Draft Sustainability Appraisal Report (Part B)

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Object

Background documents

Representation ID: 94691

Received: 27/10/2019

Respondent: Mrs LDT Gallagher

Representation:

The plan is not sound.
Without a sound glass recycling policy/plan Including flat glass recycling NCC fails their own sustainability objectives SA1, SA3, SA4, SA5. SA6, SA8, SA9, 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).

Full text:

The Vision Policy and Objectives fail for the following reasons

If Norfolk County Council adhered to NPPF for guidance it would look conserve minerals as it states in (Ch 17, para 204.b) that authorities should 'take account of...recycled materials...before considering extraction of primary materials..'. NCC is failing to recycle before extracting raw materials and therefore their plan to 2036 is not sound.

Waste Management Objectives 1-8 - How do NCC intend to prevent and minimise waste without the ability to recycle 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. You cannot have net self sufficiency if you export waste from within Norfolk to outside those County boundaries; landfill is not the answer as this exacerbates both the need for areas to fill and the emissions that will inevitably be caused by transport 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.

Mineral Strategic Objectives 1-10 - Quantify 'adequate' in MSO2. This figure is calculated by profit driven industry not 'the need'. This forecast 'need' is based on continuing to extract raw materials before considering better recycling. This reduces the need to 'winning over' large swathes of countryside to quarrying and would reduce the areas needed fulfilling MSO6. MSO7 could be fulfilled by recycling glass; thereby ensuring the residents of West Norfolk will not need to fear for their deteriorating health from Cancers to obesity, from respiratory disease and mental health issues caused by quarrying. The road network in this part of Norfolk is saturated already, that cannot mitigate against the increase of CO2 risking the health and wellbeing of residents.

Reducing the amount of mineral extraction and championing a World beating glass recycling plant NCC could fulfil MSO8 objective. In order to do this NCC needs to plan to recycle glass more efficiently and to a better quality within Norfolk. NCC need to comply with the Climate Change Act and the UK's legal obligations to reduce greenhouse gas emissions.

NCC has failed objective MSO9 this in part is due to Sibelco's proven poor record for restoration of previous worked sites, in the case of AOSE the area is already biodiverse.

MSO10 states- Increase public access to the countryside .... through enhancing the amenity value of the land when restoring excavation sites. AOS E and the ⅓ of SIL 02 which remains in the plan is not owned by NCC, therefore the operator; Sibelco, nor the landowner/s, can be compelled by NCC to enhance access for the public as it will not revert to flat open farmland.

Policies MW1-6 There are no sustainable economic or social benefits to be had for the local areas around Marham and Shouldham from any quarrying in Shouldham Warren or Marham Fen. There would only be a couple of jobs created but the siting of a quarry will deter people visiting the area for recreation and tourism and will also stop any local growth, such as that being planned by the Borough Council of King's Lynn and West Norfolk in their Local Plan. Quarrying these areas will remove the social benefits currently enjoyed by residents and visitors to Shouldham Warren and the Nar Valley Way; this is hardly following the NPPF.

MW2 - SA1-13 In AOS E and the area of SIL 02 that it still contains, cannot not be mitigated against, especially the bird-strike risk highlighted by the MOD (DIO) objection, the cumulative effect of all these objectives in short, medium and long term is unacceptable.

MW3 - Transport. We agree with the NCC policy on transport in regards of mineral and waste developments. However, we fail to see how any mitigation measures would be sufficient to not generate all of the unacceptable outcomes listed in MW3 if any mineral development were to be granted permission in AOS E and the area of SIL 02 that it still encompasses.

MW4 - Climate change mitigation and adaptation. NCC has no plans in place to account for reducing CO2 emissions from the quarrying of silica sand. It should put in place a plan that increases the quantity and quality of glass recycling; this will reduce the amount of raw material (silica sand) required to be quarried, which reduces the CO2 emissions from both quarrying and glass manufacturing (more recycled glass used in manufacture reduces CO2 emitted and the energy required).

MW5 - The Brecks Protected Habitats and Species. We note here that birds are afforded a greater buffer zone than that considered acceptable for people close to any proposed or actual mineral development. That is unacceptable. However, there are breeding pairs of Nightjars within The Warren (AOSE) and possibly Woodlarks too, therefore, the Warren should be afforded a 400m buffer as per MW5.

