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Anglian Water Services Limited, Stewart Patience Thank You for The Reference Respondent Representation Wish to participate in Reason Number examination? operate? - Legally Legally Compliant? Sound? Compliance with Duty to Co 102330120 Anglian Thank you for the opportunity to comment on the Water Appropriate Assessment report prepared in support of the Services Suffolk Minerals and Waste Local Plan. The following Limited, comments are submitted on behalf of Anglian Water. Stewart Having reviewed the report it doesn’t appear to raise any Patience issues of relevance to Anglian Water. Therefore we have no comments relating to the content of the Appropriate Assessment report. Should you have any queries relating to this response please let me know . 102330382 AONB Team, General Comment Overall we accept the conclusions of the Beverley Appropriate Assessment (AA) however we have a number of McClean issues to raise which are discussed below. It is not clear how the recommendations in the 2018 AA will be integrated into the Suffolk County Council Submission Minerals and Waste Plan Local Plan. Any mitigation identified through the AA needs to be integrated into the relevant site specific policies in the document. We have proposed suggested amendments later in this response in relation to this matter. 102330651 AONB Team, Section 2 All the Special Areas of Conservation (SAC), Special Beverley Protection Areas (SPA) and Ramsar sites that could McClean potentially be affected by proposals in the Submission Suffolk Minerals and Waste Plan have been correctly identified in Section 2 of the HRA report. Section 2.3 - Likely Significant Effects We agree with the conclusion set out in paragraph 2.5.1 of the HRA that the proposed allocation of sites M2 Barnham, M4 Cavenham and M7 Wangford and the supporting policies for these sites had the potential to result in likely significant effects and therefore required further consideration through Appropriate Assessment. 102330814 AONB Team, Section 3 Appropriate Assessment Appropriate Assessment AONB team proposed -in addiot Beverley of Policy MP2/MS2, Site M2 Barnham We concur with the modification With regards, McClean potential likely significant effects identified in paragraphs impacts on European Sites, we 3.2.4 & 3.2.5 in the HRA report that could arise from the consider that bullet point j of proposed allocation and policy for MP2/MS2, Site M2 policy MS2 "needs to be Barnham. amended to specify (i) The Mitigation embedded in the Local Plan In section 3.1.1, the need for a high-quality AA states the following ‘Policy GP4 states that minerals and restoration scheme to benefit waste development will be acceptable provided that curlews as identified in the proposals adequately assess and address potentially Appropriate Assessment in para significant adverse impacts upon biodiversity.’ Any proposal 3.2.12 (ii) the policy should also that would have an adverse affect upon the integrity of any be amended to specify the European site would fail this policy test, and not be permitted.’ need for a site specific HRA at Policy GP4 (General Environmental Criteria) is regarded as a the planning application. mitigating policy in the Suffolk’s Submission Minerals & Waste This change is also needed for Local Plan. As drafted, we consider that the need to assess impacts of proposals in the Submission Suffolk Mineral and Waste Local clarity. Plan on international/European designated sites is only implied in Section 3.3 - Appropriate bullet point (d) of policy GP4. The need to assess impacts on all Assessment of Policy designated sites including Natura 2000 sites (and Ramsar sites) MP2/MS4, Site M4 Cavenham should be made much clearer in policy GP4. Such an amendment We concur with the" would provide certainty for operators and ensure that impacts on "potential likely significant internationally designated & European Sites are properly considered throughout the entire mineral & waste planning effects identified in paragraphs processes. As stated in para 3.3.1 of the AA, Policy MP2 3.3.3 & 3.3.4 identifies the requirements that future planning applications for this in the HRA report that could site will need to satisfy. This includes the importation of inert arise from the proposed materials to aid restoration, phased working and restoration, allocation and policy for impacts on European sites, an air quality assessment to address MP2/MS4, Site M4 pollution and dust and a noise assessment. When considered along side the requirements of policy GP4 we are satisfied with the Cavenham. Mitigation conclusion reached in para 3.2.19 that all measures are in place to embedded in the local plan for ascertain that there would be no adverse affect upon the integrity of site M4 Cavenham. As stated any European site, and a long-tern benefit to Breckland SPA would in para occur for the proposed allocation at Barnham. However, the 3.3.7 of the AA, Policy MP4 recommendations in the AA regarding the site at Barnham M2 have identifies issues that future not been carried forward into the site specific policy for Barnham which is necessary to ensure compliance with