Policy WP1: Waste management capacity to be provided

we need to protect the earth from exploitation and find other non invasive ways of providing for human needs or learn to live differently.

This is not sustainable for the planet which means it's not sustainable for the human race

WP1 - NCC states that 'new facilities.... which help to achieve the targets for recycling.....will be encouraged'. This is a policy that NCC should be pursuing itself and not relying on the private recycling companies to come forward with solutions. Also, the policy mentions that 'initiatives to reduce waste and improve recycling are largely outside the scope of this Plan', however, whilst individual initiatives may be outside the scope they are not exclusive from the Plan. NCC currently ignores the fact that recycling glass more efficiently would not only reduce the amount of CO2 emissions in Norfolk and lessen the requirement for quarrying silica sand and destroying the Norfolk landscape but would also vastly increase the local economy through the number of jobs created. This is a dereliction of duty to the taxpayers of Norfolk and not fulfilling the UK legal obligation to reduce CO2 emissions. WP1 fails sustainability objective SA1, SA11 and SA13 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).

Waste Management Objectives 1-8 - How do NCC intend to prevent and minimise waste without the ability to recycle glass or a system of reuse within the county? Further reductions in CO2 emissions from collections and distribution of waste can only be achieved by a world class glass recycling centre in Norfolk with a good train-line link for import/export of glass to be turned into cullet. You cannot have net self sufficiency if you export waste from within Norfolk to outside the County boundary; landfill is not the answer as this exacerbates both the need for areas to fill plus the emissions that will inevitably be caused by HGV transportation to those sites. Recycling glass will fulfil WSO8 in generating employment. Recycling glass could lead to a clean green industry within West Norfolk with the potential of hundreds of jobs.

NCC states that 'new facilities.... which help to achieve the targets for recycling.....will be encouraged'. NCC should be pursuing itself. Also, the policy mentions that 'initiatives to reduce waste and improve recycling are largely outside the scope of this Plan', however, whilst individual initiatives may be outside the scope they are not exclusive from the Plan. NCC currently ignores the fact that recycling glass more efficiently would not only reduce the amount of CO2 emissions in Norfolk and lessen the requirement for quarrying silica sand and destroying the Norfolk landscape, but would also vastly increase the local economy through the number of jobs created. This is a dereliction of duty to the taxpayers of Norfolk and not fulfilling the UK legal obligation to reduce CO2 emissions. NCC should also be planning to recover the glass from construction sites for recycling to improve the quality of cullet available for the manufacture of new flat glass. This would reduce the amount of raw material (silica sand) required to be quarried from the Norfolk countryside for use elsewhere. By not planning for this glass recovery and recycling NCC is not mitigating to reduce CO2

Fracking
Unnatural disturbance of the Earth's geological structure and plates is caused by fracking. Unknown effects could be disastrous and harmful for communities. It is irresponsible and dangerous for the current and future population. Fracking will contribute to climate change so goes against all policies to lessen effects of unnatural 'actions', eruptions and earth tremors.
Fracking already taking place in the Country has caused several tremors, causing fear, alarm and distress to residents. This is a material effect on human health and well-being.

Incineration
West Norfolk is responsible for more than a quarter of the County's emissions
(Lynn News page 12 - 9 August 2019.)

To allow, or even think of putting incineration into policies, is blatantly going against democracy of the last King's Lynn & West Norfolk Borough Poll where 65,000 people voted against incineration and NCC wasted millions of pounds on an abandoned project. Efforts should be put into alternative methods of waste reduction and disposal, or re-use schemes.

Questions asked by Norfolk County Councillor, Alexandra Kemp to NCC Cabinet.
Following £34 million lost from Council's budget, with the cancellation of the infamous South Lynn incinerator contract for Planning Failure in 2014, Council agreed a No-Incineration-in-Norfolk Policy, ("Appendix M").

West Norfolk is alarmed by the criteria-based Draft Waste Plan, which fails to state our No-Incineration Policy, instead permissively lists forms of incineration ( page 56), endangers West Winch Growth Area by permitting prospecting for fracking ( page 90), erroneously ignoring prospecting always causes earthquakes.

