MIN 51 & MIN 13 - land west of Bilney Road, Beetley

Showing comments and forms 1 to 9 of 9

Comment

Preferred Options consultation document

Representation ID: 94423

Received: 22/10/2019

Respondent: Beetley parish council

Agent: Mr B Leigh

Representation:

Parish Council, whilst accepting this is a suitable site for gravel extraction, concerned regarding the start date of 2020. There is already a gravel site within Beetley/East Bilney which an extension has been requested for in this consultation. It feels that Sites MIN51 and MIN13 should not commence extraction until the existing site MIN12 has finished. This is to ensure there are no additional transport movements through Beetley/East Bilney. The assessment states that there would be 10 out per day a total of twenty for the site. All 20 would be in addition to the 30 movements planned for MIN12.

Full text:

Parish Council, whilst accepting this is a suitable site for gravel extraction, concerned regarding the start date of 2020. There is already a gravel site within Beetley/East Bilney which an extension has been requested for in this consultation. It feels that Sites MIN51 and MIN13 should not commence extraction until the existing site MIN12 has finished. This is to ensure there are no additional transport movements through Beetley/East Bilney. The assessment states that there would be 10 out per day a total of twenty for the site. All 20 would be in addition to the 30 movements planned for MIN12.

Support

Preferred Options consultation document

Representation ID: 94619

Received: 25/10/2019

Respondent: Longwater Gravel Co. Ltd.

Representation:

Summary: Longwater Gravel fully supports the allocation of MIN 51/MIN 13 - land west of Bilney Road, Beetley in the Norfolk Minerals and Waste Local Plan, but asks that MIN 08 is also allocated as it is likely, due to the anticipated closure of Coxford Abbey Quarry, that MIN 51/MIN 13 will be worked at a higher annual output and will therefore exhaust reserves before the end of the plan period.

Longwater Gravel fully supports Norfolk County Council's proposal to include MIN 51/MIN 13 as a preferred site in the Norfolk Minerals and Waste Local Plan review. Longwater Gravel also supports the detail of the Specific Site Allocation Policy for MIN 51/MIN 13.

A separate response setting out the justification for the inclusion of MIN 08 within the Norfolk Minerals and Waste Local Plan has been submitted under MIN 08 - Land North of Stoney Lane, Beetley. Longwater Gravel are now the preferred operator for working this site and consider that MIN 08 will be required to maintain sand and gravel supply towards the end of the Plan period and forms a logical extension to mineral extraction in areas MIN 51 and MIN 13.

Longwater Gravel intends to submit a planning application to seek permission to extract sand and gravel from MIN 13, MIN 51 and MIN 08 as a combined site as opposed to three separate individual sites operating at the same time. Processing activities, i.e. washing, screening, crushing, etc. of sand and gravel would only take place on MIN 13. Initially, the output of sand and gravel from MIN 13 will be 70,000 tonnes/year. From 2027, due to the anticipated closure of Coxford Abbey Quarry, the output of sand and gravel from MIN 13 will rise to 110,000 tonnes/year.

HGV movements would be restricted to MIN 13 only with access to and from the road network using an entrance road from MIN 13 onto Rawhall Lane at the northeast corner of the site. No HGV's will be required to access MIN 51 or MIN 08. Initially, HGV movements will be around 10 per day from the site with this rising to 15 from 2027.

Whilst extraction takes place in MIN 13, MIN 51 and MIN 08 would be retained in agricultural use. Only when mineral reserves have been exhausted in MIN 13 would extraction commence in MIN 51 and only when mineral reserves have been exhausted in MIN 51 would extraction commence in MIN 08. During the mineral plan period, the timescales for working the three sites is anticipated to be as follows:

MIN 13: 2020 - 2027
MIN 51: 2028 - 2032
MIN 08: 2033 -

During the extraction phases, all three sites would be progressively restored and the land returned to agricultural use along with appropriate biodiversity/habitat creation. Only the operations area in MIN 13 would remain unrestored until mineral extraction from the final phase of MIN 08 is completed.

