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Initial Consultation document
Representation ID: 92027
Received: 09/08/2018
Respondent: Longwater Gravel Co. Ltd.
We write to inform you that Longwater Gravel disagrees with the initial conclusion in respect of MIN 45 and would urge Norfolk County Council to reconsider its proposal not to allocate the north extension at Coxford Abbey Quarry. Norfolk County Council's adopted Minerals Site Specific Allocations Development Plan Document (Minerals SSA DPD), currently allocates the remaining minerals in the central area of Coxford Abbey Quarry, along with two extension areas to the east and south along with the north extension which is proposed to be removed. Longwater Gravel remains committed to extraction from the north extension with restoration to native woodland as it was understood that Norfolk County Council, by virtue of the allocation in the adopted Minerals SSA DPD and from informal discussion with planning officers in April 2015, that when the timing was right, i.e. when the permitted reserves at Coxford Abbey Quarry were almost exhausted, a planning application could then be submitted.
You will remember that during the Minerals SSA DPD consultation period (2008-2012), Longwater Gravel was preparing a planning application for the same area as that which is currently allocated along with an additional extension area to the west. Initial consultation drafts of the Minerals SSA DPD published in October 2009, May 2011 and February 2012 indicated that the plantation on ancient woodland site in the north extension would be included in the allocation, however in late 2012 and following advice from Norfolk County Council's ecological and landscape officers, changes were made to policy MIN 45 which ostensibly removed the north extension from the allocation. Fearing that the inclusion of the north extension in the planning application would result in a refusal of planning permission, Longwater Gravel took the decision to delete the north extension and submitted a planning application which only included the central area, along with extensions to the east, west and south.
You will also remember that during the independent examination of the Minerals SSA DPD held in March 2013, the Planning Inspector, Mr Andrew Freeman BSc (Hons) DipTP DipEM FRTPI FIHT MIEnvSc, directed Norfolk County Council to include the north extension within policy MIN 45. Unfortunately by this time the planning application for Coxford Abbey Quarry had already been submitted and it was now too late to withdraw and revise it to include the north extension. Shortly after planning permission was granted in March 2014, discussion with Norfolk County Council development control officers about the situation led to the formal submission of a request for a screening/scoping opinion for mineral extraction from the north extension, the aim being to resolve the situation by applying for planning permission for the area which had been deleted. The screening/scoping opinion was received in July 2014, NCC reference PP/C/2/2014/2007, and Longwater Gravel commenced work on the development of the application, closely following the requirements of the now adopted Policy MIN 45. At a meeting in April 2015, Longwater Gravel was advised by Norfolk County Council planning officers not to submit the application for planning permission for the north extension as it would likely result in a refusal, due to the fact that sufficient minerals were now permitted at Coxford Abbey Quarry and other sites in Norfolk and also because it was considered unlikely that the north extension could be worked within the adopted Minerals SSA DPD period (2010-2026). Longwater Gravel duly accepted and followed this advice and the planning application for the north extension was not submitted. It has therefore come as an unwelcome surprise that having reached an understanding with planning officers about the timing of an application, Norfolk County Council are now proposing to remove MIN 45 from the Minerals and Waste Sites Development Plan.
Whilst the presence of the PAWS is acknowledged, Longwater Gravel would not insist that Norfolk County Council allocate MIN 45 if the woodland was deemed to be of significant ecological or historic importance or indeed if it was an established native broadleaved woodland. It should be noted that a substantial proven sand and gravel reserve actually lies immediately to the north of the proposed MIN 45 extraction area, the majority of which is outside of the area designated as a PAWS, but as this already contains a number of mature broadleaved trees, Longwater Gravel's development proposals for MIN 45 do not include this area for mineral extraction, but do include the progressive restoration of this area by the thinning/selective felling of the conifers and additional replanting of native broadleaved woodland species trees in an effort to restore Coxford Wood.
As part of developing the application for planning permission for the north extension, a number of habitat studies have already been undertaken, all in accordance with the requirements of bullet point 1 of the adopted Policy MIN 45, i.e. 'a survey to identify any features, including soils, that remain of the ancient woodland and protection/mitigation for any features identified'. These include studies to identify the presence of flora and fauna associated with ancient woodland, e.g. bluebells, fungi, remnant tree stumps, veteran trees, etc. along with soil sampling, testing and soil germination trials. Sadly, all of these habitat studies noted a complete absence of any definitive ancient woodland indicators in the PAWS at MIN 45. Accepting that the only remaining feature of the ancient woodland is the soil, protection and mitigation, in the form of careful translocation will be proposed. The phased extraction and restoration of MIN 45 can be designed so that soils from the woodland areas can be directly placed without the need for the soil to be stored in bunds. The open arable field in the west (phase 1) would be worked and restored first with the soil from this area being placed into a soil storage bund in the main quarry. As this phase is completed, the block of woodland in the southwest, i.e. phase 2, would be felled and the soils carefully translocated onto the restored surface in phase 1. As extraction progresses, the process would be repeated until the final phase where the soils stored in the main quarry would be used to complete the restoration. Longwater Gravel plans to trial turve cutting/lifting equipment, similar to that used in heathland translocation, in order to minimise soil disturbance. Consultant ecologists will be employed to evaluate and monitor the recovery of the translocated soils, the findings from which will inform and recommend any changes in translocation technique which may be necessary. New planting will be sourced from local stock to maintain provenance and a maintenance scheme to regularly remove invasive weeds will also be implemented.
