Proposed Main Modifications

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Object

Proposed Main Modifications

MM01 - Vision, Page 19

Representation ID: 99616

Received: 13/12/2024

Respondent: Mineral Products Association

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

It is beyond the role of the planning system to specify which vehicles can and cannot be used to transport minerals. The planning system can promote use, but this could not be enforced.
Also, Minerals can only be worked where they are found and as such, unlike waste developments, their locations are constrained by geology.

Object

Proposed Main Modifications

MM03 - Minerals Strategic Objectives, Page 21

Representation ID: 99617

Received: 13/12/2024

Respondent: Mineral Products Association

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The amendments should reflect the requirements of the NPPF and avoid the use of loose or superfluous wording. For example, the words “where practicable” are not within the NPPF with respect to Industrial sands and the p.

Object

Proposed Main Modifications

MM05 - Policy MW1. Development Management Criteria, Page 27

Representation ID: 99618

Received: 13/12/2024

Respondent: Mineral Products Association

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The wording is introducing text which it suggests is part of the historic environment policy requirements in the NPPF. This is not the case, nor does the wording appear in the Planning Practice Guidance.
In addition, unlike mandatory BNG, geodiversity may not always be practicable or possible to include and clearly it needs to be relevant to the surroundings, safe and geologically beneficial.

Object

Proposed Main Modifications

MM07 - Policy MW3. Climate change mitigation and adaption, Page 39

Representation ID: 99619

Received: 13/12/2024

Respondent: Mineral Products Association

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Poor choice of wording. “Demonstrate” suggests a practical demonstration, whereas in reality, the Council will be seeking “a description or details of”

Object

Proposed Main Modifications

MM30 - Paragraph MP1.4, Page 68

Representation ID: 99620

Received: 13/12/2024

Respondent: Mineral Products Association

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The proposed modification does not appear to accord with the requirements of the NPPF, be align with the LAA and the wording is subjective and therefore not positively prepared.

Object

Proposed Main Modifications

MM33 - Paragraph MP1.7, Pages 68-69

Representation ID: 99621

Received: 13/12/2024

Respondent: Mineral Products Association

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

We do not believe the Council has taken the essence of the 10% buffer in accordance with the discussions at the EIP. The Council does not appear to have made any effort to forecast demand and is simply using the “10% buffer” as a forecast. The figures should be revisited to forecast demand and then the 10% buffer added.

Object

Proposed Main Modifications

MM41 - Paragraph MP1.18, Page 70

Representation ID: 99622

Received: 13/12/2024

Respondent: Mineral Products Association

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The Council needs to provide clarity on sales and production figures. Reference is made 10-years production and then 3-yearsproduction, followed by 10-years average sales data and 3-years sales data. It then refers to raw silica sand throughput of the plant. The wording requires clarity as these figures will undoubtedly be very different.

Object

Proposed Main Modifications

MM42 - Paragraph MP1.20, Page 71

Representation ID: 99623

Received: 13/12/2024

Respondent: Mineral Products Association

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The wording does not reflect the NPPF or the wording of proposed amendment MM41. The latter states that “the quantity of silica sand to be planned for will be at least the current maximum lawful throughput of the Leziate processing plant site”. The proposed wording does not reflect “at least the current maximum”, it is precisely the quoted current maximum. The text should be amended to read:
"The permitted reserve of silica sand, at 31/12/2022 is estimated at 3.08 million tonnes. The permitted reserve therefore provides a [delete: landbank] [insert: stock of permitted reserves] of less than 10 years' worth of silica sand production, which is below the level required by the NPPF.
Further, the forecast is clearly an underestimate and is not being based upon true output but a “maximum throughput”. This is also wholly contrary to the discussions and agreement at the EIP. The amended text using the 10 year average clearly states silica sand production in Norfolk over the last 10 years (2013-2022) was 825,643 . It is this figure which should be used to forecast production over the next 16 years to ensure a steady and adequate supply of silica sand is maintained and avoid under-supply. Failure to deliver this will render the plan unsound.

Object

Proposed Main Modifications

MM43 - Policy MP1. Provision for mineral extraction, Page 72

Representation ID: 99624

Received: 13/12/2024

Respondent: Mineral Products Association

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Whilst we recognise a more positive wording, as highlighted above, we have concerns over the forecast for growth which has not been predicted and is limited to an arbitrary 10% buffer.

Object

Proposed Main Modifications

MM44 - Paragraph MP1.25, Page 72

Representation ID: 99625

Received: 13/12/2024

Respondent: Mineral Products Association

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

We believe the identification of overriding planning reasons should be broadened to reflect spatial planning issues and planning policy requirements.

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