MIN 25 - land at Manor Farm (between Loddon Road and Thorpe Road), Haddiscoe

Re planning application in Haddiscoe.

Once again I find myself making an objection to a new application to extract gravel out of Manor Farm Haddiscoe.

This application is no different to the one that was turned down some 6/7 years ago do we have to go there all over again and wast thousands of pounds to come out with the same conclusion NOT WANTED.

Bring up HADDISCOE STOPIT web page you will see all the arguments against.

The E D P was on the case,Councillors unanimous in rejecting the planning application. so whats changed nothing.



Chris & Shirley Colby

This development will have a detrimental impact on Haddiscoe particularly regarding highway access, noise and dust pollution.

The A143 is a busy road which as a pedestrian is already very difficult to cross because of the volume and speed of traffic. This would only get worse and more dangerous with the addition of 80 HGV movements per day.

The layout of the junctions of A143 and B1136 and B1136 and Crab Apple Lane would not cope with increased traffic flow and road surfaces would deteriorate.

It is unknown what impact Haddiscoe will suffer regarding noise and dust pollution.

I strongly oppose this plan. A plan that once again has been forced upon the residents of Haddiscoe who in the past have gone to great efforts in time and expense to stop our village being ripped apart.
I hope the village will jointly oppose this plan once again. The ONLY difference in this new plan is that the south side of the Hales road will not be affected.
For me personally, I object purely on the fact that my property will have to endure the noise and dust from the site and also the extra 80 plus lorry movements past my house.
which incidentally shakes every time a lorry goes past it!!
Why cant a relief road be built across the land by Cemex to link up with the Ravingham site??
Or will this cost poor old Cemex too much money??
It also states that the gravel WILL be processed on site, I am sure this will not be a quiet and dust free process?

The Company wholly supports the inclusion of this site in the Plan.

I wish to further object to the proposal on the grounds of :-
Noise - The land is currently used for agriculture but when it is being worked on for planting, sowing, reaping or ploughing the noise from tractors , combined harvesters and other agricultural machinery can be clearly heard across the village. This is fortunately on an infrequent basis and is a nuisance annoying but tolerable
I fail to understand how noise from a 5-6 day operation for at least 8 hours each day can be mitigated against?
During the Summer this year I played Golf at Bungay Golf Club It was a beautiful sunny summers day and the only noise I could hear was the extraction and washing processes emanating from Earsham Gravel plant which was at least a Mile away. I look forward to an explanation of how such noise pollution could be engineered out of the proposal.
Traffic Movement - an additional 80 vehicle movements
Light pollution- at high point of the village.
Conversion of an agricultural site into an industrial site adjacent to the heart of the village.
The Eastern end of the site is adjacent to a local amenity described as "a small disused mineral working" where Children Nature lovers and Dog walkers alike are able to enjoy quiet open space
Ongoing disruption to the Village when the extraction is exhausted and the land is being "restored" to its previous use.
Sufficient material in the current gravel bank options
Visual impact
The selection of this proposal will impact severely on this beautiful rural village

Thankyou for your email notification regarding the Norfolk Minerals and Waste consultations currently in session.
My objections to the planning application referenced above are as follows:
1. The road infrastructure in and around Haddiscoe are inadequate for sustained and prolonged use by heavy industrial traffic and plant. Already an accident black spot Haddiscoe is a Parish Hamlet and many of its roads/lanes are very narrow with numerous bends and poor visibility, particularly when the trees and bushes are in leaf. At the top of Thorpe Road there is a dangerous T-Junction with only enough room for single lane traffic, and the Loddon Road has more meanders in it than a snake, and all with multiple blind spots. They are clearly unsuitable for the extra demand that would be placed on them, and general road user safety will be massively compromised in an area already subject to a Police Safety Scheme.
It is worthy of note that ramblers, cyclists and dog walkers and local people regularly use the roads without pavement provisions, and a massive increase in heavy haulage would serve only to put them further at risk. If this application was successful Haddiscoe will soon mirror a rural industrial estate, with the A143 morphing into a motorway.
2. Environmental Impact. There is a multitude of diverse wildlife habitats in and around Haddiscoe, not least the family of barn owls who live the nearby the proposed site. If they had a voice I wonder if they would agree to this application? I suspect not and disruption to local habitiat caused by all of the various types of pollution will inevitably have an adverse, and catastrophic effect on flora and forna in the immediate and surrounding area. I don't suppose for one minute that muntjacks breed near bulldozes or under floodlights. Not least to mention the local brown hare population that frequent areas all around the proposed site.

3. Flooding also presents serious problems for Haddiscoe which often received flood warning alerts from the Water and Broads Authority. Being in effect marshland it sits the wrong end of the water table, and it is the natural defences of fields, trees and flora that all play a significant part controlling water levels from the river. I do not think these things should be interfered with or Haddiscoe will become more at risk of becoming Haddiscoe-Next-Sea!

4. Community Impact: Quarrying in Haddiscoe will irrevocably erode its Parish ambience which is the reason that most people chose to live here in the first place. Property values and their re-sale will be adversely affected and Haddiscoe will become the victim of noise, dust, light and traffic (heavy) and dust pollution.