Full text:

Longwater Gravel fully supports Norfolk County Council's proposal to include MIN 51/MIN 13 as a preferred site in the Norfolk Minerals and Waste Local Plan review. Longwater Gravel also supports the detail of the Specific Site Allocation Policy for MIN 51/MIN 13.

A separate response setting out the justification for the inclusion of MIN 08 within the Norfolk Minerals and Waste Local Plan has been submitted under MIN 08 - Land North of Stoney Lane, Beetley. Longwater Gravel are now the preferred operator for working this site and consider that MIN 08 will be required to maintain sand and gravel supply towards the end of the Plan period and forms a logical extension to mineral extraction in areas MIN 51 and MIN 13.

Longwater Gravel intends to submit a planning application to seek permission to extract sand and gravel from MIN 13, MIN 51 and MIN 08 as a combined site as opposed to three separate individual sites operating at the same time. Processing activities, i.e. washing, screening, crushing, etc. of sand and gravel would only take place on MIN 13. Initially, the output of sand and gravel from MIN 13 will be 70,000 tonnes/year. From 2027, due to the anticipated closure of Coxford Abbey Quarry, the output of sand and gravel from MIN 13 will rise to 110,000 tonnes/year.

HGV movements would be restricted to MIN 13 only with access to and from the road network using an entrance road from MIN 13 onto Rawhall Lane at the northeast corner of the site. No HGV's will be required to access MIN 51 or MIN 08. Initially, HGV movements will be around 10 per day from the site with this rising to 15 from 2027.

Whilst extraction takes place in MIN 13, MIN 51 and MIN 08 would be retained in agricultural use. Only when mineral reserves have been exhausted in MIN 13 would extraction commence in MIN 51 and only when mineral reserves have been exhausted in MIN 51 would extraction commence in MIN 08. During the mineral plan period, the timescales for working the three sites is anticipated to be as follows:

MIN 13: 2020 - 2027
MIN 51: 2028 - 2032
MIN 08: 2033 -

During the extraction phases, all three sites would be progressively restored and the land returned to agricultural use along with appropriate biodiversity/habitat creation. Only the operations area in MIN 13 would remain unrestored until mineral extraction from the final phase of MIN 08 is completed.

Support

Preferred Options consultation document

Representation ID: 94637

Received: 25/10/2019

Respondent: Longwater Gravel Co. Ltd.

Representation:

Longwater Gravel has now been successfully granted a licence by the Environment Agency to abstract water 25,000m3/year for mineral washing from a borehole located and installed at MIN 13. Licence number AN/034/0011/079.

Full text:

Longwater Gravel has now been successfully granted a licence by the Environment Agency to abstract water 25,000m3/year for mineral washing from a borehole located and installed at MIN 13. Licence number AN/034/0011/079.

Object

Preferred Options consultation document

Representation ID: 95014

Received: 30/10/2019

Respondent: Mr Mark Kiddle-Morris

Representation:

If this combination of sites were to be allocated and the operators intent to commence extraction from 2020 were realized there would potentially be 2 processing plants and 2 quarry entrances within a very small area. There would also be an increase in HGV movements accessing the B1146 at the same point as the existing operation. The cumulative impact of the 2 adjacent operations would be unacceptable.
Should these sites be allocated the start date should be beyond the finish date of the operation of MIN 12, this may be beyond the plan period. Any planning granted on these sites should condition a speed limit reduction on the B1146

Full text:

If this combination of sites were to be allocated and the operators intent to commence extraction from 2020 were realized there would potentially be 2 processing plants and 2 quarry entrances within a very small area. There would also be an increase in HGV movements accessing the B1146 at the same point as the existing operation. The cumulative impact of the 2 adjacent operations would be unacceptable.
Should these sites be allocated the start date should be beyond the finish date of the operation of MIN 12, this may be beyond the plan period. Any planning granted on these sites should condition a speed limit reduction on the B1146

Object

Preferred Options consultation document

Representation ID: 98276

Received: 30/10/2019

Respondent: Mr & Mrs R Beazley

Number of people: 2

Representation:

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.

