SIL01 - land at Mintlyn South, Bawsey

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

SIL01 forms part of a valuable wildlife corridor on the edge of King's Lynn serving the Gaywood River, Roydon Common SPA, Sugar, Leziate and Derby Fen SSSIs. These important ecological assets cannot thrive if they are increasingly isolated by development and quarrying. The extraction sites worked by Silbelco and/or their predecessors, located to the North West, have been left in an appalling state with NO RESTORATION. The water in the resulting lakes is badly discoloured from low pH/contamination and therefore significantly detracts from the natural environment. Planning was recently granted for Leziate Sailing Club land for the development of housing with the loss of community assets which were covered by covenants and/or a Section 52 order by the BCKLWN. There is local concern that the site will not be appropriately restored and, if it is, that it will not be sufficiently protected long-term.

I wish to lodge an objection to the proposed extraction of silica sand from the Mintlyn South site. I did try to lodge my complaint online however you only seem to allow 100 words in your objection box therefore rendering the process inadequate.

The main points of my objection are as follows:
*The first point I would like to object to is the Agricultural Land Classification being Non-Agricultural Use. A good percentage of this site is owned by [redacted text - personal data] who run their pedigree livestock farm from this area producing top quality Beef Shorthorn Cattle (including highly successful show cattle), Kerry Hill Sheep (again to successful show standards) and the rare breed Large Black Pig of which they have five bloodlines which is unique in the UK. The proposed extraction will not only decimate their land but kill their business with the majority of animals having to go to slaughter. This is the only area of land available to them for winter grazing therefore they will have no option other than to cease trading. No doubt you will side with the large mineral company regardless of impact to any other small companies that are 'in the way'. Does NCC not support British Farming?

*I would like to drawer your attention to the Government's Environment Bill as it does seem that the extraction of silica sand from this site goes completely against the principles of what Defra are looking to achieve with this bill which had its second reading in Westminster on Monday 28th October. I quote from the Defra website "The Bill will build on the UK's strong track record and sets out a comprehensive and world-leading vision to allow future generations to prosper. Environmental principles will be enshrined in law and measures will be introduced to improve air and water quality, tackle plastic pollution and restore habitats so plants and wildlife can thrive." Allowing Sibelco to take 1.2 million tonnes of sand from this site WILL NOT allow future generations to prosper, it WILL NOT improve air and water quality and it WILL NOT restore habitats so plants and wildlife can thrive! The trees within this proposed excavation site include 25 Oak, 2 Beech, Scotch Pine and Birch which, if Sibelco get permission to excavate, will be flattened and furthermore taking the wildlife with it.
*Between 2009 and 2017 Bob Osborne of the British Trust for Ornithology carried out a record of the bird life that he alone had seen in the area you refer to as SIL 01. The list is not exhaustive with birds like the Nightjar frequenting the trees in the summer. The very same trees destined for destruction. Surely a comprehensive study should be completed prior to any excavation being allowed to take place? His findings were as follows:
(SEE ATTACHED IMAGE)

* I understand that Bats in the UK are protected by the Wildlife and Countryside Act 1981 and that ALL species are protected by the law. If this is the case then surely it would be an offence to destroy the habitat in which hundreds if not thousands of bats roost throughout the year. Allowing Sibelco to rip out the trees at the Mintlyn Park site WILL destroy such a habitat.

* While being within the confounds of this proposed extraction site I wonder what Sibelco would propose to do with all the frogs, toads, sand lizards, crested newts, common newts, adders and grass snakes that have made that area their home? In the days of Hepworth Minerals they employed the services of a wildlife expert who regularly visited to record the amount of wildlife in the park yet when Hepworth were eventually taken over by Sibelco, this expert was told he was no longer required. This is presumably because they did not want this information recorded in case it caused them problems in the future?
* Please also take into account the point of restoration as:
o The previous extraction sites leased to Silbelco or the previous owners located to the North West have been left in an appalling state with NO RESTORATION!
o Please look at the areas of water left following the previous extractions. Many of these 'lakes' are not suitable for anything at all.
oWhat restoration is proposed and how will it be governed?

* Covenants should also be considered because:
o Covenants to restore the land etc following the extraction appear to have no or little value. Planning was granted to Leziate Sailing club land for the development of housing with the loss of community assets which were covered by covenants and/or a Section 52 order by the BCKLWN {18/00053/O}
o The Land Registry documents for this site have numerous covenants - Have these no value too?
* Does this area really need another large lake following this proposed excavation? It is my firm belief that, following recent deaths in other Bawsey lakes, this area has enough lakes and despite warnings, people will enter the water. If Norfolk County Council agree to allow this excavation there WILL be future problems with the resulting water and if any deaths occur in this water the County Councillors will have this on their conscience forevermore.
I would in summary ask you to seriously consider whether the threat to a small farming family business who produce some of the best pedigree livestock in the country, a vast array of birds, wildlife species and trees are really worth destroying in order to allow a large corporate business to extract 1,200,000 tonnes of sand just to increase their profits. With recent bad publicity and the loss of lives through drowning in the bawsey/leziate lakes I believe we do not need another lake left in the area as a result of sand excavation.

1. Response to Draft Policies
1.1 Strategy - Vision and Objectives
1.1.1 Mineral Safeguarding should refer to paragraph 182 of the revised National Planning Policy Framework (NPPF) such that the applicant for adjacent development ('agent of change') should be required to provide suitable mitigation to take account of existing and allocated development.

1.2 Mineral Strategic Objectives
1.2.1 The Mineral Strategic Objectives should be revised to properly reflect the wording of the NPPF.

1.2.2 MSO2
1.2.3 We suggest that MSO2 is amended to read (new text in CAPITALS):
"To provide a steady and adequate supply of industrial minerals by identifying adequate mineral extraction sites/areas within Norfolk sufficient to meet the forecast need AND STOCKS OF PERMITTED RESERVES OF SILICA SAND OF AT LEAST 10 YEARS PRODUCTION FOR INDIVIDUAL SILICA SITES OR AT LEAST 15 YEARS WHERE SIGNIFICANT NEW CAPITAL IS CAPITAL IS REQUIRED and safeguarding existing infrastructure"

1.2.4 We suggest that MS04 is amended to read:
1.2.5 "To safeguard silica sand, carstone, and sand and gravel resources for future use. Avoiding unnecessary sterilisation by encouraging the extraction of minerals prior to other development taking place where practicable and using minerals in construction on the land from which they are extracted. THE 'AGENT OF CHANGE' PRINCIPLE WILL BE APPLIED TO ANY NEW PROPOSED DEVELOPMENT IMPACTING ON SAFEGUARDED AREAS OR SITES."

