Initial Consultation document

Submission Norfolk Minerals and Waste Local Plan Consultation
Thank you for consulting the Ministry of Defence (MOD) in relation to the above referenced consultation document.
DIO Safeguarding main concern when reviewing Mineral and Waste local plan, relates to the proposed site allocations and the restoration/aftercare scheme.
The county of Norfolk has several statutory safeguarding sites within its authority area, these being RAF Lakenheath, RAF Lakenheath, RAF Mildenhall and RAF Marham.
On reviewing the proposed mineral sites the following occupy statutory birdstrike safeguarding consultation zones for RAF Marham: MIN 19 & 205;76;77;40; SIL01 SIL02; AOS E &J.
Therefore, DIO Safeguarding is concerned with the development of open water bodies, the creation of wetland habitat, refuse and landfill sites. These types of development have the potential to attract large flocking bird species hazardous to aviation safety. Therefore, we would recommend dry restoration and dry phased working.
The following sites MIN 6; MIN 204; MIN 74; MIN 206 and MIN 32 the restoration is dry using inert waste or imported inert materials. If this were to change to wet restoration or there was potential for wet working as part of the extraction scheme, DIO Safeguarding would need to be consulted.
Please note the remaining sites fall outside of the statutory safeguarding areas and we have no concerns regarding these allocations.
Please note the above comments are purely related to the DIO Statutory Safeguarding interests. I trust this adequately explains our position on this matter.

Submission Norfolk Minerals and Waste Local Plan Consultation
Thank you for consulting the Ministry of Defence (MOD) in relation to the above referenced consultation document.
DIO Safeguarding main concern when reviewing Mineral and Waste local plan, relates to the proposed site allocations and the restoration/aftercare scheme.
The county of Norfolk has several statutory safeguarding sites within its authority area, these being RAF Lakenheath, RAF Lakenheath, RAF Mildenhall and RAF Marham.
On reviewing the proposed mineral sites the following occupy statutory birdstrike safeguarding consultation zones for RAF Marham: MIN 19 & 205;76;77;40; SIL01 SIL02; AOS E &J.
Therefore, DIO Safeguarding is concerned with the development of open water bodies, the creation of wetland habitat, refuse and landfill sites. These types of development have the potential to attract large flocking bird species hazardous to aviation safety. Therefore, we would recommend dry restoration and dry phased working.
The following sites MIN 6; MIN 204; MIN 74; MIN 206 and MIN 32 the restoration is dry using inert waste or imported inert materials. If this were to change to wet restoration or there was potential for wet working as part of the extraction scheme, DIO Safeguarding would need to be consulted.
Please note the remaining sites fall outside of the statutory safeguarding areas and we have no concerns regarding these allocations.
Please note the above comments are purely related to the DIO Statutory Safeguarding interests. I trust this adequately explains our position on this matter.

Submission Norfolk Minerals and Waste Local Plan Consultation
Thank you for consulting the Ministry of Defence (MOD) in relation to the above referenced consultation document.
DIO Safeguarding main concern when reviewing Mineral and Waste local plan, relates to the proposed site allocations and the restoration/aftercare scheme.
The county of Norfolk has several statutory safeguarding sites within its authority area, these being RAF Lakenheath, RAF Lakenheath, RAF Mildenhall and RAF Marham.
On reviewing the proposed mineral sites the following occupy statutory birdstrike safeguarding consultation zones for RAF Marham: MIN 19 & 205;76;77;40; SIL01 SIL02; AOS E &J.
Therefore, DIO Safeguarding is concerned with the development of open water bodies, the creation of wetland habitat, refuse and landfill sites. These types of development have the potential to attract large flocking bird species hazardous to aviation safety. Therefore, we would recommend dry restoration and dry phased working.
The following sites MIN 6; MIN 204; MIN 74; MIN 206 and MIN 32 the restoration is dry using inert waste or imported inert materials. If this were to change to wet restoration or there was potential for wet working as part of the extraction scheme, DIO Safeguarding would need to be consulted.
Please note the remaining sites fall outside of the statutory safeguarding areas and we have no concerns regarding these allocations.
Please note the above comments are purely related to the DIO Statutory Safeguarding interests. I trust this adequately explains our position on this matter.

