Preferred Options consultation document

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Comment

Preferred Options consultation document

Policy MP13: Areas of Search for silica sand extraction

Representation ID: 99004

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

Policy MP13 provides a criterion based approach to potential development in Areas of Search, including Area E. The expectation is that various assessments about related impacts will be provided in support of any applications, covering matters such as archaeology, landscape etc. Heavy reliance is placed on the safeguards from supporting studies to achieve acceptable development.

Full text:

Original response received 30.10 2019
Revised response received 18.12.2019

3. Implications for the Borough from sand and gravel and silica sand policies / areas
3.1 Tottenhill (Site 206 - West of Lynn Road) This is an extension of existing works. The Tottenhill sites would be worked sequentially to mitigate any cumulative impacts. Potentially acceptable subject to the requirements in the policy.

3.2 A site at East Winch (Site MIN06 Mill Drove, Middleton) is allocated for carstone extraction. Potentially acceptable subject to the requirements in the policy.

3.3 Silica sand - AoS's (E, F, J and I) and SIL01. The County Council concludes that Site SIL01 is suitable to allocate for silica sand extraction. Development will be subject to compliance with the relevant Minerals and Waste Local Plan Policies and Specific Site Allocation Policy SIL01. There are reasonable safeguards for the locality.

3.4 The AoS are the same as previously expressed in the Initial Consultation document. Silica sand is a nationally important industrial mineral, and as such, the County Council must make adequate provision for its extraction. However they are not able to find suitable sites for the quantity of sand required, especially having dropped a site at Shouldham / Marham. The AoS are large and the expectation is that a suitable location could be found within one of the areas. Without detailed further information or operator preferences, it is not possible to pinpoint a site and therefore assess the localised impacts. Whilst this may be unsatisfactory for local communities who fear the consequences of extraction, it does give a positive indication that the County Council is safeguarding land and narrowing down suitable sites. It would be unrealistic to seek to have no areas of search at all, and the Plan could be found 'unsound', which would not be of benefit to the area.

Policy MP13 Silica Sand Area of Search (AoS E - Shouldham Warren area) and Policy MP2 - Spatial Strategy for mineral extraction (including reference to Silica Sand Areas of Search, and buffer zones (clause e))
3.5 Policy MP13 provides a criterion based approach to potential development in Areas of Search, including Area E. The expectation is that various assessments about related impacts will be provided in support of any applications, covering matters such as archaeology, landscape etc. Heavy reliance is placed on the safeguards from supporting studies to achieve acceptable development.
The recent decision by Norfolk County Council (in respect of it's Environmental Policy - County Council 25 November) to support the planting of some 1 million trees over the next 5 years to mitigate for the effects of climate change suggests a significant policy shift in the important role that trees play in County Council operations. It is clear that much more attention needs to be given the retention of existing tree cover in any mineral extraction situation. Shouldham Warren is an extensive area of tree cover, with additional recreation opportunities. An elevated status needs to be given to this in the planning balance as to whether an Area of Search should be designated at Shouldham, the Borough Council view is that the County Council should remove the AoS for this reason.
Additionally, Policy MP2 provides a degree of protection for areas with defined characteristics. Clause a. refers to 'ancient' woodland. In view of the County Council decision referred to above, it would be appropriate to delete the word 'ancient', leaving an enhanced level of protection to woodland generally.
Conclusion on AoS E (Shouldham) - Taking into account the two proposed amendments to policies affecting the potential for extraction at Shouldham, and the significant additional constraints now evident, the AoS should be removed.
MP2 Clause e) - Whilst the hydrological catchment around Roydon Common and Dersingham Bog, is specifically mentioned in Policy MP2e for exclusion, the complex hydrology and geology of these extremely sensitive sites is not fully understood. These two habitats have been recognised through the Ramsar, SAC and SSSI designations as having protected status. The introduction of wider 1.5km buffer zones would better mitigate any risk.

3.6 Policy MP7 (relating to restoration and aftercare) suggests that preference will be given to enhancing biodiversity, green infrastructure, and high quality local landscapes. This approach is supported. Whilst not necessarily appropriate in all circumstances, tree planting on restored sites would be a useful additional boost to mitigate for climate change. It is proposed that an additional clause is added to this effect as a fifth bullet point in paragraph four to the policy.

4. Implications for the Borough from the NCC approach to proposed waste and other policies on 'energy minerals'.

4.1 NCC have reviewed the policies in the current plans and as with Minerals moved them on to an end date of 2036. One particular item is relevant to West Norfolk. This is the overall locational strategy for waste management facilities.
4.2 Main points:
* From Policy WP2 in the Preferred Options it would seem possible to locate waste management facilities away from the broad location that generated the waste. Thus necessitating potentially significant transport movements, and possibly generating resentment from recipient communities.
* Whilst not necessarily inappropriate for all types of waste where specialist facilities are needed, extremely careful thought should be given to general waste or significant quantities requiring movement.
* A better approach would seem to be one where the policy encouraged waste to be dealt with as near to the generating source as possible.
* It is suggested our original comments are still appropriate to make.
4.3 Incineration - For the avoidance of doubt, it would be helpful if the County Council could add text to explain the position whereby the County Council will not seek to procure incinerators within Norfolk.
The position of the Borough Council on incineration is clear from previous involvement in planning inquiries. A clear statement on the matter from the County Council in the Minerals and Waste Local Plan would avoid any uncertainty for residents.

4.4 Fracking - Reference could be made to latest Government announcements about the potential restrictions / banning on this subject.

