Preferred Options consultation document

Comments sought on Preferred Options Consultation on the Norfolk Minerals and
Waste Local Plan (M&WLP).
Thank you for your consultation on the above site, received on 16th September 2019.
We were previously consulted on 28th June 2018 and responded under the following
reference, FWS/18/8/6750 -2, dated 30th July 2018. Our comments at that time are
included below:
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.

Policy MW4: We welcome that this policy supports policy MW2 with the provision of flood
risk assessments (FRA) and although not specifically stated we assume that this policy's
intention is that any FRA will include appropriate consideration of the most up to date
climate change allowances.
It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts
should be considered during a planning application and appropriate measures. These
measures may not be required until reinstatement when post development ground levels
are considered in detail.

With regard to specific sites put forward we have the following comments:

MIN12 - Beetly - We would like to highlight that we are aware of reports of external
flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.

MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems

SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

It is noted that our recommendation that policy MW2 is changed for point d) to
include groundwater flooding has not been taken forward. Our advice remains that
this should be changed.

Our comments on MW4, MIN12, MIN37 and SIL02 also remain.

Comments sought on Preferred Options Consultation on the Norfolk Minerals and
Waste Local Plan (M&WLP).
Thank you for your consultation on the above site, received on 16th September 2019.
We were previously consulted on 28th June 2018 and responded under the following
reference, FWS/18/8/6750 -2, dated 30th July 2018. Our comments at that time are
included below:
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.

Policy MW4: We welcome that this policy supports policy MW2 with the provision of flood
risk assessments (FRA) and although not specifically stated we assume that this policy's
intention is that any FRA will include appropriate consideration of the most up to date
climate change allowances.
It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts
should be considered during a planning application and appropriate measures. These
measures may not be required until reinstatement when post development ground levels
are considered in detail.

With regard to specific sites put forward we have the following comments:

MIN12 - Beetly - We would like to highlight that we are aware of reports of external
flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.

MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems

SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

It is noted that our recommendation that policy MW2 is changed for point d) to
include groundwater flooding has not been taken forward. Our advice remains that
this should be changed.

Our comments on MW4, MIN12, MIN37 and SIL02 also remain.

Comments sought on Preferred Options Consultation on the Norfolk Minerals and
Waste Local Plan (M&WLP).
Thank you for your consultation on the above site, received on 16th September 2019.
We were previously consulted on 28th June 2018 and responded under the following
reference, FWS/18/8/6750 -2, dated 30th July 2018. Our comments at that time are
included below:
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.

Policy MW4: We welcome that this policy supports policy MW2 with the provision of flood
risk assessments (FRA) and although not specifically stated we assume that this policy's
intention is that any FRA will include appropriate consideration of the most up to date
climate change allowances.
It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts
should be considered during a planning application and appropriate measures. These
measures may not be required until reinstatement when post development ground levels
are considered in detail.

With regard to specific sites put forward we have the following comments:

MIN12 - Beetly - We would like to highlight that we are aware of reports of external
flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.

MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems

SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

It is noted that our recommendation that policy MW2 is changed for point d) to
include groundwater flooding has not been taken forward. Our advice remains that
this should be changed.

Our comments on MW4, MIN12, MIN37 and SIL02 also remain.

Comments sought on Preferred Options Consultation on the Norfolk Minerals and
Waste Local Plan (M&WLP).
Thank you for your consultation on the above site, received on 16th September 2019.
We were previously consulted on 28th June 2018 and responded under the following
reference, FWS/18/8/6750 -2, dated 30th July 2018. Our comments at that time are
included below:
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.

Policy MW4: We welcome that this policy supports policy MW2 with the provision of flood
risk assessments (FRA) and although not specifically stated we assume that this policy's
intention is that any FRA will include appropriate consideration of the most up to date
climate change allowances.
It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts
should be considered during a planning application and appropriate measures. These
measures may not be required until reinstatement when post development ground levels
are considered in detail.

With regard to specific sites put forward we have the following comments:

MIN12 - Beetly - We would like to highlight that we are aware of reports of external
flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.

MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems

SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

It is noted that our recommendation that policy MW2 is changed for point d) to
include groundwater flooding has not been taken forward. Our advice remains that
this should be changed.

Our comments on MW4, MIN12, MIN37 and SIL02 also remain.

Comments sought on Preferred Options Consultation on the Norfolk Minerals and
Waste Local Plan (M&WLP).
Thank you for your consultation on the above site, received on 16th September 2019.
We were previously consulted on 28th June 2018 and responded under the following
reference, FWS/18/8/6750 -2, dated 30th July 2018. Our comments at that time are
included below:
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.

Policy MW4: We welcome that this policy supports policy MW2 with the provision of flood
risk assessments (FRA) and although not specifically stated we assume that this policy's
intention is that any FRA will include appropriate consideration of the most up to date
climate change allowances.
It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts
should be considered during a planning application and appropriate measures. These
measures may not be required until reinstatement when post development ground levels
are considered in detail.

With regard to specific sites put forward we have the following comments:

MIN12 - Beetly - We would like to highlight that we are aware of reports of external
flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.

MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems

SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

It is noted that our recommendation that policy MW2 is changed for point d) to
include groundwater flooding has not been taken forward. Our advice remains that
this should be changed.

Our comments on MW4, MIN12, MIN37 and SIL02 also remain.