Question 74: Proposed site SIL 02 (land at Shouldham and Marham)

I am a keen ornithologist and bird ringer for the British trust of ornithology. I have monitor, reported on and watched birds all over the world and ring birds at Marham little fen.
it is with total horror that i see there are plans in place to extract sand and gravel from this area.
The area around Button fen and around the back of the warren has had breeding Lapwing, Yellowhammer, Linnet and Grey partridge on this year. All these birds are on the RED list of the RSPB birds of concern. They are struggling enough with yet more land being turn into a dust bowl of quarries.

Reed Bunting, Mute Swan, Little Grebe, Black headed Gull all nest around here to and are on the amber list of British birds of concern.

I was born in Marham in 1963 and have watched the destruction of the little fen over the years as they drained it and lost a fantastic habitat for Marsh Harrier, Reed warbler and other species.

The amount of noise dust and disturbance is intolerable and the proposed plans as to what they replace it with is utterly useless for birds. Deep sided lakes no good for swans or waders they do this to prevent encouraging birds down because of the bird strike threat to RAF Marham. So you dig up a fantastic habitat and replace with something utterly useless for the species that use to use it.

I now live in leziate near to the silica quarry. I can not imaging the traffic using these small roads to ferry sand back to leziate its bad enough on the A roads.

THIS PROPOSED PLAN HAS TO BE STOPPED.

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.

In our opinion the plan is fit for purpose. We have a few comments/ recommendations regarding the plan as follows:

SIL 02 Land at Shouldham and Marham
This site is located adjacent to the River Narr SSSI, we would advise no extraction takes place outside of the 'reduced development area' between the proposed site and River Narr SSSI to reduce the likelihood of impacts on the River Narr SSSI and its qualifying features.
We agree that an assessment of potential impacts on the River Narr SSSI and Marham Fen, including from dust deposition and hydrogeology, together with appropriate mitigation would be required as part of any planning application.
It should be noted in the 'initial conclusion' that an ecological assessment to determine baseline conditions on the site must be prepared which may lead to the need for further surveys and mitigation measures, if necessary. (This should always be the case with 'greenfield sites'. I know this was mentioned in the wider document, however it would be good if this could be included in the 'initial conclusions' for new sites). It would also be useful in the initial conclusions to ensure it is clear that a restoration scheme to protect and enhance biodiversity will be put in place post extraction.

MIN45 land North of Coxford Quarry and MIN 77 Runs Wood Tottenhill
We are in agreement with the conclusions that the sites are unsuitable for allocation in accordance with Section 15 of the NPPF.

MIN40 land east of Grandcourt Farm, East Winch
We agree with the Arboricultural officers comments for land east of Grandcourt Farm. It should also be noted that if avoidance measures are not possible and these veteran trees are removed, an assessment of the value of these trees for wildlife in particular bats and nesting birds must be undertaken prior to any works on these trees.

Search: AOS E land to the North of Shouldham and MIN115 Lord Anson's Wood near North Walsham
Woodland is located within the allocated area for these sites. These woodland areas are of ecological value and likely support protected species and other wildlife. We would like to see woodland areas retained where possible. Where woodland areas are proposed for removal then an ecological assessment needs to be undertaken and any further surveys need to be carried out or mitigation proposed, if necessary.

MIN 92 Land east of Ferry Lane, Heckingham
We agree with the Arboricultural officers comments that this site is unsuitable for allocation.

I wish to lodge my objection to the proposed site SIL 02 as a preferred area for silica sand extraction.

I understand the need to provide a future source of silica sand, however, I feel that this development will have a disproportionate and devastating impact on a rural community, already affected by a rapidly expanding RAF airbase of strategic national importance.

I would also like to note that the proposal put forward by Sibelco is an optimistic 'best case scenario' which downplays the negative impact on the residents' wellbeing, our community, and the environment, especially considering the massive size of this site and the timescales involved in the development.

I would also like to point out that the process has not adhered to the principles laid out in Norfolk County Council's own 'Statement of Community Involvement'. Residents were completely unaware of these plans, they were not notified of the consultation and had only a few days to prepare a response ahead of the deadline.

