Support
Preferred Options consultation document
Representation ID: 98741
Received: 30/10/2019
Respondent: Frimstone Limited
Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 77 - land at Runs Wood, south of Whin Common Road, Tottenhill)
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 77 for the reasons outlined below.
Amenity
The feasibility study completed as part of the noise prediction exercise carried out by Independent Environmental Consultancy Limited has shown that NPPG noise criterion can be met at the nearest noise-sensitive receptor positions. 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.
Historic Environment
Following the findings from the Heritage Appraisal carried out by independent consultants Andrew Josephs Associates. It is proposed that 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.
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 on this site.
Landscape
It is considered that Runs Wood no longer constitutes a significant area of woodland within the local landscape and therefore does not have a significant biodiversity value. Runs Wood is an area of ornamental woodland, likely planted to provide cover for shooting with a significant shrub layer dominated by Rhododendron ponticum. The woodland is largely unmanaged with many large dead and fallen trees throughout, with the southern part of the woodland including a large pheasant pen and elsewhere evidence of further gamekeeper activity. There are also a number of Ash trees within the woodland which may be susceptible to Ash Die Back. Furthermore, it is proposed that a screening buffer of trees shall be retained around the perimeter of the excavation. This coupled with the fact that in recent years the Estate have felled a number of dead or dying trees means that the once considered significant densely populated woodland, is now very sparsely populated with poor quality trees remaining above a shrub layer dominated by Rhododendron ponticum, subsequently reducing the biodiversity value.
I therefore wish to object to paragraph M77.7 Landscape: suggesting that the conclusions reached in terms of Runs Wood constituting a significant area of woodland within the local landscape are reconsidered to take account for the recent deterioration in the woodland habitat associated with the management by the Estate, and that the dominance of Rhododendron ponticum should suggest that the biodiversity value can no longer be considered as significant.
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.
Restoration
It is proposed that the site is restored to nature conservation after use comprising a mixture of ponds, wet woodland and wet grassland. The proposed restoration scheme would result in the planting of additional woodland to blend in with the screening buffer of trees to be retained around the excavation. Since the woodland is now very sparsely populated with poor quality trees remaining above a shrub layer dominated by Rhododendron ponticum it is considered that the existing woodland would be able to be replaced and enhanced as a result of the proposed restoration. The restoration proposals will subsequently mitigate against the loss of the existing woodland and provide for a net biodiversity gain.
I therefore wish to object to paragraph M77.19 Restoration: suggesting that the conclusions reached in terms of the proposed restoration scheme not being able to replace the existing established woodland and not mitigate for the loss of the existing woodland are reconsidered to take account for the recent deterioration in the woodland habitat.
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 0.63 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 77 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
Ecological Scoping Report (Ref. E17854) dated 31 July 2017
Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 77 - land at Runs Wood, south of Whin Common Road, Tottenhill)
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 77 for the reasons outlined below.
Amenity
The feasibility study completed as part of the noise prediction exercise carried out by Independent Environmental Consultancy Limited has shown that NPPG noise criterion can be met at the nearest noise-sensitive receptor positions. 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.
Historic Environment
Following the findings from the Heritage Appraisal carried out by independent consultants Andrew Josephs Associates. It is proposed that 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.
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 on this site.
Landscape
It is considered that Runs Wood no longer constitutes a significant area of woodland within the local landscape and therefore does not have a significant biodiversity value. Runs Wood is an area of ornamental woodland, likely planted to provide cover for shooting with a significant shrub layer dominated by Rhododendron ponticum. The woodland is largely unmanaged with many large dead and fallen trees throughout, with the southern part of the woodland including a large pheasant pen and elsewhere evidence of further gamekeeper activity. There are also a number of Ash trees within the woodland which may be susceptible to Ash Die Back. Furthermore, it is proposed that a screening buffer of trees shall be retained around the perimeter of the excavation. This coupled with the fact that in recent years the Estate have felled a number of dead or dying trees means that the once considered significant densely populated woodland, is now very sparsely populated with poor quality trees remaining above a shrub layer dominated by Rhododendron ponticum, subsequently reducing the biodiversity value.
I therefore wish to object to paragraph M77.7 Landscape: suggesting that the conclusions reached in terms of Runs Wood constituting a significant area of woodland within the local landscape are reconsidered to take account for the recent deterioration in the woodland habitat associated with the management by the Estate, and that the dominance of Rhododendron ponticum should suggest that the biodiversity value can no longer be considered as significant.
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.
Restoration
It is proposed that the site is restored to nature conservation after use comprising a mixture of ponds, wet woodland and wet grassland. The proposed restoration scheme would result in the planting of additional woodland to blend in with the screening buffer of trees to be retained around the excavation. Since the woodland is now very sparsely populated with poor quality trees remaining above a shrub layer dominated by Rhododendron ponticum it is considered that the existing woodland would be able to be replaced and enhanced as a result of the proposed restoration. The restoration proposals will subsequently mitigate against the loss of the existing woodland and provide for a net biodiversity gain.
I therefore wish to object to paragraph M77.19 Restoration: suggesting that the conclusions reached in terms of the proposed restoration scheme not being able to replace the existing established woodland and not mitigate for the loss of the existing woodland are reconsidered to take account for the recent deterioration in the woodland habitat.
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 0.63 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 77 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
Ecological Scoping Report (Ref. E17854) dated 31 July 2017