Biodiversity and Geological Conservation

Paragraphs 8.18 to 21 do not appear to explicitly distinguish between the hierarchy of international, national and locally designated sites as advised by paragraph 171 of NPPF. These paragraphs should be revised to accomodate this guidance, else, in the view of the Company, be found unsound.

Preferred Options Plan
Thank you for the opportunity to comment on the Preferred Options stage of the Norfolk Minerals and Waste Local Plan. We have commented on the policies and allocated sites in the same format as the Local Plan itself below.

The Process so far
We are pleased to see water resources are mentioned in this section. However, this section could be strengthened by making reference to whether working beneath the water table is required and whether dewatering is required. This could potentially pose a challenge to sites moving forward so it should have a stronger mention in this section.

Policy MW2: Development Management Criteria
We are pleased to see that point k in this policy makes reference to the natural and geological environment. This point could be enhanced by also making reference to the hydrogeological environment including maintaining groundwater dependent wetlands, surface water flows, groundwater quantity and flow regime.

The policy makes no reference to local air quality regarding waste developments, be it from gas utilisation units or fugitive emissions from landfilled areas and their perimeter. This is especially key where development is close to sensitive receptors or such receptors are developed close to the sites.

We welcome the inclusion of point D in the policy. This could be enhanced to state
"flood risk TO THOSE WORKING on site or an increase in flood risk elsewhere" (addition in CAPITALS ). The policy could also be improved by requiring a Flood Response Plan to manage the safety of the people on site.

Pollution and Local Amenity Impacts
We agree with the inclusion of paragraph 8.12 that lighting levels should be assessed with consideration given to the impact lighting will have on European Protected species. Mitigation could include limiting the operational hours of the site and using down lighting.

We fully support the protection of Local Wildlife sites (county wildlife sites, local nature reserves and local wildlife sites) highlighted in paragraph 8.20 as well as priority habitats and species. We agree that any proposal should only be permitted where it can be demonstrated that the activities will not significantly harm the site, and will require submission of appropriate ecological surveys, carried out by an appropriately qualified ecologist, at the correct time of year as described in paragraph 8.21. We recommend the rewording of the final sentence of paragraph 8.20 to state "Development that may affect Water Framework Directive waterbodies e.g. rivers, streams, lakes will require a WFD compliance assessment".

Water Framework Directive
The plan should make reference to the fact that any development that could impact the status of a water body, whether WFD or not, should be subject to a WFD assessment.

Flooding, Water resources and water quality
We agree with the reference this section makes to flood risk betterment after restoration, reducing flood risk elsewhere and acknowledgement that climate change needs to be considered. However this section does not refer to ensuring there is no increase in flood risk elsewhere through the duration of the works. In addition there is no mention of the flood risk to people on site and the need for management to ensure their safety with a Flood Response Plan. The plan should therefore be updated to this effect.


It is encouraging to see that paragraph 8.40 makes it clear that dewatering for mineral abstraction purposes requires a water abstraction licence from the Environment Agency. However, it should be noted that an abstraction licence for dewatering may not be granted and it is likely that any de-watering water will need to be returned to the aquifer close to where it is abstracted and in a timely manner after the abstraction takes place. Our current Catchment Area Management Strategy (CAMS) policy for issuing abstraction licences intervening use of this water for activities such as mineral washing and dust suppression which have a consumptive element will not be permitted, this be a challenge for sites going forward if alternative sources of water for associated activities such as mineral washing and dust suppression cannot be found.

Paragraph 8.40 refers to the Water Framework directive. A WFD assessment is a good addition and we welcome the suggestion to protect the designated drinking water source protection zones. We also support the use of pollution prevention measures, to prevent pollution of surface and groundwater. This paragraph should also state that the assessment should determine if there could be a deterioration in WFD status. Activities should not allow any deterioration in any of the WFD elements. Minerals and waste management developments should not cause deterioration or prevent a water body from achieving Good Ecological Status/Potential, and whenever possible, help to implement environmental improvement measures to improve waterbodies.

Policy MW4: Climate Change mitigation and adaptation
Paragraph 10.2 states the need to minimise demands on potable water resources. The sentence should continue by saying 'and water resources in general'. As stated above, we are not issuing new consumptive abstraction licences.

