Preferred Options consultation document

Comments on the Norfolk Minerals and Waste Plan - Preferred Options, July 2019

MJCA are instructed by FH Ventures Norfolk Ltd to review the Norfolk Minerals and Waste Local Plan - Preferred Options document, July 2019 and prepare a response with comments on policies in the plan relevant to waste management and the site at Harling Road, Snetterton (an allocated site in the Adopted Norfolk Waste Site Specific Allocations Development Plan Document 2013 (DPD, 2013)).

The site at Harling Road, Snetterton is part of a former mineral working including the road frontage which is occupied by the site access road and a ready mix cement plant. To the south and adjacent to the former mineral working is a closed, restored landfill site, substation and recycling centre. A copy of the plan showing the site is attached for your information. The former mineral working and the closed, restored landfill are under separate ownership. In this document reference to the site is to the former mineral working and the road frontage.

As part of the work to assess the relevant Preferred Options Policy the planning status of the site has been reviewed and information on the current status regarding the adjacent closed, restored landfill site has been discussed with Norfolk County Council. The approved restoration scheme is for a single landform with a domed profile over the landfill and the former mineral extraction site. It is concluded that based on the dual ownership status, together with the presence of the closed landfill to the south of the site at which leachate and landfill gas generated is actively managed it is highly unlikely that the approved restoration scheme for the site will be achieved this is in particular as the sites are owned separately and any restoration scheme covering both sites in a single domed profile would include filling of a boundary wedge which would extend into both sites. It is also highly unlikely that it would be viable to raise the ground levels at the site to the domed shape in the approved profile with wastes that needed to be deposited in engineered containment cells due to the limited waste void that would be generated. It is considered that the site is suitable for the base to be raised with suitable compacted inert material if a larger footprint is needed for waste treatment and storage. The landowner acknowledges that the site can be returned to a beneficial use and that there is a need to bring forward a plan which addresses the long term use of the site compatible with its setting.

The Company are considering development options for the site such as waste treatment and storage and as part of any planning application will amend the consented restoration scheme for the former mineral extraction site which as stated above cannot be achieved.

Comments on specific policies

Policy WP1 Waste management capacity to be provided
The Policy provides indicative arising forecasts for waste types during the plan period up to 2036. It should be acknowledged that a strategic policy relating to waste management capacity may need to be updated over time as forecasts for the quantities of waste generated change and sites included in the capacity assessment close, or are not brought forward. The policy does acknowledge that new facilities or changes to existing facilities which help achieve the targets for recycling, composting, reuse and recovery set out in the Waste Management Plan for England (2013) will be encouraged. The wording of Policy WP1 should be changed to remove reference to sufficient capacity exists to meet the growth forecast as it is likely this will change during the plan period. The implementation of the Resources and Waste Strategy (December 2018) will require flexibility in plans in order that waste management operators can respond to specific requirements as the policy details become clearer.

Policy WP2 Spatial Strategy for waste management facilities
The policy is generally supported and provides flexibility for new waste management sites to be brought forward where they are needed on sites in proximity to where the production of waste is likely to be concentrated in the larger settlements where the greatest housing and employment growth during the plan period will take place.
It is stated in Policy WP2 that waste management facilities will only be acceptable on the types of land identified within Policy WP3 (land potentially suitable for waste management facilities). It is considered that to provide flexibility to ensure waste management sites are brought forward where a need is demonstrated on sites that are suitable in the specific development context wording such as 'or other sites demonstrated as suitable for the facility proposed' should be added to the policy.

Policy WP3 Land potentially suitable for waste management facilities
The policy provides flexibility for new waste management sites to be brought forward where they are needed based on contracts and market conditions during the timeframe of the plan. It is considered that former mineral extraction sites should be added to the list of land types where waste management facilities will be acceptable. It is unclear why a call for sites exercise was undertaken earlier in 2019 if the Council were not intending to allocate sites in the plan. The need to allocate sites for waste management development should be reconsidered as part of the examination process. As stated in the Preferred Options Document planning applications for waste management facilities will come forward during the plan period and allocations for the location of potential waste management sites is helpful in terms of planning for a specific area.