The MOD previously commented on the Norfolk Minerals and Waste Local Plan in August 2018. However, based on safeguarding comments regarding birdstrike, the policy team submitted additional information to determine the viability of the proposed sites.
The sites identified as part of the Norfolk Minerals and Waste Local Plan occupy the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The MODs main concern regarding mineral schemes is the phased working, proposed restoration and aftercare of the site. As the creation of open water bodies in this area has the potential to increase birdstrike risk to aircraft operations.
Please note each planning application is assessed on their individual merits at present there is limited information for a full detailed assessment to be carried out. However, please see below the MODs comments based on the additional
information received on the 18/11/18:

MIN 19 & 205 Land north of the River Nar, Pentney
The site is approximately 6km north west of RAF Marham. The restoration plan for this site shows a series of lakes, which are deep and steep sided surrounded by wet woodland with reed fringes. The design also includes 2 proposed walkways consisting of grassy glades which lie above water level.
Therefore, the MOD would have no safeguarding concerns subject to open water being kept to a minimum; the lakes are designed to be less than 200mx200m with steep bank sides as per restoration plan. A robust Bird Hazard Management Plan (BHMP) to be approved by the MOD should be applied to manage the hazardous birds i.e. waterfowl, gulls, heron etc. and applied to the adjacent site if owned by the same company.

MIN 76 Land at West Field, Watlington Road, Tottenhill
The MOD have recently reviewed this planning consultation and submitted conditional response citing subject to a BHMP being implemented we have no safeguarding concerns as part of planning consent.

MIN 40 - Land East of Grandcourt Farm, East Winch
The MOD commented on this application and the proposed extension to Grandcourt Farm at planning stages. There is an existing BMP in place which includes the extension site. Therefore, the MOD stated no objection subject to the BMP being implemented as part of planning consent.

SIL 01 Land at Mintlyn South, Bawsey
This site is approximately 12.4km north by north west from RAF Marham, any proposed water bodies would need to be designed to the following principles:
 No islands- as they provide safe predator free environment for roosting and nesting birds
 The bank margins are planted with dense goose proof barrier of emergent vegetation (common reed), or fenced to prevent easy access between open water and nearby short grass areas.
 A BHMP to remove or treat any feral goose nests and eggs to prevent feral geese successfully breeding on site
The above is based on the information available at present.

SIL 02 Land at Shouldham and Marham
This site is approximately 4.8km north west from RAF Marham. The proposed extraction site is a considerable area which is planned to be restored with large areas of open water.
A development of this nature in such proximity to the aerodrome is of great concern to aircraft safety.
Even if the site were to be reduced in scale this would be of serious concern to the MOD. Therefore, we would object to this site based on current plans.

AOS E Land north of Shouldham
It is difficult to determine the risk of wet restoration in this location without any plans illustrating the extent and design of open water bodies.
The MOD have safeguarding concerns to the wet working and restoration of this site due to its potential to attract and support hazardous waterfowl closer within critical airspace. Therefore, further information would be required before a definitive response can be made.

AOS J Land east of Tottenhill
In line with my comments above wet working and restoration at this location would have the potential to attract and support hazardous waterfowl. The MOD is unable to determine the extent of our concerns without knowing the restoration scheme.

In summary, MIN 19, 205, 76 & 40 the MOD has no safeguarding concerns subject to the implementation of a robust Bird Hazard Management Plan approved by the MOD as part of any planning permission granted.

With regards to SIL 01 at present this site is of concern to the MOD. However, due
to its location depending on the nature and scale of the restoration should be manageable with the right restoration and a BHMP in place.

