Preferred Options consultation document

Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 74 - land at Turf Field, Watlington Road)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 74 for the reasons outlined below.

Amenity
The results of the noise prediction exercise carried out by Independent Environmental Consultancy Limited show that the outline scheme for Turf Field would have exceed typical criterion for routine operations at the nearest dwelling located at Tottenhill Row. Consequently, the proposal scheme increases the separation distance to in excess of 100m between the western boundary of the extraction area and the nearest dwelling located at Tottenhill Row and increases the screening bund height up to 4m by utilising the onsite subsoils.

As part of these proposals appropriate noise criterion at Oak House and Tottenhill Row can now both be met with careful consideration of the haul route between Turf Field and the existing processing plant located to the south.

Therefore, the feasibility study has shown that NPPG noise criterion can be met at the nearest noise-sensitive receptor positions with the amended operational scenario detailed in the above paragraphs. Any future planning application for mineral extraction at this site will include a further noise and dust assessment and outline mitigation measures to deal appropriately with any amenity impacts.

I therefore wish to object to paragraph M74.1 Amenity: and for the Draft Norfolk Minerals and Waste Local Plan to now take account for the amendments to the scheme detailed above by making clear that all the nearest residential properties will be in excess of 100m from the extraction area.

Historic Environment
The findings from the Heritage Appraisal carried out by independent consultants Andrew Josephs Associates demonstrate that there are no listed structures or scheduled monuments within 1km of Turf Field. Therefore, no listed buildings or scheduled monuments would be affected by the proposed allocation. Furthermore, Tottenhill Row Conservation Area north eastern boundary lies in excess of 50m from Turf Field given that it is now proposed to increase the separation distance between the western margin of the extraction area from the Conservation Area.

Mineral extraction has previously taken place to the east and west of the Conservation Area now restored to lakes and species rich grassland. Mineral extraction is currently taking place directly to the south of the Conservation Area within MIN 76 (West Field), and it is more than likely that there is an historic working within the Conservation Area itself represented by a pond feature. Mineral extraction is therefore not alien to the vicinity, and the number of historic workings in the locality stresses the temporary nature of these proposals. Nonetheless, due to the proximity of Turf Field to the northeast of the Conservation Area, it is proposed that the site will require careful design of boundary treatments to negate any visual impact and stand-offs from any potential receptors in excess of 100m to reduce other impacts such as from noise and dust.

It is proposed that restoration shall be sympathetic to the current agricultural context of Tottenhill Row by returning the site back to productive agricultural land. Any future planning application for mineral extraction at this site will include a further Heritage Statement to identify heritage assets and their settings, assess the potential for impacts and identify appropriate mitigation measures if required.

I therefore wish to object to paragraph M74.4 by amending the wording to state that there are no Listed Buildings or Scheduled Monuments within 1km of the extraction area and that Tottenhill Row Conservation Area is in excess of 50m from the site given the amendments to the scheme detailed above.

Archaeology
Following the archaeological background section included in the Heritage Appraisal carried out by independent consultants Andrew Josephs Associates. It is proposed that any future planning application will be accompanied by an assessment of the significance of archaeological remains, in order to protect and mitigate the impact of mineral extraction in this site.

Landscape
It is considered that the sightlines sections drawing no. W13/LAN/002 submitted in support of Turf Field's allocation at the 'call for mineral extraction sites' stage of the Norfolk Minerals and Waste Local Plan Review in August 2017, demonstrates that the site will not have any adverse effects on the existing landscape given the implementation of appropriately designed screening bunds, existing and proposed planting.

It is proposed that all screening bunds shall have shallow outer slopes and are to be sown to grassland at the first available opportunity to match the adjacent field. The screening bunds will vary in height from 2m on the southern boundary adjacent to Watlington Road up to 4m on the eastern boundary closest to Oak House. Furthermore, where possible it is proposed to reinforce the existing planting in advance of mineral workings to aid screening.

Therefore, it can be demonstrated by these sightline sections that once the above mitigation proposals have been implemented the site will not afford any views to potential external sensitive receptors, or at least winter intermittent sightlines only from Oak House first floor window when working the western portion of the site. Any future planning application for mineral extraction at this site will include a further landscape assessment and scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents.

I therefore wish to object to paragraph M74.6 Landscape: suggesting that the conclusions reached in terms of screening the views from the Nar Valley Way and Tottenhill Conservation Area are reconsidered to take account for the sightline sections included in the original Turf Field representation, that clearly demonstrate given the mitigation proposals above that suitable screening can be implemented. Furthermore, I wish to object to the conclusions drawn regarding the screening or bunding being intrusive in its own right, as it has been specifically designed to have shallow outer slopes and to be sown to grassland at the first available opportunity to match the adjacent field, and therefore blending into the surrounding agricultural landscaping setting.

Ecology
Following the Ecological Scoping Report carried out by independent consultants The Landscape Partnership in support of the original representation. It is proposed that any future planning application will be accompanied by an assessment of potential impacts, including from dust deposition and hydrogeology, together with appropriate mitigation on all designated sites within the vicinity of the site.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.16 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Furthermore, it should be considered that under the current adopted Norfolk Minerals and Waste Development Framework Core Strategy and Minerals and Waste Development Management Policies Development Plan Document 2010-2026, Core Strategy Policy CS2 - General locations for mineral extraction and associated facilities MIN 74 is proposed as an extension to an existing site and therefore will be preferred by the MPA to new sites. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Amenity Impact & Mitigation Report (Ref. IEC/3650/01/AVH) dated 04 August 2017 Heritage Appraisal (No Reference) dated July 2017
Sightline Sections (Drawing No. W13/LAN/002) dated July 2017
Ecological Scoping Report (Ref. E17854) dated 31 July 2017

Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 77 - land at Runs Wood, south of Whin Common Road, Tottenhill)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 77 for the reasons outlined below.

Amenity
The feasibility study completed as part of the noise prediction exercise carried out by Independent Environmental Consultancy Limited has shown that NPPG noise criterion can be met at the nearest noise-sensitive receptor positions. Any future planning application for mineral extraction at this site will include a further noise and dust assessment and outline mitigation measures to deal appropriately with any amenity impacts.

Historic Environment
Following the findings from the Heritage Appraisal carried out by independent consultants Andrew Josephs Associates. It is proposed that any future planning application for mineral extraction at this site will include a further Heritage Statement to identify heritage assets and their settings, assess the potential for impacts and identify appropriate mitigation measures if required.

Archaeology
Following the archaeological background section included in the Heritage Appraisal carried out by independent consultants Andrew Josephs Associates. It is proposed that any future planning application will be accompanied by an assessment of the significance of archaeological remains, in order to protect and mitigate the impact of mineral extraction on this site.

Landscape
It is considered that Runs Wood no longer constitutes a significant area of woodland within the local landscape and therefore does not have a significant biodiversity value. Runs Wood is an area of ornamental woodland, likely planted to provide cover for shooting with a significant shrub layer dominated by Rhododendron ponticum. The woodland is largely unmanaged with many large dead and fallen trees throughout, with the southern part of the woodland including a large pheasant pen and elsewhere evidence of further gamekeeper activity. There are also a number of Ash trees within the woodland which may be susceptible to Ash Die Back. Furthermore, it is proposed that a screening buffer of trees shall be retained around the perimeter of the excavation. This coupled with the fact that in recent years the Estate have felled a number of dead or dying trees means that the once considered significant densely populated woodland, is now very sparsely populated with poor quality trees remaining above a shrub layer dominated by Rhododendron ponticum, subsequently reducing the biodiversity value.

I therefore wish to object to paragraph M77.7 Landscape: suggesting that the conclusions reached in terms of Runs Wood constituting a significant area of woodland within the local landscape are reconsidered to take account for the recent deterioration in the woodland habitat associated with the management by the Estate, and that the dominance of Rhododendron ponticum should suggest that the biodiversity value can no longer be considered as significant.

Ecology
Following the Ecological Scoping Report carried out by independent consultants The Landscape Partnership in support of the original representation. It is proposed that any future planning application will be accompanied by an assessment of potential impacts, including from dust deposition and hydrogeology, together with appropriate mitigation on all designated sites within the vicinity of the site.

Restoration
It is proposed that the site is restored to nature conservation after use comprising a mixture of ponds, wet woodland and wet grassland. The proposed restoration scheme would result in the planting of additional woodland to blend in with the screening buffer of trees to be retained around the excavation. Since the woodland is now very sparsely populated with poor quality trees remaining above a shrub layer dominated by Rhododendron ponticum it is considered that the existing woodland would be able to be replaced and enhanced as a result of the proposed restoration. The restoration proposals will subsequently mitigate against the loss of the existing woodland and provide for a net biodiversity gain.

I therefore wish to object to paragraph M77.19 Restoration: suggesting that the conclusions reached in terms of the proposed restoration scheme not being able to replace the existing established woodland and not mitigate for the loss of the existing woodland are reconsidered to take account for the recent deterioration in the woodland habitat.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.63 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Furthermore, it should be considered that under the current adopted Norfolk Minerals and Waste Development Framework Core Strategy and Minerals and Waste Development Management Policies Development Plan Document 2010-2026, Core Strategy Policy CS2 - General locations for mineral extraction and associated facilities MIN 77 is proposed as an extension to an existing site and therefore will be preferred by the MPA to new sites. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Amenity Impact & Mitigation Report (Ref. IEC/3650/01/AVH) dated 04 August 2017
Heritage Appraisal (No Reference) dated July 2017
Ecological Scoping Report (Ref. E17854) dated 31 July 2017

Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 32 - land west of Lime Kiln Road, West Dereham)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 32 for the reasons outlined below.

