Question 57: Proposed site MIN 38 (Waveney Forest, Fritton)

I object to Brett's application on MIN 38.
Comments: This is a rural area for families.

I object to Brett's application on MIN 38.
Comments: Very sad spoils our countryside.

I object to Brett's application on MIN 38.
Comments: Ruins countryside, beautiful place to walk.

I object to Brett's application on MIN 38.

As you will be aware NCC is currently consulting on possible sites which could be included in the next minerals strategy.

One of the options proposed by landowners, is the Waveney Forest near to Fritton. I am emailing to reiterate that Mr Lewis remains opposed to a quarry in this location and is hopeful that after review NCC officers will not recommend that this site is included in the final strategy.

The enclosed statement for this application came from the Ipswich office of the Environment Agency some five years ago. I have contacted them and they have said we that could resubmit it as it is still pertinent.

OBJECT Environment Agency (Miss C Williams)
Summary:
With regard to MIN38A, we have previously objected to this proposed site on ecological grounds in our response dated 25 April 2008. No real detail was provided in this response as to the reasons for our objection. For your information, part of this proposed site comprises a large (6.7ha) wet woodland with a sphagnum moss bog. Sphagnum bogs in wet woods are rare in the east of the county due to the dry climate. Wet woodlands are also a UK BAP Priority Habitat and wet woodlands within the Wensum Catchment have been targeted by The Norfolk Wet Woodland Project (a partnership of various organisations including County Councils, the Forestry Commission, the Wildlife Trusts and Natural England). A site of this size is therefore notable and could support rare invertebrate species such as the bog bush-cricket and various beetles. Bogs are very sensitive to changes in groundwater levels. Excavating a large area of gravel could therefore have a significant adverse impact on this habitat. This site is not formally designated, however it could be of local significance. Norfolk Wildlife Trust or Natural England might be able to provide more assistance.

Objection to MIN38 proposal further to my other posts

I have already posted details of my turbulence objection which I consider to be unanswerable by the developer. The dust particulates will be set onto nearby residences many having been ionised by the hightension wires crossing the area. Our medical advice is that the 2.5 particulates will stick in the lungs and cause a variety of troubles to both humans and animals ,horses being especially vunerable. I have been given a file containing the names and details of some 13 residents of New Rd suffering from bronchial difficulties, several have gone into details of their health which I do not feel I wish to disclose publically however I can present this file to an appropriate authority in confidence if required. Your department has suggested I retain it at the moment.

The County Council historic officer has stated that the military archives in the woods are many and varied and are so hidden and widely scattered as to leave little space for development if they are to be sustained. The owners have already destroyed some of the hides that we told them about, as they went about their everyday forestry activities. My own uncle was in the auxiliaries building these Fritton hides in the second world war, and there is so much more to be preserved as this type of archive is very hard to find nationally, these days and should be protected. Indeed I know English Heritage is looking into this.

Our new main worry is for Hillside Animal sanctuary which this year has moved in immediately south west of the site using some 200 acres and expect to house approx. 1000 horses some 300 will be very close indeed. These include old misused and vulnerable horses some with special needs. They are not likely to find sanctuary adjacent a mineral quarry. Any run off from the quarry could run down into the dykes which they drink.

These same dykes have been dredged to facilitate the passage of eels from the river Waveney to Fritton Lake. Eels are of course protected and again would be vulnerable to any run off from the quarry just above.

All our other worries about this proposal still apply and I particulary worry about the 50 lorries they suggest could join the A143 .I do not accept the Highways contention that the road could absorb this traffic .No one has recently seemed to assess this road .The tail backs which occur daily now extend from Haddiscoe to Fritton Lake and the traffic from Lowestoft often cannot join and has to wait. The tight corner in Fritton produces many accidents and heavy lorries in different directions struggle to pass one another. The suggested access road would ruin the overhead tree canopy between our two villages.

Noise the complete traquility in the forest would be destroyed.

Fire the forest has always been a fire hazard and due to the surface materials it usually takes days to extinguish. Machinery of any sort only needs to produce a single spark on the tinder dry land.

There are many clubs that use the woods for a variety of reasons due to the biodiversity.
As the principle woodland amenity for Lowestoft and Gt Yarmouth these trees can t be spared.

The forestry commission seeks to ask for more trees to sequestrate carbon not less.

There are numerous other reasons why this proposal should simply not be contemplated but we have wasted enough valuable time fighting these people please do not spend public money by giving the proposal further consideration

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.

I object to Brett's application on MIN 38.
Comments: We need and must keep our countryside and woodland.

I object to Brett's application on MIN 38.

I object to Brett's application on MIN 38.
Comments: This would have a devastating effect on an area of natural beauty and tranquillity.

I object to Brett's application on MIN 38.
Comments: Very sad losing lovely countryside.

I object to Brett's application on MIN 38.
Comments: Such a lovely countryside ruined.

I object to Brett's application on MIN 38.
Comments: I strongly object to this quarry.

I object to Brett's application on MIN 38.
Comments: We need this forest for our community.

I object to Brett's application on MIN 38.
Comments: I strongly object.

I object to Brett's application on MIN 38.
Comments: No way.

I object to Brett's application on MIN 38.
Comments: Say no!

I object to Brett's application on MIN 38.
Comments: Save the woodland!

I object to Brett's application on MIN 38.

I object to Brett's application on MIN 38.

I object to Brett's application on MIN 38.
Comments: Too beautiful to spoil.

I object to Brett's application on MIN 38.
Comments: Traffic and dust will be a big issue.

I object to Brett's application on MIN 38.
Comments: Traffic is too heavy. Fritton bends at Decoy public house is dangerous to both traffic and pedestrians. A143 ext to A47 at Decoy public house has increased traffic flow.

I object to Brett's application on MIN 38.

I object to Brett's application on MIN 38.

I object to Brett's application on MIN 38.
Comments: This planet needs every tree not less.

I object to Brett's application on MIN 38.
Comments: Enough is enough.

I object to Brett's application on MIN 38.
Comments: Noise, pollution, traffic and discomfort to residents of the area.

I object to Brett's application on MIN 38.