Initial Consultation document

Sirs, on behalf of Tarmac Trading Ltd we make the following comments on the content of the Norfolk Minerals and Waste Local Plan Review 'Initial Consultation May 2018':
(i) Q54. We are pleased to note the appraisal of Site 'MIN 65: Land north of Stanninghall Quarry' and the initial conclusion that the site is suitable for allocation for sand and gravel extraction. We also note the requirements relating to the issues which a planning application for extraction at the site would need to address, and we are confident that at the detailed planning application / EIA stage each of the issues could be addressed in a way which would satisfactorily mitigate effects on the respective interests.
The one note of concern is the suggestion that the site would need to be phased with other sites in the area so that only one site is worked at any one time. In terms of the Stanninghall development, the northern extension area would be phased as part of a comprehensive working and restoration scheme for the existing quarry and extension area, and the timescale for the operation in the extension area would need to reflect the progress of extraction and restoration within the existing quarry and any re-phasing which may be proposed. Any cumulative effects of extraction at Stanninghall with other sites in the locality would be a matter for consideration as part of an EIA (as it was a the time of the original Stanninghall application and inquiry), and this will be an issue which will need to be considered on its merits at the time. The Authority will appreciate that Tarmac has no control over the timing of other developments in the area undertaken by third parties, and there should thus be no planning policy restrictions regarding the timing of the development: this will be a matter for consideration at the application stage. It is also noted that this phasing / timing requirement does not feature in the application requirements for the nearest other potential allocation (MIN 64 Grange Farm Horstead).
(ii) Q27. Tarmac supports the approach of seeking to allocate sites to deliver at least an additional 23m tonnes of sand and gravel over the plan period (ref calculation in the table on page 30). This will make the plan more robust than an alternative approach of using a 10 year average for sales over the last10 years, since this coincided with a recession in the aggregates industry (and economy in general) which supressed sales to historically low levels. (It should also be noted that there appears to be an error in the 'alternative table' on page 64 where the figures for reserves and shortfall seem to be been transposed).
(iii) Q27. Notwithstanding this support for the resource calculation approach in Policy MP1, Tarmac objects to the indication that the sand and gravel landbank will be maintained at "between 7 years and 10 years supply". NPPF (July 2018) and the predecessor version of NPPF 2012 is clear in requiring the maintenance of sand and gravel landbanks of "at least 7 years" with no upper limit on the landbank. This is re-enforced in Planning Practice Guidance which confirms that "there is no maximum landbank level and each application must be considered on its own merits regardless of the length of the landbank" (ref ID27-084). The suggested wording of policy MP1 is contrary to NPPF and the plan would not be 'sound' based upon such a policy wording. In practical terms, strict adherence to the policy as worded would mean that an otherwise acceptable development could be refused if the landbank, at an arbitrary date of determination, was just above 10 years. This would be unreasonable. Policy MP1 should be revised to simply confirm a commitment to maintain a sand and gravel landbank of "at least 7 years", consistent with the requirements of NPPF.
We hope that these comments will be regarded in the constructive way in which they are intended and we look forward to participating in future stages of the plan making process. In that respect, I would be grateful if you could add me (SLR) to your database of interested parties to be notified of future consultation stages.
I would also be grateful if you could acknowledge receipt of these comments.