Amenity
The feasibility study completed as part of the noise prediction exercise carried out by Independent Environmental Consultancy Limited has shown that NPPG noise criterion can be met at the nearest noise-sensitive receptor positions. Any future planning application for mineral extraction at this site will include a further noise and dust assessment and outline mitigation measures to deal appropriately with any amenity impacts.

Historic Environment
Following the findings from the Heritage Appraisal carried out by independent consultants Andrew Josephs Associates. It is proposed that any future planning application for mineral extraction at this site will include a further Heritage Statement to identify heritage assets and their settings, assess the potential for impacts and identify appropriate mitigation measures if required.

Archaeology
Following the archaeological background section included in the Heritage Appraisal carried out by independent consultants Andrew Josephs Associates. It is proposed that any future planning application will be accompanied by an assessment of the significance of archaeological remains, in order to protect and mitigate the impact of mineral extraction on this site.

Landscape
It is considered that the sightlines sections drawing no. W12_LAN_006 submitted in support of MIN 32 allocation at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review in August 2018, demonstrates that the site will not have any adverse effects on the existing landscape given the implementation of appropriately designed screening bunds, existing and proposed planting.

It is proposed that all screening bunds shall have shallow outer slopes and are to be sown to grassland at the first available opportunity to match the adjacent fields. The screening bunds will be 3m in height with 1 in 5 outer slopes on the eastern and northern boundaries and 1 in 10 outer slopes on the southern boundary. Furthermore, where possible it is proposed to reinforce the existing planting in advance of mineral workings and also the planting of an additional hedgerow along the southern boundary to aid screening, as illustrated in the supporting concept development plan drawing no. W12_LAN_004.

Therefore, it can be demonstrated by these sightline sections that once the above mitigation proposals have been implemented as per the concept development plan the site will not afford any views to potential external sensitive receptors. Any future planning application for mineral extraction at this site will include a further landscape assessment and scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents.

I therefore wish to object to paragraph M32.6 Landscape: suggesting that the conclusions reached in terms of screening the views from West Dereham, A134, Lime Kiln Road and Bath Road Area are reconsidered to take account for the sightline sections included in the amended MIN 32 representation at the 'Initial Consultation' stage of the Plan, that clearly demonstrate given the mitigation proposals above that suitable screening can be implemented. Furthermore, I wish to object to the conclusions drawn regarding the screening or bunding being intrusive in the open landscape, as it has been specifically designed to have shallow outer slopes and to be sown to grassland at the first available opportunity to match the adjacent field, and therefore blending into the surrounding agricultural landscaping setting.

Ecology
Following the Ecological Scoping Report carried out by independent consultants The Landscape Partnership in support of the original representation. It is proposed that any future planning application will be accompanied by an assessment of potential impacts, including from dust deposition and hydrogeology, together with appropriate mitigation on all designated sites within the vicinity of the site.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.56 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Furthermore, it should be considered that under the current adopted Norfolk Minerals and Waste Development Framework Core Strategy and Minerals and Waste Development Management Policies Development Plan Document 2010-2026, Core Strategy Policy CS2 - General locations for mineral extraction and associated facilities MIN 32 is proposed as an extension to an existing site and therefore will be preferred by the MPA to new sites. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Amenity Impact & Mitigation Report (Ref. IEC/3674/01/AVH) dated 03 August 2017
Heritage Appraisal (No Reference) dated July 2017
Concept Development Plan (Drawing No. W12_LAN_004)
Concept Restoration Plan (Drawing No. W12_LAN_005)
Sightline Sections (Drawing No. W12_LAN_006)
Sightline Locations (Drawing No. W12_LAN_007)
Ecological Scoping Report (Ref. E17855) dated 21 July 2017

Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 35 - land at Heath Road, Eccles, Quidenham)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 35 for the reasons outlined below.

Landscape
Following the initial findings of the Preferred Options Consolation a Landscape and Visual Statement was commissioned and completed by Collington Winters in October 2019. The report demonstrates and concludes that the site would have acceptable local landscape impacts and that the screening would not be intrusive in its own right. The report also recommends that it will be possible to mitigate adverse landscape impacts through advance planting and bunding.

It is highlighted in the enclosed Landscape and Visual Statement that the proposed site is not located within the AONB, a Core River Valley or any other designated landscape features. It must be noted that unlike MIN 69 - land north of Holt Road, Aylmerton, MIN 211 - land west of Bath Hills Road, Earsham (Extension area 3) which is adjacent to the boundary of the Broads Authority Executive Area and MIN 25 - land at Manor Farm (between Loddon Road and Thorpe Road), Haddiscoe which is adjacent to a Core River Valley and also is adjacent to the boundary of the Broads Authority Executive Area).

The enclosed report also demonstrates that the existing landscape detractors mean that the proposed site cannot be considered a tranquil, unspoilt area of the countryside.
The proposal sets the limit of extraction approximately 150 metres from the southern boundary of the site, so as to allow the site to be screened in a way which would not be significantly detrimental to the views from the immediate south. Existing bunding associated with the historic landfill is present which already screens out long-range views for properties to the south of the proposed site.
The proposed new bunding associated with the MIN 35 development will be set back from the southern boundary so as to not have an adverse effect on views over the field and the woodland to the west from those properties to the south of the site. The proposed limit of extraction means that there would be less difference between the views of the existing bunding associated with the historic landfill and those of new bunding associated with this proposed development from the south and southeast of the site.

Screen bunding and advance hedge planting is proposed along the site boundary on Heath Road to ensure that users of Heath Road are not able to gain medium-to-long-range views across the site, including the existing partially screened timber yard opposite the area of the site not proposed to be worked.

Any future application for mineral extractions at this site will be accompanied with a
further carefully designed landscape scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents. Substantial buffer zones are proposed comprising advanced planting of woodland copses and planting belts, that are to be retained within the site restoration, and screen bunds in place surrounding the immediate area proposed for mineral extraction.

The temporary bunds are proposed to be of adequate height to screen the upper story views from housing and it will be ensured that the grading, profiles appearance and management of vegetation on the temporary bunds will benefit from careful treatment. These mitigation requirements shall be followed to ensure that the screening features are not visually intrusive as it is recognised that residents may have views of these across the existing agricultural fields to the east and southwest of the site, and also from the adjacent road.

I therefore wish to object to the conclusions reached in terms of considering MIN 35 unsuitable for allocation in landscape terms, as following a review of baseline information, together with consideration of likely landscape and visual effects, it is considered that the application site and wider landscape is able to accommodate the proposal for mineral extraction, in landscape and visual terms, without having an unacceptable effect or loss of landscape character or visual amenity. Any loss of landscape character would be temporary and upon restoration, character would be reinforced and enhanced.

Provision for minerals extraction (Policy MP1)
The NPPG suggests that the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision. The sub-national guidelines are for Norfolk to produce 2.57 million tonnes of sand and gravel a year.
It has been considered by the MPA that planning to provide the 20-year average annual production figure would enable a sufficient quantity of sand and gravel resources to be available over the 18- year plan period and would take into account potential fluctuations in the economy.
Over the 18-year plan period to 2036, using the considered suitable 20-year average of 1.868 million tpa, 33.624 million tonnes of sand and gravel resources would be needed in total. Taking into account the existing permitted reserve, the remaining need for allocated sites is 20.313 million tonnes of sand and gravel.
However, using the sub-national guidelines for sand and gravel, as specified in the NPPG this would mean that sites for 32,949,300 tonnes of sand and gravel extraction would need to be allocated over the plan period. The sub-national guideline figures cover the period 2005-2020 and therefore remains current at this stage of the Consultation process, and must remain so until these figures are updated. Therefore, a stronger case has to be made by the MPA as to why they consider the current subnational guidelines not to be relevant in producing this plan and more specifically the landbank figure required in the Plan period to the end of 2036. Furthermore, may I raise the question to the MPA as to what the justification is for using a 20-year average annual production figure, rather than a 25-year
average or likewise 18-year to cover the remainder of the plan period, for example?

I therefore wish to object to the methodology used in establishing the required tonnages of sand and gravel resource to be allocated within the Plan period to the end 2036 as referred to in Policy MP1: Provisions of minerals extraction. The 20-year average methodology has not been accepted as a valid methodology for establishing this figure and therefore should not be considered as sound. This is demonstrated by the NPPG which considers that only the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision.

I would consequently like to object to this figure in relation to MIN 35, which at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review was considered as suitable for allocation based on the proposed 20-year average annual production figure in August 2018.

However, the current proposed allocation figure less than 18 months later is greatly reduced and is considered the only reason for the site to now be considered as unsuitable, due to the fact that the proposals have not changed in terms of the site development since that date.

Suitability of alternatives considered as suitable for allocation
There are a number of sites that have been considered suitable for allocation in the Norfolk Minerals and Waste Local Plan Review that are very similar to MIN 35 in terms of their potential impact on the local landscape from viewpoints from surrounding sensitive receptors. The table below and subsequent consultation extracts identifies and breaks down each site in terms of the number of sensitive receptors within 250m and 100m of the proposed extraction area compared with MIN 35, respectively. Therefore, on a logical comparative basis MIN 35 sits within the top three of the proposed sites with the least number of sensitive receptors.