I have spoke to many people in Haddiscoe both residents and visitors all of whom objected to the application but most of whom were not even aware of the current consultations. And so it is for all of the above that I object to this application for mineral extraction in Haddiscoe/Loddon.
It is worthy of note that for a very few this application represents purely monetary gain but for most the effects will be seriously detrimental with high environmental costs.
It certainly would be nice if the views from Haddiscoe church could remain a peaceful patchwork quilt of fields and tress as opposed to quarrying sites with the drone of JCB's and aggregate plant.
Norfolk and Suffolk Councils have always been very good at protecting their rural spaces, and it is this conservation ethos that ensures people return year after year to holiday, and why Norfolk people love their County so much.
Thank you for your considerations

With reference to the enclosed letter I am opposing plans as I am an elderly person and have chest complaints and I think this disruption will add to these.
Also the noise element of the machines and extra vehicles on this already quite busy road for a small village as people use as a cut through is bad enough now so any extra will be too much to contend with.

As a resident of Haddiscoe and would be living in very close proximity to the proposed gravel pit, I would like raise some objections to the proposals.

I am concerned about increased Noise levels. Attenuation measures do not work and the constant noise especially during summer months would be draining.

The Dust created from these works would horrendous covering my home, vehicle.caravan etc. [redacted text - personal data].

Traffic levels with numerous fully laden HGV's would have a large impact on this small local hamlet let alone the it being in very close proximity to the local school and church.

Local wildlife which there is much off would be devastated

Finally I am concerned that my property value would decrease.

Thank you for your letter of 13th September. I am astounded that less than six years after a planning application to extract gravel from the vicinity of land to the north west of StMary.s Church Haddiscoe was successfully opposed by residents of this village at great cost in time money and general anxiety the County Council is considering the area within 250 m of this church and my property as a suitable site for the extraction of sand and gravle. If the County Council peruses the planning documentation that should
still be on the planning departments files possibly at South Norfolk Diastrict Council all the relevant issues were discussed fully less than seven years ago and a correct decision was made to refuse planning for gravle extraction. The issues have been fully explored already but revolve around the local disturbance to residential areas , further heavy traffic and congestion on country roads and the already overbirdened A143 and the environmental impact on this region. Gravle has already been extracted many years ago from areas to the south and east of haddiscoe and sufficent material has already been taken from this locality. PleASE DO NOT include the arera in Haddiscoe in the local plan, the issue has not been properly publisied as many villagers have not received any notice by letter or otherwise of your proposals to consider the area for inclusion in the local plan, Any mineral extraction will need planning which once again will be strenuosly defenced by local residents and a full public consultation shpuld be made for all villagers to attend not just those within 250 metres of the sire as ot will affect all of us. Heavy lorries, noise due to increased trafiic and mining activities will make this village an unpleasant place for residents and destroy valuable wildlfe in a very rurla location. Any progression of these plans to extract gravle will be srtrongly objected to and every effort made to protect our lovely village so please reconsider, please

I own a holiday let property which was granted planning permission in 2018 on Thorpe Road, Haddiscoe, next to the Grade 2 listed White House Farm. I have invested funds into the property which has been previously refused planning for residential dwelling due to its proximity to the Broads executive area owing to impact on the Norfolk Broads area. The purpose of my investment within the Broads was to make a commercially successful and attractive holiday let for people to enjoy the Broads. The property is 30m away from the proposed recommended minerals extraction site. I grew up in the village and lived there for around 20 years.
I have a number of comments and questions on the appraisal to date in respect of the proposed development MIN25 and its inclusion in the Minerals Development Plan site specific allocation. I have also looked at the development policies shown on the minerals planning website to see if it is a sound proposal.

Site history and preface

In 2009, the site was deemed unacceptable for allocation by Norfolk County Council because of landscape, highway, amenity and groundwater impacts. In 2011, it was considered unsuitable for allocation on the basis of landscape impacts, noting that highway, amenity and groundwater impacts further decreased the site's acceptability. In 2013/14 the site was refused planning and dismissed at appeal. I cannot see how things have changed or a need can be demonstrated beyond those same comments. An argued need could be the allocation of the mineral resource, although suitable resource seems to be near or actually identified in mostly extension sites within the new plan allocation. With such abundant sand and gravel resources in the area, I feel a review could be triggered or other far more sustainable resources could be found before a breaking point in 2036.
The site is well known as having previously failed planning and appeal for minerals extraction. The recent county council sustainability assessment for potentially allocated sites states this is solely down to the setting on St Marys church of the previously promoted site to the south of the B1136. My view after reading the appeal decision is that In fact, the whole site was called into question. The inspector clearly did not exclude the northern site from statements about suitability. Mentioned in the appeal decision was reference of preferred option to extend existing sites (promoting sustainability), and also stating there was no continuing public benefit across the entire development. All of the site was also deemed to have some impact on the grade 1 listed historic asset.

Points for the initial MIN25 assessment to date by NCC

Questions regarding the information and reasoning on which this has initially been assessed suitable for inclusion in the development plan allocation:

1. Has the inspectors position on the previous appeal been completely addressed with the statement that the appeal was dismissed purely on the grounds of the setting of the St Marys church Grade 1 listed asset for the parcel of land south of the B1136.

