Question 59: Proposed site MIN 45

We are writing on behalf of mineral operator Longwater Gravel Company Ltd. in relation to site MIN 45 and in response to the consultation on the Norfolk Minerals and Waste Local Plan Review "Initial Consultation" in summer 2018.

As you will be aware, the Council has come to the initial conclusion that the site is considered to be unsuitable for allocation because:
* It is considered unlikely that a proposal largely on an ancient woodland site, for the extraction of sand and gravel, would meet the benefit/loss test set out in the NPPF.
* It has not been proved that soil translocation would have no detrimental effects to the quality of the PAWS, or that this would aid the proposal in meeting the benefit/loss test. Natural England in 2012 stated that "ancient woodland as a system cannot be moved", and the Joint Nature Conservation Committee states that the uncertainty of habitat translocation means that it should be viewed only as a measure of last resort in partial compensation for damaging developments."

Proposed Policy MW 2 states that:
"Proposals for minerals development and/or waste management development will be permitted where it can be demonstrated that the development would not have an unacceptable impact (including cumulative impact in combination with other existing or permitted development) on:
... k. The natural and geological environment (including internationally, nationally or locally designated sites and irreplaceable habitats);
... Where appropriate, enhancement of the environment would be sought, including, but not exclusively, the enhancement of the Public Rights of Way Network, creation of recreation opportunities and enhancement of the natural, historic and built environment and surrounding landscapes."

The supporting text to Policy MW 2 states further that:
"Minerals or waste management development which impacts on Sites of Special Scientific Interest, National Nature Reserves and irreplaceable priority habitats such as ancient woodland and aged or veteran trees will only be permitted where the impact does not conflict with the wildlife or geological conservation interests of that asset."

The proposal for MIN 45 is compliant with this proposed policy. Although the site encompasses an area of a planted ancient woodland site (PAWS), in accordance with Policy MW 2 the proposal will not conflict with the wildlife or geological conservation interest of the ancient woodland asset. Furthermore, the proposed minerals development will lead to an overall environmental enhancement. These aspects of compliance of the proposal to extract sand and gravel from site MIN 45 are explained in more detail throughout this representation.

Since the publication of the consultation document, the NPPF has been revised and the Council will be aware that it continues to provide protection to ancient woodland and veteran trees as an "irreplaceable habitat" unless there are wholly exceptional reasons and a suitable compensation strategy can be agreed (Paragraph 175c). We believe 'wholly exceptional circumstances' exist in this particular case and that a suitable compensation strategy can be agreed. Paragraph 205 of the revised NPPF supports this and requires that "great weight" is given to the benefits of minerals extraction.

Firstly, as the Council will be aware, MIN 45 consists predominantly of a conifer plantation planted in the late 1960s/early 1970s, which has likely undergone at least two conifer rotations. This is significant in terms of the ecological value of the area. A survey of flora completed by Norfolk Wildlife Services shows very little flora associated with ancient woodland and it is thought that over 100 years of coniferous cover on the site is the reason for this. MIN 45 currently exists solely for providing lumber on a commercial basis, not for providing biodiversity value. Most, if not all, of the existing trees within MIN 45 will eventually be cut down, regardless of any proposals for minerals extraction, and will likely be replaced with more conifers, thus limiting the long-term habitat potential of this site.

It is worth noting that site MIN 115 shares the same characteristics as MIN 45 in that they are both conifer plantations, although MIN 115 has not been designated as a plantation on ancient woodland site. MIN 115 has been found suitable for allocation, despite providing the same habitat as MIN 45.

It is also worth pointing out that the revised National Planning Policy Framework (July 2018) definition of "irreplaceable habitat" is:
"Habitats which would be technically very difficult (or take a very significant time) to restore, recreate or replace once destroyed, taking into account their age, uniqueness, species diversity or rarity. They include ancient woodland, ancient and veteran trees, blanket bog, limestone pavement, sand dunes, salt marsh and lowland fen."

Ancient woodland designations are based on historic mapping which indicates whether the site has been continuously wooded, not on the quality of the habitat at the time of designation. In this respect, it is not a biodiversity designation.

