Initial Consultation document

Support

Representation ID: 92004

Received: 08/08/2018

Respondent: Longwater Gravel Co. Ltd.

Agent: Small Fish

We are writing on behalf of mineral operator Longwater Gravel Co. Ltd. in relation to site MIN 64.

The Council has come to the initial conclusion that the site is considered to be suitable for allocation and Longwater Gravel Co. Ltd. strongly supports the Council's conclusion that site MIN 64 is suitable for development. The site offers a number of benefits in terms of its locational aspects, including:
* Being extremely well-related to the transport network and able to use the existing quarry access onto the B1354;
* Being located close to the major growth area, the Norwich Growth Triangle, as well as the market towns of Aylsham and North Walsham where further housing and employment growth is allocated;
* Being remote from any international, national or local biodiversity designations;
* Not jeopardising any of the best and most versatile agricultural lands;
* Being relatively far from sensate residential receptors, limiting any amenity impacts;
* Being outside of any landscape designations; and
* Its location outside of any flood risk zones and able to be worked dry above the water table.

In line with the Council's recommendations resulting from the Site Assessment of MIN 64, the Company can confirm that it will, when submitting a planning application for minerals development on this site, provide:
* a detailed screening scheme which will include mitigation of views from nearby properties, and surrounding roads;
* noise and dust assessments and a programme of mitigation measures to deal appropriately with any amenity impacts;
* a Heritage Statement to identify heritage assets and their settings, which will assess the potential for impacts and identify appropriate mitigation measures (if needed);
* a proportionate archaeological assessment in consultation with Norfolk County Council, to determine whether any mitigation measures are needed;
* a hydrogeological assessment to inform the maximum depth of working above the water table; and
* a detailed restoration scheme, which will include any opportunities identified during working for geodiversity assets to be studied and an open face to be included for future scientific study and arable land with margins to allow for long-term screening and biodiversity gains.

Site MIN 64 appears to be fully compliant with national planning policy as well as the policies proposed in the Minerals and Waste Local Plan Review: Initial Consultation, as well as the recently revised National Planning Policy Framework (July 2018). On this basis and with consideration for the above, the Company encourages the Council to allocate the site for minerals development within the Minerals and Waste Local Plan.

Support

Representation ID: 92005

Received: 08/08/2018

Respondent: Longwater Gravel Co. Ltd.

Agent: Small Fish

We are writing on behalf of mineral operator Longwater Gravel Company Ltd. in relation to site MIN 45 and in response to the consultation on the Norfolk Minerals and Waste Local Plan Review "Initial Consultation" in summer 2018.

As you will be aware, the Council has come to the initial conclusion that the site is considered to be unsuitable for allocation because:
* It is considered unlikely that a proposal largely on an ancient woodland site, for the extraction of sand and gravel, would meet the benefit/loss test set out in the NPPF.
* It has not been proved that soil translocation would have no detrimental effects to the quality of the PAWS, or that this would aid the proposal in meeting the benefit/loss test. Natural England in 2012 stated that "ancient woodland as a system cannot be moved", and the Joint Nature Conservation Committee states that the uncertainty of habitat translocation means that it should be viewed only as a measure of last resort in partial compensation for damaging developments."

Proposed Policy MW 2 states that:
"Proposals for minerals development and/or waste management development will be permitted where it can be demonstrated that the development would not have an unacceptable impact (including cumulative impact in combination with other existing or permitted development) on:
... k. The natural and geological environment (including internationally, nationally or locally designated sites and irreplaceable habitats);
... Where appropriate, enhancement of the environment would be sought, including, but not exclusively, the enhancement of the Public Rights of Way Network, creation of recreation opportunities and enhancement of the natural, historic and built environment and surrounding landscapes."

The supporting text to Policy MW 2 states further that:
"Minerals or waste management development which impacts on Sites of Special Scientific Interest, National Nature Reserves and irreplaceable priority habitats such as ancient woodland and aged or veteran trees will only be permitted where the impact does not conflict with the wildlife or geological conservation interests of that asset."

The proposal for MIN 45 is compliant with this proposed policy. Although the site encompasses an area of a planted ancient woodland site (PAWS), in accordance with Policy MW 2 the proposal will not conflict with the wildlife or geological conservation interest of the ancient woodland asset. Furthermore, the proposed minerals development will lead to an overall environmental enhancement. These aspects of compliance of the proposal to extract sand and gravel from site MIN 45 are explained in more detail throughout this representation.

Since the publication of the consultation document, the NPPF has been revised and the Council will be aware that it continues to provide protection to ancient woodland and veteran trees as an "irreplaceable habitat" unless there are wholly exceptional reasons and a suitable compensation strategy can be agreed (Paragraph 175c). We believe 'wholly exceptional circumstances' exist in this particular case and that a suitable compensation strategy can be agreed. Paragraph 205 of the revised NPPF supports this and requires that "great weight" is given to the benefits of minerals extraction.

