Question 81: Proposed site MIN 210

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'.

The plans were explained to the parish council in detail, Questions were asked and answered by a representative from Earsham Gravels, and overall parish councillors were happy with the screening of the site and the envisaged noise levels.

There appeared to be no increase in vehicle movement and would mean continued employment for the workforce which is important in a rural location such as this.

At a recent parish council meeting, members of the public were in attendance and also had the opportunity to discuss their queries with the Earsham Gravels representative.

I am writing to raise my objections regarding the gravel quarry that is being proposed in Earsham village. Only people within 250 meters of the site got a letter and even some of those residents didn't receive one. So few people have been informed and the documents and comments form being online means that it is not accessible to everyone in the village. Furthermore, I believe this will effect people outside of the village too in regards to the Wetland centre and public walkways. I am particularly concerned about the noise, traffic, dust and air pollution that will be created, as well as the disruption of the natural habitats home to a number of our wildlife.

I am writing to raise my objections regarding the gravel quarry that is being proposed at Earsham. This will spoil the natural beauty of the village, the Wetland centre and public walkways. I am particularly concerned about the noise, traffic, dust and air pollution that will be created, as well as the obvious destruction of the natural habitats of a number of our precious wildlife.
I look foward to hearing your response

Further information is provided in support of this Allocation including alterations to the original submission. This are illustrated on drawings submitted under separate cover, replacing the original versions.
The information/alterations comprise:
(i) The processing plant site will be relocated out of the Broads Authority Executive Area and into Extraction Area 1. This will take place once sufficient space has been created within the Area to accommodate the plant site, estimated to be 5 years from commencing the development.
(ii) The order of working Areas 2 and 3 has been reversed.
(iii) Additional screening of the development by means of bunding and advance planting is proposed.
(iv) Revised restoration proposals aimed at further increasing biodiversity.
(v) A replacement Location Plan to illustrate the extent of a future Application Area.
(vi) A replacement Access Plan to reflect the new position of the processing plant site.

I am writing to raise my objections regarding the gravel quarry that is being proposed at Earsham. This will spoil the natural beauty of the village, the Wetland centre and public walkways. I am particularly concerned about the noise, traffic, dust and air pollution that will be created, as well as the obvious destruction of the natural habitats of a number of our precious wildlife.

I look foward to hearing your response

I object to the proposed expansion of Earsham Gravel Ltd's sites in Earsham and to ask for an extended consultation period and more transparent communication to residents of the village.

I object to the proposed expansion of Earsham Gravel Ltd's site in Earsham & to ask for an extended consultation period & more transparent communications to residents of the village.

I am writing this email to express my disappointment and objection to the expansion of the gravel quarry in Earsham.

As a regular visitor of Earsham and Bungay area I feel that this expansion would have a drastically negative impact on the local area and surrounding landscape. Additional noise, traffic and air pollution are all big concerns (to name just a few) of mine as well as the many friends and family I have who live locally - those of whom will also be writing to address their concerns.

I hope that in this case, the needs of the local area and residents will be taken into account (as they clearly haven't been thus far - considering that the efforts of the consultation have been so limited!).

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

I am writing to express concerns I have about the three sites proposed for the expansion of Earsham Gravel Ltd In Earsham (Min 209, 210 and 211). My concerns about the proposals and the way they have been communicated are as follows:
* The map on the proposal application is misleading as it doesn't show most of the housing in the area.
* The sites are extremely close to the village and the dust, noise and emissions would negatively impact residents
* Only some residents, within a small radius of the proposed sites, have been informed by post with a very short notice period in which to voice any concerns they may have. In addition, many of the residence that would be effected by the expansion of Earsham Gravel are elderly and are unable to access the documents online and would find it difficult to travel to Libraries to access the information.
* Widening Hall road and increasing traffic (especially large industrial trucks) would discorrage many from using Pheasants walk and other public paths, which would make Earsham a less attractive place for visitors and residents.
* long term the proposals have no solid offer of improving the village
* the proposals for the site after gravel has been extracted are ambiguous

I feel that there should be an extended consultation period and clear, accessible information provided for the residents of Earsham.

