6. The Strategy - Vision and Strategic Objectives

Without a radical overhaul of the glass recycling infrastructure in Norfolk, especially for clear and flat glass, the following Strategic Objectives are not being fulfilled and the plan is unsound:
WSO 1 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, is required to support the objective to prevent/minimise waste in line with the Waste Hierarchy.
WSO 2 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, is required to support the aim of increasing the amount of waste reused, recycled and recovered.
WSO 4 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, is required to enable the aim of self-sufficiency in waste management (Vision 2036).
WSO 6 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, is required to support the reduction of greenhouse gas emissions (a legally binding objective), minimise landfill (in Norfolk and nationally), and reduce waste transport distances.
WSO 8 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, is required to recognise the importance of waste management as a generator of local employment.
MSO 2 - A radical overhaul of glass recycling in Norfolk is required, especially clear and flat glass, to increase the future timescale of providing a steady and adequate supply of silica sand by reducing the quantity of raw material required for the manufacture of glass due to an increase in the quantity and quality of recycled glass, especially clear and flat glass (Vision 2036).
MSO3 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, is required to encourage the sustainable use of minerals by using secondary and recycled aggregates (NPPF, Ch 17, para 204.b).
MSO 8 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, to minimise the impact of climate change through the reduction of CO2 emissions due to increased use of high quality recycled glass cullet, especially clear and flat glass, in glass manufacturing.
MSO 10 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, that ensures more public access to the countryside due to the decrease in quarrying area required for silica sand because of the increased use of high quality recycled glass cullet.

Thank you for consulting Great Yarmouth Borough Council (GYBC) on this document. Following consideration of the documentation, the Borough Council's response is set out below. This response was considered and endorsed by the Council's Policy and Resources Committee on the 15th October 2019:

Strategic vision and Objectives:
Comment: Support for the aims of the Strategic Vision and Objectives

Policy MW2-Development Management Criteria
Comment: The supporting text to the Policy doesn't explicitly reference 'all sources of flooding' just notes flood risk, GYBC would suggest that reference is made to all sources of flooding as well as reference to the Environment agency's flood mapping as well as the Strategic Flood Risk Assessments which have been produced across Norfolk. The supporting text should make clear that site specific flood risk assessments will be required where flood risk is identified within the Strategic Flood Risk Assessments.

Policy MW6 - Agricultural Soils
Comment: Parts of the Great Yarmouth Borough are classified as Grade 1 agricultural land. The need for development of land for housing and other uses mean that some of this land will be lost to development. The Council therefore supports this policy to minimise the loss of grade 1 agricultural land, when there are sufficient areas of lower grade agricultural land elsewhere in the County to accommodate minerals and waste developments.

Policy WP3 - Land potentially suitable for waste management facilities &
Policy WP6 -Transfer, storage, processing and treatment of hazardous waste
Comments: These policies set out a criteria based approach to waste development and hazardous waste. The criterion indicates that land in B2 (general industrial) or B8 (storage and distribution) use would be potentially suitable for waste development. It also indicates that waste development would be suitable on land allocated for B2 and B8 uses in Local Plans or other development plan documents.
Whilst the Council considers this a broadly acceptable approach, it has significant concerns with respect to two strategic employment areas within the Borough. It is considered that new generic waste development would not be suitable on the proposed Beacon Business Park extension or the existing Beacon Park Business Park and therefore strongly objects to the policy as currently drafted. It is also considered that new generic waste development would not be suitable within the identified Great Yarmouth port and harbour area. The Council's objectives for these sites are to promote businesses within the offshore energy and port related sectors. Generic waste developments in these areas would either be incompatible with these proposed uses or use land needed to create a cluster of these proposed uses. The strategic significance of these sites is also recognised through the Enterprise Zone status of Beacon Business Park and its extension, and the wider area associated with the outer harbour.
The Council therefore requests that an exception is made to this policy for the above employment areas. The Council recognises that there may be some waste operations which can be associated with port and offshore energy/engineering activities which could be more compatible in principle (for example, some kinds of decommissioning). The Council would welcome the opportunity to discuss how the policy could be redrafted to best support the strategic aims of these employment areas within the Borough.
The extent of the above areas can be seen in the August 2018 Local Part 2 consultation document. Beacon Park Business Park is defined in emerging policy GN4-dp. The Beacon Park extension is defined in emerging policy GN5-dp. The Great Yarmouth Port and Harbour area is defined in policy GY12-dp

Policy MP1 - Prevision for minerals extraction
Comments: Given that the plan will allocate sufficient land to meet forecasted need, the Council supports this policy to resist proposals for Mineral extraction sites for sand and gravel outside of allocated sites.