Object

Preferred Options consultation document

AOS E - land to the north of Shouldham

Representation ID: 99005

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

The recent decision by Norfolk County Council (in respect of it's Environmental Policy - County Council 25 November) to support the planting of some 1 million trees over the next 5 years to mitigate for the effects of climate change suggests a significant policy shift in the important role that trees play in County Council operations. It is clear that much more attention needs to be given the retention of existing tree cover in any mineral extraction situation. Shouldham Warren is an extensive area of tree cover, with additional recreation opportunities. An elevated status needs to be given to this in the planning balance as to whether an Area of Search should be designated at Shouldham, the Borough Council view is that the County Council should remove the AoS for this reason.
Additionally, Policy MP2 provides a degree of protection for areas with defined characteristics. Clause a. refers to 'ancient' woodland. In view of the County Council decision referred to above, it would be appropriate to delete the word 'ancient', leaving an enhanced level of protection to woodland generally.
Conclusion on AoS E (Shouldham) - Taking into account the two proposed amendments to policies affecting the potential for extraction at Shouldham, and the significant additional constraints now evident, the AoS should be removed.

Full text:

Original response received 30.10 2019
Revised response received 18.12.2019

3. Implications for the Borough from sand and gravel and silica sand policies / areas
3.1 Tottenhill (Site 206 - West of Lynn Road) This is an extension of existing works. The Tottenhill sites would be worked sequentially to mitigate any cumulative impacts. Potentially acceptable subject to the requirements in the policy.

3.2 A site at East Winch (Site MIN06 Mill Drove, Middleton) is allocated for carstone extraction. Potentially acceptable subject to the requirements in the policy.

3.3 Silica sand - AoS's (E, F, J and I) and SIL01. The County Council concludes that Site SIL01 is suitable to allocate for silica sand extraction. Development will be subject to compliance with the relevant Minerals and Waste Local Plan Policies and Specific Site Allocation Policy SIL01. There are reasonable safeguards for the locality.

3.4 The AoS are the same as previously expressed in the Initial Consultation document. Silica sand is a nationally important industrial mineral, and as such, the County Council must make adequate provision for its extraction. However they are not able to find suitable sites for the quantity of sand required, especially having dropped a site at Shouldham / Marham. The AoS are large and the expectation is that a suitable location could be found within one of the areas. Without detailed further information or operator preferences, it is not possible to pinpoint a site and therefore assess the localised impacts. Whilst this may be unsatisfactory for local communities who fear the consequences of extraction, it does give a positive indication that the County Council is safeguarding land and narrowing down suitable sites. It would be unrealistic to seek to have no areas of search at all, and the Plan could be found 'unsound', which would not be of benefit to the area.

Policy MP13 Silica Sand Area of Search (AoS E - Shouldham Warren area) and Policy MP2 - Spatial Strategy for mineral extraction (including reference to Silica Sand Areas of Search, and buffer zones (clause e))
3.5 Policy MP13 provides a criterion based approach to potential development in Areas of Search, including Area E. The expectation is that various assessments about related impacts will be provided in support of any applications, covering matters such as archaeology, landscape etc. Heavy reliance is placed on the safeguards from supporting studies to achieve acceptable development.
The recent decision by Norfolk County Council (in respect of it's Environmental Policy - County Council 25 November) to support the planting of some 1 million trees over the next 5 years to mitigate for the effects of climate change suggests a significant policy shift in the important role that trees play in County Council operations. It is clear that much more attention needs to be given the retention of existing tree cover in any mineral extraction situation. Shouldham Warren is an extensive area of tree cover, with additional recreation opportunities. An elevated status needs to be given to this in the planning balance as to whether an Area of Search should be designated at Shouldham, the Borough Council view is that the County Council should remove the AoS for this reason.
Additionally, Policy MP2 provides a degree of protection for areas with defined characteristics. Clause a. refers to 'ancient' woodland. In view of the County Council decision referred to above, it would be appropriate to delete the word 'ancient', leaving an enhanced level of protection to woodland generally.
Conclusion on AoS E (Shouldham) - Taking into account the two proposed amendments to policies affecting the potential for extraction at Shouldham, and the significant additional constraints now evident, the AoS should be removed.
MP2 Clause e) - Whilst the hydrological catchment around Roydon Common and Dersingham Bog, is specifically mentioned in Policy MP2e for exclusion, the complex hydrology and geology of these extremely sensitive sites is not fully understood. These two habitats have been recognised through the Ramsar, SAC and SSSI designations as having protected status. The introduction of wider 1.5km buffer zones would better mitigate any risk.

3.6 Policy MP7 (relating to restoration and aftercare) suggests that preference will be given to enhancing biodiversity, green infrastructure, and high quality local landscapes. This approach is supported. Whilst not necessarily appropriate in all circumstances, tree planting on restored sites would be a useful additional boost to mitigate for climate change. It is proposed that an additional clause is added to this effect as a fifth bullet point in paragraph four to the policy.

4. Implications for the Borough from the NCC approach to proposed waste and other policies on 'energy minerals'.

4.1 NCC have reviewed the policies in the current plans and as with Minerals moved them on to an end date of 2036. One particular item is relevant to West Norfolk. This is the overall locational strategy for waste management facilities.
4.2 Main points:
* From Policy WP2 in the Preferred Options it would seem possible to locate waste management facilities away from the broad location that generated the waste. Thus necessitating potentially significant transport movements, and possibly generating resentment from recipient communities.
* Whilst not necessarily inappropriate for all types of waste where specialist facilities are needed, extremely careful thought should be given to general waste or significant quantities requiring movement.
* A better approach would seem to be one where the policy encouraged waste to be dealt with as near to the generating source as possible.
* It is suggested our original comments are still appropriate to make.
4.3 Incineration - For the avoidance of doubt, it would be helpful if the County Council could add text to explain the position whereby the County Council will not seek to procure incinerators within Norfolk.
The position of the Borough Council on incineration is clear from previous involvement in planning inquiries. A clear statement on the matter from the County Council in the Minerals and Waste Local Plan would avoid any uncertainty for residents.

4.4 Fracking - Reference could be made to latest Government announcements about the potential restrictions / banning on this subject.

Comment

Preferred Options consultation document

Policy MP2: Spatial Strategy for minerals extraction

Representation ID: 99006

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

The recent decision by Norfolk County Council (in respect of it's Environmental Policy - County Council 25 November) to support the planting of some 1 million trees over the next 5 years to mitigate for the effects of climate change suggests a significant policy shift in the important role that trees play in County Council operations. It is clear that much more attention needs to be given the retention of existing tree cover in any mineral extraction situation.

