Support
Preferred Options consultation document
Representation ID: 98742
Received: 30/10/2019
Respondent: Frimstone Limited
Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 32 - land west of Lime Kiln Road, West Dereham)
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 32 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 the sightlines sections drawing no. W12_LAN_006 submitted in support of MIN 32 allocation at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review in August 2018, 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 fields. The screening bunds will be 3m in height with 1 in 5 outer slopes on the eastern and northern boundaries and 1 in 10 outer slopes on the southern boundary. Furthermore, where possible it is proposed to reinforce the existing planting in advance of mineral workings and also the planting of an additional hedgerow along the southern boundary to aid screening, as illustrated in the supporting concept development plan drawing no. W12_LAN_004.
Therefore, it can be demonstrated by these sightline sections that once the above mitigation proposals have been implemented as per the concept development plan the site will not afford any views to potential external sensitive receptors. 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 M32.6 Landscape: suggesting that the conclusions reached in terms of screening the views from West Dereham, A134, Lime Kiln Road and Bath Road Area are reconsidered to take account for the sightline sections included in the amended MIN 32 representation at the 'Initial Consultation' stage of the Plan, 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 the open landscape, 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 0.56 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 32 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/3674/01/AVH) dated 03 August 2017
Heritage Appraisal (No Reference) dated July 2017
Concept Development Plan (Drawing No. W12_LAN_004)
Concept Restoration Plan (Drawing No. W12_LAN_005)
Sightline Sections (Drawing No. W12_LAN_006)
Sightline Locations (Drawing No. W12_LAN_007)
Ecological Scoping Report (Ref. E17855) dated 21 July 2017
Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 32 - land west of Lime Kiln Road, West Dereham)
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 32 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 the sightlines sections drawing no. W12_LAN_006 submitted in support of MIN 32 allocation at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review in August 2018, 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 fields. The screening bunds will be 3m in height with 1 in 5 outer slopes on the eastern and northern boundaries and 1 in 10 outer slopes on the southern boundary. Furthermore, where possible it is proposed to reinforce the existing planting in advance of mineral workings and also the planting of an additional hedgerow along the southern boundary to aid screening, as illustrated in the supporting concept development plan drawing no. W12_LAN_004.
Therefore, it can be demonstrated by these sightline sections that once the above mitigation proposals have been implemented as per the concept development plan the site will not afford any views to potential external sensitive receptors. 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 M32.6 Landscape: suggesting that the conclusions reached in terms of screening the views from West Dereham, A134, Lime Kiln Road and Bath Road Area are reconsidered to take account for the sightline sections included in the amended MIN 32 representation at the 'Initial Consultation' stage of the Plan, 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 the open landscape, 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 0.56 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 32 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/3674/01/AVH) dated 03 August 2017
Heritage Appraisal (No Reference) dated July 2017
Concept Development Plan (Drawing No. W12_LAN_004)
Concept Restoration Plan (Drawing No. W12_LAN_005)
Sightline Sections (Drawing No. W12_LAN_006)
Sightline Locations (Drawing No. W12_LAN_007)
Ecological Scoping Report (Ref. E17855) dated 21 July 2017