1. Introduction

The very first paragraph of the M&WLP (pg 7) states, "The provision of a steady and adequate supply of minerals.......constitute essential infrastructure to support the economic development of the county". All of the silica sand quarried in Norfolk is taken out of the county for use elsewhere in the UK. Therefore, there is no argument that NCC can demonstrate that the extraction of silica sand is to 'support the economic development of the county'. NCC is also unable to define what a 'steady and adequate' supply is since at pg 8 of the introduction section of the M&WLP it states the proposed plan is to extract 750K tonnes per annum of silica sand based on the average sales data. This is in conflict with the statement by Sibelco, on pg 245 at the 4th bullet point under 'Site Characteristics' of SIL 02, that they would intend to extract 800-900K tonnes per annum from SIL 02 alone. So what is an adequate supply? Which figure is correct? If it is the 750K tonnes quoted by NCC then what are Sibelco intending to do with the extra 50-150K tonnes per annum from SIL 02? (Coincidentally this is the amount used in fracking in the UK at this time) It throws doubt on Sibelco's claim that the silica sand sole use is in the manufacture of clear glass. Interestingly, we were told the area SIL 02 contained approx 16,000,000 tonnes of silica sand. Two thirds of SIL02 has been removed in the preferred Options Plan but the NCC notice for the preferred options phase of consultation attached to Wessex BLD telegraph pole on Spring Lane at grid ref; X:5698, Y:3110, indicates the same amount,16,000,000 tonnes for extraction in the area which has only ⅓ of the original area remaining. How can that be?

The National Planning Policy Framework states that Mineral Planning Authorities should look to recycle before they start extracting raw materials. Norfolk (2014 figures) accounts for 20% of all silica sand extraction in the UK and 60% of the silica sand for clear glass manufacture. That is a huge amount of raw material being extracted yet the M&WLP does not make any mention of recycling glass, nor does it contain any figures of how much glass is recycled in Norfolk. The only figures available are for generic waste recycling of on average 46.7% (2016-17) described on the Norfolk Recycles web site. Norfolk Recycles is described as "the public facing brand of Norfolk Waste Partnership and Norfolk County, District, Borough and City Councils working together to improve waste and recycling services for Norfolk's residents and visitors". Therefore, when it comes to recycling glass before extracting raw materials the M&WLP is not sound.

If Norfolk County Council adhered to NPPF for guidance it would look to conserve minerals as it states in Ch 17, para 204.b, that authorities should 'take account of...recycled materials...before considering extraction of primary materials..'. NCC is failing to recycle before extracting raw materials and therefore their plan to 2036 is not sound.
NCC fails their own sustainability objectives SA1, SA3, SA4, SA5. SA6, SA8, SA9, SA11 and SA13 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).

This consultation response is an internal response by Officers of the County Council in its capacity as the Waste Disposal Authority for Norfolk. It has therefore focussed exclusively on policies relating specifically to waste management. There are no comments on those elements of the review relating to Minerals.

As the WDA for Norfolk, the County Council has a statutory duty under section 51 of the Environmental Protection Act 1990 to arrange:

a) for the disposal of controlled waste collected in its area by the waste collection authorities
b) for places to be provided where persons resident in its area may deposit their household waste.

The County Council in its capacity as the WDA, has a policy for the commissioning of residual waste treatment services that precludes the use of facilities in Norfolk that incinerate residual waste that the County Council as WDA is responsible for. However, our comments here are made in clear recognition that the function of the County Council as a planning authority is separate from its function as a WDA and are therefore given in a manner that is neutral about waste treatment technology.

No comment is offered on the planning or sustainability implications of specific sites because it is considered that these are matters on which the WDA would remain neutral.

The Waste Disposal Authority submitted comments during the pre-consultation phase of the development of the Local plan in relation to the general policies and waste specific policies. We are contented that our comments were taken into account at that stage in the development of the policies now presented in the Preferred Options document and will not repeat them in this response.

Nevertheless, we have reviewed the policies contained in the Preferred Options document and their associated Sustainability Appraisals and have very few further comments to add to those already given during the pre-consultation phase.

