Appendix 3 - Existing Waste Site Specific Allocations Policies

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Comment

Preferred Options consultation document

Representation ID: 94675

Received: 25/10/2019

Respondent: Norfolk County Council - Waste Disposal Authority

Representation Summary:

The Waste Disposal Authority notes that Appendix 3 deletes the existing waste site specific policies with a view to determining planning applications on those sites in accordance with criteria-based policies. Although the Waste Disposal Authority has no comment on any specific sites, we can confirm that we have no objection to this general approach.

Full text:

The Waste Disposal Authority notes that Appendix 3 deletes the existing waste site specific policies with a view to determining planning applications on those sites in accordance with criteria-based policies. Although the Waste Disposal Authority has no comment on any specific sites, we can confirm that we have no objection to this general approach.

Comment

Preferred Options consultation document

Representation ID: 98892

Received: 30/10/2019

Respondent: F H Ventures Norfolk Ltd

Agent: MJCA

Representation Summary:

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.

Full text:

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.

Object

Preferred Options consultation document

Representation ID: 98904

Received: 28/10/2019

Respondent: Serruys Property Company Limited

Agent: Howes Percival LLP

Representation Summary:

We write on behalf Serruys Property Company Limited ("SPCL") in response to the Norfolk Minerals and Waste Local Plan Preferred Options document ("Emerging Plan"):

1. SPCL is the owner of the Site totalling 9.1 hectares. The Site includes the following land identified on the enclosed plan:
a. Part of the Site edged blue allocated by Policy WAS 76 in the Waste Site Specific Allocations Development Plan Document (adopted October 2013) ("Adopted DPD"). This allocation extends to 0.4 hectares for an extension to the existing scrap metal recycling facility with an estimated capacity of 50,000 tonnes per annum. Policy WAS 76 is copied below:

Policy WAS 76
The site is allocated for an extension to the existing scrap metal recycling facility. Development will be subject to compliance with adopted Core Strategy and Development Management poIicies, and will require any planning application to address. in particular, the requirements below:
* Screening and landscaping along the boundary with Marriott's Way to protect landscape and local amenity;
* Protection or the amenities of residents, other businesses. and users of Marriott's Way through the siting and design of buildings, plant and equipment, including consideration of cumulative impacts with existing metal recycling on adjoining land, and mitigation and control of visual intrusion, noise, vibration, dust, Iitter and lighting;
* Appropriate site design. engineering and operations, including a Surface Water Management Strategy, impermeable site surfacing and a sealed drainage system, to ensure no adverse effects on the integrity of the River Wensum SAC and other protected habitats in the vicinity of the site;
* Submission of a Transport Assessment to include evaluation of the impacts of the development on the A1067 and on accesses to the A47 and provide appropriate mitigation if necessary; and
* Provision of acceptable highway access, including improvements to and rationalisatlon of existing site highway accesses off the A1067.

b. The remainder of the part of the Site coloured orange of
8.7 hectares and allocated by Policy WAS 78 in the Adopted DPD for mixed waste processing, metal recycling, inert waste recycling, treatment of household waste etc of up to 150,000 tonnes per annum. Policy WAS 78 is copied below:

Policy WAS 78
The site is allocated for mixed waste processing, metal recycling, inert waste recycling, in-vessel composting, physical, chemical, and/or mechanical/biological treatment of household waste, waste transfer. and other forms of residual waste treatment excluding thermal treatment. Development will be subject to compliance with adopted Core strategy and Development Management policies, and will require any planning application to address, in particular, the requirements below:
* The scale and bulk of new buildings and structures being compatible with the landscape in this location on the edge of the Wensum Valley;
* Screening and landscaping along the boundary with Marriott's Way to protect landscape and local amenity;
* Protection of the amenities of residents, other businesses. and users of Marriott's Way through the siting and design of buildings, plant and equipment, and mitigation and control of visual intrusion, noise, vibration, dust, bioaerosols, litter, odour, and lighting;
* Appropriate site design, engineering and operations, including a Surface Water Management Strategy, impermeable site surfacing and a sealed drainage system, to ensure no adverse effects on the integrity of the River Wensum SAC and other protected habitats in the vicinity of the site, particularly from water run-off and emissions to air;
* Submission of a Transport Assessment to include evaluation of the impacts of the development on the A1067 and on accesses to the A47 and provide appropriate mitigation if necessary; and
* Provision of acceptable highway access, including improvements to and rationalisation of existing highway accesses off the A1067.