Additionally, Policy MP2 provides a degree of protection for areas with defined characteristics. Clause a. refers to 'ancient' woodland. In view of the County Council decision referred to above, it would be appropriate to delete the word 'ancient', leaving an enhanced level of protection to woodland generally.

MP2 Clause e) - Whilst the hydrological catchment around Roydon Common and Dersingham Bog, is specifically mentioned in Policy MP2e for exclusion, the complex hydrology and geology of these extremely sensitive sites is not fully understood. These two habitats have been recognised through the Ramsar, SAC and SSSI designations as having protected status. The introduction of wider 1.5km buffer zones would better mitigate any risk.

Full text:

Original response received 30.10 2019
Revised response received 18.12.2019

3. Implications for the Borough from sand and gravel and silica sand policies / areas
3.1 Tottenhill (Site 206 - West of Lynn Road) This is an extension of existing works. The Tottenhill sites would be worked sequentially to mitigate any cumulative impacts. Potentially acceptable subject to the requirements in the policy.

3.2 A site at East Winch (Site MIN06 Mill Drove, Middleton) is allocated for carstone extraction. Potentially acceptable subject to the requirements in the policy.

3.3 Silica sand - AoS's (E, F, J and I) and SIL01. The County Council concludes that Site SIL01 is suitable to allocate for silica sand extraction. Development will be subject to compliance with the relevant Minerals and Waste Local Plan Policies and Specific Site Allocation Policy SIL01. There are reasonable safeguards for the locality.

3.4 The AoS are the same as previously expressed in the Initial Consultation document. Silica sand is a nationally important industrial mineral, and as such, the County Council must make adequate provision for its extraction. However they are not able to find suitable sites for the quantity of sand required, especially having dropped a site at Shouldham / Marham. The AoS are large and the expectation is that a suitable location could be found within one of the areas. Without detailed further information or operator preferences, it is not possible to pinpoint a site and therefore assess the localised impacts. Whilst this may be unsatisfactory for local communities who fear the consequences of extraction, it does give a positive indication that the County Council is safeguarding land and narrowing down suitable sites. It would be unrealistic to seek to have no areas of search at all, and the Plan could be found 'unsound', which would not be of benefit to the area.

Policy MP13 Silica Sand Area of Search (AoS E - Shouldham Warren area) and Policy MP2 - Spatial Strategy for mineral extraction (including reference to Silica Sand Areas of Search, and buffer zones (clause e))
3.5 Policy MP13 provides a criterion based approach to potential development in Areas of Search, including Area E. The expectation is that various assessments about related impacts will be provided in support of any applications, covering matters such as archaeology, landscape etc. Heavy reliance is placed on the safeguards from supporting studies to achieve acceptable development.
The recent decision by Norfolk County Council (in respect of it's Environmental Policy - County Council 25 November) to support the planting of some 1 million trees over the next 5 years to mitigate for the effects of climate change suggests a significant policy shift in the important role that trees play in County Council operations. It is clear that much more attention needs to be given the retention of existing tree cover in any mineral extraction situation. Shouldham Warren is an extensive area of tree cover, with additional recreation opportunities. An elevated status needs to be given to this in the planning balance as to whether an Area of Search should be designated at Shouldham, the Borough Council view is that the County Council should remove the AoS for this reason.
Additionally, Policy MP2 provides a degree of protection for areas with defined characteristics. Clause a. refers to 'ancient' woodland. In view of the County Council decision referred to above, it would be appropriate to delete the word 'ancient', leaving an enhanced level of protection to woodland generally.
Conclusion on AoS E (Shouldham) - Taking into account the two proposed amendments to policies affecting the potential for extraction at Shouldham, and the significant additional constraints now evident, the AoS should be removed.
MP2 Clause e) - Whilst the hydrological catchment around Roydon Common and Dersingham Bog, is specifically mentioned in Policy MP2e for exclusion, the complex hydrology and geology of these extremely sensitive sites is not fully understood. These two habitats have been recognised through the Ramsar, SAC and SSSI designations as having protected status. The introduction of wider 1.5km buffer zones would better mitigate any risk.

3.6 Policy MP7 (relating to restoration and aftercare) suggests that preference will be given to enhancing biodiversity, green infrastructure, and high quality local landscapes. This approach is supported. Whilst not necessarily appropriate in all circumstances, tree planting on restored sites would be a useful additional boost to mitigate for climate change. It is proposed that an additional clause is added to this effect as a fifth bullet point in paragraph four to the policy.

4. Implications for the Borough from the NCC approach to proposed waste and other policies on 'energy minerals'.

4.1 NCC have reviewed the policies in the current plans and as with Minerals moved them on to an end date of 2036. One particular item is relevant to West Norfolk. This is the overall locational strategy for waste management facilities.
4.2 Main points:
* From Policy WP2 in the Preferred Options it would seem possible to locate waste management facilities away from the broad location that generated the waste. Thus necessitating potentially significant transport movements, and possibly generating resentment from recipient communities.
* Whilst not necessarily inappropriate for all types of waste where specialist facilities are needed, extremely careful thought should be given to general waste or significant quantities requiring movement.
* A better approach would seem to be one where the policy encouraged waste to be dealt with as near to the generating source as possible.
* It is suggested our original comments are still appropriate to make.
4.3 Incineration - For the avoidance of doubt, it would be helpful if the County Council could add text to explain the position whereby the County Council will not seek to procure incinerators within Norfolk.
The position of the Borough Council on incineration is clear from previous involvement in planning inquiries. A clear statement on the matter from the County Council in the Minerals and Waste Local Plan would avoid any uncertainty for residents.

4.4 Fracking - Reference could be made to latest Government announcements about the potential restrictions / banning on this subject.

