Object

Preferred Options consultation document

Representation ID: 98233

Received: 17/10/2019

Respondent: Mr James Farman

Representation Summary:

I own a holiday let property which was granted planning permission in 2018 on Thorpe Road, Haddiscoe, next to the Grade 2 listed White House Farm. I have invested funds into the property which has been previously refused planning for residential dwelling due to its proximity to the Broads executive area owing to impact on the Norfolk Broads area. The purpose of my investment within the Broads was to make a commercially successful and attractive holiday let for people to enjoy the Broads. The property is 30m away from the proposed recommended minerals extraction site. I grew up in the village and lived there for around 20 years.
I have a number of comments and questions on the appraisal to date in respect of the proposed development MIN25 and its inclusion in the Minerals Development Plan site specific allocation. I have also looked at the development policies shown on the minerals planning website to see if it is a sound proposal.

Site history and preface

In 2009, the site was deemed unacceptable for allocation by Norfolk County Council because of landscape, highway, amenity and groundwater impacts. In 2011, it was considered unsuitable for allocation on the basis of landscape impacts, noting that highway, amenity and groundwater impacts further decreased the site's acceptability. In 2013/14 the site was refused planning and dismissed at appeal. I cannot see how things have changed or a need can be demonstrated beyond those same comments. An argued need could be the allocation of the mineral resource, although suitable resource seems to be near or actually identified in mostly extension sites within the new plan allocation. With such abundant sand and gravel resources in the area, I feel a review could be triggered or other far more sustainable resources could be found before a breaking point in 2036.
The site is well known as having previously failed planning and appeal for minerals extraction. The recent county council sustainability assessment for potentially allocated sites states this is solely down to the setting on St Marys church of the previously promoted site to the south of the B1136. My view after reading the appeal decision is that In fact, the whole site was called into question. The inspector clearly did not exclude the northern site from statements about suitability. Mentioned in the appeal decision was reference of preferred option to extend existing sites (promoting sustainability), and also stating there was no continuing public benefit across the entire development. All of the site was also deemed to have some impact on the grade 1 listed historic asset.

Points for the initial MIN25 assessment to date by NCC

Questions regarding the information and reasoning on which this has initially been assessed suitable for inclusion in the development plan allocation:

1. Has the inspectors position on the previous appeal been completely addressed with the statement that the appeal was dismissed purely on the grounds of the setting of the St Marys church Grade 1 listed asset for the parcel of land south of the B1136.

2. The public need confirmation on the quantity of the mineral to be won from the site based on a realistic calculation of the future development area which would be allowed. If buffer zones from existing houses and priority ecological habitats are needed and taken account of, a potential stand off buffer around the historic assets required, and a development boundary is also applied and sterilised to potential new housing as submitted to the housing assessment call for sites by the landowner, with a noise bund area, access and turning, allow for the sloping sides of the extraction area and fencing and the site and it is reduced in capacity by a very large area. Even with just the 100m from existing dwellings, noise bund and pit walls the site would not operate at the full capacity of the red line area. I have developed the property 20m away from the boundary and found the water table during excavation. I would like to know NCC are positive the aggregate reserve is close to the 1.3Mt asserted. This must be a material consideration as when balanced against the negative impacts it will sway the planning decision. A simple overestimation now would also not be fair on other sites trying to be allocated.

3. The assessment appears to be based on the developer removing aggregate from Haddiscoe, and then being dropped off by lorry at Norton Subcourse for processing, then back into a lorry for movement onto the identified primary market in Great Yarmouth. Whilst this is an understandable business proposal, this gives major issues on sustainability and its proximity to supply destination against other potential sites.

4. The site area, once buffer zones are constructed could be relatively small, meaning that if aggregates were processed onsite rather than at Norton, it would be a confined working area and the processing equipment would have to move around the site. This could mean extraction would be a more laboured process. This would create a time extension to the extraction as well as create extra noise and dust. Compared to other sites it would not be an efficient process meaning it could use more energy per tonne to extract the minerals.

