Minerals and Waste Local Plan: Pre-Submission Publication

Comment

Representation ID: 99316

Received: 15/12/2022

Respondent: Norfolk Gravel

Agent: David L Walker Ltd

Norfolk Gravel has secured planning consent (ref FUL/2019/0001) to recover approximately half of the mineral resource identified in this allocation profile. This planning consent was granted by the members of the council’s planning committee, as it represented as a sustainable and logical extension to the current site utilising the processing and access infrastructure (including access arrangements) of the latter. As such 1 million tonnes of the 2 million tonne allocation already forms part of the sand and gravel landbank.
The planning consent was implemented in early 2021, and the extraction operations are within the allocation area. It is therefore proposed that the initial bullet points under the site specific content take this into account.
Norfolk Gravel would also question the need to cover the northern part of the allocation area as this is now operable. Norfolk Gravel would be happy to provide further plan work to support this aspect should the council requires

Comment

Representation ID: 99317

Received: 15/12/2022

Respondent: Norfolk Gravel

Agent: David L Walker Ltd

Norfolk Gravel would not disagree with the wording of paragraph M69.1 which is factual in nature but would suggest that for context the influence of the A148 on local amenity is clearly indicated as this forms part of the baseline consideration of any scheme.

Object

Representation ID: 99318

Received: 15/12/2022

Respondent: Norfolk Gravel

Agent: David L Walker Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Regarding paragraph M69.2, this matter was subject to detailed consideration as part of the determination of application ref FUL/2019/0001, with the Local Members agreeing at the point of determination that no such upgrades were required to the junction with the A148. Norfolk Gravel would maintain that there is no need or requirement for any upgrades to this junction which has continued to operate without incident even after the recommencement of extraction activities at the site in 2021. Thus, consistent with Paragraph 110 of the NPPF 2021 it can be readily demonstrated that a “safe and suitable access to the site can be achieved for all users”, and as such it is proposed that it is not justified or necessary to include the recommendations for right turn lanes etc.
Norfolk Gravel will continue to challenge the inclusion of such wording through all phases of the plan making process.
Soundness test: not justified

Comment

Representation ID: 99319

Received: 15/12/2022

Respondent: Norfolk Gravel

Agent: David L Walker Ltd

Reference paragraph M69.5, as part of the recently determined planning application Norfolk Gravel, have provided geophysical investigation and trial trench evidence which has identified that whilst there are finds and features on site these are indicative of the surrounding area and as such would only have a local value or significance. These investigations have been set out in a publication report as required under planning conditions. Again, this could be added to provide context, as the report has been published.

Comment

Representation ID: 99320

Received: 15/12/2022

Respondent: Norfolk Gravel

Agent: David L Walker Ltd

Norfolk Gravel would wholly support the wording of paragraph M69.7 although again would ask if this content needs to be updated to reflect the grant of consent FUL/2019/0001, and the issue of consent FUL/2019/0000 which related to the older area of working. It may also be worth identifying that the concrete production relates to ready-mix only, as the site no longer has the ability to manufacture precast or other block work products (same comment applying to paragraph M69.9)

Support

Representation ID: 99321

Received: 15/12/2022

Respondent: Norfolk Gravel

Agent: David L Walker Ltd

Norfolk Gravel would wholly support the wording of paragraph M69.7 although again would ask if this content needs to be updated to reflect the grant of consent FUL/2019/0001, and the issue of consent FUL/2019/0000 which related to the older area of working. It may also be worth identifying that the concrete production relates to ready-mix only, as the site no longer has the ability to manufacture precast or other block work products (same comment applying to paragraph M69.9)

Comment

Representation ID: 99322

Received: 15/12/2022

Respondent: Norfolk Gravel

Agent: David L Walker Ltd

This paragraph relates to matters of geodiversity, and whilst Norfolk Gravel are under a current obligation for a watching brief for the current extension, it does not follow that this would be required for the remainder of site M69. If the current watching brief and annual reporting requirement doesn’t identify any features of particular merit or significance, then there may be no need to continue arrangements. Instead of using the word “essential” in the ninth sentence, Norfolk Gravel would merely suggest that the wording “potentially be required” to take account of this occurrence.

Comment

Representation ID: 99323

Received: 15/12/2022

Respondent: Norfolk Gravel

Agent: David L Walker Ltd

On the wording of Specific Site Allocation Policy MIN 69 (land north of Holt Road, Aylmerton) Norfolk Gravel would re iterate the same points as above, and would comment as follows:-
• criteria d is proposed to be simplified, with any requirements to upgrade the nearby highway removed;
• the need for criteria e is questioned as the stand off is already significant due to the provision of advance planting that would remain in situ;
• under criteria j instead of using the word “necessary” the council could use the wording “need to be maintained” as the advance planting is already installed;
• it is suggested that criteria o be split into two, one aspect related to footpaths and the other related to interpretation boards. Again, however it is questioned why such content needs to be included when it already forms part of the conditions and obligations under consent ref FUL/2019/0001.
A key aspect for the remainder of the allocation area would be to continue to maintain a very high quality restoration scheme for both the existing site, and proposed extension, with an emphasis on nature conservation habitat (specifically heathland), with improved public access, better access to geo-diversity and retention of exposures wherever possible; together with information boards (conveying information about the ecology, geology and geomorphology of the site). The provision of permissive routes through the restoration landform would also be continued to be considered by Norfolk Gravel as part of any future development scheme.
In general terms the company supports the allocation of site MIN69, with the above intended to provide greater context and content for the allocation profile.

Support

Representation ID: 99325

Received: 15/12/2022

Respondent: Norfolk Gravel

Agent: David L Walker Ltd

Norfolk Gravel would wholly support the wording of paragraphs M69.9 to M69.13 inclusive and would reaffirm that as part of the current planning application the company is developing long term plans to sustainably manage the biodiversity and geo-diversity.

Support

Representation ID: 99326

Received: 15/12/2022

Respondent: Norfolk Gravel

Agent: David L Walker Ltd

Norfolk Gravel would wholly support the wording of paragraphs M69.9 to M69.13 inclusive and would reaffirm that as part of the current planning application the company is developing long term plans to sustainably manage the biodiversity and geo-diversity.