Comment

Preferred Options consultation document

Site WS5 Land east of Mill Drove, at Blackborough End landfill site

Representation ID: 99007

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

WS5.1 Amenity
The site has the potential to cause emissions of PM10 and PM2.5 which can affect the health and amenity of local residents
The nearest residential property is located 450m from the site boundary, with the settlement of Blackborough End located 450m away. Although the greatest noise and dust impacts are likely to be within 100m from the source (if uncontrolled), we would still insist on a planning application for this site to include noise, air quality, odour, and lighting assessments, along with details of appropriate mitigation measures to reduce both amenity and health impacts on nearby receptors..
It must be ensured that the preparation or use of the site will not result in an exceedance of the national air quality objectives, or an AQMA may need to be declared.
Additionally, cumulative emissions from nearby allocations MIN 06 and MIN 40 should be taken into account during these assessments.

WS5.2 Highway Access
The site would use the existing site access turning onto Mill Drove and then along East Winch Road (C57A), joining the A47 Lynn Road at the existing junction. This is the same as the permitted access route for the landfill site operations. The site is not within an AQMA. The estimated number of HGV movements is 50 to 70 per day. We therefore request that a transport assessment be submitted with a planning application, detailing any air quality impacts from these movements on local residents.
Additionally dust nuisance from haulage routes must be considered within any future planning application, along with the cumulative effects of transportation to and from allocations MIN 06 and MIN 40.

Full text:


Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Mineral Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Submitted noise assessments and air quality/dust assessments should consider and include mitigation measures to deal appropriately with any potential health impacts, such as operational practices, separation/standoff areas and screening and/or bunding in line with Development Management Policies DM12 and DM13.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework.

Lighting:
Lighting is not included in the document as this is generally something which can be considered at any proposed planning application stage; however we would hope that any proposed lighting for site security and worker safety would be carefully considered prior to the planning stage so details can be submitted with any planning application. We would assume lighting would be pole mounted in elevated positions, and therefore the throw and spread of this should be assessed to ensure that there is no impact on residents. Light should be contained within the confines of sites and positioned appropriately. If necessary lighting is located near dwellings, this should be angled away and hooded/cowled to prevent any adverse impact on residents.

Vibrations:
The potential impact from vibrations should also be considered at any future planning stage, if sites are chosen close to residential receptors - including vibrations from site operations and associated transportation of extracted materials.

Soil Stripping:
Soil stripping operations must be effectively controlled through mitigation methods (e.g. buffer zones and bunding) to reduce fugitive emissions, which pose short term health impacts on nearby residents. These mitigation measures must be included in any future planning application.

Haul Roads:
Fugitive emissions from haul roads need to be addressed in any future planning application, with mitigation planned where necessary such as wheel washing.

[see attached table for comments on individual sites]

Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Waste Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Any future applications for waste sites should be accompanied by noise, odour, dust, and air quality management schemes, which should identify potential sources and mitigation/control measures to prevent nuisance issues and health impacts (e.g. emissions from as gas flaring).
Where sites are likely to be illuminated for safety/security, lighting plans and details should also be submitted which should include where lights will be located, their heights and angle/orientation, the type of lighting and the throw and spill of light across the site, and measures to ensure light spill is contained within site boundaries.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework

Existing Waste Site Specific Allocation Policies:
We note that WAS 05, WAS 25, WAS 36, WAS 40, WAS 37, WAS 45 and WAS 65 are no longer required and would therefore be deleted. There is therefore no risk to residential amenity from these sites.

Odour:
An odour impact assessment should be included within any future planning applications for allocated waste sites, along with suitable mitigation measures where appropriate.

Climate Change:
Climate change mitigation should be considered with regards to methane emissions (a greenhouse gas) released from allocated landfill sites.

[see attached table for comments on individual sites]

Comment

Preferred Options consultation document

Site WS6 Land north of Main Road, Crimplesham

Representation ID: 99008

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

WS6.1 Amenity
The site has the potential to cause emissions of PM10 and PM2.5 which can affect the health and amenity of local residents.
The nearest residential property is 98m from the site boundary. There are 3 residential properties within 250m of the site boundary. The settlement of Crimplesham is 480m away. The greatest noise and dust impacts are likely to be within 100m of a source, if uncontrolled.
Therefore, the site poses a risk and we would require a planning application to include a noise, air quality, odour, and lighting assessment, along with details of appropriate mitigation measures to reduce both amenity and health impacts on nearby receptors.
It must be ensured that the preparation or use of the site will not result in an exceedance of the national air quality objectives, or an AQMA may need to be declared or allocation deemed unsuitable.
These assessments should also include the cumulative emissions from nearby allocation MIN 32.

WS6.2 Highway Access
The site would use the existing access onto Main Road (C543) and turn east onto the A134. The site is not within an AQMA. The estimated number of HGV movements is 35 per day (17 in and 17 out). To ensure nearby residents are not negatively affected by these movements, a transport assessment should be undertaken, taking into account air quality and dust emissions from additional HGV movements along Main Road and A134. The cumulative effects of movements from allocation MIN32 should also be included.

Full text:


Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Mineral Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Submitted noise assessments and air quality/dust assessments should consider and include mitigation measures to deal appropriately with any potential health impacts, such as operational practices, separation/standoff areas and screening and/or bunding in line with Development Management Policies DM12 and DM13.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework.

Lighting:
Lighting is not included in the document as this is generally something which can be considered at any proposed planning application stage; however we would hope that any proposed lighting for site security and worker safety would be carefully considered prior to the planning stage so details can be submitted with any planning application. We would assume lighting would be pole mounted in elevated positions, and therefore the throw and spread of this should be assessed to ensure that there is no impact on residents. Light should be contained within the confines of sites and positioned appropriately. If necessary lighting is located near dwellings, this should be angled away and hooded/cowled to prevent any adverse impact on residents.

Vibrations:
The potential impact from vibrations should also be considered at any future planning stage, if sites are chosen close to residential receptors - including vibrations from site operations and associated transportation of extracted materials.