AOS E and AOS J the MOD has concerns and would require further information to determine whether the sites could be managed with design principles and a BMP.
Finally, SIL 02 the MOD object to this site being implemented on its current design and scale.

I trust this is clear however should you have any questions please do not hesitate to contact me.

The MOD previously commented on the Norfolk Minerals and Waste Local Plan in August 2018. However, based on safeguarding comments regarding birdstrike, the policy team submitted additional information to determine the viability of the proposed sites.
The sites identified as part of the Norfolk Minerals and Waste Local Plan occupy the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The MODs main concern regarding mineral schemes is the phased working, proposed restoration and aftercare of the site. As the creation of open water bodies in this area has the potential to increase birdstrike risk to aircraft operations.
Please note each planning application is assessed on their individual merits at present there is limited information for a full detailed assessment to be carried out. However, please see below the MODs comments based on the additional
information received on the 18/11/18:

MIN 19 & 205 Land north of the River Nar, Pentney
The site is approximately 6km north west of RAF Marham. The restoration plan for this site shows a series of lakes, which are deep and steep sided surrounded by wet woodland with reed fringes. The design also includes 2 proposed walkways consisting of grassy glades which lie above water level.
Therefore, the MOD would have no safeguarding concerns subject to open water being kept to a minimum; the lakes are designed to be less than 200mx200m with steep bank sides as per restoration plan. A robust Bird Hazard Management Plan (BHMP) to be approved by the MOD should be applied to manage the hazardous birds i.e. waterfowl, gulls, heron etc. and applied to the adjacent site if owned by the same company.

MIN 76 Land at West Field, Watlington Road, Tottenhill
The MOD have recently reviewed this planning consultation and submitted conditional response citing subject to a BHMP being implemented we have no safeguarding concerns as part of planning consent.

MIN 40 - Land East of Grandcourt Farm, East Winch
The MOD commented on this application and the proposed extension to Grandcourt Farm at planning stages. There is an existing BMP in place which includes the extension site. Therefore, the MOD stated no objection subject to the BMP being implemented as part of planning consent.

SIL 01 Land at Mintlyn South, Bawsey
This site is approximately 12.4km north by north west from RAF Marham, any proposed water bodies would need to be designed to the following principles:
 No islands- as they provide safe predator free environment for roosting and nesting birds
 The bank margins are planted with dense goose proof barrier of emergent vegetation (common reed), or fenced to prevent easy access between open water and nearby short grass areas.
 A BHMP to remove or treat any feral goose nests and eggs to prevent feral geese successfully breeding on site
The above is based on the information available at present.

SIL 02 Land at Shouldham and Marham
This site is approximately 4.8km north west from RAF Marham. The proposed extraction site is a considerable area which is planned to be restored with large areas of open water.
A development of this nature in such proximity to the aerodrome is of great concern to aircraft safety.
Even if the site were to be reduced in scale this would be of serious concern to the MOD. Therefore, we would object to this site based on current plans.

AOS E Land north of Shouldham
It is difficult to determine the risk of wet restoration in this location without any plans illustrating the extent and design of open water bodies.
The MOD have safeguarding concerns to the wet working and restoration of this site due to its potential to attract and support hazardous waterfowl closer within critical airspace. Therefore, further information would be required before a definitive response can be made.

AOS J Land east of Tottenhill
In line with my comments above wet working and restoration at this location would have the potential to attract and support hazardous waterfowl. The MOD is unable to determine the extent of our concerns without knowing the restoration scheme.

In summary, MIN 19, 205, 76 & 40 the MOD has no safeguarding concerns subject to the implementation of a robust Bird Hazard Management Plan approved by the MOD as part of any planning permission granted.

With regards to SIL 01 at present this site is of concern to the MOD. However, due
to its location depending on the nature and scale of the restoration should be manageable with the right restoration and a BHMP in place.

