MIN 12 - land north of Chapel Lane, Beetley

East Bilney Quarry is a well established Quarry and has operated without significant objection for many years. The Allocation would serve as an extension to the Quarry once reserves within the existing area are exhausted. The Sand and Gravel deposit is of a high quality containing a good proportion of stone. All mineral would continue to be conveyed to the Plant Site for processing and sale with the land restored back to agriculture at the lower level but with landscape and biodiversity enhancements. The proposer can confirm that all the requirements of Specific Site Allocation Policy MIN 12 will be addressed in a future Planning Application. On behalf of Middleton Aggregates Limited I would ask for this site to remain as an Allocation.

The Parish Council supports the assessment for this site as it is an extension to the existing and would have no detrimental transport issues.

This site extends the existing Middleton Aggregates operation and it is proposed to use the existing conveyor system to transfer material to the existing processing plant. Providing that adequate mitigation measures are taken with regard to noise and visual amenity there will be little further impact on the local community.

We are residents of Fakenham Road, Beetley, NR20 4ET and our property is opposite one of the sites designated for the mineral plan.

We have objected to the development since the first consultation and are concerned about the effect of the development will have on our property, chiefly the noise, dirt and traffic that will be generated.

I feel that it would be right and property for representatives of Norfolk County Council, Breckland Council and the companies involved in the extraction process to meet with residents of the affected properties and local parish councils so that proper discussion could take place.

POOR BEETLEY! Yet another quarry proposal threatening to surround the village.
The climate is already deciding our fate, and we are constantly warned not to ignore the shortage of food that will be felt world wide, yet Norfolk persists in its sacrifice of arable land on an unprecedented scale and is destined to be a patchwork of housing estates and quarries. Certainly, another quarry in Beetley is one too far. This one, together with the 2018 intrusion, threatens to overshadow Field Lane, a route to Old Beetley used by locals and visitors alike avoiding overgrown hedgerows and the hectic 1156 highway. Is there really no end to Norfolk's demise.

Ref. Norfolk Minerals and Waste Local Plan:Preferred Options Consultation Your ref:
M&WLPPO2019
I refer to your consultation letter dated 13th September 2019 regarding the above preferred Options consultation.I wish to raise objection to the proposed mineral extraction site MIN 12 land north of Chapel Lane,Beetly identified on the Breckland Sites "Map of proposed sites Beetly (Min 08; Min 12; Min13; Min 51).The following are the key salient points of objection:
1.IMPACT ON RESIDENTIAL AMENITY
The proposed use of the site for sand and gravel extraction for an estimated 80,000 tonnes per annum would result in significant adverse impacts in terms of noise and dust as well as resulting in significant impacts on air quality of which no assessment has been made.Given the relatively close proximity of my property within 200m to the site, it is inevitable that my property will be adversely impacted by dust and noise even with any proposed mitigation measures and would adversely impact on my quality of life.The proposal would result in the breach of my Human Rights Act 1988.Protocal 1,Article 1 your right to enjoy your property peacefully .Every natural or legal person is entitled to the peaceful enjoyment of his possessions.No one shall be deprived of his possessions except in the public interest and subject to the conditions provided for by law and by the principles of international law.No assessment has been made or referred to in the assessment characteristics of this site ,regarding the Human Rights implications.The consultation is considered flawed as no regard or assessment has been made and appropriate legal action will be persued.
The amenity impacts on the residential properties within 250m of the proposed site would be significant and demonstrably effect my quality of life as well as those of other immediate residents.
2. IMPACT ON CHARCTER AND APPERANCE OF AREA
The proposal would result in a significant visual intrusion within the landscape given the size of the site for mineral extraction.Given the open nature of the site with few landscape features apart from boundary hedgerows.The proposal would result in demonstrable harm to the character and appearance of the area.
3.IMPACT ON HISTORIC ENVIRONMENT
The proposal would also adversely impact on the setting and character and appearance of the Grade 1 Church of at Mary Magdalen and listed buildings within the vicinity.The proposed use of the site for mineral extraction would not comply with Section 66 of the Planning (Listed Buildings and Conservation Areas)Act and would adversely impact on their character and setting. Historic England have not been consulted and are a statutory consultee regarding any impact on the setting of Grade I Listed buildings.Failure to comply with this would be grounds for judicial review as due regard would not have been had to these Heritage Assets.These assessments need to be carried out first.
4.HIGHWAYS
The proposed use of the site for gravel extraction would result in significant traffic generation it is noted an estimated 30 HGV movements in and out per day.No Traffic Impact Assessment has been provided to justify the acceptability of the use of the site for this purpose.The surrounding road network is considered in appropriate for the additional traffic movement that would be generated.
5.ECOLOGY
The proposal would have an adverse impact on the ecology of the site. Please advise whether an appropriate Habitats Regulation Assesment ( HRA) has been carried out for the site as a competent authority.
The site is also know to contain Badger Sets which are protected under the protection of Badgers Act 1992.The proposed use of the site for mineral extraction would destroy these protected habitats. Again no assessment has been undertaken regarding these matters.
CONCLUSION
In conclusion I strongly object to the use of this site for mineral extraction for the reasons set out above. Please keep me informed

