Minerals and Waste Local Plan: Pre-Submission Publication
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Minerals and Waste Local Plan: Pre-Submission Publication
4.3 Minerals Strategic Objectives
Representation ID: 99306
Received: 15/12/2022
Respondent: Norfolk Gravel
Agent: David L Walker Ltd
In relation to the Minerals Objectives, whilst Norfolk Gravel recognise that the council have an objective to provide a steady and adequate supply, it is considered that this needs to also include the actual commitment (i.e requirement to maintain relevant landbanks).
In relation to the Minerals Objectives, whilst Norfolk Gravel recognise that the council have an objective to provide a steady and adequate supply, it is considered that this needs to also include the actual commitment (i.e requirement to maintain relevant landbanks).
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Policy MW1: Development Management Criteria
Representation ID: 99307
Received: 15/12/2022
Respondent: Norfolk Gravel
Agent: David L Walker Ltd
The company would support Policy MW1, but would suggest that in the final paragraph when considering potential environmental benefits this could clearly states geo-diversity benefits where applicable.
In the final paragraph when considering potential environmental benefits this could clearly states geo-diversity benefits where applicable.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Policy MW2: Transport
Representation ID: 99308
Received: 15/12/2022
Respondent: Norfolk Gravel
Agent: David L Walker Ltd
Regarding Policy MW2 whist the company supports the aspiration for the use of other transport modes, more often than not such avenues are not available, and as such the term “Where appropriate” should replace the word “All”. Similarly, in relation to the last bullet point of the policy is it not always practical to access a site by alternative means, and often access by car is the only means, especially for mineral sites which tend to be located in the rural hinterland.
The term “Where appropriate” should replace the word “All”. Similarly, in relation to the last bullet point of the policy is it not always practical to access a site by alternative means, and often access by car is the only means, especially for mineral sites which tend to be located in the rural hinterland.
Support
Minerals and Waste Local Plan: Pre-Submission Publication
Policy MP1: Provision for minerals extraction – STRATEGIC POLICY
Representation ID: 99309
Received: 15/12/2022
Respondent: Norfolk Gravel
Agent: David L Walker Ltd
As regards to the Mineral policies the contents of paragraphs MP1-MP10 inclusive are supported in full, although at the outset when considering the sand and gravel landbank, Norfolk Gravel would question why when considering the sand and gravel landbank ten year sales doesn’t include 2021, when the returns and data should be readily available at this time of the year?
No comments are offered on the remainder of the “strategic landbank” type policies for the other minerals.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
MP2.5
Representation ID: 99310
Received: 15/12/2022
Respondent: Norfolk Gravel
Agent: David L Walker Ltd
Under paragraph MP2.5, the company would question the definition of a Main Town as this does not appear to list the town of Sherringham which is a clear development centre identified under local policy documents.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Policy MP2: Spatial Strategy for minerals extraction – STRATEGIC POLICY
Representation ID: 99311
Received: 15/12/2022
Respondent: Norfolk Gravel
Agent: David L Walker Ltd
In respect of Policy MP2, paragraph 23 of the NPPF states “Broad locations for development should be indicated on a key diagram, and land use designations and allocations identified on a policies map.” Can the council please confirm that when referencing “resource areas” within the policy they are actually referring to the “Mineral Safeguarding Areas” on the Key Diagrams as a “reserve area” is noted in the legend for those plans.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
MP7.5
Representation ID: 99312
Received: 15/12/2022
Respondent: Norfolk Gravel
Agent: David L Walker Ltd
Paragraph MP7.5 refers to Green Infrastructure mapping. It is suggested that a high-resolution copy of the map provided is either included as an appendix or a weblink, as the drawing provided is of low quality and cannot be easily used on an interpretive basis.
Paragraph MP7.5 refers to Green Infrastructure mapping. It is suggested that a high-resolution copy of the map provided is either included as an appendix or a weblink, as the drawing provided is of low quality and cannot be easily used on an interpretive basis.
Object
Minerals and Waste Local Plan: Pre-Submission Publication
Policy MP7: Progressive working, restoration and after-use
Representation ID: 99313
Received: 15/12/2022
Respondent: Norfolk Gravel
Agent: David L Walker Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
In respect of Policy MP7, the application of the wording “exceptional circumstances” is questioned as this creates an unnecessary barrier to change. Sometimes the reason for a change can be simple, and therefore applying a qualifying criterion seems unjustified and unnecessary. The test should be no diminishment in quality, as per the remainder of the policy.
The absence of drainage and flood risk wording under Policy MP7 is also notable as these are key aspects when considering the design of any restoration landform under the modern day planning regime.
Soundness test: not justified
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Policy MP9: Asphalt plants, concrete batching plants and the manufacture of concrete products
Representation ID: 99314
Received: 15/12/2022
Respondent: Norfolk Gravel
Agent: David L Walker Ltd
It is respectfully suggested that Policies MP9 and MP10 could be expanded to include reference to precast blockworks to use indigenous materials and aggregate bagging plants, as both are viable forms of ancillary development at aggregates sites in principle.
Policies MP9 and MP10 could be expanded to include reference to precast blockworks to use indigenous materials and aggregate bagging plants, as both are viable forms of ancillary development at aggregates sites in principle.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Policy MP10: safeguarding of port and rail facilities, and facilities for the manufacture of concrete, asphalt and recycled materials – STRATEGIC POLICY
Representation ID: 99315
Received: 15/12/2022
Respondent: Norfolk Gravel
Agent: David L Walker Ltd
It is respectfully suggested that Policies MP9 and MP10 could be expanded to include reference to precast blockworks to use indigenous materials and aggregate bagging plants, as both are viable forms of ancillary development at aggregates sites in principle.
Policies MP9 and MP10 could be expanded to include reference to precast blockworks to use indigenous materials and aggregate bagging plants, as both are viable forms of ancillary development at aggregates sites in principle.