AOS E and AOS J the MOD has concerns and would require further information to determine whether the sites could be managed with design principles and a BMP.
Finally, SIL 02 the MOD object to this site being implemented on its current design and scale.

I trust this is clear however should you have any questions please do not hesitate to contact me.

The MOD previously commented on the Norfolk Minerals and Waste Local Plan in August 2018. However, based on safeguarding comments regarding birdstrike, the policy team submitted additional information to determine the viability of the proposed sites.
The sites identified as part of the Norfolk Minerals and Waste Local Plan occupy the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The MODs main concern regarding mineral schemes is the phased working, proposed restoration and aftercare of the site. As the creation of open water bodies in this area has the potential to increase birdstrike risk to aircraft operations.
Please note each planning application is assessed on their individual merits at present there is limited information for a full detailed assessment to be carried out. However, please see below the MODs comments based on the additional
information received on the 18/11/18:

MIN 19 & 205 Land north of the River Nar, Pentney
The site is approximately 6km north west of RAF Marham. The restoration plan for this site shows a series of lakes, which are deep and steep sided surrounded by wet woodland with reed fringes. The design also includes 2 proposed walkways consisting of grassy glades which lie above water level.
Therefore, the MOD would have no safeguarding concerns subject to open water being kept to a minimum; the lakes are designed to be less than 200mx200m with steep bank sides as per restoration plan. A robust Bird Hazard Management Plan (BHMP) to be approved by the MOD should be applied to manage the hazardous birds i.e. waterfowl, gulls, heron etc. and applied to the adjacent site if owned by the same company.

MIN 76 Land at West Field, Watlington Road, Tottenhill
The MOD have recently reviewed this planning consultation and submitted conditional response citing subject to a BHMP being implemented we have no safeguarding concerns as part of planning consent.

MIN 40 - Land East of Grandcourt Farm, East Winch
The MOD commented on this application and the proposed extension to Grandcourt Farm at planning stages. There is an existing BMP in place which includes the extension site. Therefore, the MOD stated no objection subject to the BMP being implemented as part of planning consent.

SIL 01 Land at Mintlyn South, Bawsey
This site is approximately 12.4km north by north west from RAF Marham, any proposed water bodies would need to be designed to the following principles:
 No islands- as they provide safe predator free environment for roosting and nesting birds
 The bank margins are planted with dense goose proof barrier of emergent vegetation (common reed), or fenced to prevent easy access between open water and nearby short grass areas.
 A BHMP to remove or treat any feral goose nests and eggs to prevent feral geese successfully breeding on site
The above is based on the information available at present.

SIL 02 Land at Shouldham and Marham
This site is approximately 4.8km north west from RAF Marham. The proposed extraction site is a considerable area which is planned to be restored with large areas of open water.
A development of this nature in such proximity to the aerodrome is of great concern to aircraft safety.
Even if the site were to be reduced in scale this would be of serious concern to the MOD. Therefore, we would object to this site based on current plans.

AOS E Land north of Shouldham
It is difficult to determine the risk of wet restoration in this location without any plans illustrating the extent and design of open water bodies.
The MOD have safeguarding concerns to the wet working and restoration of this site due to its potential to attract and support hazardous waterfowl closer within critical airspace. Therefore, further information would be required before a definitive response can be made.

AOS J Land east of Tottenhill
In line with my comments above wet working and restoration at this location would have the potential to attract and support hazardous waterfowl. The MOD is unable to determine the extent of our concerns without knowing the restoration scheme.

In summary, MIN 19, 205, 76 & 40 the MOD has no safeguarding concerns subject to the implementation of a robust Bird Hazard Management Plan approved by the MOD as part of any planning permission granted.

With regards to SIL 01 at present this site is of concern to the MOD. However, due
to its location depending on the nature and scale of the restoration should be manageable with the right restoration and a BHMP in place.

