MIN 77 - land at Runns Wood, south of Whin Common Road, Tottenhill

I am very disgusted with the new planning applications for MIN 74-77-206.

MIN 74.
Is near our property and conservation area, we are very concerned about the impact on our wildlife also draining of water away from our properties, these cottages are old and have no proper footings so draining of the underground water could be a serious problem.

MIN 77.
I can not believe that you would consider taking trees down in Rons Wood, as they are lovely mature mixed trees, when we hear all the time we need to set trees for the ozone layer.
How can this be an extension to existing site? All sites close to this are disclosed.

MIN 206
Once again I'm very concerned about MIN 206 because it runs so near to the A10 road.
People driving along the A10 will have to look (like people do) at the site and I'm sure accidents will happen, local people know this is as a accident black spot (even though all the high risk road signs have been taken down) and we are aware as to why this has happened.
We may be cabbage liking but we are not green.

How many more of these applications for minerals are we going to get? This has been going on for years.
I really do think that the people on the Row have had enough.
The last one isn't yet over and my goodness what we've had to put up with has and still will be terrible.
The land owner and Frimstone does not care about conservation, they start out obeying the rules but soon decide they will do what they want what ever.
The fact they are draining the water away from the area doesn't seem to matter.
We do not need any more vehicle noise, dust, or early morning wake up calls from vehicles.
Most of the people living here are elderly and I feel are entitled to some peace and quiet.
I really do feel that a visit would help you and others, to see what is going to happen if all the applications are passed.
We have lost quite a bit of wildlife please leave us with some.

Objection to potential silica extraction site. Tottenhill
We are Tottenhill residents of 32 years standing.
We wish to register out joint objections to the proposed potential silica extraction site mostly within Tottenhill civil parish as shown on attached map. Our main reason for objection is the very close proximity of this site to Tottenhill village. Silica extraction on this site will inevitably lead to high levels of noise, dust etc. to the detriment of residents of Tottenhill village.
Additionally extraction from this site will require the creation of a new access onto the A134 at a point close to Wormegay primary school with all the additional stopping and turning of traffic that this will entail. The road network to the immediate west of the proposed site, comprising entirely of single track roads, is wholly inadequate to cater for any additional heavy traffic.
For these reasons we wish to register our objections to mineral extraction from this site.

Objections to MIN 74, 76, 77 and 206 in Tottenhill and AOS E and AOS J
Objection to AOS E - land between Marham and Shouldham and includes Shouldham Warren

I object to AOS E, including Shouldham Warren and the overlap with formerly SIL 02, in the Norfolk Minerals and Waste Local Plan. I strongly object to the fact that Norfolk County Council has deliberately misled residents by announcing the removal of SIL 02 when in reality a third of it is now/still included in AOS E.
As a member of the community, I echoed the concerns held by the Ministry of Defence when they objected to these proposals, due to the fact that the plan of a wet working and restoration in close proximity to RAF Marham, well within the statutory 13 kms limit, will increase the risk of "bird strikes" or worst-case scenario, end in an aircraft crash and potential loss of life. The economic cost of such a mishap would be greater than £100M just to replace an F35 Lightning II; add to that the costs for the emergency services and for the immediate and subsequent treatments through the NHS for the physical and mental injuries caused, and the financial costs become an unaffordable risk.
Permanent loss of agricultural land will impact rural Norfolk, its farming jobs, jobs of local employees i.e. British Sugar, including the increased need for home grown food, due to the impact of Brexit.
I object to the negative impact on villagers'/visitors' health. According to Public Health Profile 2018, our villages have higher levels of respiratory problems and reduced respiratory function (Chronic Obstructive Pulmonary Disease, Asthma), silica particles will exacerbate these conditions. Loss of natural spaces has been proven to adversely affect health, mental and physical. This fenland and forest (Shouldham Warren) is our community's public open space, our gym and our sanctuary, hundreds of people use it daily for physical recreation and social wellbeing interactions.
I object to the fact that the plan would ruin the Landscape, Shouldham Warren, the Countryside, including habitats for birds, animals, and insects. The Warren is home to 64 species of conservation concern, including endangered bats, nightjars and woodlarks. We need nature and trees now more than ever to combat pollution and climate change.
I object to the unsustainable use of a finite mineral resource, when the county only recycles a fraction of the glass already in circulation. There are national government policies and guidance including DEFRA and the Dept for Business Energy & Industrial Strategy that are clearly being ignored in order to allow a privately-owned Belgian company to profit from the devastation of our community asset, landscape and environment.
I further object to the worrying possibility of damage to our Public Water. It is very concerning that if quarrying was allowed to take place, whether through wet or dry working, the water supply could be affected, as the whole area of AOS E has very productive to moderately productive aquifers.
A further objection relates to the lack of restoration plans. Any restoration would take in excess of 30 years, until then the community would suffer from a devastated industrial landscape, increased flow of heavy articulated lorries, preventing any appreciation of its landscape and countryside. Sibelco has a poor track record for restoration in the area, and have failed to ensure safety of sites after extraction - its Bawsey site was the cause of deaths by drowning. The company has not been a 'good neighbour' and has done nothing to engage with the community or alleviate residents' concerns.
Lastly, I object to the fact that there would be no benefit to the local community or economy if this proposal goes through. What is clear is that a number of local communities will bear the brunt of a hugely disruptive and harmful industrial process; that a very popular public amenity enjoyed by a much larger section of the population will be permanently lost; and the only beneficiaries of this development will be a few landowners, Norfolk County Council, but principally the private owners of the Belgian company Sibelco.
Given that County Councils are responsible for the provision of public services for taxpayers and community wellbeing, and not the promotion of harmful and irresponsible businesses that present no local benefit, but with multiple risks, dictates that Norfolk County Council should put public interest before private profit.