A possible linkage could be made between point's b and c - on site renewable energy (both electricity and hot water) could well be provided from captured landfill gas emissions. Any excess energy could then be fed into the local networks.
It would be beneficial to update the wording of point 3 to state "...including rising sea levels, LARGER RIVER FLOWS, and coastal erosion..." (addition in CAPITALS).

Waste Management Specific Policies
In terms of paragraph W0.3, you should ensure that you plan for sites that will 'Prepare for Re-use' as it has been stated that greater weight is being put to the management methodology at the top of the waste hierarchy.

W1.12
The plan states "The latest Defra estimate of C&I waste growth for England is 0.6% per annum, therefore an alternative option would be to forecast C&I waste growth over the Plan period at 0.6% per annum instead of 1.5% per annum. However, it is considered that it is more appropriate to use the Norfolk specific figure of 12.5% per annum". We are unsure where and how this figure of 12.5% has been calculated and why it is so different to DEFRA's estimate. Sustainable economic growth will need enough commercial and industrial waste processing capacity to deal with this increase in waste generation.

Policy WP2: Spatial Strategy for Waste Management Facilities
We support the policy WP2 regarding the location of Water Recycling Centres. It should be noted that the decision, ultimately, remains with Anglian Water Services.

Policy WP3: Land potentially suitable for waste management facilities
This policy should state that waste management facilities (aggregate recycling) also need to consider consumptive water use and where this water will come from.

Policy WP6: Transfer, Storage, Processing and treatment of hazardous waste
It is highly likely that any proposals for the discharge of hazardous waste to surface water or groundwater will require a discharge permit, if allowed. The policy could be improved by saying that under no circumstances, should there be a discharge of treated hazardous waste/materiel to surface waters or groundwater without prior consultation with the EA.

Policy WP9: Anaerobic Digestion
The policy could be improved by making reference to Emergency Planning. Proposals for Anaerobic Digestion (AD) facilities should include a detailed emergency plan should there be an incident, such as a major leak or fire for example. AD leachate is extremely rich in nutrients, which if entering a watercourse, could cause significant environmental harm. We suggest the emergency pan includes nearby watercourses, overlying geology, depth to water table, detailed site drainage plan for example. If possible, an emergency plan should be provided for the Environment Agency to review.

W12: Non-hazardous and hazardous waste landfill
Along with section 5.35, we question whether allowing planning permission for Blackborough End to become an inert landfill and reducing the county's non-hazardous landfill waste capacity to just 1.53 million cubic metres is sufficient for residual waste disposal over the plan period. It is unclear from the Local Plan what the options for residual waste disposal will actually be, except reliance on Refuse Derived Fuel (RDF) and its export. Bearing in mind NCC are keen for sustainable waste management, then the export of RDF by definition its potential energy, does not appear the best long term option. Although waste management options higher up the waste hierarchy are always preferable, there will always be waste streams that can only be disposed in landfill.

Policy WP13: Landfill Mining and Reclamation
Please note that such a proposal will require detailed input and agreement from the Environment Agency.

Policy WP15: Whitlingham Water Recycling Centre
We have previously provided comments stating that we welcomed that the WRC has a long term policy to ensure that further capacity is provided in line with growth. We continue to support long term plans being developed for Whittingham and other WRCs.
W15.2 mentions the sites location is close to the Broads and the associated 'landscape and flood risk concerns'. The location also means there are concerns for water quality due to the close proximity of sensitive protected sites of conservation importance. A statement to acknowledge that water quality needs to be protected should therefore be added to the plan here or in this policy.

Policy MP2: Spatial Strategy for mineral extraction
Point e makes reference to the hydrological catchment around Roydon Common SSSI and Dersingham Bog SSSI. It should be ensured that it is mentioned that it is the hydrological and hydrogeological catchment around Roydon Common and Dersingham bog which should be avoided.
We support the policy to provide a 250m buffer around ancient woodland and designated sites.

Policy MP5: Core River Valleys
This policy should also include "the impact of mineral development on groundwater and the potential to need to work beneath the water table".
Any proposal for quarrying activity within a core river valley should not be approved unless the applicant can demonstrate no adverse effect on the WFD status of the river water body, or its tributaries. A Full WFD assessment (as outlined above) will be required for any proposal for this activity to be carried out within a floodplain.

Policy MP7: Progressive working, restoration and after-use
We are fully supportive of supporting paragraph 7.3 which states there may be suitable ark sites to protect wild-clawed crayfish. Such sites need to be identified well in advance of de-commissioning to that the site can remain bio-secure.
The first bullet point in policy MP7 refers to BAP habitat. Please note that this has been superseded by Priority Habitat (S41 NERC Act, 2006).