AOS E and AOS J the MOD has concerns and would require further information to determine whether the sites could be managed with design principles and a BMP.
Finally, SIL 02 the MOD object to this site being implemented on its current design and scale.

I trust this is clear however should you have any questions please do not hesitate to contact me.

The MOD previously commented on the Norfolk Minerals and Waste Local Plan in August 2018. However, based on safeguarding comments regarding birdstrike, the policy team submitted additional information to determine the viability of the proposed sites.
The sites identified as part of the Norfolk Minerals and Waste Local Plan occupy the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The MODs main concern regarding mineral schemes is the phased working, proposed restoration and aftercare of the site. As the creation of open water bodies in this area has the potential to increase birdstrike risk to aircraft operations.
Please note each planning application is assessed on their individual merits at present there is limited information for a full detailed assessment to be carried out. However, please see below the MODs comments based on the additional
information received on the 18/11/18:

MIN 19 & 205 Land north of the River Nar, Pentney
The site is approximately 6km north west of RAF Marham. The restoration plan for this site shows a series of lakes, which are deep and steep sided surrounded by wet woodland with reed fringes. The design also includes 2 proposed walkways consisting of grassy glades which lie above water level.
Therefore, the MOD would have no safeguarding concerns subject to open water being kept to a minimum; the lakes are designed to be less than 200mx200m with steep bank sides as per restoration plan. A robust Bird Hazard Management Plan (BHMP) to be approved by the MOD should be applied to manage the hazardous birds i.e. waterfowl, gulls, heron etc. and applied to the adjacent site if owned by the same company.

MIN 76 Land at West Field, Watlington Road, Tottenhill
The MOD have recently reviewed this planning consultation and submitted conditional response citing subject to a BHMP being implemented we have no safeguarding concerns as part of planning consent.

MIN 40 - Land East of Grandcourt Farm, East Winch
The MOD commented on this application and the proposed extension to Grandcourt Farm at planning stages. There is an existing BMP in place which includes the extension site. Therefore, the MOD stated no objection subject to the BMP being implemented as part of planning consent.

SIL 01 Land at Mintlyn South, Bawsey
This site is approximately 12.4km north by north west from RAF Marham, any proposed water bodies would need to be designed to the following principles:
 No islands- as they provide safe predator free environment for roosting and nesting birds
 The bank margins are planted with dense goose proof barrier of emergent vegetation (common reed), or fenced to prevent easy access between open water and nearby short grass areas.
 A BHMP to remove or treat any feral goose nests and eggs to prevent feral geese successfully breeding on site
The above is based on the information available at present.

SIL 02 Land at Shouldham and Marham
This site is approximately 4.8km north west from RAF Marham. The proposed extraction site is a considerable area which is planned to be restored with large areas of open water.
A development of this nature in such proximity to the aerodrome is of great concern to aircraft safety.
Even if the site were to be reduced in scale this would be of serious concern to the MOD. Therefore, we would object to this site based on current plans.

AOS E Land north of Shouldham
It is difficult to determine the risk of wet restoration in this location without any plans illustrating the extent and design of open water bodies.
The MOD have safeguarding concerns to the wet working and restoration of this site due to its potential to attract and support hazardous waterfowl closer within critical airspace. Therefore, further information would be required before a definitive response can be made.

AOS J Land east of Tottenhill
In line with my comments above wet working and restoration at this location would have the potential to attract and support hazardous waterfowl. The MOD is unable to determine the extent of our concerns without knowing the restoration scheme.

In summary, MIN 19, 205, 76 & 40 the MOD has no safeguarding concerns subject to the implementation of a robust Bird Hazard Management Plan approved by the MOD as part of any planning permission granted.

With regards to SIL 01 at present this site is of concern to the MOD. However, due
to its location depending on the nature and scale of the restoration should be manageable with the right restoration and a BHMP in place.

AOS E and AOS J the MOD has concerns and would require further information to determine whether the sites could be managed with design principles and a BMP.
Finally, SIL 02 the MOD object to this site being implemented on its current design and scale.

