Object
Initial Consultation document
Representation ID: 92200
Received: 15/08/2018
Respondent: Miss L Tanner
Please accept this letter as a formal objection to the above at area ref AOS E.
As a resident of Marham living in close proximity to this planned development I, like most other residents, was totally unaware or advised of such a scheme until a neighbour informed me of it a few days ago. Apparently only 10 letters were sent out to properties closest to the site. It now also appears that this plan has been discussed by the county council for over three years. The consultation period for this development ends in the next few days giving the residents of Marham and Shouldham insufficient time to review and comment on such a scheme. Considering the size and nature of this planned development this is totally unacceptable and unprofessional. Why have we not been made aware of this plan earlier?
Fortunately a meeting was held by Shouldham Parish Council 6th August 2018 and the following key points were identified;
* If approved, the first phase of the project will involve the stripping of all vegetation, soil and clay from the fields allowing access to the sand below. This will involve the use of heavy duty earth moving equipment.
* The second phase will involve the flooding of the land and dredging on the sand, operating 24 hours a day, 7 days a week. No restriction on working hours has been planned. There are also concerns as this type of dredging has not been carried out by Sibelco in the UK before.
* Planned start date 2026 for a period in excess of 20 years.
The reasons for my objection to the above are as follows;
1. Environmental issues
a. Stripping such a large plot of land for over 20 years will totally destroy the wildlife in this area. The Fen in Marham and the woods in Shouldham Warren will become isolated.
b. Mow Fen, a country Wildlife site, is located within this area
c. The Carbon footprint of the area will be greatly affected by the removal of such a large area of crops. Plants and agricultural farmland.
d. Any screening or Bunding of the site to reduce noise and light pollution will ruin this beautiful landscape and views currently seen across the fen. Where will all the removed soil be stored from the land stripping process?
2. Health and safety
a. The dust created by such a development will cause health and safety issues. Smaller particles of sand and dust will travel long distances and easily reach properties in Marham and Shouldham. This area of land is extremely flat with no natural barriers to slow or prevent the movement of dust and fine particles from the site to the adjacent properties. The effects of this on the health of the elderly, asthma sufferers and those with breathing issues will be significant.
The government website states the following;
www.hse.gov.uk/construction/healthrisks/cancer-and-construction/silica-dust.htm
Silica is the biggest risk to construction workers after asbestos. Heavy and prolonged exposure to RCS can cause lung cancer and other serious respiratory diseases. HSE commissioned estimates it was responsible for the death of over 500 construction workers in 2005. In addition to the risks from lung cancer, silica is also linked to other serious lung diseases:
* Silicosis can cause severe breathing problems and increases the risk of lung infections. Silicosis usually follows exposure to RCS over many years, but extremely high exposures can cause acute silicosis more quickly.
* Chronic obstructive pulmonary disease is a group of lung diseases including bronchitis and emphysema. It results in severe breathlessness, prolonged coughing and chronic disability. It can be very disabling and is a leading cause of death.
The NHS website also states;
www.nhs.uk/conditions/silicosis/
Silicosis
Silicosis is a long-term lung disease caused by inhaling large amounts of crystalline silica dust, usually over many years.
Silica is a substance naturally found in certain types of stone, rock, sand and clay. Working with these materials can create a very fine dust that can be easily inhaled.
Once inside the lungs, the dust particles are attacked by the immune system.
This causes swelling (inflammation) and gradually leads to areas of hardened and scarred lung tissue (fibrosis). Lung tissue that's scarred in this way doesn't function properly.
People who work in the following industries are particularly at risk:
* stone masonry and stone cutting - especially with sandstone
* construction and demolition - as a result of exposure to concrete and paving materials
* pottery, ceramics and glass manufacturing
* mining and quarrying
* sand blasting
3. Noise, dust and light pollution
a. The area under consideration is extremely flat with no natural noise, light or dust barriers. Therefore screening will be ineffective and the entire site will be visible to the majority of the residents of Marham. There is no Bunding large enough to provide a barrier against the noise and light pollution this work will cause. The noise, dust and light pollution from the estimated 11 hour day land stripping and 24 hour a day 7 days a week dredging is totally unacceptable.