5. The length of activity is proposed to be 9 years with increased road movements. At its suggested maximum capacity of 80 movements per day 40 loads leaving site this is a confident target given the economic outlook. Would the planning term be reflected by the the local community being able to draw on a bond for damages if the planning term were to overrun? There are many instances where these quarries are extended, the simple fact is when the hole is there, it is there. The initial consultation also does not mention the traffic movements for restoration of the site and imported materials, which would almost certainly be essential if the biodiversity scheme were to be implemented. Typically soil and stone is imported to the site amongst other suitable materials for remediation which would be up to the same volume as the asserted 1.3 million tonnes of gravel extracted, which means refilling the void will double the lifetime road movements. This will be a part of the planning and so should be a part of the site analysis for consideration into the development plan allocation. There is no doubt that for a development this significant more details should be given to local residents about its remediation including topography and proposed fill / use at this stage.

General considerations

1. Development policy gives more weight to extension of existing mineral extraction areas. This is not an extension to an existing site. Nor, by its bordering of open countryside to the West as per the inspectors findings, nor due to its other three boundaries being dwellings, the Broads executive area and the setting on St Marys Church is it ever going to be extended which must blight it as a site for selection. There is also much record of negative comment from council, public and planning inspectorate against amenity, groundwater, traffic, setting on historic assets and impact of noise and dust on a village community. All question on the sites sustainability.

2. The landowner has also submitted sites adjacent to the proposed minerals site under a call for sites for housing allocation in the Greater Norwich Development Plan http://www.greaternorwichgrowth.org.uk/planning/greater-norwich-local-plan/call-forsites/. These housing sites do not have planning permission but when in a similar state of suggestion for allocation, they should be considered. I understand and support that Haddiscoe should bear its weight on housing supply. In fact, the supply of housing in the right setting within Haddiscoe will, in my opinion, add to the village and assist in more social inclusion, and more use of the local facilities of the pub, village hall and play area. The proposed selected sites for housing allocation are also within 100m of the proposed extraction area and so would be subject to noise and dust. This would reduce their chance of success with planning and developers and also reduce the likelihood of people wanting to move to the village - it will be viewed as a more industrial landscape. There needs to be some joined up thinking from the council and feedback to the village as to which is the greater need - amenity of the locals, preservation of character and availability of housing, or mineral sites in exclusivity.

3. The site has an 11kV power line running across it which is not noted in the utilities report. I appreciate that this along with the Anglian Water main can be relocated at the developers expense as necessary

Norfolk County Council Minerals Development policies:
The site is against presumption in favour of sustainable development owing to the increased traffic miles compared to other sites in the proposed allocation, and other sites available within the minerals safeguarding area in proximity to Great Yarmouth. A sequential test would likely show this is the most carbon intensive site to include in the allocation to service Great Yarmouth.
I understand the land is Grade 3, best and most versatile land. For the site to be properly appraised, and for the public to properly consider this site for inclusion in the plan, they should be better informed of the remediation and timescales, and also net benefits of the biodiversity scheme.
The suggested site also moves a PROW without any definition. The PROW and net benefits to the public required and mentioned in the inspectors report are not seen at this stage and should be with such a major decision on a contentious site.
The NCC sustainability assessment identified the site could hold archaeological finds and geological finds which would need monitoring and mitigation. I understand this can be achieved but has been the grounds for removal of the Fritton site from the allocation. The Fritton site assets could be worked around and mitigated as Haddiscoe and are much more recent in their setting.
There is an undeniable impact on the setting and amenity of the grade 1 listed church and grade 2 listed asset in the churchyard. The grounds of the grade 1 church are within 60 meters of the site and the church itself little over 100 meters away.
The Haddiscoe site has to be considered a cumulative impact to the Norton Subcourse mineral extraction site. This is due to the proposed processing at Norton. Being as Norton Subcourse already has its own significant resource, with its own planning permission and associated HGV movement restriction, how can this be increased to accommodate MIN25? The supply at Norton is already 2,370,000 tonnes as consented in 2015 (reserve left unknow but significant). More traffic will lessen the ability of that site to operate at its proposed capacity as well as potentially increase traffic impacts for the communities around that site. Surely the Norton site should increase its planning permission for traffic movements first in order for processing of the MIN25 won gravel to be considered?
Efficiency of the A143 and A146 junctions off the B1136 would be called into question. As would safety of existing and new residents in Haddiscoe using Crab Apple Lane and Thorpe Road in events where the main routes were blocked.
The site does not sound aligned with climate change mitigation policies owing to the traffic movements to Norton Subcourse. Other potential sites in the allocation are in closer proximity to Great Yarmouth where the aggregate is deemed to be supplied. Transport to Norton is likely to be by 8 wheeler lorry which averages 8mpg fully laden. A quick estimate reveals over 1,000,000 kg of carbon just for the extra processing movements which are not proposed on this mass scale at any other minerals extraction site. If judged against the Burgh Castle site these extra road miles and carbon can be doubled.