Sirs, on behalf of Tarmac Trading Ltd we make the following comments on the content of the Norfolk Minerals and Waste Local Plan Review 'Initial Consultation May 2018':
(i) Q54. We are pleased to note the appraisal of Site 'MIN 65: Land north of Stanninghall Quarry' and the initial conclusion that the site is suitable for allocation for sand and gravel extraction. We also note the requirements relating to the issues which a planning application for extraction at the site would need to address, and we are confident that at the detailed planning application / EIA stage each of the issues could be addressed in a way which would satisfactorily mitigate effects on the respective interests.
The one note of concern is the suggestion that the site would need to be phased with other sites in the area so that only one site is worked at any one time. In terms of the Stanninghall development, the northern extension area would be phased as part of a comprehensive working and restoration scheme for the existing quarry and extension area, and the timescale for the operation in the extension area would need to reflect the progress of extraction and restoration within the existing quarry and any re-phasing which may be proposed. Any cumulative effects of extraction at Stanninghall with other sites in the locality would be a matter for consideration as part of an EIA (as it was a the time of the original Stanninghall application and inquiry), and this will be an issue which will need to be considered on its merits at the time. The Authority will appreciate that Tarmac has no control over the timing of other developments in the area undertaken by third parties, and there should thus be no planning policy restrictions regarding the timing of the development: this will be a matter for consideration at the application stage. It is also noted that this phasing / timing requirement does not feature in the application requirements for the nearest other potential allocation (MIN 64 Grange Farm Horstead).
(ii) Q27. Tarmac supports the approach of seeking to allocate sites to deliver at least an additional 23m tonnes of sand and gravel over the plan period (ref calculation in the table on page 30). This will make the plan more robust than an alternative approach of using a 10 year average for sales over the last10 years, since this coincided with a recession in the aggregates industry (and economy in general) which supressed sales to historically low levels. (It should also be noted that there appears to be an error in the 'alternative table' on page 64 where the figures for reserves and shortfall seem to be been transposed).
(iii) Q27. Notwithstanding this support for the resource calculation approach in Policy MP1, Tarmac objects to the indication that the sand and gravel landbank will be maintained at "between 7 years and 10 years supply". NPPF (July 2018) and the predecessor version of NPPF 2012 is clear in requiring the maintenance of sand and gravel landbanks of "at least 7 years" with no upper limit on the landbank. This is re-enforced in Planning Practice Guidance which confirms that "there is no maximum landbank level and each application must be considered on its own merits regardless of the length of the landbank" (ref ID27-084). The suggested wording of policy MP1 is contrary to NPPF and the plan would not be 'sound' based upon such a policy wording. In practical terms, strict adherence to the policy as worded would mean that an otherwise acceptable development could be refused if the landbank, at an arbitrary date of determination, was just above 10 years. This would be unreasonable. Policy MP1 should be revised to simply confirm a commitment to maintain a sand and gravel landbank of "at least 7 years", consistent with the requirements of NPPF.
We hope that these comments will be regarded in the constructive way in which they are intended and we look forward to participating in future stages of the plan making process. In that respect, I would be grateful if you could add me (SLR) to your database of interested parties to be notified of future consultation stages.
I would also be grateful if you could acknowledge receipt of these comments.

Sirs, on behalf of Tarmac Trading Ltd we make the following comments on the content of the Norfolk Minerals and Waste Local Plan Review 'Initial Consultation May 2018':
(i) Q54. We are pleased to note the appraisal of Site 'MIN 65: Land north of Stanninghall Quarry' and the initial conclusion that the site is suitable for allocation for sand and gravel extraction. We also note the requirements relating to the issues which a planning application for extraction at the site would need to address, and we are confident that at the detailed planning application / EIA stage each of the issues could be addressed in a way which would satisfactorily mitigate effects on the respective interests.
The one note of concern is the suggestion that the site would need to be phased with other sites in the area so that only one site is worked at any one time. In terms of the Stanninghall development, the northern extension area would be phased as part of a comprehensive working and restoration scheme for the existing quarry and extension area, and the timescale for the operation in the extension area would need to reflect the progress of extraction and restoration within the existing quarry and any re-phasing which may be proposed. Any cumulative effects of extraction at Stanninghall with other sites in the locality would be a matter for consideration as part of an EIA (as it was a the time of the original Stanninghall application and inquiry), and this will be an issue which will need to be considered on its merits at the time. The Authority will appreciate that Tarmac has no control over the timing of other developments in the area undertaken by third parties, and there should thus be no planning policy restrictions regarding the timing of the development: this will be a matter for consideration at the application stage. It is also noted that this phasing / timing requirement does not feature in the application requirements for the nearest other potential allocation (MIN 64 Grange Farm Horstead).
(ii) Q27. Tarmac supports the approach of seeking to allocate sites to deliver at least an additional 23m tonnes of sand and gravel over the plan period (ref calculation in the table on page 30). This will make the plan more robust than an alternative approach of using a 10 year average for sales over the last10 years, since this coincided with a recession in the aggregates industry (and economy in general) which supressed sales to historically low levels. (It should also be noted that there appears to be an error in the 'alternative table' on page 64 where the figures for reserves and shortfall seem to be been transposed).
(iii) Q27. Notwithstanding this support for the resource calculation approach in Policy MP1, Tarmac objects to the indication that the sand and gravel landbank will be maintained at "between 7 years and 10 years supply". NPPF (July 2018) and the predecessor version of NPPF 2012 is clear in requiring the maintenance of sand and gravel landbanks of "at least 7 years" with no upper limit on the landbank. This is re-enforced in Planning Practice Guidance which confirms that "there is no maximum landbank level and each application must be considered on its own merits regardless of the length of the landbank" (ref ID27-084). The suggested wording of policy MP1 is contrary to NPPF and the plan would not be 'sound' based upon such a policy wording. In practical terms, strict adherence to the policy as worded would mean that an otherwise acceptable development could be refused if the landbank, at an arbitrary date of determination, was just above 10 years. This would be unreasonable. Policy MP1 should be revised to simply confirm a commitment to maintain a sand and gravel landbank of "at least 7 years", consistent with the requirements of NPPF.
We hope that these comments will be regarded in the constructive way in which they are intended and we look forward to participating in future stages of the plan making process. In that respect, I would be grateful if you could add me (SLR) to your database of interested parties to be notified of future consultation stages.
I would also be grateful if you could acknowledge receipt of these comments.