MW6 - In respect of the remaining ⅓ of SIL 02 that is within AOS E, this objective cannot be met since Sibelco (the company proposing the site) state the site would be restored to a lake and not returned to grade 3 agricultural land.

Waste Management WP1 - WP4, SA1-13 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.

Mineral Specific Policies- Forecast need for 13.5M tonnes of silica 2019-36; permitted reserves 3.0M tonnes, therefore, 10.5M tonnes required. All of this is based on no increase in the recycling of clear glass than is already happening.

MP1 -Flawed in respect of silica sand as it assumes that clear glass recycling will not improve, which would reduce the amount of CO2 produced to extract silica sand and during the manufacture of new glass with use of additional high quality cullet. This conflicts with MSO3 and NPPF Guidance (Ch 17, para 204.b) that states to look to recycle before extracting raw material.

MP2 - The area of 250m around sensitive receptors, etc is completely arbitrary and has no basis in research. There have been no studies conducted in the UK, therefore, a 250m zone to mitigate against respiratory dust is unsound.

In addition it is noted that in policy MW5 a buffer of 1500m from a mineral site is mandated for areas supporting a bird (Stone Curlew) yet a buffer of merely 250m, or less, is deemed acceptable for humans. This also makes the M&WLP unsound.

MP5 - There needs to be a specific time scale added to this statement as to destroy biodiversity for profit under the guise of enhancing it later (20-30+ years hence) through restoration is an illogical step and unacceptable. Also the M&WLP at section MP5 on page 76 describes Core River Valleys in Norfolk as 'vital ecological habitats and corridors, supporting a variety of biodiversity habitats and species. In this respect, Core River Valleys are a key component in the development of Norfolk's identified Green Infrastructure corridors. Sand and gravel resources are commonly found in river valleys and many of Norfolk's river valleys have therefore been quarried for aggregate extensively over many years. This has led to many large bodies of open water left on restoration of past mineral workings which are not in keeping with the general character of Norfolk's river valleys. Although not formally designated, safeguarding the Core River Valleys will help preserve the unique and rich quality of Norfolk's landscape and natural heritage'. With ref to AOS E, including the overlap area that includes a part of SIL 02, with a water bodies already at Pentney and at the Middleton aggregate works just to the north of the river Nar SSSI, then the addition of a much larger water body (e.g.such as the aftermath of SIL 02 as described by Sibelco previously) so close would be exactly what this paragraph explicitly says we shouldn't be doing.

MP6 - Whilst MP6 is about cumulative impacts from other concurrent mineral extraction sites, (we are surrounded by mineral sites and plants in West Norfolk already), and Middleton aggregates is just across the river Nar, it fails to address the other potential cumulative impacts in an area, e.g. a close military airbase with the persistent jet noise. Neither does it mention the cumulative impacts of the period of time for working an area if it is to be prolonged.

MP7 - Restoration - the local community suffer the losses of amenity for the benefit of the mineral operator, the landowner and kudos for the MPA, with a mineral extraction site for many years and even generations being blighted. Neither does it address the timescale that some sites may be actively quarried before greater public access is potentially achievable. Finally, it does not specify that the restoration will be for the benefit of the local community and not a fee paying public for a development by a private company.

MP11 - States on pg 83 of the M&WLP that minerals are a finite natural resource; therefore, NCC's M&WLP is flawed without plans to extend the life of the silica sand resources in Norfolk through an advanced glass recycling policy and plan.

Without a sound glass recycling policy/plan NCC fails their own sustainability objectives SA1, SA3, SA4, SA5. SA6, SA8, SA9, 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).

Object

Background documents

Representation ID: 94928

Received: 29/10/2019

Respondent: Mr JJ Gallagher

Representation:

Without a sound glass recycling policy/plan the NCC M&WLP fails their own sustainability objectives SA1, SA3, SA4, SA5. SA6, SA8, SA9, 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).

Full text:

Norfolk County Council's (NCC) Mineral and Waste Local Plan (M&WLP) fails its Vision, Policies and Objectives. Let me expand below.

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.

Mineral Strategic Objectives - In order for MSO 2 to be sound it must quantify what is an 'adequate' supply. Currently, in the case of silica sand, the figures that NCC use to quantify adequate are based on the 'need' that Sibelco, the monopoly company extracting silica sand in Norfolk, tell NCC is the need. There is no independent verification by NCC of these figures; they do not know where the extracted silica sand goes to once it leaves Norfolk; they do not know if any glassmaking sand from Leziate is exported; they do not have independent verification of the actual quantities extracted each year. An extremely loose set of affairs that makes the plan for silica sand extraction in Norfolk unsound.

