Question 83: Proposed site MIN 25

I cannot believe that I am having to write again on the Minerals and Waste strategy proposal for the land adjacent to Hall Farm in the village of Haddiscoe.
As you area aware, this site went through a full planning application in 2014, was unanimously rejected as unsuitable by the parish, District and Norfolk County Council and then went to appeal to the minister and inspectors and was rejected as wholly unsuitable.
The issues with the site then are still issues now, namely proximity and disturbance to the village of Haddiscoe, the unsuitability of the road infrastructure and the impact of the historical church. There is also a public footpath across the site which would be rendered inoperable by any development.
Like many of the houses in the village, we are adjacent to the proposed site, our properties would be blighted and our retirement plans ruined by such a site. I am extremely concerned by the health impacts on myself and my family and other villagers from the dust and particulate matters. If it were to be approved, the we would have little choice but to seek compensation from the council and developers through the legal system.

It is with regret and astonishment that I am writing to express my opinions on the councils Minerals and Waste strategy proposal using land adjacent to the village of Haddiscoe.

Having been through a full and thorough testing of the site, a previous planning application was totally rejected by all councils as wholly unsuitable. The application was taken to the highest appeal and ministers rejected it unanimously.

The issues which led to rejection are still applicable and therefore make this site unacceptable for the council's future plans, namely: proximity to the village, (my property borders onto the proposed site), the road infrastructure and traffic volume would be a serious concern, along with pollutants which would lead to health issues for residents. The effect on the water table and wildlife being on the Broads National Park would also have a considerable effect.

I feel there is no case to answer as this site has been fully investigated and found lacking, therefore, common sense suggests no more time or money should be wasted by considering its inclusion on the Minerals and Waste proposal.

With reference to your letter dated 26th June 2018, regarding the initial proposal for sand and gravel extraction, MIN25, Manor Farm, Haddiscoe.

This site has been the subject of a planning application and was rejected on appeal in 2014.

This site lies close to our property and we feel strongly that, if approved this time, it would have a negative impact on our quality of life. While we recognise that three sides of the site are screened with a mature hedge, our home boarders the site on the same side as Manor Farm, and the report clearly states that there is no screening of any sort along this boundary. We are approx. 100 meters from the site boundary, and the resulting noise, disruption and threat to health from air born small dust particles would have a negative effect on us.

The three homes that are situated along this border seem to have been given no consideration and no mention in the initial report. We find this very disturbing as the report itself clearly states that "the greatest impacts will be within 100 metres of the source, if uncontrolled". As no mention of protection for ourselves or our neighbours seems planned we can only assume that we will be given no consideration by the company seeking to work this site for 9 long years.

The plan will inevitably lower the value of our property, lower the quality of our lives and has the possibility of affecting our health. As I am 67 years old I feel that the effect this will have on me will be considerable, and the likelihood of chest and breathing problems from the small dust particles almost inevitable.

MIN 25 - land at Manor Farm (between Loddon Road and Thorpe Road), Haddiscoe

I hereby object to the above proposal as laid out in the M&WLPR.
To start with, this site was previously looked at (and dismissed in 2014 as stated in the document), but this is the first notification I have had regarding the new proposal. Surely given the previous plan and subsequent years of claim and counter claim, residents of Haddiscoe deserved to be informed of the new proposal before this review.
The proposal suggests 9 years to extract the minerals. What if there is a lack of demand for the materials, how long will it go on for then? Will there be a time limit on the proposer to complete? Or will Haddiscoe be left with another hole in the ground!
We hear on the news etc. that there is an increasing need to feed an increasing population, but here we are removing agricultural land from the system. I am no expert on how good the land is, but I can see with my own eyes that the crops grow.
Also, the proposal mentions how far Gorleston and Gt Yarmouth are from the site, is this where the materials are to be transported to? What consideration has been given to the 'carbon footprint' regarding transporting extracted minerals over this distance? Should not the strategy be trying to look at other alternatives, such as dredging materials from the sea beds at these locations. Another 'carbon footprint' concern is the number of HGV lorry movements (80 per day), increasing diesel pollution and noise.
The document states "There are mature screen planting......on all sides of the site, except a section of the eastern boundary closest to Manor Farm". I wish to point out that I can see farm vehicles working in the field, from my garden! Therefore, we are not screened!
In my opinion, the way the document has been laid out, it would appear this site has already been given the 'green light'. It seems to lack any consideration for the residents of Haddiscoe, who will suffer the noise, dust and pollution this proposal will produce: as well as possible health problems caused by it.

I wish to object in the strongest possible terms to the proposal to extract and process sand and gravel and batch concrete on this site at Haddiscoe.