INSERT TABLE

MIN 210 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from Park Farm Cottages will predominantly be screened by bunding"

MIN 211 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from nearby properties will predominantly be screened by bunding"

MIN 65 "glimpses of the land can be seen from Frettenham Road to the west through gaps in boundary hedges. Views could also be seen from two properties which lie close to the site perimeter to the west and east respectively"

MIN 213 "views into the site may be possible from Shorthorn Road, through the proposed entrance"

MIN 25 "there are mature screen planting forming hedgerows on all sides of the site, except a section of the eastern boundary closest to Manor Farm"

MIN 12 "views of the site would be seen from Field Lane, a road used as a public path which bounds the site to the north. In addition, the southern part of the site is slightly elevated and may be visible in a long view from public paths crossing land to the north of the Whitewater valley"

MIN 209 "a number of properties back onto the road overlook the site, the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting"

The above findings were concluded by the MPA as being acceptable subject to the erection of screen bunds and advanced planting. Likewise, it is stated that any potential views of MIN 35 would require mitigation through screen bunding and advance hedge planting. Therefore, given the supporting information above, as part of the independent Landscape and Visual Statement, it is considered that the MIN 35 site should be considered suitable for allocation due to the similarities it shares in landscape terms with the above sites that themselves have been considered suitable for allocation.

Furthermore, three sites have been considered suitable for allocation that are either within or adjacent to the AONB, a Core River Valley or any other designated landscape features, namely MIN 69, MIN 211 and MIN 25. Since MIN 35 is not located within or even close to any of these designated landscape features, preference must be given to this site in planning terms as required by the
requirements of NPPF Paragraph 205.

Since the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review and additional site has come forward and is now considered as suitable for allocation in the 'Preferred Options Consultation'. This is MIN 213 land at Mansom Plantation, Stratton Strawless for a total estimated sand and gravel resource of 1 million tonnes. The site has been selected in preference to MIN 35, due to the fact that the MIN 35 site was formerly considered as suitable for allocation at the 'Initial Consultation' stage. However, it is considered that this new site (MIN 213) not only presents a similar landscape impact to MIN 35 as described above, but also represents a site that will result in the permanent loss of a well-established coniferous plantation for after use as a holiday lodge development. MIN 213 is also located adjacent to an ancient replanted woodland to which deterioration is likely to occur as a result of the mineral operation. As such, any application that concludes this unless there are wholly exceptional reasons should be refused as in accordance with NPPF Paragraph 175c. Therefore, the site cannot be considered as being suitable for allocation given this likely impact.

I therefore would like to object to the inclusion of the above sites as being considered suitable for allocation, whereas MIN 35 is considered unsuitable solely on landscape grounds. It has been demonstrated above that preference should not be given to any of these sites over and above MIN 35 and that MIN 35 should be reconsidered in light of the additional supporting landscape and visual statement and be concluded as once again suitable for allocation as at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.5 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Landscape and Visual Statement (Ref. CW0121-RPT-001), dated 30 October 2019
Ecological Scoping Report (Ref. E17864), dated 2 August 2017

Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 35 - land at Heath Road, Eccles, Quidenham)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 35 for the reasons outlined below.

Landscape
Following the initial findings of the Preferred Options Consolation a Landscape and Visual Statement was commissioned and completed by Collington Winters in October 2019. The report demonstrates and concludes that the site would have acceptable local landscape impacts and that the screening would not be intrusive in its own right. The report also recommends that it will be possible to mitigate adverse landscape impacts through advance planting and bunding.

It is highlighted in the enclosed Landscape and Visual Statement that the proposed site is not located within the AONB, a Core River Valley or any other designated landscape features. It must be noted that unlike MIN 69 - land north of Holt Road, Aylmerton, MIN 211 - land west of Bath Hills Road, Earsham (Extension area 3) which is adjacent to the boundary of the Broads Authority Executive Area and MIN 25 - land at Manor Farm (between Loddon Road and Thorpe Road), Haddiscoe which is adjacent to a Core River Valley and also is adjacent to the boundary of the Broads Authority Executive Area).

The enclosed report also demonstrates that the existing landscape detractors mean that the proposed site cannot be considered a tranquil, unspoilt area of the countryside.
The proposal sets the limit of extraction approximately 150 metres from the southern boundary of the site, so as to allow the site to be screened in a way which would not be significantly detrimental to the views from the immediate south. Existing bunding associated with the historic landfill is present which already screens out long-range views for properties to the south of the proposed site.
The proposed new bunding associated with the MIN 35 development will be set back from the southern boundary so as to not have an adverse effect on views over the field and the woodland to the west from those properties to the south of the site. The proposed limit of extraction means that there would be less difference between the views of the existing bunding associated with the historic landfill and those of new bunding associated with this proposed development from the south and southeast of the site.

Screen bunding and advance hedge planting is proposed along the site boundary on Heath Road to ensure that users of Heath Road are not able to gain medium-to-long-range views across the site, including the existing partially screened timber yard opposite the area of the site not proposed to be worked.

Any future application for mineral extractions at this site will be accompanied with a
further carefully designed landscape scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents. Substantial buffer zones are proposed comprising advanced planting of woodland copses and planting belts, that are to be retained within the site restoration, and screen bunds in place surrounding the immediate area proposed for mineral extraction.

The temporary bunds are proposed to be of adequate height to screen the upper story views from housing and it will be ensured that the grading, profiles appearance and management of vegetation on the temporary bunds will benefit from careful treatment. These mitigation requirements shall be followed to ensure that the screening features are not visually intrusive as it is recognised that residents may have views of these across the existing agricultural fields to the east and southwest of the site, and also from the adjacent road.

I therefore wish to object to the conclusions reached in terms of considering MIN 35 unsuitable for allocation in landscape terms, as following a review of baseline information, together with consideration of likely landscape and visual effects, it is considered that the application site and wider landscape is able to accommodate the proposal for mineral extraction, in landscape and visual terms, without having an unacceptable effect or loss of landscape character or visual amenity. Any loss of landscape character would be temporary and upon restoration, character would be reinforced and enhanced.

Provision for minerals extraction (Policy MP1)
The NPPG suggests that the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision. The sub-national guidelines are for Norfolk to produce 2.57 million tonnes of sand and gravel a year.
It has been considered by the MPA that planning to provide the 20-year average annual production figure would enable a sufficient quantity of sand and gravel resources to be available over the 18- year plan period and would take into account potential fluctuations in the economy.
Over the 18-year plan period to 2036, using the considered suitable 20-year average of 1.868 million tpa, 33.624 million tonnes of sand and gravel resources would be needed in total. Taking into account the existing permitted reserve, the remaining need for allocated sites is 20.313 million tonnes of sand and gravel.
However, using the sub-national guidelines for sand and gravel, as specified in the NPPG this would mean that sites for 32,949,300 tonnes of sand and gravel extraction would need to be allocated over the plan period. The sub-national guideline figures cover the period 2005-2020 and therefore remains current at this stage of the Consultation process, and must remain so until these figures are updated. Therefore, a stronger case has to be made by the MPA as to why they consider the current subnational guidelines not to be relevant in producing this plan and more specifically the landbank figure required in the Plan period to the end of 2036. Furthermore, may I raise the question to the MPA as to what the justification is for using a 20-year average annual production figure, rather than a 25-year
average or likewise 18-year to cover the remainder of the plan period, for example?

I therefore wish to object to the methodology used in establishing the required tonnages of sand and gravel resource to be allocated within the Plan period to the end 2036 as referred to in Policy MP1: Provisions of minerals extraction. The 20-year average methodology has not been accepted as a valid methodology for establishing this figure and therefore should not be considered as sound. This is demonstrated by the NPPG which considers that only the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision.

I would consequently like to object to this figure in relation to MIN 35, which at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review was considered as suitable for allocation based on the proposed 20-year average annual production figure in August 2018.

However, the current proposed allocation figure less than 18 months later is greatly reduced and is considered the only reason for the site to now be considered as unsuitable, due to the fact that the proposals have not changed in terms of the site development since that date.

Suitability of alternatives considered as suitable for allocation
There are a number of sites that have been considered suitable for allocation in the Norfolk Minerals and Waste Local Plan Review that are very similar to MIN 35 in terms of their potential impact on the local landscape from viewpoints from surrounding sensitive receptors. The table below and subsequent consultation extracts identifies and breaks down each site in terms of the number of sensitive receptors within 250m and 100m of the proposed extraction area compared with MIN 35, respectively. Therefore, on a logical comparative basis MIN 35 sits within the top three of the proposed sites with the least number of sensitive receptors.

