MIN 71 - land west of Norwich Road, Holt

The Company objects the the exclusion of this site from the Plan. The landowner has indicated that they are prepared to see the site worked as an extension to CEMEX's Holt Quarry, and is in the process of securing this indication is writing. As an extension to Holt Quarry as opposed to a stand-alone operation, it is felt that the objections to the site as a Specific Site for Aggregate extraction can be overcome.

I received a letter explaining proposed site MIN 71. I appreciate the balanced content of it. Agreeing to this change of use from agricultural use to a gravel extraction site raises many concerns, many of which you have mentioned.

My concerns include :
* How often have gravel extraction sites opened in Norfolk so close to a town, indeed to a residential area?
* How often have gravel extraction sites opened in Norfolk so close to protected or sensitive areas?
* How long the working day is, and how many days of the week?
* Will the site need to be flood lit during the shorter days of the week (i.e. winter)
* The plan refers to the time period up to 2036, but how long will this site stay operational?
* The impact on the value of nearby properties from now on (not just when it is operational)
* The impact on the wide range of wildlife in the direct area and surrounding. (insects to plants to birds and mammals)

* I ma trying to understand the local traffic impact...please correct me if I am wrong on the following potential concerns:

-Your link* below suggests that at least 500,000 tonnes could be extracted between 2030 and 2036?
-When full, I understand eight wheeler trucks carry up to 20 tonnes, so that will be a minimum of 500,000/20 = 25,000 journeys over 5 years approximately, i.e. 5,000 journeys per year.
- At 25 loads per day (letter says 20 to 30), that means the trucks will leave site 5000/ 25 = 200 days of the year.
- There are only about 250 working days in each year, so the site will be working maximum at 200/250 , i.e. 80% of the weekdays.
- The truck loads may average 25 times a day, but all trucks will have to go and come back so that doubles the number of times a truck may pass by me daily to 50 times a day. Over an 8 hour day, that a truck nearly every (8 x 60 mins)/ 50 = 9.6 trucks per hour... nearly every 6 minutes.

*(https://www.norfolk.gov.uk/what-we-do-and-how-we-work/policy-performance-and-partnerships/policies-and-strategies/minerals-and-waste-planning-policies/norfolk-minerals-and-waste-local-plan-review )


I can see from the plans and your letter that the following subjects have been noted , but what impact will all these aspects have, and have they been carefully and fairly reviewed:


ISSUE TO MANAGE - Noise
EFFECTS - General noise emission standards
Noise standards associated with particular types of activities
Standards associated with buffer zones
Timing restrictions on operations
Part of quarry management plan?
Use of noise barriers such as earth bunds or acoustic fences
Equipment type and insulation

ISSUE TO MANAGE - Vibration
EFFECTS - General vibration standards
Timing restrictions on operations
Part of quarry management plan?

ISSUE TO MANAGE - Dust and air quality effects
EFFECTS - Performance standards for particulate matter
Assessment criteria to determine dust effects
Best practicable option
Part of quarry management plan?

ISSUE TO MANAGE - Earthworks, stockpiling and overburden
EFFECTS - Part of quarry management plan? (including an earthworks management plan)
Assigning council responsibility
Screening and landscaping

ISSUE TO MANAGE - Traffic
EFFECTS - General traffic movement standards
Part of quarry management plan? (which often includes a traffic management plan)

ISSUE TO MANAGE - Water quality and use Guidelines
EFFECTS - Activity performance standards
Part of quarry management plan?

ISSUE TO MANAGE - Vegetation removal and ecological effects
EFFECTS - Activity performance standards
Offsetting
Quarry and landscape management plan

ISSUE TO MANAGE - Visual effects
EFFECTS - General bulk and location standards
Part of quarry management plan?
Progressive restoration and rehabilitation
Use of visual barriers such as earth bunds or solid fences

ISSUE TO MANAGE - Cultural and historic heritage values
EFFECTS - Policies relating to archaeological sites
Consultation policies and agreements
Cultural impact assessments and cultural value reports
Part of quarry management plan?
Avoiding specific sites,

ISSUE TO MANAGE - Rehabilitation
EFFECTS - Part of quarry management plan?
Rehabilitation plan

RE: NORFOLK MINERALS AND WASTE LOCAL PLAN REVIEW: INITIAL CONSULTATION
That you once again for your letters dated 26th and 30th June 2018, and I write again regarding this matter, along with raising new concerns for you to consider.
As you know, this potential mineral extraction site, MIN 71, is a serious concern for us and many of our neighbours. We live in The Laurels which is located on Holt Road (B1149) directly opposite the Hunworth Road (C267) and this proposed site.
I appreciate that you are only carrying out the Initial Public Consultation and that this doesn't grant Norfolk Gravel the right to proceed and that planning consent will be required. However, there are serious issues that both the County Council and District Council should consider before taking this matter any further.
1. Infrastructure/Highways
As you are no doubt aware, traffic congestion in and around the Georgian Market Town of Holt is often very serious, particularly during the holiday periods when there is an increase in the number of visitors and tourists to the area and the current infrastructure is of concern.
The B1149 Holt Road is only a 'B' Road, but it carries 'A' road traffic being the main route that runs from Norwich, past Holt and on to Fakenham. It is of major concern that there will be 30 plus trucks per day using a narrow 'C' road, approaching the dangerous junction at Holt Road. We would appreciate further input from your highways department as to how this junction will be changed to accommodate the increased traffic load on an already very dangerous junction. Furthermore, I would like to comment on how the road conditions will be compromised, due to the fact that at present there are numerous HGVs delivering to the Quarry and Thaxters Wood Merchants on the (C267) along with all bus services, this is enormously impacting the conditions of the road - especially on the corner itself, not to mention the grid lock that is forming back into Holt along the Norwich Road. * New Concerns*
2. Dust
There is no doubt that this potential mineral extraction site will create a dust problem, not only for the immediate local residents and those inhabiting Holt, but it will also affect the young children at Holt Primary School, situated no more than 100m from this site, and also the children at Gresham's pre-prep and prep schools, whose boundary adjoins the main Cromer Road. We would appreciate a full report on how the dust will affect the location. I note that you have concluded that 'Dust suppression measures will be necessary to ensure that dust deposition does not affect the integrity of Norfolk Valley Fens SAC' but surely it is more important to protect the people that live in the immediate vicinity?
3. Noise Impact
I can clearly hear the works and transporters that are using the existing Cemex site daily and it can also be heard by residents in the centre of Holt. The proposed site will be closer to us and to Holt, so the noise impact will increase and be a serious concern.
4. Other Matters
I note that you have requested other matters to be resolved and reports completed, as outlined below, and I look forward to receiving copies of these, in addition to the matters raised above.
* Hydrogeological Risk Assessment
* Standoff/buffer zone plans
* Confirmation of site restoration
* A Landscape and Visual Impact Assessment
* A Heritage Statement
* An Archaeological Assessment
I understand that there are already three mineral extraction sites within the immediate vicinity - Cemex (Hunworth Road), Gresham Sand and Gravel (Cromer Road), which is a new quarry, and Norfolk Gravel - Sheringham Quarry - (Britons Lane). There are also sites further south and west. Please could we have an explanation as to why there needs to be further extraction from North Norfolk close to a Georgian town and where the products are sold? Are the minerals extracted for us in the UK or are they exported?
Please take this letter as formal notice of our objection to this land being designated as a potential Mineral Extraction Site. Please confirm receipt of this letter.

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.

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.