Question 46: Proposed site MIN 35

MIN 35 - land at Heath Road, Quidenham
I am against this being done, as I live in Eccles near the station and can hear the combine when they did the field next to the proposed site, so having mineral extraction going which will cause noise pollution in the area and an excess of dust which could be blown over when there is high winds

I am writing to object to the mineral extraction,
(1) At 29mtrs we are the 2nd closest property to the site.
My Husband [redacted text - personal data] the dust would be extremely detrimental to his health. We have lived here for 42 years & hoped to spend our later years in peace, not confined behind closed doors because of the noise & dust from our 'neighbours'.
(2)The highway access at the top of Heath Road is NOT suitable,it comes out on to a 45 degree bend,with the Snetterton Recycling Site directly to the right. A commercial wood yard is to the left, Putting an exit road further along would bring it out at a blind bend. Heath Road itself is a narrow (7 Feet wide) no through road. Our only vehicular access is the top of the road. If anything blocks the top of the road, we cannot get out! Heath road is on the national cycling route. We get a lot of cyclists up & down. Also Dog walkers use the road & field
(3) Heath Road is an Historic site,The cottage at the bottom of the road is built on foundations dating back before the 1600's.
(4)Utilities infrastructure:Yes,there are 2x underground electricity cables which run across the top of Heath Road, from the straw burner at Snetterton to the sub-station at Diss, but also running down Heath Road, are 3x 11000v cables, that connect Snetterton industrial estates & Snetterton Circuit. Also the main Fibre Optic cable serving Snetterton. And our Water pipe.
(5)Hydrogeology: The South side of the old land fill site is unlined & filled with chicken carcasses. The leachate is monitored regularly down Heath Road,but that wouldn't be good if all that is disturbed.
Heath Crossing Cottage, at the bottom of Heath Road has only a private water supply.By way of a bore hole, coming from an aquafer into the chalk seam. the cottage is DEPENDENT on this water supply. This Bore Hole Water supplies 3 dwellings, there is no Anglian Water!! I believe that this development would compromise the integrity of our bore hole.
My husband & myself are not happy with this proposed site, it would impact hugely on our quality of life, we would see it, hear it, smell it & feel it, all at very close quarters. As Owner & landlady of Heath Crossing Cottage, I am LEGALLY responsible for the quality of the water supply to the cottage. I have to have it tested & certified regularly. The developer of the proposed site must take full responsibility for the quality of the water from our bore-hole.
signed Mr & Mrs Lentin

Whilst the initial conclusion is supported, clarity is required concerning the dimensions of the buffer provided to protect residential amenity. Under the heading 'Amenity' the assessment states, 'the nearest residential property is 42m from the extraction area'. This is incorrect. The buffer area has been designed to ensure the limit of extraction is no closer than 150 metres from the closest residential property positioned close to the southern site boundary.

It is entirely unacceptable for greater emphasis to be given to a collection of beetles living several km away than the impact of local residents. The extraction of minerals from this site would simply encourage the growth of the existing Snetterton light industrial and distribution park towards the nearby villages of Eccles and Quidenham.
Whilst I agree that the area is not 'naturally unspoilt' it is wrong to say that it is not tranquil. The developments do not impose significantly on residents. The nearby racetrack causes short periods of loud noise at some weekends; the recycling centre is small and quiet, the light industrial units are vey small in scale. well hidden and make little or no noise. In contrast, the proposed extraction site would be visible to many local residents and would truly be a blot on the landscape.
I do not think any council officer would wish for a gigantic hole to be built 150m from their house for a period of 7 years, yet it is being considered acceptable for local residents. The local residents and the village of Eccles have absolutely nothing to gain from this development.

This proposed site has been rejected multiple times already due to the close proximity of local residents and habitation. I live here with my husband and our 3 children, plus the cottage opposite us has a family so that is an extra 7 people living close to the proposed site. How come this is facing another round of consultations when the local residents are still here, just multiplying!

I do not consider the DPD is legally compliant nor sound, in relation to Site Reference MIN 35, for the following reasons -

I note on the OS Map that you are using is originally from 2011, so the current properties down Heath Road aren't represented accurately - the 3 homes appear to be represented as 1 Tetris block! Therefore, looking at the "proposed site" you want to extract sand and gravel from, there is currently 3 homes!!

I note the Mineral reserve has been amended and reduced from 650,000 to 525,000 and now is 500,000. Does this mean the depth of the 'pit' is going to be less? More clarification is required please.

No-where does it state the proposed operational hours and noise limits. Snetterton Racing Circuit have rules to abide by, so these need clarification.

Heath Road is a cul-de-sac (the rail crossing was closed 25 years ago on 29/03/1993 and the movement of lorries will mean that the road will be blocked during operational hours. Implications as follows:-
I am a Class 2 lorry driver and work full-time so its imperative I get to work to provide for my family.
Emergency Vehicle access would be hampered. In the case of the Wood Yard fire on 25/06/09, we were trapped with no means of vehicular access. [redacted text - personal data] the thought of an ambulance being delayed because of potential lorry movement doesn't bear thinking about. My wife and 2 children [redacted text - personal data] will be affected by the dust from extraction.

The top of the road is a sharp bed - one only has to note the chevron signs on the corner!


Down Heath Road we have colonies of bats which are protected under Schedule 2 of the Conservation Natural Habitats Regulations 1994. This proposed site would affect their local distribution or abundance, or affect their ability to survive, breed or rear young - this is an offence to upset their habitat.

Our landlords have installed a Bore Hole for our household use and I fear that this extraction will disturb the land and therefore our water supply - the full effects of extraction haven't been fully investigated.
The proposed site is very close to the closed landfill site which was unlined and filled with inert waste. There is regular testing (one site down Heath Rd) to measure any potential contamination of the land. This extraction has the possibility to speed up the potential contamination of the surrounding land.

This proposed site has been rejected multiple times already due to the close proximity of local residents and habitation. I now live here with my husband and our 3 children, plus the cottage opposite us has a family so that is an extra 7 people living close to the proposed site. How come this is facing another round of consultations when the local residents are still here, just multiplying!

I do not consider the DPD is legally compliant nor sound, in relation to Site Reference MIN 35, for the following reasons:-

I note on the OS Map that you are using is originally from 2011, so the current properties down Heath Road aren't represented accurately - the 3 homes appear to be represented as 1 Tetris block! Therefore, looking at the "proposed site" you want to extract sand and gravel from, there is currently 3 homes!!

I note the Mineral reserve has been amended and reduced from 650,000 to 525,000 and now is 500,000. Does this mean the depth of the 'pit' is going to be less? More clarification is required please.

No-where does it state the proposed operational hours and noise limits. Snetterton Racing Circuit have rules to abide by, so these need clarification.

Heath Road is a cul-de-sac (the rail crossing was closed 25 years ago on 29/03/1993 and the movement of lorries will mean that the road will be blocked during operational hours. Implications as follows:-
I am a senior co-ordinating midwife which is a reserved occupation and the slightest of incidents would mean I would be unable to leave for work. It is vital that I am at work on time.
Emergency Vehicle access would be hampered. In the case of the Wood Yard fire on 25/06/09, we were trapped with no means of vehicular access. [redacted text - personal data] the thought of an ambulance being delayed because of potential lorry movement doesn't bear thinking about. Myself and 2 children [redacted text - personal data] will be affected by the dust from extraction.

Down Heath Road we have colonies of bats which are protected under Schedule 2 of the Conservation Natural Habitats Regulations 1994. This proposed site would affect their local distribution or abundance, or affect their ability to survive, breed or rear young - this is an offence to upset their habitat.

In my original objection letters, I have written that the site was 7.38ha, however in the most recent document you have published, it states it is 7.5ha. Now I have lived here since I was 6 hours old and haven't noticed that the field boundary has grown! Dearie me, how utterly confusing your documents are!

Our landlords have installed a Bore Hole for us and I fear that this extraction will disturb the land and our water supply - the full effects of extraction haven't been fully investigated.
The proposed site is very close to the closed landfill site which was unlined and filled with inert waste. There is regular testing (one site down Heath Rd) to measure any potential contamination of the land. This extraction has the possibility to speed up the potential contamination of the surrounding land .

MIN 35 application

I would like to lodge my objection to the above application.

No 1, We suffer from a lot of noise in our village more would be totally unacceptable, we have lived in Eccles for over 30 years during this time Snetterton has got louder and louder in fact tonight they have only just stopped (written at 7.40pm) we have to endure the circuit very nearly everyday and evening, they are the only track to hold a 24 hour race and have up to 31 days a year using un-silenced vehicles. We also have to put up with reverse bleepers from lorries and forklifts both day and night from the warehouses in the industrial estate.