INSERT TABLE

MIN 210 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from Park Farm Cottages will predominantly be screened by bunding"

MIN 211 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from nearby properties will predominantly be screened by bunding"

MIN 65 "glimpses of the land can be seen from Frettenham Road to the west through gaps in boundary hedges. Views could also be seen from two properties which lie close to the site perimeter to the west and east respectively"

MIN 213 "views into the site may be possible from Shorthorn Road, through the proposed entrance"

MIN 25 "there are mature screen planting forming hedgerows on all sides of the site, except a section of the eastern boundary closest to Manor Farm"

MIN 12 "views of the site would be seen from Field Lane, a road used as a public path which bounds the site to the north. In addition, the southern part of the site is slightly elevated and may be visible in a long view from public paths crossing land to the north of the Whitewater valley"

MIN 209 "a number of properties back onto the road overlook the site, the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting"

The above findings were concluded by the MPA as being acceptable subject to the erection of screen bunds and advanced planting. Likewise, it is stated that any potential views of MIN 35 would require mitigation through screen bunding and advance hedge planting. Therefore, given the supporting information above, as part of the independent Landscape and Visual Statement, it is considered that the MIN 35 site should be considered suitable for allocation due to the similarities it shares in landscape terms with the above sites that themselves have been considered suitable for allocation.

Furthermore, three sites have been considered suitable for allocation that are either within or adjacent to the AONB, a Core River Valley or any other designated landscape features, namely MIN 69, MIN 211 and MIN 25. Since MIN 35 is not located within or even close to any of these designated landscape features, preference must be given to this site in planning terms as required by the
requirements of NPPF Paragraph 205.

Since the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review and additional site has come forward and is now considered as suitable for allocation in the 'Preferred Options Consultation'. This is MIN 213 land at Mansom Plantation, Stratton Strawless for a total estimated sand and gravel resource of 1 million tonnes. The site has been selected in preference to MIN 35, due to the fact that the MIN 35 site was formerly considered as suitable for allocation at the 'Initial Consultation' stage. However, it is considered that this new site (MIN 213) not only presents a similar landscape impact to MIN 35 as described above, but also represents a site that will result in the permanent loss of a well-established coniferous plantation for after use as a holiday lodge development. MIN 213 is also located adjacent to an ancient replanted woodland to which deterioration is likely to occur as a result of the mineral operation. As such, any application that concludes this unless there are wholly exceptional reasons should be refused as in accordance with NPPF Paragraph 175c. Therefore, the site cannot be considered as being suitable for allocation given this likely impact.

I therefore would like to object to the inclusion of the above sites as being considered suitable for allocation, whereas MIN 35 is considered unsuitable solely on landscape grounds. It has been demonstrated above that preference should not be given to any of these sites over and above MIN 35 and that MIN 35 should be reconsidered in light of the additional supporting landscape and visual statement and be concluded as once again suitable for allocation as at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.5 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Landscape and Visual Statement (Ref. CW0121-RPT-001), dated 30 October 2019
Ecological Scoping Report (Ref. E17864), dated 2 August 2017

Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 35 - land at Heath Road, Eccles, Quidenham)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 35 for the reasons outlined below.

Landscape
Following the initial findings of the Preferred Options Consolation a Landscape and Visual Statement was commissioned and completed by Collington Winters in October 2019. The report demonstrates and concludes that the site would have acceptable local landscape impacts and that the screening would not be intrusive in its own right. The report also recommends that it will be possible to mitigate adverse landscape impacts through advance planting and bunding.

It is highlighted in the enclosed Landscape and Visual Statement that the proposed site is not located within the AONB, a Core River Valley or any other designated landscape features. It must be noted that unlike MIN 69 - land north of Holt Road, Aylmerton, MIN 211 - land west of Bath Hills Road, Earsham (Extension area 3) which is adjacent to the boundary of the Broads Authority Executive Area and MIN 25 - land at Manor Farm (between Loddon Road and Thorpe Road), Haddiscoe which is adjacent to a Core River Valley and also is adjacent to the boundary of the Broads Authority Executive Area).

The enclosed report also demonstrates that the existing landscape detractors mean that the proposed site cannot be considered a tranquil, unspoilt area of the countryside.
The proposal sets the limit of extraction approximately 150 metres from the southern boundary of the site, so as to allow the site to be screened in a way which would not be significantly detrimental to the views from the immediate south. Existing bunding associated with the historic landfill is present which already screens out long-range views for properties to the south of the proposed site.
The proposed new bunding associated with the MIN 35 development will be set back from the southern boundary so as to not have an adverse effect on views over the field and the woodland to the west from those properties to the south of the site. The proposed limit of extraction means that there would be less difference between the views of the existing bunding associated with the historic landfill and those of new bunding associated with this proposed development from the south and southeast of the site.

Screen bunding and advance hedge planting is proposed along the site boundary on Heath Road to ensure that users of Heath Road are not able to gain medium-to-long-range views across the site, including the existing partially screened timber yard opposite the area of the site not proposed to be worked.

Any future application for mineral extractions at this site will be accompanied with a
further carefully designed landscape scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents. Substantial buffer zones are proposed comprising advanced planting of woodland copses and planting belts, that are to be retained within the site restoration, and screen bunds in place surrounding the immediate area proposed for mineral extraction.

The temporary bunds are proposed to be of adequate height to screen the upper story views from housing and it will be ensured that the grading, profiles appearance and management of vegetation on the temporary bunds will benefit from careful treatment. These mitigation requirements shall be followed to ensure that the screening features are not visually intrusive as it is recognised that residents may have views of these across the existing agricultural fields to the east and southwest of the site, and also from the adjacent road.

I therefore wish to object to the conclusions reached in terms of considering MIN 35 unsuitable for allocation in landscape terms, as following a review of baseline information, together with consideration of likely landscape and visual effects, it is considered that the application site and wider landscape is able to accommodate the proposal for mineral extraction, in landscape and visual terms, without having an unacceptable effect or loss of landscape character or visual amenity. Any loss of landscape character would be temporary and upon restoration, character would be reinforced and enhanced.

Provision for minerals extraction (Policy MP1)
The NPPG suggests that the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision. The sub-national guidelines are for Norfolk to produce 2.57 million tonnes of sand and gravel a year.
It has been considered by the MPA that planning to provide the 20-year average annual production figure would enable a sufficient quantity of sand and gravel resources to be available over the 18- year plan period and would take into account potential fluctuations in the economy.
Over the 18-year plan period to 2036, using the considered suitable 20-year average of 1.868 million tpa, 33.624 million tonnes of sand and gravel resources would be needed in total. Taking into account the existing permitted reserve, the remaining need for allocated sites is 20.313 million tonnes of sand and gravel.
However, using the sub-national guidelines for sand and gravel, as specified in the NPPG this would mean that sites for 32,949,300 tonnes of sand and gravel extraction would need to be allocated over the plan period. The sub-national guideline figures cover the period 2005-2020 and therefore remains current at this stage of the Consultation process, and must remain so until these figures are updated. Therefore, a stronger case has to be made by the MPA as to why they consider the current subnational guidelines not to be relevant in producing this plan and more specifically the landbank figure required in the Plan period to the end of 2036. Furthermore, may I raise the question to the MPA as to what the justification is for using a 20-year average annual production figure, rather than a 25-year
average or likewise 18-year to cover the remainder of the plan period, for example?

I therefore wish to object to the methodology used in establishing the required tonnages of sand and gravel resource to be allocated within the Plan period to the end 2036 as referred to in Policy MP1: Provisions of minerals extraction. The 20-year average methodology has not been accepted as a valid methodology for establishing this figure and therefore should not be considered as sound. This is demonstrated by the NPPG which considers that only the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision.

I would consequently like to object to this figure in relation to MIN 35, which at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review was considered as suitable for allocation based on the proposed 20-year average annual production figure in August 2018.

However, the current proposed allocation figure less than 18 months later is greatly reduced and is considered the only reason for the site to now be considered as unsuitable, due to the fact that the proposals have not changed in terms of the site development since that date.

Suitability of alternatives considered as suitable for allocation
There are a number of sites that have been considered suitable for allocation in the Norfolk Minerals and Waste Local Plan Review that are very similar to MIN 35 in terms of their potential impact on the local landscape from viewpoints from surrounding sensitive receptors. The table below and subsequent consultation extracts identifies and breaks down each site in terms of the number of sensitive receptors within 250m and 100m of the proposed extraction area compared with MIN 35, respectively. Therefore, on a logical comparative basis MIN 35 sits within the top three of the proposed sites with the least number of sensitive receptors.

INSERT TABLE

MIN 210 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from Park Farm Cottages will predominantly be screened by bunding"

MIN 211 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from nearby properties will predominantly be screened by bunding"

MIN 65 "glimpses of the land can be seen from Frettenham Road to the west through gaps in boundary hedges. Views could also be seen from two properties which lie close to the site perimeter to the west and east respectively"

MIN 213 "views into the site may be possible from Shorthorn Road, through the proposed entrance"

MIN 25 "there are mature screen planting forming hedgerows on all sides of the site, except a section of the eastern boundary closest to Manor Farm"

MIN 12 "views of the site would be seen from Field Lane, a road used as a public path which bounds the site to the north. In addition, the southern part of the site is slightly elevated and may be visible in a long view from public paths crossing land to the north of the Whitewater valley"

MIN 209 "a number of properties back onto the road overlook the site, the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting"

The above findings were concluded by the MPA as being acceptable subject to the erection of screen bunds and advanced planting. Likewise, it is stated that any potential views of MIN 35 would require mitigation through screen bunding and advance hedge planting. Therefore, given the supporting information above, as part of the independent Landscape and Visual Statement, it is considered that the MIN 35 site should be considered suitable for allocation due to the similarities it shares in landscape terms with the above sites that themselves have been considered suitable for allocation.

