Object
Initial Consultation document
Representation ID: 91760
Received: 18/07/2018
Respondent: Mr Chris Dearmun
I am agreeing to the NCC's recommendation to reject Site MIN38 as a site for mineral extraction.
One of the many good reasons not to allocate this site is that, even with Brett's original proposal having been reduced in size, the extraction operations will still be in VERY close proximity to a large number of dwellings in New Road, the main residential area in the village, and the proposed screening will do little to minimise the attendant problems of noise, dust and light pollution.
Additionally, I have always been concerned that the policies and considerations set out in the document issued by the Office of the Deputy Prime Minister that the Government expects Mineral Planning Authorities (MPAs) to follow in preparing mineral and waste development schemes, have been followed in the case of MIN38.
The following are specific references from the said document, MPS32, which we believe are at odds with the selection of MIN38 :-
Para 4) " MPAs should.....ensurethat.....the transport of materials are kept to an absolute minimum". Given the Burgh Castle pit's much nearer proximity to Great Yarmouth, and it's ability to satisfy GY's requirements for the forseeable future (as stated by GYC), this surely precludes the opening of another pit further away.
"MPAs should.....protect areas of nationally-designated or archaeological value, cultural heritage or nature conservation from mineral development, other than excetional circumstances where it can be demonstrated that the proposed development is in the public interest". We would question what "exceptional circumstance" exist in relation to MIN38, and how it has been "demonstrated that the proposed development is in the public interest", when exactly the opposite would appear to be the case.
Para 5) "MPAs should liaise appropriately with......English Nature, the Countryside Agency......vouluntary conservation and enviromental groups". The developer's application had not even been referred to the Broads Authority let alone any of the others. At a meeting that took place between a group from the village and the Planners, it was stated by them that they were not obliged to do so, but this is directly contradicted by MPS2.
Para 8) "mineral working applications......in or affectingthe following designations (National Parks, the Broads).....should be subject to the most rigorous examinnation, nomally including an Environmental Statement, regardless of the size of the site". This consideration was taken into account in the site being found "Not Acceptable".
Para 11) "Development plan policies and proposals for mineral extraction and associated development should take into account: the impacts of mineral working, such as visual intrusion, dewatering,water pollution, noise, dust and fine particulates, blasting and traffic". These are surely key to the planner's recommendation not to allocate this site. Likewise "the impacts on landscape, agricultural land,soil resources,ecology and wildlife, including severance of landscape and habitat loss, and impacts on sites of nature conservation, archaeologicla and cultural heritage value".''
Para 12) "MPAs shouls also have regard where relevant to cumulative impacts of simultaneous and/or successive working of a number of sites in a wider area of commercially viable deposits. These may effect communities and localities over an extended period, the nature, age and size of the site". Burgh Castle pit is already and has at least 10 years more supply at current estimates. MIN38 would blight the village of Fritton for 22 years.
Para18) "Any.....loss of amenity must be kept to an acceptable minimum.....Where effective mitigation of unacceptable impact is not possible, permission should be refused". The Planners have correctly taken the view that the "mitigations" in the developer's proposal would do little to mitigate the loss of amenity for walkers, dog exercising, birwathching etc. or the destruction of the WW11 sites dotted around the site.
I am agreeing to the NCC's recommendation to reject Site MIN38 as a site for mineral extraction.
One of the many good reasons not to allocate this site is that, even with Brett's original proposal having been reduced in size, the extraction operations will still be in VERY close proximity to a large number of dwellings in New Road, the main residential area in the village, and the proposed screening will do little to minimise the attendant problems of noise, dust and light pollution.
Additionally, I have always been concerned that the policies and considerations set out in the document issued by the Office of the Deputy Prime Minister that the Government expects Mineral Planning Authorities (MPAs) to follow in preparing mineral and waste development schemes, have been followed in the case of MIN38.
The following are specific references from the said document, MPS32, which we believe are at odds with the selection of MIN38 :-
Para 4) " MPAs should.....ensurethat.....the transport of materials are kept to an absolute minimum". Given the Burgh Castle pit's much nearer proximity to Great Yarmouth, and it's ability to satisfy GY's requirements for the forseeable future (as stated by GYC), this surely precludes the opening of another pit further away.
"MPAs should.....protect areas of nationally-designated or archaeological value, cultural heritage or nature conservation from mineral development, other than excetional circumstances where it can be demonstrated that the proposed development is in the public interest". We would question what "exceptional circumstance" exist in relation to MIN38, and how it has been "demonstrated that the proposed development is in the public interest", when exactly the opposite would appear to be the case.
Para 5) "MPAs should liaise appropriately with......English Nature, the Countryside Agency......vouluntary conservation and enviromental groups". The developer's application had not even been referred to the Broads Authority let alone any of the others. At a meeting that took place between a group from the village and the Planners, it was stated by them that they were not obliged to do so, but this is directly contradicted by MPS2.
Para 8) "mineral working applications......in or affectingthe following designations (National Parks, the Broads).....should be subject to the most rigorous examinnation, nomally including an Environmental Statement, regardless of the size of the site". This consideration was taken into account in the site being found "Not Acceptable".
Para 11) "Development plan policies and proposals for mineral extraction and associated development should take into account: the impacts of mineral working, such as visual intrusion, dewatering,water pollution, noise, dust and fine particulates, blasting and traffic". These are surely key to the planner's recommendation not to allocate this site. Likewise "the impacts on landscape, agricultural land,soil resources,ecology and wildlife, including severance of landscape and habitat loss, and impacts on sites of nature conservation, archaeologicla and cultural heritage value".''
Para 12) "MPAs shouls also have regard where relevant to cumulative impacts of simultaneous and/or successive working of a number of sites in a wider area of commercially viable deposits. These may effect communities and localities over an extended period, the nature, age and size of the site". Burgh Castle pit is already and has at least 10 years more supply at current estimates. MIN38 would blight the village of Fritton for 22 years.
Para18) "Any.....loss of amenity must be kept to an acceptable minimum.....Where effective mitigation of unacceptable impact is not possible, permission should be refused". The Planners have correctly taken the view that the "mitigations" in the developer's proposal would do little to mitigate the loss of amenity for walkers, dog exercising, birwathching etc. or the destruction of the WW11 sites dotted around the site.