Full text:

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.

Object

Preferred Options consultation document

Representation ID: 98587

Received: 09/10/2019

Respondent: Gressenhall parish council

Representation:

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.

Full text:

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.

Support

Preferred Options consultation document

Representation ID: 98678

Received: 30/10/2019

Respondent: Norfolk Wildlife Trust

Representation:

We support the creation of new wet woodland habitat around retained wetland areas, as well as new hedgerows and oak standards alongside the northern boundary.

Full text:

Norfolk Minerals & Waste Local Plan Review 2019

Policies
Vision
* We support the progressive restoration schemes and enhancement of Norfolk's biodiversity. Where the third paragraph makes reference to the enhancement of Norfolk's biodiversity, we recommend this is expanded to incorporate the upcoming mandatory requirement for biodiversity net gain, as set out in the Environment Bill and supported by the NPPF.
* Recognising the negative impacts a changing climate will have on the future for wildlife in Norfolk, we recommend that the Vision's target for minimising the impact of minerals development and waste management on climate change is made more ambitious, by changing it to at least a target of net zero or net positive where possible. Opportunities exist for gains for both wildlife and carbon sequestration through appropriate habitat restoration and creation as part of proposals, as already noted in Minerals Strategic Objective MS08.

MW2 - Development Management Criteria
* We support the policy requirement to ensure that development will not have a damaging effect on the natural environment, in particular for locally designated sites (I.e. the County Wildlife Site network).
* However, the aim of the policy appears to focus on a no net loss principle, with enhancements only being sought 'where appropriate'. We recommend that in order to conform with the NPPF, the policy makes reference to the requirement for biodiversity net gain. Reference can also be made to the recent publications by DEFRA on its implementation.

MW4 - Climate change adaptation and mitigation
We support the inclusion of targets for emissions minimisation and renewable energy provision. Given the overlap between new habitat creation, the upcoming mandatory provision of biodiversity net gain and carbon sequestration, we recommend that the policy and supporting text is expanded to note the role habitat creation and restoration can provide in climate change mitigation.

MP2 - Spatial strategy for minerals extraction
We recommend that in addition to the existing defining areas of search, that County Wildlife Sites are also excluded from the Areas of Search for silica sand extraction. We are concerned at the overlap between some proposed minerals sites and the County Wildlife Site network and we do not believe that allocating minerals extraction on CWSs is compatible with the plan's Vision to enhance Norfolk's biodiversity.

MP5 - Core river valleys
We support the approach taken by this policy to safeguard these important key corridors for wildlife through the county, in particular through the requirement for development in these areas to demonstrate that it will enhance the biodiversity of the river valley either immediately or on restoration.

MP7 - Progressive working, restoration and after-use
* Notwithstanding any site specific concerns regarding loss of wildlife sites or indirect impacts (e.g. dust and hydrology), we strongly support the restoration of mineral sites to priority habitats. Such measures offer a rare opportunity to create new habitats that can help Norfolk's wildlife recover from the significant and ongoing declines which it faces.
* Restoration plans should be included at the planning application stage to ensure that the strategic contribution of the site to landscape scale conservation and delivery of biodiversity net gain can be considered.
* Wherever possible, restoration proposals should be matched to existing priority habitats in proximity, to allow for greater connectivity through the landscape for local species. This will also help create a more permeable landscape for the movement of species' ranges in response to climate change in the future.
* Wherever possible, if there is the potential for native species seeds to be present in the seed bank at the start of the working period, then such soils should be stored appropriately to ensure that it can be used in any restoration scheme and allow for recolonization by native flora.

MP8 - Aftercare
We support the aftercare of restored mineral sites in order to ensure that their target habitats are achieved. We strongly support the requirement for longer aftercare provision to ensure successful establishment and maintenance of the approved after-use. As habitat creation/ restoration offers the opportunity to also provide carbon sequestration and contribute to climate change mitigation targets, their establishment may also require longer aftercare periods to demonstrate successful delivery.

