Object

Preferred Options consultation document

Representation ID: 98026

Received: 28/10/2019

Respondent: Peter Loudoun

Representation Summary:

Below are my objections to the proposed Mineral site MIN116 (Breckland). I uphold the current view that the site is unsuitable but the reasons given in the plan are incomplete and must be updated to include the objections from myself and others in this stage of the review.

1. Reference Information
1.1. Health Hazards
Industry Standard dictates: "Smaller dust particles remain airborne for longer, dispersing widely and depositing more slowly over a wider area. Large dust particles (greater than 30 μ m), which make up the greatest proportion of dust emitted from mineral workings, will largely deposit within 100m of sources. Intermediate-sized particles (10-30 μ m) are likely to travel up to200-500m. Smaller particles (less than 10 μ m) which make up a small proportion of the dust emitted from most mineral workings, are only deposited slowly but may travel 1000m or more".

1.2. Department of Environment Guidance on Planning for Quarries (including Gravel and Sand extraction)
3.3 Dust deposition/air quality
As in the case of noise, there are numerous sources of dust generation within quarries, including the stripping of topsoil, the excavation of sand and gravel, the crushing and screening of aggregates, ancillary activities such as concrete mixing, and the transport of sand, gravel and finished products (point emissions). Wind can carry dust particles well beyond the site boundaries, and fine materials from lorries can be deposited along public roads (fugitive emissions).
Residents living in proximity to quarries can potentially be affected by dust up to 0.5km from the source, although continual or severe concerns about dust are most likely to be experienced within about 100m of the dust source. The main potential impacts of dust are visual impacts, coating/soiling of property (including housing, washing, and cars), coating of vegetation, contamination of soils, water pollution, change in plant species composition, loss of sensitive plant species, increased inputs of mineral nutrients and altered pH balances. Respirable particles, i.e. those less than 10 micrometers in diameter, have the potential to cause effects on human health, depending on exposure levels.

3.4 Water supplies and groundwater
The quantity, and physical and chemical quality, of surface waters and groundwaters may be affected by quarrying activities; flows can be increased or decreased and may be contaminated by runoff or dust from the quarry. The removal of topsoil, overburden and aggregates may affect the quality of water recharging of an aquifer, and excavation below the water table may lead to de-watering of adjacent watercourses and wells.


2. Objections Relating to the approval of Site MIN 116 - land at Woodrising Road, Cranworth

2.1. Location Devastation
This is not a brownfield site, or wasteland, its not grassland or scrubland. This is Greenfield and Prime Agricultural land, of high grade, that is farmed annually. The landscape will be permanently and irreplaceably scarred. Locals for many miles will have to put up with the noise, dust, and increased HGVs. The site is next to a Public Right of Way and a Bridleway which are the only public access in an area of natural beauty and wildlife. Consideration should also be given to the diminishing areas of unspoilt natural beauty and wildlife as this is one of the few such areas still remaining.
2.1.1. The site is bounded by restricted byway and bridleway which represents only local off-road access to the countryside.
2.1.2. The area is rich in wildlife and plants which includes Red Kites, Buzzards, Skylarks, Deer, Hares, Bats and Hobbys. These will be adversely affected by the dust and noise from the proposed site.
2.1.3. This is at one of the higher points in the areas with beautiful far reaching views. These views will be ruined by the proposed site.
2.1.4. The area surrounding the proposed site is a popular local amenity and used by walkers, horse riders, cyclists, runners and dog walkers. People come from many of the surrounding villages and the town of Hingham. The noise, dust and traffic would be detrimental to these activities.
2.1.5. Mineral extraction at this site would have unacceptable local landscape impacts and screening and bunding could be intrusive in its own right. Whilst it may be possible to mitigate adverse landscape impacts through advance planting and bunding, this is uncertain and there are more acceptable alternative sites for sand and gravel extraction proposed in the Plan.
2.1.6. Due to the higher elevation of the proposed site, waste water from the extraction process may pollute the lower water sources which will affect homes, wildlife, plants and trees.
2.1.7. Widening the lanes would not be possible without removing many mature oak trees and hedging that line the routes. Trees lining Woodrising Road are often damaged by passing machinery/large vehicles. Removal of hedging is detrimental to wildlife habitat.