1.3 Policy MW3 Transport
1.3.1 Proposed amendment to bullet point 4 under part d) of the policy:
1.3.2 "Where practical and realistic measures to reduce car travel to the site by workers and visitors and encourage walking, cycling and use of public transport."

1.3.3 Policy MW4 Climate Change
1.3.4 Proposed change:
g) incorporate proposals for sustainable travel, including travel plans where PRACTICAL AND appropriate.
1.3.5 Due to the often-isolated nature of mineral workings public transport or cycling are not practical. Therefore, the additional wording is suggested to make the policy effective and preventing unnecessary work for the developer/applicant.

1.4 MW6: Agricultural Soils
1.4.1 This policy should be applied flexibly since minerals can clearly only be worked where they exist and for silica sand for glass making the potential land is further restricted by virtue of the scarcity of this mineral.

1.5 MP1: Provision for minerals extraction
1.5.1 Changes are required to make it clear that the landbanks levels have to be maintained so they are in place at the end of the plan period to make the policy accord with national policy and be effective. In respect of silica sand changes are needed to make the policy accord with NPPF .

1.5.2 Suggested changes as follows;
The strategy for minerals extraction is to allocate sufficient sites to meet the forecast need for both sand & gravel and hard rock (carstone).

For sand and gravel, specific sites to deliver at least 20,313,300 tonnes of resources will be allocated. The sand and gravel landbank will be maintained at a level of at least 7 years supply THROUGHOUT THE PLAN PERIOD (excluding any contribution from borrow pits for major construction projects).

Mineral extraction for sand and gravel outside of allocated sites will be resisted by the Mineral Planning Authority unless the applicant can demonstrate: a) There is an overriding justification and/or overriding benefit for the proposed extraction, and b) The proposal is consistent with all other relevant policies set out in the Development Plan.

For carstone, a site or sites to deliver at least 340,200 tonnes of resources will be allocated.
The landbank for carstone will be maintained at a level of at least 10 years' supply
THROUGHOUT THE PLAN PERIOD.

For silica sand, sufficient sites and/or areas to deliver at least 10,500,000 tonnes of silica sand
will be allocated. The landbank STOCKS OF PERMITTED RESERVES FOR SILICA SAND WILL BE
MAINTAINED AT A LEVEL OF AT LEAST 10 YEARS' SUPPLY PRODUCTION FOR EACH INDIVIDUAL SILICA SAND SITE OR AT LEAST 15 YEARS WHERE SIGNIFICANT NEW CAPITAL IS REQUIRED [DELETE: Where practicable]. Planning applications for silica sand extraction located outside of allocated sites or areas of search, which would address the shortfall in permitted reserves, will be determined on their own merits in accordance with the policies in this Local Plan, including the requirements contained within Policy MP13.

1.6 Policy MP2: Spatial Strategy for mineral extraction - strategic policy

1.6.1 There should be no buffers applied to the so-called planning constraints. The acceptability or not of approaching such constraints will be a matter for the EIA and the development management process. Arbitrary buffers risk the sterilisation of workable mineral when they could be satisfactorily worked without impact.

1.6.2 There is no evidential basis for the buffers and the policy is unsound as it is not effective and is not positive planning.

1.7 Policy MP11: Mineral Safeguarding Areas and Mineral Consultation Areas

1.7.1 The policy wording should be altered to incorporate the 'agent of change' principle:
The County Council will safeguard existing, permitted and allocated mineral extraction sites from inappropriate development proposals. Minerals Consultation Areas are delineated on the Policies Map and extend to 250 metres from each safeguarded site. Development proposals within 250 metres of a safeguarded site should demonstrate that they would not prevent or prejudice the use of the safeguarded site for mineral extraction, AND THE AGENT OF CHANGE PRINCIPLE WILL BE APPLIED IN ALL SUCH CASES. The County Council will object to development proposals which would prevent or prejudice the use of safeguarded sites for mineral extraction.

2. Proposed Mineral Extraction Sites

2.1 MIN 40 land east of Grandcourt Farm, East Winch
2.1.1 Sibelco supports the specific site allocation of MIN 40.
2.1.2 Sibelco submitted a planning application accompanied by an environmental impact assessment which determines that there will be no significant impacts from the continued working of Grandcourt quarry.

2.2 SIL01 land at Mintlyn South, Bawsey
2.2.1 Sibelco supports the specific site allocation of SIL01.

2.3 AOS E land to the north of Shouldham.
2.3.1 Sibelco supports the inclusion of Area of Search E, land to the north of Shouldham.

2.3.2 We disagree with the updated plans of the area which identify an arbitrarily drawn heritage setting standoff. The standoffs are based on a Heritage Impact Assessment (Percival, 2019) which by its own admission is incomplete. There is not 'clear and convincing justification' for these arbitrarily drawn standoffs. Any application forthcoming within the Areas of Search should be determined on its own merits and supported by a detailed environmental impact assessment.

2.4 AOS F land to the north of Stow Bardolph
2.4.1 Sibelco supports the inclusion of Area of Search F.

2.5 AOS I land to the east of South Runcton
2.5.1 Sibelco supports the inclusion of Area of Search I.

2.6 AOS J land to the east of Tottenhill
2.6.1 Sibelco supports the inclusion of Area of Search J.

2.7 Policy MP13: Areas of Search for silica sand extraction
2.7.1 Sibelco supports policy MP13. This policy should be applied flexibly since minerals can clearly only be worked where they exist and for silica sand for glass making the potential land is further restricted by virtue of the scarcity of this mineral.