The area included in the scheme is on the top of a hill with commanding views across the marshes and rolling countryside. Our village is directly adjacent on 2 sides, our two Saxon/Norman Churches, Thorpe and Haddiscoe, overlook from opposite corners, my house overlooks both areas to the south and north of Loddon Road and the Blacksmith's Forge I run with my partner is just to the south of this, with my wild flower meadow in between.

The increase in traffic from Earsham Gravel's own lorries and those vehicles coming to the site to buy sand, gravel and concrete will cause a good deal more noise and add greatly to the danger of already busy, narrow (for main) roads: the B1136 and A143. There is no pavement from my house to the village and for villagers walking to the allotments next to the church, on the B1136, and for those of us who cycle or ride horses along these roads, it is already quite hair-raising. Cars travel very fast along the B1136 coming towards Haddiscoe, often overtaking in a dangerous manner on the stretch leading up to the 30 mph limit sign. This has a reputation as a racetrack, particularly for motorcycles, since the removal of hedges by the Manor Farm owners many years ago gives the illusion of being able to see a great distance along the road. However, the bends and dips are often not clearly discernible until almost upon them. There have been several accidents this year; the added traffic and vehicles passing in and out of the entrance to a gravel pit and plant can only exacerbate this situation.

Although I appreciate that the modern rubber-surfaced equipment is much quieter than the clanging and rattling of the all metal machinery, there will still be industrial type noises of engines, vehicles and the carrying on of trade, very intrusive in the countryside, adding another dimension to the already existing traffic noise, which is sporadic most of the day, increasing only during the early morning and evening "rush hours".

There is nothing in the proposal to give any incentive to the village by way of reward for the disruption, inconvenience and nuisance for 20 years: we are not offered access to appreciate the "landscaped" nature reserve promised after extraction is complete, the landowners can offer the amenity to a private association or keep it to themselves, albeit one public path passes through or around the area. There is no convincing offer of any local employment opportunities. Many of the villagers are retired, hoping to live out the remainder of their lives in peace without this industrial scale disruption and disturbance; they may not be around to appreciate any amenity proposal in 20 years time, were it even to be offered.

There is a large supply of gravel to be extracted over the next 14 years from the Norton/ Heckingham pits only 3-4 miles away from our village and not adjacent to people's homes, gardens and churches.

This pit proposal is unnecessary and inappropriate and I trust will not receive serious consideration from the Council.

I enclose my poem written upon first hearing the outline proposals in 2008, which further expresses my and many others' views.

Today Planning Committee endorsed the response below to the Norfolk Minerals and Waste Local Plan Issues and Options consultation.

I hope this is helpful and I am happy to clarify any points if needed.


Main document
* The Broads has been identified by Historic England as an area with exceptional potential for waterlogged archaeology. Any excavation within or close to the executive area will require particularly robust archaeological evaluation prior to consenting and not rely on a brief desk based evaluation and conditions.
* For the avoidance of doubt, perhaps say that this covers the entire county of Norfolk.
* Perhaps something about how it fits with our Local Plans? Something about how Authorities consulted if application in or near to area? We would like to understand how our special qualities and our policies that could be of relevance would be considered in decision making.
* Page 16, 28 - the Broads has a status equivalent to a national park.
* Page 23 - suggest A3 landscape.
* Page 28: Typographical error: 'Landscape Character Assessments have been carried by the Local Planning Authorities in for Norfolk and they consider where locally designated landscapes of importance are situated'.
* Page 39: Typographical error: 'and/or the volumes of waste in each area so low that it would be unviable for a full range of waste management facilities to exist in every area'.
* Page 41: Typographical error: 'end-of-live vehicles' - should this be 'life'?
* Page 46: Typographical error: '...have similar locational requirements due to their potential to impact on local amenity and the environmental'.
* Page 49: Typographical error: 'of waste electronic electrical and electronic equipment (WEEE)'
* WP17 and MP10 and MP11 - will you provide GIS layers of these facilities and consultation zones?
* Page 61: Typographical error: 'the most recently available date'
* The areas on page 67 - the Broads is not mentioned. Presumably this is because silica sand only occurs in West Norfolk Borough?
* Page 77: Typographical error: 'will be made by on a case by case basis'.
* Page 78: Typographical error: 'Carstone is also a scare resource in Norfolk and therefore it is appropriate for the entire carstone resource to be safeguarded as part of the MSA'
* Page 78 - reference to peat. Whilst extraction is not supported in the NPPF, what about the removal of peat as part of the development related to minerals and waste? Peat has many important qualities and the Authority has a policy relating to peat. How will this be used in determining applications in the Broads? As well as that, you may wish to look at policies relating to peat in terms of its removal and how it is to be treated in relation to its properties.
* Page 81 - are there any areas in Norfolk that could be investigated for unconventional hydrocarbons/fracking?
* Appendix 4: What about moorings and river bank stabilisation and other such applications that occur in the Broads but probably not elsewhere in Norfolk?
* General comment: headers and paragraph numbering would make the document easier to read - pages of text with no breaks was difficult to read.