Minerals Site Allocations

Silica Sand

MIN40
* We note the potential dewatering risk to East Winch Common SSSI and CWS 140 East Winch Common. This site should only be included in the plan if the Council is confident that such issues can be dealt with satisfactorily through hydrological studies at planning permission, in order to avoid risks to delivery of the plan.
* We therefore support the recommendation that any permission will require a detailed hydrological assessment to determine the safe extent of working that can occur without risking impacts on nearby SSSIs and CWSs.
* We recommend that the restoration proposals include heathland due to the proximity to heathland habitats on East Winch Common, as this will provide ecological connectivity and allow for more movement of wildlife through the landscape.
* The site also has the potential to provide new green infrastructure for the adjoining settlement through provision of wildlife rich public open space as part of restoration proposals.

SIL01 (land at Mintlyn South Bawsey)
* During the previous consultation phase we highlighted that part of the proposed allocation overlaps with CWS 416 '70 & 100 Plantations' and recommended that these areas are safeguarded. The supporting text correctly identifies potential adverse impacts to this CWS and the adjacent CWS 418 Haverlesse Manor Plantation, but makes no attempt to safeguard these. The most appropriate way to ensure that impacts to the CWS are avoided is to exclude it from the minerals allocation, therefore we strongly recommend that CWS 416 is completely excluded from the proposed allocation. In addition, in order to safeguard from any indirect impacts to CWS from impacts such as dust, any allocation would need to include a non-worked buffer between it and both CWS.
* We support the recommendations in the policy text for noise, dust, air quality and hydrology assessments which will help inform ecological assessments of potential impacts on nearby wildlife sites. We recommend that any restoration plan ensures that the existing ecological connectivity between the adjacent wildlife sites is maintained through progressive working and that restoration post-extraction complements the adjoining habitats.
* We also note in the supporting text that the land use of the proposed allocation is classed as non-agricultural land, however we understand that this is likely to be incorrect as the southern part of the site has been in regular use as grazed grassland for at least twenty years. This area is likely to be of ecological significance, with anecdotal records of several protected species present as well as a number of mature oak trees on the southern boundary. In the absence of further information on the ecological value of this area and the potential impacts on a range of protected species (and any consequent impacts on delivery) as a precaution we recommend that this part of the site is removed from the allocation.

AoS E
* We are concerned at the large scale of this AoS and its proximity to multiple CWS. Any application within the AoS would need to be accompanied by a detailed ecological appraisal and hydrological assessment where appropriate.
* Mow Fen CWS is within the AoS and not suitable for minerals extraction, therefore we strongly recommend its removal from AoS and the provision of a buffer around it to avoid impacts such as dust.
* The AoS lies adjacent to CWS 373, species-rich grassland which will need buffering from the AoS.

AoS F
* We note the proximity of the northern area of the AoS to CWS 365, Broad Meadow Plantation. We strongly recommend a stand-off or buffer between any proposal in the AoS and the CWS in order to safeguard from indirect impacts.
* Proposals in proximity to any CWS would need to be accompanied by dust and hydrology assessments.
* We note from the maps provided that there appear to be a high number of ponds within the AoS and in the wider landscape. The potential for impacts on protected species and the likely requirements for ecological restoration will need to be considered as part of any application in this AoS.

AoS J
Due to the proximity to wildlife sites, we support the requirement for ecology and hydrology assessments as part of any application within this AoS.

SIL02 - land at Shouldham and Marham (silica sand)
Due to the unknown potential scale of minerals development that this Area of Search would support and the number of CWS in close proximity in particular Marham Fen CWS, we are concerned at the potential for significant impacts on wildlife and therefore support the Council's recommendation that this site is not progressed in the plan.

Carstone

MIN6 - Land off East Winch Road, Mill Drove, Middleton
We support the working of this site dry to avoid hydrology impacts, and the proposed restoration of this site to heathland habitat.

Breckland

MIN51&MIN13
We support the creation of new wet woodland habitat around retained wetland areas, as well as new hedgerows and oak standards alongside the northern boundary.