2.8 SIL02: land at Shouldham and Marham
2.8.1 Sibelco supports the inclusion of SIL02 as an allocated site and would propose that given the promoters knowledge of the local geology, the site should be allocated as a Specific Site.
Further silica sand provision will be required at the end of the Plan period
2.8.2 The National Planning Practice Guidance says:
"designating Specific Sites - where viable mineral resources are known to exist, landowners are supportive of minerals development and the proposal is likely to be acceptable in planning terms..."
2.8.3 This definition applies to SIL02.
2.8.4 The Mineral Planning Authorities conclusion (paragraph 2.28) is subjective. It would be for any planning application coming forward on the site to proposed a method of working and restoration to satisfy concerns regarding bird hazard.
2.8.5 In the context of NPPF paragraph 16 the plan as written is not positively prepared and there remains a significant shortfall in silica sand supply. SIL02 should be allocated as a specific site with any subsequent planning application required to evidence the effective mitigation measure in relation to concerns regarding bird hazard.

Thank you for consulting DIO Safeguarding on the Norfolk Minerals and Waste preferred options consultation paper. This office previously commented on the Norfolk Minerals and Waste Local Plan in December 2018.

The sites identified as part of the Norfolk Minerals and Waste Local Plan occupy the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The MODs main concern regarding mineral schemes is the phased working, proposed restoration and aftercare of the site. As the creation of open water bodies in this area has the potential to increase birdstrike risk to aircraft operations.
The preferred options paper identifies sites deemed viable for sand and gravel extraction. Please note each planning application is assessed on their individual merits at present there is limited information for a full detailed assessment to be carried out. The MODs original representation dated the 10th December remains extant:

MIN 40 - Land East of Grandcourt Farm, East Winch
The MOD commented on this application and the proposed extension to Grandcourt Farm at planning stages. There is an existing BMP in place which includes the extension site. Therefore, the MOD stated no objection subject to the BMP being implemented as part of planning consent.

MIN 6 - Land East of Winch Road,Mill Drove Middleton
This site occupies the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The proposed restoration for this site is low level heathland. The MOD has no safeguarding objection to this site being used subject to dry restoration.

SIL 01 Land at Mintlyn South, Bawsey
This site is approximately 12.4km north by north west from RAF Marham, any proposed water bodies would need to be designed to the following principles:
* No islands- as they provide safe predator free environment for roosting and nesting birds
* The bank margins are planted with dense goose proof barrier of emergent vegetation (common reed) or fenced to prevent easy access between open water and nearby short grass areas.
* A BHMP to remove or treat any feral goose nests and eggs to prevent feral geese successfully breeding on site
The above is based on the information available at present.

AOS E Land north of Shouldham
The sites use is already constrained by Historic England. Therefore, the land to the south, east and west of AOS E is being identified for mineral extraction.
The area of search is approximately 6km west from the centre of the main runway at RAF Marham. It is difficult to determine the risk of wet restoration in this location without any plans illustrating the extent and design of open water bodies.
The MOD have safeguarding concerns to the wet working and restoration of this site due to its potential to attract and support hazardous waterfowl closer within critical airspace. Therefore, further information would be required before a definitive response can be made.

AOS J Land east of Tottenhill
In line with my comments above wet working and restoration at this location would have the potential to attract and support hazardous waterfowl. The MOD is unable to determine the extent of our concerns without knowing the restoration scheme.

AOS F Land to the North of Stow Bardolph
In line with my comments above wet working and restoration at this location would have the potential to attract and support hazardous waterfowl. The MOD is unable to determine the extent of our concerns without knowing the restoration scheme.

AOS I Land to the East of South Runcton
In line with my comments above wet working and restoration at this location would have the potential to attract and support hazardous waterfowl. The MOD is unable to determine the extent of our concerns without knowing the restoration scheme.

The MOD note site SIL 02 Land at Shouldham and Marham has been deemed to be an unviable site option. This site is approximately 4.8km north west from RAF Marham. The proposed extraction is a considerable area which is planned to be restored with large areas of open water.

A development of this nature in such proximity to the aerodrome is of great concern to aircraft safety.

Even if the site were to be reduced in scale this would be of serious concern to the MOD. Therefore, we support the removal of this site based on current restoration plans.

In summary, MIN 40 and MIN 6 the MOD has no safeguarding concerns subject to the implementation of a robust Bird Hazard Management Plan approved by the MOD as part of any planning permission granted.

With regards to SIL 01 at present this site is of concern to the MOD. However, due to its location depending on the nature and scale of the restoration should be manageable with the right restoration and a BHMP in place.

AOS E, F, J and I the MOD has concerns and would require further information to determine whether the sites could be managed with design principles and a BMP. This is supported by policy NP13 'if a planning application were to be submitted for these sites the applicant must submit a bird hazard management plan and bird hazard assessment.'

I trust this is clear however should you have any questions please do not hesitate to contact me.

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 Draft 2019

Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]

SUMMARY
Whilst we consider many aspects of the plan to be sound we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan.

Under paragraph 35 of the NPPF some aspects of this Plan are unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound. In summary we highlight the following issues:

a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.

b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.

c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.

d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.

Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes do not go to the heart of the Plan's soundness, but instead are intended to improve upon it. We believe that these comments can be addressed by changes to wording in the plan.

Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.

We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.

In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.

Please note that absence of a comment on a policy, allocation or document in this letter does not mean that Historic England is content that the policy, allocation or document is devoid of historic environment issues. We should like to stress that this response is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise as a result of this plan, where we consider that these would have an adverse effect upon the historic environment.

If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.

Original draft response received 30.10.2019
Revised response received 08.11.2019

Highway Authority comments regarding sites proposed for allocation only

MIN 12 - North of Chapel Lane, Beetley
Acceptable subject to continued use of conveyor

MIN 51 & MIN 13 - West of Bilney Road, Beetley
Acceptable subject to suitable access strategy. MIN51 to be accessed via MIN13

MIN 200 - West of Cuckoo Lane, Carbrooke
Acceptable subject to provision of acceptable access at Mill Lane along with provision of passing places between the site and the B1108. Existing haul route and Mill Lane crossing to processing plant to be utilised, or appropriate alternative to be provided. Routing agreement required along with weight limit to protect Carbrooke settlement north of the site.

MIN 202 - South of Reepham Road, Attlebridge
Acceptable subject to use of existing access at Reepham Road and lorry routing via A1270 Broadland Northway

MIN 37 - Mayton Wood, Coltishall Rd, Buxton
Acceptable subject to provision of satisfactory temporary access at C494 Coltishall Road with acceptable visibility. Local highway improvements including widening required, to be delivered via S278 agreement. Temporary access to be removed on restoration of site. Routing agreement required.