Question 5: MW2
* Page 26, MW2 could mention dark skies. You could refer to the CPRE Night Blight data as well as our dark skies policy and zones.
* Page 27: Dark skies are important in the Broads and elsewhere. Perhaps more could be said about lighting: directing lighting downwards and away from properties and only lighting if needed and temporary versus permanent illumination.
* Page 27: 'A baseline ecological survey will be necessary where biodiversity features are present on a proposed site. Such surveys are essential in identifying what exists on a proposed mineral or waste management site and establishing whether such features should be retained and managed'. This is a bit confusing and seems to say that a survey would be needed to see if there are biodiversity features on a proposed site to then need a survey? We recommend that all sites would require baseline ecological survey and assessment of the presence of rare and protected species.
* Page 28: 'Local recreation assets, including Public Open Space and other outdoor facilities such as country parks, are protected in District, Borough and City Local Plans'. Also protected in the Local Plan for the Broads.
* Page 29: 'whilst others designated at a local level are subject to protection through District, Borough and City Local Plans'. Also mention the Local Plan for the Broads.

Question 6: MW3
* Page 33: 'All proposals for minerals development or waste management facilities must assess and consider positively the potential for non-HGV transportation of materials to and from the facilities, principally by rail or water'. Perhaps you might want to require an assessment that looks into this and shows their considerations? As written, an applicant does not seem to be required to do anything other than think about it.
* Page 33: 'The County Council will consider minerals and waste development proposals to be satisfactory in terms of access where anticipated HGV movements, taking into account any mitigation measures proposed, do not generate'. Wonder if this could be worded in a more simple way?

Question 7: MW4
* Uses the word 'should' which is quite weak term. A stronger term similar to that uses in other policies (like will need to, must, is required to) might be better.
* Some aspects repeat MW2 - does that matter?

Question 9: MW6
* Does MW6 repeats MW2?
* See previous comment about peat. Should peat be mentioned in this policy?

Question 11: WP2
* Page 45: what is 'appropriate transport infrastructure'?
* Page 45: is the five mile requirement as the crow flies or by road/path etc?

Question 12: WP3
* Page 46: 'Policy WP3: Land uses potentially suitable for waste management facilities'. This does not seem an ideal title for the policy; the policy seems to be more about where waste management facilities can go. Not all of the areas listed in the criteria are land uses in the typical sense; they are areas to which such facilities are directed towards.
* Page 46, do criteria d, e, f apply even if the proposal is not within 5 miles of a town as talked about in the previous policy? How do WP2 and WP3 work together?

Question 16: WP7
* WP7: regarding the location, these could be away from urban areas according to some criteria in WP3. Should these be located near to larger urban areas (i.e. near to the source of the waste)?

Question 22: WP13
* Are the areas of these landfills identified and are any in the Broads?

Question 25: WP16
* Should this include reference to MW2? That seems to have relevant and detailed criteria.

Question 28: Policy MP2
* The Broads, which has a status equivalent to a national park, may need to be listed as a planning constraint

Question 29: MP3
* There is no mention of the requirement for restoration.
* In other policies you cross refer to a more detailed policy, but not in this policy. Presumably policy MW2 is of relevance and could be cross referred to?

Question 31: MP5
* Who does the assessment? Does that need to be handed in with the planning application? How will you liaise with the Broads Authority if proposals come forward in the river valleys in the Broads rather than just consult? Why is the Broads not included in the core river valleys? Is a separate policy on the Broads required? Or is it the case that the Broads is not covered by this policy as the Broads Authority Executive Area is shown on the policies map as a landscape designation and so rivers and broads within the BEA not included under core river valleys policy, potentially affording greater protection i.e. development could be acceptable in Core River Valleys? This could usefully be clarified.
* In other policies you cross refer to a more detailed policy, but not in this policy. Presumably policy MW2 is of relevance and could be cross referred to?
Question 32: MP6
* What are the criteria or is there a checklist that helps ascertain if cumulative impacts are unacceptable?

Question 33: MP7
* As well as GI, ecological networks? There is ecological network work underway for the entire county which could be of relevance.
* The last part says 'The Green infrastructure Strategy' - which strategy is this? The strategy of the district in which the proposal is located?
* There is also a Norfolk-wide habitats map that could be of relevance.