Appendix 3 - Existing Waste Site Specific Allocations Policies
It is noted that all of the sites allocated in the Waste Strategic Sites Allocations Document, 2013 are proposed for deletion. It is acknowledged in the Preferred Options document, 2019 that waste management sites will come forward during the plan period. It is considered that site allocations provide certainty regarding the type and location of waste management sites that may come forward during the plan period. In the event that the allocated sites are reviewed as part of the Examination it is requested that the promoters are provided the opportunity to make representation on the assessment of previously allocated sites.

Appendix 10 - Proposed Waste Management Sites
It is unclear why a call for sites exercise was undertaken in early 2019 if site allocations were not going to be included in the emerging plan. At Appendix 10 of the Preferred Options document an assessment of the sites proposed is presented. The conclusions for site WS2 (Former mineral working at Heath Road, Snetterton) presented in Appendix 10 that the site is unsuitable to allocate are disputed. The site is a former mineral extraction with an approved unachievable restoration scheme hence an alternative restoration or use for the site should be encouraged. The need to restore the site to a uniform ground level before a waste management facility, or other development could be brought forward would be subject to a detailed design and risk assessment in consultation with the Planning Authority and the Environment Agency. This is a specific characteristic of the site which would need careful consideration during the design and assessment of any development proposal at the site, but is not considered a significant constraint that would affect the deliverability of a permanent waste management facility on the site. It should be noted that development at the site may also be proposed without the need to infill the site to a uniform ground level.

Comments on the Norfolk Minerals and Waste Plan - Preferred Options, July 2019

MJCA are instructed by FH Ventures Norfolk Ltd to review the Norfolk Minerals and Waste Local Plan - Preferred Options document, July 2019 and prepare a response with comments on policies in the plan relevant to waste management and the site at Harling Road, Snetterton (an allocated site in the Adopted Norfolk Waste Site Specific Allocations Development Plan Document 2013 (DPD, 2013)).

The site at Harling Road, Snetterton is part of a former mineral working including the road frontage which is occupied by the site access road and a ready mix cement plant. To the south and adjacent to the former mineral working is a closed, restored landfill site, substation and recycling centre. A copy of the plan showing the site is attached for your information. The former mineral working and the closed, restored landfill are under separate ownership. In this document reference to the site is to the former mineral working and the road frontage.

As part of the work to assess the relevant Preferred Options Policy the planning status of the site has been reviewed and information on the current status regarding the adjacent closed, restored landfill site has been discussed with Norfolk County Council. The approved restoration scheme is for a single landform with a domed profile over the landfill and the former mineral extraction site. It is concluded that based on the dual ownership status, together with the presence of the closed landfill to the south of the site at which leachate and landfill gas generated is actively managed it is highly unlikely that the approved restoration scheme for the site will be achieved this is in particular as the sites are owned separately and any restoration scheme covering both sites in a single domed profile would include filling of a boundary wedge which would extend into both sites. It is also highly unlikely that it would be viable to raise the ground levels at the site to the domed shape in the approved profile with wastes that needed to be deposited in engineered containment cells due to the limited waste void that would be generated. It is considered that the site is suitable for the base to be raised with suitable compacted inert material if a larger footprint is needed for waste treatment and storage. The landowner acknowledges that the site can be returned to a beneficial use and that there is a need to bring forward a plan which addresses the long term use of the site compatible with its setting.

The Company are considering development options for the site such as waste treatment and storage and as part of any planning application will amend the consented restoration scheme for the former mineral extraction site which as stated above cannot be achieved.

