Policy MP12: Conventional and unconventional oil and gas development

Fracking is not sustainable, highly damaging environmentally and totally unnecessary when non carbon energy sources are being rapidly developed to eliminate fossil fuels. Investigatory drilling to evaluate viability of fracking should not be permitted. I am aware it is permitted by national policies but NCC should determine on the basis of environmental impact and adverse effect on sustainability that it should not form a permitted part of the Plan.

Would you be kind enough to forward this email to whoever it may concern.

Clenchwarton Parish Council wish to register their objections to any Incineration or Fracking being included in Norfolk County Councils Mineral and Waste Plan.

Incineration and Fracking may be included in the Governments national policies however not all areas are as sensitive as the areas around THE WASH.

The Wash and it's environs have national and international protection.

The Wash is protected by an SSI, SPA and more importantly is also a RAMSAR site.

This area should be protected at all cost.

At the moment NCC has a 'No Incineration Policy'

Incineration and Fracking should be removed from the draft plan.

Over 65,000 people voted against incineration in West Norfolk.

I write in response to your consultation for Minerals & Waste, ending 30th October. I was one of the 65,000 people who voted no to incineration for Norfolk. I would not like incineration to be considered as an option for Norfolk's waste. Neither would I like fracking to go ahead in Norfolk. Many thanks.

As a resident of West Winch near King's Lynn I wish to point out that I don't see anywhere within your plan where it's stated that previously in excess of 65,000 local people who rejected the plans for an incineration facility being built locally for all the obvious reasons.

Please include this in your new proposals and take note that people still haven't changed their views on this!

I am lead to believe that there is still the push for 3,000 new homes in the West Winch Setchey corridor which is contentious due to the appalling lack of road/rail infrastructure that isn't in place prior to this possibly beginning.

To have the potential of fracking included near West Winch then seems ludicrous as across the USA Canada and recently parts of England this is known to cause earth tremors, why would you be pushing for new housing developments to then plague these with earth tremors and other known negative effects?

I am writing to register my dismay with this Council. May I respectfully ask what you don't understand about the two letters NO? 65000 West Norfolk Residents voted against incineration in West Norfolk. Norfolk County Council adopted a No incineration in Norfolk policy in December 2014 and yet nowhere is this stated in above mentioned plan. WHY NOT?
Also you are now proposing for fracking to go ahead in Norfolk. It is well known and documented that this is very controversial and known to have caused earth tremors and damage to surrounding property.
Do you think this would enhance the prospects for the housing development around the A10 corridor in West Winch? Who on earth would want to buy a property that stands a fair chance of being affected by fracking?
As regards above mentioned development in West Winch I understand that 350 houses have to be built before 1.1 million of funding will become available. So with other words we have to have gridlock before something can be done about it. Somehow that doesn't seem to be very sensible to me as it will also affect the businesses you are hoping to attract to West Norfolk.
I sincerely hope you will take the points the public is making to you into consideration in future decision making.

65000 West Norfolk residents voted NO to incineration in the Borough Council poll so the Plan must say incineration is unacceptable in West Norfolk.
The Plan must say fracking is unacceptable in West Norfolk, as it would affect the Wash, a protected area and West Winch Growth Area.

I note the incinerator and fracking is back on the counties waste plan.

65,000 west Norfolk residents voted NO to incineration in the Borough Council poll so the plan must say incineration is unacceptable in West Norfolk.
The plan must say fracking is unacceptable in West Norfolk, as it would affect the Wash, a protected area and West Winch growth area

I would like to object to any form of incineration in the minerals and waste plan at The Willows Industrial Estate, King's Lynn.
65,000 West Norfolk residents, including myself, voted NO to incineration in the Borough Council poll so the plan must say incineration is unacceptable in West Norfolk.
The plan must say fracking is unacceptable in West Norfolk, as it would affect the Wash, a protected area and West Winch Growth Area.

Here are my comments on the minerals and waste plan as a resident of West Winch for the last 14 years:-

65,000 West Norfolk residents voted 'No' to incineration in the borough council poll so the plan must say incineration is unacceptable in west norfolk.