2. The public need confirmation on the quantity of the mineral to be won from the site based on a realistic calculation of the future development area which would be allowed. If buffer zones from existing houses and priority ecological habitats are needed and taken account of, a potential stand off buffer around the historic assets required, and a development boundary is also applied and sterilised to potential new housing as submitted to the housing assessment call for sites by the landowner, with a noise bund area, access and turning, allow for the sloping sides of the extraction area and fencing and the site and it is reduced in capacity by a very large area. Even with just the 100m from existing dwellings, noise bund and pit walls the site would not operate at the full capacity of the red line area. I have developed the property 20m away from the boundary and found the water table during excavation. I would like to know NCC are positive the aggregate reserve is close to the 1.3Mt asserted. This must be a material consideration as when balanced against the negative impacts it will sway the planning decision. A simple overestimation now would also not be fair on other sites trying to be allocated.

3. The assessment appears to be based on the developer removing aggregate from Haddiscoe, and then being dropped off by lorry at Norton Subcourse for processing, then back into a lorry for movement onto the identified primary market in Great Yarmouth. Whilst this is an understandable business proposal, this gives major issues on sustainability and its proximity to supply destination against other potential sites.

4. The site area, once buffer zones are constructed could be relatively small, meaning that if aggregates were processed onsite rather than at Norton, it would be a confined working area and the processing equipment would have to move around the site. This could mean extraction would be a more laboured process. This would create a time extension to the extraction as well as create extra noise and dust. Compared to other sites it would not be an efficient process meaning it could use more energy per tonne to extract the minerals.

5. The length of activity is proposed to be 9 years with increased road movements. At its suggested maximum capacity of 80 movements per day 40 loads leaving site this is a confident target given the economic outlook. Would the planning term be reflected by the the local community being able to draw on a bond for damages if the planning term were to overrun? There are many instances where these quarries are extended, the simple fact is when the hole is there, it is there. The initial consultation also does not mention the traffic movements for restoration of the site and imported materials, which would almost certainly be essential if the biodiversity scheme were to be implemented. Typically soil and stone is imported to the site amongst other suitable materials for remediation which would be up to
the same volume as the asserted 1.3 million tonnes of gravel extracted, which means refilling the void will double the lifetime road movements. This will be a part of the planning and so should be a part of the site analysis for consideration into the development plan allocation. There is no doubt that for a development this significant more details should be given to local residents about its remediation including topography and proposed fill / use at this stage.

General considerations

1. Development policy gives more weight to extension of existing mineral extraction areas. This is not an extension to an existing site. Nor, by its bordering of open countryside to the West as per the inspectors findings, nor due to its other three boundaries being dwellings, the Broads executive area and the setting on St Marys Church is it ever going to be extended which must blight it as a site for selection. There is also much record of negative comment from council, public and planning inspectorate against amenity, groundwater, traffic, setting on historic assets and impact of noise and dust on a village community. All question on the sites sustainability.

2. The landowner has also submitted sites adjacent to the proposed minerals site under a call for sites for housing allocation in the Greater Norwich Development Plan http://www.greaternorwichgrowth.org.uk/planning/greater-norwich-local-plan/call-forsites/. These housing sites do not have planning permission but when in a similar state of suggestion for allocation, they should be considered. I understand and support that Haddiscoe should bear its weight on housing supply. In fact, the supply of housing in the right setting within Haddiscoe will, in my opinion, add to the village and assist in more social inclusion, and more use of the local facilities of the pub, village hall and play area. The proposed selected sites for housing allocation are also within 100m of the proposed extraction area and so would be subject to noise and dust. This would reduce their chance of success with planning and developers and also reduce the likelihood of people wanting to move to the village - it will be viewed as a more industrial landscape. There needs to be some joined up thinking from the council and feedback to the village as to which is the greater need - amenity of the locals, preservation of character and availability of housing, or mineral sites in exclusivity.

3. The site has an 11kV power line running across it which is not noted in the utilities report. I appreciate that this along with the Anglian Water main can be relocated at the developers expense as necessary