1.12 of the Preferred Options document recognises that there is currently sufficient permitted capacity in Norfolk to cover the forecast growth in waste arisings to 2036. However, there is a distinction between capacity that is permitted and that which is realistically commercially available to the serve the needs of the Waste Disposal Authority.

In terms of residual waste for which the Waste Disposal Authority is responsible, it is necessary to export much of this outside of Norfolk following either receipt at a transfer station or some degree of pre-treatment and there is currently sufficient permitted capacity for this. The Waste Disposal Authority would not wish the perception that there is sufficient capacity in general to undermine any specific case made for the need for local residual waste treatment capacity.

However, the Waste Disposal Authority does not believe that the Preferred Options document creates such a difficulty. Paragraph 1.12 clearly recognises the contract driven nature of the waste management industry and that any planning application would be assessed against the M&WLPR criteria-based policies.

I object to the whole of Norfolk M&WLP and especially the large area of SIL02 that has been included in AOS E after it was said not to be allocated. NPPF states in para 35, four criteria by which a sound plan is based; Positively Prepared, Justified, Effective,and Consistent with National Policy. This plan is unsound based on these four criteria especially relating to SIL02 overlap in AOSE.

Positively Prepared - Norfolk County Council has not looked into the positives of glass recycling at all, never mind looking into recycling flat glass (which is done to great effect in Germany). Recycling glass, especially flat glass would preserve minerals for future generations; see Ch.17 para 204.b NPPF. The other benefit of glass recycling would be to show that Norfolk, especially West Norfolk is not up for sale to greedy business; we have ineffectual governance of our County if this plan is enacted. It is Norfolk being stripped of a finite resource at the say so of Sibelco (sales figures are Sibelco's own figures and have no breakdown of how they are derived) for Sibelco company profit, with little or no financial benefit to us, the residents. County Council is not looking after the Norfolk taxpayers interests; the real investors in Norfolk. Quarrying is not environmentally friendly; to offset any CO2 emissions HGV transport needs to be avoided if we want to be carbon neutral in the timescale the Govt. has mandated.
Justified - How can you put forward huge areas for reduction to smaller areas knowing that in the future Sibelco will ask for extension after extension to 'land grab' that original large area? Even in their own literature NCC admit they give more weight to an area that has already been developed, which for the area of SIL02 is 390 hectares and AOSE nearly 1000 hectares. How can you justify quarrying in light of Climate Change Act and reductions to be made to be carbon neutral? How can it be justified that large areas of good agricultural land and forest is to be decimated for sand, over food and health of our communities? How can it be justified to blight the landscape with a quarry that sits directly in the historic environment of Pentney Priory Gatehouse? How can it be justified whilst we import many other goods- medicines, foodstuffs and others - but we fail to import silica sand, which would preserve our own reserves of this finite material and also preserve the heritage, health, and wealth of the nation for future generations?
Effective - This plan is not compliant with DEFRA's 25 Year Plan, with BEIS Clean Growth Strategy, or NPPG Refs : 27-012,013,017 and 045-20140306 , or NPPF guidance to look to recycle before extraction of raw materials. How can you say this plan is effective when you have no vision to change the past destructive practices of quarrying and continue with the status quo? Only a forward thinking plan that includes recycling glass, especially flat glass would make the plan effective. NCC has a duty of care to the taxpayers of Norfolk to ensure that our homes and lives are not affected to our detriment. How is this plan effective if NCC is not abiding by the Climate Change Act; DEFRAs 25 Year Plan, BEIS Green Energy Plan, the need to be more self-sufficient in growing food-stuffs for the nation and the practise of ignoring NPPF on the need to reserve finite resources effectively?
Consistent with National Policy - This plan is NOT compliant with DEFRAs 25 Year Plan to Improve the Environment, the Gov plan for Rural Proofing, the NPPW, BEIS Clean Growth Strategy, NPPG Refs : 27-012,013,017 and 045-20140306, or NPPF looking to recycle before extraction of raw materials; therefore, this plan is not consistent with National Policy and is unsound.

