MIN 35 - land at Heath Road, Eccles, Quidenham

Dear sir,I and my Husband are writing to object to the mineral extraction for the following reasons:
1) At 29 mtrs we are the 2nd closest property & downwind, to the site. My Husband [redacted text - personal data] the dust would be extremely detrimental to his health.We have lived here for 43 years & hoped to spend our later years in peace, not confined behind closed doors because of the noise & dust from our 'neighbours'
2) The highway access at the top of Heath Road id NOT suitable,it comes out on to a 45 degree bend,with the Snetterton Recycling Site directly to the right.A commercial Wood Yard is on the left. Putting an exit roadfurther along would bring it out onto a blind bend (we have had 2 seroius accidents in the last 5 years) Heath Road is a narrow (7 FEET, 2.1 meters wide) no through road. Our only vehicular access is the top of the road. We cannot get out, there is a pedestrian-only railway crossing at the bottom of the road. Heath Road is on the National Cycling Route. We get a lot of cyclists up & down. Also dog walkers use the road & field.
3)Heath Road is an historic site, the Railway Cottage at the bottom of the road was built when the railway was built, but it is built over foundations dating back to the 1600's.
4) Utilities infrastructure: down Heath Road there are 3 x 11000volt cables & the Fibre Optic Cable, both connecting to the Snetterton Circuit & industrial sites. Also across the top of the road (at right angles to Heath Road) Run the main cables connection the Straw Burning Plant at Snetterton to the substation at Diss.
5) Hydrogeology:The South side of the old landfill site is unlined & filled with chicken carcasses from the Edwina Curry Salmonella debar cal. The leachate is monitored regularly down Heath Road. But as the site is adjacent to & downhill from, the old unlined site it could pose a very unpleasant public health issue. Heath Crossing Cottage, at the bottom of Heath Road, has ONLY a private water supply , by way of a borehole, into the aquafer in the chalk seam. The Cottage is DEPENDENT on this water supply. This borehole water supplies 3 dwellings, There is NO Anglian water to the cottage. We believe this development would compromise the integrity of our Borehole.
6) My Husband & myself are not happy with this proposed site, it would impact hugely on our quality of life, we would see it, hear it, smell it & feel it, all at very close quarters. As owner & Landlady of Heath Crossing Cottage, I am LEGALLY responsible for the quality of the water supply to the cottage. I have it tested & certified regularly. The developer of the site must take full responsibility for the quality of the water from our borehole. If it fails the testing I am going to be unable to let it, so the will also be loss of income.
Signed: Mr & Mrs Lentin, Wood View, Heath Road, Eccles, Norfolk, NR16 2PD

I am emailing you through my secure work account because I can't work out how to lodge an objection through the website.

I wish to lodge my objections with regards to the proposed MIN 35, located on Heath Road, Eccles, NR16 for the following reasons:
1) The road is very narrow and only accommodates one car (there are no passing places) along the length. If there are any lorries blocking the road, this is our only exit.
2) Unsuitable junction. The sharp bend at the point of access is dangerous and vision is poor. The extra lorry movement would constitute an accident risk.
3) We need access at all times because I am a shift worker, my husband works as a lorry driver. In addition to this, I help to care for my Father who lives next door to us [redacted text - personal data] he requires regular appointments and help to the house.
4) Noise Pollution. The Racing Circuit got served a noise abatement order and now run under strict guidelines set out by Environmental Health at NCC. This would mean that due to the close proximity of the proposed site, they wouldn't be able to run quietly enough!
5) Bats live in the woods next to the proposed site. It is illegal to disturb the surrounding area and thus potential breeding grounds of bats.
6) This proposed site has been lodged before and has been deemed unsuitable due to the close proximity of residential properties.

Please accept the above as an objection to the proposed MIN 35 site at Heath Road, Eccles NR16

I am emailing you through my personal account because I can't work out how to lodge an objection through the website.

I wish to lodge my objections with regards to the proposed MIN 35, located on Heath Road, Eccles, NR16 for the following reasons:
1) The road is very narrow and only accommodates one car (there are no passing places) along the length. If there are any lorries blocking the road, this is our only exit.
2) Unsuitable junction. The sharp bend at the point of access is dangerous and vision is poor. The extra lorry movement would constitute an accident risk.
3) We need access at all times because my wife is a shift worker and I work as a lorry driver. In addition to this, I help to care for my Father in law who lives next door and [redacted text - personal data] requires regular appointments and help to the house.
4) Noise Pollution. The Racing Circuit got served a noise abatement order and now run under strict guidelines set out by Environmental Health at NCC. This would mean that due to the close proximity of the proposed site, they wouldn't be able to run quietly enough!
5) Bats live in the woods next to the proposed site. It is illegal to disturb the surrounding area and thus potential breeding grounds of bats.
6) This proposed site has been lodged before and has been deemed unsuitable due to the close proximity of residential properties.

Please accept the above as an objection to the proposed MIN 35 site at Heath Road, Eccles NR16

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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

We trust this advice is useful.

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