c. Land hatched blue comprising the existing metal recycling facilities (which includes part of the Site allocated under WAS 78) [The capacity from this facility is included in Appendix 1 "Waste facilities over 20,000 tonnes per annum in Norfolk 2012-2016" to the Waste Capacity Assessment 2017 (updated in June 2019) ("Waste Capacity Assessment")].

d. Land hatched red comprising part of the existing allocation WAS 78 of 2.1 hectares that has the benefit of planning permission for waste processing and the production of Refuse Derived Fuel ("RDF") with an annual throughput of 150,000 tonnes per annum and associated works. This development is permitted pursuant to planning permissions granted under reference APP/X2600/W/17/318973 dated 22 August 2018 and under reference C/5/2017/5007 dated 20 September 2018 ("Existing Consents").

2. The Site remains available. SPCL remain committed and supportive of waste management facilities across the Site and in turn would fully support - and recommend - the retention of the allocations under WAS 76 and WAS 78 in the Emerging Plan.

3. As explained in previous representations made on behalf of SPCL, the Site has a capacity for waste processing of up to 300,000 tonnes; 150,000 of which has already been permitted through the Existing Consents and 50,000 of which is already deemed acceptable through the current WAS 76 allocation. An increase of only 100,000 tonnes per annum is therefore proposed, which may appropriately be accommodated on the Site.

4. It is acknowledged that the Waste Capacity Assessment concluded: "sufficient capacity already exists to accommodate the forecast growth in waste [arising] over the Plan period to 2036. Therefore, it is not considered necessary to allocate any specific sites for waste management facilities in the M&WLPR. However, planning applications for new waste management facilities are still expected to come forward during the Plan period, both to move waste management up the waste hierarchy and because waste management is a contract driven and competitive industry. Therefore, the M&WLPR contains criteria-based policies to determine those planning applications that come forward for waste management facilities. [Emerging Plan, paragraph 1.2,]

5. However, the Waste Capacity Assessment has taken into account - when reaching the conclusion that sufficient capacity may exist for waste facilities over the plan period - the anticipated capacity from the Site allocated already under WAS 78 and permitted under the Existing Consents. [Waste Capacity Assessment, paragraph 2.4 and Appendix 2]

6. It is therefore crucial to ensure that this part of the Site remains allocated for waste processing uses. Otherwise there cannot be any guarantee that the Site, or any waste processing sites of a suitable type and location to meet identified needs, would come forward during the plan period.

7. For this same reason, SPCL would support the continued allocation of the Site as a whole for waste management uses in the Emerging Plan for up to 300,000 tonnes per annum. SPCL would also propose that the proposed uses reflect that contained in existing Policy WAS 78 save for the addition of thermal treatment. This is particularly because most of RDF is currently exported as the UK does not have sufficient facilities to properly convert RDF into energy. An allocation for thermal treatment would therefore be of substantial benefit, particularly following Brexit and the uncertainties over continuation of the export of RDF.

8. It must also be remembered that the suitability of the Site for waste processing has already been accepted through adoption of the Adopted DPD policies WAS 76 and WAS 78 [See paragraphs 6.76.2 to 6.76.5 and 6.78.2 to 6.78.5 of the Adopted DPD] and the Existing Consents.