Other opportunities

I am surprised that more obligation or support for minerals suppliers to use the new outer harbour at Great Yarmouth is not there. Great Yarmouth is after all the destination of the aggregate. A number of minerals suppliers have active dredging licences a few miles off the coast of Great Yarmouth where over a millions of tonnes of aggregates are dredged each year. These are long term secure licences and new applications to extend dredging areas are in right now. This is not only economical and sustainable, it is already happening with a lot of product being landed into Ipswich, and Great Yarmouth itself receiving hundreds of thousands of tonnes of Type 1 Granite for
construction each year which all means it is feasible. The outer harbour was not operational to its current capability during the last Minerals planning round.
There is a good sand and gravel resource available in many areas of Norfolk. On top of this, as a construction community we should be looking to win sand and stone from sites by screening construction and demolition waste onsite or at approved facilities which is by far the most economical and sustainable option.
Lastly, Haddiscoe has within recent memory experienced gravel extraction which has not been an overall positive memory. Evidence of former quarry sites still lay within the village. It should be a resolve to make sure these are all tidied up before moving on to another project. Also, for Haddiscoe to bear another round of extraction so soon, with so many mitigating reasons not to is unfair on us voters and taxpayers. Whilst I appreciate the council has granted permission for holiday lodges on one former site, this is still at present an untidy site some 20 years since it was last occupied.

I would request the Developer and Minerals Planning team also answer whether the following could be conditioned and monitored within a permission:
* Need to use electrically driven processing equipment at the Haddiscoe site (as opposed to diesel driven plant) if possible to reduce noise and carbon emissions.
* Need to reduce road miles and carbon compared to other sites suggested for allocation as the carbon impact sounds unacceptable.
* Need to monitor dust to the highest standard and best available techniques due to it being in proximity to so many sensitive receptors and a stones throw from the settlement of Haddiscoe.
* Consider restricted activity in Westerly wind conditions to minimise noise.
* Consider the long term views and aspirations of the village when looking at a section 106 agreement - can a developer fund be made available to offset the harm.
* Require a full EIA and bird survey - from my holiday let development I have seen barn owls nesting close to the site, a pair of breeding marsh harriers on a regular basis and other raptors using the marsh in the Broads authority national park area less than 50 meters from the proposed site. These birds roost in the deciduous woodland priority habitat within and adjacent to the site. The Broads area adjacent to the site is also home to other priority species in this environmentally sensitive area. These were key reasons why I developed the holiday let - for people to enjoy these features.
* Need to address the traffic impact on the B1136-A143 junction and the B1136-A146 junctions. Understood these will be planning objectives but their success should be judged now as to whether the council spend on taking this site forward is justified.
* Look at working hours. Longer hours are not necessary as there is no direct retail to the construction industry proposed from the Haddiscoe site. The site could operate say 09:30 - 16:00 with lower traffic impact and no effect on aggregate production which would help with noise.

Conclusion

I am not against aggregates developments and support them happening in the correct place. Aggregates sites obviously support wider economic growth and need not be a nuisance. New sites test the planning system and are controlled for noise, impacts on the natural and historic environment, sustainability, effects on amenity, dust and all other criteria. When weighing up all of these I am by no means confident of this sites chance of success and question whether the council should promote it at taxpayer expense. Even though the has its history, the site can only be judged for allocation based on the information in this allocation process which is not enough to give it a positive light. There are a number of policies with which this site conflicts, and although the site still has to pass planning, this process gives sites an amber light. If it has a low chance of success and is less sustainable than the other sites requesting allocation, it could be a waste of time and money for the developer and council and that is the question being asked in this consultation - viability. On the balance of information available now I deeply object to the scheme being allocated in the minerals plan as I can see a successful challenge to planning being mounted.