I object to the proposed expansion of Earsham Gravel Ltd's sites in Earsham and to ask for an extended consultation period and more transparent communications to the residents of Earsham Village.

I feel that this will impact us as residents of Earsham and we have not been provided adequate information in these circumstances.

I object to the proposed expansion of Earsham Gravel Ltd's sites in Earsham and to ask for an extended consultation period and more transparent communications to the residents of Earsham Village.
It will clearly impact all residents of the village and yet very few of us were notified or given any information of the proposal, which is unacceptable.

I write as (a) District Councillor for the Earsham Ward, and (b) a glacial geomorphologist and geodiversity expert (author of 2 editions of the book "Geodiversity: valuing and conserving abiotic nature" (Wiley-Blackwell, 2004 & 2013)).

As District Councillor my primary concern is the well-being of residents and the impact on them of quarrying activities. All 3 extension sites have houses nearby where impacts of noise, dust, traffic, etc. will need to be assessed. Site MIN209 is on the opposite side of the A143 to a field that has been submitted for housing allocation in the South Norfolk Council Local Plan, though no decision has been reached on this as yet.

As a glacial geomorphologist, the dilemma is that excavation of land often leads to evidence for past processes and environments yet also destroys physical features. Recent research at the existing quarry in Pheasants Walk, Earsham (Proceedings of the Geologists' Association, Vol 129, pps 70-88, 2018) has shed new light on the origin of the Earsham Terrace that has traditionally been interpreted as an outwash terrace deposited from a glacier whose terminus may have lain at Homersfield. The important point is that the gravel terrace and gravels at Earsham are scientifically important and this needs to be taken into account in the allocation sites for gravel extraction in this area. As such I have no objection to site MIN211 on Bath Hills Road which is east of the existing quarry and remote from the main terrace surface below Park Farm. Similarly, on geomorphological grounds, I have no objection to site MIN209 as an extension to the existing quarry. I have more problems with site MIN210 as it extends westwards into the main terrace surface, and would object to its allocation as a gravel extraction extension site.

We object to the proposed expansion of Earsham Gravel Ltd's sites in Earsham and ask for an extended consultation period and more transparent communications with residents of the village.

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.

I object to the proposed expansion of Earsham gravel ltd's site in Earsham and ask to have an extended consultation period and more transparent communications to residents of the village.

I live opposite to (within 200m)of the proposed site so would like more information on :

*the implications of the main road as hall Road will be widened... There is also a foot path opposite (down the side of our house) so would this make it more difficult to cross the road which we do daily to walk our dog.

*how will this impact on my property value?

*my way of life as at the moment I have the back door open, and the field views (which I understand will be restored after 6years?)

*I have a young child and would like to know the working hours as I wouldn't want loud noise when trying to get him to bed.

*this will impact on us for the 6 year period.

Due to the above concerns what compensation would we be offered? I look forward to hearing from you and answers to my questions.

We have just been informed of this entirely unacceptable proposal to extract minerals from sites adjacent to the A143 at Earsham. The impact to the local environment and quality of life to the residents of Earsham is beyond comprehension.

Therefore:

I object to the proposed expansion Earsham Gravel Ltd's sites in Earsham and to request an extended consultation period and more transparent communication to residents of the village.

Sites MIN 209, MIN 210, MIN 211

I have only just heard about the application for extensions to Earsham Gravel Ltd's mineral extraction sites. I am very surprised that there has not been full consultation in the village as, the last time a major extension was proposed to Earsham Gravel, there was a display of the proposals in the village hall and local people were notified and encouraged to comment. This time, only a few people have received notification and little publicity has been given, with a short public consultation period.

