Question 76: Proposed site MIN 71

Showing comments and forms 1 to 26 of 26

Object

Initial Consultation document

Representation ID: 91832

Received: 20/07/2018

Respondent: Mr R Carter

Representation Summary:

I disagree with the initial conclusion of the Planning Officer that: the site is considered suitable for sand and gravel extraction, subject to any planning application addressing the requirements below..."
I would comment as follows:

AMENITY:
1. "The nearest residential property is 11m from the site boundary"
An inspection of local maps shows that a number of properties directly share a boundary with the mineral site, or are the width of a road from the boundary.
2. "There are 82 sensitive receptors within 250m of the site boundary. Most of these properties are in the settlement of Holt, which is 26m away."
This statement fails to convey the fact that significant numbers of people living in Holt will be affected by the proximity of the site. No figure of actual numbers is given but it would not be unreasonable to estimate a figure in the range of 160 to 240.
3. "The greatest impact will be within 100 metres of a source..."
No number is given here, but in the context of the above statement, it clearly needs to be addressed.

LANDSCAPE: There are a number of properties on different sides of the quarry which require stand off protection, and substantive landscape treatments to properly protect the inhabitants. It is clear that the scale and extent of works needed to the quarry would cause a serious loss of amenity to residents and tourists alike, and would visually impair the open and attractive landscapes of one of the major roads into Holt.

ECOLOGY: There are numerous references to County Wildlife Sites, giving the distance from the site boundary. There is though, no mention of Holt Country Park, which is a Green Flag award winner and is situated near the site - it is a woodland dominated by Scots pines and native broadleaves, with orchids, a wide variety of butterflies, dragonflies and damselflies and an abundant display of wildlife including goldcrests, greater spotted woodpeckers and deer.

CONCLUSION:
There are significant numbers of residents within a short distance of the site boundaries. Many of them are of retirement age with respiratory and medical complaints which are exacerbated by dust, pollution and contaminants.
in order to mitigate the risk of quarrying to residents in such close proximity, significant landscape and groundworks need to be undertaken, which in themselves risk being intrusive in their own right. The visual impact on nearby dwellings and the disruption to the surrounding landscape would be severe, and it would significantly affect the residents and visiting tourists quiet enjoyment of the surrounding countryside.

I would refer the Planning Department to other sites in their consultation document that they found 'unacceptable' due to the detrimental impact quarrying would have on the landscape and residential properties (MIN 23, MIN 116, MIN 74, MIN 32), and ask that they apply the same policy to MIN 71.

Full text:

MIN 71 - land west of Norwich Road, Holt - Question 76

I disagree with the initial conclusion of the Planning Officer that: the site is considered suitable for sand and gravel extraction, subject to any planning application addressing the requirements below..."
I would comment as follows:

AMENITY:
1. "The nearest residential property is 11m from the site boundary"
An inspection of local maps shows that a number of properties directly share a boundary with the mineral site, or are the width of a road from the boundary.
2. "There are 82 sensitive receptors within 250m of the site boundary. Most of these properties are in the settlement of Holt, which is 26m away."
This statement fails to convey the fact that significant numbers of people living in Holt will be affected by the proximity of the site. No figure of actual numbers is given but it would not be unreasonable to estimate a figure in the range of 160 to 240.
3. "The greatest impact will be within 100 metres of a source..."
No number is given here, but in the context of the above statement, it clearly needs to be addressed.

LANDSCAPE: "graded screen bunds would be required on site boundaries... boundary treatments in the form of hedge and woodland planning would improve screening of the site... a standoff area from these properties (would be needed) for the site to be acceptable."
There are a number of properties on different sides of the quarry which require stand off protection, and substantive landscape treatments to properly protect the inhabitants. It is clear that the scale and extent of works needed to the quarry would cause a serious loss of amenity to residents and tourists alike, and would visually impair the open and attractive landscapes of one of the major roads into Holt.

ECOLOGY: There are numerous references to County Wildlife Sites, giving the distance from the site boundary:
CWS 2006 'Spout Common' is 460m from the site boundary.
CWS 2121 'Common Hills Plantation' is 220m from the site boundary.
CWS 1093 'Disused railway' is 500m from the site boundary.
CWS 1098 'Edgefield Heath' is 250m from the site boundary.
There is though, no mention of Holt Country Park, which is a Green Flag award winner and is situated near the site - it is a woodland dominated by Scots pines and native broadleaves, with orchids, a wide variety of butterflies, dragonflies and damselflies and an abundant display of wildlife including goldcrests, greater spotted woodpeckers and deer.

CONCLUSION:
There are significant numbers of residents within a short distance of the site boundaries. Many of them are of retirement age with respiratory and medical complaints which are exacerbated by dust, pollution and contaminants.
in order to mitigate the risk of quarrying to residents in such close proximity, significant landscape and groundworks need to be undertaken, which in themselves risk being intrusive in their own right. The visual impact on nearby dwellings and the disruption to the surrounding landscape would be severe, and it would significantly affect the residents and visiting tourists quiet enjoyment of the surrounding countryside.

I would refer the Planning Department to other sites in their consultation document that they found 'unacceptable' due to the detrimental impact quarrying would have on the landscape and residential properties, and ask that they apply the same policy to MIN 71.

MIN 23 Land North of back Land Beeston "mineral extraction at this site would have unacceptable landscape impacts".
MIN 116 land at Woodrising Road, Cranworth "local landscape impacts would be unacceptable".
MIN 74 land at Turf Field, Watlington Road "Any mineral working on this site would have unacceptable impacts on the landscape".
MIN 32 land west of Lime Kiln Road, West Dereham "Any mineral working on this site would have unacceptable impacts on the landscape."

Object

Initial Consultation document

Representation ID: 91851

Received: 24/07/2018

Respondent: Holt Town Council

Representation Summary:

Holt Town Council strongly objects to this site MIN71.
The Council is concerned that this site is creeping towards the town and is far too close to the market town and also residential dwellings.

Full text:

Holt Town Council strongly objects to this site MIN71.
The Council is concerned that this site is creeping towards the town and is far too close to the market town and also residential dwellings.

Object

Initial Consultation document

Representation ID: 91867

Received: 27/07/2018

Respondent: Mr Paul Jackson

Representation Summary:

It is wholly unacceptable for further ravages of the landscape close to the ancient Market Town of Holt to be under consideration by NCC, the result of which would be only in the interests of commercial profiteers and to the detriment of those of us who have invested heavily in the lifestyle that Holt and District provides in retirement. It is inevitable that there will be air and noise pollution within an indeterminate area according to changes in wind force & direction, and perpetuation and unwelcome increases of heavy commercial traffic in and around Holt and surrounding settlements. Absolutely NO.

Full text:

It is wholly unacceptable for further ravages of the landscape close to the ancient Market Town of Holt to be under consideration by NCC, the result of which would be only in the interests of commercial profiteers and to the detriment of those of us who have invested heavily in the lifestyle that Holt and District provides in retirement. It is inevitable that there will be air and noise pollution within an indeterminate area according to changes in wind force & direction, and perpetuation and unwelcome increases of heavy commercial traffic in and around Holt and surrounding settlements. Absolutely NO.