We live at High House farm Bilney road Gressenhall and as such are some of the closest dwellings to Min08

We wish to confirm support for the views of the Parish Council as expressed below and specifically we object to Min 08, Min 51 and Min 13

3. We note that MIN12 is put forward by Middleton Aggregates as an extension to their existing operation which will take mineral back to their long established plant site due north of Gressenhall Village. We note that this has estimated minerals of well in excess of 1million tonnes and that this allocation will enable the Middleton Aggregates pit to continue to be served well beyond the plan period to 2036. As such we do not have an objection with this allocation.
4. MIN13 and MIN51 have been put forward by a different mineral operator on the basis that the new operator would need to establish its own plant on site.
5. Given that Middleton Aggregates are operating a pit immediately next door and mindful also of the existence of a second independent mineral operator namely McLeod Aggregates who are based approximately 2 miles away on the western side at Bittering, we see no case whatsoever for the introduction of a third operator in this location.
6. By definition there is plenty of competition in existence already with two operators able to service the local market and we see no case for that situation changing. Accordingly we object to the application of MIN13 and MIN51 within the Local Plan.
7. With regard to MIN13 and MIN51, we note the National Planning Practice Guidance which considers the circumstances under which it is appropriate for planning authorities to focus on extensions to existing sites rather than new sites.
This guidance goes on to identify the need for the mineral in the specific representation; the economic considerations; the positive and negative environmental impact; and accumulative impact of proposals in an area.
8. We consider that the NPP guidance as set out above therefore fully supports our contention that you should support MIN12 but reject MIN13 and MIN51.
9. Immediately due south of MIN13 and MIN51 is an allocation referred to as MIN08 which we understand has been put in by the landowner. This site does include land owned by the Gressenhall Poors Charity and the extent of the Charity's ownership is shown on the enclosed plan being towards the northern end of MIN08.
10. Gressenhall Poors Charity has made no representation to the Minerals Local Plan and no doubt the Trustees of that Charity will write and confirm this point to you.
11. Notwithstanding that point, we object strongly to the allocation of MIN08 in principle since it is wholly premature and far too close to the village of Gressenhall to be appropriate.
12. We question whether there is sufficient mineral within the field to justify extraction but in any event it is most certainly premature but it is also inappropriate mindful of its location.

I noticed the Planning Notice on the Traffic Sign post plus the map in Chapel Lane Beetley and it looks to us that MIN 12 Grid Ref X: 5968 Y: 3181 is the field opposite our Chapel. We have had no other information given to us until a neighbour let us see the letter sent to him.
I recall we wrote to you in 2011 in which we set out our objections to the Plan at the time and this new area seem to be even closer. As mentioned then we were built in 1871 and are now looking forward to our 150th Anniversary in 2021. The heavy traffic would have a detrimental effect on the structure of the chapel as well as the danger posed to the congregation. We are still a very active church as part of the Central Norfolk Methodist Circuit and hold numerous services, at least six each month and meetings of all kinds throughout the week. We also hold Weddings and Funerals and our Chapel is open to people of all ages.
We are not sure where any entrance to the site would be but the road outside the chapel would require a lot of improvements to support heavy plant.
As Trustees of this much loved Chapel we have a responsibility to continue the work started in 1871 in praise of our Lord and to keep up the work they started with a view to the future worship in this Community as in the past.
I enclose a copy of the letter sent to you in August 2011.

