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Legally Legally Compliant? Sound? Compliance withDuty 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. Accordingly, there is Wangford. no requirement for the competent authority to undertake a Habitats Regulations Assessment.” 102286913 Cemex UK Yes Yes Yes Despite the Company’s reservations regards paragraph 2.5.2 None Materials of the HRA/AA it is wholly in agreement with the conclusions Ltd, Shaun made by paragraph 3.7.1 of the same. Denny 98780786 Cotgrove, Ian 102285551 Du Cann, No No No This Habitats Regulation Assessment (HRA) does not This proposal needs to be Charlotte adequately assess the Likely Significant Effect’s (LSE’s) of the rejected on the ground outlined proposed gravel pit in Reydon/Wangford. The HRA does not above. The plan should be provide justification for including the Wangford site in the amended to exclude Wangford Minerals and Waste Plan and fails to adequately completely, as there is no valid demonstrate that these LSE’s can be overcome or mitigated. justification for including this The HRA appears to be written as a generic document site in the Plan. covering all the proposed sites in the Minerals and Waste Plan. It fails to mention that the proposed Wangford site is in the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB). Hence in Section 4 General Policies on Page 12 the HRA presents an interpretation of the National Planning Policy Framework (NPPF). The NPPF is clear that major developments (such as the proposed Wangford (such as the proposed Wangford pit extension) should normally be refused in AONB’s (and National Parks), unless there is an over-riding national interest. It is clear that the demand for gravel could be easily met from outside of the AONB, and hence there is no national need, and therefore no justification for allowing the proposed pit. The proposed Wangford/Reydon site and neighbouring reservershave a rich bio diversity that will be threatened by the industrial scheme. The habitats include estuary, pasture, reed beds, arable farmland, hedges, trees and gardens. Farmland is an essential part of this mix and currently is the feeding ground for vulnerable bird species such as as the curlew, lapwing, fieldfare and redwing, as well as for marsh harriers and red kites. Other vulnerable species in the adjacent Hen Reedbeds Nature Reserve and European Protected Sites, such as the bittern and kingfisher, are also likely to be significantly affected by the proposed gravel pit. In Appendix 2 Section 7. Wangford, the HRA appears to acknowledge there will likely be significant adverse effects of this proposed development, however it proposes that any environmental survey work were done after, rather than before, the plan is submitted. It seems clear there are LSE’s on the vulnerable species and the European Sites, as well as a complete lack of justification for the proposal based on the NPPF and AONB, There is no way that 'migitation' or barriers will either screen the Outstanding Ugliness of any kind of industrial development, nor will assist wild life in any shape or form, as can be witnessed by the current gravel pit excavation along the Mardle Road and its oppressive and disturbing earthworks to human and non-human inhabitants and visitors. 102034990 Environment Thank you for your consultation dated 5 November 2018. Agency, Liam We have reviewed the Appropriate Assessment dated Robson November 2018 as submitted and can confirm that we have no comments. 102366834 Forestry Thank you for consulting the Forestry Commission on the Commission Suffolk Minerals and Waste Local Plan. The information England, Neil below is provided to assist you in assessing the Jarvis appropriateness of sites for future development with regard to any which may be near to Ancient Woodland. It is noted from the Minerals Plan that ancient woodlands are in the vicinity of three of the proposed sites i.e. at Barnham, Belstead and Tattingstone. As a non- statutory consultee, the Forestry Commission is pleased to provide you with the inserted links, information that may be helpful when you consider site allocations or policies within your draft plan. Details of Government Policy relating to Ancient woodland. Information on the importance and designation of ancient woodland. Ancient woodlands are irreplaceable. They have great value because they have a long history of woodland cover, with many features remaining undisturbed. This applies both to ancient semi natural woodland (ASNW) and Plantations on Ancient Woodland Sites (PAWS). It is government policy to refuse development that will result in the loss or deterioration of irreplaceable habitats including ancient woodland, unless "there are wholly exceptional reasons and a suitable compensation strategy exists" (NPPF PARA 175). We also refer you to further technical information set out in Natural England and Forestry Commissions standing advice on ancient woodlands - plus supporting assessment guide and case decisions. As a non ministerial government department, we provide no opinion supporting or objecting to a policy, an application or site allocation. Rather we are including information on the potential impact that the proposed development would have on ancient woodland. This response provides factual information on related policy which the planning authority may take into account of when preparing plans and when making its decisions on applications. If the Planning Authority takes the decision to approve an application which may impact on Ancient Woodland sites we may be able to give further support in developing appropriate conditions in relation to woodland management mitigation or compensation measures. Please note however the the standing advice states that ""Ancient woodland or veteran trees are irreplaceable, so you should not consider proposed compensation measures as part of your assessment of the benefits of the development proposal"". We suggest that you take regard of any points provided by Natural England about the biodiversity of any such woodland. The resilience of existing and new woodland is a key theme of the Forestry Commission's work to protect, improve and expand woodland in England we will continue to work with Forestry/woodland owners, agents, contractors and other Stakeholders to highlight, identify, pests and diseases and to work in partnership to enable woodlands and forests are resilient to the impacts of Climate Change. Woodfuel and timber supplies continue to be an opportunity for local market growth whilst also enabling woodlands to be brought back into active management. The planting of newriparian and floodplain woodland, can help reduce diffuse pollution, protect river morphology, moderate stream temperature and aid flood risk management, as well as meet" Biodiversity Action Plan Targets for the restoration and expansion of wet woodland. The Forestry Commission is keen to work in partnership with woodland/forest stakeholders to develop opportunities for woodland creation to deliver these objectives highlighted above. In the wider context the forestry commission encourages local authorities to consider the role of trees in delivering planning objectives as part of a wider integrated landscape approach. For instance through: the inclusion of green infrastructure (including trees abd woodland) in and around new development; and the use of locally sourced wood in construction and as a sustainable carbon lean fuel. 101221063 Frederick I support the legal compliance and soundness of the HRA/AA No modifications are necessary Hiam Ltd, Yes Yes Yes Peter Orroc 102307704 Gerrard, No Not happy with the affect it has on residents. With the dust Do not feel it should go ahead - Alan and mess etc 102204992 Gordon, No No No Doesn’t adhere to planning permission with regard to dust Dust monitors are required to - Joanna pollution. We live within 50m of boundary of quarry and police site. Operator sound not house, garden gets covered. Air quality extremely poor in operate when wind is above summer months. Beaufort Scale 4! The oparator Ahmad flouts this constantly. We are seriously worried about long term health problems from the fine dust - scilicosis. Quarry propose an extension to the site which puts out property right in the path of the prevailing wind from the quarry. This extension would also be far too close to new Crest Nicolson housing development only 60m to the north. THIS MUT NOT GO AHEAD! Dreadful risk to everyone’s health!!!! 102206062 Gordon, No No No Aggmax the operator totally disregards it’s planning Dust monitors need to be Philip permission levels with regard to generation of sand/dust implemented by independent kicked up into air during dry spring and summer months. party from operators and Our property is only 50m away from current site and even results made public. I think closer to proposed extension. Seriously problem for us as council would be horrified by our property gets coated in fine sand constantly and can’t levels of pollutant dust in the open any windows during dry months. Operator continues air. We are happy to have digging in high winds even when they shouldn’t produce monitors installed within dust over Beaufort scale 4. Scilicosis is a real worry for us in grounds of our house for your the future. Extension planning permission should NOT be convenience. granted! Vehicles drive too fast within quarry making matters worse. 