Our Client: Serruys Property Company Limited
Atlas Works, Norwich Road, Morton-on-the-Hill and Weston Longville ("Site")
Norfolk Minerals and Waste Local Plan Preferred Options Consultation
We write on behalf Serruys Property Company Limited ("SPCL") in response to the Norfolk Minerals and Waste Local Plan Preferred Options document ("Emerging Plan"):

1. SPCL is the owner of the Site totalling 9.1 hectares. The Site includes the following land identified on the enclosed plan:

a. Part of the Site edged blue allocated by Policy WAS 76 in the Waste Site Specific Allocations Development Plan Document (adopted October 2013) ("Adopted DPD"). This allocation extends to 0.4 hectares for an extension to the existing scrap metal recycling facility with an estimated capacity of 50,000 tonnes per annum. Policy WAS 76 is copied below:

Policy WAS 76
The site is allocated for an extension to the existing scrap metal recycling facility. Development will be subject to compliance with adopted Core Strategy and Development Management policies, and will require any planning application to address. in particular, the requirements below:
* Screening and landscaping along the boundary with Marriott's Way to protect landscape and local amenity;
* Protection or the amenities of residents, other businesses. and users of Marriott's Way through the siting and design of buildings, plant and equipment, including consideration of cumulative impacts with existing metal recycling on adjoining land, and mitigation and control of visual intrusion, noise, vibration, dust, litter and lighting;
* Appropriate site design. engineering and operations, including a Surface Water Management Strategy, impermeable site surfacing and a sealed drainage system, to ensure no adverse effects on the integrity of the River Wensum SAC and other protected habitats in the vicinity of the site;
* Submission of a Transport Assessment to include evaluation of the impacts of the development on the A1067 and on accesses to the A47 and provide appropriate mitigation if necessary; and
* Provision of acceptable highway access, including improvements to and rationalisation of existing site highway accesses off the A1067.

b. The remainder of the part of the Site coloured orange of 8. 7 hectares and allocated by Policy WAS 78 in the Adopted DPD for mixed waste processing, metal recycling, inert waste recycling, treatment of household waste etc of up to 150,000 tonnes per annum. Policy WAS 78 is copied below:

Policy WAS 78
The site is allocated for mixed waste processing, metal recycling, inert waste recycling, in-vessel composting, physical, chemical, and/or mechanical/biological treatment of household waste, waste transfer. and other forms of residual waste treatment excluding thermal treatment. Development will be subject to compliance with adopted Core strategy and Development Management policies, and will require any planning application to address, in particular, the requirements below:
* The scale and bulk of new buildings and structures being compatible with the landscape in this location on the edge of the Wensum Valley;
* Screening and landscaping along the boundary with Marriott's Way to protect landscape and local amenity;
* Protection of the amenities of residents, other businesses. and users of Marriott's Way through the siting and design of buildings, plant and equipment, and mitigation and control of visual intrusion, noise, vibration, dust, bioaerosols, litter, odour, and lighting;
* Appropriate site design, engineering and operations, including a Surface Water Management Strategy, impermeable site surfacing and a sealed drainage system, to ensure no adverse effects on the integrity of the River Wensum SAC and other protected habitats in the vicinity of the site, particularly from water run-off and emissions to air;
* Submission of a Transport Assessment to include evaluation of the impacts of the development on the A1067 and on accesses to the A47 and provide appropriate mitigation if necessary; and
* Provision of acceptable highway access, including improvements to and rationalisation of existing highway accesses off the A1067.

c. Land hatched blue comprising the existing metal recycling facilities (which includes part of the Site allocated under WAS 78) [The capacity from this facility is included in Appendix 1 "Waste facilities over 20,000 tonnes per annum in Norfolk 2012-2016" to the Waste Capacity Assessment 2017 (updated in June 2019) ("Waste Capacity Assessment")].

d. Land hatched red comprising part of the existing allocation WAS 78 of 2.1 hectares that has the benefit of planning permission for waste processing and the production of Refuse Derived Fuel ("RDF") with an annual throughput of 150,000 tonnes per annum and associated works. This development is permitted pursuant to planning permissions granted under reference APP/X2600/W/17/318973 dated 22 August 2018 and under reference C/5/2017/5007 dated 20 September 2018 ("Existing Consents").