MIN200
We support the restoration proposals for this site.

MIN 102
We support the exclusion of this site from further consideration in the plan due to the adverse impacts likely on the adjacent Swangey Fen SSSI, a component of the Norfolk Valley Fens SAC.

Broadland

MIN202
* We previously raised concerns that this allocation overlaps with CWS 1344 'Triumph and Foxburrow Plantations' and repeat our recommendation that, in order to safeguard the CWS, the allocation boundary should be modified, with a stand-off area between any mineral working and wildlife sites (the CWS and ancient woodland at Mileplain Plantation) in order to mitigate for any indirect impacts such as dust.
* We support the restoration to a mosaic of acid grassland, woodland and wetland [check policy text] and recommend that the potential for heathland to be added.

MIN37 & MIN64
We hold no specific information on the proposed sites MIN 37 and MIN 64, but note their proximity to two County Wildlife Sites and strongly recommend that any restoration proposals for these sites, if allocated, are targeted to match wherever possible the habitats present in the nearby CWS in order to maximize ecological connectivity.

MIN96
We note the proximity to CWS 2205, Spixworth Bridge Meadows, and CWS 1396, Spixworth Meadows, and support the requirement for this site to only be worked dry in order to avoid any potential impacts on the CWSs through changes in local hydrology. We also support the requirement for a dust assessment.


MIN213
* We note that this allocation is adjacent to CWS 2204, Hevingham Park, a replanted ancient woodland with pingos and rich ground flora in places, as well as an additional area of ancient woodland outside the CWS. These habitats will be vulnerable to typical impacts from minerals operations and any application will need to be supported by a dust assessment, with appropriate mitigation including vegetative screening for the extraction period.
* The policy text indicates that the site would be worked wet. We support the policy requirement for a hydrogeological assessment to be provided as part of any application, and note this should also cover impacts on the ecology of adjacent wildlife sites. In addition, we also recommend that the Council will need to be sure that the site can be worked wet without leading to adverse impacts on adjacent wildlife sites (after mitigation) in order to ensure that it is deliverable.
* We support the restoration proposals to heathland where opportunities around the existing holiday park consent allow.
* We have been made aware of the likely presence of great crested newts on the site. In addition, given the extensive woodland on site, the presence of other protected species such as bats are also likely. As a result we would expect any application to be accompanied by a detailed ecological appraisal. Should such populations be present, then any progressive working programme is likely to require retention of sufficient areas of habitat at any one time to allow for their retention.
* Given the proximity of pingos to the north, the potential for this site to include pingos should also be investigated.

MIN48
Due to the proximity to Swannington Upgate Common SSSI and likely impacts, we support the removal of this from the plan.

Great Yarmouth

MIN38 - land at Waveney Forest, Fritton
We support the exclusion of this site from further consideration in the plan due to the likely impacts on the Waveney Forest and Fritton Warren South County Wildlife Sites (CWS), in particular the remnant heathland elements of the Forest and the adjoining wetland habitats at Fritton Warren. Should the Council proceed with this site in the plan, then we would expect further evidence on ecology and hydrology to demonstrate that it is deliverable whilst avoiding impacts on the adjacent CWSs. Given the potential for the areas adjacent to the CWSs to support protected species and be of similar ecological value, any application would need to be accompanied by detailed ecological and hydrological appraisals, including restoration plans that complement the adjacent wildlife sites.

King's Lynn & West Norfolk

MIN 206 - land at Oak Field, west of Lynn Road, Tottenhill
We support the requirements for hydrological assessment in the supporting text as part of any ecological appraisal accompanying an application for this site, and recommend that this is also included in the policy text for clarity.

MIN 45
We support the exclusion of this site from further consideration in the plan due to its location on ancient woodland, defined as an irreplaceable habitat in the NPPF.

MIN19&205
We support the exclusion of these sites from further consideration in the plan due to the proximity to the River Nar SSSI.

MIN74
We support the exclusion of this site from further consideration in the plan due to the adverse impacts predicted on wildlife sites.