MSO 6 could be fulfilled by planning and instigating a world-class glass recycling infrastructure in Norfolk. It would reduce the need to quarry huge areas of countryside. MSO7 could also be fulfilled by the plan for recycling glass above because the areas required would be reduced meaning fewer people living within proximity of a silica sand quarry.

NCC is poorly placed to argue that MSO 8 is being fulfilled without planning to introduce a world-class recycling infrastructure in Norfolk. Without this, they are not fulfilling their obligation to The Climate Change Act or supporting the UK's legal obligations to reduce the production of greenhouse gases. Recycling as suggested here reduces the amount of raw material required in glass manufacture, which reduces the CO2 produced in the process and uses less energy. Without more efficient clear and flat glass recycling at greater rates than present NCC fail MSO 8.

In respect of MSO 9, it is illogical and unsound to try and defend destroying already richly diverse habitats for generations to come in order to quarry for minerals, by stating that your objective is, "The after use will protect and enhance the environment, including landscape and biodiversity improvements". The areas in question are already biodiverse, if they need improving then do that now not pretend that quarries will be returned to an idyllic wonderland. That statement in MSO 9 is at best wishful thinking and history proves it is unenforceable. Without a doubt, MSO 9 is unsound.

Similarly, MSO10 is unsound and illogical if the plan is to give over to quarrying areas of countryside that are already accessible to the public. Such areas exist within the M&WLP and whilst they remain the plan is unsound.
Policies MW - There are no sustainable economic or social benefits to be had for the local areas from quarrying in Shouldham Warren or Marham Fen. For a couple of jobs created by a quarry there, more agricultural working jobs would be lost Tourists to the Nar Valley Way and Shouldham Warren would be deterred - why would they wish to spend their recreational outdoor leisure time next to a working silica sand quarry? Those tourists deterred then impact local businesses. The area is specifically designated in the local Borough Council's Local Development Plan as an area for new housing to support the RAF Main Operating Base for the Lightning II at RAF Marham, but why would families locate there to live beside a working silica sand quarry? The answer is they wouldn't. Quarrying in these areas will not enhance the social benefits or amenity currently enjoyed by residents and visitors to Shouldham Warren and the Nar Valley Way; it will remove them and that is not following the NPPF.

MW2 There are 13 impacts listed that mineral development must not have an unacceptable impact upon. For AOS E and the area of SIL 02 that it still contains all of the impacts listed are present and cannot be mitigated against The bird-strike risk alone highlighted by the MOD (DIO) objection in the Initial Consultation, should be enough to have these areas removed from the M&WLP; however, add the cumulative effect of all the objectives and in any timeframe quarrying in these areas is an unacceptable risk.

MW3 - NCC policy on transport in regards to mineral and waste developments is agreeable in general. However, if any mineral development were to be granted permission in AOS E and the area of SIL 02 that it still contains, it is difficult to see what mitigation measures would be sufficient against all of the unacceptable outcomes listed.

MW4 - Without forging a robust, advanced clear and flat glass recycling facility here in Norfolk, which would reduce the CO2 emissions from both quarrying and glass manufacturing (more recycled glass used in manufacture reduces CO2 emissions and the energy required), the M&WLP is unsound in not accounting for the reductions that are available but not planned for as set out in MW4.

MW5 - The Brecks Protected Habitats and Species. How can it be acceptable to place a greater protection buffer zone around a species of bird than that considered acceptable for people who live close to any proposed or actual mineral development? Providing protection to wildlife from the adverse impacts of humans is right and proper. There are breeding pairs of Nightjars within Shouldham Warren (AOSE) and possibly Woodlarks too; therefore, the Warren should be afforded a 400m buffer as per MW5.

MW6 - In respect of the remaining ⅓ of SIL 02 that is within AOS E, this objective cannot be met since Sibelco (the company proposing the site) state the site would be restored to a lake and not returned to grade 3 agricultural land. Therefore, AOS E and SIL 02 should be removed from the plan going forward.

