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Comment

Initial Consultation document

Question 8: Policy MW5 'The Brecks protected habitats and species'

Representation ID: 92359

Received: 13/08/2018

Respondent: D K Symes Associates

Representation Summary:

It would be helpful to clarify that 'mineral extraction' (including associated plant) is not classed as 'built development' (so does not fall to be considered under Policy MW5).

Full text:

I set out below my comments on the above document based on the Questions. I have only commented on a limited number of questions.

Question 7
It is recognised that Policy MW4 relates to both minerals and waste. Regarding the use of renewable energy there is more potential for waste developments than for mineral. In practice, mineral developments have extremely limited opportunities to use 'site specific' renewable energy sources (e.g. solar, panels, wind turbines, gas generation, etc.) and this needs to be recognised. Further, the choice of energy provider may already have a percentage generated by renewable and this should be given weight in meeting this policy.

It is noted that the 'practicality' of meeting this element of the policy allows a degree of flexibility, however it would be helpful if the text could recognise that the opportunities for renewable are noticeably more constrained for mineral developments.

As a final note, Policy MW2 does not refer to demonstrating that 'renewable' energy use is a development management criteria, suggesting that Policy MW4 should have greater flexibility.

Question 8
It would be helpful to clarify that 'mineral extraction' (including associated plant) is not classed as 'built development' (so does not fall to be considered under Policy MW5).

Question 30
The encouragement for agricultural reservoirs is supported as this reflects the policy guidance from the EA. For clarity, it should be made clear that 'proven need' is for the reservoir, not the mineral extracted.

Question 75
Agree with initial conclusion.

Comment:
The recognition that this site when developed as an extension to Briton's Lane Quarry, will offer considerably improved restoration to create heathland habitat with a range of micro-scale biodiversity is supported. In addition, the development offers the opportunity to increase the geological interest by providing additional exposed sections of the Briton's Lane Formation.

The suggested requirement for the road junction with the A148 to be upgraded is noted. Advice from Highway Consultants is that the number of turning movements generated by the development is below the guidance level to justify a full right hand turn lane. However, site measurements of the road indicate that with limited widening sufficient additional 'road' width can be secured that will avoid through traffic being held up by the occasional turning lorry. This suggestion does not result in a 'full' standard right turn lane, but will achieve the same objective. It would be helpful if the comments were less specific by referring to road improvements at the A148 / Briton's Lane junction to allow some flexibility.

Question 76
The identification of MIN 71 is supported.

Question 78
The identification of MIN 207 is supported.

I trust these comments are of interest and I would be grateful for confirmation of receipt.

Comment

Initial Consultation document

Question 30 : Policy MP4 'agricultural or potable water reservoirs'

Representation ID: 92360

Received: 13/08/2018

Respondent: D K Symes Associates

Representation Summary:

The encouragement for agricultural reservoirs is supported as this reflects the policy guidance from the EA. For clarity, it should be made clear that 'proven need' is for the reservoir, not the mineral extracted.

Full text:

I set out below my comments on the above document based on the Questions. I have only commented on a limited number of questions.

Question 7
It is recognised that Policy MW4 relates to both minerals and waste. Regarding the use of renewable energy there is more potential for waste developments than for mineral. In practice, mineral developments have extremely limited opportunities to use 'site specific' renewable energy sources (e.g. solar, panels, wind turbines, gas generation, etc.) and this needs to be recognised. Further, the choice of energy provider may already have a percentage generated by renewable and this should be given weight in meeting this policy.

It is noted that the 'practicality' of meeting this element of the policy allows a degree of flexibility, however it would be helpful if the text could recognise that the opportunities for renewable are noticeably more constrained for mineral developments.

As a final note, Policy MW2 does not refer to demonstrating that 'renewable' energy use is a development management criteria, suggesting that Policy MW4 should have greater flexibility.

Question 8
It would be helpful to clarify that 'mineral extraction' (including associated plant) is not classed as 'built development' (so does not fall to be considered under Policy MW5).

Question 30
The encouragement for agricultural reservoirs is supported as this reflects the policy guidance from the EA. For clarity, it should be made clear that 'proven need' is for the reservoir, not the mineral extracted.

