MIN 69 - land north of Holt Road, Aylmerton

Showing comments and forms 1 to 8 of 8

Comment

Preferred Options consultation document

Representation ID: 93565

Received: 01/10/2019

Respondent: Mr Brian Cushion

Representation Summary:

The parish boundary between Beeston Regis and Aylmerton is between the existing and proposed sites. It consists of a variable bank with irregularly spaced trees of some age and is an important part of the local historic environment. I have reported this to the NCC HER. A bridleway runs to it's west. These should not be destroyed under any circumstances. Access should be from another direction. Various public footpaths also exist within the proposed site on agricultural land, and given their location and rather difficult means of linking with others on the A148 could be considered of lesser importance.

Full text:

The parish boundary between Beeston Regis and Aylmerton is between the existing and proposed sites. It consists of a variable bank with irregularly spaced trees of some age and is an important part of the local historic environment. I have reported this to the NCC HER. A bridleway runs to it's west. These should not be destroyed under any circumstances. Access should be from another direction. Various public footpaths also exist within the proposed site on agricultural land, and given their location and rather difficult means of linking with others on the A148 could be considered of lesser importance.

Comment

Preferred Options consultation document

Representation ID: 95055

Received: 30/10/2019

Respondent: Natural England

Representation Summary:

Support the requirements listed under this policy with regard to the AONB landscape and adjacent Briton's Lane Gravel Pit SSSI. In particular, restoration proposals need to be sensitive to the Cromer Ridge in terms of the proposed gradients. Removal of the strip of land that lies between the existing quarry and the proposed extension would need to be undertaken carefully and in ways to minimise the resulting impacts that would arise from the removal of wooded areas on the landscape character, biodiversity and users of public rights of way within the AONB.

Full text:

Support the requirements listed under this policy with regard to the AONB landscape and adjacent Briton's Lane Gravel Pit SSSI. In particular, restoration proposals need to be sensitive to the Cromer Ridge in terms of the proposed gradients. Removal of the strip of land that lies between the existing quarry and the proposed extension would need to be undertaken carefully and in ways to minimise the resulting impacts that would arise from the removal of wooded areas on the landscape character, biodiversity and users of public rights of way within the AONB.

Support

Preferred Options consultation document

Representation ID: 98270

Received: 30/10/2019

Respondent: Carter Concrete Limited

Agent: David L Walker Ltd

Representation Summary:

Carter Concrete own and operate the existing sand and gravel pit at Beeston Regis. The site benefits from an allocation for an eastern extension (site MIN69 under the adopted MSA). The company is promoting the same area of land under this emerging plan (retaining the reference MIN 69).

Comments on site MIN 69
Carter Concrete has recently submitted a planning application (ref FUL/2019/0001) to receive approximately half of the mineral resource identified in this allocation profile. This is as a sustainable and logical extension to the current site utilising the processing and access infrastructure of the latter. A Regulation 25 response is being collated and will shortly be submitted to address matters raised through the consultation process in the determination of the planning application.

Carter Concrete would confirm that the boundary on the allocation map is correct but would state that the indicative site buffer illustrated in the south of the allocation are is no longer proposed. This was proposed to provide a means of mitigation in view of the proposal to remove part of the existing woodland around the current site. This proposal no longer forms part of the scheme and therefore the mitigation isn't required. It is therefore proposed that the area indicated as the herringbone hatch on the plan is no longer required and should be included in the allocation area.

A plan confirming this proposed change is attached. This also illustrates a 100m radius around the allocation area, with the only potentially sensitive receptors situated south of Holt Road which is a clear and apparent source of acoustic and air quality impacts. Carter Concrete would not disagree with the wording of paragraph M69.1 which is factual in nature but would suggest that for context the influence of the A148 on local amenity is clearly indicated as this forms part of the baseline consideration of any scheme.

Regarding paragraph M69.2, Carter Concrete have committed to provide enhancements to Britons Lane and the junction of Holt Road with Britons Lane as part of application ref FUL/2019/0001. This has included an alternative solution to provide a cost-effective means (consistent with paragraph 108c of the NPPF) to consider highways safety. The reference to the consideration of a sustainable and cost-effective alternative solution (backed up by an RSA) could therefore also be provided in this paragraph. It should also be noted that the company is also content to enter into an obligation to restrict right turn access out of the site thereby limiting traffic along Britons Lane north of the site access.