Waste Management WP1 - WP4, SA1-13 NCC states that 'new facilities.... which help to achieve the targets for recycling.....will be encouraged' but also says, 'initiatives to reduce waste and improve recycling are largely outside the scope of this Plan'. This makes the plan unsound as you cannot have it both ways; if you want to encourage recycling then new initiatives cannot be outside the scope of the plan. NCC should be pursuing a radical overhaul to their current system of glass recycling with a view to leading the field nationally in forging ahead with an innovative plan to ensure Norfolk sets the standards for clear and flat glass recycling. 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. Not engaging in this is a dereliction of duty to the taxpayers of Norfolk and is not fulfilling the UK legal obligation to reduce CO2 emissions.

Mineral Specific Policies- Forecast need for 13.5M tonnes of silica 2019-36; permitted reserves 3.0M tonnes, therefore, 10.5M tonnes required. This is all assuming there is no increase in the recycling of clear glass than is already happening.

MP1 -The policy is flawed because it assumes, for silica sand, that clear glass recycling will not improve, which in turn conflicts with MSO3 and NPPF Guidance (Ch 17, para 204.b) that states to look to recycle before extracting raw material.

MP2 - Where is the research that shows an area of 250m around sensitive receptors, etc is a reasonable and sound distance? It is completely arbitrary and has no basis in research, therefore the figure assumed is unsound. In addition, it is noted that in policy MW5 a protection zone of 1500m from a mineral site is mandated for any area supporting a bird (Stone Curlew) but a buffer of merely 250m, or less, is deemed acceptable for humans. This also makes the M&WLP unsound.

MP5 - This policy is unsound without the addition of an acceptable timescale. It is too open-ended and could allow for quarrying for several generations before any 'enhancement' occurs; that is unacceptable. Also, the M&WLP at section MP5 on page 76 describes Core River Valleys in Norfolk as 'vital ecological habitats and corridors, supporting a variety of biodiversity habitats and species. In this respect, Core River Valleys are a key component in the development of Norfolk's identified Green Infrastructure corridors. Sand and gravel resources are commonly found in river valleys and many of Norfolk's river valleys have been quarried for aggregate extensively over many years. This has led to many large bodies of open water left on restoration of past mineral workings which are not in keeping with the general character of Norfolk's river valleys. Although not formally designated, safeguarding the Core River Valleys will help preserve the unique and rich quality of Norfolk's landscape and natural heritage'. With ref to AOS E, including the overlap area that includes a part of SIL 02, with a water bodies already at Pentney and at the Middleton aggregate works just to the north of the river Nar SSSI, then the addition of a much larger water body (e.g.such as the aftermath of SIL 02 as described by Sibelco previously) so close would be exactly what this paragraph explicitly says we shouldn't be doing.

MP6 - The areas around Shouldham and Marham have a plethora of mineral sites and plants already, and whilst MP6 is to address cumulative impacts of phased workings the M&WLP fails to address the other potential cumulative impacts in an area, e.g. a close military airbase with the persistent jet noise. Neither does it mention the cumulative impacts of the period of time for working an area if it is to be prolonged. Without these consideration being added to the policy, it is unsound.

MP7 - Restoration - Once again there is no timeframe bounding how long communities must suffer quarrying in their area before it will be restored. The statement "that worked land is reclaimed at the earliest opportunity" is open to interpretation in favour of the quarrying company and the disadvantage of the local residents. That makes the policy flawed, unacceptable and unsound. As it currently stands the policy means a local community suffers the loss of amenity for the benefit of the mineral operator, the landowner and the kudos for the MPA, for a mineral extraction site that lasts for many years and even generations. Finally, it does not specify that the restoration will be for the benefit of the local community and not a fee-paying public for a development by a private company. Without a definitive timescale to restoration and guarantees that land will be returned freely for the amenity of the local community, this policy is unsound.

MP11 - States on pg 83 of the M&WLP that minerals are a finite natural resource; therefore, NCC's M&WLP is unsound without plans to extend the life of the silica sand resources in Norfolk through an advanced glass recycling policy and plan.

Without a sound glass recycling policy/plan the NCC M&WLP fails their own sustainability objectives SA1, SA3, SA4, SA5. SA6, SA8, SA9, 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).