Tottenhill surrounded by quarries
No of HGV/Traffic congestion
Pollution
Too near Wormegay school
Accident black spot A134/A10 roundabout and Wormegay school
Please record this as my objection

We are Tottenhill residents of 32 years standing.
We wish to register out joint objections to the proposed potential silica extraction site mostly within Tottenhill civil parish as shown on attached map. Our main reason for objection is the very close proximity of this site to Totten hill village. Silica extraction on this site will inevitably lead to high levels of noise, dust etc. to the detriment of residents of Tottenhill village.
Additionally extraction from this site will require the creation of a new access onto the A134 at a point close to Wormegay primary school with all the additional stopping and turning of traffic that this will entail. The road network to the immediate west of the proposed site, comprising entirely of single track roads, is wholly inadequate to cater for any additional heavy traffic.
For these reasons we wish to register our objections to mineral extraction from this site.

Objections to MIN 74, 76, 77 and 206 in Tottenhill and AOS I and AOS J
Objection to AOS E - land between Marham and Shouldham and includes Shouldham Warren

I object to AOS E, including Shouldham Warren and the overlap with formerly SIL 02, in the Norfolk Minerals and Waste Local Plan. I strongly object to the fact that Norfolk County Council has deliberately misled residents by announcing the removal of SIL 02 when in reality a third of it is now/still included in AOS E.
As a member of the community, I echoed the concerns held by the Ministry of Defence when they objected to these proposals, due to the fact that the plan of a wet working and restoration in close proximity to RAF Marham, well within the statutory 13 kms limit, will increase the risk of "bird strikes" or worst-case scenario, end in an aircraft crash and potential loss of life. The economic cost of such a mishap would be greater than £100M just to replace an F35 Lightning II; add to that the costs for the emergency services and for the immediate and subsequent treatments through the NHS for the physical and mental injuries caused, and the financial costs become an unaffordable risk.
Permanent loss of agricultural land will impact rural Norfolk, its farming jobs, jobs of local employees i.e. British Sugar, including the increased need for home grown food, due to the impact of Brexit.
I object to the negative impact on villagers'/visitors' health. According to Public Health Profile 2018, our villages have higher levels of respiratory problems and reduced respiratory function (Chronic Obstructive Pulmonary Disease, Asthma), silica particles will exacerbate these conditions. Loss of natural spaces has been proven to adversely affect health, mental and physical. This fenland and forest (Shouldham Warren) is our community's public open space, our gym and our sanctuary, hundreds of people use it daily for physical recreation and social wellbeing interactions.
I object to the fact that the plan would ruin the Landscape, Shouldham Warren, the Countryside, including habitats for birds, animals, and insects. The Warren is home to 64 species of conservation concern, including endangered bats, nightjars and woodlarks. We need nature and trees now more than ever to combat pollution and climate change.
I object to the unsustainable use of a finite mineral resource, when the county only recycles a fraction of the glass already in circulation. There are national government policies and guidance including DEFRA and the Dept for Business Energy & Industrial Strategy that are clearly being ignored in order to allow a privately-owned Belgian company to profit from the devastation of our community asset, landscape and environment.
I further object to the worrying possibility of damage to our Public Water. It is very concerning that if quarrying was allowed to take place, whether through wet or dry working, the water supply could be affected, as the whole area of AOS E has very productive to moderately productive aquifers.
A further objection relates to the lack of restoration plans. Any restoration would take in excess of 30 years, until then the community would suffer from a devastated industrial landscape, increased flow of heavy articulated lorries, preventing any appreciation of its landscape and countryside. Sibelco has a poor track record for restoration in the area, and have failed to ensure safety of sites after extraction - its Bawsey site was the cause of deaths by drowning. The company has not been a 'good neighbour' and has done nothing to engage with the community or alleviate residents' concerns.
Lastly, I object to the fact that there would be no benefit to the local community or economy if this proposal goes through. What is clear is that a number of local communities will bear the brunt of a hugely disruptive and harmful industrial process; that a very popular public amenity enjoyed by a much larger section of the population will be permanently lost; and the only beneficiaries of this development will be a few landowners, Norfolk County Council, but principally the private owners of the Belgian company Sibelco.
Given that County Councils are responsible for the provision of public services for taxpayers and community wellbeing, and not the promotion of harmful and irresponsible businesses that present no local benefit, but with multiple risks, dictates that Norfolk County Council should put public interest before private profit.