MIN 64 - Grange Farm, Buxton Rd, Horstead
Acceptable subject to provision of satisfactory temporary access at C494 Coltishall Road with acceptable visibility. Local highway improvements including widening required, to be delivered via S278 agreement. Temporary access to be removed on restoration of site. Routing agreement required.

MIN 65 - North of Stanninghall Quary
Acceptable subject to access via existing site and routing agreement.

MIN 96 - Grange Farm (between Spixworth Rd & Coltishall La), Spixworth
Acceptable subject to access via A1270 Broadland Northway roundabout at Norwich Airport. Improvements required at the roundabout to formalise access to site, along with relocation of access gates to provide sufficient space for 2 HGVs to stop clear of the roundabout. Relocation of processing plant to south of C250 Church Lane required. Removal of HGV access at Buxton Road also required.

MIN 213 - Mansom Plantation, Stratton Strawless
Acceptable subject to acceptable access at Shortthorn Road and routing agreement via A140.

MIN 206 - Oak Field west of Lynn Road, Tottenhill
Acceptable subject to access via land to north, then A10. Routing agreement required.

MIN 69 - North of Holt Road, Aylmerton
Acceptable subject to provision of right hand turn lane at A148 junction with Briton's Lane, visibility improvements at site access, improvements to Britons Lane and routing agreement, in accordance with the existing allocation.

MIN 115 - Lord Anson's Wood, North Walsham
Acceptable subject to site access being via private haul route to acceptable access at B1150

MIN 207 - Pinkney Field, Briston
Acceptable subject to continuation of existing haul route

MIN 208 - South of Holt Road, East Beckham
Acceptable subject to access via existing right turn facility. Right turn lane to be removed following completion of extraction/restoration.

MIN 209 - Adjacent to A143 (Extension Area 1), Earsham
Acceptable subject to appropriate highway access and local highway improvements at Hall Road

MIN 210 - Adjacent to A143 (Extension Area 2), Earsham
Acceptable subject to site access via Site MIN 209 along with any appropriate improvements to the local highway at Hall Road and the site access. Material conveyor required.

MIN 211 - West of Bath Hills Rd (Extension Area 2), Earsham
Acceptable subject to site access via Site MIN 209 along with any appropriate improvements to the local highway at Hall Road and the site access. Material conveyor required.

MIN 25 - Manor Farm (between Loddon Rd & Thorpe Rd), Haddiscoe
Acceptable subject to suitable access strategy either via Crab Apple Lane, or direct to B1136. Access via Crab Lane would require local highway improvements to include widening to the access and visibility at the B1136 junction in accordance with DMRB. Direct access via B1136 to include visibility in accordance with DMRB.

MIN 212 - Mundham Rd, Mundham
The Highway Authority would not wish to comment regarding the proposed mineral extraction site. However, the location of the processing site is a concern and in particular the routing of HGVs through Trowse village. It would be desirable if the material could be processed at source.

MIN 6 - East Winch Rd, Mill Drove, Middleton
Acceptable subject to use of internal haul route, existing processing facilities, acceptable visibility at access and routing agreement. The allocation would result in a continuation of turning movements at the A47, Highways England should have the opportunity to comment.

MIN 40 - East of Grandcourt Farm, East Winch
Acceptable subject to material processing at existing plant, use of existing internal haul-route required and continued use of rail for material transportation.

SIL 01 - Mintlyn South, Bawsey
Acceptable subject to extraction phased with MIN 40, submission of Transport Assessment with acceptable access strategy. Material transportation to existing processing plant via internal haul route and acceptbale crossing / conveyor of highway and utilise existing rail facilities.

AOS E - North of Shouldham
Subject to submission of Transport Assessment including delivery of acceptable highway improvements. Access to be via A143 with right turn lane with suitable levels of visibility. Access via West Briggs Drove would not be appropriate without significant improvement. Movement of material using off-highway routes, or conveyor/pipeline etc. preferred. Should material be conveyed by highway, a suitable access to the processing facility shall be provided shall be provided at B1145, to an acceptable standard including visibility. Highways England should be consulted regarding vehicle movements at Hardwick Interchange. Material extraction to be phased such that no more than one Silica site at any one time will transport material by road.

AOS F - North of Stow Bardolph
Subject to submission of Transport Assessment including delivery of acceptable highway improvements. Northern site, access via Runcton Road, widening may be required along with improvements at its junction with A10 to include right turn lane. Southern site, access to be via A10 with right turn lane with suitable levels of visibility. Movement of material using off-highway routes, or conveyor/pipeline etc. preferred. Should material be conveyed by highway, a suitable access to the processing facility shall be provided shall be provided at B1145, to an acceptable standard including visibility. Highways England should be consulted regarding vehicle movements at Hardwick Interchange. Material extraction to be phased such that no more than one Silica site at any one time will transport material by road.

AOS I - East of South Runcton
Subject to submission of Transport Assessment including delivery of acceptable highway improvements. Runcton Road would require widening along with improvements at its junction with A10, or A134 to include right turn lane. Movement of material using off-highway routes, or conveyor/pipeline etc. preferred. Should material be conveyed by highway, a suitable access to the processing facility shall be provided shall be provided at B1145, to an acceptable standard including visibility. Highways England should be consulted regarding vehicle movements at Hardwick Interchange. Material extraction to be phased such that no more than one Silica site at any one time will transport material by road.

AOS J - East of Tottenhill
Subject to submission of Transport Assessment including delivery of acceptable highway improvements. Access via A134 to include right turn lane. Movement of material using off-highway routes, or conveyor/pipeline etc. preferred. Should material be conveyed by highway, a suitable access to the processing facility shall be provided shall be provided at B1145, to an acceptable standard including visibility. Highways England should be consulted regarding vehicle movements at Hardwick Interchange. Material extraction to be phased such that no more than one Silica site at any one time will transport material by road.

Response to the Preferred Options Consultation for the Proposed Silica Extraction Site at Land north of Stow Bardolph within the Norfolk Minerals Local Plan Review
October 2019
Prepared by Fisher German LLP on behalf of Mr and Mrs Plaxton

01 Introduction
These representations have been prepared on behalf of Mr and Mrs Plaxton in respect of their land interests at the Wallington Hall Estate. The Wallington Hall Estate is situated within the Borough of Kings Lynn and West Norfolk and is located 8 miles to the south of Kings Lynn town centre. The Estate is situated between South Runcton to the north and Stow Bardolph to the south and is bounded by Lynn Road (A10) to the east and Woodlakes Park to the west.