The relatively young commercial plantation woodland at MIN 45 should not be considered an irreplaceable habitat in the context of Paragraph 175c of the NPPF, as all of the trees lost during the minerals extraction process (the vast majority of which are conifers) will be replaced with native species broadleaved trees. As the site measures around 22 hectares, this will result in a massive gain in terms of biodiversity and landscape. Therefore, with reference to the definition of irreplaceable habitat, the site would not "be technically very difficult to restore, recreate or replace" and therefore should not be considered an irreplaceable habitat.

Mineral extraction is temporary and cannot be compared to other developments which would lead to the permanent loss of ancient woodland such as buildings, roads, etc. constructed on ancient woodland sites. If the final stage of a mineral extraction development is to replant the woodland, using the same soils in exactly the same location, then arguably there is no loss. The restoration of MIN 45, which will be to replant the woodland with native broadleaved trees will provide a significantly improved habitat for local biodiversity. Whilst there may be some adverse effects in the short-term in terms of habitat loss during the extraction of the minerals, the proposal and its restoration plan will provide a long-term benefit to biodiversity.

In this particular case, the circumstances of the proposal are wholly exceptional and the restoration of the site to a native, high-quality broadleaved woodland habitat should be considered a long-term public benefit when coupled with the economic benefits of the minerals extraction, which would more than adequately replace and compensate for the loss of a low-quality conifer woodland habitat.

In addition to the biodiversity benefit, MIN 45 also offers the following environmental, social and economic benefits:
* Existing minerals site extension, operated by a reputable local minerals operator
* Suitable existing highways access
* Retention of jobs at this facility for an additional 7 years
* Well-located to facilitate growth in Fakenham, an area designed for significant growth in the West Norfolk Local Plan
* Remote from settlements and housing, limiting amenity impacts such as noise, dust and vibration
* Not in an area of flood risk
* No impact on water resources
* No impact on landscape designations, such as AONB, Heritage Coast, National Parks or Core River Valleys
* No impacts likely on any international, national or locally designated nature conservation sites, such as Ramsar, SPA, SAC, SSSI, NNR, LNR, CGS or CWS
* No impacts likely on any designated or known non-designated heritage assets, including Listed Buildings, Scheduled Monuments, Historic Parks or Conservation Areas
* This site is not within or near to an AQMA
* Restoration proposal would act as a carbon sink, absorbing CO2 emissions

Therefore, we urge you to reconsider the Council's initial conclusion that MIN 45 is unsuitable for allocation, as the single short-term impact of the loss of a relatively poor-quality habitat needs to be sensibly balanced against (and will be outweighed by) the numerous benefits the site would provide in environmental, social and economic terms.

We write to inform you that Longwater Gravel disagrees with the initial conclusion in respect of MIN 45 and would urge Norfolk County Council to reconsider its proposal not to allocate the north extension at Coxford Abbey Quarry. Norfolk County Council's adopted Minerals Site Specific Allocations Development Plan Document (Minerals SSA DPD), currently allocates the remaining minerals in the central area of Coxford Abbey Quarry, along with two extension areas to the east and south along with the north extension which is proposed to be removed. Longwater Gravel remains committed to extraction from the north extension with restoration to native woodland as it was understood that Norfolk County Council, by virtue of the allocation in the adopted Minerals SSA DPD and from informal discussion with planning officers in April 2015, that when the timing was right, i.e. when the permitted reserves at Coxford Abbey Quarry were almost exhausted, a planning application could then be submitted.

You will remember that during the Minerals SSA DPD consultation period (2008-2012), Longwater Gravel was preparing a planning application for the same area as that which is currently allocated along with an additional extension area to the west. Initial consultation drafts of the Minerals SSA DPD published in October 2009, May 2011 and February 2012 indicated that the plantation on ancient woodland site in the north extension would be included in the allocation, however in late 2012 and following advice from Norfolk County Council's ecological and landscape officers, changes were made to policy MIN 45 which ostensibly removed the north extension from the allocation. Fearing that the inclusion of the north extension in the planning application would result in a refusal of planning permission, Longwater Gravel took the decision to delete the north extension and submitted a planning application which only included the central area, along with extensions to the east, west and south.

