Initial Consultation document

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: 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 be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: 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 be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: 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 be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: 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 be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: 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 be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: 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 be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: 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 be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: 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 be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: 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 be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: 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 be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.