Regarding paragraph M69.3, it is recommended that the earthwork and bank features along the parish boundary between Aylmerton and Beeston Regis (Norfolk HER ref 57910) areclearly referenced for baseline context.

Reference paragraph M69.5, as part of the current planning application Carter Concrete have provided geophysical investigation and trial trench evidence which has identified that whilst there are finds and features on site these are indicative of the surrounding area and as such would only have a local value or significance. Again, this could be added to provide context.

With regard to Paragraph M69.6 this should reflect the fact that the woodland to the south is mainly advance planting provided by the applicant as a means of long-term visual mitigation.

Carter Concrete would wholly support the wording of paragraphs M69.7 and M69.8.

With respect to paragraph M69.10, it is noted that the Council would be willing to consider the removal of some trees to connect to the two landforms. Would the council be willing to confirm how much woodland could be removed in principle, as recent discussions indicated that some of the council's internal departments would be concerned with large scale removal of such habitat.

Carter Concrete would wholly support the wording of paragraphs M69.12 to M69.19 inclusive and would reaffirm that as part of the current planning application the company is developing long term plans to sustainably manage the biodiversity and geo-diversity.

Paragraphs M80.20-M69-24 inclusive, no comments are offered.

Regarding paragraph M69.25, the company would consult with the council and other interested stakeholders to develop a suitable site restoration strategy.

The prime focus of the scheme would be to provide a very high quality restoration scheme for both the existing site, and proposed extension, with an emphasis on nature conservation habitat (specifically heathland), with improved public access, better access to geo-diversity and retention of exposures wherever possible; together with information boards (conveying information about the ecology, geology and geomorphology of the site). The provision of permissive routes through the restoration landform would also be considered by Carter Concrete.

In general terms the company supports the allocation of site MIN69, with the above intended to provide greater context and content for the allocation profile.

In the event that written reps and or a hearing is required as part of the examination process Carter Concrete would reserve the right to make further representations either to reinforce the above or provide new content where applicable.

Full text:

We are instructed by Carter Concrete (part of the RG Carter Group) to prepare and submit representations on the Preferred Options consultation of the Minerals and Waste Local Plan Review.
Carter Concrete own and operate the existing sand and gravel pit at Beeston Regis. The site benefits from an allocation for an eastern extension (site MIN69 under the adopted MSA). The company is promoting the same area of land under this emerging plan (retaining the reference MIN 69).


Addressing each in turn.
1. General policy comments
Carter Concrete would support the Vision promoted by the council in section 6 of the document. However, the company would like to see emphasis placed on the value and significance of minerals and waste development in providing a diverse and affluent rural economy consistent with Paragraph 83 of the NPPF.

Carter Concrete is pleased to see the council's commitment to Sustainable Development, but is disappointed to note that the council haven't provided a clear policy in this regard. Such an approach is clearly not consistent with the NPPF nor the attendant Planning Practice Guidance. The council already has a policy in this regard (SD1 of the Mineral Site Allocations DOD 2017) which could be easily translated into this emerging policy document.

The company would support Policy MW2, but would suggest that in the final paragraph when considering potential environmental benefits this could clearly states geo-diversity benefits where applicable.

Regarding Policy MW3 whist the company supports the aspiration for the use of other transport modes more often that not such avenues are not available, and as such the term "Where appropriate" should replace the word "All".

No comments are offered on the remainder of the general or the waste policies.

As regards to the mineral policies the contents of paragraphs MP1-MP10 inclusive are supported in full. No comments are offered on the remainder of the strategic landbank type policies for the other minerals.

Under paragraph MP2.6 the company would question the definition of a Main Town as this does not appear to list the town of Sherringham which is a clear development centre identified under local policy documents.

In respect of Policy MP2, paragraph 23 of the NPPF states "Broad locations for development should be indicated on a key diagram, and landuse designations and allocations identified on a policies map." The spatial definition identified is suggested to be too narrow to meet the broad criteria identified above and is therefore not consistent with national policy as it does not take account of the unique facet of minerals extraction (i.e. they can only be worked where they are found).

Paragraph MP7.6 refers to Green Infrastructure mapping. It is suggested that a high-resolution copy of the map provided is either included as an appendix or a weblink, as the drawing provided is of low quality and cannot be easily used on an interpretive basis.