The plan must also say fracking is unacceptable in west norfolk, as it would affect the wash, a protected area and west winch growth area.

I am writing to say that I oppose both the Incinerator being built at the Willows site and Fracking at Setchey.

A vote was offered to the residents in King's Lynn and district area and the vote was a NO to the Incinerator. Unless this country no longer is a democratic society the NO vote means NO.

The Fracking that is being done up north has already caused minor earthquakes and has been stopped to assess the damage it may be causing. Do those people who live in the area of Setchey have to go through the same process?

I am against incineration and fracking in West Norfolk as it would affect the Wash
a protected area and the West Winch Growth Area

As a West Winch resident of more than 30 years - I was part of the 5 year campaign against the incineration plant proposal for the Willows Industrial Estate, which was quashed. I was therefore shocked to find that this had appeared again on the draft Waste plan.

65,000 West Norfolk residents voted NO to Incineration in the Borough Council Poll stating that Incineration was unacceptable in West Norfolk - therefore this must not happen.

Along with this and in light of all the data around how dangerous Fracking is we find that there is a proposal for this to be placed in Setchey - this again must not happen - Fracking is being stopped all over the country - if this is pursued it will be met will huge opposition from the residents of West Norfolk.

People are more important than money - something the planners do not seem to understand.

I would like to protest about West Norfolk being included in the County's waste plan and also about the possibility of Fracking taking place in our area. The vast majority of the people voted not to have an incinerator in the recent past so why include it again. Perhaps the County Council have got another £30 000 000 to spare in which case they can use it to finance a proper A10 bypass for this area.

I object to incineration and fracking being included in the waste plan. It is unacceptable for county council to say that they have to be in the plan as they are national policies. This makes a nonsense of the concept of a 'local' plan which should consider the views of the local community.
Fracking may work in the open spaces of the USA, but is totally unacceptable in heavily built up areas.
65,000 West Norfolk residents voted No to incineration in a previous borough council poll. Th county council's attempt to force incineration on us became hugely divisive, resulted in the loss of a conservative majority in county hall and an eventual loss to council tax payers in excess of 30 million pounds. Does the council really want to risk going through all this again?

There are two issues that I would like to comment on:

Norfolk has a no incineration policy following the abandonment of the proposed facility on the Willows site in Saddlebow in Kings Lynn. In a poll organised by the Borough Council 65000 people voted to say that they did not want this built. Therefore. to keep the option of incineration in the proposals is in violation of the Council's own policy.

Fracking should not be allowed anywhere near people's homes or near the Wash or any other protected areas. In addition it is a retrograde policy at a time when we should be putting every effort in producing our energy from sustainable and low carbon sources. Therefore, fracking along with incineration needs to be removed from the Draft Plans.

Five years ago 65,000 West Norfolk residents voted a resounding 'No' to an Incineration plant in the Borough Council poll so it follows that the proposed Plan now on the table must specify that any incineration in unacceptable in West Norfolk.
In addition, the Plan must state that fracking is unacceptable in West Norfolk as it would affect the Wash that is a 'protected area', as well as affect the West Winch Growth Area.
The collective voice of local residents must be respected when it relates what is happening in their locality. Local communities have a democratic right to be consulted prior to any Plans being considered and certainly before any start to be are implemented.

I am writing to you to voice my concerns that incineration and fracking are in the county plan ,as you know incineration cost the county 40 million last time and the leader his job .
65,000 West Norfolk residents voted no incineration in Norfolk as the representative of these people you should be mindful of their wishes. fracking is also damaging to people's homes and this concerns me greatly as i live in West Winch. No incineration or fracking in Norfolk

