Object

Initial Consultation document

Representation ID: 91974

Received: 07/08/2018

Respondent: Mr A Austin

Representation Summary:

Also SIL2 overlaps with the AOS Site E to some degree and it is not acceptable that SIL2 is also and AOS Site E because it provides doubt on the validity of SIL2 and really confirms AOS Site E is not a search area but a really long term proposal being put on hold until SIL2 is worked out.

Regarding the drawn area of AOS Site E the summary of the evaluation leaves aside any planning factor which does not support the proposal or can be summarily ignored in that evaluation. I am sure many others will raise a number of concerns but I will summerise mine with a few factors.
1. Shouldham Warren is a widely used area for recreation - perhaps 50,000 visits each year. The closure of the land for recreational purposes (including people from outside the Kings Lynn catchment area) should be taken into account.
2. The area contains colony of adders (however many people hate them, especially when they kill pet animals) and maybe other species and their right to exist should be acknowledged in the evaluation.
3. I suspect that the AOS does not exclude all residential properties within that area. Working from a OS map is suspect as it has not been updated in detail for twenty years or more. Being a rural area not enough units of change in any density have resulted in any detailed updates being made to the map base for 15 years or more.
4. The forestation is at risk for any scale of mineral extraction. The life of a tree before felling will be towards 30 years. Mineral extraction will put maybe fourty year break on this - and then only if the area was to return to being a managed forest - and this would seriously dent the carbon capture affect of trees in this area.
5. There is no benefit of SIL2 becoming a recreation area (water based) after extraction finishes because it is different to the value of Shouldham Warren (foot, bicycle and horse based). There are other worked out quarries in the area providing water based recreational facilities but no alternative to Shouldhan Warren exists in this area.
6. As AOS-E is adjacent to (and overlaps) SIL02. in these proposals then it would make sense to extend the proposed pipeline from SIL02 to AOS-E as a requirement of any extraction taking place there (should that come to pass).
7. SIL01, AOS-F, AOS-I, AOS-J and MN40 also mention silica sand. As SIL02 would be the largest extraction proposal the promoters of this site would clearly wish to concentrate their resources at one place than spread across a collection of smaller sites although some are already being worked. It should be made clear if the other sites are alternatives or additional sites to be added to a very long term list of proposals and the consequent time scale involved - after all this plan is supposed to be until 2036 not 2066.

With regards to MP13 I find the statements contained and in comparison with the indicative maps shown in the document most confusing. The maps clearly show a protection zone around residential premises but the policy does not include any comment on the evaluation of proposals against its effects on people. It concentrates on flora, forna and ground conditions with absolutely no reference to the destruction of dwellings or any activity of people as though people do not exist. One should either confirm the content of MP13 by showing and dwelling or any structure actually affected by the proposals by not excluding them, or preferably adding to MP13 reference to the effect the proposals would have being judged against any affect on individuals or people in general. (It is not clear if another MP does include that as a factor in the evaluation). Either way this part of the consultation seems to be both a cake and the eating of it!
If residential premises can be excluded for sites then recreational areas should also be excluded, meaning AOS-E should fall as a potential extraction site.

Full text:

There are specific points I wish to make regarding two sites in the consultation document but I would also wish to make a point regarding the consultation process:-
1. The process does not really wok. Using just the prescribed media not longer is fit for purpose. Only specific people will use the Statutory Notices pages of the selected media, not people in general. I was fortunate in that my local parish council clerk had me on an e-mail list otherwise I would not have known of this at all. Out West - well away from the cauldron of Norwich we have minimal contact with NCC, even less regarding any planning consultation process. You have to be actively looking for information especially through a broadcast medium such as the internet and clearly this has not worked other than through the very narrow base of local government contacts.
The consultation system needs a complete overhaul to become meaningful.

With regard to two sites in the consultation document I have some comments to make. One is site SIL2 west of Marham and the other AOS Site E North of Shouldham and the Main Policy 13.

Regarding SIL2 I would anticipate RAF Marham wold be concerned should the proposed extraction method (dredging) result in a rise in birds strike risk especially as each new aeroplane will cost more than the probable profit arising from the extraction of sand from this site.
Also SIL2 overlaps with the AOS Site E to some degree and it is not acceptable that SIL2 is also and AOS Site E because it provides doubt on the validity of SIL2 and really confirms AOS Site E is not a search area but a really long term proposal being put on hold until SIL2 is worked out.

Regarding the drawn area of AOS Site E the summary of the evaluation leaves aside any planning factor which does not support the proposal or can be summarily ignored in that evaluation. I am sure many others will raise a number of concerns but I will summerise mine with a few factors.
1. Shouldham Warren is a widely used area for recreation - perhaps 50,000 visits each year. The closure of the land for recreational purposes (including people from outside the Kings Lynn catchment area) should be taken into account.
2. The area contains colony of adders (however many people hate them, especially when they kill pet animals) and maybe other species and their right to exist should be acknowledged in the evaluation.
3. I suspect that the AOS does not exclude all residential properties within that area. Working from a OS map is suspect as it has not been updated in detail for twenty years or more. Being a rural area not enough units of change in any density have resulted in any detailed updates being made to the map base for 15 years or more.
4. The forestation is at risk for any scale of mineral extraction. The life of a tree before felling will be towards 30 years. Mineral extraction will put maybe fourty year break on this - and then only if the area was to return to being a managed forest - and this would seriously dent the carbon capture affect of trees in this area.
5. There is no benefit of SIL2 becoming a recreation area (water based) after extraction finishes because it is different to the value of Shouldham Warren (foot, bicycle and horse based). There are other worked out quarries in the area providing water based recreational facilities but no alternative to Shouldhan Warren exists in this area.
6. As AOS-E is adjacent to (and overlaps) SIL02. in these proposals then it would make sense to extend the proposed pipeline from SIL02 to AOS-E as a requirement of any extraction taking place there (should that come to pass).
7. SIL01, AOS-F, AOS-I, AOS-J and MN40 also mention silica sand. As SIL02 would be the largest extraction proposal the promoters of this site would clearly wish to concentrate their resources at one place than spread across a collection of smaller sites although some are already being worked. It should be made clear if the other sites are alternatives or additional sites to be added to a very long term list of proposals and the consequent time scale involved - after all this plan is supposed to be until 2036 not 2066.

With regards to MP13 I find the statements contained and in comparison with the indicative maps shown in the document most confusing. The maps clearly show a protection zone around residential premises but the policy does not include any comment on the evaluation of proposals against its effects on people. It concentrates on flora, forna and ground conditions with absolutely no reference to the destruction of dwellings or any activity of people as though people do not exist. One should either confirm the content of MP13 by showing and dwelling or any structure actually affected by the proposals by not excluding them, or preferably adding to MP13 reference to the effect the proposals would have being judged against any affect on individuals or people in general. (It is not clear if another MP does include that as a factor in the evaluation). Either way this part of the consultation seems to be both a cake and the eating of it!
If residential premises can be excluded for sites then recreational areas should also be excluded, meaning AOS-E should fall as a potential extraction site.