Object
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99532
Received: 16/12/2022
Respondent: Dr L David Ormerod
Legally compliant? No
Sound? No
Duty to co-operate? No
These comments are limited to the Single-issue Silica Sand Site Selection process. It is of considerable concern when the NMW Local Plan policies accommodate a clear avoidance of the public interest.
NPPF paragraphs 98 and 99 are quoted.
As the recreational jewel of West Norfolk within a badly scarred regional environment with a local road system unsuitable for recreational pursuits, and where no realistic alternatives exist, it is surprising that the proposition of AOS E as a silica sand extraction candidate survived for so long. I believe that the Shouldham Warren should have been declared off-limits to all development. including mineral developments, as it provides an absolutely unique and traditional environment for West Norfolk country recreation.
1.The initial task is to convince N.C.C. that public land-use issues must always be respected in silica sand extraction site negotiations in particular, and in mineral and waste site negotiations in general. It is the law. How can the public interest be totally disregarded in a major Local Plan? This fails to pass the notions of "legal compliance" and of administrative "soundness."
2. The main problem with public representation involves the failure to recognize the long-term public recreational land-use interest in Shouldham Warren, part of AOS E.
The new "Criteria-based Policy
One concern over from the newly-proposed "criteria-based policy" shortcircuiting the NMWLP site assessments directly into the Planning Process is that a new, refashioned minerals application might be afforded lesser oversight than the Local Plan provided. The evidence shows unequivocally that no part of Shouldham Warren should ever be proposed for silica sand extraction. The Warren had been used for 40 years before mineral safeguarding was developed. The site had been exempted from silica sand and carstone safeguarding, and the Warren is a uniquely valuable public resource in a regional landscape already badly scarred by several hundred years of sand mining. It is the hope that Shouldham Warren can be preserved ad infinitum and that Norfolk County Council will formally support this characterisation.
Soundness tests: Not effective, not positively prepared, not consistent with national policy.
Policy MPSS1 - Strategic Policy: Add the statement, "The possibility of unrecorded or under-recorded public rights of way on the site must be investigated." Before the statement beginning, "Submission of a suitable scheme for the temporary diversion and re-instatement of any Public Rights of Way located within the site."