In particular, my objection is based on the following grounds:

Health / Safety & Environment
a) Unacceptable increase in Noise, Dust and Light pollution as a direct result of the proposed extraction is in violation of local residents' rights as per European Convention on Human Rights, specifically Article 2 (right of life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 ( respect for one's private and family life, home and correspondence ), and Protocol 1 (right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents.
b) Prolonged exposure to Silica dust present significant risk to vulnerable members of the community, particularly the elderly and young, given the village demographics.
c) No information has been provided regarding the impact of mineral extraction on local water supply/quality.
d) No restriction on site working hours is proposed.
e) This is the only proposal within Norfolk M&WLP that is in a high-risk flood area. Flood risks are further exacerbated by the removal of ancient drainage ditches.

Economic.
a) No proposed economic benefit for the villages of Marham or Shouldham.
b) No additional job creation.
c) Reduction in house values.
d) Potential impact on home insurance due to increased flood risk.
e) Reduction in tourism and visitors to the Nar Valley Way.
f) Creation of trapped residents unable to move due to the inevitable slowing of the housing market.

Local Infrastructure
a) Existing road infrastructure is unsuitable for HGV and plant access. Precedence has been established by RAF Marham who are prohibited from using village roads for access purposes.
b) Local trunk roads will be negatively affected by increased traffic (A47 & A10 ).
c) No proposal for Sibelco's preferred option for above ground pipelines between proposed site and their current site at Leziate taking into account natural and transport barriers.

Ecology
a) Destruction of habitat of endangered wildlife species including:
a1) Voles, Newts, scarce Emerald Damselfly, Mayfly, Moths including the Grizzled Skipper, Dingy Skipper.
a2) Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet, Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge.
b) Dust deposition relating to the River Nar - a designated SSSI and Core River Valley.
d) No proposal as to how the Core River Valley will be enhanced following mineral extraction.
e) Detrimental impact on ecology and biodiversity on nearby Country Wildlife Sites.
f) No restoration plan proposed for the entire site, which suggests there is no intention to remedy the harm caused, fears exacerbated by the very poor and dangerous condition of other Sibelco sites, such as Bawsey and Leziate.

Landscape
a) Marham village enjoys an elevated position relative to the proposed site, with beautiful long-reaching views across the fen landscape.
a1) Bunds or screening will be ineffective and intrusive in their own right.
a1) Proposed works will be visually detrimental and out of character with the local landscape.
b) Prevailing North and North West winds will aggravate noise and dust pollution concerns and impact on health.
c) Irreplaceable loss of agricultural land.
d) Destruction of ancient footpaths and relocation of rights of way (further than the stipulated 100m permitted) contained both within and adjacent to the proposed site, which are extensively used by local residents, schools and tourists.
e) Detrimental impact on the open nature of the landscape and to the setting of the scheduled monuments Pentney Priory Gatehouse and other heritage assets.
f) No assurances have been received regarding the possibility of the site being used for Landfill in the future.

Archaeology
a) This area is potentially very rich in archaeological finds, from Pre-Historic to Roman to Medieval and any undiscovered sites would be destroyed permanently by the project.
b) Close proximity to Pentney Priory Gatehouse and the unexplored Cistercian Nunnery in Marham.

In conclusion, nothing in this proposal addresses residents' concerns about the devastating impact the development will have on our community, quality of life, health and wellbeing for decades to come. No assurances have been given that the site will not be abandoned as industrial wasteland with zero potential for leisure or ecological benefit.

If you require any clarification of the points raised, we would be happy to discuss the matter further.

I wish to lodge my objection to the proposed site SIL 02 as a preferred area for silica sand extraction.

I understand the need to provide a future source of silica sand, however, I feel that this development will have a disproportionate and devastating impact on a rural community, already affected by a rapidly expanding RAF airbase of strategic national importance.

I would also like to note that the proposal put forward by Sibelco is an optimistic 'best case scenario' which downplays the negative impact on the residents' wellbeing, our community, and the environment, especially considering the massive size of this site and the timescales involved in the development.

