Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Object

Representation ID: 3983

Received: 26/09/2024

Respondent: Norfolk County Council - Minerals and Waste Team

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Norfolk County Council in its capacity as the Mineral Planning Authority considers that Policy VC EAR2 is currently unsound; as it is inconsistent with national policy (NPPF paragraph 218), and the adopted Development Plan in Norfolk (policy CS16 of the Norfolk Minerals and Waste Core Strategy), in relation to mineral resource safeguarding.

The proposed site allocation VC EAR2, is located within the consultation area for safeguarded mineral extraction site, Earsham Quarry, which is only 25m from the boundary of site VC EAR2 at the closest point, with the A143 in between. The quarry has permission for mineral extraction and processing until 2040. There is currently no reference to this in either the site assessment or the site policy.

Proposed allocation site VC EAR2 also underlain by a safeguarded mineral resource, sand and gravel. However, as the site is less than 2 hectares in size, we do not consider that a policy requirement regarding investigation and prior extraction of mineral on the allocation site is necessary.

However, the allocation of the site for development without policy requirements to protect the existing mineral extraction operation is not consistent with national policy. The agent of change principle (paragraph 193 of the NPPF) would also apply.

We consider that it is appropriate and relevant for the requirements of a strategic policy (in this case Policy CS16 of the Norfolk Minerals and Waste Core Strategy) to be included in a site allocation policy where it sets out how the policy will apply to a specific site at the development management stage.

Object

Representation ID: 4020

Received: 26/09/2024

Respondent: Norfolk County Council - Minerals and Waste Team

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Norfolk County Council in its capacity as the Mineral Planning Authority considers that Policy VC DIT1 REV is currently unsound; as it is inconsistent with national policy (NPPF paragraph 218), and the adopted Development Plan in Norfolk (policy CS16 of the Norfolk Minerals and Waste Core Strategy), in relation to mineral resource safeguarding. Proposed allocation VC DIT1 REV is over 2ha in size and underlain by a safeguarded mineral resource, sand and gravel. Therefore, the allocation of the site for development without policy requirements to avoid needless sterilisation of the mineral is not consistent with national policy.

The Mineral Planning Authority recognises that reference to underlain mineral resource has been included in the supporting text, however, we request inclusion of a requirement to avoid needless sterilisation of the mineral resource in the policy itself. We consider that it is appropriate and relevant for the requirements of a strategic policy (in this case Policy CS16 of the Norfolk Minerals and Waste Core Strategy) to be included in a site allocation policy where it sets out how the policy will apply to a specific site at the development management stage.