Firstly, as the Council will be aware, MIN 45 consists predominantly of a conifer plantation planted in the late 1960s/early 1970s, which has likely undergone at least two conifer rotations. This is significant in terms of the ecological value of the area. A survey of flora completed by Norfolk Wildlife Services shows very little flora associated with ancient woodland and it is thought that over 100 years of coniferous cover on the site is the reason for this. MIN 45 currently exists solely for providing lumber on a commercial basis, not for providing biodiversity value. Most, if not all, of the existing trees within MIN 45 will eventually be cut down, regardless of any proposals for minerals extraction, and will likely be replaced with more conifers, thus limiting the long-term habitat potential of this site.

It is worth noting that site MIN 115 shares the same characteristics as MIN 45 in that they are both conifer plantations, although MIN 115 has not been designated as a plantation on ancient woodland site. MIN 115 has been found suitable for allocation, despite providing the same habitat as MIN 45.

It is also worth pointing out that the revised National Planning Policy Framework (July 2018) definition of "irreplaceable habitat" is:
"Habitats which would be technically very difficult (or take a very significant time) to restore, recreate or replace once destroyed, taking into account their age, uniqueness, species diversity or rarity. They include ancient woodland, ancient and veteran trees, blanket bog, limestone pavement, sand dunes, salt marsh and lowland fen."

Ancient woodland designations are based on historic mapping which indicates whether the site has been continuously wooded, not on the quality of the habitat at the time of designation. In this respect, it is not a biodiversity designation.

The relatively young commercial plantation woodland at MIN 45 should not be considered an irreplaceable habitat in the context of Paragraph 175c of the NPPF, as all of the trees lost during the minerals extraction process (the vast majority of which are conifers) will be replaced with native species broadleaved trees. As the site measures around 22 hectares, this will result in a massive gain in terms of biodiversity and landscape. Therefore, with reference to the definition of irreplaceable habitat, the site would not "be technically very difficult to restore, recreate or replace" and therefore should not be considered an irreplaceable habitat.

Mineral extraction is temporary and cannot be compared to other developments which would lead to the permanent loss of ancient woodland such as buildings, roads, etc. constructed on ancient woodland sites. If the final stage of a mineral extraction development is to replant the woodland, using the same soils in exactly the same location, then arguably there is no loss. The restoration of MIN 45, which will be to replant the woodland with native broadleaved trees will provide a significantly improved habitat for local biodiversity. Whilst there may be some adverse effects in the short-term in terms of habitat loss during the extraction of the minerals, the proposal and its restoration plan will provide a long-term benefit to biodiversity.

In this particular case, the circumstances of the proposal are wholly exceptional and the restoration of the site to a native, high-quality broadleaved woodland habitat should be considered a long-term public benefit when coupled with the economic benefits of the minerals extraction, which would more than adequately replace and compensate for the loss of a low-quality conifer woodland habitat.

In addition to the biodiversity benefit, MIN 45 also offers the following environmental, social and economic benefits:
* Existing minerals site extension, operated by a reputable local minerals operator
* Suitable existing highways access
* Retention of jobs at this facility for an additional 7 years
* Well-located to facilitate growth in Fakenham, an area designed for significant growth in the West Norfolk Local Plan
* Remote from settlements and housing, limiting amenity impacts such as noise, dust and vibration
* Not in an area of flood risk
* No impact on water resources
* No impact on landscape designations, such as AONB, Heritage Coast, National Parks or Core River Valleys
* No impacts likely on any international, national or locally designated nature conservation sites, such as Ramsar, SPA, SAC, SSSI, NNR, LNR, CGS or CWS
* No impacts likely on any designated or known non-designated heritage assets, including Listed Buildings, Scheduled Monuments, Historic Parks or Conservation Areas
* This site is not within or near to an AQMA
* Restoration proposal would act as a carbon sink, absorbing CO2 emissions

Therefore, we urge you to reconsider the Council's initial conclusion that MIN 45 is unsuitable for allocation, as the single short-term impact of the loss of a relatively poor-quality habitat needs to be sensibly balanced against (and will be outweighed by) the numerous benefits the site would provide in environmental, social and economic terms.

Summary: We strongly object to the conclusion that site MIN 45 is not suitable for allocation. The existing conifer plantation is not a high quality or irreplaceable habitat and the proposed restoration scheme will result in a significant habitat improvement and environmental gain. The circumstances surrounding this site and the proposed development are wholly exceptional and the site should be considered suitable for sand and gravel extraction and allocated.