Comments on specific policies

Policy WP1 Waste management capacity to be provided
The Policy provides indicative arising forecasts for waste types during the plan period up to 2036. It should be acknowledged that a strategic policy relating to waste management capacity may need to be updated over time as forecasts for the quantities of waste generated change and sites included in the capacity assessment close, or are not brought forward. The policy does acknowledge that new facilities or changes to existing facilities which help achieve the targets for recycling, composting, reuse and recovery set out in the Waste Management Plan for England (2013) will be encouraged. The wording of Policy WP1 should be changed to remove reference to sufficient capacity exists to meet the growth forecast as it is likely this will change during the plan period. The implementation of the Resources and Waste Strategy (December 2018) will require flexibility in plans in order that waste management operators can respond to specific requirements as the policy details become clearer.

Policy WP2 Spatial Strategy for waste management facilities
The policy is generally supported and provides flexibility for new waste management sites to be brought forward where they are needed on sites in proximity to where the production of waste is likely to be concentrated in the larger settlements where the greatest housing and employment growth during the plan period will take place.
It is stated in Policy WP2 that waste management facilities will only be acceptable on the types of land identified within Policy WP3 (land potentially suitable for waste management facilities). It is considered that to provide flexibility to ensure waste management sites are brought forward where a need is demonstrated on sites that are suitable in the specific development context wording such as 'or other sites demonstrated as suitable for the facility proposed' should be added to the policy.

Policy WP3 Land potentially suitable for waste management facilities
The policy provides flexibility for new waste management sites to be brought forward where they are needed based on contracts and market conditions during the timeframe of the plan. It is considered that former mineral extraction sites should be added to the list of land types where waste management facilities will be acceptable. It is unclear why a call for sites exercise was undertaken earlier in 2019 if the Council were not intending to allocate sites in the plan. The need to allocate sites for waste management development should be reconsidered as part of the examination process. As stated in the Preferred Options Document planning applications for waste management facilities will come forward during the plan period and allocations for the location of potential waste management sites is helpful in terms of planning for a specific area.

Appendix 3 - Existing Waste Site Specific Allocations Policies
It is noted that all of the sites allocated in the Waste Strategic Sites Allocations Document, 2013 are proposed for deletion. It is acknowledged in the Preferred Options document, 2019 that waste management sites will come forward during the plan period. It is considered that site allocations provide certainty regarding the type and location of waste management sites that may come forward during the plan period. In the event that the allocated sites are reviewed as part of the Examination it is requested that the promoters are provided the opportunity to make representation on the assessment of previously allocated sites.

Appendix 10 - Proposed Waste Management Sites
It is unclear why a call for sites exercise was undertaken in early 2019 if site allocations were not going to be included in the emerging plan. At Appendix 10 of the Preferred Options document an assessment of the sites proposed is presented. The conclusions for site WS2 (Former mineral working at Heath Road, Snetterton) presented in Appendix 10 that the site is unsuitable to allocate are disputed. The site is a former mineral extraction with an approved unachievable restoration scheme hence an alternative restoration or use for the site should be encouraged. The need to restore the site to a uniform ground level before a waste management facility, or other development could be brought forward would be subject to a detailed design and risk assessment in consultation with the Planning Authority and the Environment Agency. This is a specific characteristic of the site which would need careful consideration during the design and assessment of any development proposal at the site, but is not considered a significant constraint that would affect the deliverability of a permanent waste management facility on the site. It should be noted that development at the site may also be proposed without the need to infill the site to a uniform ground level.

Comments on the Norfolk Minerals and Waste Plan - Preferred Options, July 2019

MJCA are instructed by FH Ventures Norfolk Ltd to review the Norfolk Minerals and Waste Local Plan - Preferred Options document, July 2019 and prepare a response with comments on policies in the plan relevant to waste management and the site at Harling Road, Snetterton (an allocated site in the Adopted Norfolk Waste Site Specific Allocations Development Plan Document 2013 (DPD, 2013)).

The site at Harling Road, Snetterton is part of a former mineral working including the road frontage which is occupied by the site access road and a ready mix cement plant. To the south and adjacent to the former mineral working is a closed, restored landfill site, substation and recycling centre. A copy of the plan showing the site is attached for your information. The former mineral working and the closed, restored landfill are under separate ownership. In this document reference to the site is to the former mineral working and the road frontage.