As the sand and gravel landbank for Norfolk remains well above 7 years and there are sufficient permitted reserves at Coxford Abbey Quarry to meet demand for the foreseeable future, clearly the timing for submitting a planning application for the north extension remains some way off. However, at some point before 2036, the landbank will reduce as Coxford Abbey Quarry and other sites exhaust their reserves, therefore, the proposal for an extension at an already established quarry which delivers a significant quantity of minerals for the county's needs along with a commitment to restoring Coxford Wood to a native broadleaved woodland might then be acceptable. If MIN 45 is removed from the Mineral and Waste Local Plan, then proposals for the north extension cannot even be submitted for consideration.
Longwater Gravel fully accepts that the NPPF 2018 does indeed preclude developments which lead to the loss of ancient woodland 'unless there are wholly exceptional reasons and a suitable compensation strategy exists'. However, the NPPF 2018 does give 'great weight' to minerals, recognising that they can only be worked where they are found and that they are necessary to provide the infrastructure that society needs. We would also argue that that mineral extraction is not a development which leads to the loss of irreplaceable habitats. In most if not all cases, restored mineral extraction sites create multiple benefits to biodiversity and there are numerous precedents where mineral extraction has been granted planning permission which leads to the loss of a PAWS. Hermitage Quarry in Kent and Brickworth Quarry in Wiltshire are two notable examples. In both cases, the operator has proposed large scale replanting of woodland to restore the quarry, which will create irreplaceable habitat in the long term. It is therefore not unique for Norfolk County Council to allocate and consider an application for mineral extraction from a PAWS.
Finally, I have asked both Small Fish Consulting and SLR Consulting, both of which have been involved with the development of the planning application for the north extension to submit additional responses arguing in support of the allocation of MIN 45.
We hope that Norfolk County Council will reverse its proposal not to allocate MIN 45.
Summary: Longwater Gravel should be allowed to submit a planning application for MIN 45 as we believe that we can develop a planning application which would be acceptable to Norfolk County Council (NCC). The only reason an application has not been submitted is because NCC have advised us to delay submission until the existing permitted reserves at Coxford Abbey Quarry are almost exhausted. The removal of MIN 45 would mean that the north extension would be a departure from the M&WLP and therefore a application to extract mineral and completely restore Coxford Wood could not be considered by NCC.
We write to inform you that Longwater Gravel disagrees with the initial conclusion in respect of MIN 45 and would urge Norfolk County Council to reconsider its proposal not to allocate the north extension at Coxford Abbey Quarry. Norfolk County Council's adopted Minerals Site Specific Allocations Development Plan Document (Minerals SSA DPD), currently allocates the remaining minerals in the central area of Coxford Abbey Quarry, along with two extension areas to the east and south along with the north extension which is proposed to be removed. Longwater Gravel remains committed to extraction from the north extension with restoration to native woodland as it was understood that Norfolk County Council, by virtue of the allocation in the adopted Minerals SSA DPD and from informal discussion with planning officers in April 2015, that when the timing was right, i.e. when the permitted reserves at Coxford Abbey Quarry were almost exhausted, a planning application could then be submitted.
You will remember that during the Minerals SSA DPD consultation period (2008-2012), Longwater Gravel was preparing a planning application for the same area as that which is currently allocated along with an additional extension area to the west. Initial consultation drafts of the Minerals SSA DPD published in October 2009, May 2011 and February 2012 indicated that the plantation on ancient woodland site in the north extension would be included in the allocation, however in late 2012 and following advice from Norfolk County Council's ecological and landscape officers, changes were made to policy MIN 45 which ostensibly removed the north extension from the allocation. Fearing that the inclusion of the north extension in the planning application would result in a refusal of planning permission, Longwater Gravel took the decision to delete the north extension and submitted a planning application which only included the central area, along with extensions to the east, west and south.