* Tottenhill surrounded by quarries
* No of HGV/Traffic congestion
* Pollution
* Too near Wormegay school
Accident black spot A134/A10 roundabout and Wormegay school
Please record this as my objection

Re: Objections to Min74, 76, 77 and 206 and ASOI and ASOJ
I object to the new quarry plans Norfolk County Council have put forward in the revised Norfolk Minerals and Waste Local Plan which include the above sites.
As a parishioner of Tottenhill I am concerned about the impact these proposals will have upon the village where I have lived for 60 years.
Permanent loss of agricultural land will impact on rural Norfolk at a time when we need to produce more home grown produce. Especially as our population increases and we are told to reduce transportation of produce.
According to Public Health Profile 2018 our villages have higher levels of respiratory problems and reduced respiratory functions. Silica particles in the air will exacerbate these conditions.
We are encouraged to exercise more for our health and wellbeing. As there are no footpaths in the village (apart from a short path on the A134 to the school) people use Deals Lane and Priors Road for walking and exercising their dogs. I regularly use this lane with my husband and grandchildren as recreation. However, the landscape will be destroyed and instead of peace, quiet and birdsong there will be noise and air pollution.
I am also concerned that if the developments are passed there is a lack of restoration plans. This village already has many quarry sites which have resulted in large areas of open water which do not enhance the village in any way. Any future landscaping would take years and the village would suffer a devastating industrial landscape. Sibelco has a poor record of restoration and has failed to ensure safety after extraction - Bawsey, cause of deaths by drowning.
The excess traffic on the A10 will make travelling on this road even worse. I use this road for work which can take me 45 minutes plus to travel 11 miles to work. With extra traffic already earmarked because of the Safari Park and developments at West Winch, not to mention the sugarbeet lorries, the situation would become intolerable. Emergency vehicles already struggle to get through - again what consideration is there for those in need. Also Oakwood Corner and the Wormegay turning at Wormegay School are already known black spots.
There is also great concern for children attending Wormegay School. We are encouraged to walk or cycle instead of using our cars for the school run. Cycling to school is a non starter for those living in Tottenhill as there is a danger of being dragged under lorries travelling on the A10. Also children using the footpath can easily be blown to the side by passing lorries. Just imagine what this is like in inclement weather. I have also witnessed near misses when cars are trying to turn right from the A134 to go to school. Vehicles often have to stand for long periods waiting for passing traffic before they can turn and are vulnerable to traffic from behind. Although there is a speed limit it is often exceeded and there in no crossing for the children to use.
If there proposals go through Tottenhill will be surrounded by quarries. Resident's health and wellbeing will suffer. Although some may want to move, there may be a devaluation of properties and who would want to live in such a village?
On a personal level my family has enjoyed the tranquility of this parish for over 60 years. Four generations have used and still use these lanes for our health and wellbeing. Other footpaths which we had access to were taken away from us by the landowner and now form part of his agricultural land. For somebody who wants to promote the protection of wildlife, what has happened to the protection of our rural communities?
Please record this as my object