No 2, I was under the the impression we had a buffer between us and industry area this field is in the buffer area. If this mineral pit is allowed what else will be allowed to come in the buffer zone.

No 3, I also think we will get lots of dust from this site not good for the health of Eccles people.

No 4, When you no longer extract minerals you will use it to get rid of waste, so we will suffer from smells and flies both of which are not good for the health of Eccles people.

Please turn down this application as it will ruin our lives.

MIN35 - Land at Heath Road, Quidenham

We are very surprised that the letter from yourself only went to a handful of houses when this application will effect everybody living in our small village.

Please decline the above application for removal of minerals in our village Eccles. My reason are as follows.

I want to keep a buffer between the village and the industrial area and believe a buffer zone has already been agreed so surely these fields are in the buffer zone.

We have experienced the noise of a gravel/sand pit previously, it was awful.

We already have to put up with the noise from Snetterton race track this is the only track in the UK to hold a 24 hour race, they have up to 31 days a year with cars which are un-silenced, we also hear the tannoy. Plus reverse bleeper noise from forklifts and lorries on the industrial estate both day and night.

What happens after the minerals have been removed we suspect you will use it for landfill, once again we have had very bad experiences with that. The smell was horrendous it meant you could not open windows and the back of our house would be covered in flies.

Please think of the people of Eccles who have breathing problems the dust from the site will not help them one bit.

Once again please decline this application, our future is in your hands.

I received a copy of Your Council's letter of 26 June 2018, addressed to a select number of households concerning the above.
I am rather perturbed about a number of aspects of this proposal. As I understand it, this letter was sent to only six residents of Sandfield Lane/Heath Lane, presumably on the assumption that those who did not receive this information would not be affected. I also understand that the Parish Council was not informed.

This assumption is completely wrong. The proposal is to excavate some half a million tonnes of sand over a prolonged period. This will mean noise pollution, air pollution, possibly a prolonged and no doubt noisy building project, a possibly unsightly finished product and overall it will have a detrimental effect on all the residents of this village. Given that we already have to tolerate substantial track noise from Snetterton, a public nuisance in the form of a sometimes intolerable level of Tannoy announcements from the track, and more recently the continual noise of vehicles reversing from the ever increasing industrialisation this is adding insult to injury.

The increase in traffic on narrow country lanes will be substantial and there will not doubt be further environmental effects as well.
All in all, it is an ill-advised and unnecessary scheme and to presume that only a few residents will be affected is a gross mis-statement.
How did you arrive at the conclusion that only residents within 250 yards would be affected? Why, if you did not advise the Parish Council, did you consider it was unnecessary to do so?
We strongly object to these scheme and we strongly object to the rather high-handed approach of Norfolk County Council.

Re: Norfolk Minerals and Waste Local Plan Review: Initial Consultation

Regarding the above referenced planning consultation I would like to raise a number of points of objection.

In Eccles we are already subject to a number of industrial operations, doing absolutely nothing to enhance the village quality of where we live, in addition to having to endure an almost daily noise pollution from the racing circuit. Is it really fair that Eccles may be considered as an easy touch and "one more industrial installation won't hurt"?

Specifically with regards to the above consultation, is it possible to guarantee 100% that there will be absolutely no noise or dust pollution from the installation planned so close to residential properties, some of which have asthma-sensitive residents? One property's water supply comes from the water table via a well; will this water remain totally unpolluted and potable?

Apart from the close proximity of the proposed site to a number of residences, the neutral zone established between the existing industry and the village will be breached and could be viewed as a precedent for future breaches if planning permission is ultimately approved. This neutral zone is used daily by dog walkers and ramblers, and the installation would be visible to all residents.

Increased vehicle movements of up to 32 lorries a day put additional strain on our narrow road system, not to mention the increased exhaust pollution and danger to local residents when driving.

I really do feel that Eccles is already full up with industrial operations and should on this occasion be given a break. I cannot imagine the value of my property would benefit from any planning application being granted, quite the opposite. Who will pay for this and the inevitable effect of dust pollution?

Please consider the above carefully and come to the resident-friendly and socially aware conclusion to down any approval to continue in this matter.

Re: Norfolk Minerals and Waste Local Plan Review: Initial Consultation

Regarding the above referenced planning consultation I would like to raise a number of points of objection.

In Eccles we are already subject to a number of industrial operations, doing absolutely nothing to enhance the village quality of where we live, in addition to having to endure an almost daily noise pollution from the racing circuit. Is it really fair that Eccles may be considered as an easy touch and "one more industrial installation won't hurt"?

Specifically with regards to the above consultation, is it possible to guarantee 100% that there will be absolutely no noise or dust pollution from the installation planned so close to residential properties, some of which have asthma-sensitive residents? One property's water supply comes from the water table via a well; will this water remain totally unpolluted and potable?

Apart from the close proximity of the proposed site to a number of residences, the neutral zone established between the existing industry and the village will be breached and could be viewed as a precedent for future breaches if planning permission is ultimately approved. This neutral zone is used daily by dog walkers and ramblers, and the installation would be visible to all residents.

Increased vehicle movements of up to 32 lorries a day put additional strain on our narrow road system, not to mention the increased exhaust pollution and danger to local residents when driving.

I really do feel that Eccles is already full up with industrial operations and should on this occasion be given a break. I cannot imagine the value of my property would benefit from any planning application being granted, quite the opposite. Who will pay for this and the inevitable effect of dust pollution?

Please consider the above carefully and come to the resident-friendly and socially aware conclusion to down any approval to continue in this matter.

Norfolk minerals and waste local plan. Min35

Comments and objections regarding the above proposed plan.

1. I am concerned that a letter was only sent to occupants that live within only 250 m of the plan! Within half-a-mile you have a whole village that will be affected. This smacks of underhandedness!

2. As with the previous guarry and then landfill, we will be having all the same issues and will be even nearer.

3. As Eccles l live and have done for the last 27 years l have some knowledge of the area.

4. The prevailing wind is southwesterly and Eccles lies in direct line of any pollution be it air, noise or any other environmental hazards that go with extraction and the landfill.

5. Heavy traffic due to lorries will increase. We are supposed to have a 7.5 tonne weight restriction around the parish put lorries totally flaut this and nobody "police's" it.

6. Noise pollution will be an issue. Look at how much Mr. Palmer has spent on bunding and other noise reduction elements at Snetterton to see what costs are involved.

7. Two other sites in the area would be less environmentally obtrusive. They are on the other side of the A11. MIN102, MIN201.

8. Even capped the last landfill on Heath road created noise pollution into Eccles from its methane conversion machinery.

9. Light pollution. There will even more, as Snetterton industrial steadied lit up like a Christmas tree in once was a reasonable dark sky area.

I am a resident of Station Road, Eccles and have severe concerns regarding the above proposal.

1. Air Pollution. The prevailing south- westerly wind would carry dust from the site straight across the village possibly causing breathing difficulties for myself and asthma sufferers.
2. Noise Pollution. The excavation would mean an increase in noise. We already have the noise from Snetterton Racetrack and the railway to contend with.
3.Increase of Traffic. I understand that approximately 32 lorries per day would be used to move the sand. This would inevitably lead to more traffic along Station Road which is already used as a 'rat run' despite the supposed 7.5 tons weight limit.
4.Loss of Habitat for Wildlife. This area is used as a nesting site for skylarks and by many other species, their habitat would be destroyed.
5. Property Values.The air and noise pollution and the fact that the site would be visible from my property would, I believe, affect the value of the property.
6. What would happen once excavation is completed? I am concerned that the site would be used as a landfill, which would result in further air pollution and also fly infestations.
7. Designated Buffer Zone. I was of the understanding that the area in question was designated a buffer zone between the industrial area and the residential area and would not be developed.

I would be grateful if you would consider these points before making your final decision.

I wish to object to this site within the policy.

Amenity: the document states that the nearest property is within 42 metres of the proposed site and that the greatest impact would be within the first 100m. Although the text states this would be if it is "uncontrolled", there is no proposal about how the impact on the very local properties would be mitigated. The initial conclusion states the potential for visual buffers, however, there is no statement on how the noise from the operation of the site and the heavy vehicle traffic would be mitigated. Although the site is not far from the racing circuit, the noise from that operation is not constant, and only impacts properties according to the wind direction. The noise from this site would have a negative impact on the residents due to the operational processes.
Despite proposing a smaller extraction area, the site is too close to residential properties and will negatively impact their value as well as the lives of the residents.

Landscape: while the site is on the edge of an industrial area, the statement that it "could not be considered a tranquil, unspoilt area of countryside" is a misrepresentation that the arable site is a buffer for this area of countryside. The houses at the end of Heath Road (not Heath Lane as the document calls it) and on Sandfield Lane are on the edge of countryside. Extracting sand and gravel from the site would compromise this countryside location.

