Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 74 - land at Turf Field, Watlington Road)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 74 for the reasons outlined below.

Amenity
The results of the noise prediction exercise carried out by Independent Environmental Consultancy Limited show that the outline scheme for Turf Field would have exceed typical criterion for routine operations at the nearest dwelling located at Tottenhill Row. Consequently, the proposal scheme increases the separation distance to in excess of 100m between the western boundary of the extraction area and the nearest dwelling located at Tottenhill Row and increases the screening bund height up to 4m by utilising the onsite subsoils.

As part of these proposals appropriate noise criterion at Oak House and Tottenhill Row can now both be met with careful consideration of the haul route between Turf Field and the existing processing plant located to the south.

Therefore, the feasibility study has shown that NPPG noise criterion can be met at the nearest noise-sensitive receptor positions with the amended operational scenario detailed in the above paragraphs. Any future planning application for mineral extraction at this site will include a further noise and dust assessment and outline mitigation measures to deal appropriately with any amenity impacts.

I therefore wish to object to paragraph M74.1 Amenity: and for the Draft Norfolk Minerals and Waste Local Plan to now take account for the amendments to the scheme detailed above by making clear that all the nearest residential properties will be in excess of 100m from the extraction area.

Historic Environment
The findings from the Heritage Appraisal carried out by independent consultants Andrew Josephs Associates demonstrate that there are no listed structures or scheduled monuments within 1km of Turf Field. Therefore, no listed buildings or scheduled monuments would be affected by the proposed allocation. Furthermore, Tottenhill Row Conservation Area north eastern boundary lies in excess of 50m from Turf Field given that it is now proposed to increase the separation distance between the western margin of the extraction area from the Conservation Area.

Mineral extraction has previously taken place to the east and west of the Conservation Area now restored to lakes and species rich grassland. Mineral extraction is currently taking place directly to the south of the Conservation Area within MIN 76 (West Field), and it is more than likely that there is an historic working within the Conservation Area itself represented by a pond feature. Mineral extraction is therefore not alien to the vicinity, and the number of historic workings in the locality stresses the temporary nature of these proposals. Nonetheless, due to the proximity of Turf Field to the northeast of the Conservation Area, it is proposed that the site will require careful design of boundary treatments to negate any visual impact and stand-offs from any potential receptors in excess of 100m to reduce other impacts such as from noise and dust.

It is proposed that restoration shall be sympathetic to the current agricultural context of Tottenhill Row by returning the site back to productive agricultural land. Any future planning application for mineral extraction at this site will include a further Heritage Statement to identify heritage assets and their settings, assess the potential for impacts and identify appropriate mitigation measures if required.

I therefore wish to object to paragraph M74.4 by amending the wording to state that there are no Listed Buildings or Scheduled Monuments within 1km of the extraction area and that Tottenhill Row Conservation Area is in excess of 50m from the site given the amendments to the scheme detailed above.

Archaeology
Following the archaeological background section included in the Heritage Appraisal carried out by independent consultants Andrew Josephs Associates. It is proposed that any future planning application will be accompanied by an assessment of the significance of archaeological remains, in order to protect and mitigate the impact of mineral extraction in this site.

Landscape
It is considered that the sightlines sections drawing no. W13/LAN/002 submitted in support of Turf Field's allocation at the 'call for mineral extraction sites' stage of the Norfolk Minerals and Waste Local Plan Review in August 2017, demonstrates that the site will not have any adverse effects on the existing landscape given the implementation of appropriately designed screening bunds, existing and proposed planting.

It is proposed that all screening bunds shall have shallow outer slopes and are to be sown to grassland at the first available opportunity to match the adjacent field. The screening bunds will vary in height from 2m on the southern boundary adjacent to Watlington Road up to 4m on the eastern boundary closest to Oak House. Furthermore, where possible it is proposed to reinforce the existing planting in advance of mineral workings to aid screening.

Therefore, it can be demonstrated by these sightline sections that once the above mitigation proposals have been implemented the site will not afford any views to potential external sensitive receptors, or at least winter intermittent sightlines only from Oak House first floor window when working the western portion of the site. Any future planning application for mineral extraction at this site will include a further landscape assessment and scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents.

I therefore wish to object to paragraph M74.6 Landscape: suggesting that the conclusions reached in terms of screening the views from the Nar Valley Way and Tottenhill Conservation Area are reconsidered to take account for the sightline sections included in the original Turf Field representation, that clearly demonstrate given the mitigation proposals above that suitable screening can be implemented. Furthermore, I wish to object to the conclusions drawn regarding the screening or bunding being intrusive in its own right, as it has been specifically designed to have shallow outer slopes and to be sown to grassland at the first available opportunity to match the adjacent field, and therefore blending into the surrounding agricultural landscaping setting.

Ecology
Following the Ecological Scoping Report carried out by independent consultants The Landscape Partnership in support of the original representation. It is proposed that any future planning application will be accompanied by an assessment of potential impacts, including from dust deposition and hydrogeology, together with appropriate mitigation on all designated sites within the vicinity of the site.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.16 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Furthermore, it should be considered that under the current adopted Norfolk Minerals and Waste Development Framework Core Strategy and Minerals and Waste Development Management Policies Development Plan Document 2010-2026, Core Strategy Policy CS2 - General locations for mineral extraction and associated facilities MIN 74 is proposed as an extension to an existing site and therefore will be preferred by the MPA to new sites. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Amenity Impact & Mitigation Report (Ref. IEC/3650/01/AVH) dated 04 August 2017 Heritage Appraisal (No Reference) dated July 2017
Sightline Sections (Drawing No. W13/LAN/002) dated July 2017
Ecological Scoping Report (Ref. E17854) dated 31 July 2017