Letter of August 2011:
Thank you for your letter of 13th June 2011 regarding the further round of consultations on the "Revised Further Issues and Options" regarding the above. Looking at the extended allocation site MIN 10a this would, as mentioned in our letter of 22nd April 2008 have a severe effect on the Methodist Chapel in Beetley on the corner of High House Road and Chapel Road.
This site would be just across a narrow road from the Chapel built in 1871 with no more than a "pathway" from the road, directly opposite the front door making a very dangerous situation with heavy vehicles unable to turn.
The environmental impact on the building would be detrimental as a result of dust, noise, and especially the vibration and movement of the heavy vehicles and plant machinery. AS mentioned before many of our congregation can remember the effect that heavy lorries have had on the structure of the building as they passed on High House Road.
We are now part of the larger Central Norfolk Methodist Church and are a very active Church with the building being used a lot more during the week than in 2008. We hold "drop in" meetings during the day attended by many elderly people who require transport but we are also open to all ages including children during holiday times.
It also has to be remembered that as a Church we hold funerals and weddings during the day and our congregation has remained steady in numbers for several years. Coffee mornings have also proved very successful. Our much loved Church is open to everyone who wishes to worship with us and we hop to pick up this role from the generations that have gone before and continue well into the future.
In the current climate our Church has been actively looking into becoming an ECO Church along with others in the Circuit and a mineral extraction site within feet of it will not be very environmentally friendly!
As mentioned in 2008 many of our congregation live in Beetley and East Bilney and hold their own personal views on these proposals. However, in this letter we once again set out concerns as a Church on how the plans will effect a building which is here for the community.

Please find below the response to the Waste and Mineral Local Plan Consultation from Gressenhall Parish Council:

1. You have kindly drawn our attention to the consultation on the Norfolk Minerals and Waste Local Plan.
2. This response is on behalf of Gressenhall Parish Council whose interest is in MIN12; MIN13; MIN51 and MIN08.
3. We note that MIN12 is put forward by Middleton Aggregates as an extension to their existing operation which will take mineral back to their long established plant site due north of Gressenhall Village. We note that this has estimated minerals of well in excess of 1million tonnes and that this allocation will enable the Middleton Aggregates pit to continue to be served well beyond the plan period to 2036. As such we do not have an objection with this allocation.
4. MIN13 and MIN51 have been put forward by a different mineral operator on the basis that the new operator would need to establish its own plant on site.
5. Given that Middleton Aggregates are operating a pit immediately next door and mindful also of the existence of a second independent mineral operator namely McLeod Aggregates who are based approximately 2 miles away on the western side at Bittering, we see no case whatsoever for the introduction of a third operator in this location.
6. By definition there is plenty of competition in existence already with two operators able to service the local market and we see no case for that situation changing. Accordingly we object to the application of MIN13 and MIN51 within the Local Plan.
7. With regard to MIN13 and MIN51, we note the National Planning Practice Guidance which considers the circumstances under which it is appropriate for planning authorities to focus on extensions to existing sites rather than new sites.
This guidance goes on to identify the need for the mineral in the specific representation; the economic considerations; the positive and negative environmental impact; and accumulative impact of proposals in an area.
8. We consider that the NPP guidance as set out above therefore fully supports our contention that you should support MIN12 but reject MIN13 and MIN51.
9. Immediately due south of MIN13 and MIN51 is an allocation referred to as MIN08 which we understand has been put in by the landowner. This site does include land owned by the Gressenhall Poors Charity and the extent of the Charity's ownership is shown on the enclosed plan being towards the northern end of MIN08.
10. Gressenhall Poors Charity has made no representation to the Minerals Local Plan and no doubt the Trustees of that Charity will write and confirm this point to you.
11. Notwithstanding that point, we object strongly to the allocation of MIN08 in principle since it is wholly premature and far too close to the village of Gressenhall to be appropriate.
12. We question whether there is sufficient mineral within the field to justify extraction but in any event it is most certainly premature but it is also inappropriate mindful of its location.

Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 35 - land at Heath Road, Eccles, Quidenham)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 35 for the reasons outlined below.

Landscape
Following the initial findings of the Preferred Options Consolation a Landscape and Visual Statement was commissioned and completed by Collington Winters in October 2019. The report demonstrates and concludes that the site would have acceptable local landscape impacts and that the screening would not be intrusive in its own right. The report also recommends that it will be possible to mitigate adverse landscape impacts through advance planting and bunding.

It is highlighted in the enclosed Landscape and Visual Statement that the proposed site is not located within the AONB, a Core River Valley or any other designated landscape features. It must be noted that unlike MIN 69 - land north of Holt Road, Aylmerton, MIN 211 - land west of Bath Hills Road, Earsham (Extension area 3) which is adjacent to the boundary of the Broads Authority Executive Area and MIN 25 - land at Manor Farm (between Loddon Road and Thorpe Road), Haddiscoe which is adjacent to a Core River Valley and also is adjacent to the boundary of the Broads Authority Executive Area).

The enclosed report also demonstrates that the existing landscape detractors mean that the proposed site cannot be considered a tranquil, unspoilt area of the countryside.
The proposal sets the limit of extraction approximately 150 metres from the southern boundary of the site, so as to allow the site to be screened in a way which would not be significantly detrimental to the views from the immediate south. Existing bunding associated with the historic landfill is present which already screens out long-range views for properties to the south of the proposed site.
The proposed new bunding associated with the MIN 35 development will be set back from the southern boundary so as to not have an adverse effect on views over the field and the woodland to the west from those properties to the south of the site. The proposed limit of extraction means that there would be less difference between the views of the existing bunding associated with the historic landfill and those of new bunding associated with this proposed development from the south and southeast of the site.

Screen bunding and advance hedge planting is proposed along the site boundary on Heath Road to ensure that users of Heath Road are not able to gain medium-to-long-range views across the site, including the existing partially screened timber yard opposite the area of the site not proposed to be worked.

Any future application for mineral extractions at this site will be accompanied with a
further carefully designed landscape scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents. Substantial buffer zones are proposed comprising advanced planting of woodland copses and planting belts, that are to be retained within the site restoration, and screen bunds in place surrounding the immediate area proposed for mineral extraction.

The temporary bunds are proposed to be of adequate height to screen the upper story views from housing and it will be ensured that the grading, profiles appearance and management of vegetation on the temporary bunds will benefit from careful treatment. These mitigation requirements shall be followed to ensure that the screening features are not visually intrusive as it is recognised that residents may have views of these across the existing agricultural fields to the east and southwest of the site, and also from the adjacent road.

I therefore wish to object to the conclusions reached in terms of considering MIN 35 unsuitable for allocation in landscape terms, as following a review of baseline information, together with consideration of likely landscape and visual effects, it is considered that the application site and wider landscape is able to accommodate the proposal for mineral extraction, in landscape and visual terms, without having an unacceptable effect or loss of landscape character or visual amenity. Any loss of landscape character would be temporary and upon restoration, character would be reinforced and enhanced.

Provision for minerals extraction (Policy MP1)
The NPPG suggests that the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision. The sub-national guidelines are for Norfolk to produce 2.57 million tonnes of sand and gravel a year.
It has been considered by the MPA that planning to provide the 20-year average annual production figure would enable a sufficient quantity of sand and gravel resources to be available over the 18- year plan period and would take into account potential fluctuations in the economy.
Over the 18-year plan period to 2036, using the considered suitable 20-year average of 1.868 million tpa, 33.624 million tonnes of sand and gravel resources would be needed in total. Taking into account the existing permitted reserve, the remaining need for allocated sites is 20.313 million tonnes of sand and gravel.
However, using the sub-national guidelines for sand and gravel, as specified in the NPPG this would mean that sites for 32,949,300 tonnes of sand and gravel extraction would need to be allocated over the plan period. The sub-national guideline figures cover the period 2005-2020 and therefore remains current at this stage of the Consultation process, and must remain so until these figures are updated. Therefore, a stronger case has to be made by the MPA as to why they consider the current subnational guidelines not to be relevant in producing this plan and more specifically the landbank figure required in the Plan period to the end of 2036. Furthermore, may I raise the question to the MPA as to what the justification is for using a 20-year average annual production figure, rather than a 25-year
average or likewise 18-year to cover the remainder of the plan period, for example?

