Comment

Initial Consultation document

Representation ID: 93119

Received: 21/08/2018

Respondent: Norfolk County Council - Natural Environment Team

Representation Summary:

For MIN 77 Runs Wood Tottenhill, the initial conclusion recommends that that the site is unsuitable for allocation in accordance with Section 15 of the NPPF. I am in agreement with this conclusion, particularly as Runs Wood is not ancient woodland but is still considered important due to its high biodiversity value.

Full text:

Overall the Norfolk Minerals and Waste Local Plan is a very thorough and accurate document. My only comments are that trees have been considered under the headings of landscape or ecology throughout the document, rather than under a separate arboriculture heading. Having said this, I am happy for the document to remain as it is.

However as far as I can see, no reference has been made with regards to Arboricultural Impact Assessments (AIA) in the initial conclusions. I feel that where hedgerow trees or woodlands are adjacent to a proposed site that the offset from them needs to be determined at the very least by an annotated Tree Protection Plan or a full AIA to ensure root protection for the long term retention of the trees. For sites where an LVIA has been recommended (e.g MIN71) this would also need to include a full AIA.

For MIN45 land North of Coxford Quarry and MIN 77 Runs Wood Tottenhill, the initial conclusions recommend that that the sites are unsuitable for allocation in accordance with Section 15 of the NPPF. I am in agreement with these conclusions, particularly as Runs Wood is not ancient woodland but is still considered important due to its high biodiversity value.

MIN40 land east of Grandcourt Farm, East Winch - there appear to be trees within the proposed site at the NW corner which would have to be removed unless the site boundaries are amended. Bearing in mind that there were requirements regarding retaining veteran trees on land at Grandcourt Farm previously, I feel that an AIA would be required for this site to determine the categorisation of the trees in this area to determine if they are worthy of retention.

AOS E land to the North of Shouldham - this area encompasses a large amount of woodland centred on Shouldham Warren that when viewed from a satellite image shows that this is a large block of woodland within a largely arable landscape that forms a connecting feature with the woodland centred on West Bilney Wood to the NE. As such, although the woodland is undesignated in any way, it is a vital connecting feature within the landscape and where possible should be retained. If any of the woodland area is removed, appropriate planting of a similar size of broadleaved woodland should be included as part of the restoration scheme.

MIN115 Lord Anson's Wood near North Walsham - I would disagree that this site is suitable for allocation, in accordance with section 170b of the NPPF. The removal of this section of woodland would degrade the overall capital value, ecosystem services and recreational values provided by the woodland.

The landscape paragraph details mature trees and woodland that are to be retained and enhanced. The initial conclusion also states that a wide screen of trees is to be left around the site. I therefore propose that if this site remains allocated that a full AIA is required to achieve this and this should be listed in the initial conclusion.

MIN 92 Land east of Ferry Lane, Heckingham - I agree with the conclusion that this site is unsuitable for allocation due to the line of mature oaks in the centre of the site.

MIN 204 land north of Lodge Road Feltwell - this site is surrounded by coniferous woodland and hedgerows and would require an AIA to ensure sufficient standoff from the adjacent trees to ensure their roots are protected for their safe long term retention.