Policy WP3: Land suitable for waste management facilities – STRATEGIC POLICY
Object
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99080
Received: 06/10/2022
Respondent: Middleton Aggregates Ltd
Agent: Stephen M Daw Limited
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The use of the term, 'at existing sand and gravel workings' has in the past been overinterpreted to mean within the active working area rather than 'at' a quarry. Siting of inert recycling facilities in such a way is unnecessarily restrictive and can prove problematical as the working area is by definition busy, constantly moving and can lead to contamination (of mineral) issues.
Clarification is required, so that the policy cannot interpreted in an overly restrictive manner, thus allowing recycling facilities to be positioned elsewhere at a quarry and for example on previously worked land or on land adjoining a quarry, provided all other criteria are met. Similar clarification is required to identical wording used in Policy WP4.
Object
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99274
Received: 14/12/2022
Respondent: Anglian Water
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Local Plan is unsound because Policy WP3 is not positively prepared in terms of achieving sustainable development or justified given reasonable alternatives.
We would welcome modifications to the policy and supporting text.
Reference is made to waste management facilities on water recycling centres being limited to composting and anaerobic digestion. In our representation to the Preferred Options Consultation, we indicated that Anglian Water as sewerage undertaker is concerned that this is not justified in that there may be other waste management uses which would be suitable at water recycling centres, dependent upon both scale and location. The policy as currently drafted stifles innovations coming forward in the field of bio-resources. Therefore, the policy should be flexible to ensure that future sustainable options for bio-resources are considered - particularly in the context of addressing climate change mitigation and nutrient neutrality.
We consider that the development management criteria in Policy MW1 should be appropriate to ensure that suitable waste management facilities are considered at water recycling centres, and the specific types of facilities do not need to be specified.
We would therefore welcome modifications to Policy WP3 to allow for other waste management uses at water recycling centres associated with ambitions for the long-term sustainable management and operation of our facilities. Amending the policy would support the delivery of lower carbon solutions and so assist in the pathway to net zero for the sector in Norfolk.
g) water recycling centres [delete: (composting and anaerobic digestion only)];
g) water recycling centres [delete: (composting and anaerobic digestion only)];
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99450
Received: 19/12/2022
Respondent: Breckland District Council
Consideration of the impact of open air composting on air and water quality for habitat sites.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99494
Received: 19/12/2022
Respondent: Broadland District Council
Note amendment to include ‘redundant’ so that criteria d) reads: ‘land within or adjacent to redundant agricultural and forestry buildings’. Whilst this differs from the Councils suggestion, this is considered acceptable.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99517
Received: 19/12/2022
Respondent: South Norfolk District Council
Note amendment to include ‘redundant’ so that criteria d) reads: land within or adjacent to redundant agricultural and forestry buildings. Whilst this differs from the Councils suggestion, this is considered acceptable.