Full text:

I own a holiday let property which was granted planning permission in 2018 on Thorpe Road, Haddiscoe, next to the Grade 2 listed White House Farm. I have invested funds into the property which has been previously refused planning for residential dwelling due to its proximity to the Broads executive area owing to impact on the Norfolk Broads area. The purpose of my investment within the Broads was to make a commercially successful and attractive holiday let for people to enjoy the Broads. The property is 30m away from the proposed recommended minerals extraction site. I grew up in the village and lived there for around 20 years.
I have a number of comments and questions on the appraisal to date in respect of the proposed development MIN25 and its inclusion in the Minerals Development Plan site specific allocation. I have also looked at the development policies shown on the minerals planning website to see if it is a sound proposal.

Site history and preface

In 2009, the site was deemed unacceptable for allocation by Norfolk County Council because of landscape, highway, amenity and groundwater impacts. In 2011, it was considered unsuitable for allocation on the basis of landscape impacts, noting that highway, amenity and groundwater impacts further decreased the site's acceptability. In 2013/14 the site was refused planning and dismissed at appeal. I cannot see how things have changed or a need can be demonstrated beyond those same comments. An argued need could be the allocation of the mineral resource, although suitable resource seems to be near or actually identified in mostly extension sites within the new plan allocation. With such abundant sand and gravel resources in the area, I feel a review could be triggered or other far more sustainable resources could be found before a breaking point in 2036.
The site is well known as having previously failed planning and appeal for minerals extraction. The recent county council sustainability assessment for potentially allocated sites states this is solely down to the setting on St Marys church of the previously promoted site to the south of the B1136. My view after reading the appeal decision is that In fact, the whole site was called into question. The inspector clearly did not exclude the northern site from statements about suitability. Mentioned in the appeal decision was reference of preferred option to extend existing sites (promoting sustainability), and also stating there was no continuing public benefit across the entire development. All of the site was also deemed to have some impact on the grade 1 listed historic asset.

Points for the initial MIN25 assessment to date by NCC

Questions regarding the information and reasoning on which this has initially been assessed suitable for inclusion in the development plan allocation:

1. Has the inspectors position on the previous appeal been completely addressed with the statement that the appeal was dismissed purely on the grounds of the setting of the St Marys church Grade 1 listed asset for the parcel of land south of the B1136.

2. The public need confirmation on the quantity of the mineral to be won from the site based on a realistic calculation of the future development area which would be allowed. If buffer zones from existing houses and priority ecological habitats are needed and taken account of, a potential stand off buffer around the historic assets required, and a development boundary is also applied and sterilised to potential new housing as submitted to the housing assessment call for sites by the landowner, with a noise bund area, access and turning, allow for the sloping sides of the extraction area and fencing and the site and it is reduced in capacity by a very large area. Even with just the 100m from existing dwellings, noise bund and pit walls the site would not operate at the full capacity of the red line area. I have developed the property 20m away from the boundary and found the water table during excavation. I would like to know NCC are positive the aggregate reserve is close to the 1.3Mt asserted. This must be a material consideration as when balanced against the negative impacts it will sway the planning decision. A simple overestimation now would also not be fair on other sites trying to be allocated.

3. The assessment appears to be based on the developer removing aggregate from Haddiscoe, and then being dropped off by lorry at Norton Subcourse for processing, then back into a lorry for movement onto the identified primary market in Great Yarmouth. Whilst this is an understandable business proposal, this gives major issues on sustainability and its proximity to supply destination against other potential sites.

4. The site area, once buffer zones are constructed could be relatively small, meaning that if aggregates were processed onsite rather than at Norton, it would be a confined working area and the processing equipment would have to move around the site. This could mean extraction would be a more laboured process. This would create a time extension to the extraction as well as create extra noise and dust. Compared to other sites it would not be an efficient process meaning it could use more energy per tonne to extract the minerals.