Can Cabinet amend the Plan to state " in West Norfolk, where 65,000 people voted against incineration in the Borough Poll, applications for incinerators will not be permitted"; and exclude fracking and prospecting for fracking?

West Winch Parish Council agrees with the County Councillor, Alexandra Kemp.

We do not need these policies which can cause more problems with emissions and climate change.

Policy WS07 Huge risks to human health and well-being and Air Quality page 17, para 5.18.

Page 26 Presumption in favour of sustainable development is likely to breach 7.1 (b) Communities health....
'Presumption in favour ...' should be removed.

Policy MW2 Development Management Criteria
'Unacceptable impact on (a) to (m).

Page 28 Pollution and Local Amenity Impacts
Para 8.9 there should be no impact on human health - densely populated area King's Lynn and proposed massive development at South East King's Lynn (SEKL).
Para 8.20 mentions Ancient Woodland - This must also apply to historical Grazing Commons, especially in West Winch and North Runcton.

Historical Environment
Para 8.28 - King's Lynn has ancient historical buildings. Harmful emissions and fracking would affect these valued buildings which attract visitors and tourists, contributing major finance to the area's economy.

West Winch and North Runcton have protected sites of local value -
Reference - page 20, West Winch and North Runcton Neighbourhood Plan (Planning material consideration)
Plus, 2 sites of Special Scientific Interest, and
3 County Wildlife Sites, including West Winch Common.

Page 32 - Land and Soil Resources
Para 8.31 Agricultural Land, which should include Grazing Common Land, must all be protected from contamination to protect our food chain for the future of the whole Country.

Page 34 Cumulative Impacts
It is imperative that cumulative impacts are taken into account as too often measurements are only taken close to the proposed development. Cumulative measurements impact on human health.

Page 46 '.... Not considered necessary to allocate any waste management sites in the Plan' - which means these sites can be developed anywhere on industrial sites etc and they could be near to densely populated areas.
This should be scrutinised more closely and incineration must be deleted.

Page 46 Policy WP1 Hazardous -----
Norfolk County Council needs to keep tight control over hazardous waste received from other Waste Planning Authorities.

Page 48 Policy WP2 Distance
Distance of waste facilities needs to be considerably increased to safe levels for human health away from populated areas.

Comments on the Norfolk Minerals and Waste Plan - Preferred Options, July 2019

MJCA are instructed by FH Ventures Norfolk Ltd to review the Norfolk Minerals and Waste Local Plan - Preferred Options document, July 2019 and prepare a response with comments on policies in the plan relevant to waste management and the site at Harling Road, Snetterton (an allocated site in the Adopted Norfolk Waste Site Specific Allocations Development Plan Document 2013 (DPD, 2013)).

The site at Harling Road, Snetterton is part of a former mineral working including the road frontage which is occupied by the site access road and a ready mix cement plant. To the south and adjacent to the former mineral working is a closed, restored landfill site, substation and recycling centre. A copy of the plan showing the site is attached for your information. The former mineral working and the closed, restored landfill are under separate ownership. In this document reference to the site is to the former mineral working and the road frontage.

As part of the work to assess the relevant Preferred Options Policy the planning status of the site has been reviewed and information on the current status regarding the adjacent closed, restored landfill site has been discussed with Norfolk County Council. The approved restoration scheme is for a single landform with a domed profile over the landfill and the former mineral extraction site. It is concluded that based on the dual ownership status, together with the presence of the closed landfill to the south of the site at which leachate and landfill gas generated is actively managed it is highly unlikely that the approved restoration scheme for the site will be achieved this is in particular as the sites are owned separately and any restoration scheme covering both sites in a single domed profile would include filling of a boundary wedge which would extend into both sites. It is also highly unlikely that it would be viable to raise the ground levels at the site to the domed shape in the approved profile with wastes that needed to be deposited in engineered containment cells due to the limited waste void that would be generated. It is considered that the site is suitable for the base to be raised with suitable compacted inert material if a larger footprint is needed for waste treatment and storage. The landowner acknowledges that the site can be returned to a beneficial use and that there is a need to bring forward a plan which addresses the long term use of the site compatible with its setting.