I therefore wish to object to the methodology used in establishing the required tonnages of sand and gravel resource to be allocated within the Plan period to the end 2036 as referred to in Policy MP1: Provisions of minerals extraction. The 20-year average methodology has not been accepted as a valid methodology for establishing this figure and therefore should not be considered as sound. This is demonstrated by the NPPG which considers that only the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision.

I would consequently like to object to this figure in relation to MIN 35, which at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review was considered as suitable for allocation based on the proposed 20-year average annual production figure in August 2018.

However, the current proposed allocation figure less than 18 months later is greatly reduced and is considered the only reason for the site to now be considered as unsuitable, due to the fact that the proposals have not changed in terms of the site development since that date.

Suitability of alternatives considered as suitable for allocation
There are a number of sites that have been considered suitable for allocation in the Norfolk Minerals and Waste Local Plan Review that are very similar to MIN 35 in terms of their potential impact on the local landscape from viewpoints from surrounding sensitive receptors. The table below and subsequent consultation extracts identifies and breaks down each site in terms of the number of sensitive receptors within 250m and 100m of the proposed extraction area compared with MIN 35, respectively. Therefore, on a logical comparative basis MIN 35 sits within the top three of the proposed sites with the least number of sensitive receptors.

INSERT TABLE

MIN 210 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from Park Farm Cottages will predominantly be screened by bunding"

MIN 211 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from nearby properties will predominantly be screened by bunding"

MIN 65 "glimpses of the land can be seen from Frettenham Road to the west through gaps in boundary hedges. Views could also be seen from two properties which lie close to the site perimeter to the west and east respectively"

MIN 213 "views into the site may be possible from Shorthorn Road, through the proposed entrance"

MIN 25 "there are mature screen planting forming hedgerows on all sides of the site, except a section of the eastern boundary closest to Manor Farm"

MIN 12 "views of the site would be seen from Field Lane, a road used as a public path which bounds the site to the north. In addition, the southern part of the site is slightly elevated and may be visible in a long view from public paths crossing land to the north of the Whitewater valley"

MIN 209 "a number of properties back onto the road overlook the site, the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting"

The above findings were concluded by the MPA as being acceptable subject to the erection of screen bunds and advanced planting. Likewise, it is stated that any potential views of MIN 35 would require mitigation through screen bunding and advance hedge planting. Therefore, given the supporting information above, as part of the independent Landscape and Visual Statement, it is considered that the MIN 35 site should be considered suitable for allocation due to the similarities it shares in landscape terms with the above sites that themselves have been considered suitable for allocation.

Furthermore, three sites have been considered suitable for allocation that are either within or adjacent to the AONB, a Core River Valley or any other designated landscape features, namely MIN 69, MIN 211 and MIN 25. Since MIN 35 is not located within or even close to any of these designated landscape features, preference must be given to this site in planning terms as required by the
requirements of NPPF Paragraph 205.

Since the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review and additional site has come forward and is now considered as suitable for allocation in the 'Preferred Options Consultation'. This is MIN 213 land at Mansom Plantation, Stratton Strawless for a total estimated sand and gravel resource of 1 million tonnes. The site has been selected in preference to MIN 35, due to the fact that the MIN 35 site was formerly considered as suitable for allocation at the 'Initial Consultation' stage. However, it is considered that this new site (MIN 213) not only presents a similar landscape impact to MIN 35 as described above, but also represents a site that will result in the permanent loss of a well-established coniferous plantation for after use as a holiday lodge development. MIN 213 is also located adjacent to an ancient replanted woodland to which deterioration is likely to occur as a result of the mineral operation. As such, any application that concludes this unless there are wholly exceptional reasons should be refused as in accordance with NPPF Paragraph 175c. Therefore, the site cannot be considered as being suitable for allocation given this likely impact.