I trust this is clear however should you have any questions please do not hesitate to contact me.

The MOD previously commented on the Norfolk Minerals and Waste Local Plan in August 2018. However, based on safeguarding comments regarding birdstrike, the policy team submitted additional information to determine the viability of the proposed sites.
The sites identified as part of the Norfolk Minerals and Waste Local Plan occupy the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The MODs main concern regarding mineral schemes is the phased working, proposed restoration and aftercare of the site. As the creation of open water bodies in this area has the potential to increase birdstrike risk to aircraft operations.
Please note each planning application is assessed on their individual merits at present there is limited information for a full detailed assessment to be carried out. However, please see below the MODs comments based on the additional
information received on the 18/11/18:

MIN 19 & 205 Land north of the River Nar, Pentney
The site is approximately 6km north west of RAF Marham. The restoration plan for this site shows a series of lakes, which are deep and steep sided surrounded by wet woodland with reed fringes. The design also includes 2 proposed walkways consisting of grassy glades which lie above water level.
Therefore, the MOD would have no safeguarding concerns subject to open water being kept to a minimum; the lakes are designed to be less than 200mx200m with steep bank sides as per restoration plan. A robust Bird Hazard Management Plan (BHMP) to be approved by the MOD should be applied to manage the hazardous birds i.e. waterfowl, gulls, heron etc. and applied to the adjacent site if owned by the same company.

MIN 76 Land at West Field, Watlington Road, Tottenhill
The MOD have recently reviewed this planning consultation and submitted conditional response citing subject to a BHMP being implemented we have no safeguarding concerns as part of planning consent.

MIN 40 - Land East of Grandcourt Farm, East Winch
The MOD commented on this application and the proposed extension to Grandcourt Farm at planning stages. There is an existing BMP in place which includes the extension site. Therefore, the MOD stated no objection subject to the BMP being implemented as part of planning consent.

SIL 01 Land at Mintlyn South, Bawsey
This site is approximately 12.4km north by north west from RAF Marham, any proposed water bodies would need to be designed to the following principles:
 No islands- as they provide safe predator free environment for roosting and nesting birds
 The bank margins are planted with dense goose proof barrier of emergent vegetation (common reed), or fenced to prevent easy access between open water and nearby short grass areas.
 A BHMP to remove or treat any feral goose nests and eggs to prevent feral geese successfully breeding on site
The above is based on the information available at present.

SIL 02 Land at Shouldham and Marham
This site is approximately 4.8km north west from RAF Marham. The proposed extraction site is a considerable area which is planned to be restored with large areas of open water.
A development of this nature in such proximity to the aerodrome is of great concern to aircraft safety.
Even if the site were to be reduced in scale this would be of serious concern to the MOD. Therefore, we would object to this site based on current plans.

AOS E Land north of Shouldham
It is difficult to determine the risk of wet restoration in this location without any plans illustrating the extent and design of open water bodies.
The MOD have safeguarding concerns to the wet working and restoration of this site due to its potential to attract and support hazardous waterfowl closer within critical airspace. Therefore, further information would be required before a definitive response can be made.

AOS J Land east of Tottenhill
In line with my comments above wet working and restoration at this location would have the potential to attract and support hazardous waterfowl. The MOD is unable to determine the extent of our concerns without knowing the restoration scheme.

In summary, MIN 19, 205, 76 & 40 the MOD has no safeguarding concerns subject to the implementation of a robust Bird Hazard Management Plan approved by the MOD as part of any planning permission granted.

With regards to SIL 01 at present this site is of concern to the MOD. However, due
to its location depending on the nature and scale of the restoration should be manageable with the right restoration and a BHMP in place.

AOS E and AOS J the MOD has concerns and would require further information to determine whether the sites could be managed with design principles and a BMP.
Finally, SIL 02 the MOD object to this site being implemented on its current design and scale.