Support

Background documents

Representation ID: 98886

Received: 30/10/2019

Respondent: Natural England

Representation:

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

We are satisfied, and agree, with the findings of both of the above Sustainability Appraisal (SA) and Habitats Regulations Assessment documents, both are thorough and robust. My only comment in regard to the SA is that it would be good under Table 8.1 under SA6: To protect and enhance Norfolk's biodiversity and geodiversity, to include an indicator which demonstrates how the Local Plan is contributing to biodiversity net gain by recording the area of new habitats created following the restoration of allocated sites.

Otherwise, I'd just like to reiterate the remarks I made in response to the Initial Options stage, that you and your team are to be congratulated on the quality of the consultation documents that have been produced. Natural England considers that the M&WLPR undertaken to date has been detailed, comprehensive and written in accordance with current legislation and policy.

Full text:

Thank you for your consultation on the above dated 17 September 2019 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

We welcome the opportunity to comment on the Preferred Options consultation of the Minerals and Waste Local Plan Review (M&WLPR) prepared by your authority, and have submitted a few comments on specific policies and proposed site allocations through the on-line consultation process, having reviewed the following documents:
* Main M&WLPR Preferred Options consultation document, dated July 2019;
* Draft Sustainability Appraisal (Part B) of the M&WLPR, dated June 2019; and
* Draft Habitats Regulations Assessment (Test of Likely Significant Effect)of M&WLPR, dated July 2019.

We are satisfied, and agree, with the findings of both of the above Sustainability Appraisal (SA) and Habitats Regulations Assessment documents, both are thorough and robust. My only comment in regard to the SA is that it would be good under Table 8.1 under SA6: To protect and enhance Norfolk's biodiversity and geodiversity, to include an indicator which demonstrates how the Local Plan is contributing to biodiversity net gain by recording the area of new habitats created following the restoration of allocated sites.

Otherwise, I'd just like to reiterate the remarks I made in response to the Initial Options stage, that you and your team are to be congratulated on the quality of the consultation documents that have been produced. Natural England considers that the M&WLPR undertaken to date has been detailed, comprehensive and written in accordance with current legislation and policy.

If you have any questions please contact me.

Comment

Background documents

Representation ID: 98975

Received: 15/10/2019

Respondent: Broads Authority

Representation:

SA - Part B
4.5 - did you consider a zone from the Broads?

Full text:

