Object
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99345
Received: 18/12/2022
Respondent: Norfolk Wildlife Trust
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
In our response to the previous 2019 consultation we noted that this site overlaps with Triumph & Foxburrow Plantations County Wildlife Site and the Mileplain Plantation ancient woodland partially within the site boundary. However, the site boundary does not appear to have been changed in order to avoid impacts on these important ecological features. Whilst we have no objection in principle to the majority of the allocation, we are significantly concerned that the allocation includes part of a County Wildlife Site, in clear contradiction with the goals of policy MW1.
Full text: In our response to the previous 2019 consultation we noted that this site overlaps with Triumph & Foxburrow Plantations County Wildlife Site and the Mileplain Plantation ancient woodland partially within the site boundary. However, the site boundary does not appear to have been changed in order to avoid impacts on these important ecological features. Whilst the supporting text for the policy states in M202.12 that there should be a stand off distance of at least 15 metres from the ancient woodland, we question why the red line boundary for the allocation abuts the ancient woodland and includes part of the CWS. Notwithstanding our concerns about the inclusion of part of a CWS in this allocation, and its unacceptable proximity to ancient woodland, we have no objection in principle to the remainder of the allocation area and support the proposed restoration to heathland.
We strongly recommend that the site boundary is modified to remove any overlap with the CWS and set the required stand off distance where ancient woodland is present. For section d, we recommend that natural regeneration rather than planting is preferred, as this is far more likely to establish successfully and will avoid any risks of introducing disease from imported tree stock. Given the proximity to Swannington Upgate Common SSSI, part of which is also the Upgate Common Norfolk Wildlife Trust reserve, we recommend that policy wording requiring dry working is included in the policy text, in line with the approach taken for MIN 200, for consistency and certainty of delivery.