Soil Stripping:
Soil stripping operations must be effectively controlled through mitigation methods (e.g. buffer zones and bunding) to reduce fugitive emissions, which pose short term health impacts on nearby residents. These mitigation measures must be included in any future planning application.

Haul Roads:
Fugitive emissions from haul roads need to be addressed in any future planning application, with mitigation planned where necessary such as wheel washing.

[see attached table for comments on individual sites]

Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Waste Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Any future applications for waste sites should be accompanied by noise, odour, dust, and air quality management schemes, which should identify potential sources and mitigation/control measures to prevent nuisance issues and health impacts (e.g. emissions from as gas flaring).
Where sites are likely to be illuminated for safety/security, lighting plans and details should also be submitted which should include where lights will be located, their heights and angle/orientation, the type of lighting and the throw and spill of light across the site, and measures to ensure light spill is contained within site boundaries.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework

Existing Waste Site Specific Allocation Policies:
We note that WAS 05, WAS 25, WAS 36, WAS 40, WAS 37, WAS 45 and WAS 65 are no longer required and would therefore be deleted. There is therefore no risk to residential amenity from these sites.

Odour:
An odour impact assessment should be included within any future planning applications for allocated waste sites, along with suitable mitigation measures where appropriate.

Climate Change:
Climate change mitigation should be considered with regards to methane emissions (a greenhouse gas) released from allocated landfill sites.

[see attached table for comments on individual sites]

Comment

Preferred Options consultation document

MIN 6 - land off East Winch Road, Mill Drove, Middleton

Representation ID: 99009

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

M6.1 Amenity
The site has the potential to cause emissions of PM10 and PM2.5 which can affect the amenity and health of local residents.
The nearest residential property is 480m from the site boundary. The settlement of Blackborough End is 481m away. Whilst a suitable separation distance, we would expect any planning application for mineral extraction at this site to include noise and dust assessments and mitigation measures where appropriate to deal with any amenity and health impacts.
Additionally, the cumulative impacts of this site, WS5, and other nearby existing and potential extraction sites must be considered within any assessment.
It must be ensured that the preparation or use of the site will not result in an exceedance of the national air quality objectives, or an AQMA may need to be declared.
We welcome the requirement that phasing of the extraction this site with other carstone quarries be undertaken to reduce cumulative effects.

M6.2 Highway Access
The site would use the existing internal haul route to the existing quarry entrance on the East Winch Road and then travel east to access the A47 Lynn Road at the existing junction, both of which are designated lorry routes. The site is not within an AQMA. As a proposed extension to an existing site, the number of vehicle movements is expected to remain the same but continue for a longer period. The estimated number of HGV movements is 30 (in and out) per day. Limited traffic may travel along the East Winch Road and Mill Drove.
Whilst this should not have an adverse impact on residential amenity, a transport assessment should be undertaken, including traffic flow along East Winch Road and Mill drove and the air quality impacts of this on the health of local residents.

M6.15 Flood Risk
The site has a low risk of surface water flooding with three locations of surface water pooling in a 1 in 30 and 1 in 100 year rainfall event, so this should be considered within a surface water drainage scheme.

M6.16 Hydrogeology
The site is partially located over a principal aquifer (bedrock) and partially over a Secondary (undifferentiated) aquifer (superficial deposits). However, there are no groundwater Source Protection Zones within the proposed site. The proposed extraction site would be worked dry (above the water table) and therefore no effect on water resources is expected. We would expect any planning application for mineral extraction at this site to include a Hydrogeological Risk Assessment to identify any potential impacts to groundwater and appropriate mitigation measures.

Full text:


Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Mineral Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Submitted noise assessments and air quality/dust assessments should consider and include mitigation measures to deal appropriately with any potential health impacts, such as operational practices, separation/standoff areas and screening and/or bunding in line with Development Management Policies DM12 and DM13.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework.

Lighting:
Lighting is not included in the document as this is generally something which can be considered at any proposed planning application stage; however we would hope that any proposed lighting for site security and worker safety would be carefully considered prior to the planning stage so details can be submitted with any planning application. We would assume lighting would be pole mounted in elevated positions, and therefore the throw and spread of this should be assessed to ensure that there is no impact on residents. Light should be contained within the confines of sites and positioned appropriately. If necessary lighting is located near dwellings, this should be angled away and hooded/cowled to prevent any adverse impact on residents.

Vibrations:
The potential impact from vibrations should also be considered at any future planning stage, if sites are chosen close to residential receptors - including vibrations from site operations and associated transportation of extracted materials.

Soil Stripping:
Soil stripping operations must be effectively controlled through mitigation methods (e.g. buffer zones and bunding) to reduce fugitive emissions, which pose short term health impacts on nearby residents. These mitigation measures must be included in any future planning application.

Haul Roads:
Fugitive emissions from haul roads need to be addressed in any future planning application, with mitigation planned where necessary such as wheel washing.

[see attached table for comments on individual sites]

Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Waste Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Any future applications for waste sites should be accompanied by noise, odour, dust, and air quality management schemes, which should identify potential sources and mitigation/control measures to prevent nuisance issues and health impacts (e.g. emissions from as gas flaring).
Where sites are likely to be illuminated for safety/security, lighting plans and details should also be submitted which should include where lights will be located, their heights and angle/orientation, the type of lighting and the throw and spill of light across the site, and measures to ensure light spill is contained within site boundaries.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework

Existing Waste Site Specific Allocation Policies:
We note that WAS 05, WAS 25, WAS 36, WAS 40, WAS 37, WAS 45 and WAS 65 are no longer required and would therefore be deleted. There is therefore no risk to residential amenity from these sites.

Odour:
An odour impact assessment should be included within any future planning applications for allocated waste sites, along with suitable mitigation measures where appropriate.

Climate Change:
Climate change mitigation should be considered with regards to methane emissions (a greenhouse gas) released from allocated landfill sites.