102254668 Groves, No No No Is the Habitat Regulation Assessment legal? The habitat Remove Wangford from Sarah assessment report has not addressed the legal requirements proposed site listings of a precautionary approach and imperative of no harm. Wildlife sightlines and sensitivity to sound and vibrations are clearly very different to ours. Referring to point 3.5.11 It is absolutely vital that the water run-off, drainage, water table and salinity levels are not affected as this will change the ecology of the freshwater, brackish and saltwater habitats of the reedbeds / Blyth estuary situated next to a Ramsar site. A change in water quality / levels here will not only affect invertebrate and fish species but also plant species and therefore every bird species that relies on these food sources, including the bittern, bearded tit, water rail, teal, gadwall, kingfishers and marsh harrier as well as otter. It is a delicate balance that absolutely must not be compromised. It is stated that the authority must conclude using scientific measures and a precautionary approach that there will be no harm to the integrity of a European Site ensuring absolutely no harm is caused to the ‘coherence of its ecological function’. Is the Habitat Regulation Assessment sound? The Habitat Regulation Assessment states that ‘Likely side effects’ were likely to occur but suggests totally inadequate mitigation measures rendering it unsound. Further extraction is likely to cause noise pollution and unnecessary disturbance to wildlife as well as threaten the enjoyment of the nearby Hen Reedbeds Nature reserve for visitors. Over the last few years, the Reedbeds have hosted thousands of roosting starlings - a red-listed species whose numbers have declined by 66% (BTO) and are a popular sight for visitors. A hedgeline will not be adequate. Refering to point 3.5.10: Four visits are absolutely not enough to establish the value of a patch of land for species. Animals and birds will move freely around landscapes as and when food or shelter is needed, and that includes the European Sites neighbouring these fields. The Assessment has relied on an inadequate report. As a recent example, over 100 curlew were seen on 8 December in the fields neighbouring the Hen Reedbeds nature reserve. Wildlife simply must have the space it needs to survive - there is no alternative for them. The fields in question contain worms and invertebrates that are a lifeline for bird species such as curlew. Economic growth is no argument for destroying vitally important habitat and there are sufficient alternative sources of gravel to meet demand. The Council’s presumption of overriding national interest is not relevant in this case. Does the Habitat Regulation Assessment comply with the Duty to Co-operate? The compiler of this Assessment appears not to have sought the views of those who objected to the Draft Waste Plan, and has only sought comments from Cemex while briefly referencing concerns from the RSPB and Suffolk Wildlife Trust. There is no reference to co-operation with those who live locally and understand the value of the oak trees, hedgerows and farmland of this site to wildlife, as well as the irreversible character change of this area of Outstanding Natural Beauty. 102287341 GVA, Matt Yes Yes Yes We are writing to you on behalf of the Nuclear Verlander Decommissioning Authority (the NDA) and Magnox Limited (Magnox), in respect of the current consultation on the Minerals & Waste Local Plan (MWLP), Appropriate Assessment (October 2018). GVA is the appointed property advisor for the NDA and Magnox, and provides planning advice across the NDA’s UK-wide estate. This representation is made in respect of the NDA site at Sizewell ‘A’ Nuclear Power Station Site (the Sizewell ‘A’ Site), which is operated by Magnox (the Site Licence Company) on the NDA’s behalf in order to carry out the decommissioning of the site (including waste management and, where appropriate, land remediation). Decommissioning is a long process expected to occur throughout and beyond the plan period. Previous Representations As you will be aware, GVA previously submitted representations on behalf of the NDA and Magnox to Suffolk County Council (SCC) at the MWLP Issues and Options consultation stage on 6th February 2017, and the Preferred Options consultation stage on 11th December 2017. In addition a response was submitted to the Pre- submission Consultation in July 2018. In summary, while the NDA and Magnox are supportive of the proposed allocation of Sizewell A in the Submission Draft, we maintain our previous stance that certain changes are required to proposed Policy WP16 and the text included within Chapter 19 (Sizewell “A” Nuclear Power Station). Therefore, GVA would like to reiterate the importance of the comments made previously, and would refer the Council / the Inspector to our representation dated 11th December 2017 in particular. Comments As noted above the NDA and Magnox are supportive of the policies in the Plan generally. The Appropriate Assessment and supporting documentation has been reviewed and we are of the view that they do not present any new additional issues of relevance to the NDA and Magnox Limited - other than those previously considered and set out in our previously submitted representations. 102295086 H R Philpot & No Strutt & Parker on behalf of H R Philpot & Sons in relation to Sons, David the Suffolk Minerals and Waste Local Plan Publication Stage Fletcher Consultation (2018) have prepared this representation. This representation has been prepared specifically in relation to the promotion of land at Holton Hall Farm, Holton St Mary, as shown on the location plan in Appendix A and should be read in conjunction with earlier representations made at Preferred Options and the Pre-Submission stage of the Local Plan. 1.2 In accordance with the requirements of the consultation, this response has been prepared solely in relation to the additional information and the appropriate assessment that has been prepared. 1.3 In accordance with the criteria set out in the Planning and Compulsory Purchase Act (2004) and the National Planning Policy Framework (NPPF), when allocating sites for development Local Authorities need to be satisfied that their plan is ‘sound’. It is the applicants view that based on the information contained within the appropriate assessment, that the plan is unsound in its current form. For reasons explained in section 2, in order for the plan to be considered sound the allocation for the new quarries at Barnham and Wangford should be removed from the plan and replaced with the allocation of land at Holton Hall Farm. 1.4 As set out in paragraph 12 of the NPPF to be sound, a development should be positively prepared, justified, effective and consistent with national policy. Namely that it is: Positively Prepared – The plan should be prepared on a strategy, which seeks to meet objectively assessed development and infrastructure requirements and consistent with achieving sustainable development. Justified – The plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. Effective – The plan should be deliverable over its period and based on effective joint working cross- boundary strategic priorities; and Consistent with National Policy – The plan should enable the delivery of sustainable development in accordance with the policies in the Framework. 1.5 This document also provides an assessment of why the current version of the local plan, is not justified, effective or consistent with National Policy having regard to the NPPF. The Appropriate Assessment, prepared by the Landscape Partnership, has been undertaken following on from objection raised to the emerging Local Plan from Natural England and the RSPB. This assessment was undertaken following the assessment from Natural England and the RSPB that the proposed new allocations for mineral extraction at Barnham, Cavenham and Wangford were found to be likely to have a significant effect upon European sites. 2.2 It is positive that this Appropriate Assessment has been undertaken to address the concerns raised by Natural England and the RSPB, but disappointing that alternative sites have not been allocated for development following the findings of the Appropriate Assessment. Each of the three sites assessed as part of the Appropriate Assessment (Barnham, Cavenham and Wangford) has been analysed in turn. Having regard to the potential impact that the allocated sites at Barnham, as acknowledged within paragraph 3.2.4 of the Appropriate Assessment, significant impacts of the proposed mineral allocation at Barnham could include a reduction in stone-curlew nesting population size resulting from: · Loss of land used for stone-curlew nesting · Loss of land used for stone- curlew foraging · Disturbance to stone-curlew nesting within or close to the allocation site 2.4 As identified by the RSPB, stone- curlew are defined as follows: ‘A strange, rare summer visitor to southern England and East Anglia, the stone-curlew is a crow- sized bird with a large head, long yellow legs and relatively long wings and tail. Active at night, its yellow eyes enable it to locate food when it is dark.’ 2.5 Stone-curlew is identified under Schedule 1 of the Wildlife and Countryside Act and UK, with breeding in the UK as low as 400 pairs annually. The strongholds for stone-curlew birds are in Wiltshire, around Salisbury Plain and the Breckland Beacons (adjacent to the Barnham application site). 2.6 As identified within paragraph 3.2.5 of the Appropriate Assessment, likely significant effects on the Breckland SAC of the proposed mineral allocation at Barnham could include deterioration of habitat caused by: · Dust Covering vegetation · Air pollution, especially nitrogen oxide deposition from vehicles 2.7 To mitigate against this impact, it is recommended within the Appropriate Assessment that a seasonal restriction is placed on mineral working at the Barnham Quarry allocation 3 (policy MS2), to restrict seasonal working of the minerals to avoid the stone- curlew nesting season. 2.8 A number of concerns are raised in relation to this approach, which is not considered to be sound in planning terms. One of the key tests of soundness, as set out in national policy (paragraph 35) is for policies to be effective and deliverable. It also states that plans must contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals. 2.9 Policy MS2 (Barnham Quarry) is not considered to be deliverable, given that the seasonal restriction on working months for the year is not considered to be enforceable or practical in planning terms. As the Mineral Planning Authority will be aware, the success of quarries is based on having contracts in place with local developers and operators to provide sand and gravel for new developments. The stone- curlew bird nesting season of April – September also coincides with the busiest period of the year for construction activity, which is often completed in Spring and Summer months, when the days are lighter and the weather is drier. Having a seasonal restriction for the Barnham Quarry to be closed during this period will place a significant restriction on the ability of the operators of the quarry to reach agreement with local developers regarding the sale and distribution of mineral from the site. This is especially the case given that most major developments have a significantly longer build programme than 6 months. It is also worth noting that timescales for construction/mineral extraction can often slip from scheduled dates, which could mean agreed orders not being completed outside of the bird-nesting season. For this reason, it also considered that restricting the extraction of material during the bird nesting period will be difficult to enforce by the Mineral Planning Authority. 