Question 52: Proposed site MIN 37

Showing comments and forms 1 to 7 of 7

Comment

Initial Consultation document

Representation ID: 91942

Received: 30/07/2018

Respondent: Lead Local Flood Authority (Norfolk County Council)

Representation:

MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems

Full text:

Norfolk Minerals and Waste Local Plan Review: Initial Consultation
Thank you for your consultation on the above site, received on 28 June 2018.
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.
Policy MW4: We welcome that that this policy supports policy MW2 with the provision of flood risk assessments (FRA) and although not specifically stated we assume that this policy's intention is that any FRA will include appropriate consideration of the most up to date climate change allowances.

It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts should be considered during a planning application and appropriate measures. These measures may not be required until reinstatement when post development ground levels are considered in detail.
With regard to specific sites put forward we have the following comments:
MIN12 - Beetley - We would like to highlight that we are aware of reports of external flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.
MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems
SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

Object

Initial Consultation document

Representation ID: 92291

Received: 13/08/2018

Respondent: Mr & Mrs Woodcock

Representation:

I am writing to object to the digging of land on the Coltishall Road, Buxton, MIN 37, having had to endure 20 plus years of digging and waste filling of adjacent land to this site (Mayton Wood), I strongly object to this extra gravel extraction when this area is grossly over prescribed with quarries, I question the need for another quarry at this site which judging by the outline of the proposed land is only a few metres from my property, with the Mayton Wood quarry, Horstead have two sites Longwater and Tarmac with another in Spixworth, the unending wreckage of the local landscape is in every corner of this area, to be subjected to another quarry on the opposite side of the road from my property is unjustifiable, Being so close as this there would be no way of avoiding noise and dust from engulfing my property, I would also highlight inaccuracies in the information provided for MIN 37, it is most probable that the 96 metres minimum distance from the nearest property would be revised upon permission being granted and it will be excavated to the outline of the site as is so often the case. If the people and families opinions who live close to this proposed site have any value at all this site will not be given permission.

Full text:

I am writing to object to the digging of land on the Coltishall Road, Buxton, MIN 37, having had to endure 20 plus years of digging and waste filling of adjacent land to this site (Mayton Wood), I strongly object to this extra gravel extraction when this area is grossly over prescribed with quarries, I question the need for another quarry at this site which judging by the outline of the proposed land is only a few metres from my property, with the Mayton Wood quarry, Horstead have two sites Longwater and Tarmac with another in Spixworth, the unending wreckage of the local landscape is in every corner of this area, to be subjected to another quarry on the opposite side of the road from my property is unjustifiable, Being so close as this there would be no way of avoiding noise and dust from engulfing my property, I would also highlight inaccuracies in the information provided for MIN 37, it is most probable that the 96 metres minimum distance from the nearest property would be revised upon permission being granted and it will be excavated to the outline of the site as is so often the case. If the people and families opinions who live close to this proposed site have any value at all this site will not be given permission.

Comment

Initial Consultation document

Representation ID: 92381

Received: 29/08/2018

Respondent: Norfolk Wildlife Trust

Representation:

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 .
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 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.

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: 92969

Received: 31/08/2018

Respondent: Historic England

Representation:

MIN 64 is close to the grade II* St Theobalds church, scheduled Great Hautbois old church, and northwest of a scheduled Roman camp which is on the heritage at risk register. MIN 37 and MIN 64 also need to be seen cumulatively with MIN 65. The recommendations in the Sustainability Appraisal Appendix B should be incorporated in 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: 93087

Received: 21/08/2018

Respondent: Norfolk County Council - Natural Environment Team

Representation:

Screening should be carefully considered, with native species chosen where possible. The extensive use of conifers should be avoided where possible. Advance planting is required to mitigate views.

Full text:

Thank you for consulting me on the Norfolk Minerals and Waste Local Plan. The plan is very thorough and I broadly feel that Landscape has been considered in an accurate and suitable manner.

MIN51 / MIN13 The landscape features within this site, including hedgerow oaks and blocks of woodland are significant in the landscape and should be protected during working of the site. These should also be used as focal points for restoration. The restoration should reflect and strengthen the retained features.

MIN23 I support the conclusion that this site would be unsuitable due to landscape impacts. Screening or bunding used to mitigate these impacts would be intrusive and due to the sloping topography, would be unlikely to be effective.

MIN200 Screening will be particularly important with this site so as to minimise views and retain the setting of nearby listed buildings.