You will also remember that during the independent examination of the Minerals SSA DPD held in March 2013, the Planning Inspector, Mr Andrew Freeman BSc (Hons) DipTP DipEM FRTPI FIHT MIEnvSc, directed Norfolk County Council to include the north extension within policy MIN 45. Unfortunately by this time the planning application for Coxford Abbey Quarry had already been submitted and it was now too late to withdraw and revise it to include the north extension. Shortly after planning permission was granted in March 2014, discussion with Norfolk County Council development control officers about the situation led to the formal submission of a request for a screening/scoping opinion for mineral extraction from the north extension, the aim being to resolve the situation by applying for planning permission for the area which had been deleted. The screening/scoping opinion was received in July 2014, NCC reference PP/C/2/2014/2007, and Longwater Gravel commenced work on the development of the application, closely following the requirements of the now adopted Policy MIN 45. At a meeting in April 2015, Longwater Gravel was advised by Norfolk County Council planning officers not to submit the application for planning permission for the north extension as it would likely result in a refusal, due to the fact that sufficient minerals were now permitted at Coxford Abbey Quarry and other sites in Norfolk and also because it was considered unlikely that the north extension could be worked within the adopted Minerals SSA DPD period (2010-2026). Longwater Gravel duly accepted and followed this advice and the planning application for the north extension was not submitted. It has therefore come as an unwelcome surprise that having reached an understanding with planning officers about the timing of an application, Norfolk County Council are now proposing to remove MIN 45 from the Minerals and Waste Sites Development Plan.

Whilst the presence of the PAWS is acknowledged, Longwater Gravel would not insist that Norfolk County Council allocate MIN 45 if the woodland was deemed to be of significant ecological or historic importance or indeed if it was an established native broadleaved woodland. It should be noted that a substantial proven sand and gravel reserve actually lies immediately to the north of the proposed MIN 45 extraction area, the majority of which is outside of the area designated as a PAWS, but as this already contains a number of mature broadleaved trees, Longwater Gravel's development proposals for MIN 45 do not include this area for mineral extraction, but do include the progressive restoration of this area by the thinning/selective felling of the conifers and additional replanting of native broadleaved woodland species trees in an effort to restore Coxford Wood.

As part of developing the application for planning permission for the north extension, a number of habitat studies have already been undertaken, all in accordance with the requirements of bullet point 1 of the adopted Policy MIN 45, i.e. 'a survey to identify any features, including soils, that remain of the ancient woodland and protection/mitigation for any features identified'. These include studies to identify the presence of flora and fauna associated with ancient woodland, e.g. bluebells, fungi, remnant tree stumps, veteran trees, etc. along with soil sampling, testing and soil germination trials. Sadly, all of these habitat studies noted a complete absence of any definitive ancient woodland indicators in the PAWS at MIN 45. Accepting that the only remaining feature of the ancient woodland is the soil, protection and mitigation, in the form of careful translocation will be proposed. The phased extraction and restoration of MIN 45 can be designed so that soils from the woodland areas can be directly placed without the need for the soil to be stored in bunds. The open arable field in the west (phase 1) would be worked and restored first with the soil from this area being placed into a soil storage bund in the main quarry. As this phase is completed, the block of woodland in the southwest, i.e. phase 2, would be felled and the soils carefully translocated onto the restored surface in phase 1. As extraction progresses, the process would be repeated until the final phase where the soils stored in the main quarry would be used to complete the restoration. Longwater Gravel plans to trial turve cutting/lifting equipment, similar to that used in heathland translocation, in order to minimise soil disturbance. Consultant ecologists will be employed to evaluate and monitor the recovery of the translocated soils, the findings from which will inform and recommend any changes in translocation technique which may be necessary. New planting will be sourced from local stock to maintain provenance and a maintenance scheme to regularly remove invasive weeds will also be implemented.