Question 75
Agree with initial conclusion.

Comment:
The recognition that this site when developed as an extension to Briton's Lane Quarry, will offer considerably improved restoration to create heathland habitat with a range of micro-scale biodiversity is supported. In addition, the development offers the opportunity to increase the geological interest by providing additional exposed sections of the Briton's Lane Formation.

The suggested requirement for the road junction with the A148 to be upgraded is noted. Advice from Highway Consultants is that the number of turning movements generated by the development is below the guidance level to justify a full right hand turn lane. However, site measurements of the road indicate that with limited widening sufficient additional 'road' width can be secured that will avoid through traffic being held up by the occasional turning lorry. This suggestion does not result in a 'full' standard right turn lane, but will achieve the same objective. It would be helpful if the comments were less specific by referring to road improvements at the A148 / Briton's Lane junction to allow some flexibility.

Question 76
The identification of MIN 71 is supported.

Question 78
The identification of MIN 207 is supported.

I trust these comments are of interest and I would be grateful for confirmation of receipt.

Support

Initial Consultation document

Question 78: Proposed site MIN 207

Representation ID: 92361

Received: 13/08/2018

Respondent: D K Symes Associates

Representation Summary:

The identification of MIN 207 is supported.

Full text:

I set out below my comments on the above document based on the Questions. I have only commented on a limited number of questions.

Question 7
It is recognised that Policy MW4 relates to both minerals and waste. Regarding the use of renewable energy there is more potential for waste developments than for mineral. In practice, mineral developments have extremely limited opportunities to use 'site specific' renewable energy sources (e.g. solar, panels, wind turbines, gas generation, etc.) and this needs to be recognised. Further, the choice of energy provider may already have a percentage generated by renewable and this should be given weight in meeting this policy.

It is noted that the 'practicality' of meeting this element of the policy allows a degree of flexibility, however it would be helpful if the text could recognise that the opportunities for renewable are noticeably more constrained for mineral developments.

As a final note, Policy MW2 does not refer to demonstrating that 'renewable' energy use is a development management criteria, suggesting that Policy MW4 should have greater flexibility.

Question 8
It would be helpful to clarify that 'mineral extraction' (including associated plant) is not classed as 'built development' (so does not fall to be considered under Policy MW5).

Question 30
The encouragement for agricultural reservoirs is supported as this reflects the policy guidance from the EA. For clarity, it should be made clear that 'proven need' is for the reservoir, not the mineral extracted.

Question 75
Agree with initial conclusion.

Comment:
The recognition that this site when developed as an extension to Briton's Lane Quarry, will offer considerably improved restoration to create heathland habitat with a range of micro-scale biodiversity is supported. In addition, the development offers the opportunity to increase the geological interest by providing additional exposed sections of the Briton's Lane Formation.

The suggested requirement for the road junction with the A148 to be upgraded is noted. Advice from Highway Consultants is that the number of turning movements generated by the development is below the guidance level to justify a full right hand turn lane. However, site measurements of the road indicate that with limited widening sufficient additional 'road' width can be secured that will avoid through traffic being held up by the occasional turning lorry. This suggestion does not result in a 'full' standard right turn lane, but will achieve the same objective. It would be helpful if the comments were less specific by referring to road improvements at the A148 / Briton's Lane junction to allow some flexibility.

Question 76
The identification of MIN 71 is supported.

Question 78
The identification of MIN 207 is supported.

I trust these comments are of interest and I would be grateful for confirmation of receipt.

Support

Initial Consultation document

Question 76: Proposed site MIN 71

Representation ID: 92362

Received: 13/08/2018

Respondent: D K Symes Associates

Representation Summary:

The identification of MIN 71 is supported.

Full text:

I set out below my comments on the above document based on the Questions. I have only commented on a limited number of questions.

Question 7
It is recognised that Policy MW4 relates to both minerals and waste. Regarding the use of renewable energy there is more potential for waste developments than for mineral. In practice, mineral developments have extremely limited opportunities to use 'site specific' renewable energy sources (e.g. solar, panels, wind turbines, gas generation, etc.) and this needs to be recognised. Further, the choice of energy provider may already have a percentage generated by renewable and this should be given weight in meeting this policy.