Norfolk County Council Minerals Development policies:
The site is against presumption in favour of sustainable development owing to the increased traffic miles compared to other sites in the proposed allocation, and other sites available within the minerals safeguarding area in proximity to Great Yarmouth. A sequential test would likely show this is the most carbon intensive site to include in the allocation to service Great Yarmouth.
I understand the land is Grade 3, best and most versatile land. For the site to be properly appraised, and for the public to properly consider this site for inclusion in the plan, they should be better informed of the remediation and timescales, and also net benefits of the biodiversity scheme.
The suggested site also moves a PROW without any definition. The PROW and net benefits to the public required and mentioned in the inspectors report are not seen at this stage and should be with such a major decision on a contentious site.
The NCC sustainability assessment identified the site could hold archaeological finds and geological finds which would need monitoring and mitigation. I understand this can be achieved but has been the grounds for removal of the Fritton site from the allocation. The Fritton site assets could be worked around and mitigated as Haddiscoe and are much more recent in their setting.
There is an undeniable impact on the setting and amenity of the grade 1 listed church and grade 2 listed asset in the churchyard. The grounds of the grade 1 church are within 60 meters of the site and the church itself little over 100 meters away.
The Haddiscoe site has to be considered a cumulative impact to the Norton Subcourse mineral extraction site. This is due to the proposed processing at Norton. Being as Norton Subcourse already has its own significant resource, with its own planning permission and associated HGV movement restriction, how can this be increased to accommodate MIN25? The supply at Norton is already 2,370,000 tonnes as consented in 2015 (reserve left unknow but significant). More traffic will lessen the ability of that site to operate at its proposed capacity as well as potentially increase traffic impacts for the communities around that site. Surely the Norton site should increase its planning permission for traffic movements first in order for processing of the MIN25 won gravel to be considered?
Efficiency of the A143 and A146 junctions off the B1136 would be called into question. As would safety of existing and new residents in Haddiscoe using Crab Apple Lane and Thorpe Road in events where the main routes were blocked.
The site does not sound aligned with climate change mitigation policies owing to the traffic movements to Norton Subcourse. Other potential sites in the allocation are in closer proximity to Great Yarmouth where the aggregate is deemed to be supplied. Transport to Norton is likely to be by 8 wheeler lorry which averages 8mpg fully laden. A quick estimate reveals over 1,000,000 kg of carbon just for the extra processing movements which are not proposed on this mass scale at any other minerals extraction site. If judged against the Burgh Castle site these extra road miles and carbon can be doubled.

Other opportunities

I am surprised that more obligation or support for minerals suppliers to use the new outer harbour at Great Yarmouth is not there. Great Yarmouth is after all the destination of the aggregate. A number of minerals suppliers have active dredging licences a few miles off the coast of Great Yarmouth where over a millions of tonnes of aggregates are dredged each year. These are long term secure licences and new applications to extend dredging areas are in right now. This is not only economical and sustainable, it is already happening with a lot of product being landed into Ipswich, and Great Yarmouth itself receiving hundreds of thousands of tonnes of Type 1 Granite for construction each year which all means it is feasible. The outer harbour was not operational to its current capability during the last Minerals planning round.
There is a good sand and gravel resource available in many areas of Norfolk. On top of this, as a construction community we should be looking to win sand and stone from sites by screening construction and demolition waste onsite or at approved facilities which is by far the most economical and sustainable option.
Lastly, Haddiscoe has within recent memory experienced gravel extraction which has not been an overall positive memory. Evidence of former quarry sites still lay within the village. It should be a resolve to make sure these are all tidied up before moving on to another project. Also, for Haddiscoe to bear another round of extraction so soon, with so many mitigating reasons not to is unfair on us voters and taxpayers. Whilst I appreciate the council has granted permission for holiday lodges on one former site, this is still at present an untidy site some 20 years since it was last occupied.

I would request the Developer and Minerals Planning team also answer whether the following could be conditioned and monitored within a permission:
* Need to use electrically driven processing equipment at the Haddiscoe site (as
opposed to diesel driven plant) if possible to reduce noise and carbon emissions.
* Need to reduce road miles and carbon compared to other sites suggested for allocation as the carbon impact sounds unacceptable.
* Need to monitor dust to the highest standard and best available techniques due to it being in proximity to so many sensitive receptors and a stones throw from the settlement of Haddiscoe. * Consider restricted activity in Westerly wind conditions to minimise noise. * Consider the long term views and aspirations of the village when looking at a section 106 agreement - can a developer fund be made available to offset the harm.
* Require a full EIA and bird survey - from my holiday let development I have seen barn owls nesting close to the site, a pair of breeding marsh harriers on a regular basis and other raptors using the marsh in the Broads authority national park area less than 50 meters from the proposed site. These birds roost in the deciduous woodland priority habitat within and adjacent to the site. The Broads area adjacent to the site is also home to other priority species in this environmentally sensitive area. These were key reasons why I developed the holiday let - for people to enjoy these features.
* Need to address the traffic impact on the B1136-A143 junction and the B1136-A146 junctions. Understood these will be planning objectives but their success should be judged now as to whether the council spend on taking this site forward is justified.
* Look at working hours. Longer hours are not necessary as there is no direct retail to the construction industry proposed from the Haddiscoe site. The site could operate say 09:30 - 16:00 with lower traffic impact and no effect on aggregate production which would help with noise.

Conclusion

I am not against aggregates developments and support them happening in the correct place. Aggregates sites obviously support wider economic growth and need not be a nuisance. New sites test the planning system and are controlled for noise, impacts on the natural and historic environment, sustainability, effects on amenity, dust and all other criteria. When weighing up all of these I am by no means confident of this sites chance of success and question whether the council should promote it at taxpayer expense. Even though the has its history, the site can only be judged for allocation based on the information in this allocation process which is not enough to give it a positive light. There are a number of policies with which this site conflicts, and although the site still has to pass planning, this process gives sites an amber light. If it has a low chance of success and is less sustainable than the other sites requesting allocation, it could be a waste of time and money for the developer and council and that is the question being asked in this consultation - viability. On the balance of information available now I deeply object to the scheme being allocated in the minerals plan as I can see a successful challenge to planning being mounted.