2.10 One of the rationales for allocation of the site at Barnham Quarry, having regard to the impact on stone-curlews, is on the basis that a quarry was granted permission on the site in 2012. However, the area of the permitted quarry is modest at 15 hectares, when compared with the size of the proposed quarry and therefore the impact upon stone-curlews is not considered to be comparable. It is also understood that the original quarry was only permitted to use the material as part of the Elvedon Bypass development. Without an identified local project for the mineral use, the allocation of this site above unconstrained sites such as land at Holton Hall Farm is considered to be not justified. 2.11 The existing permission at Barnham has already raised concerns regarding deliverability of the site. The original permission was granted in 2012, but has already been extended twice in the short period since its original permission. Most recently this was in 2018. The Appropriate Assessment states that the reason for the 2012 permission not coming forward is a downturn in the market. This is particularly surprising given that construction sector has been buoyant between 2012 – 2018. The lack of interest/deliverability in this site is clearly as a result of the seasonal restrictions on the site from April – September. 2.12 As stated within paragraph 32 of the NPPF, Local Plans and Spatial Development Strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should address how the plan has addressed relevant economic, social and environmental objectives. Significant adverse 4 impact on these objectives should be avoided and, wherever possible, alternative options which reduce and eliminate such impacts should be pursued. 2.13 Although Suffolk County Council have produced a Sustainability Appraisal for the emerging Local Plan, this Sustainability Appraisal was undertaken prior to the Appropriate Assessment being undertaken. It is considered that in order for the plan to be justified, that the Sustainability Appraisal should be updated in order to account for the findings of the Sustainability Appraisal. 2.14 An update to the Sustainability Appraisal for the Barnham quarry site is considered to be particularly important, given that the current Sustainability Appraisal assesses the impact upon Barnham Quarry on Biodiversity and Geodiversity as ‘amber’. It is questioned, why the quarry wasn’t scored ‘red’ given the proximity of the site to the Breckland Beacons Special Protection Area. The Appropriate Assessment is considered to provide additional evidence for the Barnham site to be considered ‘red’ on the sustainability appraisal. 2.15 In addition to the ecological matters, Barnham Quarry is also some two miles from the nearest trunk road (A11). Access and egress to the quarry will require HGV’s to travel along single countryside lanes (such as Elevedon Road), which will be detrimental in terms of air and noise pollution to neighbouring dwellings in the area. Conversely, land at Holton Hall Farm, is located only 700 metres distance from the A12. It is also questioned why Barnham is being allocated, given that it is on the edge of Suffolk and relatively remote from the majority of the housing growth, which is likely to be delivered in and around Ipswich. It is located in close proximity to Thetford, which is within Norfolk so therefore will not assist with meeting the mineral need required within Suffolk. Conversely the land at Holton Hall Farm is located in very close proximity with ideal access to the housing growth in Ipswich and the infrastructure upgrades to the A12. 2.16 In addition, it is noted that the Appropriate Assessment was prepared by the Landscape Partnership. The Landscape Partnership were also responsible for the production of the landscape plans to support the Barnham Quarry allocation. It is considered that there is a clear conflict of interest, with the Landscape Partnership acting for both the Council and the applicants on the Barnham Quarry allocation. It is questioned how this approach can be justified and explanation is required in this regard. 2.17 Having regard to paragraph 32 of the NPPF, in order for the plan to be considered sound it is considered that an alternative allocation needs to be considered and Barnham Quarry removed from the plan, in order to protect the Brecklands Beacons SPA. The land at Holton Hall Farm, Holton St Mary unlike Barnham Quarry is not located in close proximity to any statutory ecological sites of European or National importance. The proposed new quarry allocation at Holton Hall Farm, could be delivered without any impact upon protected sites and therefore should be allocated within the plan in place of Barnham Quarry. The final allocation assessed as part of the Appropriate Assessment relate to Wangford, which is located only 240 metres from Minsmere – Walberswick Special Protection Area (SPA). 2.21 As identified within paragraph 3.5.8 of the Appropriate Assessment, the likely significant effects on the Minsmere – Walberswick SPA/SAC/RAMSAR of the proposed mineral allocation could include the following: · A reduction in bird population size resulting from disturbance to birds on the SPA · Loss of land used for SPA/RAMSAR bird roosting on the site at high tide · Hydrological changes e.g. through excavation, dewatering, drainage or abstraction severing, reducing or increasing surface water or groundwater flows into the SAC/SPA/RAMSAR · Water chemistry changes in the SPA, for example through groundwater pollution, reduced freshwater flows increasing upstream saline incursion or sediment laden- water entering the upper estuary. 2.22 As detailed within the Appropriate Assessment, a number of mitigation measures would be needed in order to ensure that the proposed quarry does not impact upon the SPA/SAC/RAMSAR site. In this regard, the plan is not considered to be in accordance with paragraph 32 of the NPPF, which states that significant adverse impacts on the three objectives of sustainable development (including environmental impacts) should be avoided. In this regard, it is considered that the Council have failed to justify why the proposed quarry at Wangford has been allocated above land at Holton Hall Farm, Holton St Mary. The plan is considered to be unsound in this regard. As referenced above, the land at Holton Hall Farm is not situated in close proximity to any designated ecology sites of national importance and can be delivered without impacting upon nesting birds. 6 The full merits of the site at Holton Hall Farm is set out within our previous representations for the site. 2.23 In addition, the proposed quarry at Wangford is located in a remote location that is not situated in close proximity to any of the major settlements within either Norfolk or Suffolk. It is therefore questionable why a quarry in Wangford has been allocated instead of Land at Holton Hall Farm, which as detailed above is ideally located to serve the housing and infrastructure growth in the County. 102298802 H R Philpot & No As set out within our Regulation 19 representations, we are It is recommended that the Sons, David not in agreement with the Council that the identified extra following amendments are Fletcher requirement for allocation of an additional 9,300 Million made to policy MP2 Tonnes of sand and gravel a year (above the already "(Proposed Sites for Sand and permitted sand and gravel reserves of 11,822 Million Gravel Extraction). That the Tonnes) will meet the extraction demand over the plan policy is amended to delete the period. It is not consistent with the indicative assessment of allocation of Site M2 Barnham housing need for the East of and/or M7 Wangford and that England Counties, which sets out a requirement for 3,112 a new allocation is made to dwellings to be built in Suffolk per year between 2016 and allocate land at Holton St Mary. 2026. Suffolk CC as the Mineral Planning Authority have also 3.2 It is recommended that not taken into account major infrastructure projects Policy MS2 committed over the plan period. In particular, the A12 (Barnham) or Policy MS7 upgrade, which land at Holton Hall Farm is ideally located to (Wangford) is removed in its serve should be assessed, which has not been done as part entirety from the plan. A new of the current Local Plan. The recent increased demand for Policy titled Holton St Mary mineral is set out within annual monitoring report, which should be added to the plan. In recorded sales of sand and gravel at 1,277 Million Tonnes accordance" per year in 2017. This is significantly above the 1,112 Million "with the wording of other Tonnes per annum Suffolk are stating that is required during policies in the plan, it is the forthcoming plan period and suggests that the Council suggested that the following have not positively planned for growth within Suffolk. 2.25 wording for the policy could be Notwithstanding our comments in the Regulation 19 provided: ‘Development will be assessment that the quantum of mineral identified should acceptable so long as the be higher; having regard to the focus of the current proposals, adequately address consultation, concern is raised in relation to the quantum of the following: a) The highway material to be extracted from the three sites that are safety, maintenance and adjacent to the Breckland Beacons and Minsmere- amenity implications of HGV’s Walberswick Special Protection Areas. 2.26 As identified b) within the Submission Draft report, the Barnham quarry has Mitigation of landscape and a reserve of some 2.570 Million Tonnes of gravel, the visual impacts through a Cavenham quarry contains 3.545 Million Tonnes of gravel, scheme of planting and and the Wangford proposed quarry has a reserve of 1 bunding and the retention" Million Tonnes of sand and gravel. Combined the three sites of boundary features and other will provide for a total of 7.115 Million Tonnes of gravel over key vegetation; c) The retention the plan period. This represents approximately a third of the of linear features on the total material 21.122 Million Tonnes of material to be boundary and within the site to extracted over the plan period up to 2036. 