Policy MP12: Conventional and unconventional oil and gas development
Unconventional oil and gas production requires a lot of water to be used so it is likely an abstraction licence will be required. In addition, much of this water ends up as wastewater so the appropriate storage, treatment and disposal methods will be required. Discharge to any surface waters or groundwater will likely require a discharge permit and an application will need to be submitted. Having said this, the local plan indicates it is highly unlikely there will be hydrocarbon exploration in Norfolk in the foreseeable future so these comments may not be necessary at this point in time.

Policy MP13: Areas of search for silica sand extraction
As stated in our previous response, policy MP13 needs to address the need for an FRA. An FRA is vital if any of the allocations are located in Flood Zones.
Site Allocations

MIN38: Land at Waveney Forest, Fritton
Following our previous comments, we are welcome the conclusions drawn in this document which state the allocation is unsuitable for allocation.

MIN200: Land West of Cuckoo Land, Carbrooke
The site allocation text mentions that the site will be worked dry above the water table several times. If this is the case then this would alleviate our concerns on impacts on Scoulton Mere SSSI. This however is not included within the policy on page 124 and must be included.

MIN40: Land East of Grandcourt Farm, East Winch
We have concerns regarding this site. In the existing site, permeant dewatering of Carstone is proposed in restoration which goes against our previously raised comments. We would recommend not allocating this site.
Any depth of extraction should be severely limited to minimise de-watering. This could impact of the amount of mineral which can be recovered. As this is a principal aquifer, any de-watering water would need to be returned to the aquifer from which it is taken. An appropriate hydrogeological impact assessment will be required and it may well be that de-watering is not considered suitable at this site, which could limit the amount of mineral that could be recovered.

MIN35: Land at Heath Road, Quidenham
Our comments that we gave to the 2018 consultation remain valid.We have no concerns as it is proposed to work above the water table. This may need to be a planning condition on any application submitted.

MIN102: Land at North Farm, Snetterton
This site is adjacent to Swangey Fen SSSI. We previously stated that we do not consider the site suitable for mineral extraction. We are therefore supportive of the conclusions drawn in this consultation document stating that it is considered unsuitable for allocation

MIN201: Land at North Farm, Snetterton
This site is adjacent to Swangey Fen SSSI. We previously stated that we do not consider the site suitable for mineral extraction. We are therefore supportive of the conclusions drawn in this consultation document stating that it is considered unsuitable for allocation.

MIN6: Land off East Winch Road, Middleton
We are pleased to see that the specific site allocation policy for MIN 6 states the need to work above the water table. However, a hydrogeological impact assessment (not impact assessment) would be required to establish the depth of working.

Min204: Land off Lodge Road, Feltwell
Our previous comments raised within the issues and options stage of the consultation remain valid.

MIN74: Land at Turf Field, Watlington Road, Tottenhill
We agree with the conclusion that this site is unsuitable to be carried forward. If the site were to be taken forward, we would want to see a suitable hydrogeological impact assessment.

MIN76: Land at West Field, Watlington Road, Tottebhill
We are already aware of the planning application that has been submitted in terms of this application and have no further comments to make.

MIN77: Land at Runns Wood, South of Whin Common, Tottenhill
We agree with the conclusion that this site is unsuitable to be carried forward. If the site were to be taken forward, we would want to see a suitable hydrogeological impact assessment.

MIN206: Land at Oak Field, west of Lynn Road, Tottenhill
We consider this site suitable for sands and gravel extraction. The need for a hydrogeological impact assessment must be included within a bullet point in the specific site allocation policy. It's likely that de-watering will be required here.

MIN32: Land west of Lime Kiln Road, West Dereham
We agree with the conclusion that the site is unsuitable to be carried forward. We would want to see a suitable hydrogeological impact assessment if the site was carried forward and, as it is sands and gravels overlying chalk bedrock, it is possible that de-watering would not be considered a suitable option.

Area of search for AOE E
Given previous issues we have had with silica sand extraction in the vicinity of this site, we would expect all extraction to be above the watertable. This is likely to limit the amount of resource that can be recovered. It should be noted that the silica sand is part of a principal aquifer.


SIL01, AOS F, AOS I and AOSJ
The starting position should be not to allow de-watering as outlined in our comments to site allocation MIN40.

