Minerals and Waste Local Plan Vision to 2038
Support
Minerals and Waste Local Plan: Pre-Submission Publication
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
Minerals and Waste Local Plan: Pre-Submission Publication
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.
Where the plan states ‘Mineral development and waste management facilities will be located, designed and operated without unacceptable adverse impacts on the amenity of local communities, the natural, built and historic environment, the landscape and townscape of Norfolk. Opportunities to enhance such features will be supported and all developments will provide biodiversity net gains.’ In order to bring greater certainty to the framing of the objectives, we recommend the wording of the final sentence is changed to read ‘Opportunities to enhance such features will be supported and all development will provide measurable biodiversity net gains’.
We recommend that in order to help frame and support plan objectives and policies that actively deliver the necessary outcomes, that the wording of this final paragraph of the Vision is modified as follows:
‘Minerals development and waste management within Norfolk will be undertaken in ways that ensure that all development consented under its policies contributes to carbon neutrality and avoids development which results in a net carbon burden to society as it progresses towards the 2050 net zero legal targets. It will also be designed and located to ensure that all opportunities to avoid, reduce and mitigate climate change contributions, and maximise adaptation measures to climatic effects, such as flooding are taken in site allocation and design’.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
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.
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). 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.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
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).