* 1.5 - one specific site[s] for carstone extraction
* 1.14 - tpa - presume that is tonnes per annum - not used consistently in this para
* Page 12 - SA section - bullet point list does not mention landscape impact or biodiversity
* 5.16 The area known as the [Breaks] Brecks
* Where is MW1? The first policy is MW2.
* MW2 - The first part is written in quite a different way to other policies I have read; rather than saying that impacts of development will be minimised on the criteria, or schemes will address the criteria, you ask for information only. I am not sure how strong this approach is. b) what about the quantity of surface water (as in what to do with it in relation to flooding) and the quality of water bodies? E) what agriculture land class do you consider this to be - Grade 1 and 2 perhaps - might need to say that. What about if the soil that is to be excavated or disturbed is peat soils? Peat soils have many special qualities, such as are a carbon sink but a carbon source if allowed to dry out. We recommend that you consider protecting Peat Soils - you can look at our Peat Soils policy for ideas. i) what are 'outdoor recreation facilities' and do you need to include Local Green Space as well as Open Space?
* 8.12 - request there is some text, perhaps as a footnote, that refers to the identified dark skies of the Broads and refers to our maps and policy.
* 8.16 says 'Directing lighting downwards and away from properties' but taking this literally, this contradicts - implying angling the light away from properties which could cause light pollution. I think you are saying design any lighting so it points downwards and ensure that there is no light trespass for example into neighbouring properties. You might want to consider that wording and you might want to look at our policy on light pollution. The key point is - do you really need lighting, if so why? Keep it to a minimum, use it when needed and point it down and have it fully shielded - I suggest you get those points across strongly in the policy.
* 8.24 first bullet point - weave in wording that refers to the setting of the landscapes.
* 8.31 and section 12 - I see you refer to soil grades 1, 2 and 3a. As a bit of advice from our experience, do you know where 3a is? There is limited mapping relating to 3a. You might want to consider removing this or just saying '3'. Happy to chat this through. Should the soil grade be mentioned in the policy? Note what is said on page 73, I - that 3a and 3b are not mapped.
* 8.32, 12.2 - temporary yes, but for a number of years. Suggest that text is clarified. See above regarding if the soil is peat soils and its care.
* 8.35 - is it worth asking applicants to state how they have considered water and rail and road and thoroughly justify their chosen mode, rather than just encourage it?
* MW3, last bullet point - is that a travel plan? MW4 refers to travel plans.
* MW4 - is it better to just say 'greenhouse gas emissions'? Does using the term 'endeavour' reduce the strength of criterion c? d) just demonstrate or implement too?
* 12.4 says 'Given their nature, most waste management facilities will tend to be suitably located on previously developed land and industrial locations and it is not expected that there will be a great need to locate such uses on agricultural land' - not sure what this is saying - they tend to be located there or are suitable to be located there?
* Map 3 - see above comments - where are areas of 3a?
* Section 12 - no mention of peat soils and their qualities - see above.
* Page 41 onwards and then 64 onwards - formatting - should this have a section number - perhaps section 13? The bullet points are numbered differently to elsewhere in the Plan - WO rather than, say, 13.2 etc.
* WP4 - a) when compared to another option that takes longer?
* W7.1 - do you mean 2018?
* WP13 - so a, b, c are 'or' and d, e, f are 'and'. It might be easier to separate them out and say something like 'in all cases d, e, f will apply'.
* WP15 - first para seems reasoned justification rather than policy text. Suggest the Broad Authority be involved in the organisations listed in para 3 - the organisations in para 4 seem to be the ones that need to be involved in the Masterplan.
* WP17 and MP11 - on adoption, presume we will be sent these GIS layers to upload to our system?
* Page 71, and MP2 - that NPPF paragraph applies to the Broads too. We have a Major Development policy. Why is the AONB excluded and the Broads not? Or is it?
* Page 73, g - why not the undesignated heritage assets?
* MP2.14 - 'Developers wanting to [extraction] extract mineral from specific sites or land within an area of search allocated in the Minerals and Waste Local Plan Review will still need to apply for and be granted planning permission before mineral extraction can take place'.
* MP2 - why the 3mile/5 mile rule for minerals?
* MP4.1 and MP4 - how about if the reservoir is not associated with mineral abstraction?
* Page 76 - what is shown on this map? There is no key. If it is core river valleys, why are the rivers over in the Broads not blue?
* MP6 might make sense but the first part says acceptable, unacceptable and acceptable. A check might be needed.
* MP8.3 'The need for annual reports after the initial five-year period [for] will be assessed on a case by case basis'.
* M65.5 - starts off saying 'The site is not located within...'. Being within is one issue, but affecting the setting of is another. So such assessments should state whether the site is near to those designations. This should therefore correctly read that the site is near to the Broads.
* Page 181 onwards - Min 38 - Waveney Forest, Fritton - support not allocating this site.
* Min 65, Stanninghall Quarry - extension to existing minerals site. No landscape visual or character concerns with regards to the Broads itself.
* Min 25, we would definitely want to be consulted on any forthcoming planning applications on this site, particularly concerning landscape scheme and restoration as the landscape character areas in this locality are well defined and susceptible to change.
* Min 211, Restoration as wet grassland for biodiversity needs to be balanced with long-term effects on local landscape character. The local character and experience of the landscape varies between the north and south of the site and restoration should reflect this.
* Generally, an LVIA assesses the effects of a development (the impact) on the landscape as a resource and the effects on visual receptors. The assessment will cover both the site itself and a wider study area determined by desk study and ground-truthing. LVIA's should be carried out to a set standard (Guidelines for landscape and visual impact assessment, 3d edition - which I believe is part of the NCC validation checklist) so by definition will be required to include the site and any surrounding area that could be affected by the development; Existing: "Submission of a Landscape and Visual Impact Assessment which will identify any potential impacts to the wider landscape and suggest appropriate mitigation measures ..." Proposed: "Submission of a Landscape and Visual Impact Assessment which will identify any potential effects and suggest appropriate mitigation measures ..." This text is used across a number of the policies.

SA Part A Scoping
Page 31 needs a very big update.
* Core Strategy, DM and Sites not in place any more.
* Local Plan adopted May 2019.
* Flood Risk SPD - most recent is 2017
* Broads Plan is 2017
Seems relevant to refer to our dark skies data and policy

SA - Part B
4.5 - did you consider a zone from the Broads?


Please note: The Broads Authority has adopted a new Local Plan which can be found here. The policies in the Core Strategy, Development Management and Site Specific documents are all superseded and not in place anymore.