Furthermore, three sites have been considered suitable for allocation that are either within or adjacent to the AONB, a Core River Valley or any other designated landscape features, namely MIN 69, MIN 211 and MIN 25. Since MIN 35 is not located within or even close to any of these designated landscape features, preference must be given to this site in planning terms as required by the
requirements of NPPF Paragraph 205.

Since the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review and additional site has come forward and is now considered as suitable for allocation in the 'Preferred Options Consultation'. This is MIN 213 land at Mansom Plantation, Stratton Strawless for a total estimated sand and gravel resource of 1 million tonnes. The site has been selected in preference to MIN 35, due to the fact that the MIN 35 site was formerly considered as suitable for allocation at the 'Initial Consultation' stage. However, it is considered that this new site (MIN 213) not only presents a similar landscape impact to MIN 35 as described above, but also represents a site that will result in the permanent loss of a well-established coniferous plantation for after use as a holiday lodge development. MIN 213 is also located adjacent to an ancient replanted woodland to which deterioration is likely to occur as a result of the mineral operation. As such, any application that concludes this unless there are wholly exceptional reasons should be refused as in accordance with NPPF Paragraph 175c. Therefore, the site cannot be considered as being suitable for allocation given this likely impact.

I therefore would like to object to the inclusion of the above sites as being considered suitable for allocation, whereas MIN 35 is considered unsuitable solely on landscape grounds. It has been demonstrated above that preference should not be given to any of these sites over and above MIN 35 and that MIN 35 should be reconsidered in light of the additional supporting landscape and visual statement and be concluded as once again suitable for allocation as at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.5 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Landscape and Visual Statement (Ref. CW0121-RPT-001), dated 30 October 2019
Ecological Scoping Report (Ref. E17864), dated 2 August 2017

Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 35 - land at Heath Road, Eccles, Quidenham)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 35 for the reasons outlined below.

Landscape
Following the initial findings of the Preferred Options Consolation a Landscape and Visual Statement was commissioned and completed by Collington Winters in October 2019. The report demonstrates and concludes that the site would have acceptable local landscape impacts and that the screening would not be intrusive in its own right. The report also recommends that it will be possible to mitigate adverse landscape impacts through advance planting and bunding.

It is highlighted in the enclosed Landscape and Visual Statement that the proposed site is not located within the AONB, a Core River Valley or any other designated landscape features. It must be noted that unlike MIN 69 - land north of Holt Road, Aylmerton, MIN 211 - land west of Bath Hills Road, Earsham (Extension area 3) which is adjacent to the boundary of the Broads Authority Executive Area and MIN 25 - land at Manor Farm (between Loddon Road and Thorpe Road), Haddiscoe which is adjacent to a Core River Valley and also is adjacent to the boundary of the Broads Authority Executive Area).

The enclosed report also demonstrates that the existing landscape detractors mean that the proposed site cannot be considered a tranquil, unspoilt area of the countryside.
The proposal sets the limit of extraction approximately 150 metres from the southern boundary of the site, so as to allow the site to be screened in a way which would not be significantly detrimental to the views from the immediate south. Existing bunding associated with the historic landfill is present which already screens out long-range views for properties to the south of the proposed site.
The proposed new bunding associated with the MIN 35 development will be set back from the southern boundary so as to not have an adverse effect on views over the field and the woodland to the west from those properties to the south of the site. The proposed limit of extraction means that there would be less difference between the views of the existing bunding associated with the historic landfill and those of new bunding associated with this proposed development from the south and southeast of the site.

Screen bunding and advance hedge planting is proposed along the site boundary on Heath Road to ensure that users of Heath Road are not able to gain medium-to-long-range views across the site, including the existing partially screened timber yard opposite the area of the site not proposed to be worked.

Any future application for mineral extractions at this site will be accompanied with a
further carefully designed landscape scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents. Substantial buffer zones are proposed comprising advanced planting of woodland copses and planting belts, that are to be retained within the site restoration, and screen bunds in place surrounding the immediate area proposed for mineral extraction.

The temporary bunds are proposed to be of adequate height to screen the upper story views from housing and it will be ensured that the grading, profiles appearance and management of vegetation on the temporary bunds will benefit from careful treatment. These mitigation requirements shall be followed to ensure that the screening features are not visually intrusive as it is recognised that residents may have views of these across the existing agricultural fields to the east and southwest of the site, and also from the adjacent road.

I therefore wish to object to the conclusions reached in terms of considering MIN 35 unsuitable for allocation in landscape terms, as following a review of baseline information, together with consideration of likely landscape and visual effects, it is considered that the application site and wider landscape is able to accommodate the proposal for mineral extraction, in landscape and visual terms, without having an unacceptable effect or loss of landscape character or visual amenity. Any loss of landscape character would be temporary and upon restoration, character would be reinforced and enhanced.

Provision for minerals extraction (Policy MP1)
The NPPG suggests that the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision. The sub-national guidelines are for Norfolk to produce 2.57 million tonnes of sand and gravel a year.
It has been considered by the MPA that planning to provide the 20-year average annual production figure would enable a sufficient quantity of sand and gravel resources to be available over the 18- year plan period and would take into account potential fluctuations in the economy.
Over the 18-year plan period to 2036, using the considered suitable 20-year average of 1.868 million tpa, 33.624 million tonnes of sand and gravel resources would be needed in total. Taking into account the existing permitted reserve, the remaining need for allocated sites is 20.313 million tonnes of sand and gravel.
However, using the sub-national guidelines for sand and gravel, as specified in the NPPG this would mean that sites for 32,949,300 tonnes of sand and gravel extraction would need to be allocated over the plan period. The sub-national guideline figures cover the period 2005-2020 and therefore remains current at this stage of the Consultation process, and must remain so until these figures are updated. Therefore, a stronger case has to be made by the MPA as to why they consider the current subnational guidelines not to be relevant in producing this plan and more specifically the landbank figure required in the Plan period to the end of 2036. Furthermore, may I raise the question to the MPA as to what the justification is for using a 20-year average annual production figure, rather than a 25-year
average or likewise 18-year to cover the remainder of the plan period, for example?

I therefore wish to object to the methodology used in establishing the required tonnages of sand and gravel resource to be allocated within the Plan period to the end 2036 as referred to in Policy MP1: Provisions of minerals extraction. The 20-year average methodology has not been accepted as a valid methodology for establishing this figure and therefore should not be considered as sound. This is demonstrated by the NPPG which considers that only the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision.

I would consequently like to object to this figure in relation to MIN 35, which at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review was considered as suitable for allocation based on the proposed 20-year average annual production figure in August 2018.

However, the current proposed allocation figure less than 18 months later is greatly reduced and is considered the only reason for the site to now be considered as unsuitable, due to the fact that the proposals have not changed in terms of the site development since that date.

Suitability of alternatives considered as suitable for allocation
There are a number of sites that have been considered suitable for allocation in the Norfolk Minerals and Waste Local Plan Review that are very similar to MIN 35 in terms of their potential impact on the local landscape from viewpoints from surrounding sensitive receptors. The table below and subsequent consultation extracts identifies and breaks down each site in terms of the number of sensitive receptors within 250m and 100m of the proposed extraction area compared with MIN 35, respectively. Therefore, on a logical comparative basis MIN 35 sits within the top three of the proposed sites with the least number of sensitive receptors.

INSERT TABLE

MIN 210 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from Park Farm Cottages will predominantly be screened by bunding"

MIN 211 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from nearby properties will predominantly be screened by bunding"

MIN 65 "glimpses of the land can be seen from Frettenham Road to the west through gaps in boundary hedges. Views could also be seen from two properties which lie close to the site perimeter to the west and east respectively"

MIN 213 "views into the site may be possible from Shorthorn Road, through the proposed entrance"

MIN 25 "there are mature screen planting forming hedgerows on all sides of the site, except a section of the eastern boundary closest to Manor Farm"

MIN 12 "views of the site would be seen from Field Lane, a road used as a public path which bounds the site to the north. In addition, the southern part of the site is slightly elevated and may be visible in a long view from public paths crossing land to the north of the Whitewater valley"

MIN 209 "a number of properties back onto the road overlook the site, the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting"

The above findings were concluded by the MPA as being acceptable subject to the erection of screen bunds and advanced planting. Likewise, it is stated that any potential views of MIN 35 would require mitigation through screen bunding and advance hedge planting. Therefore, given the supporting information above, as part of the independent Landscape and Visual Statement, it is considered that the MIN 35 site should be considered suitable for allocation due to the similarities it shares in landscape terms with the above sites that themselves have been considered suitable for allocation.

Furthermore, three sites have been considered suitable for allocation that are either within or adjacent to the AONB, a Core River Valley or any other designated landscape features, namely MIN 69, MIN 211 and MIN 25. Since MIN 35 is not located within or even close to any of these designated landscape features, preference must be given to this site in planning terms as required by the
requirements of NPPF Paragraph 205.