Question 34: Policy MP8
* To gain the ecological benefits outlined for many of the sites an outline aftercare strategy for a minimum of ten years, rather than five years is required prior to the determination of the planning application

Question 35: MP9
* It is not clear if the works then need to be removed and form part of the restoration works or are moth-balled. This could usefully be clarified.

Sites Document
* MIN 38 - land at Waveney Forest, Fritton - the Authority supports the conclusion that this should not be allocated for the reasons as set out in the assessment. Page 169 - the landscape character assessment is also relevant: http://www.broads-authority.gov.uk/news-and-publications/publications-and-reports/planning-publications-and-reports/landscape-character-assessments. Broads Landscape Character Assessment 2016; Land considered as heathland Landscape Character Type (LCT) within the St Olaves to Burgh Castle Landscape Character Area (LCA). Land to the north and west considered to be estuarine marshland LCT within the same LCA. Haddiscoe Island LCA beyond river. The Authority strongly requests that Norfolk County Council liaise with us regarding this site and any future policy prior to the next version of the Local Plan. Strongly support this conclusion and the reasons for it. The current commercial forest operation, whilst not ideal in terms of the HE features within it, offers a degree of continued protection to those features. Page 169 Typographical error: "although food practice for tree felling" presumably should read good practice.

* MIN65; support submission of Heritage statement

* MIN 209, 210, 211; For information, the Broads Landscape Character Assessment 2016 says that this area is LCA Outney Common and Bath Hills, Industrial / Early post-industrial LCT boarders MIN 211. The Authority strongly requests that Norfolk County Council liaise with us regarding this site and the policy prior to the next version of the Local Plan. Support removal of plant site from BA executive area. What will go in its place?

* MIN 25; Broads Landscape Character Assessment 2016; Norton Marshes to Haddiscoe Dismantled Railway LCA immediately NE. Adjacent LCT is settlement fringe which would be covered in time by the Broads settlement fringe policy. Support submission of Heritage statement.Whilst this is not within the Broads, the Authority strongly requests that Norfolk County Council liaise with us regarding this site and the policy prior to the next version of the Local Plan.

MIN 92; Broads Landscape Character Assessment 2016; Chet Valley LCA, Carr woodland LCT to west and upland LCT to the north and south. Recommended not to support this site going forward (in terms of landscape) for reasons as set out in the supporting text under 'landscape'.

I am writing to you in my capacity of Parish Clerk to Haddiscoe Parish Council. Could you please include our comments below in your Consultation:

This Parish Council are implacably opposed to developing the site you identify as MIN 25 in the village of Haddiscoe. We are also surprised that we were not a recipient of your letter dated 26.06.18, notifying only the immediate residents of the proposed site. We supported the residents of this village in preventing an identical development four years ago, planning ref APP/X2600/A/13/2197841. The original Planning application was refused, despite the Planning Officer's recommendation for approval, thanks to our parishioners energetic campaign called "Stopit". The reasons for the original refusal and the upholding of the Council's decision on Appeal in 2014, were the protection of heritage assets, in particular our Grade I Listed Church, and an unacceptable impact on the environment and residential amenities, from what would have been an industrial scale development in the heart of our village. The Stopit campaign raised £ 19,300 by private subscription from residents in order to fund legal fees. Of 227 households in the village, 120 were active Stopit members and in the planning process there were 175 objections and just 1 supporting letter (from the owner of the site). This was a stressful and anxious six years which we do not wish to repeat. We would earnestly request that this site is excluded from the Local Plan review.

Norfolk Minerals and Waste Local Plan Review: Initial Consultation
I write in response to your letter of 26th June concerning the above subject. I was surprised that you were writing to me.

The site at Haddiscoe (Min25) in the last consultation document received objections from 175 Haddiscoe residents. It was turned down by the Parish Council and the District Council, and did not make it on to the County Council's own "preferred list. as it was deemed in your own policy documents of 2011 "inappropriate for allocation due to potential landscape, amenity and highways impacts."

Despite this the proposers pursued the application with support from an officer in your department. The application was rejected by the County Council's planning committee voting against the recommendation of your department.

The applicants appealed, forcing your department into a U turn, as you now had to defend the committee's decision. The appeal was dismissed by Her Majesty's planning Inspector in 2014. All this at considerable cost to the County Council and the residents of Haddiscoe.

Now only four years later you are proposing to put the community through this ridiculous, over elaborate, expensive, and evidently flawed process again.

Hence my surprise.