Please find attached our comments to the above from Haddiscoe Parish Council.

As a Parish Council, we have read the consultation document and canvassed the opinions of our Parishioners. We would comment on the document text as follows :
* M25.1 does not include mention of light pollution, at one of the highest elevations in the village
* M25.2 a further 80 HGV movements is unacceptable to us, and can only contribute further to the dangerous conditions on our single track roads. What is not mentioned in the consultation document is that if the material is processed at Norton and then transported to Gt Yarmouth or Lowestoft, a further 80 HGV movements through our village will add to the traffic count
* M25.4 notes that there are three listed buildings within 250 m of the site and a further 10 listed buildings within 2 Kms. The noise and additional traffic will adversely impact on the setting of these historic buildings.
* M25.8 describes "a small disused mineral working" on the Eastern boundary. This piece of land belongs to this Parish and is used as a recreational ground for children playing and dog walkers. The proposed development will impact on this village asset. The daily lives of the inhabitants of "properties along the northern boundary" will be similarly blighted.
* M25.9 is misleading in that it infers that the only reason Planning was refused and the appeal in 2014 was rejected, was the part of that proposed development south of the B1136. This is not the case. In his proof of evidence in 2014, Simon Smith (Planning NCC) quotes the original grounds for refusal, including "The landscape and visual impacts of the proposed development, including the construction of artificial bunds and land-raised areas would be detrimental to the appearance and rural character of the area" and "The proposed development would adversely affect the amenities of nearby residents due to increased noise, dust and traffic that would arise from the proposed quarry" which applies to the area as a whole, not just in the vicinity of St Mary's church.
* M25.21 seems to have missed the line of Overhead power lines through the middle of the site.
* M25.23 does not detail the fact that to fill a hole will take as long as it took to dig it, with just as many HGV movements and taking the same amount of time
The inclusion of this site in the allocation list does not look acceptable from our, or an overall perspective. In particular :
* Is there really a need to develop this site ? Again, in his proof of evidence in 2014, Simon Smith (Planning NCC) states "Given a current landbank of of over seven years and Suffolk's high landbank levels and the likely approval of an extension at Norton Subcourse, if this proposal does not go ahead there will be sufficient other local sources of minerals." We cannot see how this situation has changed in just five years and cannot justify the negative impact on our community
* This consultation does not appear to join up with another consultation which starts one day after this one closes. This is the call for sites for housing allocation in the Greater Norwich Development plan, including four sites adjacent to the main road in the middle of this village. If some or all of these sites are adopted, then the timeframes will overlap and there is the potential for two major construction sites working either end of our village, at the same time, which would be incredibly disruptive to our daily lives.
We would urge you to de-select M25 from consideration.

I thank you for your letter notifying me of the proposed mineral extraction site in Haddiscoe on land between Loddon Road, Crabapple Lane and Thorpe Road. As my property lies nestled within 250 metres of this site I would like my objections on record and taken into account as follows:
1) I would expect to be disturbed by constant and considerable noise during working hours and actually moved to the countryside in order to enjoy the peace and quiet and enjoy the natural sounds of birdsong which would either be drowned out or frightened away by the increased volume of traffic and loud rumbling of the extraction site.
2) dust pollution could be considerable and constant during working hours as my property is in close proximity to the site. I have two small Grandsons whom I care for regularly 2-3 days each week who enjoy playing in my garden, I would anticipate on certain days this would not be possible and would impact mine and my families health, lifestyle and wellbeing.
3) Although I understand the vehicular route will not pass by my property I would expect the village to be affected by the increase in volume of heavy lorries causing tailbacks in the village, affecting the noise quality of properties on the Beccles Road opposite the Loddon Road junction, also making this junction even more of a hazardous spot than it is now.
Many thanks in advance for your consideration of my objections.

I am writing to object to MIN 25, as part of the minerals and waste strategy review, being the proposed Pit at the land at Manor Farm, Haddiscoe.

My objection is in line with previous failed applications for a Pit at this site, namely, the close proximity of the proposed pit to the village of Haddiscoe. I note that the proposed pit site actually borders the western boundary of the village. I and my family live within 75 meters of the proposed site, we are retired and therefore spend all our time at the house. Of particular concern to me [redacted personal data] is the impact that dust and particulate matter will have on my health. As the prevailing wind is from a westerly direction, the extraction process will regularly shower properties in the village in dust and particulate matter, impacting the quality of air for the villagers. I therefore urge you to exclude this site from the councils minerals and waste strategy.

I would like to register my objections to the proposed site as part of the mineral extraction strategy, in Haddiscoe.
I am on the view that gravel extraction would have a detrimental impact on the well-being of villagers and the village as a whole. Indeed, the extraction process would cause many health issues (physical and mental health) from noise, particulate matter and HGV traffic pollution, particularly as the proposed site would be within 50 meters of residents. Our family would be directly affected living in such close proximity (our house is on the boarder of the site), [redacted text - personal data], as well as the noise pollution, having an adverse impact on my family's mental and physical wellbeing.
This site has been considered and rejected at the highest level in the recent past, all the points raised then in terms of sheer size, environmental impact both to wildlife (boarding the Broads National Park) and the issues of noise and particulate matter, along with traffic disruption and lack of road infrastructure still remain. I am sure there are many more suitable sites available to the council, that are not in such close proximity to a pretty village in Norfolk without causing such a detrimental impact on a community.