You will also remember that during the independent examination of the Minerals SSA DPD held in March 2013, the Planning Inspector, Mr Andrew Freeman BSc (Hons) DipTP DipEM FRTPI FIHT MIEnvSc, directed Norfolk County Council to include the north extension within policy MIN 45. Unfortunately by this time the planning application for Coxford Abbey Quarry had already been submitted and it was now too late to withdraw and revise it to include the north extension. Shortly after planning permission was granted in March 2014, discussion with Norfolk County Council development control officers about the situation led to the formal submission of a request for a screening/scoping opinion for mineral extraction from the north extension, the aim being to resolve the situation by applying for planning permission for the area which had been deleted. The screening/scoping opinion was received in July 2014, NCC reference PP/C/2/2014/2007, and Longwater Gravel commenced work on the development of the application, closely following the requirements of the now adopted Policy MIN 45. At a meeting in April 2015, Longwater Gravel was advised by Norfolk County Council planning officers not to submit the application for planning permission for the north extension as it would likely result in a refusal, due to the fact that sufficient minerals were now permitted at Coxford Abbey Quarry and other sites in Norfolk and also because it was considered unlikely that the north extension could be worked within the adopted Minerals SSA DPD period (2010-2026). Longwater Gravel duly accepted and followed this advice and the planning application for the north extension was not submitted. It has therefore come as an unwelcome surprise that having reached an understanding with planning officers about the timing of an application, Norfolk County Council are now proposing to remove MIN 45 from the Minerals and Waste Sites Development Plan.
Whilst the presence of the PAWS is acknowledged, Longwater Gravel would not insist that Norfolk County Council allocate MIN 45 if the woodland was deemed to be of significant ecological or historic importance or indeed if it was an established native broadleaved woodland. It should be noted that a substantial proven sand and gravel reserve actually lies immediately to the north of the proposed MIN 45 extraction area, the majority of which is outside of the area designated as a PAWS, but as this already contains a number of mature broadleaved trees, Longwater Gravel's development proposals for MIN 45 do not include this area for mineral extraction, but do include the progressive restoration of this area by the thinning/selective felling of the conifers and additional replanting of native broadleaved woodland species trees in an effort to restore Coxford Wood.
As part of developing the application for planning permission for the north extension, a number of habitat studies have already been undertaken, all in accordance with the requirements of bullet point 1 of the adopted Policy MIN 45, i.e. 'a survey to identify any features, including soils, that remain of the ancient woodland and protection/mitigation for any features identified'. These include studies to identify the presence of flora and fauna associated with ancient woodland, e.g. bluebells, fungi, remnant tree stumps, veteran trees, etc. along with soil sampling, testing and soil germination trials. Sadly, all of these habitat studies noted a complete absence of any definitive ancient woodland indicators in the PAWS at MIN 45. Accepting that the only remaining feature of the ancient woodland is the soil, protection and mitigation, in the form of careful translocation will be proposed. The phased extraction and restoration of MIN 45 can be designed so that soils from the woodland areas can be directly placed without the need for the soil to be stored in bunds. The open arable field in the west (phase 1) would be worked and restored first with the soil from this area being placed into a soil storage bund in the main quarry. As this phase is completed, the block of woodland in the southwest, i.e. phase 2, would be felled and the soils carefully translocated onto the restored surface in phase 1. As extraction progresses, the process would be repeated until the final phase where the soils stored in the main quarry would be used to complete the restoration. Longwater Gravel plans to trial turve cutting/lifting equipment, similar to that used in heathland translocation, in order to minimise soil disturbance. Consultant ecologists will be employed to evaluate and monitor the recovery of the translocated soils, the findings from which will inform and recommend any changes in translocation technique which may be necessary. New planting will be sourced from local stock to maintain provenance and a maintenance scheme to regularly remove invasive weeds will also be implemented.
As the sand and gravel landbank for Norfolk remains well above 7 years and there are sufficient permitted reserves at Coxford Abbey Quarry to meet demand for the foreseeable future, clearly the timing for submitting a planning application for the north extension remains some way off. However, at some point before 2036, the landbank will reduce as Coxford Abbey Quarry and other sites exhaust their reserves, therefore, the proposal for an extension at an already established quarry which delivers a significant quantity of minerals for the county's needs along with a commitment to restoring Coxford Wood to a native broadleaved woodland might then be acceptable. If MIN 45 is removed from the Mineral and Waste Local Plan, then proposals for the north extension cannot even be submitted for consideration.
Longwater Gravel fully accepts that the NPPF 2018 does indeed preclude developments which lead to the loss of ancient woodland 'unless there are wholly exceptional reasons and a suitable compensation strategy exists'. However, the NPPF 2018 does give 'great weight' to minerals, recognising that they can only be worked where they are found and that they are necessary to provide the infrastructure that society needs. We would also argue that that mineral extraction is not a development which leads to the loss of irreplaceable habitats. In most if not all cases, restored mineral extraction sites create multiple benefits to biodiversity and there are numerous precedents where mineral extraction has been granted planning permission which leads to the loss of a PAWS. Hermitage Quarry in Kent and Brickworth Quarry in Wiltshire are two notable examples. In both cases, the operator has proposed large scale replanting of woodland to restore the quarry, which will create irreplaceable habitat in the long term. It is therefore not unique for Norfolk County Council to allocate and consider an application for mineral extraction from a PAWS.
Finally, I have asked both Small Fish Consulting and SLR Consulting, both of which have been involved with the development of the planning application for the north extension to submit additional responses arguing in support of the allocation of MIN 45.
We hope that Norfolk County Council will reverse its proposal not to allocate MIN 45.