I would also like to point out that the process has not adhered to the principles laid out in Norfolk County Council's own 'Statement of Community Involvement'. Residents were completely unaware of these plans, they were not notified of the consultation and had only a few days to prepare a response ahead of the deadline.

In particular, my objection is based on the following grounds:

Health / Safety & Environment
a) Unacceptable increase in Noise, Dust and Light pollution as a direct result of the proposed extraction is in violation of local residents' rights as per European Convention on Human Rights, specifically Article 2 (right of life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 ( respect for one's private and family life, home and correspondence ), and Protocol 1 (right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents.
b) Prolonged exposure to Silica dust present significant risk to vulnerable members of the community, particularly the elderly and young, given the village demographics.
c) No information has been provided regarding the impact of mineral extraction on local water supply/quality.
d) No restriction on site working hours is proposed.
e) This is the only proposal within Norfolk M&WLP that is in a high-risk flood area. Flood risks are further exacerbated by the removal of ancient drainage ditches.

Economic.
a) No proposed economic benefit for the villages of Marham or Shouldham.
b) No additional job creation.
c) Reduction in house values.
d) Potential impact on home insurance due to increased flood risk.
e) Reduction in tourism and visitors to the Nar Valley Way.
f) Creation of trapped residents unable to move due to the inevitable slowing of the housing market.

Local Infrastructure
a) Existing road infrastructure is unsuitable for HGV and plant access. Precedence has been established by RAF Marham who are prohibited from using village roads for access purposes.
b) Local trunk roads will be negatively affected by increased traffic (A47 & A10 ).
c) No proposal for Sibelco's preferred option for above ground pipelines between proposed site and their current site at Leziate taking into account natural and transport barriers.

Ecology
a) Destruction of habitat of endangered wildlife species including:
a1) Voles, Newts, scarce Emerald Damselfly, Mayfly, Moths including the Grizzled Skipper, Dingy Skipper.
a2) Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet, Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge.
b) Dust deposition relating to the River Nar - a designated SSSI and Core River Valley.
d) No proposal as to how the Core River Valley will be enhanced following mineral extraction.
e) Detrimental impact on ecology and biodiversity on nearby Country Wildlife Sites.
f) No restoration plan proposed for the entire site, which suggests there is no intention to remedy the harm caused, fears exacerbated by the very poor and dangerous condition of other Sibelco sites, such as Bawsey and Leziate.

Landscape
a) Marham village enjoys an elevated position relative to the proposed site, with beautiful long-reaching views across the fen landscape.
a1) Bunds or screening will be ineffective and intrusive in their own right.
a1) Proposed works will be visually detrimental and out of character with the local landscape.
b) Prevailing North and North West winds will aggravate noise and dust pollution concerns and impact on health.
c) Irreplaceable loss of agricultural land.
d) Destruction of ancient footpaths and relocation of rights of way (further than the stipulated 100m permitted) contained both within and adjacent to the proposed site, which are extensively used by local residents, schools and tourists.
e) Detrimental impact on the open nature of the landscape and to the setting of the scheduled monuments Pentney Priory Gatehouse and other heritage assets.
f) No assurances have been received regarding the possibility of the site being used for Landfill in the future.

Archaeology
a) This area is potentially very rich in archaeological finds, from Pre-Historic to Roman to Medieval and any undiscovered sites would be destroyed permanently by the project.
b) Close proximity to Pentney Priory Gatehouse and the unexplored Cistercian Nunnery in Marham.

In conclusion, nothing in this proposal addresses residents' concerns about the devastating impact the development will have on our community, quality of life, health and wellbeing for decades to come. No assurances have been given that the site will not be abandoned as industrial wasteland with zero potential for leisure or ecological benefit.

If you require any clarification of the points raised, we would be happy to discuss the matter further.

I wish to lodge my objection to the proposed site SIL 02 as a preferred area for silica sand extraction.

I understand the need to provide a future source of silica sand, however, I feel that this development will have a disproportionate and devastating impact on a rural community, already affected by a rapidly expanding RAF airbase of strategic national importance.