I trust this is clear however should you have any questions please do not hesitate to contact me.

The MOD previously commented on the Norfolk Minerals and Waste Local Plan in August 2018. However, based on safeguarding comments regarding birdstrike, the policy team submitted additional information to determine the viability of the proposed sites.
The sites identified as part of the Norfolk Minerals and Waste Local Plan occupy the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The MODs main concern regarding mineral schemes is the phased working, proposed restoration and aftercare of the site. As the creation of open water bodies in this area has the potential to increase birdstrike risk to aircraft operations.
Please note each planning application is assessed on their individual merits at present there is limited information for a full detailed assessment to be carried out. However, please see below the MODs comments based on the additional
information received on the 18/11/18:

MIN 19 & 205 Land north of the River Nar, Pentney
The site is approximately 6km north west of RAF Marham. The restoration plan for this site shows a series of lakes, which are deep and steep sided surrounded by wet woodland with reed fringes. The design also includes 2 proposed walkways consisting of grassy glades which lie above water level.
Therefore, the MOD would have no safeguarding concerns subject to open water being kept to a minimum; the lakes are designed to be less than 200mx200m with steep bank sides as per restoration plan. A robust Bird Hazard Management Plan (BHMP) to be approved by the MOD should be applied to manage the hazardous birds i.e. waterfowl, gulls, heron etc. and applied to the adjacent site if owned by the same company.

MIN 76 Land at West Field, Watlington Road, Tottenhill
The MOD have recently reviewed this planning consultation and submitted conditional response citing subject to a BHMP being implemented we have no safeguarding concerns as part of planning consent.

MIN 40 - Land East of Grandcourt Farm, East Winch
The MOD commented on this application and the proposed extension to Grandcourt Farm at planning stages. There is an existing BMP in place which includes the extension site. Therefore, the MOD stated no objection subject to the BMP being implemented as part of planning consent.

SIL 01 Land at Mintlyn South, Bawsey
This site is approximately 12.4km north by north west from RAF Marham, any proposed water bodies would need to be designed to the following principles:
 No islands- as they provide safe predator free environment for roosting and nesting birds
 The bank margins are planted with dense goose proof barrier of emergent vegetation (common reed), or fenced to prevent easy access between open water and nearby short grass areas.
 A BHMP to remove or treat any feral goose nests and eggs to prevent feral geese successfully breeding on site
The above is based on the information available at present.

SIL 02 Land at Shouldham and Marham
This site is approximately 4.8km north west from RAF Marham. The proposed extraction site is a considerable area which is planned to be restored with large areas of open water.
A development of this nature in such proximity to the aerodrome is of great concern to aircraft safety.
Even if the site were to be reduced in scale this would be of serious concern to the MOD. Therefore, we would object to this site based on current plans.

AOS E Land north of Shouldham
It is difficult to determine the risk of wet restoration in this location without any plans illustrating the extent and design of open water bodies.
The MOD have safeguarding concerns to the wet working and restoration of this site due to its potential to attract and support hazardous waterfowl closer within critical airspace. Therefore, further information would be required before a definitive response can be made.

AOS J Land east of Tottenhill
In line with my comments above wet working and restoration at this location would have the potential to attract and support hazardous waterfowl. The MOD is unable to determine the extent of our concerns without knowing the restoration scheme.

In summary, MIN 19, 205, 76 & 40 the MOD has no safeguarding concerns subject to the implementation of a robust Bird Hazard Management Plan approved by the MOD as part of any planning permission granted.

With regards to SIL 01 at present this site is of concern to the MOD. However, due
to its location depending on the nature and scale of the restoration should be manageable with the right restoration and a BHMP in place.

AOS E and AOS J the MOD has concerns and would require further information to determine whether the sites could be managed with design principles and a BMP.
Finally, SIL 02 the MOD object to this site being implemented on its current design and scale.