[see attached table for comments on individual sites]

Comment

Preferred Options consultation document

MIN 45 - land north of Coxford Abbey Quarry, East Rudham

Representation ID: 99010

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

Summary
We note that this site is unsuitable for allocation due to the ancient woodland site.

M45.1 Amenity
The site has the potential to cause emissions of PM10 and PM2.5 which can affect the amenity and health of local residents.
The nearest residential property is 822m from the site boundary. The settlement of Syderstone is 848m away. Although adverse dust impacts are uncommon beyond 250m from dust generating activities, we would expect a planning application to include a dust impact assessment along with appropriate mitigation measures to address health and amenity concerns.
It must be ensured that the preparation or use of the site will not result in an exceedance of the national air quality objectives, or an AQMA may need to be declared.
Additionally, the cumulative effect of this and other nearby existing and potential extraction sites must be considered within any assessment.

M45.2 Highway Access
The site would use the existing site access route on to the B1454 (Fakenham Road), which is a designated lorry route, and then onto the A148. The site is not within an AQMA. As a proposed extension to an existing site, the number of vehicle movements is expected to remain the same but continue for a longer period. The estimated number of HGV movements is 14 per day.
We would expect a transport assessment to include air quality impacts from transportation on local residents if a planning application is submitted.

M45.13 Flood Risk
The site has a low probability of surface water flooding, with a minor surface water flow path along the southern boundary of the site in a 1 in 1000 year rainfall event, so we have no concerns regarding surface water drainage.

M45.14 Hydrogeology
The site is located over a principal aquifer (bedrock) and a secondary A aquifer (superficial deposits). A small part of the site is within groundwater Source Protection Zone 2. As the site would be worked dry (above the water table) there should be no effect on groundwater.

Full text:


Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Mineral Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Submitted noise assessments and air quality/dust assessments should consider and include mitigation measures to deal appropriately with any potential health impacts, such as operational practices, separation/standoff areas and screening and/or bunding in line with Development Management Policies DM12 and DM13.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework.

Lighting:
Lighting is not included in the document as this is generally something which can be considered at any proposed planning application stage; however we would hope that any proposed lighting for site security and worker safety would be carefully considered prior to the planning stage so details can be submitted with any planning application. We would assume lighting would be pole mounted in elevated positions, and therefore the throw and spread of this should be assessed to ensure that there is no impact on residents. Light should be contained within the confines of sites and positioned appropriately. If necessary lighting is located near dwellings, this should be angled away and hooded/cowled to prevent any adverse impact on residents.

Vibrations:
The potential impact from vibrations should also be considered at any future planning stage, if sites are chosen close to residential receptors - including vibrations from site operations and associated transportation of extracted materials.

Soil Stripping:
Soil stripping operations must be effectively controlled through mitigation methods (e.g. buffer zones and bunding) to reduce fugitive emissions, which pose short term health impacts on nearby residents. These mitigation measures must be included in any future planning application.

Haul Roads:
Fugitive emissions from haul roads need to be addressed in any future planning application, with mitigation planned where necessary such as wheel washing.

[see attached table for comments on individual sites]

Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Waste Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Any future applications for waste sites should be accompanied by noise, odour, dust, and air quality management schemes, which should identify potential sources and mitigation/control measures to prevent nuisance issues and health impacts (e.g. emissions from as gas flaring).
Where sites are likely to be illuminated for safety/security, lighting plans and details should also be submitted which should include where lights will be located, their heights and angle/orientation, the type of lighting and the throw and spill of light across the site, and measures to ensure light spill is contained within site boundaries.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework

Existing Waste Site Specific Allocation Policies:
We note that WAS 05, WAS 25, WAS 36, WAS 40, WAS 37, WAS 45 and WAS 65 are no longer required and would therefore be deleted. There is therefore no risk to residential amenity from these sites.

Odour:
An odour impact assessment should be included within any future planning applications for allocated waste sites, along with suitable mitigation measures where appropriate.

Climate Change:
Climate change mitigation should be considered with regards to methane emissions (a greenhouse gas) released from allocated landfill sites.

[see attached table for comments on individual sites]

Comment

Preferred Options consultation document

MIN 204 - land north of Lodge Road, Feltwell

Representation ID: 99011

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

Summary
We note that this site is unsuitable for allocation due to Breckland Forest SSSI.

M204.1 Amenity
The site has the potential to cause emissions of PM10 and PM2.5 which can affect the amenity and health of local residents.
The nearest residential property is 21m from the site boundary. There are five sensitive receptors within 250m of the site boundary and two of these are within 100m of the site boundary. The settlement of Feltwell is 1.3km away. Without mitigation, adverse dust impacts from sand and gravel sites can occur within 250m from the nearest dust generating activities, with the greatest impacts within 100m of a source, if uncontrolled. These can result in negative impacts upon human health.
Therefore we would expect any planning application for mineral extraction at this site to include noise, dust, and air quality assessments, and mitigation measures to minimise harmful emissions to air and address appropriately any human health or amenity impacts.
The control and mitigation of dust at this site should be discussed between the operator and the LA Environmental Health Department before an application is submitted. Matters that may need to be explored are:
* the existing dust climate at the locality;
* the need for, and scope of, a dust assessment study to be conducted by the operator prior to a detailed design.
* the potential for different site activities to emit dust and their relationship to residential properties and other sensitive uses;
* how the layout of the site could minimise impacts; and the proposed methods of mitigation and control of dust generating activities such as buffer zones.
It must be ensured that the preparation or use of the site will not result in an exceedance of the national air quality objectives, or an AQMA may need to be declared.
Boundary dust measurement may need to be conducted, due to the close proximity of residential properties to the proposed site, to ensure there are no breaches of national air quality objectives.
Without appropriate mitigation of air pollution from the site, human health could be impacted, thus making the site allocation unsuitable.

M204.2 Highway Access
The site would use the new access onto the B1112 (Lodge Road), which is a designated lorry route (approx. 150 m west of the Sawmill access). The site is not within an AQMA. The estimated number of HGV movements is 20 per day.
A transport assessment should be undertaken which includes traffic flow along the B1112 and takes into account air quality implications for local residents.