I am writing to put in an objection regarding the possible planning for extraction of minerals and local waste in the field that is directly opposite us. Being a business I believe that this would have a negative impact on ourselves as a whole business, that is before also putting a negative valuation on the business. There are also the wider aspects to the procedure of obtaining from this particular area. The impact on the wildlife and the marshes themselves would be a huge concern. Another objection that I would have would be the health concerns, the amount of dust that there would be to contend with, causing breathing problems.
I would also like to ask what the impact would be to the actual soil stability and drainage, I cannot imagine that there would not be a detrimental affect on the eco system, as well as the noise pollution in the area. I think as well that this would affect more people than at first thought. I could not find an actual reference number to quote on the letter that I received regarding this issue, however this is regarding the Norfolk Minerals and Waste local plan review and the principal planner is Caroline Jeffery.

Thank you for your time in this matter and if my comments could be taken on board it is very much appreciated.

Please refer to our comments on protected landscapes in our letter of 13 August 2018.

There have been pits in Haddiscoe historically & I see no reason to block this pit now. It will bring much needed employment to the area & potentially boost local businesses

Strongly opposed to this application that seems to ignore the result of a
previous attempt AND THE FEELINGS of the residents of Haddiscoe.
The extra traffic, noise and dust that it will generate is not acceptable,
the previous application was not felt to be benificial and the case for it
was dismissed, as should this one.

Tree screening will not stop the significant noise pollution from the extraction. Resulting in damage to enjoyment of rural environment. Dangerous junction with A146 80 lorries daily means increased risk to life. The impact on Landspring bec and water levels potentially effects the whole village as past disruption to the water table continues to be problematic. Dispite promises in any application there is no protection that if this plan is followed that subsequent requests to fill the remaining hole with rubbish will not be made as has happened in all the other excavation sites within and near to the village.

1/ The road infrastructure is both unsuitable and incapable of supporting the increase in heavy goods traffic that would result. Manor farm is surrounded by minor roads and country lanes which at times struggle to cope with domestic traffic.
2/ The impact on properties in the surrounding area will be devastating in both noise nuisance, and consequent devaluation. Developing Manor farm in this way would alter the character and enjoyment of the locality.
3/ This development would have a negative impact to the village, it's wildlife and movement of traffic. Haddiscoe is already a road traffic accident hot spot.

Object on basis of noise, dust, increased traffic. The boundary towards the village has no screening planting. 25% of the village is in close proximity to the proposed site.
The old gravel pit, once owned by Cemex is an eyesore with a dangerous lake (drownings have occurred) and has been semi abandoned for many years. No trust that an idyllic grassland would be restored. Current boundary screening lends itself to fly tipping and is more open during winter months. Have no wish to listen to heavy machinery, gravel being tipped, constant reversing alarms, and have sand blowing through the streets

Initial conclusion regarding highway access.
You state that any planning application addresses the requirement to have a highway access that is considered suitable by the Highway Agency. I would hope that this would include a thorough investigation and consultation on the adequacy of the existing routes serving the site and the impact that the increased traffic(80HGV lorries a day) would have on the environment and residents of Haddiscoe.

I wish to object in the strongest possible terms to the inclusion of the Manor Farm site at Haddiscoe on the list of proposed mineral extraction sites in the Initial Consultation document.

The siting of a gravel pit so close to our village is completely inappropriate. The peace and tranquillityof my house and garden would be ruined by noise, dust and grit produced by the extraction processes and all the lorries.

We fought against this for many years, through a Planning procedure initiated in 2008, which was rejected by plannning committee in 2012, and again thrown out on Appeal in 2014.

Inclusion of this site on the proposed mineral extraction sites Initial Consultation document is unnecessary and inappropriate and I trust will not receive serious consideration from the Council.

As a resident of Haddiscoe and living in close proximity to the proposed extraction site I would like raise objections to the proposals.
I am concerned about Potential Noise ,Dust ,Traffic and Environmental issues which will ensue as a result of the works and impact on those Residences which are in its vicinity
The Village is a very quiet area and the constant movement of gravel loading and vehicles reversing and beeping constantly will almost certainly detract from this pleasant rural location.
This proposal is far to close to residences for it not to have an impact and consequently will devalue property prices
There have been previous applications for Gravel Extraction in the village. Notably the land to the South of Loddon Road
Fortunately these applications were rejected and at the time we were advised that there was a sufficient Gravel Bank in Norfolk to meet projected demand.
Therefore there is no need to start any extraction at Haddiscoe within the next 40 years
Currently the nearest working Extraction site is only a short distance from the proposed site and has been given permission to extend the extraction process

