Question 10: Policy WP1 'waste management capacity to be provided'

* The draft plan avoids explicitly planning for the anticipated amount of waste that might be generated (Policy WP1). Whilst this is justified to a point in the supporting text, it could be risky, especially if higher amounts of waste are generated. A lack of suitable sites being proposed is part of the issue, and the draft plan may generate sites. A more robust strategy should be put in place.

This representation is made on behalf of Aggregate Industries UK Limited (AIUK). AIUK is a leading player in the construction and infrastructure industries producing and supplying a wide range of construction materials including aggregates, asphalt, ready-mixed concrete and precast concrete products. AIUK imports and produces cementitious materials and offers a national road surfacing and contracting service. AIUK prides itself on best practice in sustainability having become the first company to be certificated to BES 6001, The Framework Standard for the Responsible Sourcing of Construction Products, developed by the BRE (Building Research Establishment) and is a founding member of the UK Green Building Council. AIUK is a member of the LafargeHolcim Group which is the leading global building materials and solutions company with 90,000 employees, operating in 80 countries.

Please see below AIUK's response to Norfolk Minerals and Waste Local Plan Consultation May 2018.

Minerals and Waste Local Plan Vision implies sand and gravel sales shall remain within Norfolk, It is hoped Norfolk will support sand and gravel demand within the region in addition to being self-sufficient.

MW4 seeks a minimum of 10 % of energy used on site to be generated from decentralised and renewable or low-carbon sources. The geographical location of minerals sites, phased operation and temporary nature hinders the ability to implement the aims of MW4.

WP1 Waste Management Capacity to be provided - waste statistics are not comprehensive or robust therefore I believe flexibility should be built into the policy allowing sites to come forward based upon market need.

MP1 Provision for Minerals Extraction - It is considered production capacity should be captured within this policy to ensure deliverability of a steady supply of mineral.

MP7 Progressive working, restoration and after-use - It is considered Best and Most Versatile soils should be recognised as a preferred afteruse.

We would be obliged if the above comments can be taken into account in the consultation process.

AIUK welcome being involved with the Minerals and Waste review process and are happy to meet in relation to these representations.

Annual Growth Rate of Waste
Statistics of how many people are in the UK are taken from out of date surveys. The Policies are allowing for 1% - 1.5% annual growth rate of waste. Will this be sufficient in the light of Government Policies on reduction of plastic use, etc. People will be disposing of all items made of these materials. Plastic bottles could potentially be changed to glass in the future. Glass needs more protection with potentially more recycling material at the initial stage of transport to and from shops. Has this been taken into account with provision of adequate facilities. More needs to be done to collect and dispose of hard plastic. The Recycling Centre at King's Lynn had this facility which is no longer available.

Waste Reduction at Source
Work needs to be done with Suppliers of goods to avoid unnecessary waste in the first place. A start has been made with alternative packaging but this should be intensified.

UK and the European Union
If the UK leaves the European Union, has the full impact of import/export of waste been taken into account and the practical and financial effects.

Development Wording - Presumption in Favour
Development presumption must not be 'in favour' when there are obvious reasons to object. The wording gives developers advantage over local issues.

Public Education on Waste Issues
Education for the Public in clear and simple messages needs to be addressed. A lot of people are confused. For instance, we have heard in the past - it does not matter about washing items. Some people think if waste items are washed it wastes the resource of water. A lot of households tend to have dishwashers and not bowls of washing-up water which can be used to wash items. Bottle and jar tops - some leave them on, some leave them off.

Water Resources
Norfolk is the driest County in the UK for water resources. Cumulative usage totals must be taken into account in any planning.

Recreation
Would you need to include the fact (just for information) that there is a Public Consultation process on anything which would affect Public Rights of Way (PROWs).

Land and Soil Resources
Stronger wording and protection must be given to Grade 1, 2 and 3a land classification. Norfolk is an agricultural and rural County. It will be crucial for growing our own food in the future - more so, if we leave the European Union. Also, the UK may need to be more self-sufficient with food growing.

Policy WP3
Land allocated for B2 and B8 uses may be situated near to populated areas where there are health risks to residents. These sites must not be assumed to be suitable.