Object

Initial Consultation document

Representation ID: 91885

Received: 28/07/2018

Respondent: Ms Julie McManus

Representation Summary:

I'm one of the residents living within 20 metres of the proposed site boundary. Noise from the current site 200m away can be heard clearly here. No 'mitigation' would suppress the level of noise we'll suffer. Our dwelling/the proposed site is in an extremely elevated position - winds tend to be stronger here-potential for dust pollution will be significant.
We enjoy a variety of wildlife within our boundary; deer/barn owls/hares/hedgehogs/small mammals.
A Quarry site on main road entering Holt will be an eyesore, ruin the town's image and would have an adverse effect on property prices and businesses.

Full text:

I'm one of the residents living within 20 metres of the proposed site boundary. Noise from the current site 200m away can be heard clearly here. No 'mitigation' would suppress the level of noise we'll suffer. Our dwelling/the proposed site is in an extremely elevated position - winds tend to be stronger here-potential for dust pollution will be significant.
We enjoy a variety of wildlife within our boundary; deer/barn owls/hares/hedgehogs/small mammals.
A Quarry site on main road entering Holt will be an eyesore, ruin the town's image and would have an adverse effect on property prices and businesses.

Object

Initial Consultation document

Representation ID: 91903

Received: 31/07/2018

Respondent: MR David Lowes

Representation Summary:

I disagree that this is a suitable location for sand and gravel extraction. The settlement of Holt is 26m away. This is basically a Quarry in the town.
The proximity to a high number of residential properties is unacceptable. I estimate our property to be 20m from the site boundary.
These properties, regardless of mitigating actions, will be impacted by dust, lorry traffic, noise and a negatively changing landscape.
This site is also in close proximity to Holt Country Park and this seems irrational given it's purpose of providing a peaceful nature experience.

Full text:

I disagree that this is a suitable location for sand and gravel extraction. The settlement of Holt is 26m away. This is basically a Quarry in the town.
The proximity to a high number of residential properties is unacceptable. I estimate our property to be 20m from the site boundary.
These properties, regardless of mitigating actions, will be impacted by dust, lorry traffic, noise and a negatively changing landscape.
This site is also in close proximity to Holt Country Park and this seems irrational given it's purpose of providing a peaceful nature experience.

Object

Initial Consultation document

Representation ID: 91912

Received: 31/07/2018

Respondent: Mr & Mrs J & G Bond

Representation Summary:

We wish to object to the proposed extraction of minerals at Hunworth Road/Norwich road Holt Norfolk. The reasons for the objections are:

1) The noise pollution that will have a detrimental impact on the quality of our lives, both from the operation that would take place on the site and the numerous HGV's servicing the site.
2) The dust that will have a detrimental impact on our health.
3) Increase in traffic on the Norwich Road and Hunworth Road especially leading out to the junction on the Norwich Road.

Full text:

We wish to object to the proposed extraction of minerals at Hunworth Road/Norwich road Holt Norfolk. The reasons for the objections are:

1) The noise pollution that will have a detrimental impact on the quality of our lives, both from the operation that would take place on the site and the numerous HGV's servicing the site.
2) The dust that will have a detrimental impact on our health.
3) Increase in traffic on the Norwich Road and Hunworth Road especially leading out to the junction on the Norwich Road.

Object

Initial Consultation document

Representation ID: 91919

Received: 31/07/2018

Respondent: Mr J Browne

Representation Summary:

I am writing to inform you that I strongly disagree to proposed quarry at Holt MIN 71.

I would like you to respond to the following points please:


1/ How can Carter Concrete can be so sure that Cemex will cease operation in 2030, and why would Carter Concrete seek permission 12 years before Cemex has finished?

Surely, it would be madness for Carter Concrete Ltd to get a planning permission, spend money, develop site, and not be able to operate new quarry, as Cemex are still extracting. Indeed, Cemex could easily apply to extend their operation for 20, 30 or 50 years with the land they have available. Cemex could even "go slow", as it is not really in their interests to have another aggregate competitor. The only opinion I can give is that both companies must be in collusion with one another. If this site is approved, I would not be surprised if Cemex suddenly stopped extracting aggregate from their better located quarry.

With the above in mind, why would the planning department take the risk of granting early permission for a new, closer quarry, when there is an existing quarry with decades of aggregate, most of which can be extracted without impacting the nearby historic Georgian Town of Holt?

2/ How can a site in such close proximity of one of Norfolk's prettiest Georgian towns be considered suitable for allocation for sand and gravel extraction? I was under the impression it was extremely difficult to obtain planning permission for a quarry next to a village, let alone permission next to a historic Georgian market town. I would also like to draw your attention to the prevailing wind direction. You can see from the diagram attached below that all dust and noise will be carried directly over the adjacent Georgian market town of Holt.

3/ I would also like to point out, it will not just be 20-30 plus aggregate lorries a day, it will also be supplemented by 20-30 plus concrete lorries. The clue can be found in the name "Carter Concrete Ltd".

I look forward to your response.

Full text:

I am writing to inform you that I strongly disagree to proposed quarry at Holt MIN 71.

I would like you to respond to the following points please:


1/ How can Carter Concrete can be so sure that Cemex will cease operation in 2030, and why would Carter Concrete seek permission 12 years before Cemex has finished?

Surely, it would be madness for Carter Concrete Ltd to get a planning permission, spend money, develop site, and not be able to operate new quarry, as Cemex are still extracting. Indeed, Cemex could easily apply to extend their operation for 20, 30 or 50 years with the land they have available. Cemex could even "go slow", as it is not really in their interests to have another aggregate competitor. The only opinion I can give is that both companies must be in collusion with one another. If this site is approved, I would not be surprised if Cemex suddenly stopped extracting aggregate from their better located quarry.

With the above in mind, why would the planning department take the risk of granting early permission for a new, closer quarry, when there is an existing quarry with decades of aggregate, most of which can be extracted without impacting the nearby historic Georgian Town of Holt?

2/ How can a site in such close proximity of one of Norfolk's prettiest Georgian towns be considered suitable for allocation for sand and gravel extraction? I was under the impression it was extremely difficult to obtain planning permission for a quarry next to a village, let alone permission next to a historic Georgian market town. I would also like to draw your attention to the prevailing wind direction. You can see from the diagram attached below that all dust and noise will be carried directly over the adjacent Georgian market town of Holt.

3/ I would also like to point out, it will not just be 20-30 plus aggregate lorries a day, it will also be supplemented by 20-30 plus concrete lorries. The clue can be found in the name "Carter Concrete Ltd".

I look forward to your response.