Silica Sand search locations
If de-watering is not to occur at the silica sand search locations as mentioned in our response above, this can heavily impact on the amount of resource available.

We trust this advice is useful.

Please note that the MPA would wish to attend the EiP.
Comment:
Vision
We agree with the principle of the vision but suggest change in wording in respect of the safeguarding vision in that mention should be made to the agent of change detailed in the NPPF (para 182) and make the vision compliant with National Policy.

Proposed Changes (new text in CAPITALS)
Resources of sand and gravel, carstone and silica sand within defined Mineral Safeguarding Areas will be safeguarded from needless sterilisation by non-mineral development. Infrastructure for the storage, handling, processing and transportation of minerals will also be safeguarded from incompatible development. THE 'AGENT OF CHANGE' PRINCIPLE WILL BE APPLIED TO ANY NEW PROPOSED DEVELOPMENT IMPACTING ON SAFEGUARDED AREAS OR SITES.

Mineral Strategic Objective
The following adjustments are suggested to the following objectives to make the to properly reflect NPPF;
Proposed Changes (new text in CAPITALS)

MSO1. To provide a steady and adequate supply of aggregate minerals AND TO PROVIDE AT LEAST A 7-YEAR LAND BANK FOR SAND AND GRAVEL, AND 10-YEAR LANDBANK FOR CARSTONE, by identifying adequate mineral extraction sites/areas within Norfolk sufficient to meet the requirements of the Local Aggregate Assessment and safeguarding existing infrastructure.

MSO2. To provide a steady and adequate supply of industrial minerals by identifying adequate mineral extraction sites/areas within Norfolk sufficient to meet the forecast need AND STOCKS OF PERMITTED RESERVES OF SILICA SAND OF AT LEAST 10 YEARS PRODUCTION FOR INDIVIDUAL SILICA SITES OR AT LEAST 15 YEARS WHERE SIGNIFICANT NEW CAPITAL IS CAPITAL IS REQUIRED and safeguarding existing infrastructure.

MSO4. To safeguard silica sand, carstone, and sand and gravel resources for future use. Avoiding unnecessary sterilisation by encouraging the extraction of minerals prior to other development taking place where practicable and using minerals in construction on the land from which they are extracted. THE 'AGENT OF CHANGE' PRINCIPLE WILL BE APPLIED TO ANY NEW PROPOSED DEVELOPMENT IMPACTING ON SAFEGUARDED AREAS OR SITES.

MSO5. To promote the sustainable transport of minerals by rail, road and water, including the safeguarding of railheads and wharfs for the import of minerals to and export of minerals from Norfolk. THE 'AGENT OF CHANGE' PRINCIPLE WILL BE APPLIED TO ANY NEW PROPOSED development impacting on safeguarded sites.

Biodiversity and Geological Conservation
Para 8.18 to 8.21
We consider that the above paragraphs do not properly reflect NPPF in that the Plan as drafted does not properly distinguish between the hierarchy of international, national and locally designated sites as required by paragraph 171 of the NPPF. As such the Plan is unsound.

Historic Environment
Para 8.28 to 8.30
In the absence of a specific policy on this topic we believe the text needs to better reflect the NPPF at paragraph 189;
"The level of detail should be proportionate to the assets' importance and no more than is sufficient to understand the potential impact of the proposal on their significance."
While the text goes some way to this by using the phrase 'in a manner appropriate to their significance', we believe that there is a difference between proportionate and appropriate. Proportionate goes to the amount of time/resource needed to determine the impact of a development proposal on a heritage asset.
In addition, as drafted the text could be interpreted that all heritage assets regardless of significance must be preserved.
For the above reasons the text is unsound as it does not align with nation al policy and is also not effective. The text needs to be redrafted to reflect national policy.

Policy MW3: Transport
Suggested altered wording for the last bullet point of the policy as follows to make the policy effective;

Proposed Changes (new text in CAPITALS)
WHERE PRACTICAL AND appropriate measures to reduce car travel to the site by workers and visitors and encourage walking, cycling and use of public transport.
This alteration is made to prevent a dogmatic approach being taken. We have examples of cycle racks needing to be provided when it was clearly impractical for individuals to safely cycle to the site.