2.27 For reasons safeguard the ecological explained earlier on in this representation, it is considered interest within the site that the approach taken in planning terms is unsound. The including hedgerows and large allocation of the three sites (but in- particular the site at hedgerow trees; d) The Barnham), will have a negative impact upon protected provision of an air quality species (stone- curlews), but will also result in assessment which considers HGV’s travelling along rural country roads that would give the potential impacts of rise to air, dust and noise pollution. The allocation of land at increased dust and pollutant Holton Hall Farm, as explained in previous representations concentration associated with has capacity for the extraction of approximately 3.8 Million the extraction. e) The provision Tonnes. It is located in a very sustainable location with direct "of measures to mitigate noise access to the 7 A12 and can also be extracted without f) Proposals to mitigate impacts resulting in a negative impact upon the Breckland Beacons upon the existing public rights and Minsmere- Walberswick Special Protection Areas or of way network without a negative noise and air pollution that the other g) The implications for the sites will have. In order for the plan to be considered sound underlying groundwater and land at Holton Hall Farm should replace the allocations at controlled waters. Proposals Barnham and Wangford, or at a minimum replace the must also be generally in allocation at Barnham. accordance with other policies of the development plan including the environmental criteria set out in Policy GP4.’ 3.3 For reasons explained within this representation , the above" amendments are required for the plan to be considered as sound. 102299454 H R Philpot & In addition to Barnham, the Appropriate Assessment also Sons, David provides an overview of the impact that the allocated sites Fletcher at Cavenham could have upon the Breckland Beacons and nesting birds. It is appreciated that Cavenham Quarry, is a slightly different situation to Breckland Beacons in that it has been an established quarry for a number of years. Nonetheless, in accumulation with the allocation of Barnham, there will be additional pressure and impact upon nesting birds within the Breckland Beacons SPA. This is an additional reason to remove the allocation of Barnham Quarry on the grounds of adverse impact upon nesting birds and the SPA. 2.19 In addition, Cavenham Quarry is located some 5.5 miles from the A11 and will involve HGV’s travelling along countryside roads and through the village of Tuddenham, which will have a negative impact in terms of noise and air pollution to residential dwellings along this route. In addition, as with Barnham Quarry it is located on the edge of Suffolk and is remote from the parts of the County with the highest need for the mineral. As set out above, conversely land at Holton Hall Farm is located in an ideal location and only 700 metres from the A12. Wangford 2.20 The final allocation assessed as part of the Appropriate Assessment relate to Wangford, which is located only 240 metres from Minsmere – Walberswick Special Protection Area (SPA). 2.21 As identified within paragraph 3.5.8 of the Appropriate Assessment, the likely significant effects on the Minsmere – Walberswick SPA/SAC/RAMSAR of the proposed mineral allocation could include the following: · A reduction in bird population size resulting from disturbance to birds on the SPA · 101228241 Hall, No No The area is AONB designated.Para 111and 116 of NPPF Impossibility to make HelenElizabe major deverlopments to be refused unless exceptional modifications other than not thJean circumstances.Close to SWT siteNPPF para 109-125 and EU allowing the extension of the directives.Southwold and Tourisim.Sensitive site particularly workings. ground water source protection zone.. 102261065 Hamilton, No No Yes Report does not highlight the lightly huge increase in traffic Re-write the repot to - Kevin through the villages of Tuddenham and Cavanham emphasise and highlight the anticipation huge increase in traffic and the catastrophic effects on quality of village life in Tuddenham and Cavanham 102262013 Hamilton, No No No This expansion of Cavenham pit will affect the nearby Stop the expansion until such - Nichola homes, have a massive detrimental impact on wildlife habit; time as a genuine plan is not only by destroying a larger area than currently but by agreed with local residents and affecting the water table on a much larger area surrounding wildlife organisation. the pit which will have a massive impact on Tuddenham Heath. 101732704 Hurst, Kevin 102284662 Irving, See Attachment saved...... 1. Summary This Habitats Bill&Aileen Regulation Assessment (HRA) does not adequately assess the Likely Significant Effect’s (LSE’s) of the proposed gravel pit in Reydon/Wangford. The HRA does not provide justification for including the Wangford site in the Minerals and Waste Plan. On the contrary, it appears to state that there are LSE’s and fails to adequately demonstrate that these LSE’s can be overcome or mitigated. Hence the HRA helps demonstrate that the proposed Wangford site should be deleted from the Plan. 2. Context of the Assessment The HRA appears to be mainly written as a generic document covering all the proposed sites in the Minerals and Waste Plan. It fails to mention that the proposed Wangford site is in the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB). Hence in Section 4 General Policies on Page 12 the HRA presents an interpretation of the National Planning Policy Framework (NPPF) biased towards development generally. The NPPF is clear that major developments (such as the proposed Wangford pit extension) should normally be refused in AONB’s (and National Parks), unless there is an over-riding national interest. It is clear that the demand for gravel could be easily met from outside of the AONB, and hence there is no national need, and therefore no justification for allowing the proposed pit. Please see our previous comments on the draft Minerals and Waste Plan for further details. 3. Habitats and biodiversity Having lived and worked near the proposed Wangford/Reydon site for some years now, it is striking how much habitat and bio diversity, perhaps especially of the bird life, there is here currently. The habitats within a very few hundred metres include estuary, pasture, reed beds, arable farmland, hedges, trees and gardens. Some of the diverse bird species occurring in the European Sites and/or in the area of the proposed gravel pit and listed as vulnerable and/or on the Wild Birds Directive Annexes are contained in the table below. The farmland is an essential part of this habitats mix, and is clearly an important feeding ground for vulnerable bird species such as the curlew, lapwing, fieldfare and redwing, as well as for the marsh harriers and red kites. It is notable that the curlews seem to feed on arable land when the tide is high in the Blyth Estuary and the mud flats are under water. The curlews seem to favour the light soil on and around the proposed site, over the adjacent heavier land, perhaps as it is easier to probe in the softer and lighter soil with their fragile "looking beaks. Other vulnerable species in the Hen Reedbeds Nature Reserve and European Protected Sites, such as the bittern and kingfisher, are also likely to be significantly affected by the proposed gravel pit. Table of selected bird species on the European Red List or Wild Birds Directive Annex 1 seen or noted on and around Lime Kiln Farm (continued on next page) English Name Latin Name Wild Birds Directive Annex European Red List Status Remarks Kingfisher Alcedo atthis I Vulnerable in EU27 Countries and Europe as a whole On list at Hen Reedbeds. Bittern Botaurus stellaris I Live in Reedbeds. Can be heard booming in Spring and Summer at Reydon Grange and around Lime Kiln Farm. On list at Hen Reedbeds. Barnacle goose Branta leucopsis I Fairly sized flocks (many dozens of birds) on Reydon marshes in Winter. Nightjar Caprimulgus euroaeus I On list at Hen Reedbeds. Summer visitor. Marsh harrier Circus aeruginosus I Common hunting around hedgerows at and around Lime Kiln Farm. Also on list at Hen Reedbeds. Hen harrier Circus cyaneus I Noted at Hen Reedbeds. Great white egret Egretta alba I Seen flying over Hen Reedbeds. On list at Hen Reedbeds. Little egret Egretta garzetta I Quite common on Reydon marshes and Blyth Estuary. On list at Hen Reedbeds. Brambling Fringilla montifringilla III Vulnerable in EU27 Countries, near vulnerable in Europe as a whole Seen in garden at Reydon Grange. Winter visitor. Oystercatcher Haematopus ostralegus IIB Vulnerable in EU27 Countries and Europe as a whole On list at Hen Reedbeds. Seen on Reydon Marshes. Wigeon Mareca penelope IIA, IIIB Vulnerable in EU27 Countries, near vulnerable in Europe as a whole Seen on Reydon Marshes. Red kite Milvus milvus I Quite common hunting over the fields and hedgerows around Lime Kiln Farm and at Reydon Grange. Eurasian curlew Numenius arquata IIB Vulnerable in EU27 Countries and Europe as a whole Commonly seen feeding on fields proposed to be dug out for gravel pit. Seem to prefer light" "sandy soil. Autumn, winter and spring visitor. Very shy bird. On list at Hen Reedbeds. Habitat includes Lime Kiln Farm and European sites. Redwing Turdus iliacus IIB Vulnerable in EU27 Countries, near vulnerable in Europe as a whole Seen in fields round Lime Kiln Farm and at Reydon Grange. Winter visitor. Fieldfare Turdus pilaris IIB Vulnerable in EU27 Countries, near vulnerable in Europe as a whole Seen in fields round Lime Kiln Farm and at Reydon Grange. Winter visitor. Lapwing Vanellus vanellus IIB Vulnerable in EU27 Countries and Europe as a whole Seen on Blyth estuary, Reydon marshes and fields round Lime Kiln Farm. On list at Hen Reedbeds. 4. Likely Significant Effects of the proposed development In Appendix 2 Section 7. Wangford, the HRA seems to be saying that yes there will very likely be significant adverse effects of this proposed development. The HRA goes on to say “….the developer will need to undertake suitable survey work….”