I trust this is clear however should you have any questions please do not hesitate to contact me.

The MOD previously commented on the Norfolk Minerals and Waste Local Plan in August 2018. However, based on safeguarding comments regarding birdstrike, the policy team submitted additional information to determine the viability of the proposed sites.
The sites identified as part of the Norfolk Minerals and Waste Local Plan occupy the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The MODs main concern regarding mineral schemes is the phased working, proposed restoration and aftercare of the site. As the creation of open water bodies in this area has the potential to increase birdstrike risk to aircraft operations.
Please note each planning application is assessed on their individual merits at present there is limited information for a full detailed assessment to be carried out. However, please see below the MODs comments based on the additional
information received on the 18/11/18:

MIN 19 & 205 Land north of the River Nar, Pentney
The site is approximately 6km north west of RAF Marham. The restoration plan for this site shows a series of lakes, which are deep and steep sided surrounded by wet woodland with reed fringes. The design also includes 2 proposed walkways consisting of grassy glades which lie above water level.
Therefore, the MOD would have no safeguarding concerns subject to open water being kept to a minimum; the lakes are designed to be less than 200mx200m with steep bank sides as per restoration plan. A robust Bird Hazard Management Plan (BHMP) to be approved by the MOD should be applied to manage the hazardous birds i.e. waterfowl, gulls, heron etc. and applied to the adjacent site if owned by the same company.

MIN 76 Land at West Field, Watlington Road, Tottenhill
The MOD have recently reviewed this planning consultation and submitted conditional response citing subject to a BHMP being implemented we have no safeguarding concerns as part of planning consent.

MIN 40 - Land East of Grandcourt Farm, East Winch
The MOD commented on this application and the proposed extension to Grandcourt Farm at planning stages. There is an existing BMP in place which includes the extension site. Therefore, the MOD stated no objection subject to the BMP being implemented as part of planning consent.

SIL 01 Land at Mintlyn South, Bawsey
This site is approximately 12.4km north by north west from RAF Marham, any proposed water bodies would need to be designed to the following principles:
 No islands- as they provide safe predator free environment for roosting and nesting birds
 The bank margins are planted with dense goose proof barrier of emergent vegetation (common reed), or fenced to prevent easy access between open water and nearby short grass areas.
 A BHMP to remove or treat any feral goose nests and eggs to prevent feral geese successfully breeding on site
The above is based on the information available at present.

SIL 02 Land at Shouldham and Marham
This site is approximately 4.8km north west from RAF Marham. The proposed extraction site is a considerable area which is planned to be restored with large areas of open water.
A development of this nature in such proximity to the aerodrome is of great concern to aircraft safety.
Even if the site were to be reduced in scale this would be of serious concern to the MOD. Therefore, we would object to this site based on current plans.

AOS E Land north of Shouldham
It is difficult to determine the risk of wet restoration in this location without any plans illustrating the extent and design of open water bodies.
The MOD have safeguarding concerns to the wet working and restoration of this site due to its potential to attract and support hazardous waterfowl closer within critical airspace. Therefore, further information would be required before a definitive response can be made.

AOS J Land east of Tottenhill
In line with my comments above wet working and restoration at this location would have the potential to attract and support hazardous waterfowl. The MOD is unable to determine the extent of our concerns without knowing the restoration scheme.

In summary, MIN 19, 205, 76 & 40 the MOD has no safeguarding concerns subject to the implementation of a robust Bird Hazard Management Plan approved by the MOD as part of any planning permission granted.

With regards to SIL 01 at present this site is of concern to the MOD. However, due
to its location depending on the nature and scale of the restoration should be manageable with the right restoration and a BHMP in place.

AOS E and AOS J the MOD has concerns and would require further information to determine whether the sites could be managed with design principles and a BMP.
Finally, SIL 02 the MOD object to this site being implemented on its current design and scale.

I trust this is clear however should you have any questions please do not hesitate to contact me.