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

Policy MW6: Agricultural soils
It is felt that the last bullet point is unnecessary and could dilute the policy in terms of the importance of agricultural restoration. With climate change the ability to have land to grow food will become even more important. The proposed changes make the policy effective.
The wording of the policy needs adjusting as follows:

Proposed Changes
Where development is proposed on agricultural land, the County Council has a clear preference for locating new mineral extraction and associated activities, and composting facilities, on land of agricultural grades 3b, 4 and 5.
Development proposals affecting Grade 1 agricultural land will only be permitted in exceptional circumstances, where it is demonstrated that there are no alternative locations for the development.
In addition to the above, when minerals development, particularly extraction, is proposed on agricultural land of grades 1, 2 or 3a it will [DELETE: only] be permitted where:
* Provision is made for high standards of soil management that would enable restoration to a condition at least as good as its previous agricultural quality. To demonstrate this, soil and land quality surveys, and soil handling and replacement strategies (based upon Defra's 'Good Practice Guide for Handling Soils') must be submitted to the County Planning Authority; or
DELETE THE FOLLOWING TEXT: "The benefit of restoring the land to another after-use can be shown to outweigh the loss of the agricultural use of the land."
Policy MP1: Provision for minerals extraction
Changes are required to make it clear that the landbanks levels have to be maintained so they are in place at the end of the plan period to make the policy accord with national policy and be effective .In respect of silica sand changes are needed to make the policy accord with NPPF .
Suggested re wording as follows;
Proposed Changes (new text in CAPITALS)
For sand and gravel, specific sites to deliver at least 20,313,300 tonnes of resources will be allocated. The sand and gravel landbank will be maintained at a level of at least 7 years supply THROUGHOUT THE PLAN PERIOD (excluding any contribution from borrow pits for major construction projects).
For carstone, a site or sites to deliver at least 340,200 tonnes of resources will be allocated. The landbank for carstone will be maintained at a level of at least 10 years' supply THROUGHOUT THE PLAN PERIOD.
For silica sand, sufficient sites and/or areas to deliver at least 10,500,000 tonnes of silica sand will be allocated. [Delete: The landbank] STOCKS OF PERMITTED RESERVES for silica sand will be maintained at a level of at least 10 years' [Delete: supply] PRODUCTION FOR EACH INDIVIDUAL SILICA SAND SITE OR AT LEAST 15 YEARS WHERE SIGNIFICANT NEW CAPITAL IS REQUIRED. [Delete: where practicable]. Planning applications for silica sand extraction located outside of allocated sites or areas of search, which would address the shortfall in permitted reserves, will be determined on their own merits in accordance with the policies in this Local Plan, including the requirements contained within Policy MP13.

Policy MP2: Spatial Strategy for mineral extraction - STRATEGIC POLICY
There should be no buffers applied to the so-called planning constraints. The acceptability or not of approaching such constraints will be a matter for the EIA and the development management process. Arbitrary buffers risk the sterilisation of workable mineral when they could be satisfactorily worked without impact.
There is no evidential basis for the buffers and the policy is unsound as it is not effective and is not positive planning.

Policy MP10: safeguarding of port and rail facilities, and facilities for the manufacture of concrete, asphalt and recycled materials
The MPA welcomes and support the reference to the 'agent of change' principle in paragraph MP10.3 of the supporting text. However, it is felt that for the purposes of clarity and effectiveness the wording of the policy should be adjusted as follows to apply the 'agent of change' principle;

Proposed Changes (new text in CAPITALS)
The County Council will safeguard:
a) Existing, planned and potential rail heads, rail links to quarries, wharfage and associated storage, handing and processing facilities for the bulk transport by rail, sea or inland waterways of minerals, including recycled, secondary and marine-dredged materials; and
b) Existing, planned and potential sites for concrete batching, the manufacture of coated materials, other concrete products and the handling, processing and distribution of PRIMARY, substitute, recycled and secondary aggregate material.
Development proposals within 250 metres of the above minerals related facilities should demonstrate that they would not prevent or prejudice the use of those facilities. THE 'AGENT OF CHANGE' PRINCIPLE WILL BE APPLIED TO ALL SUCH DEVELOPMENT.

