Minerals and Waste Local Plan: Pre-Submission Publication
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Minerals and Waste Local Plan: Pre-Submission Publication
Specific Site Allocation Policy MIN 25 (land at Manor Farm, Haddiscoe):
Representation ID: 99213
Received: 09/12/2022
Respondent: Breedon Trading Limited
The Company supports the identification of the Haddiscoe site as a Specific Site for the winning and working of sand and gravel.
Support
Minerals and Waste Local Plan: Pre-Submission Publication
Specific Site Allocation Policy MIN 202 (land south of Reepham Road, Attlebridge):
Representation ID: 99214
Received: 09/12/2022
Respondent: Breedon Trading Limited
The Company supports the identification of the site as a site allocation for the winning and working of minerals.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Sand and gravel
Representation ID: 99215
Received: 09/12/2022
Respondent: Breedon Trading Limited
The references to the planning status of the Attlebridge and Haddiscoe sites should be updated. Attlebridge is current not subject to a planning application whilst the Haddiscoe site is (submitted November 2022).
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Policy MP1: Provision for minerals extraction – STRATEGIC POLICY
Representation ID: 99216
Received: 09/12/2022
Respondent: Breedon Trading Limited
Neither the policy itself or its pre-amble actually identify which sites have been selected to fulfil the 12.597 mt. It would be helpful for readers of the document for the sites identified to be listed in the policy itself or the pre-amble, or a reference made to where the schedule of identified sites lies within the wider document.
Object
Minerals and Waste Local Plan: Pre-Submission Publication
Policy MP1: Provision for minerals extraction – STRATEGIC POLICY
Representation ID: 99288
Received: 15/12/2022
Respondent: Breedon Trading Limited
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Company wishes to object to the inclusion of the following phrase within the policy: -
“…Mineral extraction for sand and gravel outside of allocated sites will be resisted by the Mineral Planning Authority unless the applicant can demonstrate:
a) There is an overriding justification and/or overriding benefit for the proposed extraction…”
In the Company’s view this does not sit at ease with the following quote from paragraph 5.3 of the Plan
“…Norfolk County Council will take a positive approach to minerals development and waste management development that reflects the presumption in favour of
sustainable development…”
To be consistent Policy MP1 should reflect the statement made by paragraph 5.3, i.e., that the Council will take a positive approach to minerals development that reflects the principles of sustainable development.
The Company suggests that the presumption against sites not allocated by the Plan is dropped and replaced by the following: -
“Mineral extraction for sand and gravel outside of allocated sites will be viewed positively the Mineral Planning Authority provided such proposals are demonstrably sustainable development and:
a) There is an justification or benefit for the proposed extraction…”
In the Company’s view this better aligns Policy MP1 and paragraph 5.3 of the Plan.
Object
Minerals and Waste Local Plan: Pre-Submission Publication
4.3 Minerals Strategic Objectives
Representation ID: 99289
Received: 15/12/2022
Respondent: Breedon Trading Limited
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
To fully reflect guidance provided by NPPF paragraph MSO1 should refer to the need to provide a steady and adequate supply of aggregate minerals for at least a seven year landbank.
To provide a steady and adequate supply of aggregate minerals and to provide at least a 7-year land bank for sand and gravel, and 10-year landbank for carstone, by identifying adequate mineral extraction sites/areas within Norfolk sufficient to meet the requirements of the Local Aggregate Assessment and safeguarding existing infrastructure.