2.2. Health Hazards
The Reference Information identifies the following risks. These include a number of risks to life.
2.2.1. Risk to the quality of adjacent water sources. This would not only affect wildlife and plants/vegetation but will also affect the many properties in the area that rely on Bore Holes as their only source of water due to the lack of piped water.
2.2.2. The main potential impacts of dust are visual impacts, coating/soiling of property (including housing, washing, and cars), coating of vegetation, contamination of soils, water pollution, change in plant species composition, loss of sensitive plant species, increased inputs of mineral nutrients and altered pH balances. Respirable particles, i.e. those less than 10 micro meters in diameter, have the potential to cause effects on human health, depending on exposure levels.
2.2.3. The effect of Respirable particles on residents taking Immune Suppressant drugs is unknown but like to have a greater impact. [Redacted text - personal data].
2.2.4. The risk to the health of animal, birds, bats and water wildlife will increase due to dust, noise pollution and increased traffic.
2.2.5. The run off of water used in the extraction process may pollute the local water, used in the bore holes, of the properties within 500 metres of the site. This may be detrimental to the health of the residents.

2.3. Highways
The proposal for site MIN116 indicates that the site would use the C159 Wood Rising Road east to the B1108 Watton Road. It is my experience that HGVs and other large vehicles utilise the shortest route to their destination, usually influenced by Satnav. This would result in the Quarry traffic taking routes that would take heavy vehicles through Cranworth, Shipdham (coming out at the junction with A1075 opposite the church or going past the school, Scoulton, Southburgh (including Pye Lane, River Lane) and the unnamed lane past Hurdlemakers Cottage.

2.3.1. Woodrising Road from the proposed site is unsuitable for HGVs. The Woodrising Road to Frost Row is substandard and would deteriorate quickly with the additional traffic, especially at passing places, many of which are not official passing places and not maintained.
2.3.2. The increased heavy traffic and other traffic will increase the risk of injury and death to pedestrians, cyclists, horse riders, runners and joggers as there are no footpaths.
2.3.3. The exit from Woodrising Road to B1108 at Frost Row is dangerous with restricted views of oncoming traffic restricted by a bend on B1108 and the angle of the road exit. The B1108 has a maximum speed limit of 60mph at the junction with Woodrising Road.
2.3.4. There is no way of restricting HGVs visiting the site from using the rural roads through villages such as Southburgh, Woodrising and Cranworth. HGVs are likely to go through Shipdham, using the exits to A1075 at the Church or going past the school.
2.3.5. Increased traffic, not only the HGVs distributing the Sand and Gravel but also extra vehicles for the daily workforce, site service vehicles and non-site vehicles collecting sand and gravel.
2.3.6. Increased Heavy Goods traffic through Hingham and its surrounding roads will have an adverse effect on the structure (roads and buildings) and safety within the town.
2.3.7. Many of the local properties are old and made from Clay Lump and have flint or brick footings rather than foundations. Vibration from heavy traffic and mining machinery may have an adverse effect on these properties.
2.3.8. Once the extraction of minerals is complete there will be additional heavy traffic infilling the site in order to return it to agricultural use. This will also have a significant impact.
2.3.9. The local roads are regularly used as crossing points for individual and herds of deer. Increased traffic will increase the probability of accidents resulting in the death or injury to deer and the resulting damage to vehicles.

2.4. Local Impact
2.4.1. The plan gives recognition to properties within 250 metres of the proposed site and recognises two properties; Hurdlemakers Cottage and Grove Farm. Grove Farm is incorrectly defined as it now is made up of two properties - Grove Farmhouse and Grove Farm Barn. The plan needs to be corrected.
2.4.2. The Norfolk County Council Infrastructure and Development Select Committee, when considering the plan, stated that "Members were concerned that the consultation distance of 250 metres was not far reaching enough especially when some of the proposed sites are in locations which had not experienced anything similar before. The sites had the potential to affect whole communities, some of which are further away than 250 metres from the proposed site". The concern of members has not been reflected in the plan.
2.4.3. Many more properties are within 500 to 750 metres of the proposed site, including a school. Kingsbrook School is a specialist residential mixed gender therapeutic school for students aged 11 to 18 years with complex needs. These include mental health and associated difficulties, for example, behavioural, emotional and social difficulties. Some of their young people will also have developed specific needs due to a range of factors including trauma, post-traumatic stress disorder or attachment disorder. The noise, dust and increased heavy traffic would have a detrimental effect on vulnerable young people.
2.4.4. Ditch water from the Grove Farm properties and the field behind them drains into the land adjacent to the proposed site. The effects of the proposed site on drainage would need to be reviewed.
2.4.5. The mineral extraction process will use a large amount of water which is likely to be extracted by borehole. This is likely to be detrimental to the many properties in the area rely on bore holes as their only supply of water. This may make water unavailable to some homes.

Full text:

Please find attached my objections to the inclusion of site MIN116 Woodrinsing Road, Cranworth in the Preferred Options of the Minerals and Waste Local Plan. I uphold the view that the site is unsuitable but the reasons given in the plan are incomplete and must be updated to include the objections from myself and others in this stage of the review.