. So the HRA seems to be saying that we should first include this proposal in the Plan, and then afterwards look at the evidence for the consequent effects on the environment. Surely we should be carrying out an adequate and more detailed assessment of the likely environmental effects of a proposal before including this proposal in the Plan, not afterwards. It seems clear there are LSE’s on the vulnerable species and the European Sites, as well as a complete lack of justification for the proposal based on the NPPF and AONB, so the plan should be amended to exclude Wangford completely, perhaps as suggested in our previous comments, as there is no valid justification for including this site in the Plan. 5. Inadequacies of proposed mitigation measures From inspecting the tree ‘screens’ planted some time ago beside the Halesworth Road and walking along Mardle Road past the current excavation area, it is clear that any ‘mitigation’ measures would completely fail to hide the fact that there was a large scale industrial development going on in the AONB" "adjacent to the Blyth estuary and along the main road into the resort of Southwold. You can see right through the tree screens along the Halesworth Road, as well as through the gaps in the screens, which were presumably planted about 30 years ago. Hence the screening mentioned in the HRA would not shield the vulnerable wildlife and European Sites from the proposed development. Walking along Mardle Road near the current gravel pit excavation area is not at all pleasant, due to all the noise produced by the excavation machinery and the oppressive looking earthworks. As a result of the disturbance due to the current excavations many people who used to walk along Mardle Road to and from the Hen Reedbeds no longer do so, which demonstrates that the kind of mitigation works proposed in the HRA do not mitigate the effects of these developments. The kind of vulnerable wildlife which lives on the fields at Lime Kiln Farm and in the nearby European sites is more nervous of human activity than the average bird watcher, rambler or dog walker in Mardle Road. So the wildlife will be at least as badly affected by the proposed works as the people. Hence the effects on the wildlife and the European Sites of the proposed excavations cannot be adequately mitigated by the kind of measures proposed, or by any similar measures that may be proposed. 102315541 Irving, No No No Legal Compliance – Lack of community involvement in the Soundness – Delete Site 7 William preparation of the plan (ref. second bullet point under (Wangford). The demand can section be met from other existing pits, 2.2. of the guidance notes attached to the blank form general excess provisions in the downloaded from SCC’s web site). Duty to co-operate – plan anyway and increased use Section 33A (2.a.) of the PCPA 2004 mentions the duty of the of marine gravel, not least as LPA “to engage constructively, actively and on an ongoing indicated by a number of basis in any process by means of which activities within gravels pit owners and subsection (3) are undertaken”, for example (in subsection operators in the area. 3) in the preparation of the plan. There is a widespread feeling that the views other public bodies (for example Suffolk Coast and Heaths Area of Outstanding Natural Beauty) and numerous private individuals have not been taken into account in preparing this Plan. In other words there does not seem to have been adequate consultation. These submissions show that the Wangford/Reydon proposed gravel pit is not justifiable, as there are adequate alternative ways of supplying the gravel without destroying the AONB. Soundness – The proposal is not justified or consistent with National Policy (for example NPPF). In other words it is not justifiable in the AONB. 98987072 Jessemey, Peta 102145739 Loftus, No No No See attachment...... This response is to be read in conjunction removal of Wangford site from Simon with the attachment to my recent email to Graham Gunby, the list of options setting out my comments in greater detail. In brief, the Assessment ignores the precautionary approach and imperative of no harm (para 1.4.7) - which is a legal requirement. It admits that Likely Side Effects were determined to occur but suggests completely inadequate measures o mitigation. In any case, the People & Wind judgement makes clear that mitigation cannot be considered in the case of Likely Significant Impacts. No proper evidence has been collected re birds listed for SPA or Ramscar designation using fields now proposed for the gravel pit site - the Assessment has relied on an inadequate report prepared by Cemex, which can hardly be considered unbiased. The Council's presumption of overriding national interest is both flawed (there are sufficient alternative sources of gravel) and irrelevant in this case. 102306582 Lucus, Adrian No No Yes General Point on long-term effects of disturbance: At the The site proposal is clearly consultation meeting in Tuddenham Village Hall on 10th Dec inappropriate, being in an SPA 2018, attendees were informed by the ecological expert and close to an SPC. It is (Andrew Murray-Wood?) that the proposed minerals insufficient (and irrelevant) to extraction claim that the expansion "expansion plan would remove habitat for a wildlife, e.g. proposals must somehow be stone- curlew, nightjar and woodlark, and that this would acceptable because the existing result in clear “disturbance” to that wildlife — no one is Cavenham site was operating claiming otherwise. Attendees were also informed that before the SPA area was stone-curlew in particular required “300m” of undisturbed defined. area around them in order to nest. However, this Therefore, the council should disturbance was explained as being acceptable because of exclude the Cavenham site the assumption that in the longer term (15-25 years) a (M4) as being inappropriate suitable habitat could potentially be restored and that the under the current environment short-term and/or cumulative effects were assumed not to regulations (not those that have an effect on the longer term. were in place several decades However, this assumption appears to be based (if it has basis ago). at all) on small-scale previously-restored land and not of the The proposed site is too large in significantly larger proposed site (and associated sites) its current form to be able to mined over several phases. An insufficient assessment has provide sufficient evidence been presented of the genuine risks of permanent from other sites that there isn’t disturbance on this particular site to the most vulnerable a significant risk to habitats and species on an extraction site of this scale. It is not sufficient wildlife caused by (for to interpolate a small-scale to a large-scale extraction example): inability of birdlife to without supporting evidence. For example, where will the move to adjacent sites that disturbed wildlife likely move to? Is there sufficient they can inhabit and breed; undisturbed area during the phased extraction for the birds that the significant noise and to move to? Is there sufficient habitat in the vicinity for dust/pollutant s (from them to move to that they will continue to be able to extraction, vehicles and establish with sufficient time to survive and nest (in the case recycling) can be adequately of birds)? It is not clear that an assessment has been assessed as having no presented or carried out that demonstrates sufficiently that significant effects. If the with the particular size and timing of the proposed council believes that a smaller expansion and recycling plant, that certain species would be site expansion can be proposed disturbed to a point where they would no longer naturally where sufficient evidence can re-inhabit this area after gravel extraction area had been be produced that no significant restored. Although the council’s representative said at the effect will occur, it should meeting that the council monitors site operations and reconsider the size of the site restoration, insufficient evidence was presented that this and make a significantly smaller would guarantee adherence to the current proposals, which proposal. this assessment and conclusions are based. The council’s Regardless of the size of the representative explained that there were a number of site, mitigation and situations in other areas where site management and enforcement proposals need to processes were found to be in breach of guidelines and the be presented before the law and prosecutions were required. Given that this occurs proposals move to detailed and that site operators clearly do not always adhere to the planning application stages. original proposals, the council should be presenting a plan which reduces or removes the significant negative effects of the proposed development rather than relying entirely on adherence and monitoring or prosecution after the damage has occurred. Please design a proposal/plan that is robust to such breaches or propose stricter regulations that would prevent or stop detrimental effects of a breach before it is too late for habitat/wildlife. 2.3.1 The proposed quarry and recycling site expansion would have a significant effect in all of the areas listed in section 2.3.1 of the HRA 2018-11-01, namely: loss of land in SPA and close to a SAC, disturbance to important bird populations through noise (extraction, vehicles and recycling), light (even the existing site is illuminated extremely brightly through much of the night), movement and increased traffic levels (on site/in area), pollution from vehicle emissions and dust (e.g. during the crushing and recycling of materials), changes in groundwater levels and/or surface water flows. Although seasonal extraction was mentioned as a general mitigation strategy, Mr Gunby noted at the meeting on 10th Dec 2018 that it was unlikely that this would be performed at the Cavenham site. It should have been a proposed mitigation strategy there and no explanation has been presented as to why this is not the case. There is insufficient explanation of mitigation strategies for noise, dust and air pollution — the report simply states that these “would be controlled” but not how this would be achieved or with evidence of effectiveness on this site. The explanation given was that this would be detail at the planning application stage, but it is not acceptable or sound to defer these important criteria for assessment until that stage. 3.4.1 states that “It is theoretically possible that an insignificant effect at each one of the allocations could, when both allocations are considered together, result in an overall significant effect leading to loss of nesting ability and an adverse affect on the integrity of Breckland SPA. However, it is considered that the small size of even the combined allocations compared to the size of the SPA, and the phased extraction and restoration, would not combine to have an adverse affect on the integrity of Breckland SPA.” No evidence is provided behind this consideration in order to demonstrate that the possibility of cumulative effects is negligible or that the proposal has been modified in order to make it so. 3.2.6 Clearly the “evidence” sited in the appendices shows that disturbance due to vehicles exists, yet it has not been quantified. As such, it is unsound to assume that the disturbance is not significant. The materials used in restoration are not defined, e.g. in draining quality, harmful contaminant levels, suitability for the site and nature restoration, etc. The site proposal is clearly inappropriate, being in an SPA and close to an SPC. It is insufficient (and irrelevant) to claim that the expansion proposals must somehow be acceptable because the existing Cavenham site was operating before the SPA area was defined. The assessment and evidence needs to be based on current standards and regulations, not what existed decades ago. 102034815 Miller, Nick I continue to be opposed to any future minerals use, for the - - site between Newton Road, Sudbury, Suffolk, and Valley Road, which is the area around the garden centre etc. This is because of its potential future need, as: New connecting road, and possible roundabout, to improve the dangerous A134 junctions at Joes Road and Valley Road; Potential area for employment or other strategic uses, to take pressure of development away from Sudbury. Also I understand the mineral resource here is slight and uneconomic. 