Industry: although access to the site is through an industrial area, it is not heavy industry. The nearby Oakwood Industrial Estate is comprised of light industry (window supplies, a brewery, mobility centre, artisan kitchen making), and any significant increase in daily lorry movements, increased noise, and visual impacts may affect the viability of these small businesses.

Firstly I wish to express my deep concern that plans of a development that will have a very considerable impact on the village of Eccles had not received sufficient publicity as to make all residents aware. This is a small village with a few new houses being built and planning permission given for a group of houses that will be directly facing this site. Such a development will spoil the tranquility of the village and have a considerable affect on house values. I believe the council has completely failed in its duty of care to residents in its failure to inform all affected. I cannot help but question if this was due to the fact that by not doing so it was hoped this development could be passed with few objections?

I wish to object to the development of this site for sand extraction on the following grounds -

1. Development of the site will remove the buffer zone between the industrial activities at Snetterton and the village of Eccles. I believe that it was agreed between villagers and the developers of the industrial zone when it was first built that this would be maintained.

2. Despite the plans for the inclusion of shielding features such as trees and bunds this site will still be visible from the village. It is on a small hill that faces the village and unless the trees planted are of a considerable size and maturity and many years elapsed before work starts the extraction period would be during a time when these trees do not provide sufficient screening.

3. Noise - We can already hear the sound of reversing warnings from vehicles up at the Snetterton Industrial area and there is obviously intermittent noise from the race track. We accept this but the sand quarrying works would involve many vehicles and almost continuous machinery noise with conveyors and plant close to the village. The working hours of the site have also not been determined. This has the potential to affect the quality of life for all that live there.

4. Dust - The wind often blows in the direction of the village from the proposed site. Despite dust extraction plans I believe we will see periods where our houses, washing etc are coated in dust. This dust in the air also has the potential to affect the health of residents. The harmful effects of inhaling silicates and sands are now becoming known! Should the health of residents be affected it is highly likely that the council and owners of the site will face the considerable costs of litigation and compensation.

5. Conservation issues - I am told there are considerable numbers of bats and other wildlife in the woods to the East of the site. The noise and disturbance created is likely to make these areas no longer suitable habitats.

I am writing as Chairman of Quidenham Parish Council, in which the proposed site is situated. This is a very sensitive site being close to main village and has caused concern to residents in the past. We therefore held a meeting of the Parish to gauge opinion, given that several years have passed. I was anxious to encourage them to read the assessment in full so that any comments they have would relate directly to this document. I know several people have already provided their comments on-line.

The comments of the Parish Council are as follows:

General: Whilst the document is factual in its assessment, it does not provide the reader with a full picture of the site.
- This site sits between the Industrial Snetterton Heath and the village of Eccles. In that sense it acts as a buffer between the industrial and the rural. To breach this 'neutral' zone would risk destroying the very character of our community.
- Allowing this operation on this site would open up the risk of further development along this neutral corridor, again destroying the character of our community. This must surely be taken into account?
- What makes matters worse is that the site sits above the village, being on the perimeter of the East Breckland Plateau. This means that the site overlooks the village and any intrusion as a result of the works would be compounded.
- The document mentions in passing the existence of the landfill site to the north. However, this has caused enormous anxiety to residents in past years and any ground works close to the landfill are bound to ring alarm bells.

Amenity: Noise and dust are inevitable in an operation such as this.
- The railway spur which sits close to the site brings in gravel, which is loaded onto trucks near the industrial buildings to the north. These are further away from residents than the proposed sand extraction and yet the vehicles operating on this site are clearly audible. The safety 'bleeps' when the vehicles reverse can carry a considerable distance and no amount of screening will prevent this.
- The prevailing winds are from the West, which means that any dust will head in the direction of our village. We cannot see how this can be mitigated given the very dry and windy conditions experienced in 2018.

Highway access: The work required to improve the site access is considerable, Can this really be viable?

Historic environment / Archaeology: The assessment in this regard seems to be reasonable given the historic nature of this region.





Landscape: Some additional comments.
- Whilst this site cannot be considered a tranquil area of countryside it provides a vital 'buffer' between industrial and rural. Any intrusion into this area would completely destroy any existing amenity/landscape value.
- There are no existing buffer zones or advanced planting on this site, which means that screening would rely entirely on some form of bund. Given that the site overlooks the community we fail to see how any bund would be anything other than a major intrusion for those living nearby.

Ecology/Water Framework Directive: We note that the extraction site would be worked dry. However, given the location of the adjacent landfill site, we are not convinced that some 'leakage' from this site might occur. We know that substantial amounts of contaminated liquids still exist within the landfill. Although the site is lined, the poor management of the site in past years makes us all understandably sceptical.

Restoration: This is perhaps the most worrying aspect of this proposed operation. The assessment paints a quite rosy picture of the restoration and its benefits. However, nothing is guaranteed. After seven years of extraction will this site really be restored or will it become just another extension of the landfill site adjacent? Other uses for the site may also be to tempting to resist. Past experience of the landfill site does not fill us with much confidence.

Summary: Quidenham Parish Council has always supported the development of Snetterton Heath, as it recognises the importance of this area to Breckland/Norfolk. Indeed, many of the residents close to this site have been fully supportive of the Council. We ARE NOT therefore a NIMBY community. This proposed operation must be balanced with a desire to maintain the predominantly rural feel of our community. Any intrusion onto this site has the potential for causing irreparable damage to the lives of our residents. This proposed site is just to close to our village and will do far more harm than good.

I was surprised given the closeness of the planned development that we did not hear from you directly. I wish to object strongly to the proposal for the following reasons:
a) Dust-I am concerned that there will be increased levels of dust which is worrying from a health perspective.
b) Bats- What studies have been undertaken to establish the habitats of the bats that are present in the area.
c) Noise- Noise can already be heard from both the track at Snetterton and the industrial area. Whilst this is just at acceptable levels increased noise from the extraction and the removal of the sand would be unacceptable.
d) Siting- The area proposed for the extraction can be seen from the village and would both spoil the character and ambiance of the village and I fear the value of the properties would be reduced by this and the noise and dust.
e) Village boundary- The siting of such a development prompts concern that Eccles would become an extension of Snetterton industrial area affecting the character of the village and the housing costs.

Regarding the above referenced planning consultation I would like to raise a number of points of objection.

In Eccles we are already subject to a number of industrial operations, doing absolutely nothing to enhance the village quality of where we live, in addition to having to endure an almost daily noise pollution from the racing circuit. Is it really fair that Eccles may be considered as an easy touch and "one more industrial installation won't hurt"?

Specifically with regards to the above consultation, is it possible to guarantee 100% that there will be absolutely no noise or dust pollution from the installation planned so close to residential properties, some of which have asthma-sensitive residents? One property's water supply comes from the water table via a well; will this water remain totally unpolluted and potable?

Apart from the close proximity of the proposed site to a number of residences, the neutral zone established between the existing industry and the village will be breached and could be viewed as a precedent for future breaches if planning permission is ultimately approved. This neutral zone is used daily by dog walkers and ramblers, and the installation would be visible to all residents.

Increased vehicle movements of up to 32 lorries a day put additional strain on our narrow road system, not to mention the increased exhaust pollution and danger to local residents when driving.

I really do feel that Eccles is already full up with industrial operations and should on this occasion be given a break. I cannot imagine the value of my property would benefit from any planning application being granted, quite the opposite. Who will pay for this and the inevitable effect of dust pollution?

Please consider the above carefully and come to the resident-friendly and socially aware conclusion to down any approval to continue in this matter.

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: Whilst we are unable to comment on the wider impacts of this proposal as they are outside of our remit, should this site be progressed, then we strongly support the Council's recommendations that this site should be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.

I am writing to register my objection to the referred proposal on the following points:
The site in question breaches the 'buffer zone' between the industrial units and Snetterton and Eccles village.
Consequently
- the noise will be constant and unbearable (I am retired and at home most of the time - I chose to relocate to Eccles because of its quiet environment).
- dust and air pollution. The prevailing wind blows from the West - Directly from the proposed site to the village!
- property values in Eccles and the immediate environs would be severely effected, no doubt.
And furthermore, what will the resultant pit be used for?
Will it be used for landfill?
If so, this in turn would create further pollution from noise, insects etc.
As a member of our Environmental Services, Ms Jeffery, I ask that this review is considered in far more detail.