County Councillor Response to Minerals and Waste Preferred Options Consultation
The Minerals and Waste Plan must state that 65,000 West Norfolk residents voted No to incineration in the Borough Poll and that Norfolk County Council has had a No Incineration in Norfolk Policy since Council's Motion of December 2014. People campaigned for 5 years to stop the incinerator in South Lynn and are outraged that incineration is still in the Plan.
The people's will must be respected.
The Plan must also state that fracking, and prospecting for fracking, will not be permitted in West Norfolk or around the Wash, as prospecting causes earthquakes and tremors. It is contradictory to say that prospecting for shale gas would only be allowed where there are no unacceptable environmental impacts. Around the UK prospectingalways causes unacceptable environmental impacts, and fracking notably caused a recent earthquake of 2.9 on the Richter scale at the UK's only active fracking site, in Blackpool, which saw its third record-breaking earthquake in under a week this August, breaking through a limit which made the government ban fracking for two years in 2011.

The National Planning Policy for Waste accepts that incineration can be excluded from a local plan at Page 6, where it says that "proposals such as incinerators that cut across up-to-date Local Plans reflecting the vision and aspiration of local communities can give rise to justifiable frustration".

The National Planning Policy for Waste says, at page 4, that there should be "early and meaningful engagement with local communities and plans shouldreflect a collective vision and agreed set of priorities, recognising that proposals for... incinerators can be controversial"

How can the Inspector not agree with these words of wisdom?

65,000 West Norfolk residents voted NO to incineration in a Borough Council poll, but once again Norfolk County wish to include incineration in their plan for West Norfolk. The Plan must make very clear that incineration is unacceptable in West Norfolk. The County Council must take into account the wishes of those 65,000 residents otherwise it is another nail in the coffin of democracy.

Fracking in West Norfolk should also be excluded from its Waste Plan as there is no evidence as yet that it is a safe method of extraction and could possibly cause damage to properties, not only in close proximity, but in a much wider area.

Fracking in West Norfolk is unacceptable as I believe it would cause damage to the Wash, a protected area, and detrimental to the West Winch Growth Area.

For the attention of Planning Services Dept, Norfolk County Council

65,000 West Norfolk residents voted NO to Incineration in the Borough Council poll so the Plan MUST say incineration is UNACCEPTABLE in West Norfolk.

The Plan MUST say Fracking is UNACCEPTABLE in West Norfolk as it would affect the Wash, a protected area and West Winch Growth Area.

I vote NO (again) to Incineration and vote ABSOLUTELY NO to fracking!!!!!!!

Over 65,000 residents have already voted NO to incineration of waste in West Norfolk. The mineral and waste plan consultation must say that incineration of waste in West Norfolk and also any attempt at "Fracking" is not acceptable as it will affect the "Wash", an already protected area and West Winch Growth Area.

Minerals and Waste Plan
Once again, the residents are being ignored by the Council They are wondering why an incinerator is back in the minerals plan.
In 2014 the locals protested loudly against the incinerator plan for South Lynn. Eventually, the plan was dropped. However, now it appears this may well be built after all. Do you not understand the people of Norfolk - the Council tax payers - disagree vehemently with this? Democratically, are not Councillors elected to carry out the wishes of the electorate? Obviously, they have forgotten the previous fight and the moans from your office relating to the money aspect.
We all fail to comprehend why an incinerator and fracking should be included in your minerals plan. Both would badly affect the whole area also cause further air pollution, damaging the health and welfare of everyone.
Parts of Norfolk will be destroyed and we rely on visitors and holidaymakers to help with the local economy. These people will not come as there will be no pretty scenery or beautiful buildings to see.
We feel these new proposals are unacceptable, damaging and ruinous to Norfolk

I am writing to you with reference to the attached copies of letters printed in the last two editions of "your local paper" relating to the above subject. These letters express the feelings of very many people in this area.
I have spent much time trawling through the Preferred Option Plan on the County Council website to no avail, and consequently I am writing to express my views on this subject and those of my wife, namely that there should be no incinerator or fracking in West Norfolk and that any mineral extraction should be conducted well away from houses, areas of proposed housing development, and places of natural beauty.
Furthermore, I feel that the on-line consultation process seems so complex and time consuming as to dissuade the general public form commenting on the proposals.