As part of the work to assess the relevant Preferred Options Policy the planning status of the site has been reviewed and information on the current status regarding the adjacent closed, restored landfill site has been discussed with Norfolk County Council. The approved restoration scheme is for a single landform with a domed profile over the landfill and the former mineral extraction site. It is concluded that based on the dual ownership status, together with the presence of the closed landfill to the south of the site at which leachate and landfill gas generated is actively managed it is highly unlikely that the approved restoration scheme for the site will be achieved this is in particular as the sites are owned separately and any restoration scheme covering both sites in a single domed profile would include filling of a boundary wedge which would extend into both sites. It is also highly unlikely that it would be viable to raise the ground levels at the site to the domed shape in the approved profile with wastes that needed to be deposited in engineered containment cells due to the limited waste void that would be generated. It is considered that the site is suitable for the base to be raised with suitable compacted inert material if a larger footprint is needed for waste treatment and storage. The landowner acknowledges that the site can be returned to a beneficial use and that there is a need to bring forward a plan which addresses the long term use of the site compatible with its setting.

The Company are considering development options for the site such as waste treatment and storage and as part of any planning application will amend the consented restoration scheme for the former mineral extraction site which as stated above cannot be achieved.

Comments on specific policies

Policy WP1 Waste management capacity to be provided
The Policy provides indicative arising forecasts for waste types during the plan period up to 2036. It should be acknowledged that a strategic policy relating to waste management capacity may need to be updated over time as forecasts for the quantities of waste generated change and sites included in the capacity assessment close, or are not brought forward. The policy does acknowledge that new facilities or changes to existing facilities which help achieve the targets for recycling, composting, reuse and recovery set out in the Waste Management Plan for England (2013) will be encouraged. The wording of Policy WP1 should be changed to remove reference to sufficient capacity exists to meet the growth forecast as it is likely this will change during the plan period. The implementation of the Resources and Waste Strategy (December 2018) will require flexibility in plans in order that waste management operators can respond to specific requirements as the policy details become clearer.

Policy WP2 Spatial Strategy for waste management facilities
The policy is generally supported and provides flexibility for new waste management sites to be brought forward where they are needed on sites in proximity to where the production of waste is likely to be concentrated in the larger settlements where the greatest housing and employment growth during the plan period will take place.
It is stated in Policy WP2 that waste management facilities will only be acceptable on the types of land identified within Policy WP3 (land potentially suitable for waste management facilities). It is considered that to provide flexibility to ensure waste management sites are brought forward where a need is demonstrated on sites that are suitable in the specific development context wording such as 'or other sites demonstrated as suitable for the facility proposed' should be added to the policy.

Policy WP3 Land potentially suitable for waste management facilities
The policy provides flexibility for new waste management sites to be brought forward where they are needed based on contracts and market conditions during the timeframe of the plan. It is considered that former mineral extraction sites should be added to the list of land types where waste management facilities will be acceptable. It is unclear why a call for sites exercise was undertaken earlier in 2019 if the Council were not intending to allocate sites in the plan. The need to allocate sites for waste management development should be reconsidered as part of the examination process. As stated in the Preferred Options Document planning applications for waste management facilities will come forward during the plan period and allocations for the location of potential waste management sites is helpful in terms of planning for a specific area.

Appendix 3 - Existing Waste Site Specific Allocations Policies
It is noted that all of the sites allocated in the Waste Strategic Sites Allocations Document, 2013 are proposed for deletion. It is acknowledged in the Preferred Options document, 2019 that waste management sites will come forward during the plan period. It is considered that site allocations provide certainty regarding the type and location of waste management sites that may come forward during the plan period. In the event that the allocated sites are reviewed as part of the Examination it is requested that the promoters are provided the opportunity to make representation on the assessment of previously allocated sites.

