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Proposed Main Modifications
MM33 - Paragraph MP1.7, Pages 68-69
Representation ID: 99546
Received: 25/10/2024
Respondent: Earsham Gravels Limited
Agent: Stephen M Daw Limited
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Respondent is disappointed the Plan has not been amended to adopt a minimum 20% buffer. A 20% buffer would still result in a small shortfall of 0.196mt,
Planned reserves at the end of the Plan period should be at least sufficient for 7 years production based on 10-year average sales figures at the time.
Should the Inspector to be minded to adopted a 20% buffer or a greater degree of flexibility or have sufficient reserve at the end of the Plan period, the Plan will need to allocate a larger quantity of sand and gravel.
To adopt a minimum 20% buffer and make provision at the end of the Plan period when calculating a sand and gravel requirement and if necessary allocate more mineral. In this consideration should be given to the Respondents site MIN 212 Mundham which contains a reserve of 0.325mt and was a site 'considered suitable for sand and gravel extraction' at the Preferred Options stage.
The Respondent is disappointed the Plan has not been amended to adopt a minimum 20% buffer (representation 99082). Using the Councils latest available figures a 20% buffer would still result in a small shortfall of 0.196mt, as below:
Reserves Required - 27.130mt (16 years x 1.413mt + 20%)
less Permitted Reserves - 17.854mt
Net Requirement = 9.176mt
less Total Allocated - 8.98mt
Shortfall = 0.196mt
The scenario adopted in landbank calculations would appear to be predicated on reserves being zero at the end of the Plan period. Instead planned reserves at the end of the Plan period should be at least sufficient for 7 years production based on 10-year average sales figures at the time.
Should the Inspector be minded to adopted a 20% buffer or a greater degree of flexibility or have sufficient reserve at the end of the Plan period, the Plan will need to allocate a larger quantity of sand and gravel. It should be noted the Respondents site at Mundham (MIN 212) contains a reserve of 0.325mt and is a site which was 'considered suitable for sand and gravel extraction' at the Preferred Options stage but was subsequently removed at the Publication Stage as not needed.