As the sand and gravel landbank for Norfolk remains well above 7 years and there are sufficient permitted reserves at Coxford Abbey Quarry to meet demand for the foreseeable future, clearly the timing for submitting a planning application for the north extension remains some way off. However, at some point before 2036, the landbank will reduce as Coxford Abbey Quarry and other sites exhaust their reserves, therefore, the proposal for an extension at an already established quarry which delivers a significant quantity of minerals for the county's needs along with a commitment to restoring Coxford Wood to a native broadleaved woodland might then be acceptable. If MIN 45 is removed from the Mineral and Waste Local Plan, then proposals for the north extension cannot even be submitted for consideration.

Longwater Gravel fully accepts that the NPPF 2018 does indeed preclude developments which lead to the loss of ancient woodland 'unless there are wholly exceptional reasons and a suitable compensation strategy exists'. However, the NPPF 2018 does give 'great weight' to minerals, recognising that they can only be worked where they are found and that they are necessary to provide the infrastructure that society needs. We would also argue that that mineral extraction is not a development which leads to the loss of irreplaceable habitats. In most if not all cases, restored mineral extraction sites create multiple benefits to biodiversity and there are numerous precedents where mineral extraction has been granted planning permission which leads to the loss of a PAWS. Hermitage Quarry in Kent and Brickworth Quarry in Wiltshire are two notable examples. In both cases, the operator has proposed large scale replanting of woodland to restore the quarry, which will create irreplaceable habitat in the long term. It is therefore not unique for Norfolk County Council to allocate and consider an application for mineral extraction from a PAWS.

Finally, I have asked both Small Fish Consulting and SLR Consulting, both of which have been involved with the development of the planning application for the north extension to submit additional responses arguing in support of the allocation of MIN 45.

We hope that Norfolk County Council will reverse its proposal not to allocate MIN 45.

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.

The Woodland Trust is the largest woodland conservation charity in the UK and a leading voice in bringing to the attention of government, land owners and the general public the state of the UK's trees and woodland. We champion and deliver the most dynamic solutions to protect and revitalise our natural environment - the recreation of wooded landscapes on a national scale.
We campaign to ensure that laws governing environmental protection are enforced and that the government is held to account on environmental pledges. We also campaign vigorously with the support of local communities, to prevent any further destruction of ancient woods.
And, to further protect the UK's natural environment, we've built up an estate of our own managed woodland covering over 73 square miles across the UK, of which a third is irreplaceable ancient woodland. With a supporter base of half a million we were the first, and remain the most significant contributor to woodland protection, restoration and creation in the UK. We are experts in a natural resource that has the potential to transform the UK's natural environment and ensure its continued
survival.
Ancient woodland, veteran and ancient trees
Ancient woodland, veteran and ancient trees are irreplaceable natural resources. Ancient Woodland is land that has remained constantly wooded since AD1600. The length at which ancient woodland takes to develop and evolve (centuries, even millennia), coupled with the vital links it creates between plants, animals and soils accentuate its irreplaceable status. The varied and unique habitats ancient woodland sites provide for many of the UK's most important and threatened fauna and flora species cannot be re-created and cannot afford to be lost.
Ancient and veteran trees are especially important for wildlife. Along with their historical or cultural significance, our ancient trees are loved by communities because of their special appearance, the rare fungi, plants and animals they support and the stories associated with them. Ancient and veteran trees can be classified due to the presence of ancient and veteran features.
As such, the Woodland Trust aims to prevent the damage, fragmentation and loss of these finite irreplaceable habitats from any form of disruptive development. Approximately one quarter of priority UK BAP species are associated with woodland habitats. Forests, woods, and trees make a significant contribution to biodiversity, and ancient sites are recognised as being of particular value.
Due to their longevity, ancient woodlands are more species rich, and are often refuges for specialist woodland species that struggle to colonise new areas.

National Policy
The recently revised NPPF states:
175. When determining planning applications, local planning authorities should apply the following principles:
c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists; and

Footnote 58 elaborates: For example, infrastructure projects (including nationally significant infrastructure projects, orders under the Transport and Works Act and hybrid bills), where the public benefit would clearly outweigh the loss or deterioration of habitat.