A proportion of our client's land has been included as an area of search for proposed silica sand extraction within the draft Preferred Options Document produced by Norfolk County Council. The draft Preferred Options document was presented to Norfolk County Council's Cabinet meeting on 5 August 2019 with a recommendation for public consultation to take place between the 18 September 2019 until the 30 October 2019. The recommendation was taken forward and this representation is submitted in response to the Preferred Options document public consultation.
Our clients have not been consulted in any way regarding the proposed inclusion of their land within an area of search for mineral extraction sites by the proposed operator or the County Council. They wish to object to the inclusion of their land, and the wider proposed allocation. This representation proposes that the site referenced as AOS F 'Land north of Stow Bardolph' should be removed as an emerging allocation in the Norfolk Minerals Local Plan. There are specific factors which indicate this site is not suitable and that there are more appropriate site allocations that should be progressed instead that will more than meet the requirements of the Plan.

Site Context
The relevant part of our client's land is shown in Figure 1 [attached] edged red and comprises the Wallington Hall Estate. The black edged plot represents the area of land which has been included as an area of search for minerals extraction.
The plan included at Figure 2 [attached] shows the extent of the proposed area of search (AOS F) which includes land to the north of Stow Bardolph. The parcel affecting our clients land is one of two being considered under this reference and extends to 30 hectares in size. The land comprises a mixture of forestry and agricultural uses and is around 17 kilometres from the Leziate processing plant.
These representations seek to demonstrate that there is compelling justification to remove the AOS F site from further consideration. There are more appropriate options for the proposed silica sand extraction sites that should be investigated further within Norfolk rather than AOS F.

Policy Context
Norfolk County Council are in the process of preparing the Norfolk Minerals and Waste Local Plan Review to consolidate the three adopted Development Plan Documents into one Local Plan in order to extend the plan period to the end of the 2036. It is noted that the Minerals and Waste Local Plan Review is currently at the Preferred Options Public Consultation stage.
The Core Strategy and Minerals and Waste Development Management Policies Development Plan Document (DPD) sets out the Norfolk Minerals and Waste Development Framework for the county. The Mineral Site Specific Allocations Development Plan Document was adopted in 2017 by Norfolk County Council and the Waste Site Specific Allocations Development Plan Document was adopted in October 2013.
The next section of the report provides extensive justification to support the view that Area of Search F should not be taken forward for silica sand extraction site in the Norfolk Minerals and Waste Local Plan review.

02 Area of Search- AOS F Land to the north of Stow Bardolph: Proposed removal of the area for further assessment.
This section of the report sets out the reasoning behind the request for the AOS F removal as an Area of Search for silica sand extraction sites in West Norfolk.
Landowner consent/support

As previously indicated, our client's land constitutes a substantial proportion of the area of search and landowner consent and approval for inclusion as an area of search has not been sought. Our client does not support the inclusion of their land within this area of search and as such extraction in this location is undeliverable. Deliverability is a key test for emerging plan allocations and this area of search fails to meet this test. This area comprises woodland which is valued by the Estate and those in the local area as set out later in this report.

Heritage Impact
There are two Grade I listed buildings situated within 1km of this area of search which importantly includes Wallington Hall, which is located 0.68km from the proposed site, and Church of the Holy Trinity (1km). The Grade I listed Hall is located approximately half a kilometre from the proposed site, and land within the same ownership as the Hall is proposed for inclusion within the area of search. Grade I listed status is particularly special and only buildings which are of exceptional national, architectural or historical importance are designated as Grade I. Such buildings represent only 2.5% of listed buildings. At such close proximity, significant heritage impact is expected if mineral extraction were to occur on land within or adjoining the estate.
The Grade II listed buildings located within 1km of the proposed silica site include the kitchen and service range for Wallington Hall (0.70km), the walled garden to Wallington Hall (0.72km), Almhouses (0.74km), the Cottage (0.74km), the Hare Arms (0.78km), the forecourt wall and gate piers to Wallington Hall enclosing rectangle to south of house (0.79km) and the remains of Church of St Margaret (0.86km). The northern section of the area of search also encroaches within the curtilage of the Wallington Hall Estate. There are a number of listed buildings within close proximity and these would be adversely affected by mineral extraction.
Paragraph 194 of the National Planning Policy Framework (NPPF) states that 'Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification. Substantial harm to or loss of: a) grade II listed buildings, or grade II registered parks or gardens, should be exceptional; b) assets of the highest significance, notably scheduled monuments, protected wreck sites, registered battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional' . Given the proximity of the area of search to both Grade I and II listed buildings a significant impact would be expected from mineral extraction on the buildings and their setting.

Amenity
Residential amenity is a key issue given that the area of search is located approximately 17 km from the Leziate processing plant which is where extracted silica would need to be transported for processing into a marketable product. Therefore, all the properties within 100m of the 17km road network would be impacted by dust, air quality impacts and noise impacts stemming from the HGV vehicle movements in order to move the extracted silica from the site to the processing plant. This would represent extensive impacts spread over a considerable geographical area and impact upon multiple sensitive receptors and residential areas.

Highway Access:
The highways access route from the proposed silica extraction site to the Silbelco processing Plant at Leziate is 17 km in distance. This means that the proposed silica sand extraction site at the land north of Stow Bardolph is located the second furthest distance away from the processing plant, when compared to the other proposed silica sand extraction sites. Additionally, the volume of traffic on the A10 is likely to increase as a result of the number of HGVs required to transport the silica from the proposed site to the processing plant at Leziate. Paragraph 109 of the NPPF states that development should be prevented if there is an 'unacceptable impact on highway safety'. Local information is that there have been a number of accidents along this section of the A10 in recent years and the additional traffic is likely to increase the risk of this.
This factor has not been adequately considered when proposing the area of search and should mean that the site is not taken forward for further consideration. The processing plant is a considerable distance from the area of search and there are more suitable sites significantly closer. The additional movements would potentially have amenity, highway safety and other adverse impacts on the transport route and adjoining areas which has not been adequately assessed to date. Forecast production of 900,000 tonnes per annum would require over 64,000 HGV movements at the site (assuming an average load of 28t per HGV) or 256 per day (assuming 50 working weeks per annum.) This would place an unacceptable burden on an already busy road.