Thank you for the opportunity to comment on the Initial Consultation for the Norfolk Minerals and Waste Local Plan. We have commented on the Policies and the Allocated Sites.
Policy MW2: Development Management Criteria
The Water Framework Directive (WFD) is an important piece of legislation when reviewing planning applications. Applicants will need to demonstrate their activities will not lead to deterioration, taking account of WFD objectives and River Basin Management Plans.
Biodiversity and geological conservation
Much of this section is focused on the terrestrial environment. We would like to see the potential impacts of waste extraction on aquatic ecology addressed in the document. Aquatic ecology assessments should be carried out to determine the potential impacts on fish, invertebrates and aquatic habitat. The need for WFD assessments should be reiterated here.
Developments are likely to encounter a number of protected species issues in Norfolk which they will need to address. Species records can be obtained from the Norfolk Biodiversity Information System (NBIS). This data can be used to inform desk based studies and future surveys.

Land and Soil Resources
We welcome this section but recommend that the last sentence is expanded to address soil erosion. Our proposed wording would be: The overall integrity of land and soil should be protected, with measures taken to prevent/control soil erosion where applicable, during working and long-term use of the site once it is fully restored

Flooding
We are pleased to see that flood risk is a consideration in the policy, however it is limited to pluvial and fluvial. Tidal, groundwater and reservoir flooding should be considered. Therefore we recommend removing the words 'Pluvial and fluvial' so that all sources of flood risk are considered.
Minerals and Waste sites have strong potential to offer betterment through reducing the runoff rates, thereby reducing the flow to adjoining watercourses. Each application should explore the potential for betterment in the site specific Flood Risk Assessment (FRA), particularly when it comes to restoration. Ideally the requirement for Minerals and Waste sites to provide flood risk betterment where possible should be identified in Policy MW2 and may be most appropriate in the last paragraph.
The first paragraph on page 30 discusses the need to ensure flood risk is not increased. The NPPF states that all plans should use opportunities offered by new development to reduce the causes and impacts of flooding. The PPG, paragraph 050, states that authorities and developers should seek opportunities to reduce the overall level of flood risk in the area and beyond. There is great opportunity for minerals and waste development to provide flood risk betterment both locally and downstream, particularly during the restoration phase. It would be beneficial to see something in the plan that encourages opportunities for betterment.
In order to comply with the Planning Practice Guidance, we would require any planning application to consider the following issues if a site is at risk of flooding; this includes a number of the sites that have been allocated within this Plan:
 An FRA would be needed to demonstrate the risk of flooding to those working onsite and to ensure that flood risk is not increased.
 Climate change should be considered to determine the risk to the site in the future. In areas that benefit from defences, residual risk will need to be considered and what may happen in an overtopping or breach scenario. We would expect bunds and materials to be stored outside of the floodplain, otherwise we would expect flow paths to be considered to ensure there is no increase in flood risk and bunds to have gaps in for flood water.
 We would recommend that a flood plan is prepared for the development, which should include an appropriate method of flood warning and evacuation, to ensure the safe use of the development in extreme circumstances.
 Some of the allocated sites are extensions to existing sites. In this instance, appropriate measures should already be in place to manage flood risk. The application should however consider the impacts of extending the works and any site specific issues.

Environmental Permit for Flood Risk Activities
An environmental permit for flood risk activities may be required for work in, under, over or within 8 metres (m) from a fluvial main river and from any flood defence structure or culvert or 16m from a tidal main river and from any flood defence structure or culvert.

Application forms and further information can be found at: https://www.gov.uk/guidance/flood-risk-activities-environmental-permits. Anyone carrying out these activities without a permit where one is required, is breaking the law.
The Local Plan should consider this when allocating development sites adjacent to a 'main river'. A permit may be required and restrictions imposed upon the work as a result in order to ensure the development does not have a detrimental impact upon the environment and flood risk.
Water Quality
This section addresses water as a resource, but does not expand upon pollution in relation to environmentally sensitive locations. We suggest the following wording could be used:
As well as flood risk, the effect of minerals and waste management development on all water bodies should be addressed in accordance with the WFD. This includes the quality and quantity of surface water and groundwater. A further consideration could be the protection of sources of drinking water, identified via designated Source Protection Zones. Development proposals must therefore prevent the pollution of surface water and groundwater by fuels, chemicals and other contaminants (e.g. sediments), and include pollution prevention planning for incidents such as fires (and the risks posed by contaminated fire-fighting water), collisions and vandalism. Minerals development must also ensure there will be no significant change to groundwater or surface water levels, including careful monitoring of any 'dewatering' operations (whereby water is pumped out of a pit to allow dry working below the water table) to ensure no adverse impacts on surrounding water availability and/or the water environment.
Point b) should be expanded to recognise the sensitive areas in Norfolk such as the Broads and SSSIs. Suggested wording would be: The quality of surface waterbodies and groundwater, with particular regard to preventing the deterioration of their existing status, and the quantity of water for resource purposes within water bodies and in environmentally sensitive areas that may be affected by water quantity and quality;

Environmental Permit for Dewatering
Dewatering for quarrying or mineral extraction purposes now falls under water abstraction licencing legislation. Any developer of a quarry or mineral extraction should contact the Environment Agency to discuss obtaining such a licence. The Environment Agency would normally expect dewatering water to be returned to the local aquifer within a short time period
Policy MW4: Climate Change Mitigation and Adaption
Part F may be better suited in the flooding, water resources and water quality section on page 30. However, it is important that climate change is considered when assessing flood risk. Therefore this section could specify that: 'site specific FRAs should include an assessment of the impact of climate change on flood risk using appropriate climate change allowances'.
Policy MW5: The Brecks Protected Habitats and Species
We support this policy's statement to protect the important flora and fauna within The Brecks. The allocated sites are mostly located away from sites supporting aquatic ecological features in Norfolk such as The Broads and North Norfolk Coast, but if any come forward in future then a further policy to address these features would assist in avoiding inappropriate development at these locations.

Policy MP5: Core River Valleys
Whilst recognising that mineral deposits have to be worked where they occur, new developments should be restricted to higher ground avoiding river valleys where possible to reduce the risk of mineral extraction impinging on groundwater.
Various authorities are restoring sections of river valley throughout Norfolk in order to enhance the ecology and condition status of water bodies. Developments which impact the success of existing restoration schemes will hinder the water bodies' potential to reach good status. This is particularly relevant to proposed sites MIN 55, MIN 202 and MIN 58. The location of these sites is close to an ongoing project to restore the River Wensum SSSI/ SAC/ SPA. If the developments are accepted there would be scope to work in partnership with the EA to create some enhancements which could include the use of natural flood management measures such as woody debris, planted berms, floodplain reconnection and tree planting.

Policy MP2: Spatial strategy for mineral extraction
We agree that each designated site and sensitive receptors will have different interest features and sensitivities. Therefore, proposed developments will need to be assessed to determine their potential impacts on the features for which each site is designated. Appropriate mitigation should be applied to reduce potential impacts. These may include planting buffer zones of trees around sites to act as dust suppression, and limit noise and light pollution from the development.
Policies MP7: Progressive Working, Restoration and After-use and MP8: Aftercare
The aggregate industry has the potential to create opportunities for delivering the UK BAP targets for conserving habitats and species. Topsoil at sites post-extraction can be reinstated and used to create wildflower meadows rich in pollinating insects.
Where possible green corridors should be strategically placed to link wildlife sites, creating a larger area for biodiversity which is consistent with the Biodiversity 2020 strategy to advocate the creation bigger and less fragmented areas for wildlife.

Native crayfish Ark sites
Using mineral extraction sites can provide highly suitable, inexpensive Ark sites for the rapidly declining white clawed crayfish. Norfolk contains some of the few remaining white claw crayfish populations but these are under threat from disease and non-native crayfish. Extraction operations can create permanently filled water bodies, isolated from existing rivers containing invasive crayfish and the virulent crayfish plague. We would encourage the creation of Ark sites to be a component of aftercare, thereby the industry will be contributing to regional and national BAP targets, adding greater value to restoration strategy. There would be opportunities for working in partnership with the EA, Norfolk Rivers Trust and Buglife to establish Arks at sites post extraction.

Policy WP15: Whitlingham Water Recycling Centre
Water Recycling Centres have the potential to cause significant impact on the water environment, and inhibit the ability for water bodies to achieve 'good' status under the WFD. We therefore welcome Whitlingham Water Recycling Centre having a long term policy to ensure that further capacity is provided in line with further growth.
Allocated Sites
In this section we have provided bespoke guidance relating to ecology, groundwater protection and flood risk at certain sites. MIN 38, Land at Waveney Forest, Fritton is of considerable concern.