M204.15 Flood Risk
The site has a low risk of surface water flooding with two locations of surface water pooling in a 1 in 30 year rainfall event and a five locations of surface water pooling in a 1 in 100 year rainfall event. In the 1:1000 year rainfall event approximately 40% of the western field is covered by surface water pooling, so this should be considered within a surface water drainage scheme.

M204.16 Hydrogeology
The site is located over a principal aquifer (bedrock) and partially located over a secondary A aquifer (superficial deposits). Part of the site is within groundwater Source Protection Zone 2. The rest of the site is not within a groundwater SPZ. The site would be worked dry (above the water table) and therefore dewatering would not be required. We would expect a planning application for mineral extraction at this site to include a Hydrogeological Risk Assessment to identify any potential impacts to groundwater, along with appropriate mitigation measures.

Full text:


Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Mineral Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Submitted noise assessments and air quality/dust assessments should consider and include mitigation measures to deal appropriately with any potential health impacts, such as operational practices, separation/standoff areas and screening and/or bunding in line with Development Management Policies DM12 and DM13.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework.

Lighting:
Lighting is not included in the document as this is generally something which can be considered at any proposed planning application stage; however we would hope that any proposed lighting for site security and worker safety would be carefully considered prior to the planning stage so details can be submitted with any planning application. We would assume lighting would be pole mounted in elevated positions, and therefore the throw and spread of this should be assessed to ensure that there is no impact on residents. Light should be contained within the confines of sites and positioned appropriately. If necessary lighting is located near dwellings, this should be angled away and hooded/cowled to prevent any adverse impact on residents.

Vibrations:
The potential impact from vibrations should also be considered at any future planning stage, if sites are chosen close to residential receptors - including vibrations from site operations and associated transportation of extracted materials.

Soil Stripping:
Soil stripping operations must be effectively controlled through mitigation methods (e.g. buffer zones and bunding) to reduce fugitive emissions, which pose short term health impacts on nearby residents. These mitigation measures must be included in any future planning application.

Haul Roads:
Fugitive emissions from haul roads need to be addressed in any future planning application, with mitigation planned where necessary such as wheel washing.

[see attached table for comments on individual sites]

Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Waste Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Any future applications for waste sites should be accompanied by noise, odour, dust, and air quality management schemes, which should identify potential sources and mitigation/control measures to prevent nuisance issues and health impacts (e.g. emissions from as gas flaring).
Where sites are likely to be illuminated for safety/security, lighting plans and details should also be submitted which should include where lights will be located, their heights and angle/orientation, the type of lighting and the throw and spill of light across the site, and measures to ensure light spill is contained within site boundaries.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework

Existing Waste Site Specific Allocation Policies:
We note that WAS 05, WAS 25, WAS 36, WAS 40, WAS 37, WAS 45 and WAS 65 are no longer required and would therefore be deleted. There is therefore no risk to residential amenity from these sites.

Odour:
An odour impact assessment should be included within any future planning applications for allocated waste sites, along with suitable mitigation measures where appropriate.

Climate Change:
Climate change mitigation should be considered with regards to methane emissions (a greenhouse gas) released from allocated landfill sites.

[see attached table for comments on individual sites]

Comment

Preferred Options consultation document

MIN 19 & MIN 205 - land north of the River Nar, Pentney

Representation ID: 99012

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

Summary
We note the site is unsuitable for allocation because the site is within a Core River Valley.

M19.1 Amenity
The site has the potential to cause emissions of PM10 and PM2.5 which can affect the amenity and health of local residents.
The nearest residential property is 570m from the site. The settlement of Blackborough End is 2.7km away. Although adverse dust impacts are uncommon beyond 250m from dust generating activities, we would still expect a planning application to include a dust impact assessment along with appropriate mitigation measures where necessary to protect human health.
It must be ensured that the preparation or use of the site will not result in an exceedance of the national air quality objectives, or an AQMA may need to be declared.

M19.2 Highway Access
The site would use the existing access route along Common Road (a designated HGV access route) up to its junction with the A47. The site is not within an AQMA. As a proposed extension to an existing site, the number of vehicle movements is expected to remain the same but continue for a longer period. The estimated number of HGV movements is 30 (in and out) per day. Highway improvements along Common Road will be needed.
A transport assessment should be undertaken which includes the extended traffic flow along Common Road and takes into account air quality implications for local residents.

M19.18 Flood Risk
The site has a low probability of surface water flooding, with a few small locations of surface water pooling in a 1 in 100-year rainfall event. In a 1 in 1000-year rainfall event there are additional small areas of surface water pooling. The site is within the East of Ouse, Polver and Nar Internal Drainage Board area, so they would comment regarding any surface water drainage concerns.

M19.19 Hydrogeology
We have no concerns regarding groundwater contamination.

Full text:


Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Mineral Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Submitted noise assessments and air quality/dust assessments should consider and include mitigation measures to deal appropriately with any potential health impacts, such as operational practices, separation/standoff areas and screening and/or bunding in line with Development Management Policies DM12 and DM13.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework.

Lighting:
Lighting is not included in the document as this is generally something which can be considered at any proposed planning application stage; however we would hope that any proposed lighting for site security and worker safety would be carefully considered prior to the planning stage so details can be submitted with any planning application. We would assume lighting would be pole mounted in elevated positions, and therefore the throw and spread of this should be assessed to ensure that there is no impact on residents. Light should be contained within the confines of sites and positioned appropriately. If necessary lighting is located near dwellings, this should be angled away and hooded/cowled to prevent any adverse impact on residents.

Vibrations:
The potential impact from vibrations should also be considered at any future planning stage, if sites are chosen close to residential receptors - including vibrations from site operations and associated transportation of extracted materials.

Soil Stripping:
Soil stripping operations must be effectively controlled through mitigation methods (e.g. buffer zones and bunding) to reduce fugitive emissions, which pose short term health impacts on nearby residents. These mitigation measures must be included in any future planning application.