It is considered that Policy MP7 should apply equally to extensions as well as new sites.

It is respectfully suggested that Policies MP9 and MP10 could be expanded to include reference to precast blockworks to use indigenous materials and aggregate bagging plants, as both are viable forms of ancillary development at aggregates sites in principal.

2. Comments on site MIN 69
Carter Concrete has recently submitted a planning application (ref FUL/2019/0001) to receive approximately half of the mineral resource identified in this allocation profile. This is as a sustainable and logical extension to the current site utilising the processing and access infrastructure of the latter. A Regulation 25 response is being collated and will shortly be submitted to address matters raised through the consultation process in the determination of the planning application.

Carter Concrete would confirm that the boundary on the allocation map is correct but would state that the indicative site buffer illustrated in the south of the allocation are is no longer proposed. This was proposed to provide a means of mitigation in view of the proposal to remove part of the existing woodland around the current site. This proposal no longer forms part of the scheme and therefore the mitigation isn't required. It is therefore proposed that the area indicated as the herringbone hatch on the plan is no longer required and should be included in the allocation area.

A plan confirming this proposed change is attached. This also illustrates a 100m radius around the allocation area, with the only potentially sensitive receptors situated south of Holt Road which is a clear and apparent source of acoustic and air quality impacts. Carter Concrete would not disagree with the wording of paragraph M69.1 which is factual in nature but would suggest that for context the influence of the A148 on local amenity is clearly indicated as this forms part of the baseline consideration of any scheme.

Regarding paragraph M69.2, Carter Concrete have committed to provide enhancements to Britons Lane and the junction of Holt Road with Britons Lane as part of application ref FUL/2019/0001. This has included an alternative solution to provide a cost-effective means (consistent with paragraph 108c of the NPPF) to consider highways safety. The reference to the consideration of a sustainable and cost-effective alternative solution (backed up by an RSA) could therefore also be provided in this paragraph. It should also be noted that the company is also content to enter into an obligation to restrict right turn access out of the site thereby limiting traffic along Britons Lane north of the site access.

Regarding paragraph M69.3, it is recommended that the earthwork and bank features along the parish boundary between Aylmerton and Beeston Regis (Norfolk HER ref 57910) areclearly referenced for baseline context.

Reference paragraph M69.5, as part of the current planning application Carter Concrete have provided geophysical investigation and trial trench evidence which has identified that whilst there are finds and features on site these are indicative of the surrounding area and as such would only have a local value or significance. Again, this could be added to provide context.

With regard to Paragraph M69.6 this should reflect the fact that the woodland to the south is mainly advance planting provided by the applicant as a means of long-term visual mitigation.

Carter Concrete would wholly support the wording of paragraphs M69.7 and M69.8.

With respect to paragraph M69.10, it is noted that the Council would be willing to consider the removal of some trees to connect to the two landforms. Would the council be willing to confirm how much woodland could be removed in principle, as recent discussions indicated that some of the council's internal departments would be concerned with large scale removal of such habitat.

Carter Concrete would wholly support the wording of paragraphs M69.12 to M69.19 inclusive and would reaffirm that as part of the current planning application the company is developing long term plans to sustainably manage the biodiversity and geo-diversity.

Paragraphs M80.20-M69-24 inclusive, no comments are offered.

Regarding paragraph M69.25, the company would consult with the council and other interested stakeholders to develop a suitable site restoration strategy.

The prime focus of the scheme would be to provide a very high quality restoration scheme for both the existing site, and proposed extension, with an emphasis on nature conservation habitat (specifically heathland), with improved public access, better access to geo-diversity and retention of exposures wherever possible; together with information boards (conveying information about the ecology, geology and geomorphology of the site). The provision of permissive routes through the restoration landform would also be considered by Carter Concrete.

In general terms the company supports the allocation of site MIN69, with the above intended to provide greater context and content for the allocation profile.

In the event that written reps and or a hearing is required as part of the examination process Carter Concrete would reserve the right to make further representations either to reinforce the above or provide new content where applicable.

Comment

Preferred Options consultation document

Representation ID: 98693

Received: 30/10/2019

Respondent: Norfolk Wildlife Trust

Representation Summary:

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.

Full text:

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.