9. In particular, the Adopted DPD acknowledges that there would be no adverse impact on the integrity of European sites (i.e. the River Wensum SAC) and that any other environmental impact or constraints could be sufficiently mitigated as may be demonstrated through a planning application. [Confirmed in paragraphs 6. 76.3 and 6. 76.5, and 6. 78.3 and 6. 78.5 for WAS 76 and WAS 78 respectively]

10. The suitability of part of the Site allocated under WAS 78 for waste processing for up to 150,000 tonnes per annum was agreed through the planning applications that culminated in the Existing Consents. Both the Council (following no objection from the various statutory consultees) and the Inspector on appeal in granting consent found that there were no planning or environmental constraints preventing the grant of planning permission for waste processing.

11. For the above reasons, it is clear that the Site should be specifically allocated for waste processing for up to 300,000 tonnes per annum for those specific uses detailed in policy WAS 78 (copied above) plus thermal treatment.

Full text:

Our Client: Serruys Property Company Limited
Atlas Works, Norwich Road, Morton-on-the-Hill and Weston Longville ("Site")
Norfolk Minerals and Waste Local Plan Preferred Options Consultation
We write on behalf Serruys Property Company Limited ("SPCL") in response to the Norfolk Minerals and Waste Local Plan Preferred Options document ("Emerging Plan"):

1. SPCL is the owner of the Site totalling 9.1 hectares. The Site includes the following land identified on the enclosed plan:

a. Part of the Site edged blue allocated by Policy WAS 76 in the Waste Site Specific Allocations Development Plan Document (adopted October 2013) ("Adopted DPD"). This allocation extends to 0.4 hectares for an extension to the existing scrap metal recycling facility with an estimated capacity of 50,000 tonnes per annum. Policy WAS 76 is copied below:

Policy WAS 76
The site is allocated for an extension to the existing scrap metal recycling facility. Development will be subject to compliance with adopted Core Strategy and Development Management policies, and will require any planning application to address. in particular, the requirements below:
* Screening and landscaping along the boundary with Marriott's Way to protect landscape and local amenity;
* Protection or the amenities of residents, other businesses. and users of Marriott's Way through the siting and design of buildings, plant and equipment, including consideration of cumulative impacts with existing metal recycling on adjoining land, and mitigation and control of visual intrusion, noise, vibration, dust, litter and lighting;
* Appropriate site design. engineering and operations, including a Surface Water Management Strategy, impermeable site surfacing and a sealed drainage system, to ensure no adverse effects on the integrity of the River Wensum SAC and other protected habitats in the vicinity of the site;
* Submission of a Transport Assessment to include evaluation of the impacts of the development on the A1067 and on accesses to the A47 and provide appropriate mitigation if necessary; and
* Provision of acceptable highway access, including improvements to and rationalisation of existing site highway accesses off the A1067.

b. The remainder of the part of the Site coloured orange of 8. 7 hectares and allocated by Policy WAS 78 in the Adopted DPD for mixed waste processing, metal recycling, inert waste recycling, treatment of household waste etc of up to 150,000 tonnes per annum. Policy WAS 78 is copied below:

Policy WAS 78
The site is allocated for mixed waste processing, metal recycling, inert waste recycling, in-vessel composting, physical, chemical, and/or mechanical/biological treatment of household waste, waste transfer. and other forms of residual waste treatment excluding thermal treatment. Development will be subject to compliance with adopted Core strategy and Development Management policies, and will require any planning application to address, in particular, the requirements below:
* The scale and bulk of new buildings and structures being compatible with the landscape in this location on the edge of the Wensum Valley;
* Screening and landscaping along the boundary with Marriott's Way to protect landscape and local amenity;
* Protection of the amenities of residents, other businesses. and users of Marriott's Way through the siting and design of buildings, plant and equipment, and mitigation and control of visual intrusion, noise, vibration, dust, bioaerosols, litter, odour, and lighting;
* Appropriate site design, engineering and operations, including a Surface Water Management Strategy, impermeable site surfacing and a sealed drainage system, to ensure no adverse effects on the integrity of the River Wensum SAC and other protected habitats in the vicinity of the site, particularly from water run-off and emissions to air;
* Submission of a Transport Assessment to include evaluation of the impacts of the development on the A1067 and on accesses to the A47 and provide appropriate mitigation if necessary; and
* Provision of acceptable highway access, including improvements to and rationalisation of existing highway accesses off the A1067.