The Company are considering development options for the site such as waste treatment and storage and as part of any planning application will amend the consented restoration scheme for the former mineral extraction site which as stated above cannot be achieved.

Comments on specific policies

Policy WP1 Waste management capacity to be provided
The Policy provides indicative arising forecasts for waste types during the plan period up to 2036. It should be acknowledged that a strategic policy relating to waste management capacity may need to be updated over time as forecasts for the quantities of waste generated change and sites included in the capacity assessment close, or are not brought forward. The policy does acknowledge that new facilities or changes to existing facilities which help achieve the targets for recycling, composting, reuse and recovery set out in the Waste Management Plan for England (2013) will be encouraged. The wording of Policy WP1 should be changed to remove reference to sufficient capacity exists to meet the growth forecast as it is likely this will change during the plan period. The implementation of the Resources and Waste Strategy (December 2018) will require flexibility in plans in order that waste management operators can respond to specific requirements as the policy details become clearer.

Policy WP2 Spatial Strategy for waste management facilities
The policy is generally supported and provides flexibility for new waste management sites to be brought forward where they are needed on sites in proximity to where the production of waste is likely to be concentrated in the larger settlements where the greatest housing and employment growth during the plan period will take place.
It is stated in Policy WP2 that waste management facilities will only be acceptable on the types of land identified within Policy WP3 (land potentially suitable for waste management facilities). It is considered that to provide flexibility to ensure waste management sites are brought forward where a need is demonstrated on sites that are suitable in the specific development context wording such as 'or other sites demonstrated as suitable for the facility proposed' should be added to the policy.

Policy WP3 Land potentially suitable for waste management facilities
The policy provides flexibility for new waste management sites to be brought forward where they are needed based on contracts and market conditions during the timeframe of the plan. It is considered that former mineral extraction sites should be added to the list of land types where waste management facilities will be acceptable. It is unclear why a call for sites exercise was undertaken earlier in 2019 if the Council were not intending to allocate sites in the plan. The need to allocate sites for waste management development should be reconsidered as part of the examination process. As stated in the Preferred Options Document planning applications for waste management facilities will come forward during the plan period and allocations for the location of potential waste management sites is helpful in terms of planning for a specific area.

Appendix 3 - Existing Waste Site Specific Allocations Policies
It is noted that all of the sites allocated in the Waste Strategic Sites Allocations Document, 2013 are proposed for deletion. It is acknowledged in the Preferred Options document, 2019 that waste management sites will come forward during the plan period. It is considered that site allocations provide certainty regarding the type and location of waste management sites that may come forward during the plan period. In the event that the allocated sites are reviewed as part of the Examination it is requested that the promoters are provided the opportunity to make representation on the assessment of previously allocated sites.

Appendix 10 - Proposed Waste Management Sites
It is unclear why a call for sites exercise was undertaken in early 2019 if site allocations were not going to be included in the emerging plan. At Appendix 10 of the Preferred Options document an assessment of the sites proposed is presented. The conclusions for site WS2 (Former mineral working at Heath Road, Snetterton) presented in Appendix 10 that the site is unsuitable to allocate are disputed. The site is a former mineral extraction with an approved unachievable restoration scheme hence an alternative restoration or use for the site should be encouraged. The need to restore the site to a uniform ground level before a waste management facility, or other development could be brought forward would be subject to a detailed design and risk assessment in consultation with the Planning Authority and the Environment Agency. This is a specific characteristic of the site which would need careful consideration during the design and assessment of any development proposal at the site, but is not considered a significant constraint that would affect the deliverability of a permanent waste management facility on the site. It should be noted that development at the site may also be proposed without the need to infill the site to a uniform ground level.