Support

Representation ID: 92023

Received: 09/08/2018

Respondent: Longwater Gravel Co. Ltd.

Agent: Small Fish

Longwater Gravel Ltd would like to confirm that it does agree with the initial conclusion to allocate Min13/Min51. In support of this opinion, Longwater Gravel would like to draw attention to the following points in relation to the emerging policies.

Policy MP2: Spatial Strategy for mineral extraction
Specific sites for sand and gravel or carstone extraction should be located within 10 miles of one of Norfolk's urban areas or main towns (detailed in the supporting text) and/or be well-related to one of Norfolk's urban areas or main towns via appropriate transport infrastructure - Dereham is classed as a main town and the site is connected to Dereham via the Fakenham Road B1146 HGV route, with Dereham being only 4.5km away. Furthermore, Fakenham is only 11km away via the B1146 and this is also a main town.

Policy MP5: Core River Valleys
The Sites are not in a core river valley.

Policy MP6: Cumulative impacts and phasing of workings
There has been concern in the past that the cumulative impacts of operating Min 13 and Min 51 at the same time could be unacceptable.

Policy MP6 makes it clear it is down to the applicant to, "demonstrate that the adverse cumulative impacts can be adequately mitigated" as part of a future planning application. Longwater Gravel is confident that this can be demonstrated. Combined, or cumulatively, the estimated extraction rate will be 70,000 tonnes per annum. This low rate of extraction has been chosen with a view to minimising any cumulative impact. For example, the low extraction rate of 70,000 tonnes generates only 10 HGV out movements per day between the sites, which is around one per hour. As these will almost immediately join the B1146 HGV route which carries a large volume of traffic, the increase is unlikely to be noticeable. Other cumulative impacts of the sites will be assessed as the application is development, such as through the dust and noise assessments.

It should be noted that the extraction rate chosen is lower than the extraction rate of many other potential sites; Min 12 (80,000), Min 35 (80,000) Min 201 (200,000 to 250,000), Min 202 (140,000), Min 37 (85,000), Min 65 (200,000), Min 96 (150,000), Min 38 (85,000 to 120,000), Min 06 (80,000), Min 45 (100,000) etc. Compared to these single sites, the cumulative impacts of Min 13 and Min 51 will be relatively modest.


This acceptability will be demonstrated by the future planning application.

Policy MP7: Progressive working, restoration and after-use and Policy MP8: Aftercare
The site is proposed to be restored at a lower level and returned to arable agricultural. Due to the expected depth of extraction, it is likely that restoration to arable will require the use of imported inert material to provide a suitable profile. Lagoons are likely to be retained as ponds with planting to create wet woodland habitat. Hedgerow interspersed with oaks will be planted along the northern boundary alongside Rawhall Lane. There should therefore be some longer term ecological benefits. The application will be accompanied by an after-care plan.

Policy MW2: Development Management Criteria
The sites are in compliance with emerging Policy MW2: Development Management Criteria. For ease of reference, these criteria are set out below with comments against each one.
a. Local amenity and health (including noise levels, odour, air quality, dust, litter, light pollution and vibration) - There should be no unacceptable amenity impacts given the distances to the nearest properties. Longwater Gravel will however, prepare both dust and noise assessments and undertake any proposed mitigation measures as part of a future planning application.
b. The quality of surface waterbodies and groundwater, with particular regard to preventing the deterioration of their existing status, and the quantity of water for resource purposes within water bodies - There will be no impact on hydrogeology or water resources as it will be worked dry. There will be no impact on watercourses such as the Blackwater because of distances and drainage. The minerals will be processed on site and so the sand and gravel to be processed will not be transported across the nearby watercourses.
c. The capacity of existing drainage systems - The site is not in an Internal Drainage Board area.
d. Pluvial and fluvial flood risk - There are no concerning flood risk issues given the land use proposed.
e. The best and most versatile agricultural land - Being Grade 3, the land is not the best and most versatile.
f. Aircraft safety due to the risk of bird strike and/or building height and position - The site is not within an aerodrome safeguarding zone.
g. The safety and capacity of the road and any other transport network - Highway access from the site should be satisfactory and an appropriate financial contribution to the B1146 Fakenham Road/Rawhall Lane junction improvements will be made if required to make the proposal acceptable in planning terms.
h. The appearance, quality and character of the landscape, countryside and visual environment and any local features that contribute to its local distinctiveness - The site is not in or near any landscape designations. The site is fairly flat and would be relatively easy to screen from views from surrounding roads and properties. The site contains interesting landscape features; the internal hedgerow oaks and the block of woodland and rough grass lie within the centre of the site are notable features in this open landscape and these will be protected by a the working scheme. A low level restoration scheme to arable agriculture with appropriate wide field margins and additional woodland should be acceptable in landscape terms and will result in a landscape gain.
i. Public Open Space, the definitive Public Rights of Way network and outdoor recreation facilities - There will be no impact on any of these assets.
j. Land stability - There are no issues regarding land stability.
k. The natural and geological environment (including internationally, nationally or locally designated sites and irreplaceable habitats) - Nature conservations designations will not be affected, especially given the stand-off distances and the quarry being worked dry. Restoration will be back to agricultural use, although this will include ensuring a long-term ecological gain. Lagoons will be retained as ponds with planting to create wet woodland habitat and hedgerow interspersed with oaks will be planted along the northern boundary alongside Rawhall Lane. Additional woodland will also be provided. Potential impacts on geodiversity will be assessed and appropriate mitigation identified as part of any future application. The application is likely to propose retaining some open faces for scientific study during the operational stages, and potentially after restoration providing this does not detract from the character of the area. Longwater Gravel will suggest a 'watching brief' is used during the extraction phase in case features of potential geodiversity interest are uncovered.
l. The historic environment, including heritage and archaeological assets and their settings - There should be no unacceptable impact on any of the heritage assets in the surrounding area, but Longwater Gravel will ensure that the planning application is accompanied by a Heritage Statement which will assess the potential for impacts and identify appropriate mitigation measures if required. There is the potential that unknown archaeology exists on the site and an assessment of the significance of archaeological deposits will be carried out at the planning application stage. It is recognised that the archaeology assessment may initially be desk-based but may need to be followed up with field surveys and trial-trenching.
m. The character and quality of the area, in which the development is situated, through poor design - Long term the character of the area will be retained if not enhanced through a high quality restoration scheme. In the short term some screening will likely be required during working, although key features that add to the character of the area such as the hedgerow oaks and the block of woodland will be protected by the working scheme.

