Minerals and Waste Local Plan: Pre-Submission Publication
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Minerals and Waste Local Plan: Pre-Submission Publication
Calculation of forecast need for sand and gravel
Representation ID: 99078
Received: 06/10/2022
Respondent: Middleton Aggregates Ltd
Agent: Stephen M Daw Limited
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The forecast shortfall does not give sufficient flexibility given the uncertainties of future demand and problems which may arise preventing allocated sites from being developed. A greater flexibility has recently been given in the Suffolk Minerals & Waste Local Plan adopted in July 2020 (para 5.33).
The Plan should include an additional 20% of 0.274 million tpa for each year, giving a total forecast need of 1.643 million tpa, equivalent to 29.957 mt over the Plan period and a shortfall of 15.059 mt, or an additional 2.462 mt required. The additional requirement could be partly met by the allocation of MIN 205 and land immediately to the north of MIN 205.
Object
Minerals and Waste Local Plan: Pre-Submission Publication
Policy WP3: Land suitable for waste management facilities – STRATEGIC POLICY
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
Policy MP5: Core River Valleys
Representation ID: 99212
Received: 07/12/2022
Respondent: Middleton Aggregates Ltd
Agent: Stephen M Daw Limited
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The policy as worded sets an unreasonably high requirement for mineral developments in a Core River Valley.
The policy wording should firstly, be amended so that not all proposals need to result in an enhancement of the landscape, historic environment and biodiversity, to be acceptable. Instead proposals should be expected to result in one or at most two forms of enhancement. Secondly, it is unreasonable to require a mineral development to result in enhancement(s) during working and so this requirement should be dropped.