4. Access to site
a. The local road network is poor and insufficient for such a project. I believe there is a possibility of installing a pipeline from this site to transport the sand for processing but no allowance has been made for the heavy duty equipment necessary for land stripping. However the Norfolk Minerals and Waste Local Plan (Dec 2017) page 11 states;
"The area of search is approximately 15 kilometres from the Leziate processing plant and it is considered likely that any extraction site would transfer mineral to the processing plant by road."
There is some confusion and misinformation over this issue.
5. The Water Table / Flood plain
a. The majority of the land under review is currently part of a HIGH RISK flood plain. The plan by Sibelco is to flood this area in order to dredge the sand. This will only increase the chance of future flooding in the area in the absence of the flood plain. Any Bunding and piles of surface soil and clay will only reduce the natural flow of water and increase the risk of flooding further.
b. Anglian water have a sewage pumping station in close proximity to the site. They also have a number of bore holes across Marham Fen for the extraction of clean water, how will these be affected by the plan.
c. Concerns have already been expressed and documented by the Council on a restoration plan after the 20 year period involving the creation of a lake and wetlands. The concern is the increase in birds and wild fowl resulting in potential bird strikes on aircraft in close proximity to RAF Marham. Surely the initial flooding of the land for the dredging will also cause this issue.
6. Value to the community.
a. What is the value of such a project to the local community and Britain? Sibelco is not a British company, its head offices are based in Belgium. The value of this type of sand is extremely high and profits made from the sale of this material will be of great value to BELGIUM and not the UK.
b. There will also be no job benefits to the local community as the manpower required to run the planned dredging operations is less than the current services of those working the land. There will therefore be a reduction in jobs and absolutely no value or benefit of such a scheme to the local community.
7. Property Value
a. This will significantly reduce the value of properties in and around Marham and Shouldham for at least 28 years. Who wants to live near and look at a Silica sand extraction plant that will be in opened from 2026 and in operation for at least 20 years, probably much longer?
Please accept the above points as part of our formal objection to the planned sand extraction by Sibelco,
Please accept this letter as a formal objection to the above at area ref AOS E.
As a resident of Marham living in close proximity to this planned development I, like most other residents, was totally unaware or advised of such a scheme until a neighbour informed me of it a few days ago. Apparently only 10 letters were sent out to properties closest to the site. It now also appears that this plan has been discussed by the county council for over three years. The consultation period for this development ends in the next few days giving the residents of Marham and Shouldham insufficient time to review and comment on such a scheme. Considering the size and nature of this planned development this is totally unacceptable and unprofessional. Why have we not been made aware of this plan earlier?
Fortunately a meeting was held by Shouldham Parish Council 6th August 2018 and the following key points were identified;
* If approved, the first phase of the project will involve the stripping of all vegetation, soil and clay from the fields allowing access to the sand below. This will involve the use of heavy duty earth moving equipment.
* The second phase will involve the flooding of the land and dredging on the sand, operating 24 hours a day, 7 days a week. No restriction on working hours has been planned. There are also concerns as this type of dredging has not been carried out by Sibelco in the UK before.
* Planned start date 2026 for a period in excess of 20 years.
The reasons for my objection to the above are as follows;
1. Environmental issues
a. Stripping such a large plot of land for over 20 years will totally destroy the wildlife in this area. The Fen in Marham and the woods in Shouldham Warren will become isolated.
b. Mow Fen, a country Wildlife site, is located within this area
c. The Carbon footprint of the area will be greatly affected by the removal of such a large area of crops. Plants and agricultural farmland.
d. Any screening or Bunding of the site to reduce noise and light pollution will ruin this beautiful landscape and views currently seen across the fen. Where will all the removed soil be stored from the land stripping process?
2. Health and safety
a. The dust created by such a development will cause health and safety issues. Smaller particles of sand and dust will travel long distances and easily reach properties in Marham and Shouldham. This area of land is extremely flat with no natural barriers to slow or prevent the movement of dust and fine particles from the site to the adjacent properties. The effects of this on the health of the elderly, asthma sufferers and those with breathing issues will be significant.
