Preferred Options consultation document
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Preferred Options consultation document
Specific Site Allocation Policy MIN 209 / MIN 210 / MIN 211 (Earsham sites)
Representation ID: 98599
Received: 22/10/2019
Respondent: East Suffolk Council
East Suffolk Council welcomes the opportunity to comment on the Norfolk County Council Minerals and Waste Local Plan consultation. East Suffolk Council was created in 2019 following the merger of Suffolk Coastal District Council and Waveney District Council, which prior to this had run a shared service for several years. It is worth being aware that the evidence base documents referred to here were prepared by the former Waveney District Council.
East Suffolk Council wishes to raise concerns regarding three sand and gravel extraction sites, MIN209, MIN210 and MIN211, which are located outside of Earsham and are very close to the northern border with East Suffolk.
The three sites in question would form an extension to an existing quarry. It is acknowledged that they would not be worked at the same time and this would reduce their impact at any given time. However, it would significantly extend the working life of the quarry and this has the potential to increase impact significantly on the East Suffolk area. Several concerns remain regarding landscape and historic environment, natural environment and road safety.
Landscape and Historic Environment Impact
The three sites would significantly increase the area to be quarried and this has the potential to cumulatively impact upon the appearance of the landscape. Once extraction work is completed a programme of landscape restoration would be required to ensure that the sites are returned to their former condition. The Minerals and Waste Local Plan does not identify these sites as being of significant landscape value. However, site MIN210 is located very close to the boundary of the Broads Authority. It is therefore possible that further extraction work on this site could impact upon the setting of The Broads. This is particularly the case given largely flat character of the area. More evidence is needed to demonstrate that any landscape impact can be successfully mitigated.
In addition, the site is located close to the town of Bungay, which is set on a peninsula in the River Waveney. An increase in extent of mineral extraction activity has the potential to impact upon the setting of the conservation area, including Bungay Castle, which is a grade I Listed Building and Ancient Monument. The Waveney Settlement Fringe Landscape Sensitivity Study identifies the western edge as being a sensitive urban edge, which could be harmed by inappropriate development and therefore it is necessary to ensure that development to the west of the town takes this into account.
The Landscape Character Assessment identifies the southern and western edge of Bungay as a Rural River Valley and as part of the Waveney Valley landscape. This is a flat and low-lying landscape with a high level of visibility across the area. It is also an important part of the setting of The Broads. As such it is susceptible to negative landscape impact from large scale development of the type proposed. Future development should protect views of The Broads and should protect the river valley floodplains, which are a valuable wetland habitat.
Environmental Impact
The proposed sites at Earsham are located close to Stow Fen, which is identified as an area of biodiversity value by the Waveney District Council Open Space Needs Assessment. This is a low-lying site sandwiched between the River Waveney to the north and its tributary the Broad Water to the south. It is not clear from the information submitted whether this area will be impacted by the proposed aggregates extraction sites or what measures are in place to protect the site. Similarly, Outney Common, which is a County Wildlife Site, is located to the north of Bungay and is an important part of the town's setting, could potentially be affected by the proposed extraction sites.
Road Impact
The Preferred Options information submitted states that these three sites will not increase the volume of traffic but rather extend the period during which traffic moves to and from the mineral extraction site. Attention is drawn to ensuring that the safety of cyclists and pedestrians is considered, particularly along the A143. In particular, the Clays roundabout to the north of Bungay has been identified by the Waveney District Council Cycle Strategy (BU2) as requiring improvement to improve cyclist safety.
East Suffolk Council welcomes the opportunity to comment on the Norfolk County Council Minerals and Waste Local Plan consultation. East Suffolk Council was created in 2019 following the merger of Suffolk Coastal District Council and Waveney District Council, which prior to this had run a shared service for several years. It is worth being aware that the evidence base documents referred to here were prepared by the former Waveney District Council.
East Suffolk Council wishes to raise concerns regarding three sand and gravel extraction sites, MIN209, MIN210 and MIN211, which are located outside of Earsham and are very close to the northern border with East Suffolk.
The three sites in question would form an extension to an existing quarry. It is acknowledged that they would not be worked at the same time and this would reduce their impact at any given time. However, it would significantly extend the working life of the quarry and this has the potential to increase impact significantly on the East Suffolk area. Several concerns remain regarding landscape and historic environment, natural environment and road safety.
Landscape and Historic Environment Impact
The three sites would significantly increase the area to be quarried and this has the potential to cumulatively impact upon the appearance of the landscape. Once extraction work is completed a programme of landscape restoration would be required to ensure that the sites are returned to their former condition. The Minerals and Waste Local Plan does not identify these sites as being of significant landscape value. However, site MIN210 is located very close to the boundary of the Broads Authority. It is therefore possible that further extraction work on this site could impact upon the setting of The Broads. This is particularly the case given largely flat character of the area. More evidence is needed to demonstrate that any landscape impact can be successfully mitigated.
In addition, the site is located close to the town of Bungay, which is set on a peninsula in the River Waveney. An increase in extent of mineral extraction activity has the potential to impact upon the setting of the conservation area, including Bungay Castle, which is a grade I Listed Building and Ancient Monument. The Waveney Settlement Fringe Landscape Sensitivity Study identifies the western edge as being a sensitive urban edge, which could be harmed by inappropriate development and therefore it is necessary to ensure that development to the west of the town takes this into account.
The Landscape Character Assessment identifies the southern and western edge of Bungay as a Rural River Valley and as part of the Waveney Valley landscape. This is a flat and low-lying landscape with a high level of visibility across the area. It is also an important part of the setting of The Broads. As such it is susceptible to negative landscape impact from large scale development of the type proposed. Future development should protect views of The Broads and should protect the river valley floodplains, which are a valuable wetland habitat.
Environmental Impact
The proposed sites at Earsham are located close to Stow Fen, which is identified as an area of biodiversity value by the Waveney District Council Open Space Needs Assessment. This is a low-lying site sandwiched between the River Waveney to the north and its tributary the Broad Water to the south. It is not clear from the information submitted whether this area will be impacted by the proposed aggregates extraction sites or what measures are in place to protect the site. Similarly, Outney Common, which is a County Wildlife Site, is located to the north of Bungay and is an important part of the town's setting, could potentially be affected by the proposed extraction sites.
Road Impact
The Preferred Options information submitted states that these three sites will not increase the volume of traffic but rather extend the period during which traffic moves to and from the mineral extraction site. Attention is drawn to ensuring that the safety of cyclists and pedestrians is considered, particularly along the A143. In particular, the Clays roundabout to the north of Bungay has been identified by the Waveney District Council Cycle Strategy (BU2) as requiring improvement to improve cyclist safety.
East Suffolk Council welcomes the chance to discuss the above issues with yourselves. Please contact me if you have any questions about this representation.