Site MIN 203 - Land North of Welcome Pit, Burgh Castle
Comments: The Council recognises that the allocation (an extension to the existing site) would be a local source of sand to potentially help supply new developments in the Borough (albeit that the annual extraction rate is low) and that having a site close by is helpful in terms of reducing miles travelled. However, the Council recognises the highways concerns identified by the County Council about the appropriateness of the surrounding road network and therefore agrees that the extension site should not be allocated as matters stand. That being said, if appropriate highways improvements could be delivered, the Council would be supportive of the extension being allocated.
It should be noted that the description of the location of the site in respect of Belton and Burgh Castle is incorrect in the amenity paragraph. The settlement of Burgh Castle is to the west, south and north of the site.
The Council's Environmental Services team has noted the following:
If this site was brought forward, contrary to the emerging Norfolk Minerals and Waste Local Plan, noise and dust assessments would be required in line with the pertinent PPG and NPPF, in order to design appropriate mitigation. Land contamination matters would have to be considered through a Phase I (desk study and site walkover) report, due to the potential for ground gas from filled pits.

Site MIN 38 - Land at Waveney Forest
Comment: The Council supports the conclusion that this site should not be allocated. The Council considers that the forest whilst not open-access, does serve as an important recreational asset to the Borough given the public rights of way around and within the site. It is also worth noting that saved policy REC11 identifies an area of recreation space to the east of the site which is not mentioned in the assessment. Therefore, the recreational value of the site should be given greater weight in the assessment.
The Council's Environmental Services team has noted the following:
If this site was brought forward, contrary to the emerging Norfolk Minerals and Waste Local Plan, noise and dust assessments would be required in line with the pertinent PPG and NPPF, in order to design appropriate mitigation. Land contamination matters would have to be considered through a Phase I (desk study and site walkover) report, due to the historic military and railways land uses.

Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019

Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]

SUMMARY
Whilst we consider many aspects of the plan to be sound we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan.

Under paragraph 35 of the NPPF some aspects of this Plan are unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound. In summary we highlight the following issues:

a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.

b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.

c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.

d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.

Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes do not go to the heart of the Plan's soundness, but instead are intended to improve upon it. We believe that these comments can be addressed by changes to wording in the plan.

Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.

We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.

In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.

Please note that absence of a comment on a policy, allocation or document in this letter does not mean that Historic England is content that the policy, allocation or document is devoid of historic environment issues. We should like to stress that this response is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise as a result of this plan, where we consider that these would have an adverse effect upon the historic environment.

If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.

We write to you on behalf of our client, Lichen Renewal, an independent UK company operating as an innovator in landfill site recovery and restoration.
Lichen Renewal (LR) has patented a holistic approach to capture Greenhouse Gases released from former landfill sites by capping them, using the harnessed gas to dry green waste, which is then used to generate renewable energy for either local users or to be transmitted via the National Grid.
Enclosed alongside this letter is an informative brochure about LR and the offer they can give to assisting in reducing greenhouse gas emissions.
In regard to the the emerging Norfolk County Council Minerals and Waste Local Plan Review consultation, which this letter relates, the effort to consolidate three separate documents into one cohesive and comprehensive Waste Management Local Plan is to be commended, and LR are in general support of the Plan, the policies within it, and the overall Vision.
A consistent target within the plan is 'to move waste up the waste management hierarchy to minimise the need for landfill.' (p90-100), which LR greatly support as an initiative to reduce waste, and to limit the impact of waste on the environment.
Policy WP10 (Residual Waste Treatment Facilities) is broadly supportive of facilities that meet the criteria of other plan policies. It states 'Facilities that include thermal treatment of waste must provide for the recovery of energy and, where practicable, heat; and the use of combined heat and power will be encouraged'. The endorsement for the generation of heat and power from waste is positive, and a factor which LR's technology can deliver.
Additionally, the plan states in the introductory text that "The Plan will provide an approach that ensures suitable areas for sustainable waste management facilities are identified and that there is a flexible approach to waste technologies so that innovation within the market is encouraged, while still providing appropriate safeguards". This forward-thinking initiative encourages new technologies to come forward in order to further move waste up the waste management hierarchy in previously unforeseen ways.
In line with the target 'to move waste up the waste management hierarchy to minimise the need for landfill', mentioned several times in the Implementation, Monitoring and Review table (p90-100), LR could offer a solution to move existing landfill sites from 'disposal' to 'other recovery'. According to the Waste Management Capacity Study (2017), there are two permitted landfill sites in Norfolk with 5.09m tonnes of void space, both of which have been mothballed. We think that one (or perhaps both) of these sites could be an opportunity for our technology, and would like to investigate this further with you.
With this in mind, we would like to propose a meeting with the Council, to explain the processes of a Lichen Renewal facility and to discuss the possibility of a waste management project in Norfolk to positively harness the greenhouse gases released from a former landfill site within the County.
We look forward to formal confirmation that these comments have been received and processed. We also look forward to the opportunity to comment on the further phases of consultation on this plan. If you have any questions or queries regarding the points raised in this letter, please do not hesitate to be in touch with me, or my colleagues at your earliest convenience.