c. Land hatched blue comprising the existing metal recycling facilities (which includes part of the Site allocated under WAS 78) [The capacity from this facility is included in Appendix 1 "Waste facilities over 20,000 tonnes per annum in Norfolk 2012-2016" to the Waste Capacity Assessment 2017 (updated in June 2019) ("Waste Capacity Assessment")].

d. Land hatched red comprising part of the existing allocation WAS 78 of 2.1 hectares that has the benefit of planning permission for waste processing and the production of Refuse Derived Fuel ("RDF") with an annual throughput of 150,000 tonnes per annum and associated works. This development is permitted pursuant to planning permissions granted under reference APP/X2600/W/17/318973 dated 22 August 2018 and under reference C/5/2017/5007 dated 20 September 2018 ("Existing Consents").

2. The Site remains available. SPCL remain committed and supportive of waste management facilities across the Site and in turn would fully support - and recommend - the retention of the allocations under WAS 76 and WAS 78 in the Emerging Plan.

3. As explained in previous representations made on behalf of SPCL, the Site has a capacity for waste processing of up to 300,000 tonnes; 150,000 of which has already been permitted through the Existing Consents and 50,000 of which is already deemed acceptable through the current WAS 76 allocation. An increase of only 100,000 tonnes per annum is therefore proposed, which may appropriately be accommodated on the Site.

4. It is acknowledged that the Waste Capacity Assessment concluded: "sufficient capacity already exists to accommodate the forecast growth in waste [arising] over the Plan period to 2036. Therefore, it is not considered necessary to allocate any specific sites for waste management facilities in the M&WLPR. However, planning applications for new waste management facilities are still expected to come forward during the Plan period, both to move waste management up the waste hierarchy and because waste management is a contract driven and competitive industry. Therefore, the M&WLPR contains criteria-based policies to determine those planning applications that come forward for waste management facilities. [Emerging Plan, paragraph 1.2,]

5. However, the Waste Capacity Assessment has taken into account - when reaching the conclusion that sufficient capacity may exist for waste facilities over the plan period - the anticipated capacity from the Site allocated already under WAS 78 and permitted under the Existing Consents. [Waste Capacity Assessment, paragraph 2.4 and Appendix 2]

6. It is therefore crucial to ensure that this part of the Site remains allocated for waste processing uses. Otherwise there cannot be any guarantee that the Site, or any waste processing sites of a suitable type and location to meet identified needs, would come forward during the plan period.

7. For this same reason, SPCL would support the continued allocation of the Site as a whole for waste management uses in the Emerging Plan for up to 300,000 tonnes per annum. SPCL would also propose that the proposed uses reflect that contained in existing Policy WAS 78 save for the addition of thermal treatment. This is particularly because most of RDF is currently exported as the UK does not have sufficient facilities to properly convert RDF into energy. An allocation for thermal treatment would therefore be of substantial benefit, particularly following Brexit and the uncertainties over continuation of the export of RDF.

8. It must also be remembered that the suitability of the Site for waste processing has already been accepted through adoption of the Adopted DPD policies WAS 76 and WAS 78 [See paragraphs 6.76.2 to 6.76.5 and 6.78.2 to 6.78.5 of the Adopted DPD] and the Existing Consents.

9. In particular, the Adopted DPD acknowledges that there would be no adverse impact on the integrity of European sites (i.e. the River Wensum SAC) and that any other environmental impact or constraints could be sufficiently mitigated as may be demonstrated through a planning application. [Confirmed in paragraphs 6. 76.3 and 6. 76.5, and 6. 78.3 and 6. 78.5 for WAS 76 and WAS 78 respectively]

10. The suitability of part of the Site allocated under WAS 78 for waste processing for up to 150,000 tonnes per annum was agreed through the planning applications that culminated in the Existing Consents. Both the Council (following no objection from the various statutory consultees) and the Inspector on appeal in granting consent found that there were no planning or environmental constraints preventing the grant of planning permission for waste processing.