5. The length of activity is proposed to be 9 years with increased road movements. At its suggested maximum capacity of 80 movements per day 40 loads leaving site this is a confident target given the economic outlook. Would the planning term be reflected by the the local community being able to draw on a bond for damages if the planning term were to overrun? There are many instances where these quarries are extended, the simple fact is when the hole is there, it is there. The initial consultation also does not mention the traffic movements for restoration of the site and imported materials, which would almost certainly be essential if the biodiversity scheme were to be implemented. Typically soil and stone is imported to the site amongst other suitable materials for remediation which would be up to
the same volume as the asserted 1.3 million tonnes of gravel extracted, which means refilling the void will double the lifetime road movements. This will be a part of the planning and so should be a part of the site analysis for consideration into the development plan allocation. There is no doubt that for a development this significant more details should be given to local residents about its remediation including topography and proposed fill / use at this stage.

General considerations

1. Development policy gives more weight to extension of existing mineral extraction areas. This is not an extension to an existing site. Nor, by its bordering of open countryside to the West as per the inspectors findings, nor due to its other three boundaries being dwellings, the Broads executive area and the setting on St Marys Church is it ever going to be extended which must blight it as a site for selection. There is also much record of negative comment from council, public and planning inspectorate against amenity, groundwater, traffic, setting on historic assets and impact of noise and dust on a village community. All question on the sites sustainability.

2. The landowner has also submitted sites adjacent to the proposed minerals site under a call for sites for housing allocation in the Greater Norwich Development Plan http://www.greaternorwichgrowth.org.uk/planning/greater-norwich-local-plan/call-forsites/. These housing sites do not have planning permission but when in a similar state of suggestion for allocation, they should be considered. I understand and support that Haddiscoe should bear its weight on housing supply. In fact, the supply of housing in the right setting within Haddiscoe will, in my opinion, add to the village and assist in more social inclusion, and more use of the local facilities of the pub, village hall and play area. The proposed selected sites for housing allocation are also within 100m of the proposed extraction area and so would be subject to noise and dust. This would reduce their chance of success with planning and developers and also reduce the likelihood of people wanting to move to the village - it will be viewed as a more industrial landscape. There needs to be some joined up thinking from the council and feedback to the village as to which is the greater need - amenity of the locals, preservation of character and availability of housing, or mineral sites in exclusivity.

3. The site has an 11kV power line running across it which is not noted in the utilities report. I appreciate that this along with the Anglian Water main can be relocated at the developers expense as necessary

Norfolk County Council Minerals Development policies:
The site is against presumption in favour of sustainable development owing to the increased traffic miles compared to other sites in the proposed allocation, and other sites available within the minerals safeguarding area in proximity to Great Yarmouth. A sequential test would likely show this is the most carbon intensive site to include in the allocation to service Great Yarmouth.
I understand the land is Grade 3, best and most versatile land. For the site to be properly appraised, and for the public to properly consider this site for inclusion in the plan, they should be better informed of the remediation and timescales, and also net benefits of the biodiversity scheme.
The suggested site also moves a PROW without any definition. The PROW and net benefits to the public required and mentioned in the inspectors report are not seen at this stage and should be with such a major decision on a contentious site.
The NCC sustainability assessment identified the site could hold archaeological finds and geological finds which would need monitoring and mitigation. I understand this can be achieved but has been the grounds for removal of the Fritton site from the allocation. The Fritton site assets could be worked around and mitigated as Haddiscoe and are much more recent in their setting.
There is an undeniable impact on the setting and amenity of the grade 1 listed church and grade 2 listed asset in the churchyard. The grounds of the grade 1 church are within 60 meters of the site and the church itself little over 100 meters away.
The Haddiscoe site has to be considered a cumulative impact to the Norton Subcourse mineral extraction site. This is due to the proposed processing at Norton. Being as Norton Subcourse already has its own significant resource, with its own planning permission and associated HGV movement restriction, how can this be increased to accommodate MIN25? The supply at Norton is already 2,370,000 tonnes as consented in 2015 (reserve left unknow but significant). More traffic will lessen the ability of that site to operate at its proposed capacity as well as potentially increase traffic impacts for the communities around that site. Surely the Norton site should increase its planning permission for traffic movements first in order for processing of the MIN25 won gravel to be considered?
Efficiency of the A143 and A146 junctions off the B1136 would be called into question. As would safety of existing and new residents in Haddiscoe using Crab Apple Lane and Thorpe Road in events where the main routes were blocked.
The site does not sound aligned with climate change mitigation policies owing to the traffic movements to Norton Subcourse. Other potential sites in the allocation are in closer proximity to Great Yarmouth where the aggregate is deemed to be supplied. Transport to Norton is likely to be by 8 wheeler lorry which averages 8mpg fully laden. A quick estimate reveals over 1,000,000 kg of carbon just for the extra processing movements which are not proposed on this mass scale at any other minerals extraction site. If judged against the Burgh Castle site these extra road miles and carbon can be doubled.