102329252 Natural Further to my earlier representations, I now wish to respond England, to the current consultation in the Habitat Regulations - - Louise Oliver Assessment for the proposed extension of Wangford Gravel Pit to Lime Kiln Farm in Reydon. I do not consider this assessment adequate and therefore regard the Plan as not legally compliant. I refer you to the detailed submission by Mr Bill Irving which provides the evidence of important wildlife on and close to this site and demonstrates the inadequacy of the mitigation measures which will not protect either the wildlife on the site nor prevent damaging impacts on recognised sites of habitat importance which are extremely close to the site. In addition, of course, if permitted this gravel pit will permanently alter a significant area of the AONB and I continue to believe you have failed to demonstrate the threshold of need required for this development to be in an AONB. Although I am making this submission in a personal capacity, I can also confirm that both the Parish Council and the Southwold and Reydon Society (the local Amenity Society with 400 members) oppose this proposal. Thank you for your consultation on the above dated 1 November 2018 which was received by Natural England on the same date. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. Natural England provided advice in relation to earlier drafts of the Habitats Regulations Assessment (HRA) for the Suffolk Minerals and Waste Local Plan review (SM&WLP) previously in correspondence dated 8 December 2017 (our ref: 230240); 23 July 2018 (our ref: 249702), 12 October 2018 (our ref: 259232) and 31 October 2018 (ref: 259232), along with comments on specific policies and proposed site allocations. In this letter, we provide further comments on the revised Habitats Regulations Assessment (HRA) dated November 2018 that is currently out to public consultation. Natural England welcomes the latest amended version of the HRA and the inclusion of some of the advice and comments provided previously, and collectively, by Suffolk Wildlife Trust, RSPB and ourselves, particularly given the tight timescale in which it was produced. Summary Natural England notes that your authority, as competent authority under the provisions of the Habitats Regulations, has undertaken an appropriate assessment of the Local Plan, in accordance with Regulation 63 of the Regulations. Natural England is a statutory consultee on the Appropriate Assessment (AA) stage of the Habitats Regulations Assessment process, and a competent authority should have regard for Natural England’s advice. The Appropriate Assessment in the HRA concludes that your authority is able to ascertain that the SM&WLP Submission Draft June 2018 will not result in adverse effects on the integrity of any of the sites in question. Having considered the assessment, and the measures proposed to mitigate for any adverse effects, it is the advice of Natural England that it is not yet possible to ascertain that the Local Plan will not result in adverse effects on the integrity of the European sites in question. Natural England advises that the Plan policies, and in places the assessment itself, do not currently provide enough certainty to justify the AA conclusion. Further assessment and consideration of Page 2 of 3 amendments to relevant policies in the Local Plan need to be undertaken, and Natural England provides the following advice on the additional assessment work required. 1. Amendments to policies Previously, Natural England, together with Suffolk Wildlife Trust and the RSPB, expressed concerns about the wording of policies GP4: General Environmental Criteria; and the following sites allocated under Policy MP2: Proposed sites for sand and gravel extraction: MS2: Barnham, MS4: Cavenham and MS7: Wangford. We advised that amendments should be made to the wording of these policies either to ensure they were compliant with the Habitats Regulations; provided broad avoidance and/or mitigation measures, identified at a strategic level, and that restoration would ensure delivery of a net biodiversity gain long term, with regard to the Breckland Special Protection Area (SPA) specifically. The requirement to include this information at application stage should be made clear in each relevant allocation. Please see previous correspondence for full details. However, the relevant policies have not been amended to address these points in full and so we are unable to agree with the conclusions in the Appropriate Assessment. There appears to be a disconnect between the HRA and the SM&WLP, particularly with regard to ensuring any restoration proposals will benefit the SPA long term. 2. Sizewell ‘A’ Nuclear Power Station In an earlier draft of the HRA, Strategic Habitats Regulations Assessment, dated August 2018, Policy WS1: Sizewell ‘A’ Nuclear Power Station was screened in for likely significant effects and considered further at the AA stage. In our response dated 12 October 2018 (our ref:259232) we commented: ‘Without further information on the proposal to manage waste arising from the decommissioning of Sizewell A and some waste potentially arriving from sister stations, it is difficult to make a specific comment. This is a highly sensitive location environmentally and any proposal would have to take full account of any likely significant impacts to landscape, biodiversity and coastal access.’ If you have specific information on likely impact pathways, please identify them as they are probably different to the list you have identified for minerals operations and cut and pasted here.” In the November 2018 HRA, Policy WS1: Sizewell ‘A’ Nuclear Power Station has not been screened in (or even mentioned) and therefore has not been considered at AA stage. It is unclear why it has been omitted and we would appreciate understanding the reasons behind this given our previous advice. 3. Other Comments on the revised HRA, dated November 2018 2.4.1 – Rather than simply listing the generic category of plan or project, the specific plans or projects identified should be listed in an annex to demonstrate what had been considered. 3.2.6, 3.2.14, 3.3.10 and 3.4.1 – It is important to note that the number of breeding pairs (of stone curlew) affected by an individual allocation or in combination with other allocations or other plans or projects should be assessed against the total number of pairs over the whole SPA rather than simply considering the area of SPA affected by an allocation. 3.6.1 – A list of the identified plans or projects which have been identified and screened out from in combination effects with the SM&WLP should be included in an annex. Appendix 3 - Stakeholder’s comments dated 31 October 2018 –we do not agree with many of the remarks made against the comments submitted by Natural England, Suffolk Wildlife Trust and RSPB) in the table. This includes those made in regard to the temporary loss of land, policy wording not being amended, traffic impacts and planning conditions. Sustainability Appraisal - The conclusions and recommendations of the revised HRA need to be Page 3 of 3 incorporated into the Sustainability Appraisal (SA) report, as well as being reflected in the allocations and policies of the SM&WLP Submission Draft June 2018. 4. New legal ruling regarding functionally-linked land Since the revised HRA was produced there has been a judgement from the European Court of Justice, issued on 7 November 2018, regarding the consideration of the typical species of SAC habitats, and also ‘functionally-linked land (Case C-461/17 Holohan and Others). Suffolk County Council, as competent authority for the Minerals and Waste Local Plan, should consider this judgment in relation to its HRA under the Conservation of Habitats and Species Regulations 2017 and may wish to take its own legal advice on the implications of the judgment, including in relation to the Wangford allocation. A link to the judgement is provided below: http://curia.europa.eu/juris/document/document.jsf;jsessio nid=AE8B2578FD5FBFD652349AA9090A083C?text=&docid= 20742 8&pageIndex=0&doclang=en&mode=req&dir=&occ=first&p art= 1&cid=577996 5. Typing errors Please note the cover page of the HRA, dated November 2018, contains a typo in the second line of the document title and should be amended to read ‘Habitats Regulations Assessment’. There is also a typo in the wording of Policy GP4: General Environmental Criteria (on page 16) of the SM&WLP Submission Draft June 2018 document which currently reads: “Minerals and waste development will be acceptable so long as the proposals, adequately access and address the potentially significant adverse impacts upon: …”. This should be amended to read ‘assess’. 6. Way Forward Natural England looks forward to working with your authority to address the issues that we have raised in this letter, and in our previous responses, to ensure that the HRA and the SM&WLP can both be deemed sound. We recommend working together, along with Suffolk Wildlife Trust and RSPB, to ensure that these matters can be resolved satisfactorily before the Examination in Public Stage of the Local Plan commences. We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us. For any queries relating to the specific advice in this letter only please contact Louise Oliver on 02080 264893. For any new consultations, or to provide further information on this consultation please send your correspondences to [email protected]. 