We are instructed by Carter Concrete (part of the RG Carter Group) to prepare and submit representations on the Preferred Options consultation of the Minerals and Waste Local Plan Review.
Carter Concrete own and operate the existing sand and gravel pit at Beeston Regis. The site benefits from an allocation for an eastern extension (site MIN69 under the adopted MSA). The company is promoting the same area of land under this emerging plan (retaining the reference MIN 69).


Addressing each in turn.
1. General policy comments
Carter Concrete would support the Vision promoted by the council in section 6 of the document. However, the company would like to see emphasis placed on the value and significance of minerals and waste development in providing a diverse and affluent rural economy consistent with Paragraph 83 of the NPPF.

Carter Concrete is pleased to see the council's commitment to Sustainable Development, but is disappointed to note that the council haven't provided a clear policy in this regard. Such an approach is clearly not consistent with the NPPF nor the attendant Planning Practice Guidance. The council already has a policy in this regard (SD1 of the Mineral Site Allocations DOD 2017) which could be easily translated into this emerging policy document.

The company would support Policy MW2, but would suggest that in the final paragraph when considering potential environmental benefits this could clearly states geo-diversity benefits where applicable.

Regarding Policy MW3 whist the company supports the aspiration for the use of other transport modes more often that not such avenues are not available, and as such the term "Where appropriate" should replace the word "All".

No comments are offered on the remainder of the general or the waste policies.

As regards to the mineral policies the contents of paragraphs MP1-MP10 inclusive are supported in full. No comments are offered on the remainder of the strategic landbank type policies for the other minerals.

Under paragraph MP2.6 the company would question the definition of a Main Town as this does not appear to list the town of Sherringham which is a clear development centre identified under local policy documents.

In respect of Policy MP2, paragraph 23 of the NPPF states "Broad locations for development should be indicated on a key diagram, and landuse designations and allocations identified on a policies map." The spatial definition identified is suggested to be too narrow to meet the broad criteria identified above and is therefore not consistent with national policy as it does not take account of the unique facet of minerals extraction (i.e. they can only be worked where they are found).

Paragraph MP7.6 refers to Green Infrastructure mapping. It is suggested that a high-resolution copy of the map provided is either included as an appendix or a weblink, as the drawing provided is of low quality and cannot be easily used on an interpretive basis.

It is considered that Policy MP7 should apply equally to extensions as well as new sites.

It is respectfully suggested that Policies MP9 and MP10 could be expanded to include reference to precast blockworks to use indigenous materials and aggregate bagging plants, as both are viable forms of ancillary development at aggregates sites in principal.

2. Comments on site MIN 69
Carter Concrete has recently submitted a planning application (ref FUL/2019/0001) to receive approximately half of the mineral resource identified in this allocation profile. This is as a sustainable and logical extension to the current site utilising the processing and access infrastructure of the latter. A Regulation 25 response is being collated and will shortly be submitted to address matters raised through the consultation process in the determination of the planning application.

Carter Concrete would confirm that the boundary on the allocation map is correct but would state that the indicative site buffer illustrated in the south of the allocation are is no longer proposed. This was proposed to provide a means of mitigation in view of the proposal to remove part of the existing woodland around the current site. This proposal no longer forms part of the scheme and therefore the mitigation isn't required. It is therefore proposed that the area indicated as the herringbone hatch on the plan is no longer required and should be included in the allocation area.

A plan confirming this proposed change is attached. This also illustrates a 100m radius around the allocation area, with the only potentially sensitive receptors situated south of Holt Road which is a clear and apparent source of acoustic and air quality impacts. Carter Concrete would not disagree with the wording of paragraph M69.1 which is factual in nature but would suggest that for context the influence of the A148 on local amenity is clearly indicated as this forms part of the baseline consideration of any scheme.

Regarding paragraph M69.2, Carter Concrete have committed to provide enhancements to Britons Lane and the junction of Holt Road with Britons Lane as part of application ref FUL/2019/0001. This has included an alternative solution to provide a cost-effective means (consistent with paragraph 108c of the NPPF) to consider highways safety. The reference to the consideration of a sustainable and cost-effective alternative solution (backed up by an RSA) could therefore also be provided in this paragraph. It should also be noted that the company is also content to enter into an obligation to restrict right turn access out of the site thereby limiting traffic along Britons Lane north of the site access.

Regarding paragraph M69.3, it is recommended that the earthwork and bank features along the parish boundary between Aylmerton and Beeston Regis (Norfolk HER ref 57910) areclearly referenced for baseline context.

Reference paragraph M69.5, as part of the current planning application Carter Concrete have provided geophysical investigation and trial trench evidence which has identified that whilst there are finds and features on site these are indicative of the surrounding area and as such would only have a local value or significance. Again, this could be added to provide context.

With regard to Paragraph M69.6 this should reflect the fact that the woodland to the south is mainly advance planting provided by the applicant as a means of long-term visual mitigation.

Carter Concrete would wholly support the wording of paragraphs M69.7 and M69.8.

With respect to paragraph M69.10, it is noted that the Council would be willing to consider the removal of some trees to connect to the two landforms. Would the council be willing to confirm how much woodland could be removed in principle, as recent discussions indicated that some of the council's internal departments would be concerned with large scale removal of such habitat.

Carter Concrete would wholly support the wording of paragraphs M69.12 to M69.19 inclusive and would reaffirm that as part of the current planning application the company is developing long term plans to sustainably manage the biodiversity and geo-diversity.

Paragraphs M80.20-M69-24 inclusive, no comments are offered.

Regarding paragraph M69.25, the company would consult with the council and other interested stakeholders to develop a suitable site restoration strategy.

The prime focus of the scheme would be to provide a very high quality restoration scheme for both the existing site, and proposed extension, with an emphasis on nature conservation habitat (specifically heathland), with improved public access, better access to geo-diversity and retention of exposures wherever possible; together with information boards (conveying information about the ecology, geology and geomorphology of the site). The provision of permissive routes through the restoration landform would also be considered by Carter Concrete.

In general terms the company supports the allocation of site MIN69, with the above intended to provide greater context and content for the allocation profile.

In the event that written reps and or a hearing is required as part of the examination process Carter Concrete would reserve the right to make further representations either to reinforce the above or provide new content where applicable.