MIN 32 - land west of Lime Kiln Road, West Dereham

My property is within 30m of the proposed site and therefore I object to the proposal presented. I believe it would have an adverse impact on my house price and also the amount of traffic and noise/actual pollution near my home. My neighbours have also argued that this would have a negative impact on them and we collectively disapprove of the council's decision.

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

I object to this preferred site as any work here would be highly visible and detrimental to the landscape, given the topography of the site. As it is at the top of a slope overlooking the whole area in every direction, any excavation would be incredibly visible and very difficult to mask.

I would like to lodge my objection to the inclusion of the above site in the local waste and mineral plan - specifically the fact that this site is being proposed for a quarry. The proposed site is extremely close to our Grade 1 listed village church - what impact would prolonged excavations have on the foundations of this building? The far reaching views from this elevated site would be ruined, as would the views for many residents. It seems as though most of West Norfolk is being earmarked for being dug up with little thought given to the environment and local residents.

My family lives at The Old Rectory in West Dereham which is south/south east of MIN 32.
We would object to this site for a number of reasons. The site land slopes fairly steeply down towards the village and it would not be possible to shield a view of the quarry without a considerable sized bund which in itself would alter the current landscape significantly. This north end of the village is already bordered by the existing Frimstone/Mick George quarry whose strong lights are clearly visible from our home. The existing quarry was supposed to begin when the quarry opposite it closed but this original quarry is still operating nine years later after three planning extensions. We can have no confidence that a new quarry would have the life extent proposed since NCC are not able to predict accurately the amounts of gravel required for the UK house building market. MIN 32 is close to our Grade 1 listed church and the site itself is a rich source of historical artefacts. With the existing quarries West Dereham - which is a residential hamlet of approximately 450 residents and 200 houses - already shoulders its fair share of mineral extraction for the country.

I wish to object to the creation of a mineral quarry between West Dereham and Crimplesham. I have resided in West Dereham for 14 years and over that time have already noticed an increase in the volume of heavy traffic. West Dereham is a rural community and the creation of a quarry would not only affect the aesthetic views of the countryside but would bring even more large vehicles into the vicinity of the village. Also the growth of any industrialised operation provides the possible threat of pollution to the local environment.

I sincerely hope you reconsider any plans to create a quarry in the vicinity of this quiet rural village.

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council Objection to Quarrying in AOS E at Shouldham and Marham, Norfolk I object to silica sand mining taking place in the area of Area Of Search (AOS) E and its surroundings as proposed in the Norfolk County Council Mineral & Waste Local Plan, Preferred Options July 2019. It is used for outdoor exercise by 1000s of people; young and old. The loss of long-established woodlands would be devastating for mental health and physical well-being. It would be a disaster for the biodiversity of flora and fauna supported by that ecosystem. The destruction of woodland, never to be restored, is unacceptable at a time when Govt's policy (Clean Growth Strategy) is to increase the number of trees in the UK - "Establish a new network of forests in England... plant 11 million trees". We are facing a Climate Crisis. Shouldham Warren is one of our precious planet's lungs, capturing 11,000 tonnes of C02 per year. The Warren provides clean air, home to precious biodiversity and valuable educational space for children. The lack of an improved glass recycling plan to increase the amount of glass cullet available to UK glass manufacturers makes further quarrying for silica sand at the current rate morally wrong. "Our environment is our most precious inheritance," says DEFRA, so I urge Norfolk County Council to not allocate the woodlands and agricultural farmland in AOS E and remove AOS E from the Mineral & Waste Local Plan.


Comments
Yes to extending Crimplesham quarry, I am based in West Dereham and have no objections to Crimplesham being extended. I know we need to extract from the ground to keep supplies but destroying Shouldham Warren is not acceptable. This is a place of natural beauty where many different wildlife live and breed, Aswell as the many different plants. AS ABOVE This woodland is used daily for many outdoor activities by the people, most of which will be objecting too, but some do not have the facilities to object on here. AS ABOVE, GLASS IS BARELY RECYCLED EVEN THOUGH WE ARE EXPECTED TO RECYCLE IT INSTEAD YOU LOT SEND IT TO LANDFILL TO MAKE MORE INSTEAD!! AND I SUPPOSE YOU PROBABLY WANT TO PUT UP A FEW 5G TOWERS AROUND THERE TOO ONCE THE TREES ARE GONE TO KILL US ALL OFF SOONER. You will start a MAJOR PROTEST if this so called PLAN goes ahead and we will NOT be backing down.

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 32 - land west of Lime Kiln Road, West Dereham)

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 32 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 the sightlines sections drawing no. W12_LAN_006 submitted in support of MIN 32 allocation at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review in August 2018, demonstrates that the site will not have any adverse effects on the existing landscape given the implementation of appropriately designed screening bunds, existing and proposed planting.

It is proposed that all screening bunds shall have shallow outer slopes and are to be sown to grassland at the first available opportunity to match the adjacent fields. The screening bunds will be 3m in height with 1 in 5 outer slopes on the eastern and northern boundaries and 1 in 10 outer slopes on the southern boundary. Furthermore, where possible it is proposed to reinforce the existing planting in advance of mineral workings and also the planting of an additional hedgerow along the southern boundary to aid screening, as illustrated in the supporting concept development plan drawing no. W12_LAN_004.

Therefore, it can be demonstrated by these sightline sections that once the above mitigation proposals have been implemented as per the concept development plan the site will not afford any views to potential external sensitive receptors. Any future planning application for mineral extraction at this site will include a further landscape assessment and scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents.

I therefore wish to object to paragraph M32.6 Landscape: suggesting that the conclusions reached in terms of screening the views from West Dereham, A134, Lime Kiln Road and Bath Road Area are reconsidered to take account for the sightline sections included in the amended MIN 32 representation at the 'Initial Consultation' stage of the Plan, that clearly demonstrate given the mitigation proposals above that suitable screening can be implemented. Furthermore, I wish to object to the conclusions drawn regarding the screening or bunding being intrusive in the open landscape, as it has been specifically designed to have shallow outer slopes and to be sown to grassland at the first available opportunity to match the adjacent field, and therefore blending into the surrounding agricultural landscaping setting.

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.

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 0.56 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 32 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/3674/01/AVH) dated 03 August 2017
Heritage Appraisal (No Reference) dated July 2017
Concept Development Plan (Drawing No. W12_LAN_004)
Concept Restoration Plan (Drawing No. W12_LAN_005)
Sightline Sections (Drawing No. W12_LAN_006)
Sightline Locations (Drawing No. W12_LAN_007)
Ecological Scoping Report (Ref. E17855) dated 21 July 2017

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]