Savills have been instructed by Hugh Crane Limited to make representations to the Greater Norwich Local Plan (GNLP) Main Modifications consultation, which runs from 25th October to midday on 6th December 2023.

Hugh Crane Limited are a landowner of a major part of the proposed allocation to the west of Acle - Policy GNLP0378R/GNLP2139R (Lane West of Acle).

Overall support is given to the proposed Main Modifications of the GNLP.

Further support is expressed for the proposed Main Modifications to Policy GNLP0378R/GNLP2139R (Land West of Acle).

Hugh Crane Limited, alongside Norfolk County Council are committed to meeting the requirements of Policy GNLP0378R/GNLP2139R and the delivery of the site within the proposed plan period, with the pragmatic involvement of all necessary parties.

Norfolk County Council as the Mineral and Waste Planning Authority wish to raise the following objections regarding the proposed Main Modifications to the Greater Norwich Local Plan.

Main Modifications relating to Safeguarded Mineral Resource, Mineral Infrastructure or Waste Management site.

We note that in the main modifications the policy text regarding safeguarded mineral resources and safeguarded sites is proposed to be removed from all of the relevant site allocation policies and moved into the supporting text. This affects over 30 allocated sites. We understand that this change was proposed by the Inspector because he considered that the current text was not a policy requirement and was simply signposting to another policy of the development plan and as a result was unsound. We disagree with this approach and consider that it is, and should be, an allocation policy requirement to ensure that safeguarded mineral resources are not sterilised by non-mineral development where this could be avoided. We are therefore objecting to the removal of the reference to mineral safeguarding from the site allocation policy wording. The affected policies were not unsound when they included the mineral safeguarding requirement, therefore the modifications proposed to remove the mineral safeguarding requirement are not required to make the document sound.

We consider that it is appropriate and relevant for the requirements of a strategic policy, in this case Policy CS16 within 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. We accept that including this wording as a cross reference to Policy CS16 may not be the most appropriate way to include this information in the site allocation policies and therefore we have proposed alternative policy wording which we consider addresses the Inspector's concerns.

Removing the mineral safeguarding requirement from the site policies would be unsound because it would not be in accordance with the NPPF (paragraph 212) which states that local planning authorities should not normally permit other development proposals in Mineral Safeguarding Areas if it might constrain potential future use for mineral working. Further information is provided in the NPPG paragraph 005 Reference ID: 27-005-20140306.

For site located in proximity to existing safeguarded mineral infrastructure or waste management facilities, the agent of change principle (NPPF paragraph 187) is also relevant.

We consider that for the sites that are underlain by safeguarded mineral resource the policy wording should state: "This site is underlain by a safeguarded mineral resource; therefore investigation and assessment of the mineral will be required, potentially followed by prior extraction to ensure that needless sterilisation of viable mineral resource does not take place."

Relevant sites:
MM69/70 Policy COL1/GNLP0331BR/GNLP0331CR
MM78 Policy GNLP0307/GNLP0327
MM81 Policy EAS1
MM83 Policy HEL2
MM87 Policy GNLP0132
MM88 Policy 0337R
MM110 Policy HET1 (part of GNLP0177A)
MM137 Policy HNF2/GNLP0466R
MM26 Policy GNLP0133DR
MM40 Policy CC4a
MM52 Policy R1
MM62 Policy R30
MM63 Policy R31
MM64 Policy R36
MM65 Policy R37
MM71 Policy COL2 (GNLP0140C)
MM79 Policy KES2 (including GNLP0497)
MM82 Policy HEL1
MM85 Policy GNLP0172
MM89 Policy GNLP0159R
MM90 Policy TROW1
MM111 Policy HET2
MM118 Policy POR3
MM119 Policy REP1
MM122/MM124 Policy GNLP0293/CAW2
MM130 Policy FOU2
MM148 Policy BKE3
MM72 Policy GNLP0253
Plus the following sites where the policy in the pre submission GNLP document did not include a safeguarding requirement:
MM80 Policy DRA1
MM103 Policy GNLP0378R/GNLP2139R
MM115 Policy 0312
MM116 Policy GNLP0463R
MM92 GNLP0596R

We consider that for the site that is within a mineral infrastructure site consultation area the policy wording should state: "The site is within the consultation area for safeguarded mineral infrastructure; therefore, the development must not prevent or prejudice the use of the existing safeguarded infrastructure for those purposes unless suitable alternative provision is made, or the applicant demonstrates that the site no longer meets the needs of the aggregate industry."

Relevant site:
MM48 Policy CC16

We consider that for the sites that are within a waste management site consultation area the policy wording should state: "The site is within the consultation area for a safeguarded waste management facility; therefore, the development must not prevent or prejudice the use of the existing waste management facility unless suitable alternative provision is made, or the facility is demonstrated to no longer be required."

Relevant sites:
MM74 Policy COS3/GNLPSL2008
MM100 Policy HETHEL2
Plus the following sites where the policy in the Pre Submission GNLP document did not include a safeguarding requirement:
AYL3
AYL4

Representations in relation to MM8, MM9 and various sites
See full submission attached for more details