the Habitats development applications for Regulations. this site will need to satisfy. These include" "importation of inert materials to aid restoration, phased working and restoration, an assessment of impacts on European sites, an air quality assessment to address pollution and dust and a noise assessment. When considered alongside the requirements of policy GP4, the AONB team is satisfied with the conclusion reached in para 3.3.13 that all measures are in place to ascertain that" "there would be no adverse effect upon the integrity of any European site, and a long-term benefit to Breckland SPA would occur for the proposed allocation at Cavenham. However, the recommendati ons in the AA regarding the site at Cavenham M4 have not been carried forward into the site specific policy for Cavenham which is necessary to ensure that the Local Plan is compliant with the Habitats" Regulations. AONB team Proposed modification With regards, impacts on European Sites, we consider that bullet point e of policy MS4 needs to be amended to specify (i) the need for a high-quality restoration scheme to benefit curlews as identified in the Appropriate Assessment in para 3.2.1 (ii) the policy should also be amended to specify the need for a site specific HRA at the planning application. "This change is needed for clarity. Appropriate Assessment of Policy MP2/MS7, site M7 Wangford We concur with the potential likely significant effects identified in paragraphs 3.5.8 in the HRA report that could arise from the proposed allocation and policy for MP2/MS7, Site M7 Wangford. Policy MP7 identifies a number of issues that future development proposals will need to satisfy. These" "include landscaping and restoration, archaeological investigation, impacts on European sites, measures to manage hydrological impact, air quality assessment to address pollution and dust and a noise assessment. When considered alongside the requirements of policy GP4, we are satisfied with the conclusion reached in para 3. 5.16 that all measures are in place to" "ascertain that there would be no adverse effect upon the integrity of any European site, from the proposed allocation of the site at Wangford. However, the recommendati ons in the AA regarding the site at Wangford have not been carried forward into the site specific policy for Wangford MS7 which is necessary to ensure that the Local Plan is compliant with the Habitats Regulations. AONB team Proposed" "modification With regards, impacts on European Sites, we consider that bullet point (d) of policy MS7 should be amended to (i) specify the need for the submission of a site specific HRA at the planning application stage. This change is needed for clarity. There is also a discrepancy between restoration proposals referenced in the AA for the Wangford site in para 3.5.12 and restoration wording in" "policy MS7 which needs further consideration. Para 3.6 In combination of effects The other plans and projects with the potential to have an impact on the Suffolk European Sites were identified as follows in sections 2.4.1 & 2.4.2 of the HRA report: • Development within Local Plans of all seven District/Borou gh Councils in Suffolk • Development within any Neighbourhoo d Plans in the" vicinity of any proposed minerals or waste site • Policies and consents of other regulators e.g. Environment Agency with respect to water abstraction licencing or the Office of Nuclear Regulation with respect to nuclear power stations. • The Norfolk Minerals and Waste Local Plan Review We do not dispute the overall conclusion of para 3.7.1 of the HRA Report that the Suffolk Minerals and Waste Local Plan either alone or in combination with any other plan or project, will have no adverse affect upon the integrity of any European site. However for the purposes of clarity we recommend that the full list of all the plans and projects assessed as part of the in combination assessment should be listed in detail in an appendix to the AA report for clarity. The AONB team would be happy to work together to agree precise wording changes to policies for Barnham, Cavenham and Wangford through a Statement of Common Ground. 99763739 Bastick, Paul 99763739 Bastick, Paul - - - - - - 99493738 Carmichael, Sheila 102286225 Cemex UK Yes No Yes The Assessment of Potential Effects on Estuarine Waterfowl Revision of the HRA/AA to Materials to which the HRA/AA refers concludes that: - “there is no reflect the findings of the Ltd, Shaun likelihood of a significant negative effect on the Minsmere- Waterfowl Assessment, i.e., Denny Walberswick SPA and Ramsar site resulting from extension that: - “there is no likelihood of of quarry workings into the Lime Kiln Farm site. Accordingly, a significant negative effect on there is no requirement for the competent authority to the Minsmere- Walberswick undertake a Habitats Regulations Assessment.” As such the SPA and Ramsar site resulting Company does not accept the conclusion of paragraph 2.5.2 from extension of quarry of the HRA/AA that an Appropriate Assessment of Policy workings into the Lime Kiln MP2 of the draft Plan is required with regard to Site M7 Farm site.
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