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Initial Consultation document

Representation ID: 92916

Received: 23/08/2018

Respondent: Environment Agency

Representation Summary:

With regards to ecology at MIN 38, our main concern about a mineral extraction site at this location would be the impact of poor water quality, as a result of runoff and dust from the site, entering the adjacent wetland habitat. The coastal grazing marsh between the River Waveney and the boundary of the site contains habitat for protected species such as water vole, Norfolk Hawker and the narrow mouthed whorl snail. The narrow mouthed snail is a NERC species of principle importance with specific habitat requirements, often limited to fringing coastal marsh habitat as found at the at MIN38. We would have concerns about issuing a permit for a development which may have the potential to impact a NERC species or their habitat. Due to the close proximity to priority habitat and species records, dust mitigation measures may be insufficient to prevent loss.

As such the suitability of this site for mineral extraction is still of concern.

Full text:

I've asked our teams for further guidance relating to SIL 02, and can now provide the following advice relating to effects on groundwater and the River Nar.

The site is partially located within an SPZ1 and therefore we may not consider it suitable for mineral extraction. The site is also bound by surface water abstractors as well as groundwater abstractions located adjacent to or on site. If it is taken forward as a site it would have to be worked wet (no de-watering licence would be issued) with strict planning conditions.

As the River Nar SSSI is a groundwater fed chalk river and has the characteristics of a lowland fen river in the lower reaches it is very important that the river is protected from adverse impacts as a result of any form of mineral extraction and associated workings. An assessment of potential impacts on the groundwater as well as surface water would be required as well as the need to show no adverse impacts on the ecology and fish populations of the river. Natural England should be consulted on any proposals likely to impact the SSSI.

With regards to ecology at MIN 38, our main concern about a mineral extraction site at this location would be the impact of poor water quality, as a result of runoff and dust from the site, entering the adjacent wetland habitat. The coastal grazing marsh between the River Waveney and the boundary of the site contains habitat for protected species such as water vole, Norfolk Hawker and the narrow mouthed whorl snail. The narrow mouthed snail is a NERC species of principle importance with specific habitat requirements, often limited to fringing coastal marsh habitat as found at the at MIN38. We would have concerns about issuing a permit for a development which may have the potential to impact a NERC species or their habitat. Due to the close proximity to priority habitat and species records, dust mitigation measures may be insufficient to prevent loss.

As such the suitability of this site for mineral extraction is still of concern.

We hope these comments can be taken into account, and please do not hesitate to contact me if you have further queries.