It is noted that the 'practicality' of meeting this element of the policy allows a degree of flexibility, however it would be helpful if the text could recognise that the opportunities for renewable are noticeably more constrained for mineral developments.

As a final note, Policy MW2 does not refer to demonstrating that 'renewable' energy use is a development management criteria, suggesting that Policy MW4 should have greater flexibility.

Question 8
It would be helpful to clarify that 'mineral extraction' (including associated plant) is not classed as 'built development' (so does not fall to be considered under Policy MW5).

Question 30
The encouragement for agricultural reservoirs is supported as this reflects the policy guidance from the EA. For clarity, it should be made clear that 'proven need' is for the reservoir, not the mineral extracted.

Question 75
Agree with initial conclusion.

Comment:
The recognition that this site when developed as an extension to Briton's Lane Quarry, will offer considerably improved restoration to create heathland habitat with a range of micro-scale biodiversity is supported. In addition, the development offers the opportunity to increase the geological interest by providing additional exposed sections of the Briton's Lane Formation.

The suggested requirement for the road junction with the A148 to be upgraded is noted. Advice from Highway Consultants is that the number of turning movements generated by the development is below the guidance level to justify a full right hand turn lane. However, site measurements of the road indicate that with limited widening sufficient additional 'road' width can be secured that will avoid through traffic being held up by the occasional turning lorry. This suggestion does not result in a 'full' standard right turn lane, but will achieve the same objective. It would be helpful if the comments were less specific by referring to road improvements at the A148 / Briton's Lane junction to allow some flexibility.

Question 76
The identification of MIN 71 is supported.

Question 78
The identification of MIN 207 is supported.

I trust these comments are of interest and I would be grateful for confirmation of receipt.

Comment

Initial Consultation document

Question 75: Proposed site MIN 69

Representation ID: 92363

Received: 13/08/2018

Respondent: D K Symes Associates

Representation Summary:

Agree with initial conclusion.

Comment:
The recognition that this site when developed as an extension to Briton's Lane Quarry, will offer considerably improved restoration to create heathland habitat with a range of micro-scale biodiversity is supported. In addition, the development offers the opportunity to increase the geological interest by providing additional exposed sections of the Briton's Lane Formation.

The suggested requirement for the road junction with the A148 to be upgraded is noted. Advice from Highway Consultants is that the number of turning movements generated by the development is below the guidance level to justify a full right hand turn lane. However, site measurements of the road indicate that with limited widening sufficient additional 'road' width can be secured that will avoid through traffic being held up by the occasional turning lorry. This suggestion does not result in a 'full' standard right turn lane, but will achieve the same objective. It would be helpful if the comments were less specific by referring to road improvements at the A148 / Briton's Lane junction to allow some flexibility.

Full text:

I set out below my comments on the above document based on the Questions. I have only commented on a limited number of questions.

Question 7
It is recognised that Policy MW4 relates to both minerals and waste. Regarding the use of renewable energy there is more potential for waste developments than for mineral. In practice, mineral developments have extremely limited opportunities to use 'site specific' renewable energy sources (e.g. solar, panels, wind turbines, gas generation, etc.) and this needs to be recognised. Further, the choice of energy provider may already have a percentage generated by renewable and this should be given weight in meeting this policy.

It is noted that the 'practicality' of meeting this element of the policy allows a degree of flexibility, however it would be helpful if the text could recognise that the opportunities for renewable are noticeably more constrained for mineral developments.

As a final note, Policy MW2 does not refer to demonstrating that 'renewable' energy use is a development management criteria, suggesting that Policy MW4 should have greater flexibility.

Question 8
It would be helpful to clarify that 'mineral extraction' (including associated plant) is not classed as 'built development' (so does not fall to be considered under Policy MW5).

Question 30
The encouragement for agricultural reservoirs is supported as this reflects the policy guidance from the EA. For clarity, it should be made clear that 'proven need' is for the reservoir, not the mineral extracted.

Question 75
Agree with initial conclusion.

