Question 51: Proposed site MIN 48

Showing comments and forms 1 to 13 of 13

Object

Initial Consultation document

Representation ID: 91698

Received: 02/07/2018

Respondent: Mr Colin Plunkett

Representation:

Please note these are just some of our concerns:
1) Water. Our bungalow has a private bore, we are concerned that the quantity and quality of our water supply could be affected.
2) As the predominant wind is westerly, any noise or smells or other pollutants from the proposed site would be direct to us affecting our health and quality of life.
3) Wildlife. Swannington bottom plantation is home to a large and varied number of wildlife species, which include birds such as buzzards, nightingales, treecreepers and nuthatches. Also summer roosting colonies of types of bat, There are badger sets to be found there too.
4) Highways. As is readily accepted by Highways Department, the village of Felthorpe has more than it share of HGV traffic, any increase would be detrimental.

Full text:

Proposed mineral extraction at SWANNINGTON BOTTOM.
Please note these are just some of our concerns:
1) Water. Our bungalow has a private bore, we are concerned that the quantity and quality of our water supply could be affected.
2) As the predominant wind is westerly, any noise or smells or other pollutants from the proposed site would be direct to us affecting our health and quality of life.
3) Wildlife. Swannington bottom plantation is home to a large and varied number of wildlife species, which include birds such as buzzards, nightingales, treecreepers and nuthatches. Also summer roosting colonies of types of bat, There are badger sets to be found there too.
4) Highways. As is readily accepted by Highways Department, the village of Felthorpe has more than it share of HGV traffic, any increase would be detrimental.

Object

Initial Consultation document

Representation ID: 91761

Received: 19/07/2018

Respondent: Swannington with Alderford and Little Witchingham

Representation:

The Parish Council objects to this proposed site. As the owner and custodian of Upgate Common SSSI which abuts this site we are concerned about the impact any extraction would cause

Full text:

The Parish Council objects to this proposed site. As the owner and custodian of Upgate Common SSSI which abuts this site we are concerned about the impact any extraction would cause

Object

Initial Consultation document

Representation ID: 91920

Received: 03/08/2018

Respondent: Felthorpe Parish Council

Representation:

Felthorpe Parish Council (FPC) has undertaken a thorough review of the proposed extraction of sand and gravel from the land at Swannington Bottom Plantation, Felthorpe. Our comments and observations are as follows.
Amenity
There is a Public Right of Way along the southern boundary of the site (Felthorpe RB7). With its close proximity to the site, it will cease to be a pleasant countryside amenity asset contrary to the ambitions of the Broadland District Council Spatial Planning team.
Highway Access
Mineral extraction over a 5 year period would add the equivalent of 80 HGV trucks per day to the road network.
Highways England and Norfolk County Council are aware of FPC's efforts to reduce traffic particularly that of HGVs using the village as a cut through, something that the new Broadland Northway has failed to remedy.
FPC is pursuing an HGV restriction along the C260 The Street from the C245 Reepham Road with Highways England undertaking initial research.
Implementation of an HGV 7.5 Ton weight restriction for Felthorpe and Swannington would encompass a far greater area than just the single C260 road and would render this proposed site almost unworkable.
A highway routing agreement to prevent HGV quarry traffic from travelling through Felthorpe or Swannington Upgate would be difficult to successfully implement and almost impossible to regulate.
Pollution
The site is less than 200 metres from the nearest housing and less than 300 metres from the main community. The risks from potential pollution are untenable.
Air
The predominant winds in the area are south westerly. Smells, dust or other pollutants from the proposed site would be directed towards the village potentially affecting health and quality of life.
Thick dust blowing up into the atmosphere could seriously impact the flying of small planes landing and taking off from Felthorpe Airfield.
Water
A number of properties on Mill Lane are served by private bores, there is a concern that the quantity and quality of the water supply could be adversely affected.
The water course that originates from the Felthorpe Hall Lake travels along the boundary of the proposed site, through water lands and marsh through Swannington Upgate Common. This is an SSSI site. Plants and animals that would be put at risk, and could be lost should there be breach during excavations.
Noise
Operation of the site will not be noise free. Under certain conditions, noise from the Mid Norfolk Shooting Ground in Deighton Hills which is over twice the distance from Felthorpe regularly disturbs the village. The noise from heavy plant and equipment operating continuously would be more intrusive.
Light
Felthorpe is classed as Rural Dark Landscape with no street lighting. Operation of the site during the winter months will regardless of any screening, will impact those living in the area and wildlife.
Wildlife / Biodiversity
Swannington bottom plantation is home to a large and varied number of wildlife species, which include birds such as buzzards, nightingales, tree creepers and nuthatches. Also summer roosting colonies of types of bat, There are badger sets to be found there too.
There are a number of SSSI areas in the surround region, which although considered in the proposal cannot fail to be impacted in some way or form by the extraction site.
Waste Disposal
The Minerals and Waste Local Plan Review does not address the refilling of the site during or upon completion of mineral extraction. It is assumed that the site would be used for waste disposal of some form.
Use as a waste disposal site would increase and extend the various sources of pollution imposed on the village of Felthorpe and traffic would increase as a result. The use as waste site would increase the risk of a bird strike for both Norwich Airport and Felthorpe Airfield depending on the type of waste.
Restoration
The current proposal indicated that the site will be restored to a heathland habitat. It is understood that the site is private land and that felling of the conifers could take place at any time. However, the loss of one particular type of habitat and replacement with a different type will not necessarily encourage existing wildlife to remain.
Conclusion
Felthorpe Parish Council understands that there is no particular shortage of readily accessible sand deposits in Norfolk for the medium term future. The infrastructure costs associated with extracting a mineral, that is allegedly not in short supply, should prohibit development of this site during the lifetime of this 2036 plan.
Felthorpe Parish Council agrees with the Initial Conclusion that the site unsuitable for allocation as there is still not a mineral operator promoting the proposed site and therefore the site is less deliverable than other sites that have been proposed for extraction. However, in view of our assessment, MIN 48 - Land at Swannington Bottom Plantation, Felthorpe should be excluded in its entirety from the Local Plan.

Full text:

Felthorpe Parish Council (FPC) has undertaken a thorough review of the proposed extraction of sand and gravel from the land at Swannington Bottom Plantation, Felthorpe. Our comments and observations are as follows.
Amenity
There is a Public Right of Way along the southern boundary of the site (Felthorpe RB7). With its close proximity to the site, it will cease to be a pleasant countryside amenity asset contrary to the ambitions of the Broadland District Council Spatial Planning team.
Highway Access
Mineral extraction over a 5 year period would add the equivalent of 80 HGV trucks per day to the road network.
Highways England and Norfolk County Council are aware of FPC's efforts to reduce traffic particularly that of HGVs using the village as a cut through, something that the new Broadland Northway has failed to remedy.
FPC is pursuing an HGV restriction along the C260 The Street from the C245 Reepham Road with Highways England undertaking initial research.
Implementation of an HGV 7.5 Ton weight restriction for Felthorpe and Swannington would encompass a far greater area than just the single C260 road and would render this proposed site almost unworkable.
A highway routing agreement to prevent HGV quarry traffic from travelling through Felthorpe or Swannington Upgate would be difficult to successfully implement and almost impossible to regulate.
Pollution
The site is less than 200 metres from the nearest housing and less than 300 metres from the main community. The risks from potential pollution are untenable.
Air
The predominant winds in the area are south westerly. Smells, dust or other pollutants from the proposed site would be directed towards the village potentially affecting health and quality of life.
Thick dust blowing up into the atmosphere could seriously impact the flying of small planes landing and taking off from Felthorpe Airfield.
Water
A number of properties on Mill Lane are served by private bores, there is a concern that the quantity and quality of the water supply could be adversely affected.
The water course that originates from the Felthorpe Hall Lake travels along the boundary of the proposed site, through water lands and marsh through Swannington Upgate Common. This is an SSSI site. Plants and animals that would be put at risk, and could be lost should there be breach during excavations.
Noise
Operation of the site will not be noise free. Under certain conditions, noise from the Mid Norfolk Shooting Ground in Deighton Hills which is over twice the distance from Felthorpe regularly disturbs the village. The noise from heavy plant and equipment operating continuously would be more intrusive.
Light
Felthorpe is classed as Rural Dark Landscape with no street lighting. Operation of the site during the winter months will regardless of any screening, will impact those living in the area and wildlife.
Wildlife / Biodiversity
Swannington bottom plantation is home to a large and varied number of wildlife species, which include birds such as buzzards, nightingales, tree creepers and nuthatches. Also summer roosting colonies of types of bat, There are badger sets to be found there too.
There are a number of SSSI areas in the surround region, which although considered in the proposal cannot fail to be impacted in some way or form by the extraction site.
Waste Disposal
The Minerals and Waste Local Plan Review does not address the refilling of the site during or upon completion of mineral extraction. It is assumed that the site would be used for waste disposal of some form.
Use as a waste disposal site would increase and extend the various sources of pollution imposed on the village of Felthorpe and traffic would increase as a result. The use as waste site would increase the risk of a bird strike for both Norwich Airport and Felthorpe Airfield depending on the type of waste.
Restoration
The current proposal indicated that the site will be restored to a heathland habitat. It is understood that the site is private land and that felling of the conifers could take place at any time. However, the loss of one particular type of habitat and replacement with a different type will not necessarily encourage existing wildlife to remain.
Conclusion
Felthorpe Parish Council understands that there is no particular shortage of readily accessible sand deposits in Norfolk for the medium term future. The infrastructure costs associated with extracting a mineral, that is allegedly not in short supply, should prohibit development of this site during the lifetime of this 2036 plan.
Felthorpe Parish Council agrees with the Initial Conclusion that the site unsuitable for allocation as there is still not a mineral operator promoting the proposed site and therefore the site is less deliverable than other sites that have been proposed for extraction. However, in view of our assessment, MIN 48 - Land at Swannington Bottom Plantation, Felthorpe should be excluded in its entirety from the Local Plan.

Object

Initial Consultation document

Representation ID: 92019

Received: 09/08/2018

Respondent: CPRE Norfolk

Representation:

We feel that the impact on nearby Swannington Upgate Common should be included in the conclusion which would be an additional reason for deeming this site to be unsuitable. Once/if the plantation is felled it would be welcome to see the land restored to heathland.

Full text:

We feel that the impact on nearby Swannington Upgate Common should be included in the conclusion which would be an additional reason for deeming this site to be unsuitable. Once/if the plantation is felled it would be welcome to see the land restored to heathland.

Object

Initial Consultation document

Representation ID: 92094

Received: 10/08/2018

Respondent: Natural England

Representation:

The site is also unsuitable due to potential hydrological and dust deposition impacts on the adjacent Swannington Upgate Common SSSI.

Full text:

The site is also unsuitable due to potential hydrological and dust deposition impacts on the adjacent Swannington Upgate Common SSSI.

Object

Initial Consultation document

Representation ID: 92127

Received: 12/08/2018

Respondent: Felthorpe Airfield

Representation:

Background:
Since 1964 Felthorpe Airfield has been home to an active aviation community formerly known as the "Felthorpe Flying Group". Approximately 30 single prop aircraft are regularly flown from the airfield, varying from vintage aircraft including a 1940 de Havilland Tiger Moth, a 1936 de Havilland Hornet Moth, and a replica First World War Fokker Dreidecker triplane to modern fixed wing aircraft and gyrocopters.
Response:
The proposed mineral extraction site Swannington Bottom Plantation, Felthorpe MIN48, lies to the North of Felthorpe Airfield. Norwich Air Traffic Control stipulates for safety reasons that all traffic flying to and from Felthorpe Airfield has to take off and land using the Swannington Lane which is directly overhead of the proposed gravel extraction site. Aircraft are required to transit the Swannington lane at 600 feet above ground level (AGL). At this height dust created by the proposed gravel extraction works could cause aircraft engine failure due to ingestion of dust and particles which could result in an air accident and loss of life. Potential increased bird activity from the gravel extraction and later landfill could cause bird strikes which are an incredibly serious danger to the safety of all aircraft but particularly light aircraft due to potential penetration of an aircraft windscreen and engine failure all resulting in the aircraft being brought down.
Conclusion
The proposed mineral extraction at MIN 48 - land at Swannington Bottom Plantation, Felthorpe would create an unacceptable risk to the safe operation of light aircraft from Felthorpe Airfield and therefore should be excluded from the local Plan.

