Minerals and Waste Local Plan Vision to 2038

Support

Representation ID: 99167

Received: 09/11/2022

Respondent: Essex County Council

Vision
The intention for Norfolk to be self-sufficient in sand and gravel production and waste management, where practicable, is supported. The continuing recognition that Norfolk is an important supplier at the national level of silica sand is also welcomed, as is the acknowledgement of the need to safeguard minerals and waste infrastructure. The inclusion of all developments providing biodiversity net gains is supported.

Object

Representation ID: 99336

Received: 18/12/2022

Respondent: Norfolk Wildlife Trust

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We support the requirement for progressive restoration schemes and the enhancement of Norfolk’s biodiversity but given the significant changes since the previous iteration of the plan in 2019 (changes to the National Planning Policy Framework, the passing of the Environment Act 2021 and the Leaders Pledge for Nature made at a virtual United Nations event in September 2020), there is a clear need for planning policy to not only encourage but ensure delivery of nature’s recovery.

Recent reporting from the COP27 and COP15 international summits on climate change and biodiversity, highlight the need for significant and urgent progress to be made in tackling the interlinked global crises of biodiversity loss and climate change.
We expect all Norfolk planning policy to make serious and effective contributions towards society’s goals of delivering a carbon neutral future and halting the ongoing decline of biodiversity, in line with legal requirements set out legislation such as the Climate Change Act and the Environment Act.
To bring greater certainty to the framing of the objectives and ensure that the plan not only supports meaningful change but requires it, we recommend the wording of the Vision is changed.

Comment

Representation ID: 99423

Received: 19/12/2022

Respondent: Natural England

Natural England commend the consideration of our comments during the initial consultation on the NMWLP in 2018, which has resulted in the removal of MIN 71 and MIN 204 as they are considered unsuitable due to the potential for adverse effects on designated sites.
Nature Recovery Network (NRN) and Local Nature Recovery Strategies (LNRSs)
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 welcome the reference to contributing, “to identified strategic green infrastructure corridors and known ecological networks,” made in Policy MP7. 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 in the Plan vision (pg. 19). 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.

Comment

Representation ID: 99509

Received: 15/12/2022

Respondent: Norfolk Gravel

Agent: David L Walker Ltd

Norfolk Gravel would support the Vision promoted by the council in section 4 of the document. However, the company would like to see emphasis placed on the value and significance of minerals and waste development in providing a diverse and affluent rural economy consistent with Paragraph 84 of the NPPF (2021).