11. For the above reasons, it is clear that the Site should be specifically allocated for waste processing for up to 300,000 tonnes per annum for those specific uses detailed in policy WAS 78 (copied above) plus thermal treatment.

12. In addition, we consider the following amendments should be made to the Emerging Plan policies for clarity:

a. Policy WP2: Spatial Strategy for waste management facilities: this policy should be amended by referring specifically to the plan on the following page so it is clear as to how the 3 and 5 mile distances are to be applied. Alternatively, such clarification may be provided in paragraph W 2.2.

b. Policy WP3: Land potentially suitable for waste management facilities: this policy should be amended so that criteria (b) includes land with an existing or lawful general industrial B2 use or storage and distribution use under B8, or on sites that were previously consented for waste management facilities.

c. Policy WP6: Transfer, storage, processing and treatment of hazardous waste: this policy should again be amended in line with the suggestion at 12 (b) above for Policy WP3.

d. Policy WP7: Household Waste Recycling Centres: this policy should be amended by replacing the words "may be" to "will only be" for clarity and to be consistent with the terminology used in policies WP3 onwards.

Should you wish to discuss further, or require any further information, please do not hesitate to contact the writer on the details below.

Comment

Preferred Options consultation document

Representation ID: 99026

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

We note that WAS 05, WAS 25, WAS 36, WAS 40, WAS 37, WAS 45 and WAS 65 are no longer required and would therefore be deleted. There is therefore no risk to residential amenity from these sites.

Full text:


Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Mineral Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Submitted noise assessments and air quality/dust assessments should consider and include mitigation measures to deal appropriately with any potential health impacts, such as operational practices, separation/standoff areas and screening and/or bunding in line with Development Management Policies DM12 and DM13.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework.

Lighting:
Lighting is not included in the document as this is generally something which can be considered at any proposed planning application stage; however we would hope that any proposed lighting for site security and worker safety would be carefully considered prior to the planning stage so details can be submitted with any planning application. We would assume lighting would be pole mounted in elevated positions, and therefore the throw and spread of this should be assessed to ensure that there is no impact on residents. Light should be contained within the confines of sites and positioned appropriately. If necessary lighting is located near dwellings, this should be angled away and hooded/cowled to prevent any adverse impact on residents.

Vibrations:
The potential impact from vibrations should also be considered at any future planning stage, if sites are chosen close to residential receptors - including vibrations from site operations and associated transportation of extracted materials.

Soil Stripping:
Soil stripping operations must be effectively controlled through mitigation methods (e.g. buffer zones and bunding) to reduce fugitive emissions, which pose short term health impacts on nearby residents. These mitigation measures must be included in any future planning application.

Haul Roads:
Fugitive emissions from haul roads need to be addressed in any future planning application, with mitigation planned where necessary such as wheel washing.

[see attached table for comments on individual sites]

Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Waste Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Any future applications for waste sites should be accompanied by noise, odour, dust, and air quality management schemes, which should identify potential sources and mitigation/control measures to prevent nuisance issues and health impacts (e.g. emissions from as gas flaring).
Where sites are likely to be illuminated for safety/security, lighting plans and details should also be submitted which should include where lights will be located, their heights and angle/orientation, the type of lighting and the throw and spill of light across the site, and measures to ensure light spill is contained within site boundaries.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework

Existing Waste Site Specific Allocation Policies:
We note that WAS 05, WAS 25, WAS 36, WAS 40, WAS 37, WAS 45 and WAS 65 are no longer required and would therefore be deleted. There is therefore no risk to residential amenity from these sites.

Odour:
An odour impact assessment should be included within any future planning applications for allocated waste sites, along with suitable mitigation measures where appropriate.

Climate Change:
Climate change mitigation should be considered with regards to methane emissions (a greenhouse gas) released from allocated landfill sites.

[see attached table for comments on individual sites]