NCC's M&WLP Vision plus Policies WP1 and WP2, Objectives WSO1,2,4,6 and 8 and MSO2,3,8 and 10, all fail without a plan for a coherent, modern glass (especially flat and clear glass) recycling plan investing with industry partners in a technologically advanced infrastructure that will save raw minerals and energy, reduce the emission of greenhouse gases, create 100s of jobs in Norfolk and, just as importantly, stop the wanton destruction of the Norfolk landscape and biodiversity with a 'business as usual' attitude to mineral extraction in our county. More detail in Representation ID:94688, selecting the link 'More detail about Representation ID:94688

I object to Norfolk's M&WLP for the following reasons. NPPF para 35, lists the four criteria that are the basis of a sound plan; Positively Prepared, Justified, Effective, and Consistent with National Policy. This plan is unsound based on these four criteria especially relating to SIL02 overlap in AOSE.

1. Positively Prepared - Norfolk County Council does not take into account Ch.17 para 204.b NPPF. There is no forward-thinking in respect of recycling glass, especially flat glass that would preserve minerals for future generations. Without glass recycling at the forefront of planning, there is no positive or preparedness in this plan and it is unsound on that basis; "the benefits of glass recycling are clear" to quote Sibelco. Norfolk, especially West Norfolk would benefit from job creation, ensuring finite resources are protected for the future and the wellbeing of residents are given paramount importance over business that takes profit from the County. Quarrying is not the answer, it's environmentally unfriendly; to offset any CO2 emissions HGV transport needs to be avoided if we want to be carbon neutral in the timescale the Govt. has mandated.

2. Justified - NCC give favourable status to areas that have already been developed by quarry operators and in Sibelco's case, they are granted extension after extension under the premise that you can only work where silica sand is found. This is true to an extent, however, you cannot justify the area around RAF Marham due to bird strike risk. There are other areas that already have bird populations that could be worked without risking RAF Marham personnel and surrounding villages. There is no justification for the area of SIL02, 390 hectares and AOSE nearly 1000 hectares. The Climate Change Act requires reductions in CO2 emissions with the aim of being carbon neutral by 2050, that cannot be achieved by quarrying no matter how it is worked. No justification for the misuse of good agricultural land and forest. No justification that allows Pentney Priory Gatehouse historic landscape to be destroyed. If we fail to import silica sand, we will lose our own reserves of this finite material and fail to preserve the heritage, health, and wealth of the nation for future generations.

3. Effective - This plan is not compliant with DEFRA's 25 Year Plan, with BEIS Clean Growth Strategy, or NPPG Refs : 27-012,013,017 and 045-20140306 , or NPPF guidance to look to recycle before extraction of raw materials. How can you say this plan is effective when you have no vision to change the past destructive practices of quarrying and continue with the status quo? Only a forward-thinking plan that includes recycling glass, especially flat glass would make the plan effective. NCC has a duty of care to the taxpayers of Norfolk to ensure that our homes and lives are not affected to our detriment. How is this plan effective if NCC is not abiding by the Climate Change Act; DEFRAs 25 Year Plan, BEIS Green Energy Plan, the need to be more self-sufficient in growing food-stuffs for the nation and the practice of ignoring NPPF on the need to reserve finite resources effectively?

4. Consistent with National Policy - This plan is NOT compliant with DEFRAs 25 Year Plan to Improve the Environment, the Gov plan for Rural Proofing, the NPPW, BEIS Clean Growth Strategy, NPPG Refs : 27-012,013,017 and 045-20140306, or NPPF looking to recycle before extraction of raw materials; therefore, this plan is not consistent with National Policy and is unsound.

Norfolk Minerals & Waste Local Plan - Preferred Options Consultation

Thank you for your Council's e-mail dated 16th September in respect of the above consultation.

The relevant documents have been considered and the proposals are outside the catchment of both the Commissioners and the Boards that we administer within Norfolk, therefore, we have no comment to make.

We look forward to your further consultation on similar documents in due course.

Please be advised that the above consultation was discussed at our recent Parish Council meeting and it was agreed that the following response should be submitted:

'Parish Councillors felt they had insufficient knowledge of the subject matter and were therefore not in a position to submit any comments relating to this consultation'

MMO Marine Planning and Marine Licensing response to Norfolk Minerals and Waste Local Plan - Preferred Options.

