4.3 Minerals Strategic Objectives

Comment

Representation ID: 99222

Received: 14/12/2022

Respondent: Historic England

Map 1 Key Diagram
We note that the map includes lots of different designations but no heritage designations. Whilst we appreciate that putting individual listed buildings on such a map of this scale would be difficult, area-based designations e.g. Conservation Areas, Registered Parks and Gardens and scheduled monuments could be included and would help to identify a wider range of environmental factors.

Object

Representation ID: 99289

Received: 15/12/2022

Respondent: Breedon Trading Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

To fully reflect guidance provided by NPPF paragraph MSO1 should refer to the need to provide a steady and adequate supply of aggregate minerals for at least a seven year landbank.

Comment

Representation ID: 99290

Received: 14/12/2022

Respondent: Mineral Products Association

Mineral Strategic Objective
The following adjustments are suggested to objectives MSO1 and MSO2 to make them to properly reflect NPPF;

Comment

Representation ID: 99303

Received: 16/12/2022

Respondent: Norwich City Council

Whilst Norwich City Council has no objection to objective MS05 or policy MP10, for the avoidance of doubt 'agent of change' should be defined.

Soundness test: Not Justified

Comment

Representation ID: 99306

Received: 15/12/2022

Respondent: Norfolk Gravel

Agent: David L Walker Ltd

In relation to the Minerals Objectives, whilst Norfolk Gravel recognise that the council have an objective to provide a steady and adequate supply, it is considered that this needs to also include the actual commitment (i.e requirement to maintain relevant landbanks).

Comment

Representation ID: 99424

Received: 19/12/2022

Respondent: Natural England

Natural England welcome the Plan’s emphasis on ensuring Biodiversity Net Gain (BNG) is achieved, enhancing the green infrastructure network, and taking a positive approach to mitigate and adapt to climate change. There is also a clear emphasis on ensuring high quality restoration and after-use of sites to protect Best and Most Versatile (BMV) Agricultural Land and to enhance Norfolk’s biodiversity and protect its landscapes. However, we advise that there is scope for the Plan to be more ambitious in its delivery of some of these policies and objectives.
Natural England commends the NMWLP for acknowledging the potential that restoration and after-use of mineral workings has for the benefit of enhancing landscape, geodiversity and biodiversity. We would advise that reference to the Nature Recovery Network [https://www.gov.uk/government/publications/nature-recovery-network/nature-recovery-network] is also included within Minerals Strategic Objective MS09 (pg. 21). The NRN is a commitment in the government’s 25 Year Environment Plan and enacted by the Environment Act 2021. Natural England is working with partners on NRN and the development of LNRSs [https://consult.defra.gov.uk/land-use/local-nature-recovery-strategies/] . The NRN is used to refer to a single, growing national network of improved joined-up, wildlife rich places which will benefit people and wildlife. LNRSs will be the key mechanism for planning and mapping local delivery of the NRN.
LNRSs will form a new system of spatial strategies for nature that will be mandated by the Environment Act. They will cover the whole of England and will be developed by Responsible Authorities (RAs) appointed by the Secretary of State, usually at a county scale. Each strategy will:
• Map the most valuable existing habitat for nature
• Map specific proposals for creating or improving habitat for nature and wider environment goals
• Agree priorities for nature’s recovery
LNRSs have also been designed to help local planning authorities deliver existing policy on conserving and enhancing biodiversity and to reflect this in the land use plans for their area.

Biodiversity Net Gain (BNG)
In line with paragraph 174(d) of the NPPF, reference to providing BNG is made throughout the NMWLP, which Natural England commends. BNG will be an important tool in securing investment for nature recovery through the planning system, helping deliver the government’s commitment to create a national NRN. However, we advise strengthening this wording by stating the minimum BNG uplift required to be delivered. With regards the upcoming mandatory requirement for a minimum of 10% BNG, we advise that you consider BNG delivery above this level, for example at 15% or 20% BNG. Strategic level viability assessments in Kent have concluded that this shift will not impact viability in most cases irrespective of onsite or offsite BNG delivery. This is because after the initial cost of securing the minimum 10% BNG, the cost of increase to 15 or 20% is much less and generally negligible. Natural England’s Biodiversity Metric 3.1 may be used to calculate biodiversity losses and gains for terrestrial and intertidal habitats and can be used to inform any development project.
It is the government’s intention that mandatory BNG will provide a financial incentive for development to support the delivery of LNRSs through an uplift in the calculation of biodiversity units created at sites identified by the strategy through the Biodiversity Metric ‘strategic significance’ scoring.