As a resident of Haddiscoe and living in close proximity to the proposed extraction site I would like raise objections to the proposals.
I am concerned about Potential Noise ,Dust ,Traffic and Environmental issues which will ensue as a result of the works and impact on those Residences which are in its vicinity
The Village is a very quiet area and the constant movement of gravel loading and vehicles reversing and beeping constantly will almost certainly detract from this pleasant rural location.
This proposal is far to close to residences for it not to have an impact and consequently will devalue property prices
There have been previous applications for Gravel Extraction in the village. Notably the land to the South of Loddon Road
Fortunately these applications were rejected and at the time we were advised that there was a sufficient Gravel Bank in Norfolk to meet projected demand.
Therefore there is no need to start any extraction at Haddiscoe within the next 40 years
Currently the nearest working Extraction site is only a short distance from the proposed site and has been given permission to extend the extraction process

1. Where is the detailed plan outlining all areas affected by the exploitation ie areas under potential risk "Devil's End Meadow" by Min25?
2. Where is the site specific plan showing position of the processing plant?
3. What compensation will be offered to properties directly affected by the works?
4. What will the closest proximity of the deposit exploitation be to the boundary of any directly affected property?
5. To what depth will the deposit be extracted to?
6. Will the reinstatement of the site be 100% accessible to the public after the works cease? Will the reinstatement be phased or will it start once the deposit has been exploited?
7. What will happen to the public right of way through the site during and after the works?
8. What detailed conservation proposals are drafted for the reinstatement?
9. The fall off from the deposit slopes towards the marshes within the Broads Authority boundary. There is a natural spring there where there are lots of newts. Will the works alter the hydrostatic fall and affect the Flora and Fauna? ie Devils End Meadow.
10. Will any jobs for locals be generated?
11. Will any plans for waste disposal as part of the reinstatement works be proposed?
12. What operating hours will be proposed for the site (any weekend work)?
13. What pollution controls will be proposed for dust, noise, mud on the road?
14. What upgrades to Crab Apple Lane junction are proposed?

With reference to the above project l am disgusted that this situation has again arisen in the light of the previous application for a gravel pit in this area was defeated several times in the courts and finally rejected by Norfolk County Council.
This is a small village with narrow roads totally unsuitable for constant use by heavy lorries etc. We strongly protest at this back door attempt to bring to this village a project that was so vigorously fought over just for what appears to be the profit of a local farmer.
The benefit to the local community is virtually nil with few if any jobs for locals. The disruption that would be caused is totally unacceptable.

We therefore request you drop this idea and look elsewhere - to a place that will not affect so many people for such little return.

We went through 6 years of Hell (2008 - 2014) fighting and winning a traumatic, stress-inducing, time-consuming and costly battle against proposals to have a gravel pit on this site and you have the audacity to write to me and ask if I want to object to it all starting again? Do I want to object? DO I WANT TO OBJECT? DO FROGS FART ON LILY PADS?

How strange things are in this 18th century staging post Forge, where I write, with roots back to the Domesday Book and beyond - Saxon ? , it nestles into a Hill Fort Rampart, a Ley Line runs through the Church and Forge - right through one of the hearths,where we light our Fire and pray-chant-spell: Ignei—Aerii—Aquantani—Terra , Spiritus salvete!

Here, in the front line of muck and bullets, we live life to the full, with all its ancient traditions, rituals, ceremonies intact.

So, every time we light one or both of our inside fires (we have 13 altogether, in and out), we chant this prayer:

Sint mihi dei acherontis propitii!
Valeat numen triples Jehovae!
Ignei, Aerii, Aquantani, Terra,
Spiritus salvete!

Followed by a Celtic spell in honour of Brighid, Goddess and Christian Saint, which I'll leave out here, those interested can come to the Forge and learn it from Wendy.

Now, when we have some wickedness, such as evil, greedy b......s trying to ruin everyones' lives, we read the full version, with all the Elizabethan Magick and Alchemy, much used by William Shakespeare, Sir Walter Raleigh, Christopher Marlow, Francis Drake, John Dee, John Donne, Sir Philip Sydney, Francis Bacon......

All of which I sent you before, in our previous exchanges.

Hasn't the village suffered enough ?

NO, WE DO NOT WANT THE BLOODY PIT

NO, NORFOLK DOES NOT NEED OUR GRAVEL

Haddiscoe has given enough gravel in the past, Wiggs Lane, behind the village hall, the -now- fishing lake (Cemex) and the Parish Pit, Gravel Pit Lane. There is a huge operation at Norton/Heckingham, only 3-4 miles away, which will be producing gravel for many more years, so I think we've done and are doing our bit!

NO It's too near two beautiful churches (why they don't have the wrath of God fall on them - the would-be re-applicants), I do not know, if I was a Christian, I'd give it up, if the Pit went ahead - but then, God allows all sorts of Holocausts to happen, perhaps he is not a proponent of an eye for an eye, tooth for a tooth (Lex Talionis) as his Yaweh persona orders, but what I, as a (K)Cabalist Jew expound: give them enough rope and they'll hang themselves (hang on- no pun- I believe in Lex Talionis too).

