Question 53: Proposed site MIN 64

I understand that no one is going to want a mineral extraction on their doorstep but the proposed site is less than 100m from our house and land which and there will be a significant impact from dust, and noise. With a prevailing wind we already experience noise pollution from the existing site. I can only assume that it is because there are relatively few properties that siting an extraction site so close to a residential area is being considered. With Norfolk being such a big county and so rural there must be other options that will not cause disruption on this scale.
My other main concern is what happens to the site when extraction is complete in 13 years if the proposal goes ahead - there needs to be an agreement that the site will not be used for landfill as I believe was the case with the current site 10 years ago.

We are writing on behalf of mineral operator Longwater Gravel Co. Ltd. in relation to site MIN 64 and in response to the consultation on the Norfolk Minerals and Waste Local Plan Review "Initial Consultation" in summer 2018.

The Council has come to the initial conclusion that the site is considered to be suitable for allocation and Longwater Gravel Co. Ltd. strongly supports the Council's conclusion that site MIN 64 is suitable for development. The site offers a number of benefits in terms of its locational aspects, including:
* Being extremely well-related to the transport network and able to use the existing quarry access onto the B1354;
* Being located close to the major growth area, the Norwich Growth Triangle, as well as the market towns of Aylsham and North Walsham where further housing and employment growth is allocated;
* Being remote from any international, national or local biodiversity designations;
* Not jeopardising any of the best and most versatile agricultural lands;
* Being relatively far from sensate residential receptors, limiting any amenity impacts;
* Being outside of any landscape designations; and
* Its location outside of any flood risk zones and able to be worked dry above the water table.

In line with the Council's recommendations resulting from the Site Assessment of MIN 64, the Company can confirm that it will, when submitting a planning application for minerals development on this site, provide:
* a detailed screening scheme which will include mitigation of views from nearby properties, and surrounding roads;
* noise and dust assessments and a programme of mitigation measures to deal appropriately with any amenity impacts;
* a Heritage Statement to identify heritage assets and their settings, which will assess the potential for impacts and identify appropriate mitigation measures (if needed);
* a proportionate archaeological assessment in consultation with Norfolk County Council, to determine whether any mitigation measures are needed;
* a hydrogeological assessment to inform the maximum depth of working above the water table; and
* a detailed restoration scheme, which will include any opportunities identified during working for geodiversity assets to be studied and an open face to be included for future scientific study and arable land with margins to allow for long-term screening and biodiversity gains.

Site MIN 64 appears to be fully compliant with national planning policy as well as the policies proposed in the Minerals and Waste Local Plan Review: Initial Consultation, as well as the recently revised National Planning Policy Framework (July 2018). On this basis and with consideration for the above, the Company encourages the Council to allocate the site for minerals development within the Minerals and Waste Local Plan.

I write to confirm that Longwater Gravel agree with and support Norfolk County Council's initial conclusion to allocate MIN 64.

Longwater Gravel Company is a small scale quarry operator which specialises in small deliveries of sand and gravel to a customer base which includes local builders, groundworkers and the general public. We also supply sand and gravel to a number of small volume readymixed concrete producers.

Our quarry at Horstead produces natural shingle, primarily used as a decorative aggregate for driveways, etc. along with a high quality building sand. MIN 64 would form an extension to the quarry and would provide sand and gravel reserves of around 650,000 tonnes. There are no plans to increase production, which is limited by Section 106 agreement to 50,000 tonnes/year. It is anticipated that existing permitted reserves at Horstead Quarry will be exhausted within the next 2-3 years and so following the successful granting of planning permission, extraction could commence in MIN 64 by the end of 2020. It should be noted MIN 64 did originally comprise the field to the west and having received planning permission, extraction has now been carried out in this area for over two years.

It is proposed to plant a small area of mixed native woodland trees in the north east corner of MIN 64, this would be planted in advance of mineral extraction commencing and once established would serve to soften views of the soil storage/screening bunds of the final eastern phase from the properties located at the north east boundary. Views of MIN 64 from the Buxton Road will be screened by the placement of soil storage bunds along the southern boundary with the existing hedgerow strengthened by additional planting of native species hedgerow trees.

MIN 64 would be worked in five separate phases working and restoring progressively from west to east. The washing plant, weighbridge and access would be retained in the existing quarry with sand and gravel transported from MIN 64 by dumptruck using an internal haulroad constructed in the northwest corner. Other than mobile plant such as excavator, loader and dumptruck, no other quarry equipment will be located within MIN 64. There are no plans to create an access directly from MIN 64 onto Buxton Road.

On completion of sand and gravel extraction, the land would be restored to agricultural use at a lower level with sloping margins around the perimeter of the extraction area which would be constructed using the surplus silt from the gravel washing operation. There are no plans to import any material e.g. household waste or inert waste to restore the site. The overall timescale to complete extraction and restoration of MIN 64 would be around 13 years.

We have asked Small Fish Consultants to assess MIN 64 and our proposals against the emerging Minerals and Waste Local Plan and they will comment separately.

The Parish Council have received concerns from parishioners about the proximity to of the site to what is currently a very rural area. The proposed site will change the nature of the area beyond recognition - not only will this impact the mental well-being of residents, it will also have a negative impact on property prices and the ability to sell said properties. There are also traffic issues along the B1354, not just from lorry movement but from those accessing the site to purchase material. There is also concern about land use after the extraction is complete.

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.

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.