Since the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review and additional site has come forward and is now considered as suitable for allocation in the 'Preferred Options Consultation'. This is MIN 213 land at Mansom Plantation, Stratton Strawless for a total estimated sand and gravel resource of 1 million tonnes. The site has been selected in preference to MIN 35, due to the fact that the MIN 35 site was formerly considered as suitable for allocation at the 'Initial Consultation' stage. However, it is considered that this new site (MIN 213) not only presents a similar landscape impact to MIN 35 as described above, but also represents a site that will result in the permanent loss of a well-established coniferous plantation for after use as a holiday lodge development. MIN 213 is also located adjacent to an ancient replanted woodland to which deterioration is likely to occur as a result of the mineral operation. As such, any application that concludes this unless there are wholly exceptional reasons should be refused as in accordance with NPPF Paragraph 175c. Therefore, the site cannot be considered as being suitable for allocation given this likely impact.

I therefore would like to object to the inclusion of the above sites as being considered suitable for allocation, whereas MIN 35 is considered unsuitable solely on landscape grounds. It has been demonstrated above that preference should not be given to any of these sites over and above MIN 35 and that MIN 35 should be reconsidered in light of the additional supporting landscape and visual statement and be concluded as once again suitable for allocation as at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.5 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Landscape and Visual Statement (Ref. CW0121-RPT-001), dated 30 October 2019
Ecological Scoping Report (Ref. E17864), dated 2 August 2017

Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 35 - land at Heath Road, Eccles, Quidenham)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 35 for the reasons outlined below.

Landscape
Following the initial findings of the Preferred Options Consolation a Landscape and Visual Statement was commissioned and completed by Collington Winters in October 2019. The report demonstrates and concludes that the site would have acceptable local landscape impacts and that the screening would not be intrusive in its own right. The report also recommends that it will be possible to mitigate adverse landscape impacts through advance planting and bunding.

It is highlighted in the enclosed Landscape and Visual Statement that the proposed site is not located within the AONB, a Core River Valley or any other designated landscape features. It must be noted that unlike MIN 69 - land north of Holt Road, Aylmerton, MIN 211 - land west of Bath Hills Road, Earsham (Extension area 3) which is adjacent to the boundary of the Broads Authority Executive Area and MIN 25 - land at Manor Farm (between Loddon Road and Thorpe Road), Haddiscoe which is adjacent to a Core River Valley and also is adjacent to the boundary of the Broads Authority Executive Area).

The enclosed report also demonstrates that the existing landscape detractors mean that the proposed site cannot be considered a tranquil, unspoilt area of the countryside.
The proposal sets the limit of extraction approximately 150 metres from the southern boundary of the site, so as to allow the site to be screened in a way which would not be significantly detrimental to the views from the immediate south. Existing bunding associated with the historic landfill is present which already screens out long-range views for properties to the south of the proposed site.
The proposed new bunding associated with the MIN 35 development will be set back from the southern boundary so as to not have an adverse effect on views over the field and the woodland to the west from those properties to the south of the site. The proposed limit of extraction means that there would be less difference between the views of the existing bunding associated with the historic landfill and those of new bunding associated with this proposed development from the south and southeast of the site.

Screen bunding and advance hedge planting is proposed along the site boundary on Heath Road to ensure that users of Heath Road are not able to gain medium-to-long-range views across the site, including the existing partially screened timber yard opposite the area of the site not proposed to be worked.

Any future application for mineral extractions at this site will be accompanied with a
further carefully designed landscape scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents. Substantial buffer zones are proposed comprising advanced planting of woodland copses and planting belts, that are to be retained within the site restoration, and screen bunds in place surrounding the immediate area proposed for mineral extraction.

The temporary bunds are proposed to be of adequate height to screen the upper story views from housing and it will be ensured that the grading, profiles appearance and management of vegetation on the temporary bunds will benefit from careful treatment. These mitigation requirements shall be followed to ensure that the screening features are not visually intrusive as it is recognised that residents may have views of these across the existing agricultural fields to the east and southwest of the site, and also from the adjacent road.

I therefore wish to object to the conclusions reached in terms of considering MIN 35 unsuitable for allocation in landscape terms, as following a review of baseline information, together with consideration of likely landscape and visual effects, it is considered that the application site and wider landscape is able to accommodate the proposal for mineral extraction, in landscape and visual terms, without having an unacceptable effect or loss of landscape character or visual amenity. Any loss of landscape character would be temporary and upon restoration, character would be reinforced and enhanced.

Provision for minerals extraction (Policy MP1)
The NPPG suggests that the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision. The sub-national guidelines are for Norfolk to produce 2.57 million tonnes of sand and gravel a year.
It has been considered by the MPA that planning to provide the 20-year average annual production figure would enable a sufficient quantity of sand and gravel resources to be available over the 18- year plan period and would take into account potential fluctuations in the economy.
Over the 18-year plan period to 2036, using the considered suitable 20-year average of 1.868 million tpa, 33.624 million tonnes of sand and gravel resources would be needed in total. Taking into account the existing permitted reserve, the remaining need for allocated sites is 20.313 million tonnes of sand and gravel.
However, using the sub-national guidelines for sand and gravel, as specified in the NPPG this would mean that sites for 32,949,300 tonnes of sand and gravel extraction would need to be allocated over the plan period. The sub-national guideline figures cover the period 2005-2020 and therefore remains current at this stage of the Consultation process, and must remain so until these figures are updated. Therefore, a stronger case has to be made by the MPA as to why they consider the current subnational guidelines not to be relevant in producing this plan and more specifically the landbank figure required in the Plan period to the end of 2036. Furthermore, may I raise the question to the MPA as to what the justification is for using a 20-year average annual production figure, rather than a 25-year
average or likewise 18-year to cover the remainder of the plan period, for example?

I therefore wish to object to the methodology used in establishing the required tonnages of sand and gravel resource to be allocated within the Plan period to the end 2036 as referred to in Policy MP1: Provisions of minerals extraction. The 20-year average methodology has not been accepted as a valid methodology for establishing this figure and therefore should not be considered as sound. This is demonstrated by the NPPG which considers that only the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision.

I would consequently like to object to this figure in relation to MIN 35, which at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review was considered as suitable for allocation based on the proposed 20-year average annual production figure in August 2018.

However, the current proposed allocation figure less than 18 months later is greatly reduced and is considered the only reason for the site to now be considered as unsuitable, due to the fact that the proposals have not changed in terms of the site development since that date.

Suitability of alternatives considered as suitable for allocation
There are a number of sites that have been considered suitable for allocation in the Norfolk Minerals and Waste Local Plan Review that are very similar to MIN 35 in terms of their potential impact on the local landscape from viewpoints from surrounding sensitive receptors. The table below and subsequent consultation extracts identifies and breaks down each site in terms of the number of sensitive receptors within 250m and 100m of the proposed extraction area compared with MIN 35, respectively. Therefore, on a logical comparative basis MIN 35 sits within the top three of the proposed sites with the least number of sensitive receptors.

INSERT TABLE

MIN 210 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from Park Farm Cottages will predominantly be screened by bunding"

MIN 211 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from nearby properties will predominantly be screened by bunding"

MIN 65 "glimpses of the land can be seen from Frettenham Road to the west through gaps in boundary hedges. Views could also be seen from two properties which lie close to the site perimeter to the west and east respectively"

MIN 213 "views into the site may be possible from Shorthorn Road, through the proposed entrance"

MIN 25 "there are mature screen planting forming hedgerows on all sides of the site, except a section of the eastern boundary closest to Manor Farm"

MIN 12 "views of the site would be seen from Field Lane, a road used as a public path which bounds the site to the north. In addition, the southern part of the site is slightly elevated and may be visible in a long view from public paths crossing land to the north of the Whitewater valley"

MIN 209 "a number of properties back onto the road overlook the site, the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting"

The above findings were concluded by the MPA as being acceptable subject to the erection of screen bunds and advanced planting. Likewise, it is stated that any potential views of MIN 35 would require mitigation through screen bunding and advance hedge planting. Therefore, given the supporting information above, as part of the independent Landscape and Visual Statement, it is considered that the MIN 35 site should be considered suitable for allocation due to the similarities it shares in landscape terms with the above sites that themselves have been considered suitable for allocation.

Furthermore, three sites have been considered suitable for allocation that are either within or adjacent to the AONB, a Core River Valley or any other designated landscape features, namely MIN 69, MIN 211 and MIN 25. Since MIN 35 is not located within or even close to any of these designated landscape features, preference must be given to this site in planning terms as required by the
requirements of NPPF Paragraph 205.

Since the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review and additional site has come forward and is now considered as suitable for allocation in the 'Preferred Options Consultation'. This is MIN 213 land at Mansom Plantation, Stratton Strawless for a total estimated sand and gravel resource of 1 million tonnes. The site has been selected in preference to MIN 35, due to the fact that the MIN 35 site was formerly considered as suitable for allocation at the 'Initial Consultation' stage. However, it is considered that this new site (MIN 213) not only presents a similar landscape impact to MIN 35 as described above, but also represents a site that will result in the permanent loss of a well-established coniferous plantation for after use as a holiday lodge development. MIN 213 is also located adjacent to an ancient replanted woodland to which deterioration is likely to occur as a result of the mineral operation. As such, any application that concludes this unless there are wholly exceptional reasons should be refused as in accordance with NPPF Paragraph 175c. Therefore, the site cannot be considered as being suitable for allocation given this likely impact.