Appendix 10 - Proposed Waste Management Sites
It is unclear why a call for sites exercise was undertaken in early 2019 if site allocations were not going to be included in the emerging plan. At Appendix 10 of the Preferred Options document an assessment of the sites proposed is presented. The conclusions for site WS2 (Former mineral working at Heath Road, Snetterton) presented in Appendix 10 that the site is unsuitable to allocate are disputed. The site is a former mineral extraction with an approved unachievable restoration scheme hence an alternative restoration or use for the site should be encouraged. The need to restore the site to a uniform ground level before a waste management facility, or other development could be brought forward would be subject to a detailed design and risk assessment in consultation with the Planning Authority and the Environment Agency. This is a specific characteristic of the site which would need careful consideration during the design and assessment of any development proposal at the site, but is not considered a significant constraint that would affect the deliverability of a permanent waste management facility on the site. It should be noted that development at the site may also be proposed without the need to infill the site to a uniform ground level.

Comments on the Norfolk Minerals and Waste Plan - Preferred Options, July 2019

MJCA are instructed by FH Ventures Norfolk Ltd to review the Norfolk Minerals and Waste Local Plan - Preferred Options document, July 2019 and prepare a response with comments on policies in the plan relevant to waste management and the site at Harling Road, Snetterton (an allocated site in the Adopted Norfolk Waste Site Specific Allocations Development Plan Document 2013 (DPD, 2013)).

The site at Harling Road, Snetterton is part of a former mineral working including the road frontage which is occupied by the site access road and a ready mix cement plant. To the south and adjacent to the former mineral working is a closed, restored landfill site, substation and recycling centre. A copy of the plan showing the site is attached for your information. The former mineral working and the closed, restored landfill are under separate ownership. In this document reference to the site is to the former mineral working and the road frontage.

As part of the work to assess the relevant Preferred Options Policy the planning status of the site has been reviewed and information on the current status regarding the adjacent closed, restored landfill site has been discussed with Norfolk County Council. The approved restoration scheme is for a single landform with a domed profile over the landfill and the former mineral extraction site. It is concluded that based on the dual ownership status, together with the presence of the closed landfill to the south of the site at which leachate and landfill gas generated is actively managed it is highly unlikely that the approved restoration scheme for the site will be achieved this is in particular as the sites are owned separately and any restoration scheme covering both sites in a single domed profile would include filling of a boundary wedge which would extend into both sites. It is also highly unlikely that it would be viable to raise the ground levels at the site to the domed shape in the approved profile with wastes that needed to be deposited in engineered containment cells due to the limited waste void that would be generated. It is considered that the site is suitable for the base to be raised with suitable compacted inert material if a larger footprint is needed for waste treatment and storage. The landowner acknowledges that the site can be returned to a beneficial use and that there is a need to bring forward a plan which addresses the long term use of the site compatible with its setting.

The Company are considering development options for the site such as waste treatment and storage and as part of any planning application will amend the consented restoration scheme for the former mineral extraction site which as stated above cannot be achieved.

Comments on specific policies

Policy WP1 Waste management capacity to be provided
The Policy provides indicative arising forecasts for waste types during the plan period up to 2036. It should be acknowledged that a strategic policy relating to waste management capacity may need to be updated over time as forecasts for the quantities of waste generated change and sites included in the capacity assessment close, or are not brought forward. The policy does acknowledge that new facilities or changes to existing facilities which help achieve the targets for recycling, composting, reuse and recovery set out in the Waste Management Plan for England (2013) will be encouraged. The wording of Policy WP1 should be changed to remove reference to sufficient capacity exists to meet the growth forecast as it is likely this will change during the plan period. The implementation of the Resources and Waste Strategy (December 2018) will require flexibility in plans in order that waste management operators can respond to specific requirements as the policy details become clearer.

Policy WP2 Spatial Strategy for waste management facilities
The policy is generally supported and provides flexibility for new waste management sites to be brought forward where they are needed on sites in proximity to where the production of waste is likely to be concentrated in the larger settlements where the greatest housing and employment growth during the plan period will take place.
It is stated in Policy WP2 that waste management facilities will only be acceptable on the types of land identified within Policy WP3 (land potentially suitable for waste management facilities). It is considered that to provide flexibility to ensure waste management sites are brought forward where a need is demonstrated on sites that are suitable in the specific development context wording such as 'or other sites demonstrated as suitable for the facility proposed' should be added to the policy.