Re: Objections to Min74, 76, 77 and 206 and ASOI and ASOJ
I object to the new quarry plans Norfolk County Council have put forward in the revised Norfolk Minerals and Waste Local Plan which include the above sites.
As a parishioner of Tottenhill I am concerned about the impact these proposals will have upon the village where I have lived for 43 years.
Permanent loss of agricultural land will impact on rural Norfolk at a time when we need to produce more home grown produce. Especially as our population increases and we are told to reduce transportation of produce.
According to Public Health Profile 2018 our villages have higher levels of respiratory problems and reduced respiratory functions. Silica particles in the air will exacerbate these conditions.
We are encouraged to exercise more for our health and wellbeing. As there are no footpaths in the village (apart from a short path on the A134 to the school) people use Deals Lane and Priors Road for walking and exercising their dogs. I regularly use this lane with my husband and grandchildren as recreation. However, the landscape will be destroyed and instead of peace, quiet and birdsong there will be noise and air pollution.
I am also concerned that if the developments are passed there is a lack of restoration plans. This village already has many quarry sites which have resulted in large areas of open water which do not enhance the village in any way. Any future landscaping would take years and the village would suffer a devastating industrial landscape. Sibelco has a poor record of restoration and has failed to ensure safety after extraction - Bawsey, cause of deaths by drowning.
The excess traffic on the A10 will make travelling on this road even worse. I use this road for work which can take me 45 minutes plus to travel 11 miles to work. With extra traffic already earmarked because of the Safari Park and developments at West Winch, not to mention the sugarbeet lorries, the situation would become intolerable. Emergency vehicles already struggle to get through - again what consideration is there for those in need. Also Oakwood Corner and the Wormegay turning at Wormegay School are already known black spots.
There is also great concern for children attending Wormegay School. We are encouraged to walk or cycle instead of using our cars for the school run. Cycling to school is a non starter for those living in Tottenhill as there is a danger of being dragged under lorries travelling on the A10. Also children using the footpath can easily be blown to the side by passing lorries. Just imagine what this is like in inclement weather. I have also witnessed near misses when cars are trying to turn right from the A134 to go to school. Vehicles often have to stand for long periods waiting for passing traffic before they can turn and are vulnerable to traffic from behind. Although there is a speed limit it is often exceeded and there in no crossing for the children to use.
If there proposals go through Tottenhill will be surrounded by quarries. Resident's health and wellbeing will suffer. Although some may want to move, there may be a devaluation of properties and who would want to live in such a village?
On a personal level my family has enjoyed the tranquility of this parish for many years. Four generations have used and still use these lanes for our health and wellbeing. Other footpaths which we had access to were taken away from us by the landowner and now form part of his agricultural land. For somebody who wants to promote the protection of wildlife, what has happened to the protection of our rural communities?
Please record this as my object

