Specific Site Allocation Policy MIN 209 / MIN 210 / MIN 211 (Earsham sites)

Our restoration scheme for the three proposed extension sites in Earsham, pledges the post-extraction land to be re-landscaped for nature conservation, just as has been the case with the two main previous extraction phases at Earsham.
The original mid-20th Century digging off Bath Hills Road saw the creation of a large lake and two ponds, which together comprise a haven for many less common birds, mammals, fish, invertebrate life and plants. Osprey has been recorded there and it is a major congregation point for newly-arrived swallows, house martins and sand martins each Spring.
The second digging, at Pheasants Walk, created a shallow scrape pond beloved of wading birds and wildfowl, alongside a large plain of heathy grassland and a clean water wildlife pond. Little ringed plover and oyster catchers breed there.
The proposed extensions to the Pheasants Walk Pit go a stage further: the creation of over 100 individual ponds to make what will probably be the densest concentration of pond habitats outside of major reserves in East Anglia.
According to the Freshwater Habitats Trust:
- Ponds (as opposed to lakes, ditches, streams and rivers) support two-thirds of all freshwater species, even though they only occupy 5% of the freshwater area.
- 50% of the UK's ponds were lost during the course of the 20th Century.
- 80% of the ponds which remain across the country are in a poor state.
- Aggregate extraction sites have been shown to be excellent places to create high quality wildlife ponds: in a recent survey of such ponds (in the Lower Windrush Valley, Oxfordshire), 80% of such newly created ponds on sand/gravel sites became classified as Priority Ponds for their high biodiversity levels.
- The reason these aggregate site ponds are so good is because (i) the ponds are fed by clean water, either groundwater or surface water from low intensity land use, and (ii) the ponds are located close to other wetland features such as lakes and rivers, which together creates a rich mosaic of wetland habitats.
- Ponds on aggregate sites support species not found in larger gravel pit lakes.
- Ponds are a priority habitat in the UK Biodiversity Action Plan (BAP), so adding new ponds and pond complexes into the matrix of habitats restored after aggregates extraction can contribute to the national Pond Habitat Action Plan (HAP). Ponds also provide habitats for 100 or so Biodiversity Action Plan priority species.
The Earsham Estate, the landowning company for these sites in Earsham, has a good record for pond conservation:
- The creation of 26 new ponds across the Estate in the last 20 years has restored the total number of ponds in the holding to 106, one pond short of the number of ponds recorded on the very detailed Ordnance Survey maps of 1888 (revised 1902).
- 32 existing ponds have been the subject of wildlife restoration work since the year 2000 - this is work which includes dredging and cutting back tree/scrub vegetation to allow light in.
- The creation and restoration of ponds has been funded jointly by the Countryside Stewardship Scheme, and with funds from past gravel extraction on the Estate.
- Previous gravel extraction on the Estate has resulted in the creation of 5 new ponds and one very large lake on the former extraction sites - all wholly or largely made over to nature conservation.
- The Estate owner has worked both for the charity Froglife and for Suffolk Wildlife Trust, in roles advising farmers and members of the public on wildlife pond creation and management.
The 100 plus ponds to be created will designed to feature varying sizes, shapes and depths to maximise the diversity of habitats. The surroundings are planned to be relatively low in nutrients (being formed of sandy subsoil), to be allowed to self-seed and managed by occasional mowing and low-intensity grazing to become a mosaic of grassy plain, scrub and woodland.
The restoration plan proposed therefore has the very real potential of going on to become a set of three neighbouring sites successfully rich in wildlife and a stronghold for less common plants and animals.

East Suffolk Council welcomes the opportunity to comment on the Norfolk County Council Minerals and Waste Local Plan consultation. East Suffolk Council was created in 2019 following the merger of Suffolk Coastal District Council and Waveney District Council, which prior to this had run a shared service for several years. It is worth being aware that the evidence base documents referred to here were prepared by the former Waveney District Council.

East Suffolk Council wishes to raise concerns regarding three sand and gravel extraction sites, MIN209, MIN210 and MIN211, which are located outside of Earsham and are very close to the northern border with East Suffolk.

The three sites in question would form an extension to an existing quarry. It is acknowledged that they would not be worked at the same time and this would reduce their impact at any given time. However, it would significantly extend the working life of the quarry and this has the potential to increase impact significantly on the East Suffolk area. Several concerns remain regarding landscape and historic environment, natural environment and road safety.

Landscape and Historic Environment Impact
The three sites would significantly increase the area to be quarried and this has the potential to cumulatively impact upon the appearance of the landscape. Once extraction work is completed a programme of landscape restoration would be required to ensure that the sites are returned to their former condition. The Minerals and Waste Local Plan does not identify these sites as being of significant landscape value. However, site MIN210 is located very close to the boundary of the Broads Authority. It is therefore possible that further extraction work on this site could impact upon the setting of The Broads. This is particularly the case given largely flat character of the area. More evidence is needed to demonstrate that any landscape impact can be successfully mitigated.

In addition, the site is located close to the town of Bungay, which is set on a peninsula in the River Waveney. An increase in extent of mineral extraction activity has the potential to impact upon the setting of the conservation area, including Bungay Castle, which is a grade I Listed Building and Ancient Monument. The Waveney Settlement Fringe Landscape Sensitivity Study identifies the western edge as being a sensitive urban edge, which could be harmed by inappropriate development and therefore it is necessary to ensure that development to the west of the town takes this into account.

The Landscape Character Assessment identifies the southern and western edge of Bungay as a Rural River Valley and as part of the Waveney Valley landscape. This is a flat and low-lying landscape with a high level of visibility across the area. It is also an important part of the setting of The Broads. As such it is susceptible to negative landscape impact from large scale development of the type proposed. Future development should protect views of The Broads and should protect the river valley floodplains, which are a valuable wetland habitat.

Environmental Impact
The proposed sites at Earsham are located close to Stow Fen, which is identified as an area of biodiversity value by the Waveney District Council Open Space Needs Assessment. This is a low-lying site sandwiched between the River Waveney to the north and its tributary the Broad Water to the south. It is not clear from the information submitted whether this area will be impacted by the proposed aggregates extraction sites or what measures are in place to protect the site. Similarly, Outney Common, which is a County Wildlife Site, is located to the north of Bungay and is an important part of the town's setting, could potentially be affected by the proposed extraction sites.

Road Impact
The Preferred Options information submitted states that these three sites will not increase the volume of traffic but rather extend the period during which traffic moves to and from the mineral extraction site. Attention is drawn to ensuring that the safety of cyclists and pedestrians is considered, particularly along the A143. In particular, the Clays roundabout to the north of Bungay has been identified by the Waveney District Council Cycle Strategy (BU2) as requiring improvement to improve cyclist safety.

East Suffolk Council welcomes the chance to discuss the above issues with yourselves. Please contact me if you have any questions about this representation.

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.