Policy WP3 Land potentially suitable for waste management facilities
The policy provides flexibility for new waste management sites to be brought forward where they are needed based on contracts and market conditions during the timeframe of the plan. It is considered that former mineral extraction sites should be added to the list of land types where waste management facilities will be acceptable. It is unclear why a call for sites exercise was undertaken earlier in 2019 if the Council were not intending to allocate sites in the plan. The need to allocate sites for waste management development should be reconsidered as part of the examination process. As stated in the Preferred Options Document planning applications for waste management facilities will come forward during the plan period and allocations for the location of potential waste management sites is helpful in terms of planning for a specific area.

Appendix 3 - Existing Waste Site Specific Allocations Policies
It is noted that all of the sites allocated in the Waste Strategic Sites Allocations Document, 2013 are proposed for deletion. It is acknowledged in the Preferred Options document, 2019 that waste management sites will come forward during the plan period. It is considered that site allocations provide certainty regarding the type and location of waste management sites that may come forward during the plan period. In the event that the allocated sites are reviewed as part of the Examination it is requested that the promoters are provided the opportunity to make representation on the assessment of previously allocated sites.

Appendix 10 - Proposed Waste Management Sites
It is unclear why a call for sites exercise was undertaken in early 2019 if site allocations were not going to be included in the emerging plan. At Appendix 10 of the Preferred Options document an assessment of the sites proposed is presented. The conclusions for site WS2 (Former mineral working at Heath Road, Snetterton) presented in Appendix 10 that the site is unsuitable to allocate are disputed. The site is a former mineral extraction with an approved unachievable restoration scheme hence an alternative restoration or use for the site should be encouraged. The need to restore the site to a uniform ground level before a waste management facility, or other development could be brought forward would be subject to a detailed design and risk assessment in consultation with the Planning Authority and the Environment Agency. This is a specific characteristic of the site which would need careful consideration during the design and assessment of any development proposal at the site, but is not considered a significant constraint that would affect the deliverability of a permanent waste management facility on the site. It should be noted that development at the site may also be proposed without the need to infill the site to a uniform ground level.

Comments on the Norfolk Minerals and Waste Plan - Preferred Options, July 2019

MJCA are instructed by FH Ventures Norfolk Ltd to review the Norfolk Minerals and Waste Local Plan - Preferred Options document, July 2019 and prepare a response with comments on policies in the plan relevant to waste management and the site at Harling Road, Snetterton (an allocated site in the Adopted Norfolk Waste Site Specific Allocations Development Plan Document 2013 (DPD, 2013)).

The site at Harling Road, Snetterton is part of a former mineral working including the road frontage which is occupied by the site access road and a ready mix cement plant. To the south and adjacent to the former mineral working is a closed, restored landfill site, substation and recycling centre. A copy of the plan showing the site is attached for your information. The former mineral working and the closed, restored landfill are under separate ownership. In this document reference to the site is to the former mineral working and the road frontage.

As part of the work to assess the relevant Preferred Options Policy the planning status of the site has been reviewed and information on the current status regarding the adjacent closed, restored landfill site has been discussed with Norfolk County Council. The approved restoration scheme is for a single landform with a domed profile over the landfill and the former mineral extraction site. It is concluded that based on the dual ownership status, together with the presence of the closed landfill to the south of the site at which leachate and landfill gas generated is actively managed it is highly unlikely that the approved restoration scheme for the site will be achieved this is in particular as the sites are owned separately and any restoration scheme covering both sites in a single domed profile would include filling of a boundary wedge which would extend into both sites. It is also highly unlikely that it would be viable to raise the ground levels at the site to the domed shape in the approved profile with wastes that needed to be deposited in engineered containment cells due to the limited waste void that would be generated. It is considered that the site is suitable for the base to be raised with suitable compacted inert material if a larger footprint is needed for waste treatment and storage. The landowner acknowledges that the site can be returned to a beneficial use and that there is a need to bring forward a plan which addresses the long term use of the site compatible with its setting.