Object

Initial Consultation document

Representation ID: 91970

Received: 07/08/2018

Respondent: Mr John Wollocombe

Representation Summary:

Notwithstanding all of the concerns (and mitigating measures) set out in pages 233 to 236 of the Initial Consultation document, I would wish to object to the development of site MIN 71 for the following reasons:
1. Min 71 is immediately adjacent to the town of Holt. North Norfolk is sparsely populated and there is therefore ample scope for this kind of development to take place on sites where the pollution and disruption caused will affect relatively small numbers of people. I note from a review of the other 40 proposed sites featured in the Consultation document that none of them is adjacent to a town with a population of a size comparable with Holt and to that extent MIN 71 seems out of line with all of the others.
2. The potential for noise and air pollution and general inconvenience for the adjacent population is likely to be exacerbated by the fact that the prevailing winds place Holt downwind of MIN 71. Holt primary school is particularly vulnerable in this regard. The issue of air pollution would be of particular concern if landfill activities were to form part of this site's ultimate restoration.
3. MIN 71 is skirted by the B1149. This is the main road both into and out of Holt to the South. Tourism is fundamental to the economic wellbeing both of Holt and the wider North Norfolk region and this stems from its reputation as a scenic and unspoilt holiday destination. If MIN 71 were to be developed, there would be a risk that every visitor's first and last impression of the town from this direction could be compromised. In terms of local economic activity and employment, tourism exceeds by far the potential benefits associated with a mining development of this type and it would be wrong to allow it to proceed if there was any question that it might negatively impact upon the potential for tourism in the area.
4. There are currently three working mining sites close to the town of Holt, one of which (Gresham's Gravel) has only recently opened. It is not clear form the Consultation document how long these existing local resources are expected to remain on stream. However, unless it can be demonstrated that within the relevant planning period, local supply of sand and gravel from these existing workings is expected to decline, or that local demand is expected to increase, I believe it would seem excessive to consider opening a fourth site in this area, particularly while it remains the case that a large proportion of the sand and gravel currently extracted in Norfolk is consumed outside of the county.
I very much hope the issues I have raised will be taken into consideration in the Preferred Options consultation process.

Full text:

Norfolk Minerals and Waste Local Plan Review: Initial Public Consultation
MIN 71 - Objection
I am writing in response to the letter from Caroline Jeffery of 26th June 2018 concerning the above.
Notwithstanding all of the concerns (and mitigating measures) set out in pages 233 to 236 of the Initial Consultation document, I would wish to object to the development of site MIN 71 for the following reasons:
1. Min 71 is immediately adjacent to the town of Holt. North Norfolk is sparsely populated and there is therefore ample scope for this kind of development to take place on sites where the pollution and disruption caused will affect relatively small numbers of people. I note from a review of the other 40 proposed sites featured in the Consultation document that none of them is adjacent to a town with a population of a size comparable with Holt and to that extent MIN 71 seems out of line with all of the others.
2. The potential for noise and air pollution and general inconvenience for the adjacent population is likely to be exacerbated by the fact that the prevailing winds place Holt downwind of MIN 71. Holt primary school is particularly vulnerable in this regard. The issue of air pollution would be of particular concern if landfill activities were to form part of this site's ultimate restoration.
3. MIN 71 is skirted by the B1149. This is the main road both into and out of Holt to the South. Tourism is fundamental to the economic wellbeing both of Holt and the wider North Norfolk region and this stems from its reputation as a scenic and unspoilt holiday destination. If MIN 71 were to be developed, there would be a risk that every visitor's first and last impression of the town from this direction could be compromised. In terms of local economic activity and employment, tourism exceeds by far the potential benefits associated with a mining development of this type and it would be wrong to allow it to proceed if there was any question that it might negatively impact upon the potential for tourism in the area.
4. There are currently three working mining sites close to the town of Holt, one of which (Gresham's Gravel) has only recently opened. It is not clear form the Consultation document how long these existing local resources are expected to remain on stream. However, unless it can be demonstrated that within the relevant planning period, local supply of sand and gravel from these existing workings is expected to decline, or that local demand is expected to increase, I believe it would seem excessive to consider opening a fourth site in this area, particularly while it remains the case that a large proportion of the sand and gravel currently extracted in Norfolk is consumed outside of the county.
I very much hope the issues I have raised will be taken into consideration in the Preferred Options consultation process.

Comment

Initial Consultation document

Representation ID: 91989

Received: 08/08/2018

Respondent: Mr Chris Chinn

Representation Summary:

The best result is for this site not to be considered at all for many reasons:-
1. It will be much too close to the very beautiful town centre of Holt where tourists visit all year round and make this area, with its obviously wonderful surroundings very popular and benefit the town financially.
2. Just the position of the the Holt country park, which is home to much wild life, being even closer to the proposed quarry shows a total lack of consideration to nature.
3. The potential of an additional 20-30 lorries a day discharging onto the B1149 cannot surely be considered as an acceptable living environment to HUMANS, OR ANIMALS in respect to noise levels and dust, which impacts on clean air to for all, in addition to the dust created by the existing extraction work and noise which is also noticeable from the existing quarry on the Hunworth road. Also the volume and speed of such large vehicles passing through domestic housing and passing Holt primary school cannot be acceptable for any reason, even making money.
4. I am 250 metres away from the boundary having moved here 13 months ago and have accepted the noise of local traffic . Haveing had the wonderful experience of deer in my garden many times and birds of prey flying over the fields, that my bungalow overlooks We are therefore very lucky as you might say and I agree, but this wonderful wildlife may have to move, even if we cannot, because our property will be devalued through no fault of our own.
5. Please explain how this proposition can be justified to make local life even bareable, let alone acceptable for our wellbeing? Can you justify the impact on the health and wellbeing of people living close by?

Full text:

The best result is for this site not to be considered at all for many reasons:-
1. It will be much too close to the very beautiful town centre of Holt where tourists visit all year round and make this area, with its obviously wonderful surroundings very popular and benefit the town financially.
2. Just the position of the the Holt country park, which is home to much wild life, being even closer to the proposed quarry shows a total lack of consideration to nature.
3. The potential of an additional 20-30 lorries a day discharging onto the B1149 cannot surely be considered as an acceptable living environment to HUMANS, OR ANIMALS in respect to noise levels and dust, which impacts on clean air to for all, in addition to the dust created by the existing extraction work and noise which is also noticeable from the existing quarry on the Hunworth road. Also the volume and speed of such large vehicles passing through domestic housing and passing Holt primary school cannot be acceptable for any reason, even making money.
4. I am 250 metres away from the boundary having moved here 13 months ago and have accepted the noise of local traffic . Haveing had the wonderful experience of deer in my garden many times and birds of prey flying over the fields, that my bungalow overlooks We are therefore very lucky as you might say and I agree, but this wonderful wildlife may have to move, even if we cannot, because our property will be devalued through no fault of our own.
5. Please explain how this proposition can be justified to make local life even bareable, let alone acceptable for our wellbeing?