Other opportunities

I am surprised that more obligation or support for minerals suppliers to use the new outer harbour at Great Yarmouth is not there. Great Yarmouth is after all the destination of the aggregate. A number of minerals suppliers have active dredging licences a few miles off the coast of Great Yarmouth where over a millions of tonnes of aggregates are dredged each year. These are long term secure licences and new applications to extend dredging areas are in right now. This is not only economical and sustainable, it is already happening with a lot of product being landed into Ipswich, and Great Yarmouth itself receiving hundreds of thousands of tonnes of Type 1 Granite for construction each year which all means it is feasible. The outer harbour was not operational to its current capability during the last Minerals planning round.
There is a good sand and gravel resource available in many areas of Norfolk. On top of this, as a construction community we should be looking to win sand and stone from sites by screening construction and demolition waste onsite or at approved facilities which is by far the most economical and sustainable option.
Lastly, Haddiscoe has within recent memory experienced gravel extraction which has not been an overall positive memory. Evidence of former quarry sites still lay within the village. It should be a resolve to make sure these are all tidied up before moving on to another project. Also, for Haddiscoe to bear another round of extraction so soon, with so many mitigating reasons not to is unfair on us voters and taxpayers. Whilst I appreciate the council has granted permission for holiday lodges on one former site, this is still at present an untidy site some 20 years since it was last occupied.

I would request the Developer and Minerals Planning team also answer whether the following could be conditioned and monitored within a permission:
* Need to use electrically driven processing equipment at the Haddiscoe site (as
opposed to diesel driven plant) if possible to reduce noise and carbon emissions.
* Need to reduce road miles and carbon compared to other sites suggested for allocation as the carbon impact sounds unacceptable.
* Need to monitor dust to the highest standard and best available techniques due to it being in proximity to so many sensitive receptors and a stones throw from the settlement of Haddiscoe. * Consider restricted activity in Westerly wind conditions to minimise noise. * Consider the long term views and aspirations of the village when looking at a section 106 agreement - can a developer fund be made available to offset the harm.
* Require a full EIA and bird survey - from my holiday let development I have seen barn owls nesting close to the site, a pair of breeding marsh harriers on a regular basis and other raptors using the marsh in the Broads authority national park area less than 50 meters from the proposed site. These birds roost in the deciduous woodland priority habitat within and adjacent to the site. The Broads area adjacent to the site is also home to other priority species in this environmentally sensitive area. These were key reasons why I developed the holiday let - for people to enjoy these features.
* Need to address the traffic impact on the B1136-A143 junction and the B1136-A146 junctions. Understood these will be planning objectives but their success should be judged now as to whether the council spend on taking this site forward is justified.
* Look at working hours. Longer hours are not necessary as there is no direct retail to the construction industry proposed from the Haddiscoe site. The site could operate say 09:30 - 16:00 with lower traffic impact and no effect on aggregate production which would help with noise.

Conclusion

I am not against aggregates developments and support them happening in the correct place. Aggregates sites obviously support wider economic growth and need not be a nuisance. New sites test the planning system and are controlled for noise, impacts on the natural and historic environment, sustainability, effects on amenity, dust and all other criteria. When weighing up all of these I am by no means confident of this sites chance of success and question whether the council should promote it at taxpayer expense. Even though the has its history, the site can only be judged for allocation based on the information in this allocation process which is not enough to give it a positive light. There are a number of policies with which this site conflicts, and although the site still has to pass planning, this process gives sites an amber light. If it has a low chance of success and is less sustainable than the other sites requesting allocation, it could be a waste of time and money for the developer and council and that is the question being asked in this consultation - viability. On the balance of information available now I deeply object to the scheme being allocated in the minerals plan as I can see a successful challenge to planning being mounted.