Support

Representation ID: 92023

Received: 09/08/2018

Respondent: Longwater Gravel Co. Ltd.

Agent: Small Fish

Longwater Gravel Ltd would like to confirm that it does agree with the initial conclusion to allocate Min13/Min51. In support of this opinion, Longwater Gravel would like to draw attention to the following points in relation to the emerging policies.

Policy MP2: Spatial Strategy for mineral extraction
Specific sites for sand and gravel or carstone extraction should be located within 10 miles of one of Norfolk's urban areas or main towns (detailed in the supporting text) and/or be well-related to one of Norfolk's urban areas or main towns via appropriate transport infrastructure - Dereham is classed as a main town and the site is connected to Dereham via the Fakenham Road B1146 HGV route, with Dereham being only 4.5km away. Furthermore, Fakenham is only 11km away via the B1146 and this is also a main town.

Policy MP5: Core River Valleys
The Sites are not in a core river valley.

Policy MP6: Cumulative impacts and phasing of workings
There has been concern in the past that the cumulative impacts of operating Min 13 and Min 51 at the same time could be unacceptable.

Policy MP6 makes it clear it is down to the applicant to, "demonstrate that the adverse cumulative impacts can be adequately mitigated" as part of a future planning application. Longwater Gravel is confident that this can be demonstrated. Combined, or cumulatively, the estimated extraction rate will be 70,000 tonnes per annum. This low rate of extraction has been chosen with a view to minimising any cumulative impact. For example, the low extraction rate of 70,000 tonnes generates only 10 HGV out movements per day between the sites, which is around one per hour. As these will almost immediately join the B1146 HGV route which carries a large volume of traffic, the increase is unlikely to be noticeable. Other cumulative impacts of the sites will be assessed as the application is development, such as through the dust and noise assessments.

It should be noted that the extraction rate chosen is lower than the extraction rate of many other potential sites; Min 12 (80,000), Min 35 (80,000) Min 201 (200,000 to 250,000), Min 202 (140,000), Min 37 (85,000), Min 65 (200,000), Min 96 (150,000), Min 38 (85,000 to 120,000), Min 06 (80,000), Min 45 (100,000) etc. Compared to these single sites, the cumulative impacts of Min 13 and Min 51 will be relatively modest.


This acceptability will be demonstrated by the future planning application.

Policy MP7: Progressive working, restoration and after-use and Policy MP8: Aftercare
The site is proposed to be restored at a lower level and returned to arable agricultural. Due to the expected depth of extraction, it is likely that restoration to arable will require the use of imported inert material to provide a suitable profile. Lagoons are likely to be retained as ponds with planting to create wet woodland habitat. Hedgerow interspersed with oaks will be planted along the northern boundary alongside Rawhall Lane. There should therefore be some longer term ecological benefits. The application will be accompanied by an after-care plan.

