Minerals and Waste Local Plan Regulation 18 Comments

Breckland Council would wish to make the following representations on the Regulation 18 Minerals and Waste Local Plan:

Question 8: Breckland supports the inclusion of Policy MW5 'The Brecks Protected Habitats and Species' within the Local Plan, however would like to bring attention to additional evidence in relation to Stone Curlew buffer zones. As part of the Habitats Regulation Assessment to support the Breckland Local Plan revisions have been required to the buffer zones and policy to reflect areas within 3km of the SPA. Further information is available within the Breckland Habitat regulations Assessment on pages 30-32. However the issue can be summarised as follows:

Evidence, explained within the HRA for the Breckland Local Plan, identifies 3km as a distance at which stone curlew outside the SPA could be associated with the SPA. Survey effort tends to be focussed on areas regularly used and good quality habitat, so the additional buffer 'orange cells' simply reflect a lack of data. The orange cells therefore represents a precautionary area, in light of our understanding of the distance outside the SPA the birds may be present, where checks are necessary and mitigation could be required if the checks identify regular use by nesting stone curlew.

The orange cell areas could therefore comprise of some functionally linked land for Stone Curlews, however the data is incomplete. The Breckland HRA has therefore proposed an additional buffer zone to include these cells where there are data gaps and additional data checks or survey data may be required to check for use by Stone Curlews. The Breckland Local Plan has interpreted the additional 'orange cell' buffer area as a location where any site allocation would need to be supported by a project level HRA.

It is recommended that the policy is revised to reflect these additional areas and the map 2 should also be updated. For your information, I have included the proposed modified Breckland policy and also map.

Question 10: The waste policy currently considers there is sufficient capacity to meet the need for waste facilities without further allocations. The growth rate has had regard to the Norfolk SHMAs. Is there sufficient capacity within the existing waste facilities using the standardised housing methodology for calculating new household growth? Further justification would be required for a criteria based approach to ensure the plan is positively prepared.

Question 12: The policy would support the development of waste facilities on general industrial areas. Breckland would not wish to see the economic potential of industrial areas reduced due to the provision of waste facilities. Breckland would wish the policy to have regard to the employment aspirations for the area. Of particular concern is the Snetterton General Employment Area which is a key priority for Breckland within the A11 Norwich to Cambridge Technology Corridor. Breckland is proposing allocations through its Local Plan which would deliver 3,174 jobs to the area. Policy EC02 of the emerging Local Plan seeks to zone the employment area in order to meet these aspirations. Further to this, the Thetford Enterprise Park is also a key area on the A11 corridor and forms an important element of the growth strategy for the area. Breckland would wish to see the policy amended to reflect that important employment sites (including general employment areas such as Snetterton and the Thetford Employment Park) should not be prejudiced through development of waste sites.

Question 46: Site MIN35 Land at Heath Road Quidenham. Whilst located within Quidenham parish, this site is directly adjacent to the Snetterton General Employment Area, which is a strategic site for economic development within Breckland on the A11 corridor. At present the assessment does not appear to make reference to the proximity of the site to the GEA, and Breckland would wish to see this acknowledged within the assessment.

The access to the site is through the General Employment Areas to the A11. Further information is requested in relation to the operating hours of the quarry. This is in relation to the potential for weekend extraction. The site is in close proximity to the Snetterton Race Track, and at weekends when the circuit predominantly operates visitor traffic will also be using the access routes to the A11. Regard should be had to this in any transport assessment.