Policy MP11: Mineral Safeguarding Areas and Mineral Consultation Areas.
For the same reasons as stated for Policy MP10 wording of the policy should be altered to incorporate the 'agent of change' principle as follows;
Proposed Changes (new text in CAPITALS)
Policy MP11: Minerals Safeguarding Areas and Minerals Consultation Areas
The County Council will safeguard existing, permitted and allocated mineral extraction sites from inappropriate development proposals. Minerals Consultation Areas are delineated on the Policies Map and extend to 250 metres from each safeguarded site. Development proposals within 250 metres of a safeguarded site should demonstrate that they would not prevent or prejudice the use of the safeguarded site for mineral extraction, AND THE AGENT OF CHANGE PRINCIPLE WILL BE APPLIED IN ALL SUCH CASES. The County Council will object to development proposals which would prevent or prejudice the use of safeguarded sites for mineral extraction.

Other Comment

Section 42. Page 84...The Targets/trigger levels do not conform with land bank policy requirements or those for stock of permitted reserves, wither in the proposed Policy MP1 or the NPPF.

The MPA would like to be present at any EiP.

Fracking
Unnatural disturbance of the Earth's geological structure and plates is caused by fracking. Unknown effects could be disastrous and harmful for communities. It is irresponsible and dangerous for the current and future population. Fracking will contribute to climate change so goes against all policies to lessen effects of unnatural 'actions', eruptions and earth tremors.
Fracking already taking place in the Country has caused several tremors, causing fear, alarm and distress to residents. This is a material effect on human health and well-being.

Incineration
West Norfolk is responsible for more than a quarter of the County's emissions
(Lynn News page 12 - 9 August 2019.)

To allow, or even think of putting incineration into policies, is blatantly going against democracy of the last King's Lynn & West Norfolk Borough Poll where 65,000 people voted against incineration and NCC wasted millions of pounds on an abandoned project. Efforts should be put into alternative methods of waste reduction and disposal, or re-use schemes.

Questions asked by Norfolk County Councillor, Alexandra Kemp to NCC Cabinet.
Following £34 million lost from Council's budget, with the cancellation of the infamous South Lynn incinerator contract for Planning Failure in 2014, Council agreed a No-Incineration-in-Norfolk Policy, ("Appendix M").

West Norfolk is alarmed by the criteria-based Draft Waste Plan, which fails to state our No-Incineration Policy, instead permissively lists forms of incineration ( page 56), endangers West Winch Growth Area by permitting prospecting for fracking ( page 90), erroneously ignoring prospecting always causes earthquakes.

Can Cabinet amend the Plan to state " in West Norfolk, where 65,000 people voted against incineration in the Borough Poll, applications for incinerators will not be permitted"; and exclude fracking and prospecting for fracking?

West Winch Parish Council agrees with the County Councillor, Alexandra Kemp.

We do not need these policies which can cause more problems with emissions and climate change.

Policy WS07 Huge risks to human health and well-being and Air Quality page 17, para 5.18.

Page 26 Presumption in favour of sustainable development is likely to breach 7.1 (b) Communities health....
'Presumption in favour ...' should be removed.

Policy MW2 Development Management Criteria
'Unacceptable impact on (a) to (m).

Page 28 Pollution and Local Amenity Impacts
Para 8.9 there should be no impact on human health - densely populated area King's Lynn and proposed massive development at South East King's Lynn (SEKL).
Para 8.20 mentions Ancient Woodland - This must also apply to historical Grazing Commons, especially in West Winch and North Runcton.

Historical Environment
Para 8.28 - King's Lynn has ancient historical buildings. Harmful emissions and fracking would affect these valued buildings which attract visitors and tourists, contributing major finance to the area's economy.

West Winch and North Runcton have protected sites of local value -
Reference - page 20, West Winch and North Runcton Neighbourhood Plan (Planning material consideration)
Plus, 2 sites of Special Scientific Interest, and
3 County Wildlife Sites, including West Winch Common.

Page 32 - Land and Soil Resources
Para 8.31 Agricultural Land, which should include Grazing Common Land, must all be protected from contamination to protect our food chain for the future of the whole Country.

Page 34 Cumulative Impacts
It is imperative that cumulative impacts are taken into account as too often measurements are only taken close to the proposed development. Cumulative measurements impact on human health.

Page 46 '.... Not considered necessary to allocate any waste management sites in the Plan' - which means these sites can be developed anywhere on industrial sites etc and they could be near to densely populated areas.
This should be scrutinised more closely and incineration must be deleted.

Page 46 Policy WP1 Hazardous -----
Norfolk County Council needs to keep tight control over hazardous waste received from other Waste Planning Authorities.

Page 48 Policy WP2 Distance
Distance of waste facilities needs to be considerably increased to safe levels for human health away from populated areas.