Thank you for giving us the opportunity to comment on the Norfolk Minerals and Waste Local Plan - Preferred Options. The comments provided within this letter refer to the documents entitled Norfolk Minerals and Waste Local Plan - Preferred Options.

As the marine planning authority for England, the MMO is responsible for preparing marine plans for English inshore and offshore waters. At its landward extent the Marine Plan boundaries extend up to the level of the mean high water spring tides mark (which includes the tidal extent of any rivers), there will be an overlap with terrestrial plans which generally extend to the mean low water springs mark.

Marine plans inform and guide decision makers on development in marine and coastal areas. Planning documents for areas with a coastal influence may wish to make reference to the MMO's licensing requirements and any relevant marine plans to ensure the necessary considerations are included. In the case of the document stated above, the East Inshore and East Offshore Marine Plans are of relevance. The East Marine Plans cover the area from Flamborough Head to Felixstowe, including the tidal extent of any rivers within this area.

All public authorities taking authorisation or enforcement decisions that affect or might affect the UK marine area must do so in accordance with the Marine and Coastal Access Act 2009 and any relevant adopted Marine Plan, in this case the East Inshore and East Offshore Marine Plans, or the UK Marine Policy Statement (MPS) unless relevant considerations indicate otherwise. Local authorities may also wish to refer to our online guidance online guidance, the Marine Information System and the Planning Advisory Service soundness self-assessment checklist.

Marine Licensing
The Marine and Coastal Access Act 2009 states that a marine licence is required for certain activities carried out within the UK marine area. The MMO is responsible for marine licensing in English waters and for Northern Ireland offshore waters.
The marine licensing team are responsible for consenting and regulating any activity that occurs "below mean high water springs" level that would require a marine licence. These activities can range from mooring private jetties to nuclear power plants and offshore windfarms.

Summary notes
Please see below suggested policies from the East Inshore and East Offshore Marine Plans that we feel are most relevant to your Minerals and Waste Local Plan.
These suggested policies have been identified based on the activities and content within the document entitled above. They are provided only as a recommendation and we would suggest your own interpretation of the East Marine Plans is completed:

* AGG1: Proposals in areas where a licence for extraction of aggregates has been granted or formally applied for should not be authorised unless there are exceptional circumstances.
* AGG2: Proposals within an area subject to an Exploration and Option Agreement with The Crown Estate should not be supported unless it is demonstrated that the other development or activity is compatible with aggregate extraction or there are exceptional circumstances.
* AGG3: Within defined areas of high potential aggregate resource, proposals should demonstrate in order of preference:
a) that they will not, prevent aggregate extraction
b) how, if there are adverse impacts on aggregate extraction, they will minimise these
c) how, if the adverse impacts cannot be minimised, they will be mitigated
d) the case for proceeding with the application if it is not possible to minimise or mitigate the adverse impacts
* DD1: Proposals within or adjacent to licensed dredging and disposal areas should demonstrate, in order of preference
a) that they will not adversely impact dredging and disposal activities
b) how, if there are adverse impacts on dredging and disposal, they will minimise these
c) how, if the adverse impacts cannot be minimised they will be mitigated
d) the case for proceeding with the proposal if it is not possible to minimise or mitigate the adverse impacts
* Other policies of relevance may include: economic, ports and shipping, ecosystem, biodiversity and climate change policy areas.

Further points to note
Page 17: 5.32. You refer to marine aggregate dredging, which is licenced by the MMO.
We would also recommend you mention the East Inshore and East Offshore Marine Plans and the UK Marine Policy Statement (MPS) as well as the National Planning Policy Framework (NPPF).

As previously stated, these are recommendations and we suggest that your own interpretation of the East Marine Plans is completed. We would also recommend you consult the following references for further information:
East Inshore and East Offshore Marine Plans and Marine Information System.

Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019

Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]

SUMMARY
Whilst we consider many aspects of the plan to be sound we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan.

Under paragraph 35 of the NPPF some aspects of this Plan are unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound. In summary we highlight the following issues:

a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.

b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.

c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.

d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.

Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes do not go to the heart of the Plan's soundness, but instead are intended to improve upon it. We believe that these comments can be addressed by changes to wording in the plan.

Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.

We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.

In preparation of the forthcoming 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 a policy, allocation or document in this letter does not mean that Historic England is content that the policy, allocation or document is devoid of historic environment issues. We should like to stress that this response 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 as a result of this plan, where we consider that these would have an adverse effect upon the historic environment.

If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.

Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019

Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]

SUMMARY
Whilst we consider many aspects of the plan to be sound we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan.

Under paragraph 35 of the NPPF some aspects of this Plan are unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound. In summary we highlight the following issues:

a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.

b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.

c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.

d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.

Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes do not go to the heart of the Plan's soundness, but instead are intended to improve upon it. We believe that these comments can be addressed by changes to wording in the plan.

Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.

We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.

In preparation of the forthcoming 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 a policy, allocation or document in this letter does not mean that Historic England is content that the policy, allocation or document is devoid of historic environment issues. We should like to stress that this response 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 as a result of this plan, where we consider that these would have an adverse effect upon the historic environment.

If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.

Thank you for your consultation on the above dated 17 September 2019 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

We welcome the opportunity to comment on the Preferred Options consultation of the Minerals and Waste Local Plan Review (M&WLPR) prepared by your authority, and have submitted a few comments on specific policies and proposed site allocations through the on-line consultation process, having reviewed the following documents:
* Main M&WLPR Preferred Options consultation document, dated July 2019;
* Draft Sustainability Appraisal (Part B) of the M&WLPR, dated June 2019; and
* Draft Habitats Regulations Assessment (Test of Likely Significant Effect)of M&WLPR, dated July 2019.

We are satisfied, and agree, with the findings of both of the above Sustainability Appraisal (SA) and Habitats Regulations Assessment documents, both are thorough and robust. My only comment in regard to the SA is that it would be good under Table 8.1 under SA6: To protect and enhance Norfolk's biodiversity and geodiversity, to include an indicator which demonstrates how the Local Plan is contributing to biodiversity net gain by recording the area of new habitats created following the restoration of allocated sites.

Otherwise, I'd just like to reiterate the remarks I made in response to the Initial Options stage, that you and your team are to be congratulated on the quality of the consultation documents that have been produced. Natural England considers that the M&WLPR undertaken to date has been detailed, comprehensive and written in accordance with current legislation and policy.

If you have any questions please contact me.