Full text:

Objection to Minerals and Waste Local Plan Review-Initial Consultation MIN 48-Land at Swannington Bottom Plantation, Felthorpe
Background:
Since 1964 Felthorpe Airfield has been home to an active aviation community formerly known as the "Felthorpe Flying Group". Approximately 30 single prop aircraft are regularly flown from the airfield, varying from vintage aircraft including a 1940 de Havilland Tiger Moth, a 1936 de Havilland Hornet Moth, and a replica First World War Fokker Dreidecker triplane to modern fixed wing aircraft and gyrocopters.
Response:
The proposed mineral extraction site Swannington Bottom Plantation, Felthorpe MIN48, lies to the North of Felthorpe Airfield. Norwich Air Traffic Control stipulates for safety reasons that all traffic flying to and from Felthorpe Airfield has to take off and land using the Swannington Lane which is directly overhead of the proposed gravel extraction site. Aircraft are required to transit the Swannington lane at 600 feet above ground level (AGL). At this height dust created by the proposed gravel extraction works could cause aircraft engine failure due to ingestion of dust and particles which could result in an air accident and loss of life. Potential increased bird activity from the gravel extraction and later landfill could cause bird strikes which are an incredibly serious danger to the safety of all aircraft but particularly light aircraft due to potential penetration of an aircraft windscreen and engine failure all resulting in the aircraft being brought down.
Conclusion
The proposed mineral extraction at MIN 48 - land at Swannington Bottom Plantation, Felthorpe would create an unacceptable risk to the safe operation of light aircraft from Felthorpe Airfield and therefore should be excluded from the local Plan.

Object

Initial Consultation document

Representation ID: 92128

Received: 12/08/2018

Respondent: Wood Farm Liveries

Representation:

Felthorpe is a quiet country village with a number of horse owners living locally many of whom ride through the village and surrounding areas.
There are fifteen owners who keep their horses in livery at Wood Farm. The riders regularly hack out along the public footpaths and bridle ways surrounding Wood Farm. One frequently used footpath, known locally as Sandy Lane, runs along side the proposed site MIN 48. The noise, dust and other activity at the site together with the increased HGV traffic along the C245 Felthorpe Road will cause disruption to both the horses and riders. Horses are easily frightened by sudden loud noises which can result in them bolting and unseating their riders. This can obviously cause a major risk of severe injury to the rider and the horse.

Full text:

Felthorpe is a quiet country village with a number of horse owners living locally many of whom ride through the village and surrounding areas.
There are fifteen owners who keep their horses in livery at Wood Farm. The riders regularly hack out along the public footpaths and bridle ways surrounding Wood Farm. One frequently used footpath, known locally as Sandy Lane, runs along side the proposed site MIN 48. The noise, dust and other activity at the site together with the increased HGV traffic along the C245 Felthorpe Road will cause disruption to both the horses and riders. Horses are easily frightened by sudden loud noises which can result in them bolting and unseating their riders. This can obviously cause a major risk of severe injury to the rider and the horse.

Object

Initial Consultation document

Representation ID: 92129

Received: 12/08/2018

Respondent: Mr Laurence Elsdon

Representation:

The proposal to extract minerals from land at Swannington Bottom Plantation, Felthorpe (MIN 48) is of significant concern to the residents of Felthorpe and surrounding neighbourhoods. The consultation documents provided so far do not include sufficient detail on the method of extraction, duration of extraction, number of heavy goods vehicle or plant vehicle movements, or details of land use after mineral extraction to be able to ascertain the effects on the community.