Object

Initial Consultation document

Representation ID: 92001

Received: 08/08/2018

Respondent: Mr A Eke

Representation Summary:

As you know, this potential mineral extraction site. MIN 71, is a serious concern for us and many of our neighbours. We live in The Laurels, which is located on Holt Road (B1149), directly opposite the Hunworth Road (C267) and this proposed site.
I appreciate that you are only carrying out the Initial Public Consultation and that this doesn't grant Norfolk Gravel the right to proceed and that planning consent will be required. However, there are serious issues that both the County Council and District Council should consider before taking this matter any further.
1. Infrastructure / Highways
As you are no doubt aware, traffic congestion in and around the Georgian market town of Holt is often very serious, particularly during the holiday periods when there is an increase in the number of visitors and tourists to the area and the current infrastructure is of concern. The B1149 Holt Road is only-a 'B' road, but it carries 'A' - road traffic being the main route that runs from Norwich, past Holt and on to Fakenham. It is of major concern that there will 30 plus trucks per day using a narrow 'C' road, approaching the dangerous junction at Holt Road. We would appreciate further input from your highways department as to how this junction will be changed to accommodate the increased traffic load on an already very dangerous junction. Presumably, this can be dealt with in a S.106 agreement with the owners, should they be successful with achieving planning consent in due course. Please confirm.
2. Dust
There is no doubt that this potential mineral extraction site will create a dust problem, not only for the immediate local residents and those inhabiting Holt, but it will also affect the young children at Holt Primary School, situated no more than 100 m from this site, and also the children at Gresham's pre-prep and prep schools, whose boundary adjoins the main Cromer Road. We would appreciate a full report on how the dust will affect the location. I note that you have concluded that 'Dust suppression measures will be necessary to ensure that dust deposition does not affect the integrity of Norfolk Valley Fens SAC', but surely it is more important to protect the people that live in the immediate vicinity?
3. Noise impact
I can clearly hear the works and transporters that are using the existing Cemex site daily and it can also be heard by residents in the centre of Holt. The proposed site will be closer to us and to Holt, so the noise impact will increase and be a serious concern.
4. Other matters
I note that you have requested other matters to be resolved and reports completed, as outlined below, and I look forward to receiving copies of these, in addition to the matters raised above.
* Hydrogeological Risk Assessment;
* Standoff /buffer zone plans;
* Confirmation of site restoration;
* A Landscape and Visual Impact Assessment;
* A Heritage Statement;
* An Archaeological Assessment.
I understand that there are already three mineral extraction sites within the immediate vicinity- Cemex (Hunworth Road), Gresham Sand and Gravel (Cromer Road), which is a new quarry, and Norfolk Gravel - Sheringham Quarry- (Britons Lane). There are also sites further south and west. Please could we have an explanation as to why there needs to be further extraction from North Norfolk close to a Georgian town and where the products are sold? Are the minerals extracted for use in the UK or are they exported?
Please take this letter as formal notice of our objection to this land being designated as a potential Mineral Extraction site.

Full text:

Thank you for your letters dated 261h and 301h June 2018.
As you know, this potential mineral extraction site. MIN 71, is a serious concern for us and many of our neighbours. We live in The Laurels, which is located on Holt Road (B1149), directly opposite the Hunworth Road (C267) and this proposed site.
I appreciate that you are only carrying out the Initial Public Consultation and that this doesn't grant Norfolk Gravel the right to proceed and that planning consent will be required. However, there are serious issues that both the County Council and District Council should consider before taking this matter any further.
1. Infrastructure / Highways
As you are no doubt aware, traffic congestion in and around the Georgian market town of Holt is often very serious, particularly during the holiday periods when there is an increase in the number of visitors and tourists to the area and the current infrastructure is of concern. The B1149 Holt Road is only-a 'B' road, but it carries 'A' - road traffic being the main route that runs from Norwich, past Holt and on to Fakenham. It is of major concern that there will 30 plus trucks per day using a narrow 'C' road, approaching the dangerous junction at Holt Road. We would appreciate further input from your highways department as to how this junction will be changed to accommodate the increased traffic load on an already very dangerous junction. Presumably, this can be dealt with in a S.106 agreement with the owners, should they be successful with achieving planning consent in due course. Please confirm.
2. Dust
There is no doubt that this potential mineral extraction site will create a dust problem, not only for the immediate local residents and those inhabiting Holt, but it will also affect the young children at Holt Primary School, situated no more than 100 m from this site, and also the children at Gresham's pre-prep and prep schools, whose boundary adjoins the main Cromer Road. We would appreciate a full report on how the dust will affect the location. I note that you have concluded that 'Dust suppression measures will be necessary to ensure that dust deposition does not affect the integrity of Norfolk Valley Fens SAC', but surely it is more important to protect the people that live in the immediate vicinity?
3. Noise impact
I can clearly hear the works and transporters that are using the existing Cemex site daily and it can also be heard by residents in the centre of Holt. The proposed site will be closer to us and to Holt, so the noise impact will increase and be a serious concern.
4. Other matters
I note that you have requested other matters to be resolved and reports completed, as outlined below, and I look forward to receiving copies of these, in addition to the matters raised above.
* Hydrogeological Risk Assessment;
* Standoff /buffer zone plans;
* Confirmation of site restoration;
* A Landscape and Visual Impact Assessment;
* A Heritage Statement;
* An Archaeological Assessment.
I understand that there are already three mineral extraction sites within the immediate vicinity- Cemex (Hunworth Road), Gresham Sand and Gravel (Cromer Road), which is a new quarry, and Norfolk Gravel - Sheringham Quarry- (Britons Lane). There are also sites further south and west. Please could we have an explanation as to why there needs to be further extraction from North Norfolk close to a Georgian town and where the products are sold? Are the minerals extracted for use in the UK or are they exported?
Please take this letter as formal notice of our objection to this land being designated as a potential Mineral Extraction site. Please confirm receipt of this letter.

Object

Initial Consultation document

Representation ID: 92048

Received: 10/08/2018

Respondent: Mr B Donovan

Representation Summary:

I received a letter explaining proposed site MIN 71. I appreciate the balanced content of it. Agreeing to this change of use from agricultural use to a gravel extraction site raises many concerns, many of which you have mentioned.

My concerns include :
* How often have gravel extraction sites opened in Norfolk so close to a town, indeed to a residential area?
* How often have gravel extraction sites opened in Norfolk so close to protected or sensitive areas?
* How long the working day is, and how many days of the week?
* Will the site need to be flood lit during the shorter days of the week (i.e. winter)
* The plan refers to the time period up to 2036, but how long will this site stay operational?
* The impact on the value of nearby properties from now on (not just when it is operational)
* The impact on the wide range of wildlife in the direct area and surrounding. (insects to plants to birds and mammals)

* I ma trying to understand the local traffic impact...please correct me if I am wrong on the following potential concerns:

 Your link* below suggests that at least 500,000 tonnes could be extracted between 2030 and 2036?
 When full, I understand eight wheeler trucks carry up to 20 tonnes, so that will be a minimum of 500,000/20 = 25,000 journeys over 5 years approximately, i.e. 5,000 journeys per year.
 At 25 loads per day (letter says 20 to 30), that means the trucks will leave site 5000/ 25 = 200 days of the year.
 There are only about 250 working days in each year, so the site will be working maximum at 200/250 , i.e. 80% of the weekdays.
 The truck loads may average 25 times a day, but all trucks will have to go and come back so that doubles the number of times a truck may pass by me daily to 50 times a day. Over an 8 hour day, that a truck nearly every (8 x 60 mins)/ 50 = 9.6 trucks per hour... nearly every 6 minutes.

*(https://www.norfolk.gov.uk/what-we-do-and-how-we-work/policy-performance-and-partnerships/policies-and-strategies/minerals-and-waste-planning-policies/norfolk-minerals-and-waste-local-plan-review )

I can see from the plans and your letter that the following subjects have been noted , but what impact will all these aspects have, and have they been carefully and fairly reviewed:

Issue to Manage: Noise
Effects: General noise emission standards; Noise standards associated with particular types of activities; Standards associated with buffer zones; Timing restrictions on operations; Part of quarry management plan? Use of noise barriers such as earth bunds or acoustic fences; Equipment type and insulation

Issue to manage: Vibration
Effects: General vibration standards; Timing restrictions on operations; Part of quarry management plan?