Comment:
The recognition that this site when developed as an extension to Briton's Lane Quarry, will offer considerably improved restoration to create heathland habitat with a range of micro-scale biodiversity is supported. In addition, the development offers the opportunity to increase the geological interest by providing additional exposed sections of the Briton's Lane Formation.

The suggested requirement for the road junction with the A148 to be upgraded is noted. Advice from Highway Consultants is that the number of turning movements generated by the development is below the guidance level to justify a full right hand turn lane. However, site measurements of the road indicate that with limited widening sufficient additional 'road' width can be secured that will avoid through traffic being held up by the occasional turning lorry. This suggestion does not result in a 'full' standard right turn lane, but will achieve the same objective. It would be helpful if the comments were less specific by referring to road improvements at the A148 / Briton's Lane junction to allow some flexibility.

Question 76
The identification of MIN 71 is supported.

Question 78
The identification of MIN 207 is supported.

I trust these comments are of interest and I would be grateful for confirmation of receipt.

Comment

Initial Consultation document

Question 7: Policy MW4 'Climate change mitigation and adaption'

Representation ID: 92364

Received: 13/08/2018

Respondent: D K Symes Associates

Representation Summary:

It is recognised that Policy MW4 relates to both minerals and waste. Regarding the use of renewable energy there is more potential for waste developments than for mineral. In practice, mineral developments have extremely limited opportunities to use 'site specific' renewable energy sources (e.g. solar, panels, wind turbines, gas generation, etc.) and this needs to be recognised. Further, the choice of energy provider may already have a percentage generated by renewable and this should be given weight in meeting this policy.

It is noted that the 'practicality' of meeting this element of the policy allows a degree of flexibility, however it would be helpful if the text could recognise that the opportunities for renewable are noticeably more constrained for mineral developments.

As a final note, Policy MW2 does not refer to demonstrating that 'renewable' energy use is a development management criteria, suggesting that Policy MW4 should have greater flexibility.

Full text:

I set out below my comments on the above document based on the Questions. I have only commented on a limited number of questions.

Question 7
It is recognised that Policy MW4 relates to both minerals and waste. Regarding the use of renewable energy there is more potential for waste developments than for mineral. In practice, mineral developments have extremely limited opportunities to use 'site specific' renewable energy sources (e.g. solar, panels, wind turbines, gas generation, etc.) and this needs to be recognised. Further, the choice of energy provider may already have a percentage generated by renewable and this should be given weight in meeting this policy.

It is noted that the 'practicality' of meeting this element of the policy allows a degree of flexibility, however it would be helpful if the text could recognise that the opportunities for renewable are noticeably more constrained for mineral developments.

As a final note, Policy MW2 does not refer to demonstrating that 'renewable' energy use is a development management criteria, suggesting that Policy MW4 should have greater flexibility.

Question 8
It would be helpful to clarify that 'mineral extraction' (including associated plant) is not classed as 'built development' (so does not fall to be considered under Policy MW5).

Question 30
The encouragement for agricultural reservoirs is supported as this reflects the policy guidance from the EA. For clarity, it should be made clear that 'proven need' is for the reservoir, not the mineral extracted.

Question 75
Agree with initial conclusion.

Comment:
The recognition that this site when developed as an extension to Briton's Lane Quarry, will offer considerably improved restoration to create heathland habitat with a range of micro-scale biodiversity is supported. In addition, the development offers the opportunity to increase the geological interest by providing additional exposed sections of the Briton's Lane Formation.

The suggested requirement for the road junction with the A148 to be upgraded is noted. Advice from Highway Consultants is that the number of turning movements generated by the development is below the guidance level to justify a full right hand turn lane. However, site measurements of the road indicate that with limited widening sufficient additional 'road' width can be secured that will avoid through traffic being held up by the occasional turning lorry. This suggestion does not result in a 'full' standard right turn lane, but will achieve the same objective. It would be helpful if the comments were less specific by referring to road improvements at the A148 / Briton's Lane junction to allow some flexibility.

Question 76
The identification of MIN 71 is supported.

Question 78
The identification of MIN 207 is supported.

I trust these comments are of interest and I would be grateful for confirmation of receipt.

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