Policy Specific Comments
We welcome the recognition of the importance of ancient woodland, aged and veteran trees for both biodiversity and landscape as set out in pages 27 and 28. However we would like to flag the revised wording set out in the NPPF, the term 'aged' has been replaced with 'ancient as this is seen to better align with the practical interpretation of the NPPF.
The Woodland Trust warmly welcomes Norfolk's proposed approach (set out on page 67) to Areas of Search for silica sand extraction; the 250m exclusion zone for dust is a best practice approach. As such we strongly support Policy MP2: Spatial Strategy for mineral extraction.

Sites
The following sites have be found to affect ancient woodland, ancient and veteran trees.

MIN 45 - land north of Coxford Abbey Quarry (south of Fakenham Road), East Rudham. Proposed for mineral extraction. Contains Coxford Wood which is a Plantation on Ancient Woodland Site (PAWS). Size of affected woodland 23.73 ha. Grid reference TF82315566.

MIN 38 - land East of Fritton marshes. Proposed for mineral extraction. Contain veteran beech. Grid reference TG46390076.

MIN 202 - land south of Reepham Road, Attlebridge. Proposed for mineral extraction. Mileplain Plantation, which is a Plantation on Ancient Woodland Site (PAWS) and is adjacent to the site boundary. Size of affected woodland 19.8 Ha. Grid reference TG14163195

AOS J - Land to the east of Tottenhill. Proposed for an area of search for mineral extraction. Two veteran oaks to the east of Craven Lane. Grid reference TF65105491


MIN 45
We strongly support the Council's initial conclusion that the site should not be taken forward due to the presence of ancient woodland.

MIN 38
Again the Trust supports the Council's position not to allocate the site but would like to add the presence of a veteran beech tree (as noted on the Ancient Tree Inventory) as a further reason not to take this site forward.

MIN 202
We welcome the recognition of Mileplain Plantation, which is a Plantation on Ancient Woodland Site (PAWS) adjacent to the site boundary. Planning authorities and inspectors increasingly act to prevent the direct destruction of ancient woodland. However, the damage and impacts posed to ancient woods by nearby development are not so widely appreciated. The Trust opposes MIN 202 in its current form due to the potential impact on ancient woodland. Any future application should be subject to a substantial planted buffer of 50m to ensure the integrity of the ancient woodland.

AOS J
We would like to highlight the presence of two veteran oaks to the east of Craven Lane which are listed on the Ancient Tree Inventory but are not listed within the constraints for AOS J. These trees must be listed as a constraint. In the event of any application coming forward these veteran trees should be subject Policy MP2.

LAND NORTH OF COXFORD ABBEY QUARRY, SOUTH OF FAKENHAM ROAD (EAST RUDHAM): POTENTIAL ECOLOGICAL IMPACTS OF EXTENDING QUARRY INTO CONIFER PLANTATION DESIGNATED AS PAWS

BACKGROUND
Norfolk County Council Minerals and Waste Local Plan Initial Consultation May 2018 concludes that the above site is unsuitable for allocation because it is largely on an area of Plantation on Ancient Woodland Site (PAWS).

Longwater Gravel Co. Ltd instructed SLR Consulting Ltd to provide a short factual report reviewing SLRs ecological work to date at the site, and briefly considering the ecological impacts of extending Coxford Abbey Quarry ("the Quarry") into the area of coniferous plantation, designated PAWS.

This letter report has been prepared by Jess Colebrook CEnv, MCIEEM and draws upon field survey reports and literature review undertaken by SLR in 2013 to inform the Ecological Impact Assessment process undertaken in respect of quarry extension.

DESCRIPTION OF PAWS AT COXFORD ABBEY QUARRY
A block of 20.6ha of woodland identified1 as Plantation on Ancient Woodland Site (PAWS) occurs at the north of the quarry, and is known as Coxford Wood.
The term Ancient Woodland is applied to sites in England and Wales whose documented history shows them to have been continuously wooded since approximately 1600, and which are by extension considered likely to have been continuously wooded since the last Ice Age. Research on the Coxford Wood site history includes Faden's map of Norfolk published in 1797 and 19th century
tithe and enclosure maps which show woodland boundaries that correspond closely to the area designated as PAWS. The First series OS Plan dated around 1880 shows the PAWS area with new plantation to the east north east and south. It is interesting to note that the detailed cartography of the time shows the PAWS area with a significant proportion of conifers. These cannot be the trees currently in place as these date from the late 1960's to the early 70s, so it seems the PAWS area has seen at least two conifer rotations.