Policy MW3: Transport
The sites are in compliance with emerging Policy MW3: Transport. For ease of reference, these criteria are set out below with comments against each one.
All proposals for minerals development or waste management facilities must assess and consider positively the potential for non-HGV transportation of materials to and from the facilities, principally by rail or water - this potential will be assessed, but given the absence of such facilities nearby such as rail sidings, the current assumption is that this will be unlikely.
a) Unacceptable risks to the safety of road users and pedestrians - The proposed highway access into the sites using Rawhall Lane is considered to be suitable by the Highway Authority and an appropriate financial contribution to the B1146 Fakenham Road/Rawhall Lane junction improvements will be made if required to make the proposal acceptable in planning terms.
b) Unacceptable impacts on the capacity and/or efficiency of the highway network (including the trunk road network). There are no capacity issues on the local road network.
c) Unacceptable impacts on air quality (particularly in relation to any potential breaches of National Air Quality Objectives and impacts on any Air Quality Management Areas) - The site is not in or near an Area Quality Management Area.
d) Unacceptable physical impacts on the highway network (e.g. road or kerbside damage) - The Fakenham Road is a designated lorry route and so suitable for HGV traffic. The short route to the Fakenham Road is a metaled adopted road and is wide enough for two-HGVs to pass and a new site access junction with Rawhall Lane will be created in accordance with design standards.
Any future planning application will be accompanied by either a Transport Statement or Transport Assessment, this being agreed with the Highway Authority in advance. This will show that:
* Suitable highway access and egress on Rawhall Lane can be achieved in accordance with published highway design guidance;
* That there is a short and suitable route to the nearest major road, this being the Fakenham Road and Longwater Gravel is content that this will be captured in a Routing Agreement if required;
* The application has considered the needs and safety of other road users, including cyclists, horse riders and pedestrians; and
* Appropriate and realistic measures to reduce car travel to the site by workers and visitors will be implemented.

Policy MW5: The Brecks Protected Habitats and Species
The sites are not in the Special Protection Area SPA or the Stone Curlew buffer zone

Policy MW6: Agricultural soils
The soil is Grade 3. It is not known at the moment whether this is Grade 3a or 3b. This will be determined during the development of a future planning application. If it is Grade 3a then a suitable soil handling management plan will be developed as part of the application. Restoration will be to agricultural land and so there will, in the long-term, be no loss to agriculture.

Summary: The combined site is in a good location for mineral extraction, being close to appropriate transport infrastructure and main towns. There appear to be few if any constraints, such as amenity or nature conservation designations, although impacts will be assessed where appropriate, such as through noise and dust assessments. The low extraction rate should make any cumulative impacts acceptable, although this will also be thoroughly assessed during the application. In addition to the benefit of extracting sand and gravel to support the construction sector, there will be additional ecological and landscape gains upon restoration.