MIN 38, Land at Waveney Forest, Fritton
We have significant concerns regarding the allocation of this site from both a Groundwater Protection and an Ecology perspective.
Groundwater Protection at Waveney Forest
Protection of groundwater quality and potable drinking supplies are of paramount concern to us.
It is highly likely that the quarry operators at this site would need to excavate below the water table, which is very shallow at this location. As such, significant dewatering would most likely result in groundwater level drawdown outside the boundary of the quarry and would affect/derogate nearby abstractions. We are aware of some local, licenced and unlicensed, abstractions which would most likely be affected.
For additional reference there is a public water supply (Northumbrian Water/Essex & Suffolk) abstraction from Fritton Lake. This is technically classed as a surface water abstraction because it is taken from the lake, but the lake is virtually a groundwater fed body, and so it is in hydraulic continuity with the same geological strata that the quarry wishes to excavate, as are the surrounding marshes. Unfortunately, our system will not assign a source protection zone to the abstraction because it only recognises the abstraction as being from surface water. While it is probably unlikely that the Lake would be impacted to the extent that it affects the public water supply abstraction, there remains the concern of contamination from air borne and groundwater pollutant resulting from quarry activities. This would otherwise have been more rigorously assessed should a Source Protection Zone have been assigned to this abstraction.
As of January this year dewatering is now a licensable activity as a New Authorisation. If we were consulted over this application, we would take a hard line, requesting detailed risk assessments and environmental impact assessments, including implications for impact to features assessed under the Water Framework Directive. We would expect detailed calculations of impact to Fritton Marshes, flow to the Waveney, Fritton Warren South County Wildlife Site, Fritton Lake, effects to local abstractors (including an updated search for domestic sources) and the Public Water Supply.
Ecology at Waveney Forest
This site has been raised in previous plans and we remain concerned that the size of the removal of aggregate could cause negative impacts on visual amenity, character and wildlife.
Numerous protected species in the area linked to fringing wetland habitat such as water vole, otter, Norfolk hawker, grass snake. Others linked to heathland and mire habitat to be lost include adder, lizard, slow-worm, nightjar and turtle dove. The narrow-mouthed whorl snail has also been recorded in habitats fringing the Waveney.
Impacts on the quality of water from run-off and draining down of surrounding wetland habitats (marshes, Fritton Lake) are likely to be severe. There is potential to compromise projects and eel passage improvements on nearby Blocka Run.
Several County Wildlife Sites (mainly heathland) will be lost to development, and it is unclear how impacts will be offset and even whether it is possible.

Allocated Sites with Ecological Constraints
The following section outlines the constraints at certain sites, which will need to be considered at the application stage to ensure that ecology is not adversely affected.
MIN 48 The proximity of the site to Swannington Upgate Common. Potential impacts on features of interest and Swannington beck, a chalk stream with associated priority habitat and species.
MIN 96 Close proximity to Spixworth Beck, concerns over impacts on the associated habitat including coastal and floodplain grazing marsh.
MIN 45 Potential impacts to ancient woodland, and county wildlife sites, particularly the hydrology and ecology of Syderstone Common SSSI which supports a population of protected natterjack toad.
MIN 202 The proximity to ancient woodland and county wildlife sites could cause habitat fragmentation.
MIN 115 Potential loss of deciduous woodland priority habitat.
MIN 25 Potential impacts on Priority Habitats - deciduous woodland and coastal and floodplain grazing marsh.
MIN 71 Proximity to Holt Lows SSSI and potential impact on groundwater dependant habitat.

Allocated Sites with Groundwater Protection Constraints

In this section we have provided guidance on the pollution prevention measures that we would expect to be considered at these allocated sites.

MIN 200, Land west of Cuckoo Lane Carbrooke
It is unclear whether de-watering is proposed. There is mention of the proximity to Scoulten Mere Wetland SSSI. If no de-watering is to take place then there would be no impacts, however if de-watering is to take place, by inference, there may be impacts. We welcome the recommendation for a hydrogeological impact assessment to determine if de-watering is acceptable, and if not then the mineral may have to be worked wet. With this proviso we agree with the conclusions that the site is likely to be suitable for complete sands and gravel extraction. The need for hydrogeological impact assessment should be added to the list of the requirements that need addressing in the initial conclusion.
We are aware of the proposed restoration of this site. The site lies within an SPZ 2 so it is recognised that sufficient protection of groundwater is required at the site. Groundwater has been identified at the base of excavation, and de-watering is a potential issue.As such any waste management development must employ pollution prevention measures where possible. The aquifers on site must be adequately protected from potential contamination, and any waste management development will require robust risk assessment. When this site is progressed, we will be heavily involved to ensure environmental protection.

MIN 35, land at Heath Road Quidenham
The site is located approximately 2km from Swangey Fen (wetland SSSI) and also close to Banham Fens and Quidenham Meres SSSI. This is proposed to be worked dry so, we have no de-watering concerns. The site is considered suitable provided there is no working below the water table.

MIN 102, land at North Farm Snetterton
The site is adjacent to Swangey Fen SSSI and therefore we do not consider it suitable for mineral extraction. A stronger argument is required than that presented in the recommendations, which state that 'this is a significant constraint to the development of the site and therefore the site is considered less deliverable than other sites that have been proposed for extraction'. If it is taken forward as a site it would have to be worked wet because we would not grant a de-watering licence, and we would request with strict planning conditions.
As the excavated void is to be utilised for waste disposal or recovery, a robust risk assessment will be required. We would expect waste disposal here to meet all best practice techniques. Due to the sensitivity of groundwater (within an SPZ2) it will not be possible to accept reduced liner thickness or design at this site. The aquifers on site must be adequately protected from potential contamination, and if this site is progressed the Environment Agency will be heavily involved to ensure environmental protection.

MIN 201, land at Swangey Farm Snetterton
The site is adjacent to Swangey Fen SSSI and therefore we do not consider it suitable for mineral extraction. If it is taken forward as a site it would have to be worked wet because we would not grant a de-watering licence, and we would request with strict planning conditions.

MIN 6, land off East Winch Road Middleton
We agree that a hydrogeological impact/risk assessment is needed for working beneath the water table. It may be necessary to apply constraints such as a limiting or precluding de-watering at the site, which will be dependent on the results of the hydrogeological risk assessment. The assessment should include impacts on protected rights (water features and other lawful users) and the risk of pulling in contaminated groundwater due to the proximity of black borough end Landfill. The issue of contaminated groundwater being mobilised from Blackborough End landfill is not addressed in the current assessment report.

MIN 204, land off Lodge Road Feltwell
It is not clear whether de-watering is proposed. Planning requirements in the initial conclusion should include the need for 'an appropriate hydrogeological risk assessment'.

MIN 40, land east of Grandcourt Farm East Winch
We agree with the need for an appropriate hydrogeological risk assessment as set out in the initial conclusions. This should also consider the proposed restoration scheme as well as the de-watering phase. Restoration and de-watering phases should consider thepossibility of a perched aquifer in the Carstone Formation. We would not accept any passive de-watering of this aquifer.

SIL 01: This is potentially a high risk site with a County Wildlife site situated within it. However we agree with the recommendation to allocate

Further Guidance
Sites MIN 40, MIN 19, MIN 205, MIN 201, MIN 35, MIN 51, MIN 13, and MIN 32 propose low level restoration using inert material to restore the site. Whilst these sites do not lie within an SPZ we would expect groundwater to be sufficiently protected. This would involve a robust waste acceptance criteria. We would expect diligence is maintained to ensure non-inert wastes are not accepted at this site. If deposition will be sub-water table, as at sites MIN 200 and MIN 102, the applicant should refer to the EA technical guidance note 30_18 'Compliance with the Landfill Directive when depositing inert waste into water'.

At sites MIN 12, MIN 08 and MIN 45, the the excavated void is to be utilised for waste disposal or recovery, so a robust risk assessment will be required. We would expect waste disposal here to meet all best practice techniques. Due to the sensitivity of groundwater (within an SPZ3) it will not be possible to accept reduced liner thickness or design at this site. The aquifers on site must be adequately protected from potential contamination, and if this site is progressed we will be heavily involved to ensure environmental protection.

At sites MIN 6, MIN 204, MIN 23 and MIN 116 it is not stipulated if these sites are to be utilised for waste disposal or recovery. If either of the options are progressed a robust risk assessment will be required. We would expect waste disposal here to meet all best practice techniques. Whilst the site does not lie within an SPZ we would expect groundwater to be sufficiently protected.

Allocated Sites with Flood Risk Constraints

MIN 102, Land at North Farm, south of the River Thet, Snetterton
As stated on p133, the majority of site MIN 102 is situated within flood zone 1, however there is a small percentage of the site within flood zones 2 and 3 which align the River Thet. There is also a small percentage shown at risk of surface water as shown on the risk of flooding from surface water flood map.
Although the site is currently considered to be unsuitable for allocation, should this change a FRA would be needed to demonstrate the risk of flooding to those working onsite and to ensure that flood risk is not increased. The impact of climate change on flood risk will also need to be considered.