I therefore would like to object to the inclusion of the above sites as being considered suitable for allocation, whereas MIN 35 is considered unsuitable solely on landscape grounds. It has been demonstrated above that preference should not be given to any of these sites over and above MIN 35 and that MIN 35 should be reconsidered in light of the additional supporting landscape and visual statement and be concluded as once again suitable for allocation as at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.5 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Landscape and Visual Statement (Ref. CW0121-RPT-001), dated 30 October 2019
Ecological Scoping Report (Ref. E17864), dated 2 August 2017

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.

Original draft response received 30.10.2019
Revised response received 08.11.2019

Highway Authority comments regarding sites proposed for allocation only

MIN 12 - North of Chapel Lane, Beetley
Acceptable subject to continued use of conveyor

MIN 51 & MIN 13 - West of Bilney Road, Beetley
Acceptable subject to suitable access strategy. MIN51 to be accessed via MIN13

MIN 200 - West of Cuckoo Lane, Carbrooke
Acceptable subject to provision of acceptable access at Mill Lane along with provision of passing places between the site and the B1108. Existing haul route and Mill Lane crossing to processing plant to be utilised, or appropriate alternative to be provided. Routing agreement required along with weight limit to protect Carbrooke settlement north of the site.

MIN 202 - South of Reepham Road, Attlebridge
Acceptable subject to use of existing access at Reepham Road and lorry routing via A1270 Broadland Northway

MIN 37 - Mayton Wood, Coltishall Rd, Buxton
Acceptable subject to provision of satisfactory temporary access at C494 Coltishall Road with acceptable visibility. Local highway improvements including widening required, to be delivered via S278 agreement. Temporary access to be removed on restoration of site. Routing agreement required.

MIN 64 - Grange Farm, Buxton Rd, Horstead
Acceptable subject to provision of satisfactory temporary access at C494 Coltishall Road with acceptable visibility. Local highway improvements including widening required, to be delivered via S278 agreement. Temporary access to be removed on restoration of site. Routing agreement required.

MIN 65 - North of Stanninghall Quary
Acceptable subject to access via existing site and routing agreement.

MIN 96 - Grange Farm (between Spixworth Rd & Coltishall La), Spixworth
Acceptable subject to access via A1270 Broadland Northway roundabout at Norwich Airport. Improvements required at the roundabout to formalise access to site, along with relocation of access gates to provide sufficient space for 2 HGVs to stop clear of the roundabout. Relocation of processing plant to south of C250 Church Lane required. Removal of HGV access at Buxton Road also required.

MIN 213 - Mansom Plantation, Stratton Strawless
Acceptable subject to acceptable access at Shortthorn Road and routing agreement via A140.

MIN 206 - Oak Field west of Lynn Road, Tottenhill
Acceptable subject to access via land to north, then A10. Routing agreement required.

MIN 69 - North of Holt Road, Aylmerton
Acceptable subject to provision of right hand turn lane at A148 junction with Briton's Lane, visibility improvements at site access, improvements to Britons Lane and routing agreement, in accordance with the existing allocation.

MIN 115 - Lord Anson's Wood, North Walsham
Acceptable subject to site access being via private haul route to acceptable access at B1150

MIN 207 - Pinkney Field, Briston
Acceptable subject to continuation of existing haul route

MIN 208 - South of Holt Road, East Beckham
Acceptable subject to access via existing right turn facility. Right turn lane to be removed following completion of extraction/restoration.

MIN 209 - Adjacent to A143 (Extension Area 1), Earsham
Acceptable subject to appropriate highway access and local highway improvements at Hall Road

MIN 210 - Adjacent to A143 (Extension Area 2), Earsham
Acceptable subject to site access via Site MIN 209 along with any appropriate improvements to the local highway at Hall Road and the site access. Material conveyor required.

MIN 211 - West of Bath Hills Rd (Extension Area 2), Earsham
Acceptable subject to site access via Site MIN 209 along with any appropriate improvements to the local highway at Hall Road and the site access. Material conveyor required.

MIN 25 - Manor Farm (between Loddon Rd & Thorpe Rd), Haddiscoe
Acceptable subject to suitable access strategy either via Crab Apple Lane, or direct to B1136. Access via Crab Lane would require local highway improvements to include widening to the access and visibility at the B1136 junction in accordance with DMRB. Direct access via B1136 to include visibility in accordance with DMRB.