2. The Site remains available. SPCL remain committed and supportive of waste management facilities across the Site and in turn would fully support - and recommend - the retention of the allocations under WAS 76 and WAS 78 in the Emerging Plan.

3. As explained in previous representations made on behalf of SPCL, the Site has a capacity for waste processing of up to 300,000 tonnes; 150,000 of which has already been permitted through the Existing Consents and 50,000 of which is already deemed acceptable through the current WAS 76 allocation. An increase of only 100,000 tonnes per annum is therefore proposed, which may appropriately be accommodated on the Site.

4. It is acknowledged that the Waste Capacity Assessment concluded: "sufficient capacity already exists to accommodate the forecast growth in waste [arising] over the Plan period to 2036. Therefore, it is not considered necessary to allocate any specific sites for waste management facilities in the M&WLPR. However, planning applications for new waste management facilities are still expected to come forward during the Plan period, both to move waste management up the waste hierarchy and because waste management is a contract driven and competitive industry. Therefore, the M&WLPR contains criteria-based policies to determine those planning applications that come forward for waste management facilities. [Emerging Plan, paragraph 1.2,]

5. However, the Waste Capacity Assessment has taken into account - when reaching the conclusion that sufficient capacity may exist for waste facilities over the plan period - the anticipated capacity from the Site allocated already under WAS 78 and permitted under the Existing Consents. [Waste Capacity Assessment, paragraph 2.4 and Appendix 2]

6. It is therefore crucial to ensure that this part of the Site remains allocated for waste processing uses. Otherwise there cannot be any guarantee that the Site, or any waste processing sites of a suitable type and location to meet identified needs, would come forward during the plan period.

7. For this same reason, SPCL would support the continued allocation of the Site as a whole for waste management uses in the Emerging Plan for up to 300,000 tonnes per annum. SPCL would also propose that the proposed uses reflect that contained in existing Policy WAS 78 save for the addition of thermal treatment. This is particularly because most of RDF is currently exported as the UK does not have sufficient facilities to properly convert RDF into energy. An allocation for thermal treatment would therefore be of substantial benefit, particularly following Brexit and the uncertainties over continuation of the export of RDF.

8. It must also be remembered that the suitability of the Site for waste processing has already been accepted through adoption of the Adopted DPD policies WAS 76 and WAS 78 [See paragraphs 6.76.2 to 6.76.5 and 6.78.2 to 6.78.5 of the Adopted DPD] and the Existing Consents.

9. In particular, the Adopted DPD acknowledges that there would be no adverse impact on the integrity of European sites (i.e. the River Wensum SAC) and that any other environmental impact or constraints could be sufficiently mitigated as may be demonstrated through a planning application. [Confirmed in paragraphs 6. 76.3 and 6. 76.5, and 6. 78.3 and 6. 78.5 for WAS 76 and WAS 78 respectively]

10. The suitability of part of the Site allocated under WAS 78 for waste processing for up to 150,000 tonnes per annum was agreed through the planning applications that culminated in the Existing Consents. Both the Council (following no objection from the various statutory consultees) and the Inspector on appeal in granting consent found that there were no planning or environmental constraints preventing the grant of planning permission for waste processing.

11. For the above reasons, it is clear that the Site should be specifically allocated for waste processing for up to 300,000 tonnes per annum for those specific uses detailed in policy WAS 78 (copied above) plus thermal treatment.

12. In addition, we consider the following amendments should be made to the Emerging Plan policies for clarity:

a. Policy WP2: Spatial Strategy for waste management facilities: this policy should be amended by referring specifically to the plan on the following page so it is clear as to how the 3 and 5 mile distances are to be applied. Alternatively, such clarification may be provided in paragraph W 2.2.

b. Policy WP3: Land potentially suitable for waste management facilities: this policy should be amended so that criteria (b) includes land with an existing or lawful general industrial B2 use or storage and distribution use under B8, or on sites that were previously consented for waste management facilities.

c. Policy WP6: Transfer, storage, processing and treatment of hazardous waste: this policy should again be amended in line with the suggestion at 12 (b) above for Policy WP3.

d. Policy WP7: Household Waste Recycling Centres: this policy should be amended by replacing the words "may be" to "will only be" for clarity and to be consistent with the terminology used in policies WP3 onwards.

Should you wish to discuss further, or require any further information, please do not hesitate to contact the writer on the details below.