One of Felthorpe's greatest assets is its large network of footpaths, tracks, and bridleways connecting Upgate Common, Gilham's Heath Plantation, The Lings, Steward's Plantation and of course, central to these is Swannington Bottom Plantation. There has so far been no indication of how these paths used by residents of Felthorpe and visitors from further afield will be protected from the proposed works.

The most significant concern will be the loss of a significant and well established unnamed path to the North of Sandy Lane that runs directly through the middle of the Swannington Bottom Plantation, often used by local walkers, runners, cyclists, dogs and their owners connecting Felthorpe Road to Upgate Common. While not indicated on the Ordnance Survey map provided within the consultation the beginnings of this track are labelled on Google Maps as "Combat St" and OpenStreetMap as Way 333171535 (https://www.openstreetmap.org/way/333171535) and Way 333171537 (https://www.openstreetmap.org/way/333171537).

Therefore, while it is reassuring to see that the initial conclusion of the consultation document is that the site is unsuitable I note as above, and in addition to other responses from the community and local organisations, that there are many significant reasons the proposed site is unsuitable for allocation.

Full text:

The proposal to extract minerals from land at Swannington Bottom Plantation, Felthorpe (MIN 48) is of significant concern to the residents of Felthorpe and surrounding neighbourhoods. The consultation documents provided so far do not include sufficient detail on the method of extraction, duration of extraction, number of heavy goods vehicle or plant vehicle movements, or details of land use after mineral extraction to be able to ascertain the effects on the community.

One of Felthorpe's greatest assets is its large network of footpaths, tracks, and bridleways connecting Upgate Common, Gilham's Heath Plantation, The Lings, Steward's Plantation and of course, central to these is Swannington Bottom Plantation. There has so far been no indication of how these paths used by residents of Felthorpe and visitors from further afield will be protected from the proposed works.

The most significant concern will be the loss of a significant and well established unnamed path to the North of Sandy Lane that runs directly through the middle of the Swannington Bottom Plantation, often used by local walkers, runners, cyclists, dogs and their owners connecting Felthorpe Road to Upgate Common. While not indicated on the Ordnance Survey map provided within the consultation the beginnings of this track are labelled on Google Maps as "Combat St" and OpenStreetMap as Way 333171535 (https://www.openstreetmap.org/way/333171535) and Way 333171537 (https://www.openstreetmap.org/way/333171537).

Therefore, while it is reassuring to see that the initial conclusion of the consultation document is that the site is unsuitable I note as above, and in addition to other responses from the community and local organisations, that there are many significant reasons the proposed site is unsuitable for allocation.

Comment

Initial Consultation document

Representation ID: 92409

Received: 29/08/2018

Respondent: Norfolk Wildlife Trust

Representation:

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, MIN 201, MIN 48, MIN 45, MIN 19, MIN 205, MIN 74 and MIN 77.

Full text:

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.

Comment

Initial Consultation document

Representation ID: 92557

Received: 08/08/2018

Respondent: Environment Agency

Representation:

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.

Full text:

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.

Object

Initial Consultation document

Representation ID: 92962

Received: 31/08/2018

Respondent: Historic England

Representation:

MIN 48 includes a scheduled round barrow which was not marked on the map, but is identified on page 146. We find the proposed allocation MIN 48 unsound owing to the failure to avoid impacts to a highly designated heritage asset. If an allocation is to be brought forward in this location it requires a heritage impact assessment to identify the appropriate location for an allocation and outline the mitigation measures required which would be incorporated into policy.

Full text:

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.

Comment

Initial Consultation document

Representation ID: 93130

Received: 30/07/2018

Respondent: Norfolk County Council - Highway Authority

Representation:

The Highway Authority considers the site is not acceptable due to concerns with the road network which is sub-standard and narrow.

Comment

Initial Consultation document

Representation ID: 93205

Received: 16/08/2018

Respondent: Norfolk County Council Historic Environment Service

Representation:

We agree with the initial conclusion, but with the following comments:
It is worth including in the reasons why the site is unsuitable that MIN 48 could not be allocated if the scheduled barrow was within its extent - it would not get Scheduled Monument Consent and would be contrary to the requirements of the NPPF.