Policy WP2: Spatial Strategy for waste management facilities – STRATEGIC POLICY
Object
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99117
Received: 11/11/2022
Respondent: Broads Authority
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
This policy says ‘New or enhanced waste management facilities should be located within five miles of one of Norfolk’s urban areas or three miles of one of the main towns and be accessible via appropriate transport infrastructure, subject to the proposed development not being located within: the Broads Authority Executive Area or the Norfolk Coast Area of Outstanding Natural Beauty, other than in exceptional circumstances and where it can be demonstrated that the development is in the public interest’.
Elsewhere, throughout the document, the stance is no minerals and waste sites within the Broads, yet this policy says they could be.
A look at the maps suggests that there are no settlements that need a facility within the AONB or Executive Area to achieve the 3 miles/5 miles criteria; as such, why is this criterion needed?
Soundness test: Not effective
If this part of the policy is to be kept in, we request there is reference to the need for close working with the Broads Authority.
We also request that any proposals would need to demonstrate no alternative sites are available.
You could amend bullet point 1 as follows:
the Broads Authority Executive Area or the Norfolk Coast Area of Outstanding Natural Beauty, other than in exceptional circumstances and where it can be demonstrated that the development is in the public interest. Any proposals in these areas would need to also demonstrate that no alternative sites outside of these areas are available. Scheme promoters will be required to work closely with the Broads Authority and AONB.
Object
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99205
Received: 01/12/2022
Respondent: Pauline Davies
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Given the existential threat to properties in West Norfolk, it surely is appropriate to locate future waste management locations beyond flooding-prone areas, which may be beyond the 3–5-mile guideline.
Object
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99226
Received: 14/12/2022
Respondent: Historic England
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We have raised concerns about the wording in relation to harm to the historic environment in policy WP2.
In order to make this policy consistent with the NPPF and effective in securing sustainable development, we suggest that the policy wording is amended.
We welcome the addition of designated heritage assets as a bullet point in this policy. Conservation Areas should also be added to this list as they are designated heritage assets.
Substantial harm is a very high bar. Less than substantial harm is still harm and harm should be avoided in the first instance. We suggest that you reword this bullet point to delete the word substantial and add reference to significance and setting.
The bullet point would then read:
• a designated heritage asset, including listed buildings, registered parks and gardens, [insert: 'conservation areas'] and scheduled monuments, or their settings if the proposed development would cause [delete: substantial] harm to [delete: or] the [delete: loss] [insert: 'significance'] of the heritage asset [insert: '(including any contribution to significance by setting)'].
Amend text to read;
a designated heritage asset, including listed buildings, registered parks and gardens, [insert: 'conservation areas'] and scheduled monuments, or their settings if the proposed development would cause [delete: substantial] harm to [delete: or] the [delete: loss] [insert: 'significance'] of the heritage asset [insert: '(including any contribution to significance by setting)'].
Support
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99273
Received: 14/12/2022
Respondent: Anglian Water
Anglian Water is supportive of the policy and welcomes the amendments following our previous representation, to ensure that it is consistent with the National Planning Policy Framework and planning practice guidance in terms of the specific locational needs for water recycling centres.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99448
Received: 19/12/2022
Respondent: Breckland District Council
Nutrient Neutrality
In March 2022, Norfolk LPAs were alerted to the issue of the “unfavourable condition” of the River Wensum and Broads SAC leading to a requirement to mitigate nutrient pollution from development, farming and to upgrade wastewater treatment works. Nitrogen and Phosphorus affects both water and air quality and Breckland District Council considers that the location of waste facilities particularly from agricultural waste and composting and its impact on the River Wensum and Broads SAC should be carefully considered.
Consider the impact of increase Nitrogen and Phosphorus Pollution from organic waste (development, agriculture) on nitrogen and phosphorus sensitive zones (i.e. where the river catchment is deemed to be in “unfavourable condition” with regards the spatial strategy for waste management facilities.
The location of agricultural waste treatment, windrow composting and community composting to nutrient sensitive river catchment areas.