I therefore would like to object to the inclusion of the above sites as being considered suitable for allocation, whereas MIN 35 is considered unsuitable solely on landscape grounds. It has been demonstrated above that preference should not be given to any of these sites over and above MIN 35 and that MIN 35 should be reconsidered in light of the additional supporting landscape and visual statement and be concluded as once again suitable for allocation as at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.5 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Landscape and Visual Statement (Ref. CW0121-RPT-001), dated 30 October 2019
Ecological Scoping Report (Ref. E17864), dated 2 August 2017

Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 35 - land at Heath Road, Eccles, Quidenham)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 35 for the reasons outlined below.

Landscape
Following the initial findings of the Preferred Options Consolation a Landscape and Visual Statement was commissioned and completed by Collington Winters in October 2019. The report demonstrates and concludes that the site would have acceptable local landscape impacts and that the screening would not be intrusive in its own right. The report also recommends that it will be possible to mitigate adverse landscape impacts through advance planting and bunding.

It is highlighted in the enclosed Landscape and Visual Statement that the proposed site is not located within the AONB, a Core River Valley or any other designated landscape features. It must be noted that unlike MIN 69 - land north of Holt Road, Aylmerton, MIN 211 - land west of Bath Hills Road, Earsham (Extension area 3) which is adjacent to the boundary of the Broads Authority Executive Area and MIN 25 - land at Manor Farm (between Loddon Road and Thorpe Road), Haddiscoe which is adjacent to a Core River Valley and also is adjacent to the boundary of the Broads Authority Executive Area).

The enclosed report also demonstrates that the existing landscape detractors mean that the proposed site cannot be considered a tranquil, unspoilt area of the countryside.
The proposal sets the limit of extraction approximately 150 metres from the southern boundary of the site, so as to allow the site to be screened in a way which would not be significantly detrimental to the views from the immediate south. Existing bunding associated with the historic landfill is present which already screens out long-range views for properties to the south of the proposed site.
The proposed new bunding associated with the MIN 35 development will be set back from the southern boundary so as to not have an adverse effect on views over the field and the woodland to the west from those properties to the south of the site. The proposed limit of extraction means that there would be less difference between the views of the existing bunding associated with the historic landfill and those of new bunding associated with this proposed development from the south and southeast of the site.

Screen bunding and advance hedge planting is proposed along the site boundary on Heath Road to ensure that users of Heath Road are not able to gain medium-to-long-range views across the site, including the existing partially screened timber yard opposite the area of the site not proposed to be worked.

Any future application for mineral extractions at this site will be accompanied with a
further carefully designed landscape scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents. Substantial buffer zones are proposed comprising advanced planting of woodland copses and planting belts, that are to be retained within the site restoration, and screen bunds in place surrounding the immediate area proposed for mineral extraction.

The temporary bunds are proposed to be of adequate height to screen the upper story views from housing and it will be ensured that the grading, profiles appearance and management of vegetation on the temporary bunds will benefit from careful treatment. These mitigation requirements shall be followed to ensure that the screening features are not visually intrusive as it is recognised that residents may have views of these across the existing agricultural fields to the east and southwest of the site, and also from the adjacent road.

I therefore wish to object to the conclusions reached in terms of considering MIN 35 unsuitable for allocation in landscape terms, as following a review of baseline information, together with consideration of likely landscape and visual effects, it is considered that the application site and wider landscape is able to accommodate the proposal for mineral extraction, in landscape and visual terms, without having an unacceptable effect or loss of landscape character or visual amenity. Any loss of landscape character would be temporary and upon restoration, character would be reinforced and enhanced.

Provision for minerals extraction (Policy MP1)
The NPPG suggests that the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision. The sub-national guidelines are for Norfolk to produce 2.57 million tonnes of sand and gravel a year.
It has been considered by the MPA that planning to provide the 20-year average annual production figure would enable a sufficient quantity of sand and gravel resources to be available over the 18- year plan period and would take into account potential fluctuations in the economy.
Over the 18-year plan period to 2036, using the considered suitable 20-year average of 1.868 million tpa, 33.624 million tonnes of sand and gravel resources would be needed in total. Taking into account the existing permitted reserve, the remaining need for allocated sites is 20.313 million tonnes of sand and gravel.
However, using the sub-national guidelines for sand and gravel, as specified in the NPPG this would mean that sites for 32,949,300 tonnes of sand and gravel extraction would need to be allocated over the plan period. The sub-national guideline figures cover the period 2005-2020 and therefore remains current at this stage of the Consultation process, and must remain so until these figures are updated. Therefore, a stronger case has to be made by the MPA as to why they consider the current subnational guidelines not to be relevant in producing this plan and more specifically the landbank figure required in the Plan period to the end of 2036. Furthermore, may I raise the question to the MPA as to what the justification is for using a 20-year average annual production figure, rather than a 25-year
average or likewise 18-year to cover the remainder of the plan period, for example?

I therefore wish to object to the methodology used in establishing the required tonnages of sand and gravel resource to be allocated within the Plan period to the end 2036 as referred to in Policy MP1: Provisions of minerals extraction. The 20-year average methodology has not been accepted as a valid methodology for establishing this figure and therefore should not be considered as sound. This is demonstrated by the NPPG which considers that only the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision.

I would consequently like to object to this figure in relation to MIN 35, which at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review was considered as suitable for allocation based on the proposed 20-year average annual production figure in August 2018.

However, the current proposed allocation figure less than 18 months later is greatly reduced and is considered the only reason for the site to now be considered as unsuitable, due to the fact that the proposals have not changed in terms of the site development since that date.

Suitability of alternatives considered as suitable for allocation
There are a number of sites that have been considered suitable for allocation in the Norfolk Minerals and Waste Local Plan Review that are very similar to MIN 35 in terms of their potential impact on the local landscape from viewpoints from surrounding sensitive receptors. The table below and subsequent consultation extracts identifies and breaks down each site in terms of the number of sensitive receptors within 250m and 100m of the proposed extraction area compared with MIN 35, respectively. Therefore, on a logical comparative basis MIN 35 sits within the top three of the proposed sites with the least number of sensitive receptors.

INSERT TABLE

MIN 210 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from Park Farm Cottages will predominantly be screened by bunding"

MIN 211 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from nearby properties will predominantly be screened by bunding"

MIN 65 "glimpses of the land can be seen from Frettenham Road to the west through gaps in boundary hedges. Views could also be seen from two properties which lie close to the site perimeter to the west and east respectively"

MIN 213 "views into the site may be possible from Shorthorn Road, through the proposed entrance"

MIN 25 "there are mature screen planting forming hedgerows on all sides of the site, except a section of the eastern boundary closest to Manor Farm"

MIN 12 "views of the site would be seen from Field Lane, a road used as a public path which bounds the site to the north. In addition, the southern part of the site is slightly elevated and may be visible in a long view from public paths crossing land to the north of the Whitewater valley"

MIN 209 "a number of properties back onto the road overlook the site, the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting"

The above findings were concluded by the MPA as being acceptable subject to the erection of screen bunds and advanced planting. Likewise, it is stated that any potential views of MIN 35 would require mitigation through screen bunding and advance hedge planting. Therefore, given the supporting information above, as part of the independent Landscape and Visual Statement, it is considered that the MIN 35 site should be considered suitable for allocation due to the similarities it shares in landscape terms with the above sites that themselves have been considered suitable for allocation.

Furthermore, three sites have been considered suitable for allocation that are either within or adjacent to the AONB, a Core River Valley or any other designated landscape features, namely MIN 69, MIN 211 and MIN 25. Since MIN 35 is not located within or even close to any of these designated landscape features, preference must be given to this site in planning terms as required by the
requirements of NPPF Paragraph 205.

Since the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review and additional site has come forward and is now considered as suitable for allocation in the 'Preferred Options Consultation'. This is MIN 213 land at Mansom Plantation, Stratton Strawless for a total estimated sand and gravel resource of 1 million tonnes. The site has been selected in preference to MIN 35, due to the fact that the MIN 35 site was formerly considered as suitable for allocation at the 'Initial Consultation' stage. However, it is considered that this new site (MIN 213) not only presents a similar landscape impact to MIN 35 as described above, but also represents a site that will result in the permanent loss of a well-established coniferous plantation for after use as a holiday lodge development. MIN 213 is also located adjacent to an ancient replanted woodland to which deterioration is likely to occur as a result of the mineral operation. As such, any application that concludes this unless there are wholly exceptional reasons should be refused as in accordance with NPPF Paragraph 175c. Therefore, the site cannot be considered as being suitable for allocation given this likely impact.

I therefore would like to object to the inclusion of the above sites as being considered suitable for allocation, whereas MIN 35 is considered unsuitable solely on landscape grounds. It has been demonstrated above that preference should not be given to any of these sites over and above MIN 35 and that MIN 35 should be reconsidered in light of the additional supporting landscape and visual statement and be concluded as once again suitable for allocation as at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.5 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Landscape and Visual Statement (Ref. CW0121-RPT-001), dated 30 October 2019
Ecological Scoping Report (Ref. E17864), dated 2 August 2017

Norfolk Minerals and Waste Local Plan: Preferred Options Consultation (MIN 35 - land at Heath Road, Eccles, Quidenham)

Further to the publication of the above I would like to make the following comments on behalf of Frimstone Ltd and wish to register an Objection to the Consultation Draft and support the allocation for MIN 35 for the reasons outlined below.

