Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99473
Received: 19/12/2022
Respondent: Sibelco UK Limited
We support the inclusion of a mineral safeguarding and mineral consultation policy but believe the policy wording should be amended as set out below. The changes set out below are suggested to ensure adequate protection of mineral resources in accordance with paragraph 210 of the NPPF. In particular, the additional text reflects the national and strategic importance of Norfolk’s silica sand resource with particular reference to colourless glass production. This would allow the Council to consult with mineral operators to seek their technical industrial knowledge of minerals to best ensure effective safeguarding. This is an approach taken by Devon County Council in response to the existence of nationally important ball clay resources.
Proposed changes to first policy paragraph: “The County Council will safeguard existing, permitted and allocated mineral extraction sites from inappropriate development proposals. Mineral Consultation Areas are delineated on the Policies Map and extend to 250 metres from each safeguarded site. Development proposals within 250 metres of a safeguarded site should demonstrate that they would not prevent or prejudice the use of the safeguarded site for mineral extraction and the ‘agent of change’ principle will be applied in all such cases. [insert: 'In consultation with mineral operators'], the County Council will object to development proposals which would prevent or prejudice the use of safeguarded sites for mineral extraction.
Proposed changes to last policy paragraph: In line with the NPPF, the Mineral Planning Authority, [insert: 'in consultation with mineral operators'], will object to development which would lead to the sterilisation of the mineral resource., [delete: 'and it would be for the relevant Local Planning Authority to decide whether there are compelling planning reasons for over-riding this safeguarding objection.']
It is considered that the delineation of the Mineral Safeguarding Area and subsequently the Minerals Consultation Area should be amended on the Policies Map as silica sand resources known to Sibelco occur outside of the area proposed to be safeguarded for silica sand. This is reflected by the extent and location of sites contained within the ‘Proposed Silica Sand Allocations Norfolk County Council Minerals and Waste Local Plan Publication Document Consultation Supplementary Information Report’. The supporting geological information supports this conclusion. On this basis it is considered that the following geological areas in the British Geological Survey (BGS) Geology 50K (DigMapGB-50) mapping should be safeguarded for silica sand:
• Leziate Member,
• Mintlyn Member and
• Carstone Formation.
Advice produced by the BGS (Mineral Safeguarding in England: Good Practice Advice (British Geological Survey, 2011) and reference in PPG Paragraph: 003 Reference ID: 27-003-20140306 states that where available other data should be incorporated into the process of defining mineral safeguarding areas. This other data is set out in paragraph 4.1.4 of the BGS advice documents and includes, “exploration data from industry that is not held by BGS, such as shallow borehole information and trial pit investigations.” It is on this basis the safeguarding area for silica sand should be extended to incorporate the above mentioned geological areas.