Too near lots of peoples' houses.

Too near, across the fields, a school.

Too near a Dog Kennels, why should the doggies have to suffer dust, grit and noise.

Yours, in real anger (real politik) at the audacity I have been asked to comment on,

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.

Thank you for your recent consultation on the above document, South Norfolk Council has the following comments to make.

General comments regarding the format of the policies:
Several policies concerning particular development types refer back to 'General' Policy MW2; whilst the reason for this is understood, there are a number of other general policies (e.g. MW3 and MW4) that might be equally applicable across a range of development types, but may get overlooked when development specific policies just refer back to MW2. As the policies in the plan should be read as a whole, is it necessary to have the references back to the general Development Management policies?
In a number of places policies are worded as aspirations, rather than requirements, consideration should be given to moving such wording to the supporting text, or strengthening the wording in the policy itself.

Comments on specific policies:

MW6 - would be more effective if it set out a hierarchy that sought development on the lowest grade of agricultural land first.

WP2 - it is not entirely clear what the first part of this policy is seeking to achieve; if it is seeking sustainable locations within easy reach of centres of population (particularly those that the proposed facilities are serving), the text may need to be expanded to better reflect this.

WP3 - in the list of potentially suitable land uses, 'within or adjacent to agriculture and forestry buildings' would appear to open up a wide range of sites to possible consideration, although it is understood that sites would need to meet the requirements of the general policies too. Permitted Development also opens up the scope for new build agricultural buildings, with relatively little input from the local planning authority. Consequently, could clause d) be caveated 'appropriately located' and 'in established use'?

WP4, WP5, WP7 etc. - a number of policies refer back to WP3 stating that proposals 'may be acceptable on land within the identified uses in', the Policy could be more effective as 'will not be acceptable outside of land identified in'.

WP7 - Concerned that this may not be legally sound, in that it goes beyond the remit of the Minerals and Waste Local Plan by seeking developer contributions. It would also be difficult to 'retro-fit' new Household Waste Recycling Centres into identified growth locations, if it was not a requirement when those locations were identified. Consideration could be given to allocating sites in the Minerals and Waste Local Plan which have good access to the growth locations.

WP15 - elements of this policy would appear to be requests rather than requirements, for example could 'strong encouragement' to Anglian Water be included in the supporting text, and the policy be reworded to say, 'Any proposals for the improvement of WWRC must to be accompanied by a longer-term vision, produced in collaboration with ...'

WP16 - This seems to overlap with MW2 and MW3; therefore, would this policy be better placed in the General Policies part of the Plan, and used to cover waste and minerals proposals?

Comments on Proposed Minerals Extraction Sites:

MIN25 at Haddiscoe - the site is very close to the nearest dwelling and the village generally, it would seem to be quite a significant site in terms of volume of material to be extracted, number of lorry movements etc. (we note there is a balance to be struck between length of extraction time and daily vehicle movements, to address concerns raised by the previous refusal of permission). Is there any scope to reduce the extent of the site, moving the boundary away from nearby dwellings and/or phasing the extraction as part of any mitigation? This, along with the impact on the Grade I Listed church and the visual impact of the proposed bunding, was a concern that South Norfolk Council raised in respect of the previous application on this site. In addition, the landscape assessment refers to mature screen planting, it would be useful if retention of this was picked up in the Initial Conclusion.

MIN 212 at Mundham - The relationship between the site and the processing plant seems to be quite poor, although it is acknowledged that the number of movements are relatively small and this is an existing route. The proposal includes increased bunding to screen the minerals workings, but doesn't indicate if that would be acceptable in terms of the landscape character type within which the site is located.

I hope you find the above comments useful.

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

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

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

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

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

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

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

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

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

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

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

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

Allocated Sites with Groundwater Protection Constraints

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

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

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

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

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

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

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

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

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

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

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

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

Allocated Sites with Flood Risk Constraints

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

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

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

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

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

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

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

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

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

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

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

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

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

I would like to object to the proposed mineral and gravel extraction at the sites along the A143 corridor in the vicinity of Fritton and Earsham. I am a resident of Belton and regularly use the A143 which is the main access point for the village. I am concerned about the increase in heavy good vehicles along this single carriageway road that these proposed developments will bring. This is due to increased exhaust fumes damaging health, increased wear and tear to the road surface and historic buildings, noise and vibrations spoiling peace and quiet, increased traffic jams & congestion on what is already a busy and often dangerous road.