Object

Preferred Options consultation document

Representation ID: 98755

Received: 30/10/2019

Respondent: Frimstone Limited

Representation Summary:

Suitability of alternatives considered as suitable for allocation

Furthermore, three sites have been considered suitable for allocation that are either within or adjacent to the AONB, a Core River Valley or any other designated landscape features, namely MIN 69, MIN 211 and MIN 25. Since MIN 35 is not located within or even close to any of these designated landscape features, preference must be given to this site in planning terms as required by the requirements of NPPF Paragraph 205.

I therefore would like to object to the inclusion of the above sites as being considered suitable for allocation, whereas MIN 35 is considered unsuitable solely on landscape grounds. It has been demonstrated above that preference should not be given to any of these sites over and above MIN 35 and that MIN 35 should be reconsidered in light of the additional supporting landscape and visual statement and be concluded as once again suitable for allocation as at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review.

Full text:

Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 35 - land at Heath Road, Eccles, Quidenham)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 35 for the reasons outlined below.

Landscape
Following the initial findings of the Preferred Options Consolation a Landscape and Visual Statement was commissioned and completed by Collington Winters in October 2019. The report demonstrates and concludes that the site would have acceptable local landscape impacts and that the screening would not be intrusive in its own right. The report also recommends that it will be possible to mitigate adverse landscape impacts through advance planting and bunding.

It is highlighted in the enclosed Landscape and Visual Statement that the proposed site is not located within the AONB, a Core River Valley or any other designated landscape features. It must be noted that unlike MIN 69 - land north of Holt Road, Aylmerton, MIN 211 - land west of Bath Hills Road, Earsham (Extension area 3) which is adjacent to the boundary of the Broads Authority Executive Area and MIN 25 - land at Manor Farm (between Loddon Road and Thorpe Road), Haddiscoe which is adjacent to a Core River Valley and also is adjacent to the boundary of the Broads Authority Executive Area).

The enclosed report also demonstrates that the existing landscape detractors mean that the proposed site cannot be considered a tranquil, unspoilt area of the countryside.
The proposal sets the limit of extraction approximately 150 metres from the southern boundary of the site, so as to allow the site to be screened in a way which would not be significantly detrimental to the views from the immediate south. Existing bunding associated with the historic landfill is present which already screens out long-range views for properties to the south of the proposed site.
The proposed new bunding associated with the MIN 35 development will be set back from the southern boundary so as to not have an adverse effect on views over the field and the woodland to the west from those properties to the south of the site. The proposed limit of extraction means that there would be less difference between the views of the existing bunding associated with the historic landfill and those of new bunding associated with this proposed development from the south and southeast of the site.

Screen bunding and advance hedge planting is proposed along the site boundary on Heath Road to ensure that users of Heath Road are not able to gain medium-to-long-range views across the site, including the existing partially screened timber yard opposite the area of the site not proposed to be worked.

Any future application for mineral extractions at this site will be accompanied with a
further carefully designed landscape scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents. Substantial buffer zones are proposed comprising advanced planting of woodland copses and planting belts, that are to be retained within the site restoration, and screen bunds in place surrounding the immediate area proposed for mineral extraction.

The temporary bunds are proposed to be of adequate height to screen the upper story views from housing and it will be ensured that the grading, profiles appearance and management of vegetation on the temporary bunds will benefit from careful treatment. These mitigation requirements shall be followed to ensure that the screening features are not visually intrusive as it is recognised that residents may have views of these across the existing agricultural fields to the east and southwest of the site, and also from the adjacent road.

I therefore wish to object to the conclusions reached in terms of considering MIN 35 unsuitable for allocation in landscape terms, as following a review of baseline information, together with consideration of likely landscape and visual effects, it is considered that the application site and wider landscape is able to accommodate the proposal for mineral extraction, in landscape and visual terms, without having an unacceptable effect or loss of landscape character or visual amenity. Any loss of landscape character would be temporary and upon restoration, character would be reinforced and enhanced.