SUBMISSION ON BEHALF OF NATIONAL GRID
National Grid has appointed Wood to review and respond to development plan consultations on its behalf.
We are instructed by our client to submit the following representation with regard to the current consultation on the above document.
About National Grid
National Grid Electricity Transmission plc (NGET) owns and maintains the electricity transmission system in England and Wales and National Grid Electricity System Operator (NGESO) operates the electricity transmission network across the UK. The energy is then distributed to the eight electricity distribution network operators across England, Wales and Scotland.
National Grid Gas plc (NGG) owns and operates the high-pressure gas transmission system across the UK. In the UK, gas leaves the transmission system and enters the UK's four gas distribution networks where pressure is reduced for public use.
National Grid previously owned part of the gas distribution system known as 'National Grid Gas Distribution limited (NGGDL). Since May 2018, NGGDL is now a separate entity called 'Cadent Gas'.
To help ensure the continued safe operation of existing sites and equipment and to facilitate future
infrastructure investment, National Grid wishes to be involved in the preparation, alteration and review of plans and strategies which may affect National Grid's assets.
Proposed sites crossed or in close proximity to National Grid infrastructure:
Following a review of the above development plan, the following sites have been identified as being crossed or in close proximity to National Grid infrastructure. Further details are provided in the table overleaf.
Gas Transmission
Site Ref: WS5 Land east of Mill Drove, Blackborough End Landfill site
Safeguard Existing Waste Management sites
Asset Details: FM02 - Brisley to Wisbech Nene West
Appendix Ref: GT128
Please see enclosed plan referenced GT128 at Appendix 2. The proposed sites are crossed by a National Grid underground high-pressure gas pipeline.
The statutory safety clearances between overhead lines, the ground, and built structures must not be infringed. Where changes are proposed to ground levels beneath an existing line then it is important that changes in ground levels do not result in safety clearances being infringed. National Grid can, on request, provide to developers detailed line profile drawings that detail the height of conductors, above ordnance datum, at a specific site. You can find National Grid's guidelines for developing near Over Head Lines here:
https://www.nationalgrid.com/sites/default/files/documents/Development%20near%20overhead%20lines_0.pdf
Electricity Distribution
UK Power Networks owns and operates the local electricity distribution network in Norfolk County Council.
Contact details can be found at www.energynetworks.org.uk.
National Grid Asset Guidance
National Grid seeks to encourage high quality and well-planned development in the vicinity of its high voltage overhead lines. Land beneath and adjacent to the overhead line route should be used to make a positive contribution to the development of the site and can for example be used for nature conservation, open space, landscaping areas or used as a parking court. National Grid, in association with David Lock Associates has produced 'A Sense of Place' guidelines, which provide detail on how to develop near overhead lines and offers practical solutions which can assist in avoiding the unnecessary sterilisation of land in the vicinity of high voltage overhead lines.
Potential developers of these sites should be aware that it is National Grid policy to retain our existing
overhead lines in-situ. The relocation of existing high voltage overhead lines will only be considered for projects of national importance which has been identified as such by central government.
National Grid requests that any High-Pressure Gas Pipelines are taken into account when site options are developed in more detail. These pipelines form an essential part of the national gas transmission system and National Grid's approach is always to seek to leave our existing transmission pipelines in situ. Please refer to the Health and Safety Executive (HSE) in the first instance.
National Grid have land rights for each asset which prevents the erection of permanent/ temporary buildings, or structures, changes to existing ground levels, storage of materials etc. Additionally, written permission will be required before any works commence within the National Grid easement strip, and a deed of consent is required for any crossing of the easement. In the first instance please consider checking with the Land Registry for the development area.
If you require any further information in relation to the above and/or if you would like to check if National Grid's transmission networks may be affected by your works, please contact National Grid's Plant Protection team via plantprotection@nationalgrid.com or visit the website: https://www.linesearchbeforeudig.co.uk/
Further Advice
National Grid is happy to provide advice and guidance to the Council concerning our networks. If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us. In addition, the following publications are available from the National Grid website or by contacting us at the address overleaf:
* A sense of place - design guidelines for development near high voltage overhead lines: A sense of place design guidelines for development near high voltage overhead lines:
https://www.nationalgridet.com/document/130626/download
* Guidelines when working near NGG assets: https://www.nationalgridgas.com/land-and-assets/workingnear-our-assets
* Guidelines when working near NGETT assets: https://www.nationalgridet.com/network-andassets/working-near-our-assets
Appendices - National Grid Assets
Please find attached in:
* Appendix 1 provides a map of the National Grid network across the UK.
* Appendix 2 provides maps of the sites referenced above in relation to the affected National Grid Transmission assets outlined above.
Please remember to consult National Grid on any Development Plan Document (DPD) or site-specific proposals that could affect our infrastructure. We would be grateful if you could add our details shown below to your consultation database: [contact details redacted]
I hope the above information is useful. If you require any further information, please do not hesitate to contact me.

Thankyou for consulting Cumbria County Council on your Minerals and Waste Local Plan.
Having reviewed the Preferred Options policies, I can confirm we have no formal comment to make as a Minerals Planning Authority.