Issue to manage: Dust and air quality effects
Effects: Performance standards for particulate matter; Assessment criteria to determine dust effects; Best practicable option; Part of quarry management plan?

Issue to manage: Earthworks, stockpiling and overburden
Effects: Part of quarry management plan? (including an earthworks management plan; Assigning council responsibility; Screening and landscaping

Issue to manage: Traffic
Effects: General traffic movement standards; Part of quarry management plan? (which often includes a traffic management plan)

Issue to manage: Water quality and use
Effects: Guidelines; Activity performance standards; Part of quarry management plan?

Issue to manage: Vegetation removal and ecological effects
Effects: Activity performance standards; Offsetting; Quarry and landscape management plan

Issue to manage: Visual effects
Effects: General bulk and location standards; Part of quarry management plan? Progressive restoration and rehabilitation; Use of visual barriers such as earth bunds or solid fences

Issue to manage: Cultural and historic heritage values
Effects: Policies relating to archaeological sites;
Consultation policies and agreements; Cultural impact assessments and cultural value reports; Part of quarry management plan? Avoiding specific sites,

Issue to manage: Rehabilitation
Effects: Part of quarry management plan? Rehabilitation plan

Full text:

I received a letter explaining proposed site MIN 71. I appreciate the balanced content of it. Agreeing to this change of use from agricultural use to a gravel extraction site raises many concerns, many of which you have mentioned.

My concerns include :
* How often have gravel extraction sites opened in Norfolk so close to a town, indeed to a residential area?
* How often have gravel extraction sites opened in Norfolk so close to protected or sensitive areas?
* How long the working day is, and how many days of the week?
* Will the site need to be flood lit during the shorter days of the week (i.e. winter)
* The plan refers to the time period up to 2036, but how long will this site stay operational?
* The impact on the value of nearby properties from now on (not just when it is operational)
* The impact on the wide range of wildlife in the direct area and surrounding. (insects to plants to birds and mammals)

* I ma trying to understand the local traffic impact...please correct me if I am wrong on the following potential concerns:

 Your link* below suggests that at least 500,000 tonnes could be extracted between 2030 and 2036?
 When full, I understand eight wheeler trucks carry up to 20 tonnes, so that will be a minimum of 500,000/20 = 25,000 journeys over 5 years approximately, i.e. 5,000 journeys per year.
 At 25 loads per day (letter says 20 to 30), that means the trucks will leave site 5000/ 25 = 200 days of the year.
 There are only about 250 working days in each year, so the site will be working maximum at 200/250 , i.e. 80% of the weekdays.
 The truck loads may average 25 times a day, but all trucks will have to go and come back so that doubles the number of times a truck may pass by me daily to 50 times a day. Over an 8 hour day, that a truck nearly every (8 x 60 mins)/ 50 = 9.6 trucks per hour... nearly every 6 minutes.

*(https://www.norfolk.gov.uk/what-we-do-and-how-we-work/policy-performance-and-partnerships/policies-and-strategies/minerals-and-waste-planning-policies/norfolk-minerals-and-waste-local-plan-review )

I can see from the plans and your letter that the following subjects have been noted , but what impact will all these aspects have, and have they been carefully and fairly reviewed:

Issue to Manage: Noise
Effects: General noise emission standards; Noise standards associated with particular types of activities; Standards associated with buffer zones;
Timing restrictions on operations; Part of quarry management plan?
Use of noise barriers such as earth bunds or acoustic fences; Equipment type and insulation

Issue to manage: Vibration
Effects: General vibration standards; Timing restrictions on operations; Part of quarry management plan?

Issue to manage: Dust and air quality effects
Effects: Performance standards for particulate matter; Assessment criteria to determine dust effects; Best practicable option; Part of quarry management plan?

Issue to manage: Earthworks, stockpiling and overburden
Effects: Part of quarry management plan? (including an earthworks management plan); Assigning council responsibility; Screening and landscaping

Issue to manage: Traffic
Effects: General traffic movement standards; Part of quarry management plan? (which often includes a traffic management plan)

Issue to manage: Water quality and use
Effects: Guidelines; Activity performance standards; Part of quarry management plan?

Issue to manage: Vegetation removal and ecological effects
Effects: Activity performance standards; Offsetting; Quarry and landscape management plan

Issue to manage: Visual effects
Effects: General bulk and location standards; Part of quarry management plan?
Progressive restoration and rehabilitation; Use of visual barriers such as earth bunds or solid fences

Issue to manage: Cultural and historic heritage values
Effects: Policies relating to archaeological sites; Consultation policies and agreements; Cultural impact assessments and cultural value reports; Part of quarry management plan? Avoiding specific sites,

Issue to manage: Rehabilitation
Effects: Part of quarry management plan? Rehabilitation plan

Thank you for the chance to give feedback

Object

Initial Consultation document

Representation ID: 92049

Received: 10/08/2018

Respondent: Mr N Gray

Representation Summary:

Regarding the above planning application. I live directly opposite the land ear marked for the application. The noise, dust and intrusion this will cause must not go with out saying. My property runs directly along the side of the Norwich road opposite the proposed site and being built back in the 1800's does not have footings. The impact from numerous heavy vehicles pounding down the Norwich road daily and the risk to my property needs serious consideration. From my experience living at this address for over 15 years, is that the wind normally blows from a SW direction, this means any dirt/dust pollution from the site will come straight towards my property, along with all the noise from the site (I have yet to visit a quiet quarry).
The visual impact to the surrounding area will be devastating for Holt residents.

Full text:

Regarding the above planning application. I live directly opposite the land ear marked for the application. The noise, dust and intrusion this will cause must not go with out saying. My property runs directly along the side of the Norwich road opposite the proposed site and being built back in the 1800's does not have footings. The impact from numerous heavy vehicles pounding down the Norwich road daily and the risk to my property needs serious consideration. From my experience living at this address for over 15 years, is that the wind normally blows from a SW direction, this means any dirt/dust pollution from the site will come straight towards my property, along with all the noise from the site (I have yet to visit a quiet quarry).
The visual impact to the surrounding area will be devastating for Holt residents.

Object

Initial Consultation document

Representation ID: 92071

Received: 10/08/2018

Respondent: Mr & Mrs T & D Fell

Representation Summary:

I write in regard to MIN 71 which is land to the west of Norwich Road, Holt. Both my wife and myself disagree with the Planning Officers initial conclusion that the site is suitable for sand and gravel extraction.
We object for the following reasons:
All properties on Norwich Road will be affected by the proximity of the site with noise, dust and not least traffic. There are a number of elderly residents on Norwich Road and we are sure that some of them will suffer from the dust exacerbating any medical conditions they may have.
Winds in the right direction will direct dust and noise over properties other than Norwich Road.
If access to this site is along Candlestick Lane then this will be a traffic hazard has cars ignore the 30 mph speed limit and career around the bend from the direction of Holt Country Park and could easily find a lorry blocking the path. The B1149 is the main artery to and from Norwich and the traffic is heavy and constant with a junction (to Briston) on a bend about 40 metres from Candlestick Lane. This road, at this point, is an accident waiting to happen as it is.
People visit Holt because it is a lovely town. Imagine the visual impact coming from the direction of Norwich. Seeing a bund wall built to hide the site is not a great first impression. This is North Norfolk not the industrial North of England. Other sites that have been found 'unacceptable' are MIN 23, MIN 32, MIN 74 and MIN 116 and we ask that the same is applied to MIN 71.