Support

Representation ID: 92024

Received: 09/08/2018

Respondent: Longwater Gravel Co. Ltd.

Summary: Longwater Gravel is a small scale quarry operator and our proposed new quarry at MIN51/13 is necessary to meet the needs of our growing customer base in the Dereham area. The quarry will annually produce 70,000 tonnes and employ 10 people. We have already commenced work to secure an abstraction licence from the Environment Agency and we are fully committed to submitting an application for planning permission which will meet all of the requirements set out in M&WLP and MIN 51/13 within the next two years.

I write to confirm that Longwater Gravel agree with and support Norfolk County Council's initial conclusion to allocate MIN 51 and MIN 13.

Longwater Gravel Company is a small scale quarry operator which specialises in small deliveries of sand and gravel to a customer base which includes local builders, groundworkers and the general public. We also supply sand and gravel to a number of small volume readymixed concrete producers.

The proposal for Longwater Gravel to develop and operate a small, low volume quarry at MIN 51/13 is driven by the need for us to further support our growing customer base in and around Dereham and in the area to the west of Norwich. The quarry, if granted planning permission, would directly employ 4 full time staff and indirectly employ a further 6. We plan to produce around 70,000 tonnes per year, the majority of which would be transported by our fleet of small delivery vehicles and a small number of HGV's. Access to the quarry would be via Rawhall Lane through a new entrance located on the north east boundary. The main operations area, where the gravel washing plant, loading areas, weighbridge, etc. will be sited, would be located in the southwest corner of MIN 13. Phased working and restoration of the quarry would commence in MIN 13 and move in a west-east direction towards Bilney Road. Once all reserves in MIN 13 have been exhausted, extraction and restoration operations will commence in MIN 51, again working in a west-east direction with the operations area remaining located in MIN 13. Soils which are stripped to enable access to the sand and gravel would be stored in grassed bunds along the northern and eastern margins which would assist in screening views of the operations area. On completion of sand and gravel extraction, the land would be restored to agricultural use at a lower level and to achieve this a small quantity of material such as soil may need to be imported to assist with constructing an acceptable restoration profile. The overall timescale to complete extraction and restoration from MIN 51/13 would be around 16 years.

We have already commenced work on the development of a quarry at MIN 51/13 and to date this work includes the drafting of legal agreements with landowners and negotiation with the Environment Agency to secure an abstraction licence for water for gravel washing. The Environment Agency has now issued a permit to Longwater Gravel to install and test a new borehole at the site which will provide data to determine if an abstraction licence can be issued. If we can secure an abstraction licence, then work will immediately commence on a planning application which will fully comply with the requirements as set out in MIN 51/13.

We have asked Small Fish Consultants to assess the site and our proposals against the emerging Minerals and Waste Local Plan and they will comment separately.

Support

Representation ID: 92027

Received: 09/08/2018

Respondent: Longwater Gravel Co. Ltd.

We write to inform you that Longwater Gravel disagrees with the initial conclusion in respect of MIN 45 and would urge Norfolk County Council to reconsider its proposal not to allocate the north extension at Coxford Abbey Quarry. Norfolk County Council's adopted Minerals Site Specific Allocations Development Plan Document (Minerals SSA DPD), currently allocates the remaining minerals in the central area of Coxford Abbey Quarry, along with two extension areas to the east and south along with the north extension which is proposed to be removed. Longwater Gravel remains committed to extraction from the north extension with restoration to native woodland as it was understood that Norfolk County Council, by virtue of the allocation in the adopted Minerals SSA DPD and from informal discussion with planning officers in April 2015, that when the timing was right, i.e. when the permitted reserves at Coxford Abbey Quarry were almost exhausted, a planning application could then be submitted.

You will remember that during the Minerals SSA DPD consultation period (2008-2012), Longwater Gravel was preparing a planning application for the same area as that which is currently allocated along with an additional extension area to the west. Initial consultation drafts of the Minerals SSA DPD published in October 2009, May 2011 and February 2012 indicated that the plantation on ancient woodland site in the north extension would be included in the allocation, however in late 2012 and following advice from Norfolk County Council's ecological and landscape officers, changes were made to policy MIN 45 which ostensibly removed the north extension from the allocation. Fearing that the inclusion of the north extension in the planning application would result in a refusal of planning permission, Longwater Gravel took the decision to delete the north extension and submitted a planning application which only included the central area, along with extensions to the east, west and south.

