MIN 204 - land north of Lodge Road, Feltwell

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Object

Preferred Options consultation document

Representation ID: 94156

Received: 14/10/2019

Respondent: Ms A Money

Representation Summary:

we need to protect the earth from exploitation and find other non invasive ways of providing for human needs or learn to live differently.

This is not sustainable for the planet which means it's not sustainable for the human race

Full text:

we need to protect the earth from exploitation and find other non invasive ways of providing for human needs or learn to live differently.

This is not sustainable for the planet which means it's not sustainable for the human race

Comment

Preferred Options consultation document

Representation ID: 94880

Received: 28/10/2019

Respondent: LP Pallett Quarry (Feltwell) Ltd

Agent: Small Fish

Representation Summary:

Representation on behalf of LP Pallett Quarry (Feltwell) Ltd
MIN 204 has been amended to exclude the north east field and we would ask that you reconsider the reduced MIN 204 on this basis. The amended proposal is 10.4 hectares with an estimated workable deposit of 575,000 tonnes. An amended MIN 204 proposal map has been provided.
Other than the comments relating to ecology the assessment demonstrates that MIN 204 is fully compliant with national planning policy as well as the Core Strategy policy framework.
In terms of ecology the first stage of the Minerals and Waste Local Plan Review concluded:
"The Habitat Regulations Assessment (HRA) Task 1 has found that the two southern parcels are likely to be able to (be) extracted without giving rise to unacceptable impacts if appropriate mitigation is put in place; this conclusion is based on the experience of mineral working to the north which is closer to the SPA. The most north-easterly parcel of land has a boundary adjacent to the SPA, and is closer than any previous working; the conclusion of the HRA is that impacts are uncertain. Therefore, the north-western (sic) parcel of land is not considered suitable for allocation."
The assessment in the latest consultation only considers the proximity of the site as a whole to the SPA and not the proximity of each individual field as in the previous consultation. It is not surprising therefore that the effects on the SPA of the whole working are judged to be uncertain. Given the more detailed assessment at the previous stage it would appear that a site based on the two southern fields only is no less deliverable than other sites that have been proposed for extraction. Hence the mineral operator, LP Pallett Quarry (Feltwell) Ltd, would like to take this opportunity to revise the extent of the site to exclude the north east field as shown on the revised proposal map.
In summary: Given that the Habitat Regulations Assessment (HRA) Task 1 found that the two southern parcels are likely to be able to be extracted without giving rise to unacceptable impacts and that the assessment otherwise demonstrates that MIN 204 is fully compliant with national planning policy as well as the Core Strategy policy framework then we assert that the revised site MIN 204 is no less deliverable than other sites that have been proposed for extraction and should be allocated.

Full text:

Representation on behalf of LP Pallett Quarry (Feltwell) Ltd
MIN 204 has been amended to exclude the north east field and we would ask that you reconsider the reduced MIN 204 on this basis. The amended proposal is 10.4 hectares with an estimated workable deposit of 575,000 tonnes. An amended MIN 204 proposal map has been provided.
Other than the comments relating to ecology the assessment demonstrates that MIN 204 is fully compliant with national planning policy as well as the Core Strategy policy framework.
In terms of ecology the first stage of the Minerals and Waste Local Plan Review concluded:
"The Habitat Regulations Assessment (HRA) Task 1 has found that the two southern parcels are likely to be able to (be) extracted without giving rise to unacceptable impacts if appropriate mitigation is put in place; this conclusion is based on the experience of mineral working to the north which is closer to the SPA. The most north-easterly parcel of land has a boundary adjacent to the SPA, and is closer than any previous working; the conclusion of the HRA is that impacts are uncertain. Therefore, the north-western (sic) parcel of land is not considered suitable for allocation."
The assessment in the latest consultation only considers the proximity of the site as a whole to the SPA and not the proximity of each individual field as in the previous consultation. It is not surprising therefore that the effects on the SPA of the whole working are judged to be uncertain. Given the more detailed assessment at the previous stage it would appear that a site based on the two southern fields only is no less deliverable than other sites that have been proposed for extraction. Hence the mineral operator, LP Pallett Quarry (Feltwell) Ltd, would like to take this opportunity to revise the extent of the site to exclude the north east field as shown on the revised proposal map.
In summary: Given that the Habitat Regulations Assessment (HRA) Task 1 found that the two southern parcels are likely to be able to be extracted without giving rise to unacceptable impacts and that the assessment otherwise demonstrates that MIN 204 is fully compliant with national planning policy as well as the Core Strategy policy framework then we assert that the revised site MIN 204 should be allocated.

Comment

Preferred Options consultation document

Representation ID: 98724

Received: 30/10/2019

Respondent: Environment Agency

Representation Summary:

Our previous comments raised within the issues and options stage of the consultation remain valid.

Full text:

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.

Comment

Preferred Options consultation document

Representation ID: 98984

Received: 30/10/2019

Respondent: Norfolk County Council - Natural Environment Team

Representation Summary:

Min 204
Located within the stone curlew buffer constraints zone, on the edge of Breckland SPA. Under Article 6 of the Habitats Directive (and Regulation 102 of the Habitats Regulations), an assessment is required where a land use plan may give rise to significant effects upon a Natura 2000 site (also known as 'European sites').