* 1.5 - one specific site[s] for carstone extraction
* 1.14 - tpa - presume that is tonnes per annum - not used consistently in this para
* Page 12 - SA section - bullet point list does not mention landscape impact or biodiversity
* 5.16 The area known as the [Breaks] Brecks
* Where is MW1? The first policy is MW2.
* MW2 - The first part is written in quite a different way to other policies I have read; rather than saying that impacts of development will be minimised on the criteria, or schemes will address the criteria, you ask for information only. I am not sure how strong this approach is. b) what about the quantity of surface water (as in what to do with it in relation to flooding) and the quality of water bodies? E) what agriculture land class do you consider this to be - Grade 1 and 2 perhaps - might need to say that. What about if the soil that is to be excavated or disturbed is peat soils? Peat soils have many special qualities, such as are a carbon sink but a carbon source if allowed to dry out. We recommend that you consider protecting Peat Soils - you can look at our Peat Soils policy for ideas. i) what are 'outdoor recreation facilities' and do you need to include Local Green Space as well as Open Space?
* 8.12 - request there is some text, perhaps as a footnote, that refers to the identified dark skies of the Broads and refers to our maps and policy.
* 8.16 says 'Directing lighting downwards and away from properties' but taking this literally, this contradicts - implying angling the light away from properties which could cause light pollution. I think you are saying design any lighting so it points downwards and ensure that there is no light trespass for example into neighbouring properties. You might want to consider that wording and you might want to look at our policy on light pollution. The key point is - do you really need lighting, if so why? Keep it to a minimum, use it when needed and point it down and have it fully shielded - I suggest you get those points across strongly in the policy.
* 8.24 first bullet point - weave in wording that refers to the setting of the landscapes.
* 8.31 and section 12 - I see you refer to soil grades 1, 2 and 3a. As a bit of advice from our experience, do you know where 3a is? There is limited mapping relating to 3a. You might want to consider removing this or just saying '3'. Happy to chat this through. Should the soil grade be mentioned in the policy? Note what is said on page 73, I - that 3a and 3b are not mapped.
* 8.32, 12.2 - temporary yes, but for a number of years. Suggest that text is clarified. See above regarding if the soil is peat soils and its care.
* 8.35 - is it worth asking applicants to state how they have considered water and rail and road and thoroughly justify their chosen mode, rather than just encourage it?
* MW3, last bullet point - is that a travel plan? MW4 refers to travel plans.
* MW4 - is it better to just say 'greenhouse gas emissions'? Does using the term 'endeavour' reduce the strength of criterion c? d) just demonstrate or implement too?
* 12.4 says 'Given their nature, most waste management facilities will tend to be suitably located on previously developed land and industrial locations and it is not expected that there will be a great need to locate such uses on agricultural land' - not sure what this is saying - they tend to be located there or are suitable to be located there?
* Map 3 - see above comments - where are areas of 3a?
* Section 12 - no mention of peat soils and their qualities - see above.
* Page 41 onwards and then 64 onwards - formatting - should this have a section number - perhaps section 13? The bullet points are numbered differently to elsewhere in the Plan - WO rather than, say, 13.2 etc.
* WP4 - a) when compared to another option that takes longer?
* W7.1 - do you mean 2018?
* WP13 - so a, b, c are 'or' and d, e, f are 'and'. It might be easier to separate them out and say something like 'in all cases d, e, f will apply'.
* WP15 - first para seems reasoned justification rather than policy text. Suggest the Broad Authority be involved in the organisations listed in para 3 - the organisations in para 4 seem to be the ones that need to be involved in the Masterplan.
* WP17 and MP11 - on adoption, presume we will be sent these GIS layers to upload to our system?
* Page 71, and MP2 - that NPPF paragraph applies to the Broads too. We have a Major Development policy. Why is the AONB excluded and the Broads not? Or is it?
* Page 73, g - why not the undesignated heritage assets?
* MP2.14 - 'Developers wanting to [extraction] extract mineral from specific sites or land within an area of search allocated in the Minerals and Waste Local Plan Review will still need to apply for and be granted planning permission before mineral extraction can take place'.
* MP2 - why the 3mile/5 mile rule for minerals?
* MP4.1 and MP4 - how about if the reservoir is not associated with mineral abstraction?
* Page 76 - what is shown on this map? There is no key. If it is core river valleys, why are the rivers over in the Broads not blue?
* MP6 might make sense but the first part says acceptable, unacceptable and acceptable. A check might be needed.
* MP8.3 'The need for annual reports after the initial five-year period [for] will be assessed on a case by case basis'.
* M65.5 - starts off saying 'The site is not located within...'. Being within is one issue, but affecting the setting of is another. So such assessments should state whether the site is near to those designations. This should therefore correctly read that the site is near to the Broads.
* Page 181 onwards - Min 38 - Waveney Forest, Fritton - support not allocating this site.
* Min 65, Stanninghall Quarry - extension to existing minerals site. No landscape visual or character concerns with regards to the Broads itself.
* Min 25, we would definitely want to be consulted on any forthcoming planning applications on this site, particularly concerning landscape scheme and restoration as the landscape character areas in this locality are well defined and susceptible to change.
* Min 211, Restoration as wet grassland for biodiversity needs to be balanced with long-term effects on local landscape character. The local character and experience of the landscape varies between the north and south of the site and restoration should reflect this.
* Generally, an LVIA assesses the effects of a development (the impact) on the landscape as a resource and the effects on visual receptors. The assessment will cover both the site itself and a wider study area determined by desk study and ground-truthing. LVIA's should be carried out to a set standard (Guidelines for landscape and visual impact assessment, 3d edition - which I believe is part of the NCC validation checklist) so by definition will be required to include the site and any surrounding area that could be affected by the development; Existing: "Submission of a Landscape and Visual Impact Assessment which will identify any potential impacts to the wider landscape and suggest appropriate mitigation measures ..." Proposed: "Submission of a Landscape and Visual Impact Assessment which will identify any potential effects and suggest appropriate mitigation measures ..." This text is used across a number of the policies.