Provision for minerals extraction (Policy MP1)
The NPPG suggests that the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision. The sub-national guidelines are for Norfolk to produce 2.57 million tonnes of sand and gravel a year.
It has been considered by the MPA that planning to provide the 20-year average annual production figure would enable a sufficient quantity of sand and gravel resources to be available over the 18- year plan period and would take into account potential fluctuations in the economy.
Over the 18-year plan period to 2036, using the considered suitable 20-year average of 1.868 million tpa, 33.624 million tonnes of sand and gravel resources would be needed in total. Taking into account the existing permitted reserve, the remaining need for allocated sites is 20.313 million tonnes of sand and gravel.
However, using the sub-national guidelines for sand and gravel, as specified in the NPPG this would mean that sites for 32,949,300 tonnes of sand and gravel extraction would need to be allocated over the plan period. The sub-national guideline figures cover the period 2005-2020 and therefore remains current at this stage of the Consultation process, and must remain so until these figures are updated. Therefore, a stronger case has to be made by the MPA as to why they consider the current subnational guidelines not to be relevant in producing this plan and more specifically the landbank figure required in the Plan period to the end of 2036. Furthermore, may I raise the question to the MPA as to what the justification is for using a 20-year average annual production figure, rather than a 25-year
average or likewise 18-year to cover the remainder of the plan period, for example?

I therefore wish to object to the methodology used in establishing the required tonnages of sand and gravel resource to be allocated within the Plan period to the end 2036 as referred to in Policy MP1: Provisions of minerals extraction. The 20-year average methodology has not been accepted as a valid methodology for establishing this figure and therefore should not be considered as sound. This is demonstrated by the NPPG which considers that only the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision.

I would consequently like to object to this figure in relation to MIN 35, which at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review was considered as suitable for allocation based on the proposed 20-year average annual production figure in August 2018.

However, the current proposed allocation figure less than 18 months later is greatly reduced and is considered the only reason for the site to now be considered as unsuitable, due to the fact that the proposals have not changed in terms of the site development since that date.

Suitability of alternatives considered as suitable for allocation
There are a number of sites that have been considered suitable for allocation in the Norfolk Minerals and Waste Local Plan Review that are very similar to MIN 35 in terms of their potential impact on the local landscape from viewpoints from surrounding sensitive receptors. The table below and subsequent consultation extracts identifies and breaks down each site in terms of the number of sensitive receptors within 250m and 100m of the proposed extraction area compared with MIN 35, respectively. Therefore, on a logical comparative basis MIN 35 sits within the top three of the proposed sites with the least number of sensitive receptors.

INSERT TABLE

MIN 210 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from Park Farm Cottages will predominantly be screened by bunding"

MIN 211 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from nearby properties will predominantly be screened by bunding"

MIN 65 "glimpses of the land can be seen from Frettenham Road to the west through gaps in boundary hedges. Views could also be seen from two properties which lie close to the site perimeter to the west and east respectively"

MIN 213 "views into the site may be possible from Shorthorn Road, through the proposed entrance"

MIN 25 "there are mature screen planting forming hedgerows on all sides of the site, except a section of the eastern boundary closest to Manor Farm"

MIN 12 "views of the site would be seen from Field Lane, a road used as a public path which bounds the site to the north. In addition, the southern part of the site is slightly elevated and may be visible in a long view from public paths crossing land to the north of the Whitewater valley"

MIN 209 "a number of properties back onto the road overlook the site, the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting"

The above findings were concluded by the MPA as being acceptable subject to the erection of screen bunds and advanced planting. Likewise, it is stated that any potential views of MIN 35 would require mitigation through screen bunding and advance hedge planting. Therefore, given the supporting information above, as part of the independent Landscape and Visual Statement, it is considered that the MIN 35 site should be considered suitable for allocation due to the similarities it shares in landscape terms with the above sites that themselves have been considered suitable for allocation.

Furthermore, three sites have been considered suitable for allocation that are either within or adjacent to the AONB, a Core River Valley or any other designated landscape features, namely MIN 69, MIN 211 and MIN 25. Since MIN 35 is not located within or even close to any of these designated landscape features, preference must be given to this site in planning terms as required by the
requirements of NPPF Paragraph 205.

Since the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review and additional site has come forward and is now considered as suitable for allocation in the 'Preferred Options Consultation'. This is MIN 213 land at Mansom Plantation, Stratton Strawless for a total estimated sand and gravel resource of 1 million tonnes. The site has been selected in preference to MIN 35, due to the fact that the MIN 35 site was formerly considered as suitable for allocation at the 'Initial Consultation' stage. However, it is considered that this new site (MIN 213) not only presents a similar landscape impact to MIN 35 as described above, but also represents a site that will result in the permanent loss of a well-established coniferous plantation for after use as a holiday lodge development. MIN 213 is also located adjacent to an ancient replanted woodland to which deterioration is likely to occur as a result of the mineral operation. As such, any application that concludes this unless there are wholly exceptional reasons should be refused as in accordance with NPPF Paragraph 175c. Therefore, the site cannot be considered as being suitable for allocation given this likely impact.