Community/Neighbourhood Value
A proportion of the Wallington Estate is currently used for charity work, in providing horse riding activities for people with disabilities through the woodland. These activities are able to take place through the Magpie Centre and are based from Wallington Hall. The charity gives people with disabilities the opportunity to horse ride and has been operating as a dedicated Riding for the Disabled Association Riding Centre for over 30 years Figures 4 and 5 show the horse riding opportunities that take place at Wallington Hall through the Magpie Centre, which operates 5 days per week.
The centre provides 130 riding and carriage driving lessons a week and is supported by over 50 volunteers from the local community who help with the ponies, lessons, field maintenance and fundraising. This shows that the centre is a valued asset to the local community and is a resource used by a significant number of people, including volunteers and people with disabilities. The implementation of the proposed silica sand extraction site would have a detrimental impact on the ability of the horse riding activities for people with disabilities to continue in the future. The mineral extraction site located adjacent to the area of woodland would generate visual, noise and air quality impacts that would adversely affect the environment in which the horses ride, to the detriment of the community that utilise this space. Therefore, the proposed silica site should be removed as an allocation. This is a valued local community use and mineral extraction would render this location no longer suitable and would be to the detriment of the riding school and all those associated with it. This Estate is a special and tranquil environment for the riding school and it is very important that this facility is retained.

Archaeology:
The area is largely unstudied in terms of archaeology and a more detailed assessment of archaeological remains should therefore be undertaken through an archaeological survey. Sites such as the remains of St Margaret's Church situated 0.86km from the proposed silica extraction site show that there could be historic assets that have not yet been uncovered. Planning policy supports the view that a more detailed assessment of the archaeology in King's Lynn and Surrounding Area should be conducted through a heritage assets assessment which includes a review of the submitted information and relevant on-site investigations. Without such information there is uncertainty regarding suitability and deliverability which means that the allocation is potentially unsound as it cannot be taken forward with confidence that archaeology is not present.

Hydrogeology:
A hydrogeological risk assessment is required and has not been undertaken and therefore the potential impact of extraction on local hydrology is completely unknown. Again, this reinforces the point that the proposed area of search has not been investigated sufficiently and without it being considered suitable, developable and deliverable the allocation would be unsound.

Landscape:
Chiswick's Wood is an ancient woodland situated 1.4km to the east and unnamed ancient woodlands are located 1.2km south east and 1.7km north east of the of the proposed silica sand extraction site.
The area of search boundary includes woodland within the Wallington Estate which is valuable to the setting of the Grade I listed Hall and the local area. National policy seeks to protect woodland and in this case the woodland provides a valuable heritage; landscape and community benefit which should be protected from the adverse impacts associated with mineral extraction.

Ecology:
The proposed silica extraction site situated at the land north of Stow Bardolph includes an area of woodland which could have a potential adverse impact on protected species within this habitat. In addition, paragraph 174 part b) of the NPPF states that plans should 'promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity'. In this case, the potential allocation of a substantial area of woodland could have adverse impact contrary to the aims of national policy.

Summary
Overall, there are substantial grounds to justify the removal of the proposed silica sand extraction allocation on land north of Stow Bardolph. These include the adverse heritage impact on the Grade I listed Wallington Hall and surrounding Estate; the loss of the woodland for use by the Riding for the Disabled Association Charity; adverse impacts on potential ecology within the woodland and landscape impacts associated with the loss of the woodland. The loss of the woodland also has impacts on the wider park and setting, as well as the circular routes used by the RDA. Additionally, the potential for archaeology; potential for hydrological impacts and the noise and dust impacts on the amenity of local residents along the 17km route from the area of search to the processing plant shows the impacts on the surrounding area within West Norfolk.

Moreover, the distance between the land at Stow Bardolph and the processing plant at Leziate is 17km and is a greater distance than all but one of the other proposed silica extraction sites. The greater distance required to transport the silica between the extraction site and the processing plant is likely to have a negative impact on the surrounding road network and contribute to increased traffic flow and congestion, because of the number of heavy goods vehicles required to transport the silica between the proposed silica sand extraction site and the processing plant.
The next section of the report identifies other silica sand extraction sites that are more suitable and sequentially preferable to the AOS_F.

03 Other Silica Extraction Site Options
The following section of the report sets out the alternative silica sand extraction site options available within West Norfolk. It is argued that alternative silica sand extraction sites would be more appropriate to be allocated than the proposed silica extraction site AOS F situated at the land north of Stow Bardolph, which includes a proportion of the Wallington Hall Estate and should be removed from further consideration.

MIN40- Land east of Grandcourt Farm, East Winch
The proposed silica extraction site located at land east of Grandcourt Farm is deemed to be more suitable than the land north of Stow Bardolph. The MIN40 allocation is situated only 1.8km from the Leziate processing plant which would make the transportation process of the silica between the extraction site and the processing plant more sustainable and minimise impacts on the highway and amenity of residents. The silica would also be transported by an internal haul route to the processing plant which would avoid any impact on the local roads. In comparison the AOS_F land north of Stow Bardolph is situated 17km from the processing plant at Leziate and is a much greater distance for transportation between the extraction site and processing plant. The proposed transportation route from AOS F would primarily use the A10 and would have greater impacts on the local roads in terms of congestion and traffic.
The MIN40 site has been put forward by Sibelco UK as an extension to an existing silica extraction site. This is not the case for the AOS_F land north of Stow Bardolph which would be a completely new silica sand extraction site.

SIL01- land at Mintlyn South Bawsey
Firstly, the proposed silica extraction site SIL01 land at Mintlyn South Bawsey is part of a former mineral working which was partially extracted. This shows that the area previously has a history of mineral working, which is not the case for the land allocated at AOS_F north of Stow Bardolph which would be a new greenfield location.
Secondly, the allocation at SIL01 is situated only 700m from the processing plant at Leziate and is much closer to the processing plant than the allocation at AOS_F north of Stow Bardolph, which is located 17km away from the processing plant. Therefore, the proposed allocation at SIL01 would be able to be transported by conveyor from the extraction site to the processing plant and would not impact on the local road network at all. Contrastingly the proposed silica extraction site at AOS_F north of Stow Bardolph would have to be transported by road and this would have far greater implications on the road network.
In addition, the Agricultural Land Classification scheme classifies the land at SIL01 Mintlyn, South Bawsey as being in 'Non- Agricultural' use whereas the land at AOS_F north of Stow Bardolph is classified as being in Agricultural use.