Full text:

I write in regard to MIN 71 which is land to the west of Norwich Road, Holt. Both my wife and myself disagree with the Planning Officers initial conclusion that the site is suitable for sand and gravel extraction.
We object for the following reasons:
All properties on Norwich Road will be affected by the proximity of the site with noise, dust and not least traffic. There are a number of elderly residents on Norwich Road and we are sure that some of them will suffer from the dust exacerbating any medical conditions they may have.
Winds in the right direction will direct dust and noise over properties other than Norwich Road.
If access to this site is along Candlestick Lane then this will be a traffic hazard has cars ignore the 30 mph speed limit and career around the bend from the direction of Holt Country Park and could easily find a lorry blocking the path. The B1149 is the main artery to and from Norwich and the traffic is heavy and constant with a junction (to Briston) on a bend about 40 metres from Candlestick Lane. This road, at this point, is an accident waiting to happen as it is.
People visit Holt because it is a lovely town. Imagine the visual impact coming from the direction of Norwich. Seeing a bund wall built to hide the site is not a great first impression. This is North Norfolk not the industrial North of England. Other sites that have been found 'unacceptable' are MIN 23, MIN 32, MIN 74 and MIN 116 and we ask that the same is applied to MIN 71.

Object

Initial Consultation document

Representation ID: 92078

Received: 10/08/2018

Respondent: Mr & Ms R & J Hunter & Raven

Representation Summary:

We do not agree with the proposed mineral extraction development at this site.
Our house is less than 100 metres from the site and the main entrance to all 6 barns is directly facing the location.
There would be a great loss of amenity to all the barns as a result of dust, noise and the planned 20 to 30 HGV lorries a day.
At present the main view from the barns is a lovely expanse of hedges and arable fields which would be replaced with an industrial development.

The footpath to the north of the site is a public right of way which is well-used by locals and visitors for country walks and exercising dogs. Users of the path would lose this amenity if it was a gravel extraction site as their peaceful enjoyment of the walk would no longer exist.
We are also concerned about the pond at the entrance to Lodge Farm Barns which is a habitat to many frogs, toads and hedgehogs as well as insects such as dragonflies.
The dust would impact this habitat and water levels could also be affected.
Birds and bats nest in the buildings and would be impacted by noise and dust.

We are also concerned at the likely adverse impact on all local wildlife in the Holt Lowes SSSI, the Glaven Valley Conservation Area and the Norfolk Valley Fens SAC.

There would be a negative effect on the heritage character of Holt itself, as visitors
approaching from the Norwich direction would regard the town as an industrial rather than a conservation area. It could well reduce visitor numbers to Holt and
as a result income to local cafes and shops. Local small businesses are already
struggling and depend on the unique Georgian appearance and atmosphere of the
town to attract tourists.

The high number of HGV lorries would increase the hazards on this road. The sharp bend where the Norwich Road meets Hunworth Road is already a difficult junction with traffic approaching at speed , despite the 30 mph sign. It is currently risky for residents of Lodge Farm Barns to emerge by car towards Holt as there is a blind corner and this would be made more dangerous with many large lorries moving in and out of the proposed site.

Full text:

Ref. Consultation MIN71 Land west of Norwich Road , Holt.
We do not agree with the proposed mineral extraction development at this site.
Our house is less than 100 metres from the site and the main entrance to all 6
barns is directly facing the location.
There would be a great loss of amenity to all the barns as a result of dust, noise
and the planned 20 to 30 HGV lorries a day.
At present the main view from the barns is a lovely expanse of hedges and arable fields which would be replaced with an industrial development.

The footpath to the north of the site is a public right of way which is well-used by locals and visitors for country walks and exercising dogs. Users of the path would lose this amenity if it was a gravel extraction site as their peaceful enjoyment of the walk would no longer exist.
We are also concerned about the pond at the entrance to Lodge Farm Barns which is a habitat to many frogs, toads and hedgehogs as well as insects such as dragonflies.
The dust would impact this habitat and water levels could also be affected.
Birds and bats nest in the buildings and would be impacted by noise and dust.

We are also concerned at the likely adverse impact on all local wildlife in the Holt Lowes SSSI , the Glaven Valley Conservation Area and the Norfolk Valley Fens SAC.

There would be a negative effect on the heritage character of Holt itself, as visitors
approaching from the Norwich direction would regard the town as an industrial rather than a conservation area. It could well reduce visitor numbers to Holt and
as a result income to local cafes and shops. Local small businesses are already
struggling and depend on the unique Georgian appearance and atmosphere of the
town to attract tourists.

The high number of HGV lorries would increase the hazards on this road. The sharp bend where the Norwich Road meets Hunworth Road is already a difficult junction with traffic approaching at speed , despite the 30 mph sign. It is currently risky for residents of Lodge Farm Barns to emerge by car towards Holt as there is a blind corner and this would be made more dangerous with many large lorries moving in and out of the proposed site.

Comment

Initial Consultation document

Representation ID: 92159

Received: 13/08/2018

Respondent: Natural England

Representation Summary:

Likely significant effect, Please refer to our comments on Habitats Regulations Assessment in our letter of 13 August 2018.

Annex 1: Natural England's comments on the Draft Habitats Regulations Assessment of the M&WLPR, dated May 2018

A recent judgment from the Court of Justice of the European Union (Case C-323/17 People Over Wind v Coillte Teoranta) has provided authoritative interpretation relating to the use of mitigation measures at the screening stage of a Habitats Regulations Assessment (HRA). The judgment concluded that it is not appropriate, at the screening stage, to take account of measures intended to avoid or reduce the harmful effects of the plan or project on a European site. However, when determining whether the plan or project will have an adverse effect on the integrity of the European site at appropriate assessment, a competent authority may take account of those avoidance and mitigation measures.
The Local Planning Authority, as competent authority for the Minerals and Waste Local Plan, should consider this judgment when undertaking the HRA screening under the Conservation of Habitats and Species Regulations 2017 and may wish to take its own legal advice on the implications of the judgment.
This means that for any sites where avoidance and mitigation measures have been identified to protect designated Natura 2000 sites such as Special Areas of Conservation (SACs), Special Areas of Protection (SPAs) or Ramsar sites, the sites should not be screened out for likely significant effect but carried forward to Appropriate Assessment, at which point any mitigation measures, eg not de-watering, conditions to control dust or lighting etc, can be assessed in detail and taken into account.
Our specific comments on various individual allocations included in the initial consultation are intended to reflect this ruling. That is, where measures have been identified specifically to protect a Natura 2000 site, then these allocations should be screened in to Appropriate Assessment. At this stage the effectiveness of any proposed avoidance and mitigation measures and all the evidence should be examined to reach a conclusion of likely significant effect, either alone or in combination with other plans or projects, and to ascertain whether an adverse effect on the integrity of the site can be ruled out.
Note that any proposal which may affect a Natura 2000 designated site must go through a project level HRA in addition to this strategic plan-level HRA. This should be identified for each relevant allocation and reflected in the policy wording, including what avoidance and mitigation measures would be necessary. This can be at a 'high' level, e.g. work would take place outside the bird breeding season to avoid disturbance to nesting birds. However, more detail would be expected in the HRA at planning application stage.
The future conclusions and recommendations of the HRA will need to be incorporated into later revisions of the Sustainability Appraisal (SA) report, and be reflected in the allocations and policies of the M&WLPR.