I therefore would like to object to the inclusion of the above sites as being considered suitable for allocation, whereas MIN 35 is considered unsuitable solely on landscape grounds. It has been demonstrated above that preference should not be given to any of these sites over and above MIN 35 and that MIN 35 should be reconsidered in light of the additional supporting landscape and visual statement and be concluded as once again suitable for allocation as at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.5 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Landscape and Visual Statement (Ref. CW0121-RPT-001), dated 30 October 2019
Ecological Scoping Report (Ref. E17864), dated 2 August 2017

Comment

Preferred Options consultation document

Representation ID: 98805

Received: 30/10/2019

Respondent: Historic England

Representation Summary:

No comments

Full text:

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.

Comment

Preferred Options consultation document

Representation ID: 98825

Received: 31/10/2019

Respondent: North Norfolk District Council

Representation Summary:

North Norfolk District Council raises no fundamental concerns regarding the four sites proposed for allocation, but reserves the right to change this position based upon feedback from members of the public to the proposed allocations through this Regulation 18 consultation.

Full text:

North Norfolk District Council welcome the opportunity to make comments on the Norfolk County Council Minerals and Waste Local Plan Preferred Options Consultation. North Norfolk District Council raise no fundamental objections to the Plan, but the Council wish to make the following comments/observations on the proposed allocations and the wording of proposed policies.

Proposed Policies

As you will be aware, North Norfolk District Council declared a state of climate emergency on the 24th April of 2019. As such in relation to draft Policy MW4 'Climate Change Mitigation and Adaption' the Council consider that more could be done in regard to the issue of climate change. It is stated that 10% of energy should be from decentralised and renewable or low-carbon sources and that due to the rural nature of the District a figure higher than this cannot be achieved. However, North Norfolk District Council consider that this figure could be higher and it is not clear as to the source of the evidence that backs up the figure of 10%.

North Norfolk District Council is currently producing an emerging Local Plan to 2036. Through the Regulation 18 consultation on the North Norfolk Local Plan, Norfolk County Council Minerals and Waste provided comments on a number of proposed allocations to include wording within the site-specific policies in line with current Policy CS 16 and the safeguarding of minerals. It is noted that the current Policy CS 16 is to be split across three different policies: MP 10 (safeguarding of port and rail facilities, and facilities for the manufacture of concrete asphalt and recycled materials); MP 11 (Minerals safeguarding Areas and Minerals Consultation Areas); and MP 17 (Safeguarding Waste Management Facilities).

The Council has no objection to the splitting up of Policy CS 16 in the way suggested. As Policy MP 11 tightens up the wording set out within existing Policy CS 16 this may have implications for comments made on future iterations of the North Norfolk Local Plan should the Norfolk County Council Minerals and Waste Local Plan be formally adopted first. North Norfolk would welcome the opportunity to include any revised policy wording in our emerging Local Plan to ensure mineral deposits are appropriately safeguarded.

Proposed Allocations

North Norfolk District Council note that there are five sites considered within North Norfolk for the extraction of minerals, four of which are proposed to be allocated and one deleted. North Norfolk District Council welcome the deletion of the site at Holt (Min 71: Land West of Norwich Road, Holt) due to the potential impact upon the natural environment.

North Norfolk District Council raises no fundamental concerns regarding the four sites proposed for allocation, but reserves the right to change this position based upon feedback from members of the public to the proposed allocations through this Regulation 18 consultation.

Notwithstanding the above, North Norfolk District Council would ask that further consideration is given to the proposed allocation, Min 115, at Lord Anson's wood, near North Walsham. In light of the proposed expansion of North Walsham through the Local Plan, careful consideration should be given to the proximity of North Walsham and the impact this expansion may have upon any transport solution based on the findings of a Transport Assessment associated with this proposal.

Comment

Preferred Options consultation document

Representation ID: 98841

Received: 30/10/2019

Respondent: Norfolk County Council - Highway Authority

Representation Summary:

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.

Full text:

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.