I wish to further object to the proposal on the grounds of :-
Noise - The land is currently used for agriculture but when it is being worked on for planting, sowing, reaping or ploughing the noise from tractors , combined harvesters and other agricultural machinery can be clearly heard across the village. This is fortunately on an infrequent basis and is a nuisance annoying but tolerable
I fail to understand how noise from a 5-6 day operation for at least 8 hours each day can be mitigated against?
During the Summer this year my Husband played Golf at Bungay Golf Club It was a beautiful sunny summers day and the only noise he could hear was the extraction and washing processes emanating from Earsham Gravel plant which was at least a Mile away. He came home and was amazed at how the noise had travelled. I look forward to an explanation of how such noise pollution could be engineered out of the proposal.
Traffic Movement - an additional 80 vehicle movements
Light pollution- at high point of the village.
Conversion of an agricultural site into an industrial site adjacent to the heart of the village.
The Eastern end of the site is adjacent to a local amenity described as "a small disused mineral working" where Children Nature lovers and Dog walkers alike are able to enjoy quiet open space
Ongoing disruption to the Village when the extraction is exhausted and the land is being "restored" to its previous use.
Sufficient material in the current gravel bank options
Visual impact
The selection of this proposal will impact severely on this beautiful rural village

Living in Haddiscoe village, I would be living in very close proximity to the proposed gravel pit, I would like to raise some objections to the proposals.

I am concerned about increased Noise levels. the constant noise especially during summer months would be irritating.

The Dust would be a major factor in my opinion [redacted text - personal data]. The level of dust would certainly affect him.

I am very worried about the amount of HGV's that would be coming through especially with young children and only having access to one car means we walk a lot.

I am also concerned that there is a danger with the amount of HGV's, probably around 100 and a local primary school in close proximity. It'd be an accident waiting to happen in my opinion.

Finally I am concerned that my property value would decrease in value

I understand that there has been, an application for a gravel pit on the northern outskirts Haddiscoe.

The Norfolk Core Strategy and Minerals and Waste Development Management Plan Document 2010 - 2026 Development Management Policy DM12, requires that the amenity of people in close proximity to potential minerals extraction should be protected.

It should be noted that a large proportion of the residents of the village of Haddiscoe live within 1 K of the proposed workings.
I wish to protest that in my opinion this is an inappropriate siting for such gravel/sand extraction.
There are several reasons for the inappropriateness of this positioning, not least of which is the increased pollution that such workings are bound to engender.

I note that in January 2013 planning permission for a similar operation was denied. One reason given; " The proposed development would *adversely, affect the amenities of nearby residents due to the increased noise, dust and traffic that would arise from the proposed quarry. This is contrary to Policy DM 12 of the Norfolk Core Strate.gy and Minerals and Waste Development Management Policies Development Plan Document 2010 - 2016 and paragraph 144 of the National Planning Policy Framework."
How would the operator plan to mitigate the environmental impact on the health of the nearby residents from the inevitable increase of noise, dust and road use?

I note that although recommendations for dust mitigation incudes the use of bowsers or sprays; one must bear in mind:-
a) the impact on local water supplies, and
b) the sensible use water in these days of increased drought risk added to the fact the Water Boards advise the population overall to preserve every drop.
The increased pollution by the use of vehicles, many of which will be heavy goods vehicles, along the little country lanes concerned, is not conducive to the well being of the residents. The roads are not built for this sort of traffic, several currently being little more than one vehicle width and subsequently frequently used by cyclists and pedestrians who would find this sudden increase in traffic threatening.
The proposed works should meet ''the diverse needs of all the people, and provide prosperity and opportunities for all, and in which environmental and social costs for on those who impose them." However, it would appear that the impact will be upon the residents of Haddiscoe and not on the applicants.
There is an increased risk that such operations. would have an unacceptable adverse impact on both the environment and human health, from noise, dust, visual intrusion, increased traffic, (particularly heavy goods vehicles), ground stability and the migration of contamination from the site. If one takes into account the cumulative effect of such operations on the nearby residents and their health, this proposal surely should not be granted and I wish to register my strong objection to such plans.

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.

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

Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Original draft response received 30.10.2019
Revised response received 08.11.2019