Re: Objections to Min74, 76, 77 and 206 and ASOI and ASOJ
I object to the new quarry plans Norfolk County Council have put forward in the revised Norfolk Minerals and Waste Local Plan which include the above sites.
As a parishioner of Tottenhill I am concerned about the impact these proposals will have upon the village where I have lived for 60 years.
Permanent loss of agricultural land will impact on rural Norfolk at a time when we need to produce more home grown produce. Especially as our population increases and we are told to reduce transportation of produce.
According to Public Health Profile 2018 our villages have higher levels of respiratory problems and reduced respiratory functions. Silica particles in the air will exacerbate these conditions.
We are encouraged to exercise more for our health and wellbeing. As there are no footpaths in the village (apart from a short path on the A134 to the school) people use Deals Lane and Priors Road for walking and exercising their dogs. I regularly use this lane with my husband and grandchildren as recreation. However, the landscape will be destroyed and instead of peace, quiet and birdsong there will be noise and air pollution.
I am also concerned that if the developments are passed there is a lack of restoration plans. This village already has many quarry sites which have resulted in large areas of open water which do not enhance the village in any way. Any future landscaping would take years and the village would suffer a devastating industrial landscape. Sibelco has a poor record of restoration and has failed to ensure safety after extraction - Bawsey, cause of deaths by drowning.
The excess traffic on the A10 will make travelling on this road even worse. I use this road for work which can take me 45 minutes plus to travel 11 miles to work. With extra traffic already earmarked because of the Safari Park and developments at West Winch, not to mention the sugarbeet lorries, the situation would become intolerable. Emergency vehicles already struggle to get through - again what consideration is there for those in need. Also Oakwood Corner and the Wormegay turning at Wormegay School are already known black spots.
There is also great concern for children attending Wormegay School. We are encouraged to walk or cycle instead of using our cars for the school run. Cycling to school is a non starter for those living in Tottenhill as there is a danger of being dragged under lorries travelling on the A10. Also children using the footpath can easily be blown to the side by passing lorries. Just imagine what this is like in inclement weather. I have also witnessed near misses when cars are trying to turn right from the A134 to go to school. Vehicles often have to stand for long periods waiting for passing traffic before they can turn and are vulnerable to traffic from behind. Although there is a speed limit it is often exceeded and there in no crossing for the children to use.
If there proposals go through Tottenhill will be surrounded by quarries. Resident's health and wellbeing will suffer. Although some may want to move, there may be a devaluation of properties and who would want to live in such a village?
On a personal level my family has enjoyed the tranquility of this parish for over 60 years. Four generations have used and still use these lanes for our health and wellbeing. Other footpaths which we had access to were taken away from us by the landowner and now form part of his agricultural land. For somebody who wants to promote the protection of wildlife, what has happened to the protection of our rural communities?
Please record this as my object

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.

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 77 - land at Runs Wood, south of Whin Common Road, Tottenhill)

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 77 for the reasons outlined below.

Amenity
The feasibility study completed as part of the noise prediction exercise carried out by Independent Environmental Consultancy Limited has shown that NPPG noise criterion can be met at the nearest noise-sensitive receptor positions. Any future planning application for mineral extraction at this site will include a further noise and dust assessment and outline mitigation measures to deal appropriately with any amenity impacts.

Historic Environment
Following the findings from the Heritage Appraisal carried out by independent consultants Andrew Josephs Associates. It is proposed that any future planning application for mineral extraction at this site will include a further Heritage Statement to identify heritage assets and their settings, assess the potential for impacts and identify appropriate mitigation measures if required.

Archaeology
Following the archaeological background section included in the Heritage Appraisal carried out by independent consultants Andrew Josephs Associates. It is proposed that any future planning application will be accompanied by an assessment of the significance of archaeological remains, in order to protect and mitigate the impact of mineral extraction on this site.

Landscape
It is considered that Runs Wood no longer constitutes a significant area of woodland within the local landscape and therefore does not have a significant biodiversity value. Runs Wood is an area of ornamental woodland, likely planted to provide cover for shooting with a significant shrub layer dominated by Rhododendron ponticum. The woodland is largely unmanaged with many large dead and fallen trees throughout, with the southern part of the woodland including a large pheasant pen and elsewhere evidence of further gamekeeper activity. There are also a number of Ash trees within the woodland which may be susceptible to Ash Die Back. Furthermore, it is proposed that a screening buffer of trees shall be retained around the perimeter of the excavation. This coupled with the fact that in recent years the Estate have felled a number of dead or dying trees means that the once considered significant densely populated woodland, is now very sparsely populated with poor quality trees remaining above a shrub layer dominated by Rhododendron ponticum, subsequently reducing the biodiversity value.

I therefore wish to object to paragraph M77.7 Landscape: suggesting that the conclusions reached in terms of Runs Wood constituting a significant area of woodland within the local landscape are reconsidered to take account for the recent deterioration in the woodland habitat associated with the management by the Estate, and that the dominance of Rhododendron ponticum should suggest that the biodiversity value can no longer be considered as significant.

Ecology
Following the Ecological Scoping Report carried out by independent consultants The Landscape Partnership in support of the original representation. It is proposed that any future planning application will be accompanied by an assessment of potential impacts, including from dust deposition and hydrogeology, together with appropriate mitigation on all designated sites within the vicinity of the site.