I would also like to note that the proposal put forward by Sibelco is an optimistic 'best case scenario' which downplays the negative impact on the residents' wellbeing, our community, and the environment, especially considering the massive size of this site and the timescales involved in the development.

I would also like to point out that the process has not adhered to the principles laid out in Norfolk County Council's own 'Statement of Community Involvement'. Residents were completely unaware of these plans, they were not notified of the consultation and had only a few days to prepare a response ahead of the deadline.

In particular, my objection is based on the following grounds:

Health / Safety & Environment
a) Unacceptable increase in Noise, Dust and Light pollution as a direct result of the proposed extraction is in violation of local residents' rights as per European Convention on Human Rights, specifically Article 2 (right of life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 ( respect for one's private and family life, home and correspondence ), and Protocol 1 (right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents.
b) Prolonged exposure to Silica dust present significant risk to vulnerable members of the community, particularly the elderly and young, given the village demographics.
c) No information has been provided regarding the impact of mineral extraction on local water supply/quality.
d) No restriction on site working hours is proposed.
e) This is the only proposal within Norfolk M&WLP that is in a high-risk flood area. Flood risks are further exacerbated by the removal of ancient drainage ditches.

Economic.
a) No proposed economic benefit for the villages of Marham or Shouldham.
b) No additional job creation.
c) Reduction in house values.
d) Potential impact on home insurance due to increased flood risk.
e) Reduction in tourism and visitors to the Nar Valley Way.
f) Creation of trapped residents unable to move due to the inevitable slowing of the housing market.

Local Infrastructure
a) Existing road infrastructure is unsuitable for HGV and plant access. Precedence has been established by RAF Marham who are prohibited from using village roads for access purposes.
b) Local trunk roads will be negatively affected by increased traffic (A47 & A10 ).
c) No proposal for Sibelco's preferred option for above ground pipelines between proposed site and their current site at Leziate taking into account natural and transport barriers.

Ecology
a) Destruction of habitat of endangered wildlife species including:
a1) Voles, Newts, scarce Emerald Damselfly, Mayfly, Moths including the Grizzled Skipper, Dingy Skipper.
a2) Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet, Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge.
b) Dust deposition relating to the River Nar - a designated SSSI and Core River Valley.
d) No proposal as to how the Core River Valley will be enhanced following mineral extraction.
e) Detrimental impact on ecology and biodiversity on nearby Country Wildlife Sites.
f) No restoration plan proposed for the entire site, which suggests there is no intention to remedy the harm caused, fears exacerbated by the very poor and dangerous condition of other Sibelco sites, such as Bawsey and Leziate.

Landscape
a) Marham village enjoys an elevated position relative to the proposed site, with beautiful long-reaching views across the fen landscape.
a1) Bunds or screening will be ineffective and intrusive in their own right.
a1) Proposed works will be visually detrimental and out of character with the local landscape.
b) Prevailing North and North West winds will aggravate noise and dust pollution concerns and impact on health.
c) Irreplaceable loss of agricultural land.
d) Destruction of ancient footpaths and relocation of rights of way (further than the stipulated 100m permitted) contained both within and adjacent to the proposed site, which are extensively used by local residents, schools and tourists.
e) Detrimental impact on the open nature of the landscape and to the setting of the scheduled monuments Pentney Priory Gatehouse and other heritage assets.
f) No assurances have been received regarding the possibility of the site being used for Landfill in the future.

Archaeology
a) This area is potentially very rich in archaeological finds, from Pre-Historic to Roman to Medieval and any undiscovered sites would be destroyed permanently by the project.
b) Close proximity to Pentney Priory Gatehouse and the unexplored Cistercian Nunnery in Marham.

In conclusion, nothing in this proposal addresses residents' concerns about the devastating impact the development will have on our community, quality of life, health and wellbeing for decades to come. No assurances have been given that the site will not be abandoned as industrial wasteland with zero potential for leisure or ecological benefit.

If you require any clarification of the points raised, we would be happy to discuss the matter further.

