrial use
c. co-located with complementary activities (including existing permanent waste management
sites)
d. on previously developed land
e. on farm holdings to facilitate agricultural waste recycling
f. within a medical or research institution which is generating waste (bio-medical, research and
clinical waste only)
g. in strategic development areas
h. at inert landfill sites (inert waste recycling only)
All strategic development will make provision for permanent waste management.”
The existing waste recycling transfer facility operated by Veolia is for general use and is not
related to on-site waste management, agricultural waste, medical/research waste, or inert waste.
Therefore, criteria (a), (e), (f) or (h) are not relevant in terms of potential alternative sites. It is
expected that previously developed land within and on the edge of Cambridge would be
redeveloped for higher value uses or the relocation of other commercial activities, and other
potentially available land would be subject to constraints including impacts on residential amenity.
The employment areas within Cambridge are protected for existing commercial uses or are
subject to redevelopment proposals which excluded general industrial type uses. The
employment areas in South Cambridgeshire are protected for a limited range of employment
uses or are in villages where impacts on residential amenity would restrict a waste recycling use.
The strategic development areas on the edge of Cambridge and in South Cambridgeshire are for
residential and high value commercial uses where a waste recycling transfer facility is not
anticipated or appropriate. Therefore, there are very limited opportunities within or close to
Cambridge for a replacement site for a waste recycling transfer facility.
Policy 4: Providing for Waste Management of the emerging Minerals and Waste Local Plan
(Proposed Submission Draft November 2019) expects existing waste sites to meet identified
needs and so no specific new allocations are proposed. Policy 4 sets out a criteria based policy
for new waste facilities, which in summary must be located on sites within the settlement
boundary of main settlements and in employment areas identified as suitable for B2/B8 uses or
within strategic employment areas. The adopted Cambridge Local Plan 2018 identifies Areas of
Major Change but none are suitable for a relocated waste recycling transfer facility, and there are
no policies that support this type of use within the settlement boundary. It is likely that any
redevelopment opportunities that exist in Cambridge would be brought forward for high value
uses e.g. residential and commercial, rather than a waste recycling transfer facility. The South
Cambridgeshire Local Plan 2018 does include allocations for B1/B2/B8 uses – at Over and
Papworth Everard (see Policy E/5), and Policies E/12 and E/13 support employment uses within
and on edge of villages but subject to no adverse impacts, and Policy E/15 identifies established
employment areas which mostly accommodate office, research and development, manufacturing
and logistics uses. It is likely that the existing employment sites in South Cambridge would not be
suitable for a relocated waste recycling transfer facility because they are too far from Cambridge
and existing and surrounding uses would be incompatible with such a facility.
The Veolia site is identified as a Waste Management Areas (WMA), and Policy 10 of the
emerging Minerals and Waste Local Plan applies. Policy 10 expects such sites to be used for
waste management or compatible facilities. Criteria (c) of Policy 10 states: “proposals which
demonstrate clear wider regeneration benefits which outweigh the harm of discontinued
operation of the site as a WMA, together with a demonstration to the Waste Planning Authority as
to how the existing (or recent) waste stream managed at the site will be (or already is being)
accommodated elsewhere”. Criteria (c) anticipates that if waste management facilities are to be
relocated – as is proposed in the North East Cambridge AAP – that there would be a strategy in
place to manage the existing waste e.g. recycled waste treated at Veolia’s existing operation.
Policy 10 is consistent with the approach advocated in Policy 26 (of the North East Cambridge
AAP) that the relocation of the existing waste recycling transfer facility is a pre-requisite of
redevelopment of the site currently occupied by Veolia.
Therefore, it is considered that there are very limited opportunities within or close to Cambridge
for a replacement site for a waste recycling transfer facility, in that available sites within
Cambridge would be redeveloped for high value uses and that existing employment sites within
Cambridge and South Cambridgeshire would not be suitable for such a use. Veolia is an existing
established business, and a replacement facility must be located within or close to Cambridge in
order to avoid the unnecessary transportation of recycled waste and material. This emphasises
the need to maximise the development value of the Veolia site through this process in order to
facilitate a relocation to ensure that they can compete with land values and ensure that that any
move is financially viable as well as operationally.
As set out in the response to Policy 24b, Veolia would be affected by the redevelopment of its
existing site, and would welcome discussions and assistance from the Council to find a suitable
alternative site from which it can operate a waste recycling transfer facility.

Comment

Representation ID: 55856

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

Policy 27 sets out the purpose and approach to planning contributions for development within the
North East Cambridge Area. It is acknowledged that the policy contains some flexibility, in that
contributions will be assessed on a site by site basis and that viability will be assessed where
relevant. It is requested that the level of planning contributions and viability matters should also
take into account whether a development is related to the relocation of an existing business or
use within the AAP area and enable the delivery of wider aspirations and a coordinated strategy
for the area. For example, it is proposed in the AAP that the existing waste recycling transfer
facility operated by Veolia will relocate off site. The Veolia site needs to be redeveloped for high
value business and housing uses. However, there will be costs associated with the relocation of
the waste recycling transfer facility to an alternative site including the purchase of land. The
relocation of the waste recycling transfer facility is a prerequisite and essential for the successful
redevelopment of this part of the AAP area. It should be noted that HIF funding has been
provided to enable the relocation of Cambridge Waste Water Treatment Works, but no public
funding is available to support the relocation of Veolia’s operations. Therefore, it is requested that
any planning contributions and viability considerations for the redevelopment of the Veolia site
reflect and take into account the costs associated with the relocation of the waste recycling
transfer facility. As outlined within these Representations the value of the Veolia site needs to be
maximised to enable a future relocation and therefore the introduction of business (B1) and
housing uses are supported. S106 or other associated development costs should be minimised.
If the redevelopment of the Veolia site and the associated relocation of the existing waste
recycling transfer facility is not viable, then it will either not happen or adjustments will need to be
made to the proposed quantum of development or mix and type of uses provided at the site
and/or to the level of planning contributions provided.