Object

Representation ID: 92911

Received: 09/08/2018

Respondent: Mr R Carter

Site MIN 71 - land west of Norwich Road, Holt. Question 76
I would ask that these comments be read in conjunction with my previous submission. I object to the initial conclusion that MIN 71 is a suitable site for the extraction of sand and gravel on the grounds that the Planning Authority is unable to demonstrate a need for extra resources of sand and gravel aggregates in Norfolk.

Supply/Demand
The apportionment targets set as Norfolk's share of the sub-national guideline figures have been missed by very wide margins every year for the last 20 years (averaging only 51.2% of apportionment in the last 10 years).

Market forces have shown that demand levels are significantly lower than the supply apportionment levels, and that Core Strategy Policy CS1 supply figures need to be severely downgraded in line with demand.

"Neighbouring Minerals Planning Authorities plan to supply the demand in their own areas, by allocating sites, and therefore Norfolk doe not need to make planned provision to supply additional aggregates".(1)

"Norfolk is a net importer of sand and gravel" (1)

Norfolk quarries have supplied "90% of local consumption" whilst exporting between 30%-50% of production. (1)

Norfolk should not be subsidising exported aggregates (reduced transport costs) for the benefit of surrounding Mineral Planning Authorities and Companies at the cost of the Norfolk Countryside and amenity of local residents.

"Norfolk, due to its geology, has considerable sand and gravel resources", consequently, there are minimal short or medium term supply risks if demand does increase - however, there is a significant risk to the countryside, the tourism industry, residents and existing agricultural if unsuitable and unwarranted sites are opened.

Methodology
"The MPA does not think it prudent... to base allocation purely on a rolling average of 10 years sales as having regarding to paragraph 14 of the NPPF, flexibility is required in allocations". (1) Instead, however, the MPA chose to base its allocation on a 20 year rolling average against the following guidance:
- Guidelines from the NPPF in March 2012 para 145 state that "MPAs... determine their own levels of aggregate production based on a rolling average of 10 years sales data..."
Guidance from the NPPG requires that LAAs should provide:
"a forecast of the demand for aggregates based on both the rolling average of ten-year sales data and local information"
It also stated that "The rolling average of 10 years sales data will inform the targets for mineral extraction data" (1)
All these guidelines unequivocally call for the 10 year rolling average to be the basis to consider supply forecasts, and any variant of this would need to be justified by compelling reasons.

The MPA has chosen to double the length of the recommended time-base against this advise, and to use a 20 year average, leading to the following supply differences -
- based on a 20 year rolling average 1.98 million tpa would be needed.
- based on a 10 year rolling average 1.41 million tpa would be needed
The difference over a 20 year plan is some 11.4 million tonnes at 570,000 tonnes a year - this clearly stretches the meaning of the phrase 'flexible' beyond any reasonable interpretation.

Conclusion
The clear evidence is that existing supply levels of aggregates are significantly greater than demand exhibited by market forces in Norfolk, and any new policies/calculations should address this significant imbalance.

(1) figures/narrative quoted are from - 'Norfolk Minerals and Waste Local Plan: Monitoring report - Mineral data Local Aggregate Assessment and Silica Sand Assessment 2016 (published October 2017)