The minerals and waste plan must say that 65,000 West Norfolk residents voted No to incineration, in a Borough Council poll. Norfolk County Council has a no incineration in Norfolk policy. Incineration and fracking is UNACCEPTABLE in West Norfolk. I used to live in Blackpool. They have been fracking there and earthquakes of increasing size have occurred. Fracking has had to cease.
Will it take the toppling of the Tower to make authorities wake up and see sense? Don't play with our special environment.

I was dismayed and horrified to learn that the County Council has put incineration for Norfolk back into the minerals and waste plan and also to permit prospecting for fracking.
Both these considerations must on no account be allowed to go ahead and I am writing to express my disapproval. The very idea of fracking, so close to the wash & very near places of growth areas, is an abomination after evidence of problems in the north of the country.
I recall vividly the many weeks of special inquiry held in King's Lynn about 5 or 6 years ago, so many meetings of which I attended. The outcome, which you seem to be ignoring, ensured that a no incineration policy in Norfolk was declared and the Willows site for waste incineration was cancelled.

To whom it might concern in the Norfolk county Council.
What are you thinking about for people living in the West Winch to start again with the worry of having another thought about incineration and fracking, WE DO NOT want either, how can you when you are planning 4000 houses in West Winch & North Runton expect people to buy these houses with such views, you only have to ask people in areas where fracking has been started & the earth tremors have appeared.
We have lived in West Winch for 48 years, very happy in the village, how do you expect families to think about moving to live in West Winch with all this hanging over their heads, we as an owner would never be able to sell our house nobody would want to buy it. I bet if a few Norfolk County councillors lived in West Winch the result would be different. We are both not in agreement with any of the TWO PLANS.
We Will fight and fight until people see sense.

We wish to register our grave concerns on the following two items contain in above plan.

Incineration. As West Norfolk residents we voted alongside 65,000 others to say no incineration in the previous Borough Council poll & find it totally unacceptable that this is now being reconsidered. The abortive costs associated with earlier application should bourn in mind.

Fracking. Report published today raises concerns regarding greenhouse gas emissions, ground water pollution, potential for fracking induced earthquakes & cost associated with land reinstatement & decommissioning. This should not be considered in an area identified for growth in West Norfolk.

Norfolk County Council Planning Department
To whom it may concern:
Five years ago 65,000 West Norfolk residents voted a resounding 'No' to an Incineration plant in the Borough Council poll so it follows that the proposed Plan now on the table must specify that any incineration in unacceptable in West Norfolk.
In addition, the Plan must state that fracking is unacceptable in West Norfolk as it would affect the Wash that is a 'protected area', as well as affect the West Winch Growth Area.
The collective voice of local residents must be respected when it relates what is happening in their locality. Local communities have a democratic right to be consulted prior to any Plans being considered and certainly before any start to be are implemented.

65000 West Norfolk residents voted No to Incineration in the Borough Council poll so the Plan must say incineration is unacceptable in West Norfolk. The Plan must say fracking is unacceptable in West Norfolk as it would affect the Wash, a protected area and west Winch Growth Area.

Preferred Options Plan
Thank you for the opportunity to comment on the Preferred Options stage of the Norfolk Minerals and Waste Local Plan. We have commented on the policies and allocated sites in the same format as the Local Plan itself below.

The Process so far
We are pleased to see water resources are mentioned in this section. However, this section could be strengthened by making reference to whether working beneath the water table is required and whether dewatering is required. This could potentially pose a challenge to sites moving forward so it should have a stronger mention in this section.

Policy MW2: Development Management Criteria
We are pleased to see that point k in this policy makes reference to the natural and geological environment. This point could be enhanced by also making reference to the hydrogeological environment including maintaining groundwater dependent wetlands, surface water flows, groundwater quantity and flow regime.

The policy makes no reference to local air quality regarding waste developments, be it from gas utilisation units or fugitive emissions from landfilled areas and their perimeter. This is especially key where development is close to sensitive receptors or such receptors are developed close to the sites.

