Object

Minerals and Waste Local Plan: Pre-Submission Publication

Representation ID: 99134

Received: 11/11/2022

Respondent: Broads Authority

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

This is immediately adjacent to the Broads Authority boundary
Landscape impact concerns are as follows:
Proximity and landscape sensitivity mean that there would be potential for adverse effects on the Broads and setting.
Visual: processing plant – topography could enable this to be more visible.  Possible lighting associated with plant and operation would exacerbate visual effects. Bunding during the extraction phases could also cause visual intrusion.
Footpath to NE across marshes - users are sensitive receptors.   There may also be views from northern valley side above Blunderston/Flixton to Herringfleet Marshes.
Noise from plant and lorry movements.
Dust from extraction operations.
Additional lorry traffic on local roads in BA area.
Heritage concerns are as follows:
The proposed site here is immediately adjacent to the BA Executive Area boundary and I would suggest that there is the potential for harm to the setting of listed buildings, in particular, the White House, which is positioned to the north-east of the site.
In its assessment the document appears to assess the impact on heritage assets largely in terms of potential views of the mineral extraction site. However, I would suggest that the definition of ‘setting’ is somewhat wider than that, with the NPPF glossary definition stating it is ‘the surroundings in which a heritage asset is experienced’. The Setting of Heritage Assets: Historic Environment Good Practice Advice in Planning Note 3 guidance by Historic England goes on to state (p2): ‘The extent and importance of setting is often expressed by reference to visual considerations. Although views of or from an asset will play an important part, the way in which we experience an asset in its setting is also influenced by other environmental factors, such as noise, dust and vibration from other land uses in the vicinity, and by our understanding of the historic relationship between places’.
Amenity concerns are as follows:
This scheme is going to bring new mineral extraction to the area. There are properties and businesses nearby, that are already in existence. The amenity impacts of the scheme on existing properties needs to be considered. Any scheme will need to consider and address amenity policy requirements and this could relate to the issue or noise, dust, over bearing, hours of operation for example. Has an assessment on the impact on amenity been completed as part of the consideration of this site?

Soundness: Not justified

Change suggested by respondent:

Policy MIN 25 (b) refers to the submission of an acceptable Landscape and Visual Impact Assessment.   However, it doesn’t include the Broads.  The assessment of impacts on the Broads needs to be included as an aim of the study.
The potential for detrimental impact on designated heritage assets is greater than implied in the policy. This section needs to improve reference to the potential for harm to the setting of listed buildings, in particular, the White House. I would suggest that there is some acknowledgement in M25.4 to the impact on the setting of the listed buildings being more than visual and in the last sentence it should say that it may be necessary to require measures to reduce the potential impacts on the setting of issues such as noise, dust and vibration, as well as providing the screening etc referred to, to reduce visual impacts.
Amenity impacts and concerns and the impact on any existing buildings and occupiers needs to be emphasised and addressed in this policy.