Waste Management Strategic Objectives

WSO1 - To support the prevention and minimisation of waste generation in line with the Waste Hierarchy, NCC needs to have a plan that enables more glass to be recycled/processed more efficiently to push it up the Waste Hierarchy, and not just collected and sorted. This is required so that more recycled material is made available to the glass making industry which, in turn, reduces the need for raw materials and the need to quarry silica sand. Currently, NCC does not have this in their plan and this is out of step with the NPPF (Ch 17, para 204.b) and fails sustainability objective SA1 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 15 of Part B (Jun 2019).

WSO2 - To support the amount of waste reused, recycled and recovered NCC need to have a plan that includes glass waste to recycle and reuse. Currently, NCC does not have this in their plan and this is contrary to the NPPF (Ch 17, para 204.b) and fails sustainability objective SA11 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 15 of Part B (Jun 2019).

WSO4 - To achieve net self-sufficiency in waste management by 2036 NCC needs to include a plan to ensure more efficient glass recycling and reuse. Currently, NCC does not have this in their M&WLP.

WSO6 - To support the reduction of greenhouse gases, minimise landfill and minimise waste transport distances, NCC needs to invest/champion a policy to have the infrastructure to be able to collect and process clear and coloured glass in greater quantity and quality. NCC currently does not have a plan to do this and this is contrary to the Climate Change Act 2008. Also, without a glass recycling policy, NCC fails their own sustainability objective SA1 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 15 of Part B (Jun 2019).

WSO8 - Recognise the importance of the waste sector in the local community as a generator of employment and its provision of infrastructure which supports business and communities. There are plans to do this for waste streams other than glass. NCC needs to plan for glass within this objective and currently, it does not. A high tech glass recycling plant in Norfolk would not only go towards fulfilling WSO8 but would also facilitate fulfilling WSO 1, 2, 4 and 6. It would also increase the employment opportunities in Norfolk and mitigate any job losses from the current mineral extraction and ancillary industries. Currently, without a glass recycling plan NCC is failing their SA4 and SA13 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).

WMO 1-8 - How do NCC intend to prevent and minimise waste without the ability to recycle or reuse within the county? Reductions in CO2 emissions from collections/distribution of waste can only be achieved by recycling glass, especially flat glass within Norfolk using a trainline for transportation. You cannot have self sufficiency whilst export waste from Norfolk, landfill is not the answer, this exacerbates the need for areas to fill and emissions that will inevitably be caused by transport to those sites. Recycling glass fulfills WSO8 in generating employment; a clean green industry with potential of hundreds of jobs.

The National Planning Policy Framework (NPPF) clearly states in Chap 17, para 204 b, that Mineral Planning Authorities (MPA) should look conserve minerals and 'take account of...recycled materials...before considering extraction of primary materials. The current proposed Preferred Options M&WLP shows no sign of adhering to this part of the NPPF and therefore the plan must be unsound

I now reference the Waste Management Objectives. Without forging a robust, advanced clear and flat glass recycling facility here in Norfolk NCC will fail to prevent and minimise waste within the county, and fail to support reductions in CO2 emissions that such a facility would bring to the glassmaking industry. To even suggest that Norfolk could be net self-sufficient in waste management is incredible if waste continues to be exported from within Norfolk to outside our boundaries. NCC could get close to net self-sufficiency in glass waste recycling if they had the vision to lead the way, nationally, in advanced glass recycling facilities, facilities that would fulfil WSO8 by generating jobs for Norfolk by the hundreds and potentially thousands.

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.