You will also remember that during the independent examination of the Minerals SSA DPD held in March 2013, the Planning Inspector, Mr Andrew Freeman BSc (Hons) DipTP DipEM FRTPI FIHT MIEnvSc, directed Norfolk County Council to include the north extension within policy MIN 45. Unfortunately by this time the planning application for Coxford Abbey Quarry had already been submitted and it was now too late to withdraw and revise it to include the north extension. Shortly after planning permission was granted in March 2014, discussion with Norfolk County Council development control officers about the situation led to the formal submission of a request for a screening/scoping opinion for mineral extraction from the north extension, the aim being to resolve the situation by applying for planning permission for the area which had been deleted. The screening/scoping opinion was received in July 2014, NCC reference PP/C/2/2014/2007, and Longwater Gravel commenced work on the development of the application, closely following the requirements of the now adopted Policy MIN 45. At a meeting in April 2015, Longwater Gravel was advised by Norfolk County Council planning officers not to submit the application for planning permission for the north extension as it would likely result in a refusal, due to the fact that sufficient minerals were now permitted at Coxford Abbey Quarry and other sites in Norfolk and also because it was considered unlikely that the north extension could be worked within the adopted Minerals SSA DPD period (2010-2026). Longwater Gravel duly accepted and followed this advice and the planning application for the north extension was not submitted. It has therefore come as an unwelcome surprise that having reached an understanding with planning officers about the timing of an application, Norfolk County Council are now proposing to remove MIN 45 from the Minerals and Waste Sites Development Plan.

Whilst the presence of the PAWS is acknowledged, Longwater Gravel would not insist that Norfolk County Council allocate MIN 45 if the woodland was deemed to be of significant ecological or historic importance or indeed if it was an established native broadleaved woodland. It should be noted that a substantial proven sand and gravel reserve actually lies immediately to the north of the proposed MIN 45 extraction area, the majority of which is outside of the area designated as a PAWS, but as this already contains a number of mature broadleaved trees, Longwater Gravel's development proposals for MIN 45 do not include this area for mineral extraction, but do include the progressive restoration of this area by the thinning/selective felling of the conifers and additional replanting of native broadleaved woodland species trees in an effort to restore Coxford Wood.

As part of developing the application for planning permission for the north extension, a number of habitat studies have already been undertaken, all in accordance with the requirements of bullet point 1 of the adopted Policy MIN 45, i.e. 'a survey to identify any features, including soils, that remain of the ancient woodland and protection/mitigation for any features identified'. These include studies to identify the presence of flora and fauna associated with ancient woodland, e.g. bluebells, fungi, remnant tree stumps, veteran trees, etc. along with soil sampling, testing and soil germination trials. Sadly, all of these habitat studies noted a complete absence of any definitive ancient woodland indicators in the PAWS at MIN 45. Accepting that the only remaining feature of the ancient woodland is the soil, protection and mitigation, in the form of careful translocation will be proposed. The phased extraction and restoration of MIN 45 can be designed so that soils from the woodland areas can be directly placed without the need for the soil to be stored in bunds. The open arable field in the west (phase 1) would be worked and restored first with the soil from this area being placed into a soil storage bund in the main quarry. As this phase is completed, the block of woodland in the southwest, i.e. phase 2, would be felled and the soils carefully translocated onto the restored surface in phase 1. As extraction progresses, the process would be repeated until the final phase where the soils stored in the main quarry would be used to complete the restoration. Longwater Gravel plans to trial turve cutting/lifting equipment, similar to that used in heathland translocation, in order to minimise soil disturbance. Consultant ecologists will be employed to evaluate and monitor the recovery of the translocated soils, the findings from which will inform and recommend any changes in translocation technique which may be necessary. New planting will be sourced from local stock to maintain provenance and a maintenance scheme to regularly remove invasive weeds will also be implemented.

As the sand and gravel landbank for Norfolk remains well above 7 years and there are sufficient permitted reserves at Coxford Abbey Quarry to meet demand for the foreseeable future, clearly the timing for submitting a planning application for the north extension remains some way off. However, at some point before 2036, the landbank will reduce as Coxford Abbey Quarry and other sites exhaust their reserves, therefore, the proposal for an extension at an already established quarry which delivers a significant quantity of minerals for the county's needs along with a commitment to restoring Coxford Wood to a native broadleaved woodland might then be acceptable. If MIN 45 is removed from the Mineral and Waste Local Plan, then proposals for the north extension cannot even be submitted for consideration.

Longwater Gravel fully accepts that the NPPF 2018 does indeed preclude developments which lead to the loss of ancient woodland 'unless there are wholly exceptional reasons and a suitable compensation strategy exists'. However, the NPPF 2018 does give 'great weight' to minerals, recognising that they can only be worked where they are found and that they are necessary to provide the infrastructure that society needs. We would also argue that that mineral extraction is not a development which leads to the loss of irreplaceable habitats. In most if not all cases, restored mineral extraction sites create multiple benefits to biodiversity and there are numerous precedents where mineral extraction has been granted planning permission which leads to the loss of a PAWS. Hermitage Quarry in Kent and Brickworth Quarry in Wiltshire are two notable examples. In both cases, the operator has proposed large scale replanting of woodland to restore the quarry, which will create irreplaceable habitat in the long term. It is therefore not unique for Norfolk County Council to allocate and consider an application for mineral extraction from a PAWS.

