Minerals and Waste Local Plan: Pre-Submission Publication
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Minerals and Waste Local Plan: Pre-Submission Publication
Policy WP2: Spatial Strategy for waste management facilities – STRATEGIC POLICY
Representation ID: 99117
Received: 11/11/2022
Respondent: Broads Authority
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
This policy says ‘New or enhanced waste management facilities should be located within five miles of one of Norfolk’s urban areas or three miles of one of the main towns and be accessible via appropriate transport infrastructure, subject to the proposed development not being located within: the Broads Authority Executive Area or the Norfolk Coast Area of Outstanding Natural Beauty, other than in exceptional circumstances and where it can be demonstrated that the development is in the public interest’.
Elsewhere, throughout the document, the stance is no minerals and waste sites within the Broads, yet this policy says they could be.
A look at the maps suggests that there are no settlements that need a facility within the AONB or Executive Area to achieve the 3 miles/5 miles criteria; as such, why is this criterion needed?
Soundness test: Not effective
If this part of the policy is to be kept in, we request there is reference to the need for close working with the Broads Authority.
We also request that any proposals would need to demonstrate no alternative sites are available.
You could amend bullet point 1 as follows:
the Broads Authority Executive Area or the Norfolk Coast Area of Outstanding Natural Beauty, other than in exceptional circumstances and where it can be demonstrated that the development is in the public interest. Any proposals in these areas would need to also demonstrate that no alternative sites outside of these areas are available. Scheme promoters will be required to work closely with the Broads Authority and AONB.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
1.2
Representation ID: 99118
Received: 11/11/2022
Respondent: Broads Authority
Factual issues
1.2 – rather than ‘lodged with district councils’ say ‘lodged with Norfolk Local Planning Authorities’ – as written, it excludes the Broads Authority.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
6.19
Representation ID: 99119
Received: 11/11/2022
Respondent: Broads Authority
6.19 – again by only mentioning district and borough local plans, you don’t include the Broads Authority’s Local Plan. Say Norfolk LPA Local Plans.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
3.12
Representation ID: 99120
Received: 11/11/2022
Respondent: Broads Authority
We have some queries and questions. These are not saying the Plan is unsound by asking these queries, but we would welcome thoughts on these and they may result in improvements to the Plan.
3.12 – could the navigable waterways of the Broads be used for the transport of such freight?
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Policy MW2: Transport
Representation ID: 99121
Received: 11/11/2022
Respondent: Broads Authority
We have some queries and questions. These are not saying the Plan is unsound by asking these queries, but we would welcome thoughts on these and they may result in improvements to the Plan.
MW2 - should this refer to how staff travel to and from the site as a place of work?
MW2 – should this refer to the potential to use clean fuel/net zero emissions fuel for the HGVs or other work vehicles?
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Policy MW3: Climate change mitigation and adaption - STRATEGIC POLICY
Representation ID: 99122
Received: 11/11/2022
Respondent: Broads Authority
We have some queries and questions. These are not saying the Plan is unsound by asking these queries, but we would welcome thoughts on these and they may result in improvements to the Plan.
MW3 - Where a site will be in place for a number of years, would resilience to the effects of climate change be sensible to consider?
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Policy WP9: Anaerobic digestion
Representation ID: 99123
Received: 11/11/2022
Respondent: Broads Authority
We have some queries and questions. These are not saying the Plan is unsound by asking these queries, but we would welcome thoughts on these and they may result in improvements to the Plan.
WP9 – aren’t anaerobic digesters an in-scope type of development in terms of impact on nutrient enrichment and therefore nutrient neutrality?
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Policy WP13: Landfill Mining and Reclamation
Representation ID: 99124
Received: 11/11/2022
Respondent: Broads Authority
We have some queries and questions. These are not saying the Plan is unsound by asking these queries, but we would welcome thoughts on these and they may result in improvements to the Plan.
Policy WP13 and paragraph 13.5 - Some of the wording in 13.5 is not included in WP13. In particular, there is no mention in the policy of the need to mitigate the potential rapid release of leachate or emissions and odours. This is mentioned in 13.5 but not in the policy. This may be covered to some extent in MW1, but as it is raised specifically in 13.5, does it need to be a consideration for schemes captured by WP13?
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
W15.6
Representation ID: 99125
Received: 11/11/2022
Respondent: Broads Authority
We have some queries and questions. These are not saying the Plan is unsound by asking these queries, but we would welcome thoughts on these and they may result in improvements to the Plan.
WP15.6 – how does the likely requirement for all WRCs to be at best available technology by 2030 relate to what is written here?
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Policy MP7: Progressive working, restoration and after-use
Representation ID: 99126
Received: 11/11/2022
Respondent: Broads Authority
We have some queries and questions. These are not saying the Plan is unsound by asking these queries, but we would welcome thoughts on these and they may result in improvements to the Plan.
MP7 – could the restoration be a walk or cycle route itself – as in, not necessarily connected to the PROW? Could it become an attraction itself?
MP7 – what about access to water, if a body of water becomes part of the scheme?