Please also note that on your website, under the chapter What Happens Next para e) Examination Hearings (January 2020), I believe the entry should read "January 2021) as per the following paragraph f).

Minerals and Waste Local Plan Review: Preferred Options

Below are my objections to the proposed Mineral site MIN116 (Breckland). I uphold the current view that the site is unsuitable but the reasons given in the plan are incomplete and must be updated to include the objections from myself and others in this stage of the review.

1. Reference Information
1.1. Health Hazards
Industry Standard dictates: "Smaller dust particles remain airborne for longer, dispersing widely and depositing more slowly over a wider area. Large dust particles (greater than 30 μ m), which make up the greatest proportion of dust emitted from mineral workings, will largely deposit within 100m of sources. Intermediate-sized particles (10-30 μ m) are likely to travel up to200-500m. Smaller particles (less than 10 μ m) which make up a small proportion of the dust emitted from most mineral workings, are only deposited slowly but may travel 1000m or more".

1.2. Department of Environment Guidance on Planning for Quarries (including Gravel and Sand extraction)
3.3 Dust deposition/air quality
As in the case of noise, there are numerous sources of dust generation within quarries, including the stripping of topsoil, the excavation of sand and gravel, the crushing and screening of aggregates, ancillary activities such as concrete mixing, and the transport of sand, gravel and finished products (point emissions). Wind can carry dust particles well beyond the site boundaries, and fine materials from lorries can be deposited along public roads (fugitive emissions).
Residents living in proximity to quarries can potentially be affected by dust up to 0.5km from the source, although continual or severe concerns about dust are most likely to be experienced within about 100m of the dust source. The main potential impacts of dust are visual impacts, coating/soiling of property (including housing, washing, and cars), coating of vegetation, contamination of soils, water pollution, change in plant species composition, loss of sensitive plant species, increased inputs of mineral nutrients and altered pH balances. Respirable particles, i.e. those less than 10 micrometers in diameter, have the potential to cause effects on human health, depending on exposure levels.

3.4 Water supplies and groundwater
The quantity, and physical and chemical quality, of surface waters and groundwaters may be affected by quarrying activities; flows can be increased or decreased and may be contaminated by runoff or dust from the quarry. The removal of topsoil, overburden and aggregates may affect the quality of water recharging of an aquifer, and excavation below the water table may lead to de-watering of adjacent watercourses and wells.


2. Objections Relating to the approval of Site MIN 116 - land at Woodrising Road, Cranworth

2.1. Location Devastation
This is not a brownfield site, or wasteland, its not grassland or scrubland. This is Greenfield and Prime Agricultural land, of high grade, that is farmed annually. The landscape will be permanently and irreplaceably scarred. Locals for many miles will have to put up with the noise, dust, and increased HGVs. The site is next to a Public Right of Way and a Bridleway which are the only public access in an area of natural beauty and wildlife. Consideration should also be given to the diminishing areas of unspoilt natural beauty and wildlife as this is one of the few such areas still remaining.
2.1.1. The site is bounded by restricted byway and bridleway which represents only local off-road access to the countryside.
2.1.2. The area is rich in wildlife and plants which includes Red Kites, Buzzards, Skylarks, Deer, Hares, Bats and Hobbys. These will be adversely affected by the dust and noise from the proposed site.
2.1.3. This is at one of the higher points in the areas with beautiful far reaching views. These views will be ruined by the proposed site.
2.1.4. The area surrounding the proposed site is a popular local amenity and used by walkers, horse riders, cyclists, runners and dog walkers. People come from many of the surrounding villages and the town of Hingham. The noise, dust and traffic would be detrimental to these activities.
2.1.5. Mineral extraction at this site would have unacceptable local landscape impacts and screening and bunding could be intrusive in its own right. Whilst it may be possible to mitigate adverse landscape impacts through advance planting and bunding, this is uncertain and there are more acceptable alternative sites for sand and gravel extraction proposed in the Plan.
2.1.6. Due to the higher elevation of the proposed site, waste water from the extraction process may pollute the lower water sources which will affect homes, wildlife, plants and trees.
2.1.7. Widening the lanes would not be possible without removing many mature oak trees and hedging that line the routes. Trees lining Woodrising Road are often damaged by passing machinery/large vehicles. Removal of hedging is detrimental to wildlife habitat.