99451555 NDA, Hannah Gray 102285184 O'Hear, No Further to my earlier representations, I now wish to respond Philip to the current consultation in the Habitat Regulations Assessment for the proposed extension of Wangford Gravel Pit to Lime Kiln Farm in Reydon. I do not consider this assessment adequate and therefore regard the Plan as not legally compliant. I refer you to the detailed submission by Mr Bill Irving which provides the evidence of important wildlife on and close to this site and demonstrates the inadequacy of the mitigation measures which will not protect either the wildlife on the site nor prevent damaging impacts on recognised sites of habitat importance which are extremely close to the site. In addition, of course, if permitted this gravel pit will permanently alter a significant area of the AONB and I continue to believe you have failed to demonstrate the threshold of need required for this development to be in an AONB. Although I am making this submission in a personal capacity, I can also confirm that both the Parish Council and the Southwold and Reydon Society (the local Amenity Society with 400 members) oppose this proposal. 99078446 Palmer, No No No Lesley 99080645 Paris, Mitchell 102034295 Peterboroug The Council have no comment to make on your appropriate h City assessment consultation. Council, Chris Stanek 101663590 Potter, Yes Yes No Chosen site next to charity farm has possibility to affect James water supply for property, we are not on mains water and use a ground water well supply. Quarrying into the adjacent land may well affect the water table and thereby our only water supply to this residence. In order to overcome this duty of care, I think it reasonable and just that any plan stipulate that we are put onto mains water supply and any costs incurred by this plus bills for water during the duration of quarrying are paid for by the person/company successful in getting planning for the quarry. 102329844 RSPB, Mark Yes No Yes We understand that comments at this stage are only We recommend that the Plan Nowers requested in relation to the Appropriate Assessment (AA) incorporates distinct policy- published for consultation on the 5 November 2018. This has wording (policies MS2, MS4, been presented for consultation after the submission stage MP6 and MP7) that will ensure of the Minerals Plan, to which we provided comments in July there is no Adverse Effect on 2018. Any disagreement we have with the contents of the Integrity (AEOI) and that AA, would mean that the plan itself is unsound. We consider restoration of minerals sites to it unusual to apply tests of soundness to the HRA process. brecks grass-heath creation for Assessing the impacts on stone-curlews should not be based stone-curlews can be achieved. on the allocation as a percentage of the SPA, but on up to Paragraph 204(f) of the date information around the number of nesting pairs, National Planning Policy foraging extent and their sensitivity to disturbance. It is Framework (NPPF) encourages imperative that any areas that could support stone-curlews councils in their planning are not compromised. We acknowledge and agree with the policies to “set out criteria or AA’s findings that “restoration to high quality nesting habitat requirements to ensure that for stone-curlew would be an essential part of those permitted and proposed - [Barnham/Cavenham] applications” (para 3.1.3), but leaving operations do not have any restoration to application stage cannot be the most unacceptable adverse impacts appropriate strategy in the context of an operation that is on the natural and historic taking place over a significant period of time within an SPA. environment”. Suffolk County This would not be justified in terms of the tests of Council has an opportunity to soundness. revise the findings of the AA and the policy wordings to ensure that these measures are secured. We remain willing to work with SCC and other key stakeholders (Natural England and the Suffolk Wildlife Trust) to ensure that a genuinely sustainable solution is agreed. 102327122 Suffolk No Yes Yes Since the publication of this draft of the Habitats Regulations Ensure that HRA takes account - Wildlife Assessment (HRA) there have been a number of further of latest EUECJ rulings in Trust, James EUECJ rulings relating to undertaking HRAs, in particular relation to the requirements of Meyer reference C- 461/17 of 7th November 2018. We query the HRA process in assessing whether the HRA will be revisited again prior to submission Plans. to take account of these rulings? 102327696 Whilst we acknowledge that the HRA document states that Include a list of all plans and the in-combination effects of other plans and projects have projects assessed for in- been considered as part of the assessment, we remain of the combination effects within the opinion that the plans and projects included as part of this report. assessment should be identified within the report in order to Suffolk provide clarity on those that have been included. It must Wildlife also be ensured that this assessment takes account of Trust, James relevant planning applications and permissions (that have Meyer not been commenced) as part of this assessment. If, as suggested in Appendix 3 of the report, it is considered that listing all of the plans and projects within the body of the report would take up too much space, we would Yes No No recommend that they are included in an appendix. 102327937 Suffolk Yes No Yes The assessment of the proposed allocations at Barnham Policies MS2 (Barnham), MS4 Wildlife (3.2), Cavenham (3.3) and Wangford (3.5) all conclude no (Cavenham) and MS7 Trust, James adverse impact on the integrity of the relevant designated (Wangford) should be updated Meyer sites subject to controls on the extraction activities and to ensure that they secure restoration proposals for the developments. For example, delivery of the measures part of the conclusion of no adverse impact on integrity of identified in the HRA report as the Breckland SPA from Barnham and Cavenham is based on necessary to ensure that the restoring the sites to habitats that are better for stone proposed allocations do not curlews than those that are currently present (sections result in an adverse impact on 3.2.14-18 and 3.3.10-13). At Wangford there are working the integrity of the relevant measures proposed, such as a maximum dig depth, to designated nature conservation prevent hydrological impacts on the nearby SPA and Ramsar sites. site (section 3.5.11). However, none of these requirements are secured as part of the proposed site allocations policies in the Plan (policies MS2 (Barnham), MS4 (Cavenham) and MS7 (Wangford)). Section 3.1.3 of the HRA report states that “the Local Plan does not normally provide specific detail that would be expected to be found within planning applications”, this sentiment is also present in sections 3.2.18 and 3.3.12. However, a plan policy must provide enough security that a planning application coming forward for one of these allocations will be required to deliver measures need to ensure that it does not result in an adverse impact on a European designated site. If these measures are known at the time of the adoption of the Local Plan they should be included within the relevant policy, at least in principle. We consider that failure to do this is contrary to the requirements of the National Planning Policy Framework (NPPF) (in particular sections 16 and 28). 102035316 Tendering I write further to the below mentioned consultation. Thank District you for consulting Tendring District Council. This is an Council, officer-level consultation response and should be taken as William such. Should there be no adverse effect on the European Fuller sites within and adjoining Suffolk, the Council would raise no objection to the emerging Plan. I would ask that you keep us informed of this and any other plans and procedures that might be published by Suffolk County Council in the future. 102035316 Tendring I write further to the below mentioned consultation. Thank N/A N/A District you for consulting Tendring District Council. This is an Council, officer-level consultation response and should be taken as William Fuller such. Should there be no adverse effect on the European sites within and adjoining Suffolk, the Council would raise no objection to the emerging Plan. I would ask that you keep us informed of this and any other plans and procedures that might be published by Suffolk County Council in the future. 102326253 Tuddenham The Parish Council have been formally charged with St Mary submitting a representation on behalf of the residents of Parish Tuddenham St Mary, this representation has been Council, authorised by a Parish Consultation held on 10th, December Vicky Bright 2018. Residents of Tuddenham St Mary would like to register a formal strong objection to the proposed expansion of the Cavenham Quarry as shown in the Draft Minerals & Waste Local Plan. The area proposed for the extraction is part of the Breckland Farmland Site of Special Scientific Interest. It is believed that the proposed expansion will have a significant negative impact both on the environment, wildlife and the quality of life of people living in the locality. It is felt the Appropriate Assessment report is vague and gives very glossed over and bland statements, regarding the detailed impact on wildlife, and human life. Residents also have grave concerns about the proposed introduction of the dumping of so called “inert waste” causing unknown substances to leak into the subsoil and hence the water table, and the impact that this will have on the environment and the quality of life of people living locally. There are also concerns that further extraction will impact on the water table and it is felt that extensive Hydrological Surveys need to be carried out before any expansion is considered. There are also concerns that the proposal will increase noise, light and harmful air pollution within the village, all of which will disturb not only the wildlife, but people living locally within Tuddenham and Cavenham. It should be noted that Air Quality for Tuddenham is currently taken in Newmarket, and we ask that air quality be monitored in the village itself as a condition of any approval. We would strongly advise the removal of the Recycling Scheme from the proposal, or confirmation that any conditions of approval include strict regulation on the types of waste and materials being brought in and processed, including to ensure that the characteristic free drainage of the soil required by Stone Curlews is not compromised, to ensure the proposed restoration to Breckland Heath is successful. We are very concerned that there are several inaccuracies within the submission from Forest Heath, including incorrect data, Air Quality readings from Newmarket, and reports on impact from supposed experts, that haven’t visited the site, village or spoken with residents. 