MIN 76, land at West Field, Watlington Road
The plan incorrectly states that MIN 76 is situated in Flood Zone 1. The North West corner of the site is situated in Flood Zones 2 and 3, as shown on our Flood Map for Planning. This should be updated to ensure flood risk is addressed and mitigation measures considered.

Policy MP13: Areas of Search for silica sand extraction
Policy MP13 does not address the need for an FRA, although the requirement to follow the sequential approach to flood risk has been listed. An FRA is vital if the planning authority is to make informed planning decisions. In the absence of an FRA, the flood risk resulting from the proposed development are unknown.

Planning Advice Service
We trust the advice we have given is useful and will contribute to the soundness of the emerging local plan. We will continue to provide further advice and comments at future statutory stages of the emerging local plan. Should you wish us to review any draft policies and text as well as technical documents and background studies, such as strategic flood risk assessments or water cycle studies which may be used to support your plan, we can offer this as part of our planning advice service.
This service will ensure that your evidence documents fully support the local plan and ensure that environmental issues are addressed in an effective and timely way contributing to sustainable development. As part of the planning advice service we will provide you with a single point of contact who will co-ordinate access to our technical specialists, who will be able to provide bespoke advice and help you prepare any supporting documents. We will be pleased to provide you with an estimated cost for any work we would undertake as part of the service.

Thank you for the opportunity to comment on the Initial Consultation for the Norfolk Minerals and Waste Local Plan. We have commented on the Policies and the Allocated Sites.
Policy MW2: Development Management Criteria
The Water Framework Directive (WFD) is an important piece of legislation when reviewing planning applications. Applicants will need to demonstrate their activities will not lead to deterioration, taking account of WFD objectives and River Basin Management Plans.
Biodiversity and geological conservation
Much of this section is focused on the terrestrial environment. We would like to see the potential impacts of waste extraction on aquatic ecology addressed in the document. Aquatic ecology assessments should be carried out to determine the potential impacts on fish, invertebrates and aquatic habitat. The need for WFD assessments should be reiterated here.
Developments are likely to encounter a number of protected species issues in Norfolk which they will need to address. Species records can be obtained from the Norfolk Biodiversity Information System (NBIS). This data can be used to inform desk based studies and future surveys.

Land and Soil Resources
We welcome this section but recommend that the last sentence is expanded to address soil erosion. Our proposed wording would be: The overall integrity of land and soil should be protected, with measures taken to prevent/control soil erosion where applicable, during working and long-term use of the site once it is fully restored

Flooding
We are pleased to see that flood risk is a consideration in the policy, however it is limited to pluvial and fluvial. Tidal, groundwater and reservoir flooding should be considered. Therefore we recommend removing the words 'Pluvial and fluvial' so that all sources of flood risk are considered.
Minerals and Waste sites have strong potential to offer betterment through reducing the runoff rates, thereby reducing the flow to adjoining watercourses. Each application should explore the potential for betterment in the site specific Flood Risk Assessment (FRA), particularly when it comes to restoration. Ideally the requirement for Minerals and Waste sites to provide flood risk betterment where possible should be identified in Policy MW2 and may be most appropriate in the last paragraph.
The first paragraph on page 30 discusses the need to ensure flood risk is not increased. The NPPF states that all plans should use opportunities offered by new development to reduce the causes and impacts of flooding. The PPG, paragraph 050, states that authorities and developers should seek opportunities to reduce the overall level of flood risk in the area and beyond. There is great opportunity for minerals and waste development to provide flood risk betterment both locally and downstream, particularly during the restoration phase. It would be beneficial to see something in the plan that encourages opportunities for betterment.
In order to comply with the Planning Practice Guidance, we would require any planning application to consider the following issues if a site is at risk of flooding; this includes a number of the sites that have been allocated within this Plan:
 An FRA would be needed to demonstrate the risk of flooding to those working onsite and to ensure that flood risk is not increased.
 Climate change should be considered to determine the risk to the site in the future. In areas that benefit from defences, residual risk will need to be considered and what may happen in an overtopping or breach scenario. We would expect bunds and materials to be stored outside of the floodplain, otherwise we would expect flow paths to be considered to ensure there is no increase in flood risk and bunds to have gaps in for flood water.
 We would recommend that a flood plan is prepared for the development, which should include an appropriate method of flood warning and evacuation, to ensure the safe use of the development in extreme circumstances.
 Some of the allocated sites are extensions to existing sites. In this instance, appropriate measures should already be in place to manage flood risk. The application should however consider the impacts of extending the works and any site specific issues.

Environmental Permit for Flood Risk Activities
An environmental permit for flood risk activities may be required for work in, under, over or within 8 metres (m) from a fluvial main river and from any flood defence structure or culvert or 16m from a tidal main river and from any flood defence structure or culvert.

Application forms and further information can be found at: https://www.gov.uk/guidance/flood-risk-activities-environmental-permits. Anyone carrying out these activities without a permit where one is required, is breaking the law.
The Local Plan should consider this when allocating development sites adjacent to a 'main river'. A permit may be required and restrictions imposed upon the work as a result in order to ensure the development does not have a detrimental impact upon the environment and flood risk.
Water Quality
This section addresses water as a resource, but does not expand upon pollution in relation to environmentally sensitive locations. We suggest the following wording could be used:
As well as flood risk, the effect of minerals and waste management development on all water bodies should be addressed in accordance with the WFD. This includes the quality and quantity of surface water and groundwater. A further consideration could be the protection of sources of drinking water, identified via designated Source Protection Zones. Development proposals must therefore prevent the pollution of surface water and groundwater by fuels, chemicals and other contaminants (e.g. sediments), and include pollution prevention planning for incidents such as fires (and the risks posed by contaminated fire-fighting water), collisions and vandalism. Minerals development must also ensure there will be no significant change to groundwater or surface water levels, including careful monitoring of any 'dewatering' operations (whereby water is pumped out of a pit to allow dry working below the water table) to ensure no adverse impacts on surrounding water availability and/or the water environment.
Point b) should be expanded to recognise the sensitive areas in Norfolk such as the Broads and SSSIs. Suggested wording would be: The quality of surface waterbodies and groundwater, with particular regard to preventing the deterioration of their existing status, and the quantity of water for resource purposes within water bodies and in environmentally sensitive areas that may be affected by water quantity and quality;

Environmental Permit for Dewatering
Dewatering for quarrying or mineral extraction purposes now falls under water abstraction licencing legislation. Any developer of a quarry or mineral extraction should contact the Environment Agency to discuss obtaining such a licence. The Environment Agency would normally expect dewatering water to be returned to the local aquifer within a short time period
Policy MW4: Climate Change Mitigation and Adaption
Part F may be better suited in the flooding, water resources and water quality section on page 30. However, it is important that climate change is considered when assessing flood risk. Therefore this section could specify that: 'site specific FRAs should include an assessment of the impact of climate change on flood risk using appropriate climate change allowances'.
Policy MW5: The Brecks Protected Habitats and Species
We support this policy's statement to protect the important flora and fauna within The Brecks. The allocated sites are mostly located away from sites supporting aquatic ecological features in Norfolk such as The Broads and North Norfolk Coast, but if any come forward in future then a further policy to address these features would assist in avoiding inappropriate development at these locations.

Policy MP5: Core River Valleys
Whilst recognising that mineral deposits have to be worked where they occur, new developments should be restricted to higher ground avoiding river valleys where possible to reduce the risk of mineral extraction impinging on groundwater.
Various authorities are restoring sections of river valley throughout Norfolk in order to enhance the ecology and condition status of water bodies. Developments which impact the success of existing restoration schemes will hinder the water bodies' potential to reach good status. This is particularly relevant to proposed sites MIN 55, MIN 202 and MIN 58. The location of these sites is close to an ongoing project to restore the River Wensum SSSI/ SAC/ SPA. If the developments are accepted there would be scope to work in partnership with the EA to create some enhancements which could include the use of natural flood management measures such as woody debris, planted berms, floodplain reconnection and tree planting.

Policy MP2: Spatial strategy for mineral extraction
We agree that each designated site and sensitive receptors will have different interest features and sensitivities. Therefore, proposed developments will need to be assessed to determine their potential impacts on the features for which each site is designated. Appropriate mitigation should be applied to reduce potential impacts. These may include planting buffer zones of trees around sites to act as dust suppression, and limit noise and light pollution from the development.
Policies MP7: Progressive Working, Restoration and After-use and MP8: Aftercare
The aggregate industry has the potential to create opportunities for delivering the UK BAP targets for conserving habitats and species. Topsoil at sites post-extraction can be reinstated and used to create wildflower meadows rich in pollinating insects.
Where possible green corridors should be strategically placed to link wildlife sites, creating a larger area for biodiversity which is consistent with the Biodiversity 2020 strategy to advocate the creation bigger and less fragmented areas for wildlife.