Landscape
Following the initial findings of the Preferred Options Consolation a Landscape and Visual Statement was commissioned and completed by Collington Winters in October 2019. The report demonstrates and concludes that the site would have acceptable local landscape impacts and that the screening would not be intrusive in its own right. The report also recommends that it will be possible to mitigate adverse landscape impacts through advance planting and bunding.

It is highlighted in the enclosed Landscape and Visual Statement that the proposed site is not located within the AONB, a Core River Valley or any other designated landscape features. It must be noted that unlike MIN 69 - land north of Holt Road, Aylmerton, MIN 211 - land west of Bath Hills Road, Earsham (Extension area 3) which is adjacent to the boundary of the Broads Authority Executive Area and MIN 25 - land at Manor Farm (between Loddon Road and Thorpe Road), Haddiscoe which is adjacent to a Core River Valley and also is adjacent to the boundary of the Broads Authority Executive Area).

The enclosed report also demonstrates that the existing landscape detractors mean that the proposed site cannot be considered a tranquil, unspoilt area of the countryside.
The proposal sets the limit of extraction approximately 150 metres from the southern boundary of the site, so as to allow the site to be screened in a way which would not be significantly detrimental to the views from the immediate south. Existing bunding associated with the historic landfill is present which already screens out long-range views for properties to the south of the proposed site.
The proposed new bunding associated with the MIN 35 development will be set back from the southern boundary so as to not have an adverse effect on views over the field and the woodland to the west from those properties to the south of the site. The proposed limit of extraction means that there would be less difference between the views of the existing bunding associated with the historic landfill and those of new bunding associated with this proposed development from the south and southeast of the site.

Screen bunding and advance hedge planting is proposed along the site boundary on Heath Road to ensure that users of Heath Road are not able to gain medium-to-long-range views across the site, including the existing partially screened timber yard opposite the area of the site not proposed to be worked.

Any future application for mineral extractions at this site will be accompanied with a
further carefully designed landscape scheme that addresses the visual impacts that may, unless controlled, potentially affect local residents. Substantial buffer zones are proposed comprising advanced planting of woodland copses and planting belts, that are to be retained within the site restoration, and screen bunds in place surrounding the immediate area proposed for mineral extraction.

The temporary bunds are proposed to be of adequate height to screen the upper story views from housing and it will be ensured that the grading, profiles appearance and management of vegetation on the temporary bunds will benefit from careful treatment. These mitigation requirements shall be followed to ensure that the screening features are not visually intrusive as it is recognised that residents may have views of these across the existing agricultural fields to the east and southwest of the site, and also from the adjacent road.

I therefore wish to object to the conclusions reached in terms of considering MIN 35 unsuitable for allocation in landscape terms, as following a review of baseline information, together with consideration of likely landscape and visual effects, it is considered that the application site and wider landscape is able to accommodate the proposal for mineral extraction, in landscape and visual terms, without having an unacceptable effect or loss of landscape character or visual amenity. Any loss of landscape character would be temporary and upon restoration, character would be reinforced and enhanced.

Provision for minerals extraction (Policy MP1)
The NPPG suggests that the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision. The sub-national guidelines are for Norfolk to produce 2.57 million tonnes of sand and gravel a year.
It has been considered by the MPA that planning to provide the 20-year average annual production figure would enable a sufficient quantity of sand and gravel resources to be available over the 18- year plan period and would take into account potential fluctuations in the economy.
Over the 18-year plan period to 2036, using the considered suitable 20-year average of 1.868 million tpa, 33.624 million tonnes of sand and gravel resources would be needed in total. Taking into account the existing permitted reserve, the remaining need for allocated sites is 20.313 million tonnes of sand and gravel.
However, using the sub-national guidelines for sand and gravel, as specified in the NPPG this would mean that sites for 32,949,300 tonnes of sand and gravel extraction would need to be allocated over the plan period. The sub-national guideline figures cover the period 2005-2020 and therefore remains current at this stage of the Consultation process, and must remain so until these figures are updated. Therefore, a stronger case has to be made by the MPA as to why they consider the current subnational guidelines not to be relevant in producing this plan and more specifically the landbank figure required in the Plan period to the end of 2036. Furthermore, may I raise the question to the MPA as to what the justification is for using a 20-year average annual production figure, rather than a 25-year
average or likewise 18-year to cover the remainder of the plan period, for example?

I therefore wish to object to the methodology used in establishing the required tonnages of sand and gravel resource to be allocated within the Plan period to the end 2036 as referred to in Policy MP1: Provisions of minerals extraction. The 20-year average methodology has not been accepted as a valid methodology for establishing this figure and therefore should not be considered as sound. This is demonstrated by the NPPG which considers that only the 10-year rolling average, 3 year rolling average and the sub-national guidelines should all be considered in order to establish a broad understanding of current and future mineral demand, especially during reviews of planned provision.

I would consequently like to object to this figure in relation to MIN 35, which at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review was considered as suitable for allocation based on the proposed 20-year average annual production figure in August 2018.

However, the current proposed allocation figure less than 18 months later is greatly reduced and is considered the only reason for the site to now be considered as unsuitable, due to the fact that the proposals have not changed in terms of the site development since that date.

Suitability of alternatives considered as suitable for allocation
There are a number of sites that have been considered suitable for allocation in the Norfolk Minerals and Waste Local Plan Review that are very similar to MIN 35 in terms of their potential impact on the local landscape from viewpoints from surrounding sensitive receptors. The table below and subsequent consultation extracts identifies and breaks down each site in terms of the number of sensitive receptors within 250m and 100m of the proposed extraction area compared with MIN 35, respectively. Therefore, on a logical comparative basis MIN 35 sits within the top three of the proposed sites with the least number of sensitive receptors.

INSERT TABLE

MIN 210 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from Park Farm Cottages will predominantly be screened by bunding"

MIN 211 "the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting. The views of the mineral working from nearby properties will predominantly be screened by bunding"

MIN 65 "glimpses of the land can be seen from Frettenham Road to the west through gaps in boundary hedges. Views could also be seen from two properties which lie close to the site perimeter to the west and east respectively"

MIN 213 "views into the site may be possible from Shorthorn Road, through the proposed entrance"

MIN 25 "there are mature screen planting forming hedgerows on all sides of the site, except a section of the eastern boundary closest to Manor Farm"

MIN 12 "views of the site would be seen from Field Lane, a road used as a public path which bounds the site to the north. In addition, the southern part of the site is slightly elevated and may be visible in a long view from public paths crossing land to the north of the Whitewater valley"

MIN 209 "a number of properties back onto the road overlook the site, the impact of the proposed mineral working on the wider landscape would predominantly be the decreased long-distance views and increased roadside vegetation due to the proposed bunding and advanced planting"

The above findings were concluded by the MPA as being acceptable subject to the erection of screen bunds and advanced planting. Likewise, it is stated that any potential views of MIN 35 would require mitigation through screen bunding and advance hedge planting. Therefore, given the supporting information above, as part of the independent Landscape and Visual Statement, it is considered that the MIN 35 site should be considered suitable for allocation due to the similarities it shares in landscape terms with the above sites that themselves have been considered suitable for allocation.

Furthermore, three sites have been considered suitable for allocation that are either within or adjacent to the AONB, a Core River Valley or any other designated landscape features, namely MIN 69, MIN 211 and MIN 25. Since MIN 35 is not located within or even close to any of these designated landscape features, preference must be given to this site in planning terms as required by the
requirements of NPPF Paragraph 205.

Since the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review and additional site has come forward and is now considered as suitable for allocation in the 'Preferred Options Consultation'. This is MIN 213 land at Mansom Plantation, Stratton Strawless for a total estimated sand and gravel resource of 1 million tonnes. The site has been selected in preference to MIN 35, due to the fact that the MIN 35 site was formerly considered as suitable for allocation at the 'Initial Consultation' stage. However, it is considered that this new site (MIN 213) not only presents a similar landscape impact to MIN 35 as described above, but also represents a site that will result in the permanent loss of a well-established coniferous plantation for after use as a holiday lodge development. MIN 213 is also located adjacent to an ancient replanted woodland to which deterioration is likely to occur as a result of the mineral operation. As such, any application that concludes this unless there are wholly exceptional reasons should be refused as in accordance with NPPF Paragraph 175c. Therefore, the site cannot be considered as being suitable for allocation given this likely impact.

I therefore would like to object to the inclusion of the above sites as being considered suitable for allocation, whereas MIN 35 is considered unsuitable solely on landscape grounds. It has been demonstrated above that preference should not be given to any of these sites over and above MIN 35 and that MIN 35 should be reconsidered in light of the additional supporting landscape and visual statement and be concluded as once again suitable for allocation as at the 'Initial Consultation' stage of the Norfolk Minerals and Waste Local Plan Review.

Conclusion
On behalf of Frimstone Limited, I would contend that the information submitted as part of this consultation adequately addresses the reasons why this site has not been considered suitable for allocation and that the site should now be allocated. This would add only a further 0.5 million tonnes to the overall landbank figure for the plan period and be worked and restored considerably before the end of 2036. Therefore, I see no reason why these revisions should not be carried forward to adoption in the review of the Local Plan.

Enc.
Landscape and Visual Statement (Ref. CW0121-RPT-001), dated 30 October 2019
Ecological Scoping Report (Ref. E17864), dated 2 August 2017