Highway Authority comments regarding sites proposed for allocation only

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

* 1.5 - one specific site[s] for carstone extraction
* 1.14 - tpa - presume that is tonnes per annum - not used consistently in this para
* Page 12 - SA section - bullet point list does not mention landscape impact or biodiversity
* 5.16 The area known as the [Breaks] Brecks
* Where is MW1? The first policy is MW2.
* MW2 - The first part is written in quite a different way to other policies I have read; rather than saying that impacts of development will be minimised on the criteria, or schemes will address the criteria, you ask for information only. I am not sure how strong this approach is. b) what about the quantity of surface water (as in what to do with it in relation to flooding) and the quality of water bodies? E) what agriculture land class do you consider this to be - Grade 1 and 2 perhaps - might need to say that. What about if the soil that is to be excavated or disturbed is peat soils? Peat soils have many special qualities, such as are a carbon sink but a carbon source if allowed to dry out. We recommend that you consider protecting Peat Soils - you can look at our Peat Soils policy for ideas. i) what are 'outdoor recreation facilities' and do you need to include Local Green Space as well as Open Space?
* 8.12 - request there is some text, perhaps as a footnote, that refers to the identified dark skies of the Broads and refers to our maps and policy.
* 8.16 says 'Directing lighting downwards and away from properties' but taking this literally, this contradicts - implying angling the light away from properties which could cause light pollution. I think you are saying design any lighting so it points downwards and ensure that there is no light trespass for example into neighbouring properties. You might want to consider that wording and you might want to look at our policy on light pollution. The key point is - do you really need lighting, if so why? Keep it to a minimum, use it when needed and point it down and have it fully shielded - I suggest you get those points across strongly in the policy.
* 8.24 first bullet point - weave in wording that refers to the setting of the landscapes.
* 8.31 and section 12 - I see you refer to soil grades 1, 2 and 3a. As a bit of advice from our experience, do you know where 3a is? There is limited mapping relating to 3a. You might want to consider removing this or just saying '3'. Happy to chat this through. Should the soil grade be mentioned in the policy? Note what is said on page 73, I - that 3a and 3b are not mapped.
* 8.32, 12.2 - temporary yes, but for a number of years. Suggest that text is clarified. See above regarding if the soil is peat soils and its care.
* 8.35 - is it worth asking applicants to state how they have considered water and rail and road and thoroughly justify their chosen mode, rather than just encourage it?
* MW3, last bullet point - is that a travel plan? MW4 refers to travel plans.
* MW4 - is it better to just say 'greenhouse gas emissions'? Does using the term 'endeavour' reduce the strength of criterion c? d) just demonstrate or implement too?
* 12.4 says 'Given their nature, most waste management facilities will tend to be suitably located on previously developed land and industrial locations and it is not expected that there will be a great need to locate such uses on agricultural land' - not sure what this is saying - they tend to be located there or are suitable to be located there?
* Map 3 - see above comments - where are areas of 3a?
* Section 12 - no mention of peat soils and their qualities - see above.
* Page 41 onwards and then 64 onwards - formatting - should this have a section number - perhaps section 13? The bullet points are numbered differently to elsewhere in the Plan - WO rather than, say, 13.2 etc.
* WP4 - a) when compared to another option that takes longer?
* W7.1 - do you mean 2018?
* WP13 - so a, b, c are 'or' and d, e, f are 'and'. It might be easier to separate them out and say something like 'in all cases d, e, f will apply'.
* WP15 - first para seems reasoned justification rather than policy text. Suggest the Broad Authority be involved in the organisations listed in para 3 - the organisations in para 4 seem to be the ones that need to be involved in the Masterplan.
* WP17 and MP11 - on adoption, presume we will be sent these GIS layers to upload to our system?
* Page 71, and MP2 - that NPPF paragraph applies to the Broads too. We have a Major Development policy. Why is the AONB excluded and the Broads not? Or is it?
* Page 73, g - why not the undesignated heritage assets?
* MP2.14 - 'Developers wanting to [extraction] extract mineral from specific sites or land within an area of search allocated in the Minerals and Waste Local Plan Review will still need to apply for and be granted planning permission before mineral extraction can take place'.
* MP2 - why the 3mile/5 mile rule for minerals?
* MP4.1 and MP4 - how about if the reservoir is not associated with mineral abstraction?
* Page 76 - what is shown on this map? There is no key. If it is core river valleys, why are the rivers over in the Broads not blue?
* MP6 might make sense but the first part says acceptable, unacceptable and acceptable. A check might be needed.
* MP8.3 'The need for annual reports after the initial five-year period [for] will be assessed on a case by case basis'.
* M65.5 - starts off saying 'The site is not located within...'. Being within is one issue, but affecting the setting of is another. So such assessments should state whether the site is near to those designations. This should therefore correctly read that the site is near to the Broads.
* Page 181 onwards - Min 38 - Waveney Forest, Fritton - support not allocating this site.
* Min 65, Stanninghall Quarry - extension to existing minerals site. No landscape visual or character concerns with regards to the Broads itself.
* Min 25, we would definitely want to be consulted on any forthcoming planning applications on this site, particularly concerning landscape scheme and restoration as the landscape character areas in this locality are well defined and susceptible to change.
* Min 211, Restoration as wet grassland for biodiversity needs to be balanced with long-term effects on local landscape character. The local character and experience of the landscape varies between the north and south of the site and restoration should reflect this.
* Generally, an LVIA assesses the effects of a development (the impact) on the landscape as a resource and the effects on visual receptors. The assessment will cover both the site itself and a wider study area determined by desk study and ground-truthing. LVIA's should be carried out to a set standard (Guidelines for landscape and visual impact assessment, 3d edition - which I believe is part of the NCC validation checklist) so by definition will be required to include the site and any surrounding area that could be affected by the development; Existing: "Submission of a Landscape and Visual Impact Assessment which will identify any potential impacts to the wider landscape and suggest appropriate mitigation measures ..." Proposed: "Submission of a Landscape and Visual Impact Assessment which will identify any potential effects and suggest appropriate mitigation measures ..." This text is used across a number of the policies.