We welcome the inclusion of point D in the policy. This could be enhanced to state
"flood risk TO THOSE WORKING on site or an increase in flood risk elsewhere" (addition in CAPITALS ). The policy could also be improved by requiring a Flood Response Plan to manage the safety of the people on site.

Pollution and Local Amenity Impacts
We agree with the inclusion of paragraph 8.12 that lighting levels should be assessed with consideration given to the impact lighting will have on European Protected species. Mitigation could include limiting the operational hours of the site and using down lighting.

We fully support the protection of Local Wildlife sites (county wildlife sites, local nature reserves and local wildlife sites) highlighted in paragraph 8.20 as well as priority habitats and species. We agree that any proposal should only be permitted where it can be demonstrated that the activities will not significantly harm the site, and will require submission of appropriate ecological surveys, carried out by an appropriately qualified ecologist, at the correct time of year as described in paragraph 8.21. We recommend the rewording of the final sentence of paragraph 8.20 to state "Development that may affect Water Framework Directive waterbodies e.g. rivers, streams, lakes will require a WFD compliance assessment".

Water Framework Directive
The plan should make reference to the fact that any development that could impact the status of a water body, whether WFD or not, should be subject to a WFD assessment.

Flooding, Water resources and water quality
We agree with the reference this section makes to flood risk betterment after restoration, reducing flood risk elsewhere and acknowledgement that climate change needs to be considered. However this section does not refer to ensuring there is no increase in flood risk elsewhere through the duration of the works. In addition there is no mention of the flood risk to people on site and the need for management to ensure their safety with a Flood Response Plan. The plan should therefore be updated to this effect.


It is encouraging to see that paragraph 8.40 makes it clear that dewatering for mineral abstraction purposes requires a water abstraction licence from the Environment Agency. However, it should be noted that an abstraction licence for dewatering may not be granted and it is likely that any de-watering water will need to be returned to the aquifer close to where it is abstracted and in a timely manner after the abstraction takes place. Our current Catchment Area Management Strategy (CAMS) policy for issuing abstraction licences intervening use of this water for activities such as mineral washing and dust suppression which have a consumptive element will not be permitted, this be a challenge for sites going forward if alternative sources of water for associated activities such as mineral washing and dust suppression cannot be found.

Paragraph 8.40 refers to the Water Framework directive. A WFD assessment is a good addition and we welcome the suggestion to protect the designated drinking water source protection zones. We also support the use of pollution prevention measures, to prevent pollution of surface and groundwater. This paragraph should also state that the assessment should determine if there could be a deterioration in WFD status. Activities should not allow any deterioration in any of the WFD elements. Minerals and waste management developments should not cause deterioration or prevent a water body from achieving Good Ecological Status/Potential, and whenever possible, help to implement environmental improvement measures to improve waterbodies.

Policy MW4: Climate Change mitigation and adaptation
Paragraph 10.2 states the need to minimise demands on potable water resources. The sentence should continue by saying 'and water resources in general'. As stated above, we are not issuing new consumptive abstraction licences.

A possible linkage could be made between point's b and c - on site renewable energy (both electricity and hot water) could well be provided from captured landfill gas emissions. Any excess energy could then be fed into the local networks.
It would be beneficial to update the wording of point 3 to state "...including rising sea levels, LARGER RIVER FLOWS, and coastal erosion..." (addition in CAPITALS).

Waste Management Specific Policies
In terms of paragraph W0.3, you should ensure that you plan for sites that will 'Prepare for Re-use' as it has been stated that greater weight is being put to the management methodology at the top of the waste hierarchy.

W1.12
The plan states "The latest Defra estimate of C&I waste growth for England is 0.6% per annum, therefore an alternative option would be to forecast C&I waste growth over the Plan period at 0.6% per annum instead of 1.5% per annum. However, it is considered that it is more appropriate to use the Norfolk specific figure of 12.5% per annum". We are unsure where and how this figure of 12.5% has been calculated and why it is so different to DEFRA's estimate. Sustainable economic growth will need enough commercial and industrial waste processing capacity to deal with this increase in waste generation.