AOS_E Land to the north of Shouldham
The area of search covers 815 hectares which is almost 25 times the size of the AOS_F proposed silica sand extraction site allocation to the north of Stow Bardolph,. The proposed mineral extraction sites information produced by Norfolk County Council show that the MIN 40 land east of Grandcourt Farm proposed silica sand extraction site has an estimated resource of 3,000,000 tonnes for a 33 hectare site.
It is evident that no detailed information was put forward regarding the potential yield of AOS E and that estimated mineral tonnages are not able to be extrapolated accurately. However, there is a possibility given the very large area that this designation covers, that the estimated resource that could be derived from the proposed silica sand extraction site at AOS_E could more than satisfy the forecast need of 10,500,000 tonnes of silica sand required during the plan period. This means there is an argument to only allocate the proposed silica sand extraction site AOS_E to the north of Shouldham because it would satisfy the need for the required silica sand needed during the plan period.
The AOS_E site allocation is situated 2km closer to the processing plant at Leziate than the AOS_F site which is another reason why the AOS_E proposed silica extraction site is a more favourable option. In addition, the AOS_E proposed silica sand extraction site is adjacent to previous and current mineral workings and close to a sand and gravel allocation. This means that the AOS_E site could be seen as an extension to existing mineral operations, which the NPPF would prefer to the opening of a new site. In comparison the surrounding land at AOS_F for the land north of Stow Bardolph has no previous history of mineral extraction.

AOS_I Land to the east of South Runcton
The proposed silica sand extraction site AOS_I land to the east of South Runcton is situated 16km from the processing plant at Leziate, which is 1km closer than the AOS_F allocation. Although this does not seem a significant difference, when the number of HGV movements that will be required to transport the resource between the silica sand extraction site and the processing plant each year is considered, it creates a noticeable increase in impact. This means that the proposed silica sand extraction site AOS_ should be considered a more favourable allocation than the AOS_F land because it is situated in closer proximity to the processing plant at Leziate.
Moreover, the proposed silica sand extraction AOS_I site covers 47 hectares which is over 15 hectares larger than the AOS_F site that incorporates part of the Wallington Hall Estate. This means that the potential resource that could be derived from the AOS_I site is likely to be greater than the AOS_F site. Therefore, the proposed silica sand extraction for AOS_I land to the east of South Runcton is more favourable to be used as a site allocation than the AOS_F land to the north of Stow Bardolph.

AOS_J Land to the east of Tottenhill
The proposed silica sand extraction site AOS_J land to the east of Tottenhill is situated 15km from the processing plant at Leziate, which is 2km closer than the distance between the proposed site AOS_F . Similarly to the point in the previous section (AOS_ I land to the east of South Runcton), although this distance does not seem a significant difference, when it is considered the number of HGVs that will be required to transport the resource between the silica sand extraction site and the processing plant each year, the impact is more significant than it may appear. Therefore the distance in the transportation of the silica between the AOS_J site and the processing plant at Leziate makes it a more favourable option than the AOS_F site allocation.

SIL02 Land at Shouldham and Marham
Although this site has not been allocated as a proposed silica sand extraction site by Norfolk County Council it has been considered as a potential 'Preferred Area'. The estimated resource in tonnes for silica that could be extracted from this site is believed to be 16,000,000 tonnes, which could more than satisfy the forecast need of 10,500,000 tonnes of silica sand during the plan period. There is an argument which supports the idea that if the proposed silica sand extraction situated at SIL02 land at Shouldham and Marham was allocated, then the other allocations would not be needed as forecast for the required silica sand within the plan period would already have been met.
However, the proposed silica sand extraction sites in West Norfolk document prepared by Norfolk County Council suggests that the proposer of the site has given a potential start date of 2027 and estimated the extraction rate to be 800,000 to 900,000 tonnes per annum. Using this information, the full mineral resource at Site SIL02 could be extracted within 20 years and means 9,000,000 tonnes could be extracted within the plan period. This means that if the SIL02 site was allocated as a proposed silica sand extraction site it would go a long way towards securing the silica required during the plan period.
Furthermore the SIL02 proposed silica extraction site should be preferred to the AOS_F site because the SIL02 site is situated only 6km from the Leziate processing plant and this enables the mineral to have the potential to be transported by pipeline rather than road. In comparison the AOS_F proposed silica sand extraction site is situated 17km from the Leziate processing plant and would need to be transported by road. For these reasons, it is evident that the SIL02 proposed silica sand extraction is a more favourable allocation than the AOS_F site.

04 Conclusion
To summarise, the preferred option document for the Minerals and Waste Local Plan Review is currently under review. The proposed area of search AOS F for silica sand extraction includes part of the Wallington Hall Estate. These representations seek to remove this area of search entirely from the local plan review process. There are alternative sequentially preferable areas under consideration and potentially significant site specific impacts associated with AOS F which justify its removal. A further point is that the landowner had not been consulted prior to the allocation of AOS F and does not approve of the submission.
Overall, there are substantial grounds in terms of potential impact to justify the removal of the proposed silica sand extraction allocation on land north of Stow Bardolph. These include the adverse heritage impact on the Grade I listed Wallington Hall and surrounding Estate; the loss of the RDA group use of the woodland; adverse impacts on potential ecology within the woodland and landscape impacts associated with the loss of the woodland; the potential for archaeology; potential for hydrological impacts and the noise and dust impacts on the amenity of local residents along the 17km route from the area of search to the processing plant.
It is appropriate to allocate sequentially preferable areas of search instead of area of search F which is not required in the extended plan period for proposed silica sand extraction and because of its size would not make a significant contribution to the tonnage required to meet the Plan's needs. There are sites situated substantially closer to the processing plant at Leziate that have a greater potential to extract a higher tonnage of silica through being larger site allocations in terms of area. Therefore, the proposed silica sand AOS_F extraction site should be removed.

Arboriculture
I am satisfied that arboricultural implications have been suitably considered within the wider landscape and ecological context for the allocated sites and that my previous comments have been addressed. I have brief comments about 2 further sites.