Finally, I have asked both Small Fish Consulting and SLR Consulting, both of which have been involved with the development of the planning application for the north extension to submit additional responses arguing in support of the allocation of MIN 45.

We hope that Norfolk County Council will reverse its proposal not to allocate MIN 45.

Summary: Longwater Gravel should be allowed to submit a planning application for MIN 45 as we believe that we can develop a planning application which would be acceptable to Norfolk County Council (NCC). The only reason an application has not been submitted is because NCC have advised us to delay submission until the existing permitted reserves at Coxford Abbey Quarry are almost exhausted. The removal of MIN 45 would mean that the north extension would be a departure from the M&WLP and therefore a application to extract mineral and completely restore Coxford Wood could not be considered by NCC.

Support

Representation ID: 92067

Received: 10/08/2018

Respondent: Longwater Gravel Co. Ltd.

I write to confirm that Longwater Gravel agree with and support Norfolk County Council's initial conclusion to allocate MIN 64.

Longwater Gravel Company is a small scale quarry operator which specialises in small deliveries of sand and gravel to a customer base which includes local builders, groundworkers and the general public. We also supply sand and gravel to a number of small volume readymixed concrete producers.

Our quarry at Horstead produces natural shingle, primarily used as a decorative aggregate for driveways, etc. along with a high quality building sand. MIN 64 would form an extension to the quarry and would provide sand and gravel reserves of around 650,000 tonnes. There are no plans to increase production, which is limited by Section 106 agreement to 50,000 tonnes/year. It is anticipated that existing permitted reserves at Horstead Quarry will be exhausted within the next 2-3 years and so following the successful granting of planning permission, extraction could commence in MIN 64 by the end of 2020. It should be noted MIN 64 did originally comprise the field to the west and having received planning permission, extraction has now been carried out in this area for over two years.

It is proposed to plant a small area of mixed native woodland trees in the north east corner of MIN 64, this would be planted in advance of mineral extraction commencing and once established would serve to soften views of the soil storage/screening bunds of the final eastern phase from the properties located at the north east boundary. Views of MIN 64 from the Buxton Road will be screened by the placement of soil storage bunds along the southern boundary with the existing hedgerow strengthened by additional planting of native species hedgerow trees.

MIN 64 would be worked in five separate phases working and restoring progressively from west to east. The washing plant, weighbridge and access would be retained in the existing quarry with sand and gravel transported from MIN 64 by dumptruck using an internal haulroad constructed in the northwest corner. Other than mobile plant such as excavator, loader and dumptruck, no other quarry equipment will be located within MIN 64. There are no plans to create an access directly from MIN 64 onto Buxton Road.

On completion of sand and gravel extraction, the land would be restored to agricultural use at a lower level with sloping margins around the perimeter of the extraction area which would be constructed using the surplus silt from the gravel washing operation. There are no plans to import any material e.g. household waste or inert waste to restore the site. The overall timescale to complete extraction and restoration of MIN 64 would be around 13 years.

We have asked Small Fish Consultants to assess MIN 64 and our proposals against the emerging Minerals and Waste Local Plan and they will comment separately.

Summary: Longwater Gravel agrees with Norfolk County Council's initial conclusion to allocate MIN64. This would form an extension to an already established quarry and would enable production to continue for a further 13 years. We are fully committed to submitting an application for planning permission which will meet all of the requirements set out in M&WLP and MIN 64 within the next two years.

Comment

Representation ID: 92535

Received: 09/08/2018

Respondent: Longwater Gravel Co. Ltd.

Agent: SLR Consulting

DESCRIPTION OF PAWS AT COXFORD ABBEY QUARRY
A block of 20.6ha of woodland identified1 as Plantation on Ancient Woodland Site (PAWS) occurs at the north of the quarry, and is known as Coxford Wood.
The term Ancient Woodland is applied to sites in England and Wales whose documented history shows them to have been continuously wooded since approximately 1600, and which are by extension considered likely to have been continuously wooded since the last Ice Age. Research on the Coxford Wood site history includes Faden's map of Norfolk published in 1797 and 19th century
tithe and enclosure maps which show woodland boundaries that correspond closely to the area designated as PAWS. The First series OS Plan dated around 1880 shows the PAWS area with new plantation to the east north east and south. It is interesting to note that the detailed cartography of the time shows the PAWS area with a significant proportion of conifers. These cannot be the trees currently in place as these date from the late 1960's to the early 70s, so it seems the PAWS area has seen at least two conifer rotations.

