Initial Consultation document

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Initial Consultation document

Question 57: Proposed site MIN 38 (Waveney Forest, Fritton)

Representation ID: 91969

Received: 31/07/2018

Respondent: The Somerleyton Estate

Agent: Evolution Town Planning

Representation Summary:

We are responding to the current consultation on the Norfolk Minerals and Waste Local Plan Review. This consultation response is made on behalf of The Somerleyton Estate and concerns proposed Mineral Extraction Site MIN38. MIN38 is located on a site known as Waveney Forest near Fritton. The Somerleyton Estate object to this potential minerals extraction site for the reasons set out below.

Our client owns and manages the Fritton Lake Holiday Resort - a significant and high quality tourist destination but also an environmental project-in-progress through its re-wilding programme and other related environmental and ecological measures. Fritton Lake is only some 400m from the proposed extraction site at its nearest point with a bulk of the extraction happening within one kilometre of the main body of the lake.

Our client wishes to object the potential minerals extraction site on the grounds of heritage, ecological impact, highways, noise and pollution.

Heritage
We understand from the Sites Assessment part of the Initial Consultation document that the minerals planning authority have already concluded that "The site is considered to be unsuitable for allocation" and this is due to harm to the significance of the Waveney Forest WW2 Military Training Area.

The Somerleyton Estate support this position and would reiterate that the NPPF refers to 'Facilitating the Sustainable Use of Minerals' but this site cannot be sustainable if, as the minerals planning authority have already recognised, the harm to the significance of the heritage assets cannot be mitigated if the heritage assets itself is completely destroyed.

The minerals planning authority may already have access to sufficient information on the history and therefore the significance of the Waveney Forest Military Camp (also known as the Fritton/Somerleyton Auxiliary Unit Patrol and Operational Base) but for ease of reference we have enclosed copies of entries from the Norfolk Heritage Explorer and (because there were no images on the Heritage Explorer website) we have provided information from a website which reinforces much of the content of the Heritage Explorer website.

Also included with this letter are records from the Broads Authority related to previous local greenspace designation assessment but more importantly because of the related references to parts of the Waveney Forest site being locally listed by The Broads Authority.

Ecology
The ecological assessment undertaken as set out in the Initial Consultation document is noted however Norfolk County Council need to be aware of the environmental sensitivity of the Fritton Lake site and the recent efforts of the owners and statutory agencies to improve the lake for the benefit of internationally endangered species. The County Council should satisfy themselves that mineral extraction at MIN38 poses zero threat to the environmental integrity of Fritton Lake.

Enclosed with this letter is information concerning the Estate's conservation efforts in and around Fritton Lake and the Waveney Forest area aimed at supporting biodiversity and critically endangered species including the European Eel. This work has been partnered by EDF, the Environment Agency and the Sustainable Eel Group (a Europe wide conservation and science led organisation working with partner bodies and individuals to accelerate the eel's recovery).

Highways
The Somerleyton Estate is concerned about the quantity and nature of the traffic movements associated with a quarry. A significant draw for tourists to this area is the quintessentially peaceful Broads environment. This is something the minerals planning authority need to bear in mind when further considering the acceptability of this site and whether it is just simply located in the wrong place.

We note from the consultation document that "the proposed highway access is considered to be suitable by the Highway Authority, subject to a right hand turn lane on the A143. Inset below is a Google StreetView image of the area in which the consultation document indicates the access will be; "a junction approximately opposite the access to PRoW Fritton and St. Olaves BRS" i.e. part of the local rights of way network ley to local tourism and public access to the countryside.
It is also difficult to see how a 'right hand turn lane' would fit in this location without having to widen the road with the resultant loss of the wooded embankments characteristic of this and other roads in the area.

Noise and Pollution
Again we note the content of the site assessment and the probability that distances between the mineral extraction sites and Fritton Lake are probably sufficient to reduce the chances of impacts arising from noise and dust. The Somerleyton Estate asks the minerals planning authority to satisfy themselves that this is truly the case and it may be necessary to consult further with relevant consultees.

However this is not the principal concern of The Estate. The Somerleyton Estate are concerned that, so far, the site assessment does not adequately consider the below ground linkages between MIN38 and Fritton Lake. The consultation document acknowledges both sites are within the same catchment but this relates to above-ground mechanisms. We assume, but cannot tell from the site assessment, that the sites are connected via groundwater to the extent that activity in the proposed Mineral site MIN38 could adversely affect Fritton Lake.

For the reasons set out above the Somerleyton Estate asks Norfolk County Council to consider this matter in detail and to obtain the necessary expert guidance from the local flood authority and the Environment Agency as necessary in order to fully understand the hydrological relationship between this potential extraction site and the highly environmentally sensitive Fritton Lake.

