MP2.11

Showing comments and forms 1 to 1 of 1

Object

Minerals and Waste Local Plan: Pre-Submission Publication

Representation ID: 99539

Received: 16/12/2022

Respondent: Dr L David Ormerod

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

These comments are limited to the Single-issue Silica Sand Site Selection process. It is of considerable concern when the NMW Local Plan policies accommodate a clear avoidance of the public interest.

NPPF paragraphs 98 and 99 are quoted.
As the recreational jewel of West Norfolk within a badly scarred regional environment with a local road system unsuitable for recreational pursuits, and where no realistic alternatives exist, it is surprising that the proposition of AOS E as a silica sand extraction candidate survived for so long. I believe that the Shouldham Warren should have been declared off-limits to all development. including mineral developments, as it provides an absolutely unique and traditional environment for West Norfolk country recreation.

1.The initial task is to convince N.C.C. that public land-use issues must always be respected in silica sand extraction site negotiations in particular, and in mineral and waste site negotiations in general. It is the law. How can the public interest be totally disregarded in a major Local Plan? This fails to pass the notions of "legal compliance" and of administrative "soundness."

2. The main problem with public representation involves the failure to recognize the long-term public recreational land-use interest in Shouldham Warren, part of AOS E.
The added comments principally seek to correct unnecessary weaknesses in the rule making regarding silica sand extraction site selection for public rural recreation areas such as Shouldham Warren and West Bilney Wood.

Soundness tests: Not effective, not positively prepared, not consistent with national policy.

Change suggested by respondent:

22. Under Policy MP2.11, suggest removal of the word "ancient" from the word "woodland; in concurrence with the decision of Cabinet relayed in the meeting report dated December 10, 2019. A definition of a minimal size of woodland would likely be necessitated, e.g. in MP2.11(b). I suggest it would be appropriate to add the phrase, "and well-used open-access Forestry Commission land." for purposes of clarity.