The majority of Coxford Wood is now plantation woodland dominated by Scot's pine Pinus sylvestris with Douglas fir Pseudotsuga menziesii, oak Quercus robur, beech Fagus sylvatica, silver birch Betula pendula, sweet chestnut Castanea sativa and rowan Sorbus aucuparia recorded. The proportion of conifers in the canopy is high throughout the woodland and typically exceeds 90%. Woodland understory is typically sparse throughout the wood and species lists from all field surveys conducted in Coxford Wood have been reviewed for records of Ancient Woodland Indictor (AWI) species in East England (Rose, 2006; as cited by Rotherham, 2011) for flora associated with ancient woodland sites.

Only three AWI species have been recorded from the site: climbing corydalis Ceratocapnos claviculata; holly Ilex aquilifolium and rowan Sorbus aucuparia. This is a very low number of AWI species for an ancient woodland site and indicates that the woodland's past management, anecdotally reported to have included two rotations of conifers, has clearly had an adverse effect upon the biodiversity value of the woodland habitat present.

Coxford Wood, including PAWS, is considered to be of Parish Value. It is unlikely to meet CWS guidelines for woodland habitats5 as it is currently in poor condition due to dominance by coniferous species and as a result of two conifer rotations reducing ground flora richness.

POTENTIAL IMPACTS OF QUARRY EXTENSION INTO PAWS
Do nothing scenario:
Commercial forestry is typically managed on a 30-60 year rotation, and therefore it is highly likely that the current tree crop including the PAWS, would be felled and replanted at some point in next 20-30 years. The felling and replanting of forest, would further disrupt the soils in ancient woodland areas, but may be an opportunity to replace mixed and coniferous stands with native broadleaves.
However, the landowner is likely to wish to maximise commercial land values and therefore another conifer rotation is more likely than a switch to lower yielding broadleaves in the absence of other drivers.

Habitat Loss, Fragmentation and Isolation due to land take
Due to its management in the last century, the biodiversity value of PAWS in Coxford Wood is considered to rest within its soils. Field surveys of the PAWS woodland have not identified any specific features indicative of ancient woodland, such as ancient or veteran trees or a diverse flora of
AWI species. In the absence of any mitigation, it is predicted that the permanent loss of soil resource
from the majority of the PAWS as a result of quarry extension would be considered an adverse
impact significant at a Parish level.
It is proposed that top-soils from the PAWS would be stripped in a phased manner and direct placed onto pre-prepared restored areas in advance of replanting with broadleaved trees which would be managed to recreate Coxford Wood, in accordance with an agreed Woodland Management Plan.
This approach to phased development, restoration and long-term management would give the best opportunity to maintain any seed bank and functional soil micro-organisms within the translocated soils and for the restored woodland habitats to maximise their biodiversity potential. A review of literature and guidance on the translocation of ancient woodlands and their soils was undertaken by SLR in 2013 (Unpublished report, refer to Appendix 1 of this report for a full list of key sources) provides evidence that this approach to compensation for the loss of the PAWS habitat has a high chance of successfully maintaining the residual value of the soils and restoring a native woodland to replace the non-native plantation currently present.
With these measures in place and the implementation of a woodland management plan, the residual effects upon woodland habitats, including PAWS, are not considered significant.

Restoration Scheme
Proposed mineral extraction on the site would provide a catalyst for the transformation of a commercial, mainly conifer woodland to native broadleaved woodland over the restoration period.
The process of PAWS soil translocation and the commitment to the long-term management of woodland habitats would produce substantial gains in terms of biodiversity value in the long-term and is considered to provide a net positive impact for biodiversity that is significant at a Parish level.

Residual Impact
In this instance, the PAWS at Coxford Abbey Quarry is considered to be of low biodiversity value and its loss to quarrying and the restoration of the site to a native woodland is not considered to be significant in biodiversity terms when compared to the predicted baseline and "do nothing" scenario.