Having read the proposal for each site, a number of questions and points of comment come to mind. I recognise that Earsham Gravel Ltd is a valued local business and that it needs new sites for ongoing development; also that the local gravel is prized throughout the country. However, I think that there should be genuine local consultation, not the absolute minimum possible, and that people need to have their concerns addressed before the application goes to the next stage. For this reason, I object to the proposed expansion of Earsham Gravel Ltd's sites in Earsham and ask for an extended consultation period, with full communication to all residents of the village and answers to questions raised.

The Initial Consultation Policies document states (4g) that the planning period extends to October 2020 and specific planning permission would follow that, yet the application for the site MIN 209 gives a potential start date of 2018 - that is, within the next four months. The dates for each project follow each other closely with no apparent allowance given for preparation or restoration, yet the documents also state that there will not be an overlap of projects and I would like to know a clearer timeframe of the whole procedure.

Restoration, in each case, is proposed to be wet grassland with ponds, landscaping etc and "geological exposure" (whatever that means) but whether that would be a public amenity, enclosed wildlife sanctuary, commercial or private fishing lakes, or anything else is not said. In addition, some 18 hectares of agricultural land will be permanently lost.

The land under consideration is at the bottom of a hill and, even with bundings in place to hide the sites from the village and main road, I wonder how much dust will be likely to drift towards the village over the main road and how much noise and visible disruption will affect those on higher ground. Two of the three sites are right by the A143 and I note that noise and dust assessments will be carried out and trust that careful consideration will be given to the results of the assessments.

In the plan for MIN 211, under Landscape, it is stated that part of the proposal is for the plant site to be moved into a restored area of the existing quarry site. However, it says it would be "preferable" for the plant site to be moved into one of the extension areas. This, slipped in so casually, is quite startling. I can see that, for the business of Earsham Gravel itself, it would be of great benefit to have the plant site by the main road rather than a long way down the single track Bath Hills Road. However, it's a huge, ugly area with great heaps of gravel and many lorries coming and going and the advantage of its present placement is that it affects very few residents. It's stated that it would be a "landscape improvement," but for whom or what? If one site is replaced by another, there is no overall improvement and there certainly would be a great impact on the new site; which would then not be restored as wet grassland.

I see that the estimated number of vehicle movements would be the same, but over a longer period - does this mean per day? The meaning is unclear and no explanation is given why the same number of vehicle movements needs a longer period of use.

Having only just read the application documents today and yet having immediately seen so many points that need to be clarified and addressed, I do hope that my concerns and objections are considered; initially in regard to the request for further public consultation.

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.

Question 80 - MIN 209
We strongly disagree with this site being used to extract gravel. Comments: - The application by Parish Councillor Bennett, the owner of Earsham Gravels is seriously flawed and makes light of serious issues. The map used in the application is years old and does not show 'the village' of Earsham as it stands today. There are no residential roads shows by either sidings, Station Road, Beach Tree Way or the location and number of people's homes or the nearby sheltered housing complex. We own a property on Hall Road which is not shown and is probably the nearest to MIN 209. The application states it is 118 metres from the site boundary. Then goes on to admit dust impacts are uncommon beyond 250 metres.
If I was a newt no disturbance would be allowed within 500 metres, but then we are only a pair of elderly humans trying to live out our retirement in peace, as are our neighbours.
58 sensitive 'receptors' within 250 metres of the site? 'Receptors', do they mean people's homes? If so, say so.
'Settlement' of Earsham. It is not a settlement it is a full blown village with 200 plus houses and still expanding. A church, village green, village hall, in which Parish Councillor Bennett sits on the parish council meetings. A pub owned by Parish Councillor Bennett. Is this just another attempt to dumb down the area? Earsham Gravel company has raped most of the countryside around Bath Hills and now seems set on raping the last bits of land near the village. MIN 209 must be kept as a buffer zone and remain agricultural land. Parish Councillor Bennett has stated if he gets permission he will move all his processing plant from Bath Hills to the Hall Road end of MIN 209. So not just dust but noise as well for Earsham residents.
There are public rights of way adjacent to site MIN 209 Pheasant Walk which runs between MIN 209 and MIN 210 is a redundant public road which has been blocked to vehicles and is popular with pedestrians and dog walkers and Hall Road (C365) the proposed access route for HGVs (46 movements a day) is part of the long distance 'Angels Way' footpath, a popular path for hikers and bikers.
MIN 209 and the field opposite (the other side of the A143) is an important site for day time rousting and feeding for lapwings in the autumn and early winter. What will happen to them?
We have no wish to see Earsham Gravels Ltd go out of business. We have no objections to MIN 210. We understand there is a vast seem stretching from MIN 210 all the way to Harleston. Surely a site can be found further up the valley, away from peoples homes with direct access to the A143 and leave the village of Earsham in peace.
Please turn down this application for MIN 209 and MIN 211, a gravel pit has no place beside a village.