Full text:

Likely significant effect, Please refer to our comments on Habitats Regulations Assessment in our letter of 13 August 2018.

Object

Initial Consultation document

Representation ID: 92162

Received: 14/08/2018

Respondent: Mr G Chapman

Representation Summary:

I am writing with my objections to this proposed new quarry which would be situated so close to Holt. I am surprised that the County Council planning officers are even contemplating this site.

As I understand it there are "82 sensitive receptors" (approx. 250people) live within 250 metres of the site, and an undisclosed number within 100 metres. My property is adjacent to the proposed site. We already have a new sand and quarry site at Sheringham, so I feel there is no need for this proposed site. You must consider the noise and dust pollution being so close to Holt. This is completely unacceptable to have this industrial site nearly in Holt and so close to residential properties.

Full text:

I am writing with my objections to this proposed new quarry which would be situated so close to Holt. I am surprised that the County Council planning officers are even contemplating this site.

As I understand it there are "82 sensitive receptors" (approx. 250people) live within 250 metres of the site, and an undisclosed number within 100 metres. My property is adjacent to the proposed site. We already have a new sand and quarry site at Sheringham, so I feel there is no need for this proposed site. You must consider the noise and dust pollution being so close to Holt. This is completely unacceptable to have this industrial site nearly in Holt and so close to residential properties.

Object

Initial Consultation document

Representation ID: 92191

Received: 15/08/2018

Respondent: Holt Town Council

Representation Summary:

Holt Town Council have already made a comment via the web page but feel we need to put in further comment to express our very real concerns as follows:-
* This site is encroaching nearer to Holt with the nearest property only 10M away.
* This will result in noise, dirt and dust and be unacceptable to the properties near to the site and to the town that depends on a tourist economy.
* We have concern that this bigger site will unduly affect the water table
* There will be a significant increase in heavy HGVs traffic
* With the vulnerable Glaven river and Spouts Common in very close proximity, we are concerned about the negative effect on this sites.
* The access to this site is very poor and dangerous with the potential to be an accident hot spot.

Full text:

Holt Town Council have already made a comment via the web page but feel we need to put in further comment to express our very real concerns as follows:-
* This site is encroaching nearer to Holt with the nearest property only 10M away.
* This will result in noise, dirt and dust and be unacceptable to the properties near to the site and to the town that depends on a tourist economy.
* We have concern that this bigger site will unduly affect the water table
* There will be a significant increase in heavy HGVs traffic
* With the vulnerable Glaven river and Spouts Common in very close proximity, we are concerned about the negative effect on this sites.
* The access to this site is very poor and dangerous with the potential to be an accident hot spot.

Support

Initial Consultation document

Representation ID: 92362

Received: 13/08/2018

Respondent: D K Symes Associates

Representation Summary:

The identification of MIN 71 is supported.

Full text:

I set out below my comments on the above document based on the Questions. I have only commented on a limited number of questions.

Question 7
It is recognised that Policy MW4 relates to both minerals and waste. Regarding the use of renewable energy there is more potential for waste developments than for mineral. In practice, mineral developments have extremely limited opportunities to use 'site specific' renewable energy sources (e.g. solar, panels, wind turbines, gas generation, etc.) and this needs to be recognised. Further, the choice of energy provider may already have a percentage generated by renewable and this should be given weight in meeting this policy.

It is noted that the 'practicality' of meeting this element of the policy allows a degree of flexibility, however it would be helpful if the text could recognise that the opportunities for renewable are noticeably more constrained for mineral developments.

As a final note, Policy MW2 does not refer to demonstrating that 'renewable' energy use is a development management criteria, suggesting that Policy MW4 should have greater flexibility.

Question 8
It would be helpful to clarify that 'mineral extraction' (including associated plant) is not classed as 'built development' (so does not fall to be considered under Policy MW5).

Question 30
The encouragement for agricultural reservoirs is supported as this reflects the policy guidance from the EA. For clarity, it should be made clear that 'proven need' is for the reservoir, not the mineral extracted.

Question 75
Agree with initial conclusion.

Comment:
The recognition that this site when developed as an extension to Briton's Lane Quarry, will offer considerably improved restoration to create heathland habitat with a range of micro-scale biodiversity is supported. In addition, the development offers the opportunity to increase the geological interest by providing additional exposed sections of the Briton's Lane Formation.

The suggested requirement for the road junction with the A148 to be upgraded is noted. Advice from Highway Consultants is that the number of turning movements generated by the development is below the guidance level to justify a full right hand turn lane. However, site measurements of the road indicate that with limited widening sufficient additional 'road' width can be secured that will avoid through traffic being held up by the occasional turning lorry. This suggestion does not result in a 'full' standard right turn lane, but will achieve the same objective. It would be helpful if the comments were less specific by referring to road improvements at the A148 / Briton's Lane junction to allow some flexibility.

Question 76
The identification of MIN 71 is supported.

Question 78
The identification of MIN 207 is supported.

I trust these comments are of interest and I would be grateful for confirmation of receipt.

Comment

Initial Consultation document

Representation ID: 92388

Received: 29/08/2018

Respondent: Norfolk Wildlife Trust

Representation Summary:

Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 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.

Full text:

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: Whilst we are unable to comment on the wider impacts of this proposal as they are outside of our remit, should this site be progressed, then we strongly support the Council's recommendations that this site should be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.

Comment

Initial Consultation document

Representation ID: 92563

Received: 08/08/2018

Respondent: Environment Agency

Representation Summary:

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 71 Proximity to Holt Lows SSSI and potential impact on groundwater dependant habitat.

Full text:

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.

Object

Initial Consultation document

Representation ID: 92911

Received: 09/08/2018

Respondent: Mr R Carter

Representation Summary:

Site MIN 71 - land west of Norwich Road, Holt. Question 76
I would ask that these comments be read in conjunction with my previous submission. I object to the initial conclusion that MIN 71 is a suitable site for the extraction of sand and gravel on the grounds that the Planning Authority is unable to demonstrate a need for extra resources of sand and gravel aggregates in Norfolk.

Supply/Demand
The apportionment targets set as Norfolk's share of the sub-national guideline figures have been missed by very wide margins every year for the last 20 years (averaging only 51.2% of apportionment in the last 10 years).

Market forces have shown that demand levels are significantly lower than the supply apportionment levels, and that Core Strategy Policy CS1 supply figures need to be severely downgraded in line with demand.

"Neighbouring Minerals Planning Authorities plan to supply the demand in their own areas, by allocating sites, and therefore Norfolk doe not need to make planned provision to supply additional aggregates".(1)

"Norfolk is a net importer of sand and gravel" (1)

Norfolk quarries have supplied "90% of local consumption" whilst exporting between 30%-50% of production. (1)

Norfolk should not be subsidising exported aggregates (reduced transport costs) for the benefit of surrounding Mineral Planning Authorities and Companies at the cost of the Norfolk Countryside and amenity of local residents.