Native crayfish Ark sites
Using mineral extraction sites can provide highly suitable, inexpensive Ark sites for the rapidly declining white clawed crayfish. Norfolk contains some of the few remaining white claw crayfish populations but these are under threat from disease and non-native crayfish. Extraction operations can create permanently filled water bodies, isolated from existing rivers containing invasive crayfish and the virulent crayfish plague. We would encourage the creation of Ark sites to be a component of aftercare, thereby the industry will be contributing to regional and national BAP targets, adding greater value to restoration strategy. There would be opportunities for working in partnership with the EA, Norfolk Rivers Trust and Buglife to establish Arks at sites post extraction.

Policy WP15: Whitlingham Water Recycling Centre
Water Recycling Centres have the potential to cause significant impact on the water environment, and inhibit the ability for water bodies to achieve 'good' status under the WFD. We therefore welcome Whitlingham Water Recycling Centre having a long term policy to ensure that further capacity is provided in line with further growth.
Allocated Sites
In this section we have provided bespoke guidance relating to ecology, groundwater protection and flood risk at certain sites. MIN 38, Land at Waveney Forest, Fritton is of considerable concern.

MIN 38, Land at Waveney Forest, Fritton
We have significant concerns regarding the allocation of this site from both a Groundwater Protection and an Ecology perspective.
Groundwater Protection at Waveney Forest
Protection of groundwater quality and potable drinking supplies are of paramount concern to us.
It is highly likely that the quarry operators at this site would need to excavate below the water table, which is very shallow at this location. As such, significant dewatering would most likely result in groundwater level drawdown outside the boundary of the quarry and would affect/derogate nearby abstractions. We are aware of some local, licenced and unlicensed, abstractions which would most likely be affected.
For additional reference there is a public water supply (Northumbrian Water/Essex & Suffolk) abstraction from Fritton Lake. This is technically classed as a surface water abstraction because it is taken from the lake, but the lake is virtually a groundwater fed body, and so it is in hydraulic continuity with the same geological strata that the quarry wishes to excavate, as are the surrounding marshes. Unfortunately, our system will not assign a source protection zone to the abstraction because it only recognises the abstraction as being from surface water. While it is probably unlikely that the Lake would be impacted to the extent that it affects the public water supply abstraction, there remains the concern of contamination from air borne and groundwater pollutant resulting from quarry activities. This would otherwise have been more rigorously assessed should a Source Protection Zone have been assigned to this abstraction.
As of January this year dewatering is now a licensable activity as a New Authorisation. If we were consulted over this application, we would take a hard line, requesting detailed risk assessments and environmental impact assessments, including implications for impact to features assessed under the Water Framework Directive. We would expect detailed calculations of impact to Fritton Marshes, flow to the Waveney, Fritton Warren South County Wildlife Site, Fritton Lake, effects to local abstractors (including an updated search for domestic sources) and the Public Water Supply.
Ecology at Waveney Forest
This site has been raised in previous plans and we remain concerned that the size of the removal of aggregate could cause negative impacts on visual amenity, character and wildlife.
Numerous protected species in the area linked to fringing wetland habitat such as water vole, otter, Norfolk hawker, grass snake. Others linked to heathland and mire habitat to be lost include adder, lizard, slow-worm, nightjar and turtle dove. The narrow-mouthed whorl snail has also been recorded in habitats fringing the Waveney.
Impacts on the quality of water from run-off and draining down of surrounding wetland habitats (marshes, Fritton Lake) are likely to be severe. There is potential to compromise projects and eel passage improvements on nearby Blocka Run.
Several County Wildlife Sites (mainly heathland) will be lost to development, and it is unclear how impacts will be offset and even whether it is possible.

Allocated Sites with Ecological Constraints
The following section outlines the constraints at certain sites, which will need to be considered at the application stage to ensure that ecology is not adversely affected.
MIN 48 The proximity of the site to Swannington Upgate Common. Potential impacts on features of interest and Swannington beck, a chalk stream with associated priority habitat and species.
MIN 96 Close proximity to Spixworth Beck, concerns over impacts on the associated habitat including coastal and floodplain grazing marsh.
MIN 45 Potential impacts to ancient woodland, and county wildlife sites, particularly the hydrology and ecology of Syderstone Common SSSI which supports a population of protected natterjack toad.
MIN 202 The proximity to ancient woodland and county wildlife sites could cause habitat fragmentation.
MIN 115 Potential loss of deciduous woodland priority habitat.
MIN 25 Potential impacts on Priority Habitats - deciduous woodland and coastal and floodplain grazing marsh.
MIN 71 Proximity to Holt Lows SSSI and potential impact on groundwater dependant habitat.

Allocated Sites with Groundwater Protection Constraints

In this section we have provided guidance on the pollution prevention measures that we would expect to be considered at these allocated sites.

MIN 200, Land west of Cuckoo Lane Carbrooke
It is unclear whether de-watering is proposed. There is mention of the proximity to Scoulten Mere Wetland SSSI. If no de-watering is to take place then there would be no impacts, however if de-watering is to take place, by inference, there may be impacts. We welcome the recommendation for a hydrogeological impact assessment to determine if de-watering is acceptable, and if not then the mineral may have to be worked wet. With this proviso we agree with the conclusions that the site is likely to be suitable for complete sands and gravel extraction. The need for hydrogeological impact assessment should be added to the list of the requirements that need addressing in the initial conclusion.
We are aware of the proposed restoration of this site. The site lies within an SPZ 2 so it is recognised that sufficient protection of groundwater is required at the site. Groundwater has been identified at the base of excavation, and de-watering is a potential issue.As such any waste management development must employ pollution prevention measures where possible. The aquifers on site must be adequately protected from potential contamination, and any waste management development will require robust risk assessment. When this site is progressed, we will be heavily involved to ensure environmental protection.

MIN 35, land at Heath Road Quidenham
The site is located approximately 2km from Swangey Fen (wetland SSSI) and also close to Banham Fens and Quidenham Meres SSSI. This is proposed to be worked dry so, we have no de-watering concerns. The site is considered suitable provided there is no working below the water table.

MIN 102, land at North Farm Snetterton
The site is adjacent to Swangey Fen SSSI and therefore we do not consider it suitable for mineral extraction. A stronger argument is required than that presented in the recommendations, which state that 'this is a significant constraint to the development of the site and therefore the site is considered less deliverable than other sites that have been proposed for extraction'. If it is taken forward as a site it would have to be worked wet because we would not grant a de-watering licence, and we would request with strict planning conditions.
As the excavated void is to be utilised for waste disposal or recovery, a robust risk assessment will be required. We would expect waste disposal here to meet all best practice techniques. Due to the sensitivity of groundwater (within an SPZ2) it will not be possible to accept reduced liner thickness or design at this site. The aquifers on site must be adequately protected from potential contamination, and if this site is progressed the Environment Agency will be heavily involved to ensure environmental protection.

MIN 201, land at Swangey Farm Snetterton
The site is adjacent to Swangey Fen SSSI and therefore we do not consider it suitable for mineral extraction. If it is taken forward as a site it would have to be worked wet because we would not grant a de-watering licence, and we would request with strict planning conditions.

MIN 6, land off East Winch Road Middleton
We agree that a hydrogeological impact/risk assessment is needed for working beneath the water table. It may be necessary to apply constraints such as a limiting or precluding de-watering at the site, which will be dependent on the results of the hydrogeological risk assessment. The assessment should include impacts on protected rights (water features and other lawful users) and the risk of pulling in contaminated groundwater due to the proximity of black borough end Landfill. The issue of contaminated groundwater being mobilised from Blackborough End landfill is not addressed in the current assessment report.

MIN 204, land off Lodge Road Feltwell
It is not clear whether de-watering is proposed. Planning requirements in the initial conclusion should include the need for 'an appropriate hydrogeological risk assessment'.

MIN 40, land east of Grandcourt Farm East Winch
We agree with the need for an appropriate hydrogeological risk assessment as set out in the initial conclusions. This should also consider the proposed restoration scheme as well as the de-watering phase. Restoration and de-watering phases should consider thepossibility of a perched aquifer in the Carstone Formation. We would not accept any passive de-watering of this aquifer.

SIL 01: This is potentially a high risk site with a County Wildlife site situated within it. However we agree with the recommendation to allocate

Further Guidance
Sites MIN 40, MIN 19, MIN 205, MIN 201, MIN 35, MIN 51, MIN 13, and MIN 32 propose low level restoration using inert material to restore the site. Whilst these sites do not lie within an SPZ we would expect groundwater to be sufficiently protected. This would involve a robust waste acceptance criteria. We would expect diligence is maintained to ensure non-inert wastes are not accepted at this site. If deposition will be sub-water table, as at sites MIN 200 and MIN 102, the applicant should refer to the EA technical guidance note 30_18 'Compliance with the Landfill Directive when depositing inert waste into water'.