I wish to lodge my objection to the proposed site SIL 02 as a preferred area for silica sand extraction.

I understand the need to provide a future source of silica sand, however, I feel that this development will have a disproportionate and devastating impact on a rural community, already affected by a rapidly expanding RAF airbase of strategic national importance.

I would also like to note that the proposal put forward by Sibelco is an optimistic 'best case scenario' which downplays the negative impact on the residents' wellbeing, our community, and the environment, especially considering the massive size of this site and the timescales involved in the development.

I would also like to point out that the process has not adhered to the principles laid out in Norfolk County Council's own 'Statement of Community Involvement'. Residents were completely unaware of these plans, they were not notified of the consultation and had only a few days to prepare a response ahead of the deadline.

In particular, my objection is based on the following grounds:

Health / Safety & Environment
a) Unacceptable increase in Noise, Dust and Light pollution as a direct result of the proposed extraction is in violation of local residents' rights as per European Convention on Human Rights, specifically Article 2 (right of life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 ( respect for one's private and family life, home and correspondence ), and Protocol 1 (right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents.
b) Prolonged exposure to Silica dust present significant risk to vulnerable members of the community, particularly the elderly and young, given the village demographics.
c) No information has been provided regarding the impact of mineral extraction on local water supply/quality.
d) No restriction on site working hours is proposed.
e) This is the only proposal within Norfolk M&WLP that is in a high-risk flood area. Flood risks are further exacerbated by the removal of ancient drainage ditches.

Economic.
a) No proposed economic benefit for the villages of Marham or Shouldham.
b) No additional job creation.
c) Reduction in house values.
d) Potential impact on home insurance due to increased flood risk.
e) Reduction in tourism and visitors to the Nar Valley Way.
f) Creation of trapped residents unable to move due to the inevitable slowing of the housing market.

Local Infrastructure
a) Existing road infrastructure is unsuitable for HGV and plant access. Precedence has been established by RAF Marham who are prohibited from using village roads for access purposes.
b) Local trunk roads will be negatively affected by increased traffic (A47 & A10 ).
c) No proposal for Sibelco's preferred option for above ground pipelines between proposed site and their current site at Leziate taking into account natural and transport barriers.

Ecology
a) Destruction of habitat of endangered wildlife species including:
a1) Voles, Newts, scarce Emerald Damselfly, Mayfly, Moths including the Grizzled Skipper, Dingy Skipper.
a2) Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet, Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge.
b) Dust deposition relating to the River Nar - a designated SSSI and Core River Valley.
d) No proposal as to how the Core River Valley will be enhanced following mineral extraction.
e) Detrimental impact on ecology and biodiversity on nearby Country Wildlife Sites.
f) No restoration plan proposed for the entire site, which suggests there is no intention to remedy the harm caused, fears exacerbated by the very poor and dangerous condition of other Sibelco sites, such as Bawsey and Leziate.

Landscape
a) Marham village enjoys an elevated position relative to the proposed site, with beautiful long-reaching views across the fen landscape.
a1) Bunds or screening will be ineffective and intrusive in their own right.
a1) Proposed works will be visually detrimental and out of character with the local landscape.
b) Prevailing North and North West winds will aggravate noise and dust pollution concerns and impact on health.
c) Irreplaceable loss of agricultural land.
d) Destruction of ancient footpaths and relocation of rights of way (further than the stipulated 100m permitted) contained both within and adjacent to the proposed site, which are extensively used by local residents, schools and tourists.
e) Detrimental impact on the open nature of the landscape and to the setting of the scheduled monuments Pentney Priory Gatehouse and other heritage assets.
f) No assurances have been received regarding the possibility of the site being used for Landfill in the future.

Archaeology
a) This area is potentially very rich in archaeological finds, from Pre-Historic to Roman to Medieval and any undiscovered sites would be destroyed permanently by the project.
b) Close proximity to Pentney Priory Gatehouse and the unexplored Cistercian Nunnery in Marham.