"Norfolk, due to its geology, has considerable sand and gravel resources", consequently, there are minimal short or medium term supply risks if demand does increase - however, there is a significant risk to the countryside, the tourism industry, residents and existing agricultural if unsuitable and unwarranted sites are opened.

Methodology
"The MPA does not think it prudent... to base allocation purely on a rolling average of 10 years sales as having regarding to paragraph 14 of the NPPF, flexibility is required in allocations". (1) Instead, however, the MPA chose to base its allocation on a 20 year rolling average against the following guidance:
- Guidelines from the NPPF in March 2012 para 145 state that "MPAs... determine their own levels of aggregate production based on a rolling average of 10 years sales data..."
Guidance from the NPPG requires that LAAs should provide:
"a forecast of the demand for aggregates based on both the rolling average of ten-year sales data and local information"
It also stated that "The rolling average of 10 years sales data will inform the targets for mineral extraction data" (1)
All these guidelines unequivocally call for the 10 year rolling average to be the basis to consider supply forecasts, and any variant of this would need to be justified by compelling reasons.

The MPA has chosen to double the length of the recommended time-base against this advise, and to use a 20 year average, leading to the following supply differences -
- based on a 20 year rolling average 1.98 million tpa would be needed.
- based on a 10 year rolling average 1.41 million tpa would be needed
The difference over a 20 year plan is some 11.4 million tonnes at 570,000 tonnes a year - this clearly stretches the meaning of the phrase 'flexible' beyond any reasonable interpretation.

Conclusion
The clear evidence is that existing supply levels of aggregates are significantly greater than demand exhibited by market forces in Norfolk, and any new policies/calculations should address this significant imbalance.

(1) figures/narrative quoted are from - 'Norfolk Minerals and Waste Local Plan: Monitoring report - Mineral data Local Aggregate Assessment and Silica Sand Assessment 2016 (published October 2017)

Full text:

Site MIN 71 - land west of Norwich Road, Holt. Question 76
I would ask that these comments be read in conjunction with my previous submission. I object to the initial conclusion that MIN 71 is a suitable site for the extraction of sand and gravel on the grounds that the Planning Authority is unable to demonstrate a need for extra resources of sand and gravel aggregates in Norfolk.

Supply/Demand
The apportionment targets set as Norfolk's share of the sub-national guideline figures have been missed by very wide margins every year for the last 20 years (averaging only 51.2% of apportionment in the last 10 years).

Market forces have shown that demand levels are significantly lower than the supply apportionment levels, and that Core Strategy Policy CS1 supply figures need to be severely downgraded in line with demand.

"Neighbouring Minerals Planning Authorities plan to supply the demand in their own areas, by allocating sites, and therefore Norfolk does not need to make planned provision to supply additional aggregates".(1)

"Norfolk is a net importer of sand and gravel" (1)

Norfolk quarries have supplied "90% of local consumption" whilst exporting between 30%-50% of production. (1)

Norfolk should not be subsidising exported aggregates (reduced transport costs) for the benefit of surrounding Mineral Planning Authorities and Companies at the cost of the Norfolk Countryside and amenity of local residents.

"Norfolk, due to its geology, has considerable sand and gravel resources", consequently, there are minimal short or medium term supply risks if demand does increase - however, there is a significant risk to the countryside, the tourism industry, residents and existing agricultural if unsuitable and unwarranted sites are opened.

Methodology
"The MPA does not think it prudent... to base allocation purely on a rolling average of 10 years sales as having regarding to paragraph 14 of the NPPF, flexibility is required in allocations". (1) Instead, however, the MPA chose to base its allocation on a 20 year rolling average against the following guidance:
- Guidelines from the NPPF in March 2012 para 145 state that "MPAs... determine their own levels of aggregate production based on a rolling average of 10 years sales data..."
Guidance from the NPPG requires that LAAs should provide:
"a forecast of the demand for aggregates based on both the rolling average of ten-year sales data and local information"
It also stated that "The rolling average of 10 years sales data will inform the targets for mineral extraction data" (1)
All these guidelines unequivocally call for the 10 year rolling average to be the basis to consider supply forecasts, and any variant of this would need to be justified by compelling reasons.

The MPA has chosen to double the length of the recommended time-base against this advise, and to use a 20 year average, leading to the following supply differences -
- based on a 20 year rolling average 1.98 million tpa would be needed.
- based on a 10 year rolling average 1.41 million tpa would be needed
The difference over a 20 year plan is some 11.4 million tonnes at 570,000 tonnes a year - this clearly stretches the meaning of the phrase 'flexible' beyond any reasonable interpretation.

Conclusion
The clear evidence is that existing supply levels of aggregates are significantly greater than demand exhibited by market forces in Norfolk, and any new policies/calculations should address this significant imbalance.

(1) figures/narrative quoted are from - 'Norfolk Minerals and Waste Local Plan: Monitoring report - Mineral data Local Aggregate Assessment and Silica Sand Assessment 2016 (published October 2017)

Object

Initial Consultation document

Representation ID: 92913

Received: 09/08/2018

Respondent: Mr R Carter

Number of people: 113

Representation Summary:

Petition relating to MIN 71 Proposed sand and gravel quarry in Holt
We the undersigned object to a sand and gravel quarry being sites on the Holt boundary at Norwich Road. We wish to object on the grounds of:
1. Proximity to Holt 26m, closest residents 11m, 200 residents within 250m.
2. Inappropriate infrastructure - heavy lorries congesting B roads and key junctions
3. Damage to environment -landscape and wildlife impact to the Glaven Valley Conservation area.
4. Adverse dust and noise - residential and school impacted due to prevailing wind direction
5. Detrimental to tourism - negative image impact on main road into the Georgian town of Holt.

Petition signed by 113 local residents.

Full text:

Petition relating to MIN 71 Proposed sand and gravel quarry in Holt
We the undersigned object to a sand and gravel quarry being sites on the Holt boundary at Norwich Road. We wish to object on the grounds of:
1. Proximity to Holt 26m, closest residents 11m, 200 residents within 250m.
2. Inappropriate infrastructure - heavy lorries congesting B roads and key junctions
3. Damage to environment -landscape and wildlife impact to the Glaven Valley Conservation area.
4. Adverse dust and noise - residential and school impacted due to prevailing wind direction
5. Detrimental to tourism - negative image impact on main road into the Georgian town of Holt.

Petition signed by 113 local residents.

Comment

Initial Consultation document

Representation ID: 92984

Received: 31/08/2018

Respondent: Historic England

Representation Summary:

No comment

Full text:

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

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

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

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

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

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

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

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

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

Comment

Initial Consultation document

Representation ID: 93099

Received: 21/08/2018

Respondent: Norfolk County Council - Natural Environment Team

Representation Summary:

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

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Comment

Initial Consultation document

Representation ID: 93144

Received: 30/07/2018

Respondent: Norfolk County Council - Highway Authority

Representation Summary:

The Highway Authority considers the site is acceptable subject to the use of the existing access and continued routing arrangements.

Comment

Initial Consultation document

Representation ID: 93195

Received: 16/08/2018

Respondent: Norfolk County Council Historic Environment Service

Representation Summary:

We agree with the initial conclusion for this site.