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.

I am writing to voice my objections to the three sites proposed for gravel extraction by Earsham Gravel Ltd In Earsham (Min 209, 210 and 211). My objections and concerns around the proposals and the way they have been communicated are as follows:

Concerns around communications and insufficient consultation:
* There has been a distinct lack of transparency and communication around this proposal. Only residents within a small radius of the proposed sites have been informed by post (even some within the designated radius didn't receive a letter). Many people in the village are only now finding out about the application with only a matter of days before the consultation closes.
* The proposal report has not been made readily available, there are many elderly people in the village for whom viewing documents online and sending emails isn't an option. Although some print copies were available in Libraries these were not located in the village and would require transportation to go and view.
* The map on the proposal application is misleading, I am not sure of the age of the map but it doesn't show any indication of the housing that would be directly opposite the proposed site at the end of Hall Road (station road etc). (the map wasn't even provided in the letter to residents)

Concerns around the impact of the proposed Gravel extraction sites (material considerations and social impact):
* The sites are extremely close to the village and the dust, noise and emissions would negatively impact residents.
* Hall road is used by residents and visitors as a tranquil place of beauty and nature for walks and recreation leading on to Pheasants walk and many other natural public paths. The traffic of heavy vehicles would spoil this and make Earsham a less attractive place for visitors and residents alike. This could impact on business for the attractions we have such as the Wetland centre and our lovely Village pub and would be disruptive to the habitats of the varied wildlife in the area.
* Although it is proposed that the sites would eventually be turned into natural areas there is no mention if these would be public and available for the village residents to enjoy or be used for other purposes.

Because of my concerns around lack of consultation my sister and I walked around the village yesterday (9/8/2018) to talk to residents, many of whom had not heard about the proposal.

I attach a petition from 19 residents of Earsham objecting to the applications as they stand and asking for an extended and more transparent consultation period for all three proposed sites.

I hope that you will take into account all of the concerns mentioned above and honour the request for an extended consultation period so that all residents of Earsham can have a fair say in the proposed changes to their village.

Please could you confirm receipt of this email and petition document.

I look forward to hearing from you soon.

Because of my concerns around lack of consultation my sister and I walked around the village yesterday (9/8/2018) to talk to residents, many of whom had not heard about the proposal.

I attach a petition from 19 residents of Earsham objecting to the applications as they stand and asking for an extended and more transparent consultation period for all three proposed sites.

I hope that you will take into account all of the concerns mentioned above and honour the request for an extended consultation period so that all residents of Earsham can have a fair say in the proposed changes to their village.

Action petitioned for:
We, the undersigned, are concerned citizens who urge the council and all involved parties to act now to extend the consultation period beyond the initial six weeks and asks that a more thorough consultation be undertaken with all residents.

Written comments made by residents who signed the petition are:
* concerned about pollution
* noise, dust, disturbance
* traffic too close to village
* too close to housing / too close to village
* moving noisy plant closer village, dust from sites.
* I don't want noise, dust, lorries in village
* undesired affect on Earsham
* road construction
* sand on verges. What is meant by waste.
* Lack of info / not enough information / more information / badly communicated
* extended consultation