SA Part A Scoping
Page 31 needs a very big update.
* Core Strategy, DM and Sites not in place any more.
* Local Plan adopted May 2019.
* Flood Risk SPD - most recent is 2017
* Broads Plan is 2017
Seems relevant to refer to our dark skies data and policy

SA - Part B
4.5 - did you consider a zone from the Broads?


Please note: The Broads Authority has adopted a new Local Plan which can be found here. The policies in the Core Strategy, Development Management and Site Specific documents are all superseded and not in place anymore.

Norfolk Minerals & Waste Local Plan Review: Preferred Options Consultation
Thank you for your recent consultation on the above document. Having reviewed the
consultation documents, we are pleased to note that the previous comments made by South Norfolk Council in relation to Policies WP7 and WP15 have been incorporated into the updated document. However, we also note that the other amendments suggested in our response to the Initial Public Consultation (dated 13 August 2018) have not been included within the latest version of the Norfolk Minerals and Waste Local Plan. We therefore wish to reiterate these comments and have again attached them to this consultation response for your ease of reference.
In addition to the above general comment, our Environmental Health colleagues have expressed their support for the submission of noise and dust assessments and mitigation measures to deal with the amenity impacts of planning applications for mineral extractions.
This is due to the proximity of existing residential properties to proposed mineral extraction sites within South Norfolk and the potential for these properties to be affected, particularly by noise and dust.
I hope you find the above comments useful.

Norfolk Minerals & Waste Local Plan Review: Initial Public Consultation
Thank you for your recent consultation on the above document, South Norfolk Council has the following comments to make.

General comments regarding the format of the policies:
Several policies concerning particular development types refer back to 'General' Policy MW2; whilst the reason for this is understood, there are a number of other general policies (e.g. MW3 and MW4) that might be equally applicable across a range of development types, but may get overlooked when development specific policies just refer back to MW2. As the policies in the plan should be read as a whole, is it necessary to have the references back to the general Development Management policies?
In a number of places policies are worded as aspirations, rather than requirements, consideration should be given to moving such wording to the supporting text, or strengthening the wording in the policy itself.

Comments on specific policies:

MW6 - would be more effective if it set out a hierarchy that sought development on the lowest grade of agricultural land first.

WP2 - it is not entirely clear what the first part of this policy is seeking to achieve; if it is seeking sustainable locations within easy reach of centres of population (particularly those that the proposed facilities are serving), the text may need to be expanded to better reflect this.

WP3 - in the list of potentially suitable land uses, 'within or adjacent to agriculture and forestry buildings' would appear to open up a wide range of sites to possible consideration, although it is understood that sites would need to meet the requirements of the general policies too. Permitted Development also opens up the scope for new build agricultural buildings, with relatively little input from the local planning authority. Consequently, could clause d) be caveated 'appropriately located' and 'in established use'?

WP4, WP5, WP7 etc. - a number of policies refer back to WP3 stating that proposals 'may be acceptable on land within the identified uses in', the Policy could be more effective as 'will not be acceptable outside of land identified in'.

WP7 - Concerned that this may not be legally sound, in that it goes beyond the remit of the Minerals and Waste Local Plan by seeking developer contributions. It would also be difficult to 'retro-fit' new Household Waste Recycling Centres into identified growth locations, if it was not a requirement when those locations were identified. Consideration could be given to allocating sites in the Minerals and Waste Local Plan which have good access to the growth locations.

WP15 - elements of this policy would appear to be requests rather than requirements, for example could 'strong encouragement' to Anglian Water be included in the supporting text, and the policy be reworded to say, 'Any proposals for the improvement of WWRC must to be accompanied by a longer-term vision, produced in collaboration with ...'

WP16 - This seems to overlap with MW2 and MW3; therefore, would this policy be better placed in the General Policies part of the Plan, and used to cover waste and minerals proposals?

Comments on Proposed Minerals Extraction Sites:

MIN25 at Haddiscoe - the site is very close to the nearest dwelling and the village generally, it would seem to be quite a significant site in terms of volume of material to be extracted, number of lorry movements etc. (we note there is a balance to be struck between length of extraction time and daily vehicle movements, to address concerns raised by the previous refusal of permission). Is there any scope to reduce the extent of the site, moving the boundary away from nearby dwellings and/or phasing the extraction as part of any mitigation? This, along with the impact on the Grade I Listed church and the visual impact of the proposed bunding, was a concern that South Norfolk Council raised in respect of the previous application on this site. In addition, the landscape assessment refers to mature screen planting, it would be useful if retention of this was picked up in the Initial Conclusion.

MIN 212 at Mundham - The relationship between the site and the processing plant seems to be quite poor, although it is acknowledged that the number of movements are relatively small and this is an existing route. The proposal includes increased bunding to screen the minerals workings, but doesn't indicate if that would be acceptable in terms of the landscape character type within which the site is located.
I hope you find the above comments useful.