The Company are considering development options for the site such as waste treatment and storage and as part of any planning application will amend the consented restoration scheme for the former mineral extraction site which as stated above cannot be achieved.

Comments on specific policies

Policy WP1 Waste management capacity to be provided
The Policy provides indicative arising forecasts for waste types during the plan period up to 2036. It should be acknowledged that a strategic policy relating to waste management capacity may need to be updated over time as forecasts for the quantities of waste generated change and sites included in the capacity assessment close, or are not brought forward. The policy does acknowledge that new facilities or changes to existing facilities which help achieve the targets for recycling, composting, reuse and recovery set out in the Waste Management Plan for England (2013) will be encouraged. The wording of Policy WP1 should be changed to remove reference to sufficient capacity exists to meet the growth forecast as it is likely this will change during the plan period. The implementation of the Resources and Waste Strategy (December 2018) will require flexibility in plans in order that waste management operators can respond to specific requirements as the policy details become clearer.

Policy WP2 Spatial Strategy for waste management facilities
The policy is generally supported and provides flexibility for new waste management sites to be brought forward where they are needed on sites in proximity to where the production of waste is likely to be concentrated in the larger settlements where the greatest housing and employment growth during the plan period will take place.
It is stated in Policy WP2 that waste management facilities will only be acceptable on the types of land identified within Policy WP3 (land potentially suitable for waste management facilities). It is considered that to provide flexibility to ensure waste management sites are brought forward where a need is demonstrated on sites that are suitable in the specific development context wording such as 'or other sites demonstrated as suitable for the facility proposed' should be added to the policy.

Policy WP3 Land potentially suitable for waste management facilities
The policy provides flexibility for new waste management sites to be brought forward where they are needed based on contracts and market conditions during the timeframe of the plan. It is considered that former mineral extraction sites should be added to the list of land types where waste management facilities will be acceptable. It is unclear why a call for sites exercise was undertaken earlier in 2019 if the Council were not intending to allocate sites in the plan. The need to allocate sites for waste management development should be reconsidered as part of the examination process. As stated in the Preferred Options Document planning applications for waste management facilities will come forward during the plan period and allocations for the location of potential waste management sites is helpful in terms of planning for a specific area.

Appendix 3 - Existing Waste Site Specific Allocations Policies
It is noted that all of the sites allocated in the Waste Strategic Sites Allocations Document, 2013 are proposed for deletion. It is acknowledged in the Preferred Options document, 2019 that waste management sites will come forward during the plan period. It is considered that site allocations provide certainty regarding the type and location of waste management sites that may come forward during the plan period. In the event that the allocated sites are reviewed as part of the Examination it is requested that the promoters are provided the opportunity to make representation on the assessment of previously allocated sites.

Appendix 10 - Proposed Waste Management Sites
It is unclear why a call for sites exercise was undertaken in early 2019 if site allocations were not going to be included in the emerging plan. At Appendix 10 of the Preferred Options document an assessment of the sites proposed is presented. The conclusions for site WS2 (Former mineral working at Heath Road, Snetterton) presented in Appendix 10 that the site is unsuitable to allocate are disputed. The site is a former mineral extraction with an approved unachievable restoration scheme hence an alternative restoration or use for the site should be encouraged. The need to restore the site to a uniform ground level before a waste management facility, or other development could be brought forward would be subject to a detailed design and risk assessment in consultation with the Planning Authority and the Environment Agency. This is a specific characteristic of the site which would need careful consideration during the design and assessment of any development proposal at the site, but is not considered a significant constraint that would affect the deliverability of a permanent waste management facility on the site. It should be noted that development at the site may also be proposed without the need to infill the site to a uniform ground level.