2.2. Health Hazards
The Reference Information identifies the following risks. These include a number of risks to life.
2.2.1. Risk to the quality of adjacent water sources. This would not only affect wildlife and plants/vegetation but will also affect the many properties in the area that rely on Bore Holes as their only source of water due to the lack of piped water.
2.2.2. The main potential impacts of dust are visual impacts, coating/soiling of property (including housing, washing, and cars), coating of vegetation, contamination of soils, water pollution, change in plant species composition, loss of sensitive plant species, increased inputs of mineral nutrients and altered pH balances. Respirable particles, i.e. those less than 10 micro meters in diameter, have the potential to cause effects on human health, depending on exposure levels.
2.2.3. The effect of Respirable particles on residents taking Immune Suppressant drugs is unknown but like to have a greater impact. [redacted text personal data].
2.2.4. The risk to the health of animal, birds, bats and water wildlife will increase due to dust, noise pollution and increased traffic.
2.2.5. The run off of water used in the extraction process may pollute the local water, used in the bore holes, of the properties within 500 metres of the site. This may be detrimental to the health of the residents.

2.3. Highways
The proposal for site MIN116 indicates that the site would use the C159 Wood Rising Road east to the B1108 Watton Road. It is my experience that HGVs and other large vehicles utilise the shortest route to their destination, usually influenced by Satnav. This would result in the Quarry traffic taking routes that would take heavy vehicles through Cranworth, Shipdham (coming out at the junction with A1075 opposite the church or going past the school, Scoulton, Southburgh (including Pye Lane, River Lane) and the unnamed lane past Hurdlemakers Cottage.

2.3.1. Woodrising Road from the proposed site is unsuitable for HGVs. The Woodrising Road to Frost Row is substandard and would deteriorate quickly with the additional traffic, especially at passing places, many of which are not official passing places and not maintained.
2.3.2. The increased heavy traffic and other traffic will increase the risk of injury and death to pedestrians, cyclists, horse riders, runners and joggers as there are no footpaths.
2.3.3. The exit from Woodrising Road to B1108 at Frost Row is dangerous with restricted views of oncoming traffic restricted by a bend on B1108 and the angle of the road exit. The B1108 has a maximum speed limit of 60mph at the junction with Woodrising Road.
2.3.4. There is no way of restricting HGVs visiting the site from using the rural roads through villages such as Southburgh, Woodrising and Cranworth. HGVs are likely to go through Shipdham, using the exits to A1075 at the Church or going past the school.
2.3.5. Increased traffic, not only the HGVs distributing the Sand and Gravel but also extra vehicles for the daily workforce, site service vehicles and non-site vehicles collecting sand and gravel.
2.3.6. Increased Heavy Goods traffic through Hingham and its surrounding roads will have an adverse effect on the structure (roads and buildings) and safety within the town.
2.3.7. Many of the local properties are old and made from Clay Lump and have flint or brick footings rather than foundations. Vibration from heavy traffic and mining machinery may have an adverse effect on these properties.
2.3.8. Once the extraction of minerals is complete there will be additional heavy traffic infilling the site in order to return it to agricultural use. This will also have a significant impact.
2.3.9. The local roads are regularly used as crossing points for individual and herds of deer. Increased traffic will increase the probability of accidents resulting in the death or injury to deer and the resulting damage to vehicles.

2.4. Local Impact
2.4.1. The plan gives recognition to properties within 250 metres of the proposed site and recognises two properties; Hurdlemakers Cottage and Grove Farm. Grove Farm is incorrectly defined as it now is made up of two properties - Grove Farmhouse and Grove Farm Barn. The plan needs to be corrected.
2.4.2. The Norfolk County Council Infrastructure and Development Select Committee, when considering the plan, stated that "Members were concerned that the consultation distance of 250 metres was not far reaching enough especially when some of the proposed sites are in locations which had not experienced anything similar before. The sites had the potential to affect whole communities, some of which are further away than 250 metres from the proposed site". The concern of members has not been reflected in the plan.
2.4.3. Many more properties are within 500 to 750 metres of the proposed site, including a school. Kingsbrook School is a specialist residential mixed gender therapeutic school for students aged 11 to 18 years with complex needs. These include mental health and associated difficulties, for example, behavioural, emotional and social difficulties. Some of their young people will also have developed specific needs due to a range of factors including trauma, post-traumatic stress disorder or attachment disorder. The noise, dust and increased heavy traffic would have a detrimental effect on vulnerable young people.
2.4.4. Ditch water from the Grove Farm properties and the field behind them drains into the land adjacent to the proposed site. The effects of the proposed site on drainage would need to be reviewed.
2.4.5. The mineral extraction process will use a large amount of water which is likely to be extracted by borehole. This is likely to be detrimental to the many properties in the area rely on bore holes as their only supply of water. This may make water unavailable to some homes.