SA Part A Scoping
Page 31 needs a very big update.
* Core Strategy, DM and Sites not in place any more.
* Local Plan adopted May 2019.
* Flood Risk SPD - most recent is 2017
* Broads Plan is 2017
Seems relevant to refer to our dark skies data and policy

SA - Part B
4.5 - did you consider a zone from the Broads?


Please note: The Broads Authority has adopted a new Local Plan which can be found here. The policies in the Core Strategy, Development Management and Site Specific documents are all superseded and not in place anymore.

Arboriculture
I am satisfied that arboricultural implications have been suitably considered within the wider landscape and ecological context for the allocated sites and that my previous comments have been addressed. I have brief comments about 2 further sites.

SIL01 Mintlyn South, Bawsey
Many trees within the site boundary will be lost. Development should be subject to the additional requirement of an Arboricultural Impact Assessment to ensure sufficient standoff from the adjacent trees

MIN 213 Stratton Strawless
This site is surrounded by coniferous woodland and would therefore require an AIA at the planning application stage to ensure sufficient standoff from the adjacent trees. This to ensure a sufficient area of their roots are protected for their safe long term retention as part of the restored site.

Landscape
I am satisfied that my previous comments have been taken into consideration and addressed where necessary. I have no further comments in relation to the proposed Waste sites Appendix 10 Sites 1-6.
SIL01
Whilst the will be unavoidable landscape and visual impacts of extraction at this site, an LVIA will be able to assess these and suggest appropriate mitigation measures. The restoration scheme will need to be carefully designed to take into account the assessment and should reflect the wider context and what is lost during the extraction.
Min 213
A suitable landscape buffer of woodland is proposed to be retained which should minimise visual impacts from outside the site It will be important that a standoff is in please to protect these trees in longevity. Consideration will be required in relation to views from the proposed entrance, to ensure that this is suitably designed to minimise impacts.

Norfolk Minerals & Waste Local Plan Review: Preferred Options Consultation
Thank you for your recent consultation on the above document. Having reviewed the
consultation documents, we are pleased to note that the previous comments made by South Norfolk Council in relation to Policies WP7 and WP15 have been incorporated into the updated document. However, we also note that the other amendments suggested in our response to the Initial Public Consultation (dated 13 August 2018) have not been included within the latest version of the Norfolk Minerals and Waste Local Plan. We therefore wish to reiterate these comments and have again attached them to this consultation response for your ease of reference.
In addition to the above general comment, our Environmental Health colleagues have expressed their support for the submission of noise and dust assessments and mitigation measures to deal with the amenity impacts of planning applications for mineral extractions.
This is due to the proximity of existing residential properties to proposed mineral extraction sites within South Norfolk and the potential for these properties to be affected, particularly by noise and dust.
I hope you find the above comments useful.

Norfolk Minerals & Waste Local Plan Review: Initial Public Consultation
Thank you for your recent consultation on the above document, South Norfolk Council has the following comments to make.

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

Comments on specific policies:

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

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

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

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

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

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

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

Comments on Proposed Minerals Extraction Sites:

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

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