Haul Roads:
Fugitive emissions from haul roads need to be addressed in any future planning application, with mitigation planned where necessary such as wheel washing.

[see attached table for comments on individual sites]

Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Waste Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Any future applications for waste sites should be accompanied by noise, odour, dust, and air quality management schemes, which should identify potential sources and mitigation/control measures to prevent nuisance issues and health impacts (e.g. emissions from as gas flaring).
Where sites are likely to be illuminated for safety/security, lighting plans and details should also be submitted which should include where lights will be located, their heights and angle/orientation, the type of lighting and the throw and spill of light across the site, and measures to ensure light spill is contained within site boundaries.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework

Existing Waste Site Specific Allocation Policies:
We note that WAS 05, WAS 25, WAS 36, WAS 40, WAS 37, WAS 45 and WAS 65 are no longer required and would therefore be deleted. There is therefore no risk to residential amenity from these sites.

Odour:
An odour impact assessment should be included within any future planning applications for allocated waste sites, along with suitable mitigation measures where appropriate.

Climate Change:
Climate change mitigation should be considered with regards to methane emissions (a greenhouse gas) released from allocated landfill sites.

[see attached table for comments on individual sites]

Comment

Preferred Options consultation document

MIN 74 - land at Turf Field, Watlington Road, Tottenhill

Representation ID: 99013

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

Summary
We note the site is unsuitable for allocation because of the unacceptable impacts on the landscape and historic environment.

M74.1 Amenity
The site has the potential to cause emissions of PM10 and PM2.5 which can affect the amenity and health of local residents.
The nearest residential property is 77m from the site boundary. There are four sensitive receptors within 250m of the site boundary and two of these are within 100m of the site boundary. Tottenhill Row is 77m away. The greatest impacts from dust will be within 100m of a source, if uncontrolled.
Therefore any planning application for mineral extraction at this site should include noise, dust and air quality assessments, along with and mitigation measures to deal appropriately with any health amenity impacts.
The control and mitigation of dust should be discussed between the operator and the LA Environmental Health Department before an application is submitted. Matters that may need to be explored are:
* the existing dust climate at the locality;
* the need for and scope of a dust assessment study to be conducted by the operator prior to a detailed design. Such a study could be part of a formal Environmental Impact Assessment.
* the potential for different site activities to emit dust and their relationship to residential properties and other sensitive uses; and
* how the layout of the site could minimise impacts; and the proposed methods of mitigation and control of dust generating activities
It must be ensured that the preparation or use of the site will not result in an exceedance of the national air quality objectives, or an AQMA may need to be declared.
Boundary dust measurement may need to be conducted, due to the close proximity of residential properties to the proposed site, to ensure there are no breaches of national air quality objectives.
We welcome the comment that the Tottenhill sites will be worked sequentially to reduce cumulative impacts.
Without appropriate mitigation of air pollution from the site, human health could be impacted, thus making the site allocation unsuitable.

M74.2 Highway Access
The site would use the existing quarry access along Watlington Road for about 150 metres before reaching the roundabout for the A10/A134 (a designated lorry route). The site is not within an AQMA. As a proposed extension to an existing site, the number of vehicle movements is expected to remain the same but continue for a longer period. The estimated number of HGV movements is 40 per day.
A transport assessment should be undertaken which includes the extended traffic flow along Watlington Road and takes into account air quality implications for local residents.

M74.14 Flood Risk
No areas of the site are at risk of flooding from surface water, so we have no concerns

M74.15 Hydrogeology
We have no concerns regarding groundwater contamination

Full text:


Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Mineral Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Submitted noise assessments and air quality/dust assessments should consider and include mitigation measures to deal appropriately with any potential health impacts, such as operational practices, separation/standoff areas and screening and/or bunding in line with Development Management Policies DM12 and DM13.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework.

Lighting:
Lighting is not included in the document as this is generally something which can be considered at any proposed planning application stage; however we would hope that any proposed lighting for site security and worker safety would be carefully considered prior to the planning stage so details can be submitted with any planning application. We would assume lighting would be pole mounted in elevated positions, and therefore the throw and spread of this should be assessed to ensure that there is no impact on residents. Light should be contained within the confines of sites and positioned appropriately. If necessary lighting is located near dwellings, this should be angled away and hooded/cowled to prevent any adverse impact on residents.

Vibrations:
The potential impact from vibrations should also be considered at any future planning stage, if sites are chosen close to residential receptors - including vibrations from site operations and associated transportation of extracted materials.

Soil Stripping:
Soil stripping operations must be effectively controlled through mitigation methods (e.g. buffer zones and bunding) to reduce fugitive emissions, which pose short term health impacts on nearby residents. These mitigation measures must be included in any future planning application.

Haul Roads:
Fugitive emissions from haul roads need to be addressed in any future planning application, with mitigation planned where necessary such as wheel washing.

[see attached table for comments on individual sites]

Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Waste Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Any future applications for waste sites should be accompanied by noise, odour, dust, and air quality management schemes, which should identify potential sources and mitigation/control measures to prevent nuisance issues and health impacts (e.g. emissions from as gas flaring).
Where sites are likely to be illuminated for safety/security, lighting plans and details should also be submitted which should include where lights will be located, their heights and angle/orientation, the type of lighting and the throw and spill of light across the site, and measures to ensure light spill is contained within site boundaries.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework

Existing Waste Site Specific Allocation Policies:
We note that WAS 05, WAS 25, WAS 36, WAS 40, WAS 37, WAS 45 and WAS 65 are no longer required and would therefore be deleted. There is therefore no risk to residential amenity from these sites.

Odour:
An odour impact assessment should be included within any future planning applications for allocated waste sites, along with suitable mitigation measures where appropriate.

Climate Change:
Climate change mitigation should be considered with regards to methane emissions (a greenhouse gas) released from allocated landfill sites.

[see attached table for comments on individual sites]

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