MIN116 I am in support of the initial conclusion for this site. Impacts on nearby dwellings/ Public Rights of Way and the local landscape would be unacceptable. Although bunding and advanced planting is proposed, I feel this would not be sufficient and the bunding itself is likely to be unnecessarily intrusive.

MIN55 The deep extraction proposed on this site would make it hard to restore to a suitable landform that could be sinuous with the surrounding landscape. I agree with the conclusion that this would make the site unsuitable for allocation.

MIN202 The deep extraction proposed on this site would make it hard to restore to a suitable landform that could be sinuous with the surrounding landscape. I agree with the conclusion that the site would be suitable for allocation with a shallower depth of extraction.

MIN 37 Screening should be carefully considered, with native species chosen where possible. The extensive use of conifers should be avoided where possible. Advance planting is required to mitigate views.

MIN64 It is important to retain field boundary hedgerows and trees, the removal of these will have a major impact on the landscape. In addition any planting proposed should strengthen the existing with hedgerow and tree belts and form part of the restoration after the site has been worked.

MIN203 The landscape impacts of this extension site would be negligible.

MIN38 Although screening trees would be retained, there are large areas of woodland within the site which, although not characteristic of the area, form an identifiable part of the landscape. Although loss of woodland in this area would not cause a large impact on the wider landscape the immediate effects from within the woodland would be noticeable.

MIN45 In support of my Arboriculture colleagues comments, I am in agreement that this site is unsuitable for allocation.

MIN204 I support the requirement for a detailed landscaping scheme to mitigate impacts on Feltwell Gate Lodge and surrounding landscape.

MIN19 and MIN205 Whilst the removal of the plant is now not a consideration in the issue of landscape gain, with the right restoration these sites could provide other landscape gain.

MIN77 In support of my Arboriculture colleagues comments, I am in agreement that this site is unsuitable for allocation due to the importance of Runs Wood.

AOS E This area contains a large amount of woodland, which is intrinsic within the overall landscape, providing important visual and biodiversity connections. Where possible woodland should be retained, but where loss is unavoidable suitable mitigation should be provided during the working of any site within the area of search, and the planting of woodland should be considered as part of any restoration.

AOS I There are a number of viewpoints which will need to be considered within this area of search, it may be that only part of the area of search is suitable for mineral extraction.

SIL02 Bunding for this site has the potential to be intrusive. There are a number of views/settings and impacts on the wider landscape that will need to be carefully considered. A combination of advanced planting and bunding may be suitable, but care needs to be taken that the mitigation in itself doesn't have further impacts.

MIN69 This site lays within the Norfolk Coast AONB therefore screening will be of utmost importance. Restoration would need to demonstrate that after the site has been worked it could become exceptionally beneficial to both the landscape and the public.

MIN71 This site has the potential to have detrimental impact on residential amenity, a suitably designed strategy will need to demonstrate that this amenity can be protected and views minimised. I would agree with conclusions that a buffer for Holt itself will be required.

MIN115 I am in agreement with my Arboriculture colleague that this site is not suitable for allocation. Should the allocation remain in place it would be necessary to ensure a suitable tree belt screen is maintained to minimise views from adjacent Public Rights of Way.

MIN209/MIN210/MIN211 I would support the movement of the processing plant to an area to be worked over the choice to relocate it to an already restored area.

MIN92 The retention of the hedgerow oaks is important with their place in the landscape being intrinsic in the attractiveness of the area. I agree that this combined with the location adjacent to the Broads Authority Executive Area make the site unsuitable for allocation.

MIN79 Sprow's pit copse should be retained throughout the works and become a focus on in the restoration scheme. The restoration scheme should incorporate and extend the copse and strengthen the boundary planting.

Public Rights of Way - Where PRoW are adjacent or within the site, consideration should be given to insure that impacts are minimal. Where works will have a direct impact on the PRoW, discussions will need to take place with NCC to agree a suitable temporary diversion and subsequent reinstatement.

Comment

Initial Consultation document

Representation ID: 93131

Received: 30/07/2018

Respondent: Norfolk County Council - Highway Authority

Representation:

The Highway Authority considers the site is acceptable subject to a new access onto Coltishall Road.

Comment

Initial Consultation document

Representation ID: 93183

Received: 16/08/2018

Respondent: Norfolk County Council Historic Environment Service

Representation:

We agree with the initial conclusion for this site.