SIL01 Mintlyn South, Bawsey
Many trees within the site boundary will be lost. Development should be subject to the additional requirement of an Arboricultural Impact Assessment to ensure sufficient standoff from the adjacent trees

MIN 213 Stratton Strawless
This site is surrounded by coniferous woodland and would therefore require an AIA at the planning application stage to ensure sufficient standoff from the adjacent trees. This to ensure a sufficient area of their roots are protected for their safe long term retention as part of the restored site.

Landscape
I am satisfied that my previous comments have been taken into consideration and addressed where necessary. I have no further comments in relation to the proposed Waste sites Appendix 10 Sites 1-6.
SIL01
Whilst the will be unavoidable landscape and visual impacts of extraction at this site, an LVIA will be able to assess these and suggest appropriate mitigation measures. The restoration scheme will need to be carefully designed to take into account the assessment and should reflect the wider context and what is lost during the extraction.
Min 213
A suitable landscape buffer of woodland is proposed to be retained which should minimise visual impacts from outside the site It will be important that a standoff is in please to protect these trees in longevity. Consideration will be required in relation to views from the proposed entrance, to ensure that this is suitably designed to minimise impacts.

Original response received 30.10 2019
Revised response received 18.12.2019

3. Implications for the Borough from sand and gravel and silica sand policies / areas
3.1 Tottenhill (Site 206 - West of Lynn Road) This is an extension of existing works. The Tottenhill sites would be worked sequentially to mitigate any cumulative impacts. Potentially acceptable subject to the requirements in the policy.

3.2 A site at East Winch (Site MIN06 Mill Drove, Middleton) is allocated for carstone extraction. Potentially acceptable subject to the requirements in the policy.

3.3 Silica sand - AoS's (E, F, J and I) and SIL01. The County Council concludes that Site SIL01 is suitable to allocate for silica sand extraction. Development will be subject to compliance with the relevant Minerals and Waste Local Plan Policies and Specific Site Allocation Policy SIL01. There are reasonable safeguards for the locality.

3.4 The AoS are the same as previously expressed in the Initial Consultation document. Silica sand is a nationally important industrial mineral, and as such, the County Council must make adequate provision for its extraction. However they are not able to find suitable sites for the quantity of sand required, especially having dropped a site at Shouldham / Marham. The AoS are large and the expectation is that a suitable location could be found within one of the areas. Without detailed further information or operator preferences, it is not possible to pinpoint a site and therefore assess the localised impacts. Whilst this may be unsatisfactory for local communities who fear the consequences of extraction, it does give a positive indication that the County Council is safeguarding land and narrowing down suitable sites. It would be unrealistic to seek to have no areas of search at all, and the Plan could be found 'unsound', which would not be of benefit to the area.

Policy MP13 Silica Sand Area of Search (AoS E - Shouldham Warren area) and Policy MP2 - Spatial Strategy for mineral extraction (including reference to Silica Sand Areas of Search, and buffer zones (clause e))
3.5 Policy MP13 provides a criterion based approach to potential development in Areas of Search, including Area E. The expectation is that various assessments about related impacts will be provided in support of any applications, covering matters such as archaeology, landscape etc. Heavy reliance is placed on the safeguards from supporting studies to achieve acceptable development.
The recent decision by Norfolk County Council (in respect of it's Environmental Policy - County Council 25 November) to support the planting of some 1 million trees over the next 5 years to mitigate for the effects of climate change suggests a significant policy shift in the important role that trees play in County Council operations. It is clear that much more attention needs to be given the retention of existing tree cover in any mineral extraction situation. Shouldham Warren is an extensive area of tree cover, with additional recreation opportunities. An elevated status needs to be given to this in the planning balance as to whether an Area of Search should be designated at Shouldham, the Borough Council view is that the County Council should remove the AoS for this reason.
Additionally, Policy MP2 provides a degree of protection for areas with defined characteristics. Clause a. refers to 'ancient' woodland. In view of the County Council decision referred to above, it would be appropriate to delete the word 'ancient', leaving an enhanced level of protection to woodland generally.
Conclusion on AoS E (Shouldham) - Taking into account the two proposed amendments to policies affecting the potential for extraction at Shouldham, and the significant additional constraints now evident, the AoS should be removed.
MP2 Clause e) - Whilst the hydrological catchment around Roydon Common and Dersingham Bog, is specifically mentioned in Policy MP2e for exclusion, the complex hydrology and geology of these extremely sensitive sites is not fully understood. These two habitats have been recognised through the Ramsar, SAC and SSSI designations as having protected status. The introduction of wider 1.5km buffer zones would better mitigate any risk.

3.6 Policy MP7 (relating to restoration and aftercare) suggests that preference will be given to enhancing biodiversity, green infrastructure, and high quality local landscapes. This approach is supported. Whilst not necessarily appropriate in all circumstances, tree planting on restored sites would be a useful additional boost to mitigate for climate change. It is proposed that an additional clause is added to this effect as a fifth bullet point in paragraph four to the policy.

4. Implications for the Borough from the NCC approach to proposed waste and other policies on 'energy minerals'.

4.1 NCC have reviewed the policies in the current plans and as with Minerals moved them on to an end date of 2036. One particular item is relevant to West Norfolk. This is the overall locational strategy for waste management facilities.
4.2 Main points:
* From Policy WP2 in the Preferred Options it would seem possible to locate waste management facilities away from the broad location that generated the waste. Thus necessitating potentially significant transport movements, and possibly generating resentment from recipient communities.
* Whilst not necessarily inappropriate for all types of waste where specialist facilities are needed, extremely careful thought should be given to general waste or significant quantities requiring movement.
* A better approach would seem to be one where the policy encouraged waste to be dealt with as near to the generating source as possible.
* It is suggested our original comments are still appropriate to make.
4.3 Incineration - For the avoidance of doubt, it would be helpful if the County Council could add text to explain the position whereby the County Council will not seek to procure incinerators within Norfolk.
The position of the Borough Council on incineration is clear from previous involvement in planning inquiries. A clear statement on the matter from the County Council in the Minerals and Waste Local Plan would avoid any uncertainty for residents.

4.4 Fracking - Reference could be made to latest Government announcements about the potential restrictions / banning on this subject.

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]