In conclusion, nothing in this proposal addresses residents' concerns about the devastating impact the development will have on our community, quality of life, health and wellbeing for decades to come. No assurances have been given that the site will not be abandoned as industrial wasteland with zero potential for leisure or ecological benefit.

If you require any clarification of the points raised, we would be happy to discuss the matter further.

The MOD previously commented on the Norfolk Minerals and Waste Local Plan in August 2018. However, based on safeguarding comments regarding birdstrike, the policy team submitted additional information to determine the viability of the proposed sites.
The sites identified as part of the Norfolk Minerals and Waste Local Plan occupy the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The MODs main concern regarding mineral schemes is the phased working, proposed restoration and aftercare of the site. As the creation of open water bodies in this area has the potential to increase birdstrike risk to aircraft operations.
Please note each planning application is assessed on their individual merits at present there is limited information for a full detailed assessment to be carried out. However, please see below the MODs comments based on the additional
information received on the 18/11/18:

MIN 19 & 205 Land north of the River Nar, Pentney
The site is approximately 6km north west of RAF Marham. The restoration plan for this site shows a series of lakes, which are deep and steep sided surrounded by wet woodland with reed fringes. The design also includes 2 proposed walkways consisting of grassy glades which lie above water level.
Therefore, the MOD would have no safeguarding concerns subject to open water being kept to a minimum; the lakes are designed to be less than 200mx200m with steep bank sides as per restoration plan. A robust Bird Hazard Management Plan (BHMP) to be approved by the MOD should be applied to manage the hazardous birds i.e. waterfowl, gulls, heron etc. and applied to the adjacent site if owned by the same company.

MIN 76 Land at West Field, Watlington Road, Tottenhill
The MOD have recently reviewed this planning consultation and submitted conditional response citing subject to a BHMP being implemented we have no safeguarding concerns as part of planning consent.

MIN 40 - Land East of Grandcourt Farm, East Winch
The MOD commented on this application and the proposed extension to Grandcourt Farm at planning stages. There is an existing BMP in place which includes the extension site. Therefore, the MOD stated no objection subject to the BMP being implemented as part of planning consent.

SIL 01 Land at Mintlyn South, Bawsey
This site is approximately 12.4km north by north west from RAF Marham, any proposed water bodies would need to be designed to the following principles:
 No islands- as they provide safe predator free environment for roosting and nesting birds
 The bank margins are planted with dense goose proof barrier of emergent vegetation (common reed), or fenced to prevent easy access between open water and nearby short grass areas.
 A BHMP to remove or treat any feral goose nests and eggs to prevent feral geese successfully breeding on site
The above is based on the information available at present.

SIL 02 Land at Shouldham and Marham
This site is approximately 4.8km north west from RAF Marham. The proposed extraction site is a considerable area which is planned to be restored with large areas of open water.
A development of this nature in such proximity to the aerodrome is of great concern to aircraft safety.
Even if the site were to be reduced in scale this would be of serious concern to the MOD. Therefore, we would object to this site based on current plans.

AOS E Land north of Shouldham
It is difficult to determine the risk of wet restoration in this location without any plans illustrating the extent and design of open water bodies.
The MOD have safeguarding concerns to the wet working and restoration of this site due to its potential to attract and support hazardous waterfowl closer within critical airspace. Therefore, further information would be required before a definitive response can be made.

AOS J Land east of Tottenhill
In line with my comments above wet working and restoration at this location would have the potential to attract and support hazardous waterfowl. The MOD is unable to determine the extent of our concerns without knowing the restoration scheme.

In summary, MIN 19, 205, 76 & 40 the MOD has no safeguarding concerns subject to the implementation of a robust Bird Hazard Management Plan approved by the MOD as part of any planning permission granted.

With regards to SIL 01 at present this site is of concern to the MOD. However, due
to its location depending on the nature and scale of the restoration should be manageable with the right restoration and a BHMP in place.

AOS E and AOS J the MOD has concerns and would require further information to determine whether the sites could be managed with design principles and a BMP.
Finally, SIL 02 the MOD object to this site being implemented on its current design and scale.

I trust this is clear however should you have any questions please do not hesitate to contact me.