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Initial Consultation document

Representation ID: 92337

Received: 23/08/2018

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

I note that the consultation document contains Development Management Criteria that are relevant when considering air quality impacts:

Policy WM2 in particular states that 'Proposals for minerals development and/or waste management development will be permitted where it can be demonstrated that the development would not have an unacceptable impact (including cumulative impact in combination with other existing or permitted development) on:
a. Local amenity and health (including noise levels, odour, air quality, dust, litter, light pollution and vibration.'

We would support the wording of this policy especially as it considers cumulative impacts with other development. The discussion section (headed Pollution and Local Amenity Impacts) states thatt detailed controls are exercised through specific pollution prevention and control regimes. However, it should be noted that some mineral activities fall outside of the environmental permitting regime and therefore mitigation under planning system may become necessary as stated in the closing paragraph of this section.

Full text:

I have considered the consultation document with reference to impacts on air quality. I note that the consultation document contains Development Management Criteria that are relevant when considering air quality impacts:

Policy WM2 in particular states that 'Proposals for minerals development and/or waste management development will be permitted where it can be demonstrated that the development would not have an unacceptable impact (including cumulative impact in combination with other existing or permitted development) on:
a. Local amenity and health (including noise levels, odour, air quality, dust, litter, light pollution and vibration.'

We would support the wording of this policy especially as it considers cumulative impacts with other development. The discussion section (headed Pollution and Local Amenity Impacts) states thatt detailed controls are exercised through specific pollution prevention and control regimes. However, it should be noted that some mineral activities fall outside of the environmental permitting regime and therefore mitigation under planning system may become necessary as stated in the closing paragraph of this section.

Policy MP6 specifically considers cumulative impacts of mineral sites which are located in close proximity and recommends mitigation. We would support the wording of this policy as other cumulative impacts (from non-mineral sites) are covered by policy WM2.

The consultation document includes two new proposed sites and one 'preferred area':
MIN204 - north of Lodge Rd Feltwell: The report notes that 'The nearest residential property is 21m from the site boundary. There are six sensitive receptors within 250m of the site boundary. We agree that any planning application for mineral extraction at this site would need to include a dust assessment and mitigation measures to deal appropriately with any amenity or health impacts. This is likely to include a buffer zone due to the proximity of the nearest sensitive receptors.
MIN206 - Oak Field, Tottenhill: The report notes that 'The only residential dwelling within 250m of the site boundary is 243m away. The settlement of Tottenhill is 243m away. We agree that any planning application for mineral extraction at this site would need to include a dust assessment and mitigation measures to deal appropriately with any amenity or health impacts.
SIL02 - land at Shouldham and Marham: This site is considered to be a potential 'Preferred Area' rather than a specific site allocation, from which smaller specific sites could come forward. The nearest residential property is reported to be 81m from the site boundary. There are 10 sensitive receptors within 250m of the site boundary. However, a buffer area is proposed which would mean that the nearest residential would be 280m from the area. We would agree that the buffer area should be enforced and that any planning application for mineral extraction within the site would need to include a dust assessment and a programme of mitigation measures to deal appropriately with any amenity or health impacts.