The majority of Coxford Wood is now plantation woodland dominated by Scot's pine Pinus sylvestris with Douglas fir Pseudotsuga menziesii, oak Quercus robur, beech Fagus sylvatica, silver birch Betula pendula, sweet chestnut Castanea sativa and rowan Sorbus aucuparia recorded. The proportion of conifers in the canopy is high throughout the woodland and typically exceeds 90%. Woodland understory is typically sparse throughout the wood and species lists from all field surveys conducted in Coxford Wood have been reviewed for records of Ancient Woodland Indictor (AWI) species in East England (Rose, 2006; as cited by Rotherham, 2011) for flora associated with ancient woodland sites.

Only three AWI species have been recorded from the site: climbing corydalis Ceratocapnos claviculata; holly Ilex aquilifolium and rowan Sorbus aucuparia. This is a very low number of AWI species for an ancient woodland site and indicates that the woodland's past management, anecdotally reported to have included two rotations of conifers, has clearly had an adverse effect upon the biodiversity value of the woodland habitat present.

Coxford Wood, including PAWS, is considered to be of Parish Value. It is unlikely to meet CWS guidelines for woodland habitats5 as it is currently in poor condition due to dominance by coniferous species and as a result of two conifer rotations reducing ground flora richness.

POTENTIAL IMPACTS OF QUARRY EXTENSION INTO PAWS
Do nothing scenario:
Commercial forestry is typically managed on a 30-60 year rotation, and therefore it is highly likely that the current tree crop including the PAWS, would be felled and replanted at some point in next 20-30 years. The felling and replanting of forest, would further disrupt the soils in ancient woodland areas, but may be an opportunity to replace mixed and coniferous stands with native broadleaves.
However, the landowner is likely to wish to maximise commercial land values and therefore another conifer rotation is more likely than a switch to lower yielding broadleaves in the absence of other drivers.

Habitat Loss, Fragmentation and Isolation due to land take
Due to its management in the last century, the biodiversity value of PAWS in Coxford Wood is considered to rest within its soils. Field surveys of the PAWS woodland have not identified any specific features indicative of ancient woodland, such as ancient or veteran trees or a diverse flora of
AWI species. In the absence of any mitigation, it is predicted that the permanent loss of soil resource
from the majority of the PAWS as a result of quarry extension would be considered an adverse
impact significant at a Parish level.
It is proposed that top-soils from the PAWS would be stripped in a phased manner and direct placed onto pre-prepared restored areas in advance of replanting with broadleaved trees which would be managed to recreate Coxford Wood, in accordance with an agreed Woodland Management Plan.
This approach to phased development, restoration and long-term management would give the best opportunity to maintain any seed bank and functional soil micro-organisms within the translocated soils and for the restored woodland habitats to maximise their biodiversity potential. A review of literature and guidance on the translocation of ancient woodlands and their soils was undertaken by SLR in 2013 (Unpublished report, refer to Appendix 1 of this report for a full list of key sources) provides evidence that this approach to compensation for the loss of the PAWS habitat has a high chance of successfully maintaining the residual value of the soils and restoring a native woodland to replace the non-native plantation currently present.
With these measures in place and the implementation of a woodland management plan, the residual effects upon woodland habitats, including PAWS, are not considered significant.

Restoration Scheme
Proposed mineral extraction on the site would provide a catalyst for the transformation of a commercial, mainly conifer woodland to native broadleaved woodland over the restoration period.
The process of PAWS soil translocation and the commitment to the long-term management of woodland habitats would produce substantial gains in terms of biodiversity value in the long-term and is considered to provide a net positive impact for biodiversity that is significant at a Parish level.

Residual Impact
In this instance, the PAWS at Coxford Abbey Quarry is considered to be of low biodiversity value and its loss to quarrying and the restoration of the site to a native woodland is not considered to be significant in biodiversity terms when compared to the predicted baseline and "do nothing" scenario.

CONCLUSION
The proposed development would lead to the predicted loss of Plantation on Ancient Woodland Site as identified on the Ancient Woodland Inventory. In biodiversity terms, PAWS at Coxford Abbey Quarry is considered to be of low biodiversity value and its loss to quarrying and the restoration of the site to a native woodland is considered not significant when compared to the "do nothing" scenario.
The ecological assessment has identified no residual impacts of habitat loss and fragmentation upon woodland or other habitats of ecological value. Long-term management commitments and restoration of woodland areas would ensure that adverse effects upon important receptors are minimised. The proposed restoration and 20-year management plan is considered to generate net biodiversity gains at a local level in comparison to the predicted baseline.