Regulation 18 draft Local Plan

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Object

Regulation 18 draft Local Plan

Policy EN3 - Biodiversity Net Gain

Representation ID: 5254

Received: 03/01/2024

Respondent: Heidelberg Materials UK

Representation Summary:

The requirement for 15% BNG conflicts with national requirement of 10% as stipulated by Government. Policy EN3 also conflicts with Policy MIN9. Policy MIN9 does not stipulate a % in the policy wording but in the supporting text refers to 10%. To provide consistency suggest Policy EN3 is amended to require at least 10%.


Our response:

Comments noted. Change from 15% to 10% as a higher percentage than the statutory objective of biodiversity net gain needs to be evidenced. In order for the Local Plan to be deemed sound this uplift above the mandatory level must be robustly evidenced.

Agree that there must be consistency between Policies EN3 and MIN9.

Object

Regulation 18 draft Local Plan

Chapter 2 – Spatial Portrait

Representation ID: 5257

Received: 03/01/2024

Respondent: Heidelberg Materials UK

Representation Summary:

Economy paragraph 2 refers to Hanson Cement. In October 2023 Hanson re-branded to Heidelberg Materials. Please therefore replace 'Hanson Cement' with 'Heidelberg Materials'


Our response:

This has been noted and will be updated in the Regulation 19 version of the plan.

Support

Regulation 18 draft Local Plan

Policy MIN1 - Spatial strategy for minerals development

Representation ID: 5388

Received: 04/01/2024

Respondent: Heidelberg Materials UK

Representation Summary:

Ketton Cement Works is an important facility at a national, regional, and local level. It supplies c15% of the UK cement demand, and is a major employer in the county. A planning application for two new quarry extension areas (both within the AoS) is due to be submitted to RCC in the coming weeks, which seeks to secure the long term future of the Cement Works.


Our response:

Noted.

Object

Regulation 18 draft Local Plan

Policy MIN2 - Mineral provision

Representation ID: 5398

Received: 04/01/2024

Respondent: Heidelberg Materials UK

Representation Summary:

With ongoing and future major investment at Ketton Cement Works the company will be seeking to secure at least 25 years of additional mineral reserves. Suggest penultimate paragraph is revised to read 'A stock of permitted reserves of at least 15 years for cement primary and secondary materials (limestone and clay) will be sought to maintain an existing plant, and at least 25 years where major investment is required for new plant or the maintenance and improvement of existing plant and equipment". To better reflect para 220 of the NPPF.


Our response:

Agreed. Amend paragraphs to reflect the requirements of paragraph 220 of the NPPF and footnote 78.

Object

Regulation 18 draft Local Plan

Policy MIN4 - Development criteria for mineral extraction

Representation ID: 5400

Received: 04/01/2024

Respondent: Heidelberg Materials UK

Representation Summary:

MIN4 (b.ii) refers to ‘adopted cement production rate’ but the Local Plan does not appear to define what that is with any clarity. NPPF 220 requires the planning authority to provide a steady and adequate supply of industrial minerals. NPPF footnote 78 notes only the minimum reserve levels to be provided and does not seek to limit what that might be. Reference to an adopted production rate does not therefore accord with national policy. MIN 4 should be amended to remove references to the ‘adopted cement production rate’.


Our response:

Agreed. Remove reference to the ‘adopted cement production rate’ in the Local Plan. Amend text.

Object

Regulation 18 draft Local Plan

Policy MIN6 - Safeguarding of minerals development

Representation ID: 5402

Received: 04/01/2024

Respondent: Heidelberg Materials UK

Representation Summary:

Policy should be strengthened to provide clarity that Ketton Cement Works should be safeguarded. As such safeguarding should include the whole of the Cement Works including the factory and kilns that convert the minerals into final products such as cement and downstream products like bagged cement / concrete products etc, the facilities to distribute the mineral products, and ancillary facilities e.g. fuel storage; rail loading facility and sidings link to the cement works.


Our response:

Policy MIN6 sets out the need to safeguard existing mineral sites. Include the safeguarding of facilities that handle, process, and distribute cement. Amend MIN6 wording.

Support

Regulation 18 draft Local Plan

Strategic objective 11:

Representation ID: 5403

Received: 04/01/2024

Respondent: Heidelberg Materials UK

Representation Summary:

Important that minerals are recognised as a strategic objective as they are a critical component in delivery of other objectives of the Plan. Supply must not be assumed.


Our response:

Support noted.Policy MIN2 (Chapter 10) recognises the importance of providing a steady and adequate supply of minerals over the Plan period.

Object

Regulation 18 draft Local Plan

Appendix 6 – Permitted sites for mineral extraction and recycling aggregates

Representation ID: 5411

Received: 04/01/2024

Respondent: Heidelberg Materials UK

Representation Summary:

The end date of the planning permission for Grange Top quarry, Ketton is 31/12/2032 (not 31/12/2026).


Our response:

Noted.

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