Full text:

We are responding to the current consultation on the Norfolk Minerals and Waste Local Plan Review. This consultation response is made on behalf of The Somerleyton Estate and concerns proposed Mineral Extraction Site MIN38. MIN38 is located on a site known as Waveney Forest near Fritton. The Somerleyton Estate object to this potential minerals extraction site for the reasons set out below.

Our client owns and manages the Fritton Lake Holiday Resort - a significant and high quality tourist destination but also an environmental project-in-progress through its re-wilding programme and other related environmental and ecological measures. Fritton Lake is only some 400m from the proposed extraction site at its nearest point with a bulk of the extraction happening within one kilometre of the main body of the lake.

Our client wishes to object the potential minerals extraction site on the grounds of heritage, ecological impact, highways, noise and pollution.

Heritage
We understand from the Sites Assessment part of the Initial Consultation document that the minerals planning authority have already concluded that "The site is considered to be unsuitable for allocation" and this is due to harm to the significance of the Waveney Forest WW2 Military Training Area.

The Somerleyton Estate support this position and would reiterate that the NPPF refers to 'Facilitating the Sustainable Use of Minerals' but this site cannot be sustainable if, as the minerals planning authority have already recognised, the harm to the significance of the heritage assets cannot be mitigated if the heritage assets itself is completely destroyed.

The minerals planning authority may already have access to sufficient information on the history and therefore the significance of the Waveney Forest Military Camp (also known as the Fritton/Somerleyton Auxiliary Unit Patrol and Operational Base) but for ease of reference we have enclosed copies of entries from the Norfolk Heritage Explorer and (because there were no images on the Heritage Explorer website) we have provided information from a website which reinforces much of the content of the Heritage Explorer website.

Also included with this letter are records from the Broads Authority related to previous local greenspace designation assessment but more importantly because of the related references to parts of the Waveney Forest site being locally listed by The Broads Authority.

Ecology
The ecological assessment undertaken as set out in the Initial Consultation document is noted however Norfolk County Council need to be aware of the environmental sensitivity of the Fritton Lake site and the recent efforts of the owners and statutory agencies to improve the lake for the benefit of internationally endangered species. The County Council should satisfy themselves that mineral extraction at MIN38 poses zero threat to the environmental integrity of Fritton Lake.

Enclosed with this letter is information concerning the Estate's conservation efforts in and around Fritton Lake and the Waveney Forest area aimed at supporting biodiversity and critically endangered species including the European Eel. This work has been partnered by EDF, the Environment Agency and the Sustainable Eel Group (a Europe wide conservation and science led organisation working with partner bodies and individuals to accelerate the eel's recovery).

Highways
The Somerleyton Estate is concerned about the quantity and nature of the traffic movements associated with a quarry. A significant draw for tourists to this area is the quintessentially peaceful Broads environment. This is something the minerals planning authority need to bear in mind when further considering the acceptability of this site and whether it is just simply located in the wrong place.

We note from the consultation document that "the proposed highway access is considered to be suitable by the Highway Authority, subject to a right hand turn lane on the A143. Inset below is a Google StreetView image of the area in which the consultation document indicates the access will be; "a junction approximately opposite the access to PRoW Fritton and St. Olaves BRS" i.e. part of the local rights of way network ley to local tourism and public access to the countryside.
It is also difficult to see how a 'right hand turn lane' would fit in this location without having to widen the road with the resultant loss of the wooded embankments characteristic of this and other roads in the area.

Noise and Pollution
Again we note the content of the site assessment and the probability that distances between the mineral extraction sites and Fritton Lake are probably sufficient to reduce the chances of impacts arising from noise and dust. The Somerleyton Estate asks the minerals planning authority to satisfy themselves that this is truly the case and it may be necessary to consult further with relevant consultees.

However this is not the principal concern of The Estate. The Somerleyton Estate are concerned that, so far, the site assessment does not adequately consider the below ground linkages between MIN38 and Fritton Lake. The consultation document acknowledges both sites are within the same catchment but this relates to above-ground mechanisms. We assume, but cannot tell from the site assessment, that the sites are connected via groundwater to the extent that activity in the proposed Mineral site MIN38 could adversely affect Fritton Lake.

For the reasons set out above the Somerleyton Estate asks Norfolk County Council to consider this matter in detail and to obtain the necessary expert guidance from the local flood authority and the Environment Agency as necessary in order to fully understand the hydrological relationship between this potential extraction site and the highly environmentally sensitive Fritton Lake.

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