MIN77
We support the exclusion of this site from further consideration in the plan due to the adverse impacts predicted on wildlife sites.

North Norfolk

MIN69 - north of Holt Road, Aylmerton
Whilst we are unable to comment on the wider impacts of this proposal as they are outside of our remit, should this site be progressed, then we strongly support the Council's recommendations that this site should only be worked dry in order to avoid hydrological impacts on the nearby Norfolk Valley Fens SAC and be subject to high quality restoration and formal aftercare, creating a large new area of heathland with benefits both for wildlife and green infrastructure provision. We support the precautionary requirement for noise and dust assessments as part of any application in order to evaluate potential impacts on nearby wildlife sites and the requirement to demonstrate that adverse effects on the Norfolk Valley Fens SAC would be avoided.

MIN115 - land at Lord Anson's Wood, near North Walsham
Due to the proximity of two SSSIs and Weaver's Way County Wildlife Site (CWS) which include wetland habitats, the site should only be worked dry in order to avoid any impacts. We support the requirement for dust assessments and identification of appropriate mitigation measures to ensure that nearby CWSs are not impacted by this allocation. We support the proposed restoration to woodland and heathland and recommend that restoration proposals are secured as part of any application.

MIN207 - land at Pinkney Field, Briston
We note the proposed restoration to reservoir and agricultural grassland which we understand is linked to existing adjacent planning consents. However, we recommend that any allocation should demonstrate it can deliver biodiversity net gain in its own right and should include sufficient areas of priority habitats as set out in policy MP7 (see supporting text MP7.5, for example woodland and heathland) to ensure this can be delivered in addition to compensating for displaced features from existing consents.

MIN208 - land south of Holt Road, East Beckham
We support the proposed restoration of the site to a mosaic of native woodland, scrub and acid grassland.

MIN71- land west of Norwich Road, Holt
We agree with the Council's evaluation that this site is unsuitable for allocation due to the likely impacts to Holt Lowes SSSI, a component of the Norfolk Valley Fens SAC, as well as to the multiple County Wildlife Sites in close proximity. In the absence of a detailed hydrological assessment it is not clear that this site can be worked without an adverse effect on the SAC, therefore there is a risk that the site would not be deliverable if retained in the plan.

South Norfolk

MIN209
We support the proposed restoration scheme for this site.

MIN210
We support the proposed restoration scheme for this site.

MIN211
* We support the requirement for dust assessment and mitigation proposals as part of any application given the proximity to CWSs and ancient woodland.
* We support the proposed restoration scheme for this site.

MIN25
* We support the requirement for dust and hydrology assessments and mitigation proposals as part of any application given the proximity to CWSs.
* We support the proposed restoration scheme for this site.

MIN212
We support the proposed restoration scheme for this site.

MIN92
We support the exclusion of this site from further consideration in the plan due to the adverse impacts predicted on wildlife sites.

Object

Preferred Options consultation document

Representation ID: 98796

Received: 30/10/2019

Respondent: Historic England

Representation:

There are no designated heritage assets on site. The grade II* church of St Peter, Manor Farmhouse listed t grade Ii and a scheduled monument (a deserted medieval village) lie to the west of the sites whilst to the north of the site lies East Bilney and several listed buildings, the closets of which is the grade II listed Almshouses.
We welcome the reference in paragraph M51.3 - 51.5 to the nearby heritage assets and the need to provide a heritage statement to identify appropriate mitigation with any planning application. We also welcome the reference in the policy to this. The policy could be improved by including specific reference to the nearest heritage assets We also welcome the reference to archaeology requirements in the policy and supporting text.

Suggested change: Include specific reference to the nearest heritage assets to read 'heritage assets and their settings (including...)

Full text:

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.

Comment

Preferred Options consultation document

Representation ID: 98832

Received: 30/10/2019

Respondent: Norfolk County Council - Highway Authority

Representation:

Acceptable subject to suitable access strategy. MIN 51 to be accessed via MIN 13.

Full text:

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.