Policy WP2: Spatial Strategy for Waste Management Facilities
We support the policy WP2 regarding the location of Water Recycling Centres. It should be noted that the decision, ultimately, remains with Anglian Water Services.

Policy WP3: Land potentially suitable for waste management facilities
This policy should state that waste management facilities (aggregate recycling) also need to consider consumptive water use and where this water will come from.

Policy WP6: Transfer, Storage, Processing and treatment of hazardous waste
It is highly likely that any proposals for the discharge of hazardous waste to surface water or groundwater will require a discharge permit, if allowed. The policy could be improved by saying that under no circumstances, should there be a discharge of treated hazardous waste/materiel to surface waters or groundwater without prior consultation with the EA.

Policy WP9: Anaerobic Digestion
The policy could be improved by making reference to Emergency Planning. Proposals for Anaerobic Digestion (AD) facilities should include a detailed emergency plan should there be an incident, such as a major leak or fire for example. AD leachate is extremely rich in nutrients, which if entering a watercourse, could cause significant environmental harm. We suggest the emergency pan includes nearby watercourses, overlying geology, depth to water table, detailed site drainage plan for example. If possible, an emergency plan should be provided for the Environment Agency to review.

W12: Non-hazardous and hazardous waste landfill
Along with section 5.35, we question whether allowing planning permission for Blackborough End to become an inert landfill and reducing the county's non-hazardous landfill waste capacity to just 1.53 million cubic metres is sufficient for residual waste disposal over the plan period. It is unclear from the Local Plan what the options for residual waste disposal will actually be, except reliance on Refuse Derived Fuel (RDF) and its export. Bearing in mind NCC are keen for sustainable waste management, then the export of RDF by definition its potential energy, does not appear the best long term option. Although waste management options higher up the waste hierarchy are always preferable, there will always be waste streams that can only be disposed in landfill.

Policy WP13: Landfill Mining and Reclamation
Please note that such a proposal will require detailed input and agreement from the Environment Agency.

Policy WP15: Whitlingham Water Recycling Centre
We have previously provided comments stating that we welcomed that the WRC has a long term policy to ensure that further capacity is provided in line with growth. We continue to support long term plans being developed for Whittingham and other WRCs.
W15.2 mentions the sites location is close to the Broads and the associated 'landscape and flood risk concerns'. The location also means there are concerns for water quality due to the close proximity of sensitive protected sites of conservation importance. A statement to acknowledge that water quality needs to be protected should therefore be added to the plan here or in this policy.

Policy MP2: Spatial Strategy for mineral extraction
Point e makes reference to the hydrological catchment around Roydon Common SSSI and Dersingham Bog SSSI. It should be ensured that it is mentioned that it is the hydrological and hydrogeological catchment around Roydon Common and Dersingham bog which should be avoided.
We support the policy to provide a 250m buffer around ancient woodland and designated sites.

Policy MP5: Core River Valleys
This policy should also include "the impact of mineral development on groundwater and the potential to need to work beneath the water table".
Any proposal for quarrying activity within a core river valley should not be approved unless the applicant can demonstrate no adverse effect on the WFD status of the river water body, or its tributaries. A Full WFD assessment (as outlined above) will be required for any proposal for this activity to be carried out within a floodplain.

Policy MP7: Progressive working, restoration and after-use
We are fully supportive of supporting paragraph 7.3 which states there may be suitable ark sites to protect wild-clawed crayfish. Such sites need to be identified well in advance of de-commissioning to that the site can remain bio-secure.
The first bullet point in policy MP7 refers to BAP habitat. Please note that this has been superseded by Priority Habitat (S41 NERC Act, 2006).

Policy MP12: Conventional and unconventional oil and gas development
Unconventional oil and gas production requires a lot of water to be used so it is likely an abstraction licence will be required. In addition, much of this water ends up as wastewater so the appropriate storage, treatment and disposal methods will be required. Discharge to any surface waters or groundwater will likely require a discharge permit and an application will need to be submitted. Having said this, the local plan indicates it is highly unlikely there will be hydrocarbon exploration in Norfolk in the foreseeable future so these comments may not be necessary at this point in time.