Transport Network
Ways of delivering goods and shopping are changing. Transport on our roads gets heavier every day, including huge HGVs. The road network in Norfolk is often congested and poorly maintained. It must be strongly stressed that impact on communities in unsuitable waste site locations for transport links should definitely be avoided.

Distance of Sites
Policy WP2 states that new or enhanced waste management facilities should be located within 5 miles .... Whilst we can understand some reasons for this - as in travelling time, the conflicting effects are major risks to human health being closer to populated areas.

Human Health Risks
Human health risks must be a major consideration in waste development as the eventual cost to the NHS and UK is huge. Health effects can be disastrous. Robust Health Policies must be in place.

Incinerators and Similar Projects
Any Policies referring to larger facilities must have stronger wording to protect the Public from harmful emissions and effects. They should not be situated within populated urban areas. Cumulative emissions from all surrounding other activities must be taken into account.

Minerals and Waste Local Plan Regulation 18 Comments

Breckland Council would wish to make the following representations on the Regulation 18 Minerals and Waste Local Plan:

Question 8: Breckland supports the inclusion of Policy MW5 'The Brecks Protected Habitats and Species' within the Local Plan, however would like to bring attention to additional evidence in relation to Stone Curlew buffer zones. As part of the Habitats Regulation Assessment to support the Breckland Local Plan revisions have been required to the buffer zones and policy to reflect areas within 3km of the SPA. Further information is available within the Breckland Habitat regulations Assessment on pages 30-32. However the issue can be summarised as follows:

Evidence, explained within the HRA for the Breckland Local Plan, identifies 3km as a distance at which stone curlew outside the SPA could be associated with the SPA. Survey effort tends to be focussed on areas regularly used and good quality habitat, so the additional buffer 'orange cells' simply reflect a lack of data. The orange cells therefore represents a precautionary area, in light of our understanding of the distance outside the SPA the birds may be present, where checks are necessary and mitigation could be required if the checks identify regular use by nesting stone curlew.

The orange cell areas could therefore comprise of some functionally linked land for Stone Curlews, however the data is incomplete. The Breckland HRA has therefore proposed an additional buffer zone to include these cells where there are data gaps and additional data checks or survey data may be required to check for use by Stone Curlews. The Breckland Local Plan has interpreted the additional 'orange cell' buffer area as a location where any site allocation would need to be supported by a project level HRA.

It is recommended that the policy is revised to reflect these additional areas and the map 2 should also be updated. For your information, I have included the proposed modified Breckland policy and also map.

Question 10: The waste policy currently considers there is sufficient capacity to meet the need for waste facilities without further allocations. The growth rate has had regard to the Norfolk SHMAs. Is there sufficient capacity within the existing waste facilities using the standardised housing methodology for calculating new household growth? Further justification would be required for a criteria based approach to ensure the plan is positively prepared.

Question 12: The policy would support the development of waste facilities on general industrial areas. Breckland would not wish to see the economic potential of industrial areas reduced due to the provision of waste facilities. Breckland would wish the policy to have regard to the employment aspirations for the area. Of particular concern is the Snetterton General Employment Area which is a key priority for Breckland within the A11 Norwich to Cambridge Technology Corridor. Breckland is proposing allocations through its Local Plan which would deliver 3,174 jobs to the area. Policy EC02 of the emerging Local Plan seeks to zone the employment area in order to meet these aspirations. Further to this, the Thetford Enterprise Park is also a key area on the A11 corridor and forms an important element of the growth strategy for the area. Breckland would wish to see the policy amended to reflect that important employment sites (including general employment areas such as Snetterton and the Thetford Employment Park) should not be prejudiced through development of waste sites.

Question 46: Site MIN35 Land at Heath Road Quidenham. Whilst located within Quidenham parish, this site is directly adjacent to the Snetterton General Employment Area, which is a strategic site for economic development within Breckland on the A11 corridor. At present the assessment does not appear to make reference to the proximity of the site to the GEA, and Breckland would wish to see this acknowledged within the assessment.

The access to the site is through the General Employment Areas to the A11. Further information is requested in relation to the operating hours of the quarry. This is in relation to the potential for weekend extraction. The site is in close proximity to the Snetterton Race Track, and at weekends when the circuit predominantly operates visitor traffic will also be using the access routes to the A11. Regard should be had to this in any transport assessment.