MIN 212 - Mundham Rd, Mundham
The Highway Authority would not wish to comment regarding the proposed mineral extraction site. However, the location of the processing site is a concern and in particular the routing of HGVs through Trowse village. It would be desirable if the material could be processed at source.

MIN 6 - East Winch Rd, Mill Drove, Middleton
Acceptable subject to use of internal haul route, existing processing facilities, acceptable visibility at access and routing agreement. The allocation would result in a continuation of turning movements at the A47, Highways England should have the opportunity to comment.

MIN 40 - East of Grandcourt Farm, East Winch
Acceptable subject to material processing at existing plant, use of existing internal haul-route required and continued use of rail for material transportation.

SIL 01 - Mintlyn South, Bawsey
Acceptable subject to extraction phased with MIN 40, submission of Transport Assessment with acceptable access strategy. Material transportation to existing processing plant via internal haul route and acceptbale crossing / conveyor of highway and utilise existing rail facilities.

AOS E - North of Shouldham
Subject to submission of Transport Assessment including delivery of acceptable highway improvements. Access to be via A143 with right turn lane with suitable levels of visibility. Access via West Briggs Drove would not be appropriate without significant improvement. Movement of material using off-highway routes, or conveyor/pipeline etc. preferred. Should material be conveyed by highway, a suitable access to the processing facility shall be provided shall be provided at B1145, to an acceptable standard including visibility. Highways England should be consulted regarding vehicle movements at Hardwick Interchange. Material extraction to be phased such that no more than one Silica site at any one time will transport material by road.

AOS F - North of Stow Bardolph
Subject to submission of Transport Assessment including delivery of acceptable highway improvements. Northern site, access via Runcton Road, widening may be required along with improvements at its junction with A10 to include right turn lane. Southern site, access to be via A10 with right turn lane with suitable levels of visibility. Movement of material using off-highway routes, or conveyor/pipeline etc. preferred. Should material be conveyed by highway, a suitable access to the processing facility shall be provided shall be provided at B1145, to an acceptable standard including visibility. Highways England should be consulted regarding vehicle movements at Hardwick Interchange. Material extraction to be phased such that no more than one Silica site at any one time will transport material by road.

AOS I - East of South Runcton
Subject to submission of Transport Assessment including delivery of acceptable highway improvements. Runcton Road would require widening along with improvements at its junction with A10, or A134 to include right turn lane. Movement of material using off-highway routes, or conveyor/pipeline etc. preferred. Should material be conveyed by highway, a suitable access to the processing facility shall be provided shall be provided at B1145, to an acceptable standard including visibility. Highways England should be consulted regarding vehicle movements at Hardwick Interchange. Material extraction to be phased such that no more than one Silica site at any one time will transport material by road.

AOS J - East of Tottenhill
Subject to submission of Transport Assessment including delivery of acceptable highway improvements. Access via A134 to include right turn lane. Movement of material using off-highway routes, or conveyor/pipeline etc. preferred. Should material be conveyed by highway, a suitable access to the processing facility shall be provided shall be provided at B1145, to an acceptable standard including visibility. Highways England should be consulted regarding vehicle movements at Hardwick Interchange. Material extraction to be phased such that no more than one Silica site at any one time will transport material by road.

Comments sought on Preferred Options Consultation on the Norfolk Minerals and
Waste Local Plan (M&WLP).
Thank you for your consultation on the above site, received on 16th September 2019.
We were previously consulted on 28th June 2018 and responded under the following
reference, FWS/18/8/6750 -2, dated 30th July 2018. Our comments at that time are
included below:
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.

Policy MW4: We welcome that this policy supports policy MW2 with the provision of flood
risk assessments (FRA) and although not specifically stated we assume that this policy's
intention is that any FRA will include appropriate consideration of the most up to date
climate change allowances.
It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts
should be considered during a planning application and appropriate measures. These
measures may not be required until reinstatement when post development ground levels
are considered in detail.

With regard to specific sites put forward we have the following comments:

MIN12 - Beetly - We would like to highlight that we are aware of reports of external
flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.

MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems

SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

It is noted that our recommendation that policy MW2 is changed for point d) to
include groundwater flooding has not been taken forward. Our advice remains that
this should be changed.

Our comments on MW4, MIN12, MIN37 and SIL02 also remain.