At sites MIN 12, MIN 08 and MIN 45, the the excavated void is to be utilised for waste disposal or recovery, so a robust risk assessment will be required. We would expect waste disposal here to meet all best practice techniques. Due to the sensitivity of groundwater (within an SPZ3) it will not be possible to accept reduced liner thickness or design at this site. The aquifers on site must be adequately protected from potential contamination, and if this site is progressed we will be heavily involved to ensure environmental protection.

At sites MIN 6, MIN 204, MIN 23 and MIN 116 it is not stipulated if these sites are to be utilised for waste disposal or recovery. If either of the options are progressed a robust risk assessment will be required. We would expect waste disposal here to meet all best practice techniques. Whilst the site does not lie within an SPZ we would expect groundwater to be sufficiently protected.

Allocated Sites with Flood Risk Constraints

MIN 102, Land at North Farm, south of the River Thet, Snetterton
As stated on p133, the majority of site MIN 102 is situated within flood zone 1, however there is a small percentage of the site within flood zones 2 and 3 which align the River Thet. There is also a small percentage shown at risk of surface water as shown on the risk of flooding from surface water flood map.
Although the site is currently considered to be unsuitable for allocation, should this change a FRA would be needed to demonstrate the risk of flooding to those working onsite and to ensure that flood risk is not increased. The impact of climate change on flood risk will also need to be considered.

MIN 76, land at West Field, Watlington Road
The plan incorrectly states that MIN 76 is situated in Flood Zone 1. The North West corner of the site is situated in Flood Zones 2 and 3, as shown on our Flood Map for Planning. This should be updated to ensure flood risk is addressed and mitigation measures considered.

Policy MP13: Areas of Search for silica sand extraction
Policy MP13 does not address the need for an FRA, although the requirement to follow the sequential approach to flood risk has been listed. An FRA is vital if the planning authority is to make informed planning decisions. In the absence of an FRA, the flood risk resulting from the proposed development are unknown.

Planning Advice Service
We trust the advice we have given is useful and will contribute to the soundness of the emerging local plan. We will continue to provide further advice and comments at future statutory stages of the emerging local plan. Should you wish us to review any draft policies and text as well as technical documents and background studies, such as strategic flood risk assessments or water cycle studies which may be used to support your plan, we can offer this as part of our planning advice service.
This service will ensure that your evidence documents fully support the local plan and ensure that environmental issues are addressed in an effective and timely way contributing to sustainable development. As part of the planning advice service we will provide you with a single point of contact who will co-ordinate access to our technical specialists, who will be able to provide bespoke advice and help you prepare any supporting documents. We will be pleased to provide you with an estimated cost for any work we would undertake as part of the service.

As the Government's adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully taken into account at all stages and levels of the local planning process. Our comments below should be read with our detailed comments in the attached table.

Summary
At this early stage in the plan process, we have identified in detail in the attached table the changes that we recommend. However, looked at as a whole we have identified two key issues to address for the next iteration of the plan, which we summarise below:

a) Evidence-based allocations: the aim should be to avoid harm in the first instance before minimising or mitigating (Planning Practice Guidance, paragraph 019 reference ID 18a-019-20140306 revision date 06 03 2014). A proposed allocation needs to be based on evidence and should seek to avoid harm to heritage assets in the first instance, then set out how it could be mitigated against if the harm is unavoidable and the public benefits justify that harm under paragraphs 194, 195, or 196 of the National Planning Policy Framework. The following sites do not meet that threshold: MIN 79 and 80, SIL 02, MIN 40, MIN 32, MIN 19 and 205, MIN 48 and MIN 116. Of those, SIL 02 (a large preferred area immediately abutting a complex of highly graded heritage assets) along with AOS E, MIN 19 and MIN 205; MIN 48 (which incorporates a scheduled monument) and MIN 79 (with other development considerations) are most concerning. We would expect some level of heritage impact assessment to be done on the most sensitive sites in order for them to be allocated.

When areas are included in allocations, preferred areas or areas of search which cannot be developed adds confusion and complexity to the planning system. Once the principle of development is established through inclusion within a site allocation, preferred area or area of search, it is more difficult to rebut the presumption in favour of development owing to the assumption that, in an evidence and plan-led system, these aspects are factored into the allocation. As such all sensitive sites should be assessed and the results of that assessment inform whether or not there is an allocation, preferred area or area of search; what size and location it can be and what policy requirements, including mitigation measures, need to be embedded to conserve or enhance the historic environment.

b) Lack of specific local historic environment policy protection: policy MW2 is too generic to provide specific local criteria and/or requirements against which planning applications will be assessed. This could be addressed through an historic environment policy or through specific site allocation policies that specify requirements such as impact assessments, avoidance and mitigation measures, archaeological investigation, progressive working, and aftercare requirements. Many of these already have been identified in the Sustainability Appraisal Annex B. This particularly affects sites MIN 35, MIN 38, and MIN 203, though we have identified where many more proposed allocations should incorporate this information.

Conclusion
As you develop the minerals and waste plan, we would welcome discussing further the points raised in our representations.

In preparation of the forthcoming minerals and waste local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

Minerals and Waste Local Plan Regulation 18 Comments

Breckland Council would wish to make the following representations on the Regulation 18 Minerals and Waste Local Plan:

Question 8: Breckland supports the inclusion of Policy MW5 'The Brecks Protected Habitats and Species' within the Local Plan, however would like to bring attention to additional evidence in relation to Stone Curlew buffer zones. As part of the Habitats Regulation Assessment to support the Breckland Local Plan revisions have been required to the buffer zones and policy to reflect areas within 3km of the SPA. Further information is available within the Breckland Habitat regulations Assessment on pages 30-32. However the issue can be summarised as follows:

Evidence, explained within the HRA for the Breckland Local Plan, identifies 3km as a distance at which stone curlew outside the SPA could be associated with the SPA. Survey effort tends to be focussed on areas regularly used and good quality habitat, so the additional buffer 'orange cells' simply reflect a lack of data. The orange cells therefore represents a precautionary area, in light of our understanding of the distance outside the SPA the birds may be present, where checks are necessary and mitigation could be required if the checks identify regular use by nesting stone curlew.

The orange cell areas could therefore comprise of some functionally linked land for Stone Curlews, however the data is incomplete. The Breckland HRA has therefore proposed an additional buffer zone to include these cells where there are data gaps and additional data checks or survey data may be required to check for use by Stone Curlews. The Breckland Local Plan has interpreted the additional 'orange cell' buffer area as a location where any site allocation would need to be supported by a project level HRA.

It is recommended that the policy is revised to reflect these additional areas and the map 2 should also be updated. For your information, I have included the proposed modified Breckland policy and also map.

Question 10: The waste policy currently considers there is sufficient capacity to meet the need for waste facilities without further allocations. The growth rate has had regard to the Norfolk SHMAs. Is there sufficient capacity within the existing waste facilities using the standardised housing methodology for calculating new household growth? Further justification would be required for a criteria based approach to ensure the plan is positively prepared.

Question 12: The policy would support the development of waste facilities on general industrial areas. Breckland would not wish to see the economic potential of industrial areas reduced due to the provision of waste facilities. Breckland would wish the policy to have regard to the employment aspirations for the area. Of particular concern is the Snetterton General Employment Area which is a key priority for Breckland within the A11 Norwich to Cambridge Technology Corridor. Breckland is proposing allocations through its Local Plan which would deliver 3,174 jobs to the area. Policy EC02 of the emerging Local Plan seeks to zone the employment area in order to meet these aspirations. Further to this, the Thetford Enterprise Park is also a key area on the A11 corridor and forms an important element of the growth strategy for the area. Breckland would wish to see the policy amended to reflect that important employment sites (including general employment areas such as Snetterton and the Thetford Employment Park) should not be prejudiced through development of waste sites.

Question 46: Site MIN35 Land at Heath Road Quidenham. Whilst located within Quidenham parish, this site is directly adjacent to the Snetterton General Employment Area, which is a strategic site for economic development within Breckland on the A11 corridor. At present the assessment does not appear to make reference to the proximity of the site to the GEA, and Breckland would wish to see this acknowledged within the assessment.

The access to the site is through the General Employment Areas to the A11. Further information is requested in relation to the operating hours of the quarry. This is in relation to the potential for weekend extraction. The site is in close proximity to the Snetterton Race Track, and at weekends when the circuit predominantly operates visitor traffic will also be using the access routes to the A11. Regard should be had to this in any transport assessment.