102326253 Tuddenham The Parish Council have been formally charged with St Mary submitting a representation on behalf of the residents of Parish Tuddenham St Mary, this representation has been Council, authorised by a Parish Consultation held on 10th, December Vicky Bright 2018. Residents of Tuddenham St Mary would like to register a formal strong objection to the proposed expansion of the Cavenham Quarry as shown in the Draft Minerals & Waste Local Plan. The area proposed for the extraction is part of the Breckland Farmland Site of Special Scientific Interest. It is believed that the proposed expansion will have a significant negative impact both on the environment, wildlife and the quality of life of people living in the locality. It is felt the Appropriate Assessment report is vague and gives very glossed over and bland statements, regarding the detailed impact on wildlife, and human life. Residents also have grave concerns about the proposed introduction of the dumping of so called “inert waste” causing unknown substances to leak into the subsoil and hence the water table, and the impact that this will have on the environment and the quality of life of people living locally. There are also concerns that further extraction will impact on the water table and it is felt that extensive Hydrological Surveys need to be carried out before any expansion is considered. There are also concerns that the proposal will increase noise, light and harmful air pollution within the village, all of which will disturb not only the wildlife, but people living locally within Tuddenham and Cavenham. It should be noted that Air Quality for Tuddenham is currently taken in Newmarket, and we ask that air quality be monitored in the village itself as a condition of any approval. We would strongly advise the removal of the Recycling Scheme from the proposal, or confirmation that any conditions of approval include strict regulation on the types of waste and materials being brought in and processed, including to ensure that the characteristic free drainage of the soil required by Stone Curlews is not compromised, to ensure the proposed restoration to Breckland Heath is successful. We are very concerned that there are several inaccuracies within the submission from Forest Heath, including incorrect data, Air Quality readings from Newmarket, and reports on impact from supposed experts, that haven’t visited the site, village or spoken with residents. 102134125 Watson, No No After reading the Habitat Regulation Assessment proposing Mark to extend the gravel pits on the borders of Reydon and Wangford to Lime Kiln Farm, I feel that it in no way adequately addresses the Likely Significant Effects of such an extension. Among other things it omits to mention that the site is not only within an important AONB, but also that it is host to many birds listed as vulnerable, such as curlews, bitterns, lapwings and kingfishers. If this proposal is accepted and goes ahead the resultant works will destroy not only a significant area within the Area of Outstanding Natural Beauty, but will also threaten the nearby Hen Reedbeds and surrounding countryside. Given that the National Planning Policy Framework (NPPF) clearly states that such large developments should not be permitted in AONBs, unless there is an over-riding national interest (which there is not - the demand for gravel could be satisfied easily elsewhere, outside the AONB), I think the proposed Wangford pit extension should be removed from the plan. 102258246 West, Kevin No No No Living very close to the proposed site, I regularly visit the Removal of Wangford from And area and am familiar with the nature and wildlife that proposed site list duplicated inhabit it. in Having read the report it is very clear that important points 102258961 have been missed. Although the Blyth estuary is not yet a Ramsar site, it is part of a larger corridor of habitat which includes the Minsmere - Walberswick Ramsar area. The wildlife moves around constantly between these sites and has no concept of borders. The existing Hen Reed Bed reserve is home to breeding Bitterns, Otter, Water Vole, Marsh Harrier. All very rare and shy species requiring no disturbance to their behaviour patterns. I note in paragraph 3.5.10 that Cemex commissioned a study involving ‘Four visits made between January and March 2018’. This is a woefully inadequate amount of time to study the area, and is clearly biased. I regularly see the changes in movement of wildlife between the fields and marshes and it is never the same. Different behaviour is observed at different time of the year by different species. I have recently counted flocks of 100 plus Curlew (conservation status, Red, RSPB) and several hundred Lapwing, (also Red listed), constantly moving between fields and the adjoining marsh land. Great spotted Woodpecker are regularly seen in the many mature oak trees along the perimeter of the proposed site. These trees also support hundreds of insect species, most of which are in serious decline and should be protected at all costs. Green Woodpecker are seen searching for ants on the ground and in winter months the Suffolk Wildlife Trust-owned Hen Reed Beds, right next to the proposed site, is home to thousands of roosting Starlings, and recent sightings of the amber listed Short Eared Owl. Buzzards, and the very rare Marsh Harrier are regular hunters directly over the site. A comprehensive study of insect and invertebrate life, tree, other plant life and fungi needs to be carried out before any decision is made on this area. To rely on Cemex commissioned data from this extremely short survey is frankly ridiculous. The screening proposed will do little to protect wildlife or people visiting the reserve, from noise, dust or diesel fume pollution. In the Habitats Regulation Assessment it is admitted that “likely significant effects were determined to occur’. These include loss of land for roosting birds, reduction in bird population and hydrological changes. 102258246 West, Kevin No No No Living very close to the proposed site, I regularly visit the Removal of Wangford from And area and am familiar with the nature and wildlife that proposed site list duplicated inhabit it. in Having read the report it is very clear that important points

102258961 have been missed. Although the Blyth estuary is not yet a Ramsar site, it is part of a larger corridor of habitat which includes the Minsmere - Walberswick Ramsar area. The wildlife moves around constantly between these sites and has no concept of borders. The existing Hen Reed Bed reserve is home to breeding Bitterns, Otter, Water Vole, Marsh Harrier. All very rare and shy species requiring no disturbance to their behaviour patterns. I note in paragraph 3.5.10 that Cemex commissioned a study involving ‘Four visits made between January and March 2018’. This is a woefully inadequate amount of time to study the area, and is clearly biased. I regularly see the changes in movement of wildlife between the fields and marshes and it is never the same. Different behaviour is observed at different time of the year by different species. I have recently counted flocks of 100 plus Curlew (conservation status, Red, RSPB) and several hundred Lapwing, (also Red listed), constantly moving between fields and the adjoining marsh land. Great spotted Woodpecker are regularly seen in the many mature oak trees along the perimeter of the proposed site. These trees also support hundreds of insect species, most of which are in serious decline and should be protected at all costs. Green Woodpecker are seen searching for ants on the ground and in winter months the Suffolk Wildlife Trust- owned Hen Reed Beds, right next to the proposed site, is home to thousands of roosting Starlings, and recent sightings of the amber listed Short Eared Owl. Buzzards, and the very rare Marsh Harrier are regular hunters directly over the site. A comprehensive study of insect and invertebrate life, tree, other plant life and fungi needs to be carried out before any decision is made on this area. To rely on Cemex commissioned data from this extremely short survey is frankly ridiculous. The screening proposed will do little to protect wildlife or people visiting the reserve, from noise, dust or diesel fume pollution. In the Habitats Regulation Assessment it is admitted that “likely significant effects were determined to occur’. These include loss of land for roosting birds, reduction in bird population and hydrological changes. 102131198 Winterbotha No No Yes I am unsure whether the HRA is legally compliant. I disagree Amend GP1 to add words in m, James with the premise that "a presumption in favour of capitals: The County Council sustainable development" will not have an LSE - it weights will take a positive approach to the Council's judgement too heavily in favour of minerals and waste development. For this reason I consider the HRA unsound. development that reflects the The Wangford site should not be in the Plan in the first place presumption in favour of but be considered only on the submission of a full planning sustainable development application and not before. EXCEPT WITHIN AREAS OF OUTSTANDING NATURAL BEAUTY. Alternatively exclude Wangford site. 102136944 Winterbotha Yes No Yes Table 2 Assessment para 7 Given the biodiversity of the area m, James there is no need for a nett gain in biodiversity. Given the nature of the landscape (mixed farming, woodland, heath, marsh and coastline) the area is already rich in biodiversity. Even farmland supports species eg the Curlews. Arguing for increased biodiversity in such an area to justify destruction of the landscape is unsound. Sensitive species will lose habitat during the mining period - which on past experience may last well beyond any date offered up during the planning stage - and given that the site will only partially be returned to agriculture there will be a net loss to eg curlews Exclude the Wangford site 102137096 Winterbotha Yes No Yes In Table 3 Mitigation I disagree that earth bunds provide an Qualify the use of "earth bunds m, James appropriate or effective mitigation for the degree of EXCEPT IN AREAS WHERE SUCH disruption caused. The landscape is flat and bunds close off TREATMENT MAY BE the long views characteristic of the area. They do not INAPPROPRIAT E TO THE mitigate noise or dust as the "mitigation" along Mardle Road LANDSCAPE CHARACTER SUCH demonstrate, as testified by many residents and walkers. AS THE SUFFOLK COAST AND Bunds will create artificial landscapes over long periods, HEATHS AONB visible across the estuary. This is not appropriate for the specific character of the landscape and maybe rejected at planning stage therefore undermining the soundness of the HRA