Policy MW2: Development Management Criteria
The sites are in compliance with emerging Policy MW2: Development Management Criteria. For ease of reference, these criteria are set out below with comments against each one.
a. Local amenity and health (including noise levels, odour, air quality, dust, litter, light pollution and vibration) - There should be no unacceptable amenity impacts given the distances to the nearest properties. Longwater Gravel will however, prepare both dust and noise assessments and undertake any proposed mitigation measures as part of a future planning application.
b. The quality of surface waterbodies and groundwater, with particular regard to preventing the deterioration of their existing status, and the quantity of water for resource purposes within water bodies - There will be no impact on hydrogeology or water resources as it will be worked dry. There will be no impact on watercourses such as the Blackwater because of distances and drainage. The minerals will be processed on site and so the sand and gravel to be processed will not be transported across the nearby watercourses.
c. The capacity of existing drainage systems - The site is not in an Internal Drainage Board area.
d. Pluvial and fluvial flood risk - There are no concerning flood risk issues given the land use proposed.
e. The best and most versatile agricultural land - Being Grade 3, the land is not the best and most versatile.
f. Aircraft safety due to the risk of bird strike and/or building height and position - The site is not within an aerodrome safeguarding zone.
g. The safety and capacity of the road and any other transport network - Highway access from the site should be satisfactory and an appropriate financial contribution to the B1146 Fakenham Road/Rawhall Lane junction improvements will be made if required to make the proposal acceptable in planning terms.
h. The appearance, quality and character of the landscape, countryside and visual environment and any local features that contribute to its local distinctiveness - The site is not in or near any landscape designations. The site is fairly flat and would be relatively easy to screen from views from surrounding roads and properties. The site contains interesting landscape features; the internal hedgerow oaks and the block of woodland and rough grass lie within the centre of the site are notable features in this open landscape and these will be protected by a the working scheme. A low level restoration scheme to arable agriculture with appropriate wide field margins and additional woodland should be acceptable in landscape terms and will result in a landscape gain.
i. Public Open Space, the definitive Public Rights of Way network and outdoor recreation facilities - There will be no impact on any of these assets.
j. Land stability - There are no issues regarding land stability.
k. The natural and geological environment (including internationally, nationally or locally designated sites and irreplaceable habitats) - Nature conservations designations will not be affected, especially given the stand-off distances and the quarry being worked dry. Restoration will be back to agricultural use, although this will include ensuring a long-term ecological gain. Lagoons will be retained as ponds with planting to create wet woodland habitat and hedgerow interspersed with oaks will be planted along the northern boundary alongside Rawhall Lane. Additional woodland will also be provided. Potential impacts on geodiversity will be assessed and appropriate mitigation identified as part of any future application. The application is likely to propose retaining some open faces for scientific study during the operational stages, and potentially after restoration providing this does not detract from the character of the area. Longwater Gravel will suggest a 'watching brief' is used during the extraction phase in case features of potential geodiversity interest are uncovered.
l. The historic environment, including heritage and archaeological assets and their settings - There should be no unacceptable impact on any of the heritage assets in the surrounding area, but Longwater Gravel will ensure that the planning application is accompanied by a Heritage Statement which will assess the potential for impacts and identify appropriate mitigation measures if required. There is the potential that unknown archaeology exists on the site and an assessment of the significance of archaeological deposits will be carried out at the planning application stage. It is recognised that the archaeology assessment may initially be desk-based but may need to be followed up with field surveys and trial-trenching.
m. The character and quality of the area, in which the development is situated, through poor design - Long term the character of the area will be retained if not enhanced through a high quality restoration scheme. In the short term some screening will likely be required during working, although key features that add to the character of the area such as the hedgerow oaks and the block of woodland will be protected by the working scheme.

Policy MW3: Transport
The sites are in compliance with emerging Policy MW3: Transport. For ease of reference, these criteria are set out below with comments against each one.
All proposals for minerals development or waste management facilities must assess and consider positively the potential for non-HGV transportation of materials to and from the facilities, principally by rail or water - this potential will be assessed, but given the absence of such facilities nearby such as rail sidings, the current assumption is that this will be unlikely.
a) Unacceptable risks to the safety of road users and pedestrians - The proposed highway access into the sites using Rawhall Lane is considered to be suitable by the Highway Authority and an appropriate financial contribution to the B1146 Fakenham Road/Rawhall Lane junction improvements will be made if required to make the proposal acceptable in planning terms.
b) Unacceptable impacts on the capacity and/or efficiency of the highway network (including the trunk road network). There are no capacity issues on the local road network.
c) Unacceptable impacts on air quality (particularly in relation to any potential breaches of National Air Quality Objectives and impacts on any Air Quality Management Areas) - The site is not in or near an Area Quality Management Area.
d) Unacceptable physical impacts on the highway network (e.g. road or kerbside damage) - The Fakenham Road is a designated lorry route and so suitable for HGV traffic. The short route to the Fakenham Road is a metaled adopted road and is wide enough for two-HGVs to pass and a new site access junction with Rawhall Lane will be created in accordance with design standards.
Any future planning application will be accompanied by either a Transport Statement or Transport Assessment, this being agreed with the Highway Authority in advance. This will show that:
* Suitable highway access and egress on Rawhall Lane can be achieved in accordance with published highway design guidance;
* That there is a short and suitable route to the nearest major road, this being the Fakenham Road and Longwater Gravel is content that this will be captured in a Routing Agreement if required;
* The application has considered the needs and safety of other road users, including cyclists, horse riders and pedestrians; and
* Appropriate and realistic measures to reduce car travel to the site by workers and visitors will be implemented.

Policy MW5: The Brecks Protected Habitats and Species
The sites are not in the Special Protection Area SPA or the Stone Curlew buffer zone

Policy MW6: Agricultural soils
The soil is Grade 3. It is not known at the moment whether this is Grade 3a or 3b. This will be determined during the development of a future planning application. If it is Grade 3a then a suitable soil handling management plan will be developed as part of the application. Restoration will be to agricultural land and so there will, in the long-term, be no loss to agriculture.

Summary: The combined site is in a good location for mineral extraction, being close to appropriate transport infrastructure and main towns. There appear to be few if any constraints, such as amenity or nature conservation designations, although impacts will be assessed where appropriate, such as through noise and dust assessments. The low extraction rate should make any cumulative impacts acceptable, although this will also be thoroughly assessed during the application. In addition to the benefit of extracting sand and gravel to support the construction sector, there will be additional ecological and landscape gains upon restoration.