Policy MP13: Areas of search for silica sand extraction
As stated in our previous response, policy MP13 needs to address the need for an FRA. An FRA is vital if any of the allocations are located in Flood Zones.
Site Allocations

MIN38: Land at Waveney Forest, Fritton
Following our previous comments, we are welcome the conclusions drawn in this document which state the allocation is unsuitable for allocation.

MIN200: Land West of Cuckoo Land, Carbrooke
The site allocation text mentions that the site will be worked dry above the water table several times. If this is the case then this would alleviate our concerns on impacts on Scoulton Mere SSSI. This however is not included within the policy on page 124 and must be included.

MIN40: Land East of Grandcourt Farm, East Winch
We have concerns regarding this site. In the existing site, permeant dewatering of Carstone is proposed in restoration which goes against our previously raised comments. We would recommend not allocating this site.
Any depth of extraction should be severely limited to minimise de-watering. This could impact of the amount of mineral which can be recovered. As this is a principal aquifer, any de-watering water would need to be returned to the aquifer from which it is taken. An appropriate hydrogeological impact assessment will be required and it may well be that de-watering is not considered suitable at this site, which could limit the amount of mineral that could be recovered.

MIN35: Land at Heath Road, Quidenham
Our comments that we gave to the 2018 consultation remain valid.We have no concerns as it is proposed to work above the water table. This may need to be a planning condition on any application submitted.

MIN102: Land at North Farm, Snetterton
This site is adjacent to Swangey Fen SSSI. We previously stated that we do not consider the site suitable for mineral extraction. We are therefore supportive of the conclusions drawn in this consultation document stating that it is considered unsuitable for allocation

MIN201: Land at North Farm, Snetterton
This site is adjacent to Swangey Fen SSSI. We previously stated that we do not consider the site suitable for mineral extraction. We are therefore supportive of the conclusions drawn in this consultation document stating that it is considered unsuitable for allocation.

MIN6: Land off East Winch Road, Middleton
We are pleased to see that the specific site allocation policy for MIN 6 states the need to work above the water table. However, a hydrogeological impact assessment (not impact assessment) would be required to establish the depth of working.

Min204: Land off Lodge Road, Feltwell
Our previous comments raised within the issues and options stage of the consultation remain valid.

MIN74: Land at Turf Field, Watlington Road, Tottenhill
We agree with the conclusion that this site is unsuitable to be carried forward. If the site were to be taken forward, we would want to see a suitable hydrogeological impact assessment.

MIN76: Land at West Field, Watlington Road, Tottebhill
We are already aware of the planning application that has been submitted in terms of this application and have no further comments to make.

MIN77: Land at Runns Wood, South of Whin Common, Tottenhill
We agree with the conclusion that this site is unsuitable to be carried forward. If the site were to be taken forward, we would want to see a suitable hydrogeological impact assessment.

MIN206: Land at Oak Field, west of Lynn Road, Tottenhill
We consider this site suitable for sands and gravel extraction. The need for a hydrogeological impact assessment must be included within a bullet point in the specific site allocation policy. It's likely that de-watering will be required here.

MIN32: Land west of Lime Kiln Road, West Dereham
We agree with the conclusion that the site is unsuitable to be carried forward. We would want to see a suitable hydrogeological impact assessment if the site was carried forward and, as it is sands and gravels overlying chalk bedrock, it is possible that de-watering would not be considered a suitable option.

Area of search for AOE E
Given previous issues we have had with silica sand extraction in the vicinity of this site, we would expect all extraction to be above the watertable. This is likely to limit the amount of resource that can be recovered. It should be noted that the silica sand is part of a principal aquifer.


SIL01, AOS F, AOS I and AOSJ
The starting position should be not to allow de-watering as outlined in our comments to site allocation MIN40.

Silica Sand search locations
If de-watering is not to occur at the silica sand search locations as mentioned in our response above, this can heavily impact on the amount of resource available.

We trust this advice is useful.