I would also like to object due to the loss of habitat to wildlife and green space. This is especially important with the proposed developments being so close to the broads national park and the detrimental affect to tourism which is essential to the local economy.

Finally I believe that there is an increase in the potential for ionised dust particles to be spread within the local areas, including Belton, due to overhead power cables in the area which have been scientifically proven to increase the risk to health from such illnesses as Cancer. I do not wish for my health to be affected by increases in particles from both vehicle emissions and from the mineral extraction itself.

For these reasons I specifically object to the developments proposed at Waveney Forrest / Fritton Woods and at Earsham and any other sites located or requiring access to the A143 and therefore impacting on my quality of life at Belton.

Thank you for taking my views into consideration.

Norfolk County Council: Minerals and Waste Local Plan Initial Consultation May 2018

Representations made on behalf of CEMEX UK Materials Ltd.

Minerals Strategic Objectives

MSO10: As currently drafted this objective appears to establish a mandatory requirement for any restoration scheme to increase public access and enhance biodiversity. There could be circumstances, however, where this requirement is not appropriate, such as limiting public access when seeking to establish an ecologically slanted restoration or where the land is best and most versatile agricultural land and returning that land back to agricultural production may be the primary driver behind its restoration. The following revision is therefore proposed: -

"WHERE APPROPRIATE, increase public access to the countryside and enhance biodiversity through enhancing the amenity value of land when restoring extraction sites."

The above would also better reflect the phrasing of Policy MW2.

General Policies

MW3: Quarries by their nature have to be located where the mineral that is sought to be quarried occurs. This often places them in rural and/or remote areas where there is little or no access to public transport. This potential remoteness can also mean that travel to work distances are too great for employees to be reasonable expected to either cycle or walk to work. Furthermore, due to the demands of customers, quarries often commence daily operations early, before public transport commences operations itself, if any is available. As drafted Policy MW3 does not reflect these practicalities. The following revision is therefore proposed: -

* "WHERE APPROPRIATE, measures to reduce car travel to the site by workers and visitors and encourage walking, cycling and use of public transport."

Minerals Specific Policies

MP1: As currently drafted the Company believes that this policy would be found to be unsound as it does not reflect Government guidance regards the provision of sand and gravel and no material circumstances have been identified by the Plan that explain why the approach taken is appropriate. The following revision is proposed: -

"For sand and gravel, specific sites to deliver at least 23,063,560 tonnes of resources will be allocated. The sand and gravel landbank will be maintained TO at LEAST 7 years' supply (excluding any contribution from borrow pits for major construction projects)."

The above phraseology better reflects guidance contained with paragraph 207f of the revised NPPF and is considered sound.

MP7: The Company wholly support the aim of retaining sample exposures of scientifically important geological exposures, but this must be tempered by health and safety considerations. There may be circumstances, such as high quarry faces or face instability where retention would not be appropriate. As such it is proposed that the policy be revised as follows: -

* Any important geology or geomorphology on the site will be retained in sample exposures for study purposes WHERE APPROPRIATE.

MP10: Paragraph b of this policy does not specifically refer to facilities for the handing of primary won aggregate; this oversight should be remedied as follows: -

b) Existing, planned and potential sites for concrete batching, the manufacture of coated materials, other concrete products and the handling, processing and distribution of PRIMARY, substitute, recycled and secondary aggregate material.

Appendix 5

Both the Company's Norwich (Broadsman Close) or Brandon (Mundford Road) railheads appear not to have be identified within this appendix as safeguarded facilities. It is requested that both are added to the appendix.

Appendix 7

Neither the Company's Costessey recycling facility nor the adjacent landfill appear to been identified within this appendix as safeguarded waste management facilities. It is requested that both are added to the appendix.

Proposed Minerals Extraction Sites

MIN 202: The Company supports the identification of land south of Reepham Road, Attlebridge, as suitable for allocation for sand and gravel extraction.

MIN 25: The Company supports the identification of land at Manor Farm (between Loddon Road and Thorpe Road), Haddiscoe, as suitable for allocation for sand and gravel extraction.

An additional site has very recently been drawn to the Company's attention, Mansom Plantation, please find attached a completed pro forma, location plan and preliminary geological report (additional detail is expected shortly). On the basis of geological investigations to date this site appears to contain approximately 1.5 million tonnes of coarse sand and gravel lying in close proximity to the County's main aggregate market, Norwich, and with direct access to the A140. Part of the site is also subject to an extant permission for leisure development. As such the Company propose its identification in the Development Plan as a Specific Site for mineral extraction.

The Company has as yet not been able to consider in detail the potential environmental constraints that relate to this site. It would be happy to discuss with the Minerals Planning Authority expanding the evidence base for this site if would assist the Authority in its deliberations.