CONCLUSION
The proposed development would lead to the predicted loss of Plantation on Ancient Woodland Site as identified on the Ancient Woodland Inventory. In biodiversity terms, PAWS at Coxford Abbey Quarry is considered to be of low biodiversity value and its loss to quarrying and the restoration of the site to a native woodland is considered not significant when compared to the "do nothing" scenario.
The ecological assessment has identified no residual impacts of habitat loss and fragmentation upon woodland or other habitats of ecological value. Long-term management commitments and restoration of woodland areas would ensure that adverse effects upon important receptors are minimised. The proposed restoration and 20-year management plan is considered to generate net biodiversity gains at a local level in comparison to the predicted baseline.
CLOSURE
This report has been prepared by SLR Consulting Limited with all reasonable skill, care and diligence, and taking account of the manpower and resources devoted to it by agreement with the client.
Information reported herein is based on the interpretation of data collected and has been accepted in good faith as being accurate and valid. SLR disclaims any responsibility to the client and others in respect of any matters outside the agreed scope of the work.

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.

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

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

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

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

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

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

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

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

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

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

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

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

Allocated Sites with Groundwater Protection Constraints

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

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

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

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

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

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

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

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

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

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

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

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

Allocated Sites with Flood Risk Constraints

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

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

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

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

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

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

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

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

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

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

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

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

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

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.

Overall the Norfolk Minerals and Waste Local Plan is a very thorough and accurate document. My only comments are that trees have been considered under the headings of landscape or ecology throughout the document, rather than under a separate arboriculture heading. Having said this, I am happy for the document to remain as it is.

However as far as I can see, no reference has been made with regards to Arboricultural Impact Assessments (AIA) in the initial conclusions. I feel that where hedgerow trees or woodlands are adjacent to a proposed site that the offset from them needs to be determined at the very least by an annotated Tree Protection Plan or a full AIA to ensure root protection for the long term retention of the trees. For sites where an LVIA has been recommended (e.g MIN71) this would also need to include a full AIA.

For MIN45 land North of Coxford Quarry and MIN 77 Runs Wood Tottenhill, the initial conclusions recommend that that the sites are unsuitable for allocation in accordance with Section 15 of the NPPF. I am in agreement with these conclusions, particularly as Runs Wood is not ancient woodland but is still considered important due to its high biodiversity value.

MIN40 land east of Grandcourt Farm, East Winch - there appear to be trees within the proposed site at the NW corner which would have to be removed unless the site boundaries are amended. Bearing in mind that there were requirements regarding retaining veteran trees on land at Grandcourt Farm previously, I feel that an AIA would be required for this site to determine the categorisation of the trees in this area to determine if they are worthy of retention.

AOS E land to the North of Shouldham - this area encompasses a large amount of woodland centred on Shouldham Warren that when viewed from a satellite image shows that this is a large block of woodland within a largely arable landscape that forms a connecting feature with the woodland centred on West Bilney Wood to the NE. As such, although the woodland is undesignated in any way, it is a vital connecting feature within the landscape and where possible should be retained. If any of the woodland area is removed, appropriate planting of a similar size of broadleaved woodland should be included as part of the restoration scheme.

MIN115 Lord Anson's Wood near North Walsham - I would disagree that this site is suitable for allocation, in accordance with section 170b of the NPPF. The removal of this section of woodland would degrade the overall capital value, ecosystem services and recreational values provided by the woodland.

The landscape paragraph details mature trees and woodland that are to be retained and enhanced. The initial conclusion also states that a wide screen of trees is to be left around the site. I therefore propose that if this site remains allocated that a full AIA is required to achieve this and this should be listed in the initial conclusion.

MIN 92 Land east of Ferry Lane, Heckingham - I agree with the conclusion that this site is unsuitable for allocation due to the line of mature oaks in the centre of the site.

MIN 204 land north of Lodge Road Feltwell - this site is surrounded by coniferous woodland and hedgerows and would require an AIA to ensure sufficient standoff from the adjacent trees to ensure their roots are protected for their safe long term retention.