Full text:

Ecology
Min 204
Located within the stone curlew buffer constraints zone, on the edge of Breckland SPA. Under Article 6 of the Habitats Directive (and Regulation 102 of the Habitats Regulations), an assessment is required where a land use plan may give rise to significant effects upon a Natura 2000 site (also known as 'European sites').
Min 213
Min 213 is located on a plantation, adjacent to Ancient re-planted woodland of Hevingham Park, and forms part of an extensive area of woodland (green infrastructure). The woodland forms part of the Core Sustenance Zone for a barbastelle bat maternity colony in the area, and this, together with its role providing habitat connectivity for wildlife, should be taken into consideration.
The woodland areas are of ecological value and likely support protected species such as bats and other wildlife. Where woodland areas are proposed for removal then an ecological assessment needs to be undertaken and any further surveys need to be carried out or mitigation proposed, if necessary. It is also located within a SSSI Impact Risk Zone requiring consultation with Natural England for any mineral application.

Comment

Preferred Options consultation document

Representation ID: 99011

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

Summary
We note that this site is unsuitable for allocation due to Breckland Forest SSSI.

M204.1 Amenity
The site has the potential to cause emissions of PM10 and PM2.5 which can affect the amenity and health of local residents.
The nearest residential property is 21m from the site boundary. There are five sensitive receptors within 250m of the site boundary and two of these are within 100m of the site boundary. The settlement of Feltwell is 1.3km away. Without mitigation, adverse dust impacts from sand and gravel sites can occur within 250m from the nearest dust generating activities, with the greatest impacts within 100m of a source, if uncontrolled. These can result in negative impacts upon human health.
Therefore we would expect any planning application for mineral extraction at this site to include noise, dust, and air quality assessments, and mitigation measures to minimise harmful emissions to air and address appropriately any human health or amenity impacts.
The control and mitigation of dust at this site should be discussed between the operator and the LA Environmental Health Department before an application is submitted. Matters that may need to be explored are:
* the existing dust climate at the locality;
* the need for, and scope of, a dust assessment study to be conducted by the operator prior to a detailed design.
* the potential for different site activities to emit dust and their relationship to residential properties and other sensitive uses;
* how the layout of the site could minimise impacts; and the proposed methods of mitigation and control of dust generating activities such as buffer zones.
It must be ensured that the preparation or use of the site will not result in an exceedance of the national air quality objectives, or an AQMA may need to be declared.
Boundary dust measurement may need to be conducted, due to the close proximity of residential properties to the proposed site, to ensure there are no breaches of national air quality objectives.
Without appropriate mitigation of air pollution from the site, human health could be impacted, thus making the site allocation unsuitable.

M204.2 Highway Access
The site would use the new access onto the B1112 (Lodge Road), which is a designated lorry route (approx. 150 m west of the Sawmill access). The site is not within an AQMA. The estimated number of HGV movements is 20 per day.
A transport assessment should be undertaken which includes traffic flow along the B1112 and takes into account air quality implications for local residents.

M204.15 Flood Risk
The site has a low risk of surface water flooding with two locations of surface water pooling in a 1 in 30 year rainfall event and a five locations of surface water pooling in a 1 in 100 year rainfall event. In the 1:1000 year rainfall event approximately 40% of the western field is covered by surface water pooling, so this should be considered within a surface water drainage scheme.

M204.16 Hydrogeology
The site is located over a principal aquifer (bedrock) and partially located over a secondary A aquifer (superficial deposits). Part of the site is within groundwater Source Protection Zone 2. The rest of the site is not within a groundwater SPZ. The site would be worked dry (above the water table) and therefore dewatering would not be required. We would expect a planning application for mineral extraction at this site to include a Hydrogeological Risk Assessment to identify any potential impacts to groundwater, along with appropriate mitigation measures.

Full text:


Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Mineral Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Submitted noise assessments and air quality/dust assessments should consider and include mitigation measures to deal appropriately with any potential health impacts, such as operational practices, separation/standoff areas and screening and/or bunding in line with Development Management Policies DM12 and DM13.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework.

Lighting:
Lighting is not included in the document as this is generally something which can be considered at any proposed planning application stage; however we would hope that any proposed lighting for site security and worker safety would be carefully considered prior to the planning stage so details can be submitted with any planning application. We would assume lighting would be pole mounted in elevated positions, and therefore the throw and spread of this should be assessed to ensure that there is no impact on residents. Light should be contained within the confines of sites and positioned appropriately. If necessary lighting is located near dwellings, this should be angled away and hooded/cowled to prevent any adverse impact on residents.

Vibrations:
The potential impact from vibrations should also be considered at any future planning stage, if sites are chosen close to residential receptors - including vibrations from site operations and associated transportation of extracted materials.

Soil Stripping:
Soil stripping operations must be effectively controlled through mitigation methods (e.g. buffer zones and bunding) to reduce fugitive emissions, which pose short term health impacts on nearby residents. These mitigation measures must be included in any future planning application.

Haul Roads:
Fugitive emissions from haul roads need to be addressed in any future planning application, with mitigation planned where necessary such as wheel washing.

[see attached table for comments on individual sites]

Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Waste Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Any future applications for waste sites should be accompanied by noise, odour, dust, and air quality management schemes, which should identify potential sources and mitigation/control measures to prevent nuisance issues and health impacts (e.g. emissions from as gas flaring).
Where sites are likely to be illuminated for safety/security, lighting plans and details should also be submitted which should include where lights will be located, their heights and angle/orientation, the type of lighting and the throw and spill of light across the site, and measures to ensure light spill is contained within site boundaries.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework

Existing Waste Site Specific Allocation Policies:
We note that WAS 05, WAS 25, WAS 36, WAS 40, WAS 37, WAS 45 and WAS 65 are no longer required and would therefore be deleted. There is therefore no risk to residential amenity from these sites.

Odour:
An odour impact assessment should be included within any future planning applications for allocated waste sites, along with suitable mitigation measures where appropriate.

Climate Change:
Climate change mitigation should be considered with regards to methane emissions (a greenhouse gas) released from allocated landfill sites.

[see attached table for comments on individual sites]