Restoration
It is proposed that the site is restored to nature conservation after use comprising a mixture of ponds, wet woodland and wet grassland. The proposed restoration scheme would result in the planting of additional woodland to blend in with the screening buffer of trees to be retained around the excavation. Since the woodland is now very sparsely populated with poor quality trees remaining above a shrub layer dominated by Rhododendron ponticum it is considered that the existing woodland would be able to be replaced and enhanced as a result of the proposed restoration. The restoration proposals will subsequently mitigate against the loss of the existing woodland and provide for a net biodiversity gain.

I therefore wish to object to paragraph M77.19 Restoration: suggesting that the conclusions reached in terms of the proposed restoration scheme not being able to replace the existing established woodland and not mitigate for the loss of the existing woodland are reconsidered to take account for the recent deterioration in the woodland habitat.

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 0.63 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Furthermore, it should be considered that under the current adopted Norfolk Minerals and Waste Development Framework Core Strategy and Minerals and Waste Development Management Policies Development Plan Document 2010-2026, Core Strategy Policy CS2 - General locations for mineral extraction and associated facilities MIN 77 is proposed as an extension to an existing site and therefore will be preferred by the MPA to new sites. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Amenity Impact & Mitigation Report (Ref. IEC/3650/01/AVH) dated 04 August 2017
Heritage Appraisal (No Reference) dated July 2017
Ecological Scoping Report (Ref. E17854) dated 31 July 2017

I am writing, somewhat belatedly, to lodge my strong objection to to the proposed plans for quarrying in and around Tottenhill. As a resident of Tottenhill I believe the impact any further plans for quarrying in the immediate area will be detrimental to the village and surrounding areas for a number of reasons. My objections are as follows:

1. The area has already been extensively quarried, which still has a daily impact on the area. Further quarrying could destroy this small hamlet of Tottenhill completely - which is already split with the A10 running through it.
2. The road network in and around Tottenhill would not support any additional traffic - there has previously been a number of accidents at the two junctions on the A10, which is a major route into Kings Lynn.
3. There are very few unspoilt areas in Norfolk, without street lighting, like Tottenhill and this should be preserved as far as possible.
4. The watercourse could be affected by additional quarrying, as well as the quality of the water and water table. As a local resident, we regularly have issues with water - many times over the course of a year we lose the water pressure and at other times we lose water altogether.
5. Although Tottenhill now has access to the mains sewer some of the local residents still use septic tanks. Further quarrying could have an impact on the sewage system.
6. Any extracted material, in particular the silica sand, would firstly need to be transported to Leziate, treated and then, as it has historically, been transported mostly by road, to various parts of the country. It will not be used in Norfolk alone, if at all.
7. Tottenhil is an area of natural beauty with many interesting birds and other species. Further quarrying can only have a detrimental effect on the wildlife in the area.
Please listen to the local residents and look at other sites in Norfolk. We are only small and already over-quarried!

I am writing to object to the proposed plans for quarrying in and around Tottenhill. As a resident of Tottenhill I believe the impact any further plans for quarrying in the immediate area will be detrimental to the area for a number of reasons. My objection is:

* The area has already been extensively quarried, which still has a daily impact on the area. Further quarrying could destroy this small hamlet of Tottenhill completely - which is already split with the A10 running through it.
* Tottenhill is an area of natural beauty with many interesting birds and other species of wildlife. Further quarrying can only have a detrimental effect on the wildlife in the area.
* The road network in and around Tottenhill would not support any additional traffic - there has previously been a number of accidents at the two junctions on the A10, which is a major route into Kings Lynn.
* The noise and dust from proposed quarrying would impact on the wellbeing of the local residents.
* There are very few unspoilt areas in Norfolk, without street lighting, like Tottenhill and this should be preserved as far as possible.
* The watercourse, quality of water and water table may be affected by further quarrying. As a local resident, we regularly have issues with water - many times over the course of a year we lose the water pressure and at other times we lose water altogether.
* Although Tottenhill now has access to the mains sewer some of the local residents still use septic tanks. Further quarrying could have an impact on the sewage system.
* Any extracted mineral, especially the silica sand, would firstly need to be transported to Leziate, where it would be treated and then transported, predominantly by road, to various parts of the country. It will not be used in Norfolk alone, if at all,
Please listen to the local residents and consider other sites in Norfolk where the impact of such quarrying would not have such an effect on the immediate community - we've had enough.

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]