The government website states the following;
www.hse.gov.uk/construction/healthrisks/cancer-and-construction/silica-dust.htm
Silica is the biggest risk to construction workers after asbestos. Heavy and prolonged exposure to RCS can cause lung cancer and other serious respiratory diseases. HSE commissioned estimates it was responsible for the death of over 500 construction workers in 2005. In addition to the risks from lung cancer, silica is also linked to other serious lung diseases:
* Silicosis can cause severe breathing problems and increases the risk of lung infections. Silicosis usually follows exposure to RCS over many years, but extremely high exposures can cause acute silicosis more quickly.
* Chronic obstructive pulmonary disease is a group of lung diseases including bronchitis and emphysema. It results in severe breathlessness, prolonged coughing and chronic disability. It can be very disabling and is a leading cause of death.
The NHS website also states;
www.nhs.uk/conditions/silicosis/
Silicosis
Silicosis is a long-term lung disease caused by inhaling large amounts of crystalline silica dust, usually over many years.
Silica is a substance naturally found in certain types of stone, rock, sand and clay. Working with these materials can create a very fine dust that can be easily inhaled.
Once inside the lungs, the dust particles are attacked by the immune system.
This causes swelling (inflammation) and gradually leads to areas of hardened and scarred lung tissue (fibrosis). Lung tissue that's scarred in this way doesn't function properly.
People who work in the following industries are particularly at risk:
* stone masonry and stone cutting - especially with sandstone
* construction and demolition - as a result of exposure to concrete and paving materials
* pottery, ceramics and glass manufacturing
* mining and quarrying
* sand blasting
3. Noise, dust and light pollution
a. The area under consideration is extremely flat with no natural noise, light or dust barriers. Therefore screening will be ineffective and the entire site will be visible to the majority of the residents of Marham. There is no Bunding large enough to provide a barrier against the noise and light pollution this work will cause. The noise, dust and light pollution from the estimated 11 hour day land stripping and 24 hour a day 7 days a week dredging is totally unacceptable.
4. Access to site
a. The local road network is poor and insufficient for such a project. I believe there is a possibility of installing a pipeline from this site to transport the sand for processing but no allowance has been made for the heavy duty equipment necessary for land stripping. However the Norfolk Minerals and Waste Local Plan (Dec 2017) page 11 states;
"The area of search is approximately 15 kilometres from the Leziate processing plant and it is considered likely that any extraction site would transfer mineral to the processing plant by road."
There is some confusion and misinformation over this issue.
5. The Water Table / Flood plain
a. The majority of the land under review is currently part of a HIGH RISK flood plain. The plan by Sibelco is to flood this area in order to dredge the sand. This will only increase the chance of future flooding in the area in the absence of the flood plain. Any Bunding and piles of surface soil and clay will only reduce the natural flow of water and increase the risk of flooding further.
b. Anglian water have a sewage pumping station in close proximity to the site. They also have a number of bore holes across Marham Fen for the extraction of clean water, how will these be affected by the plan.
c. Concerns have already been expressed and documented by the Council on a restoration plan after the 20 year period involving the creation of a lake and wetlands. The concern is the increase in birds and wild fowl resulting in potential bird strikes on aircraft in close proximity to RAF Marham. Surely the initial flooding of the land for the dredging will also cause this issue.
6. Value to the community.
a. What is the value of such a project to the local community and Britain? Sibelco is not a British company, its head offices are based in Belgium. The value of this type of sand is extremely high and profits made from the sale of this material will be of great value to BELGIUM and not the UK.
b. There will also be no job benefits to the local community as the manpower required to run the planned dredging operations is less than the current services of those working the land. There will therefore be a reduction in jobs and absolutely no value or benefit of such a scheme to the local community.
7. Property Value
a. This will significantly reduce the value of properties in and around Marham and Shouldham for at least 28 years. Who wants to live near and look at a Silica sand extraction plant that will be in opened from 2026 and in operation for at least 20 years, probably much longer?
Please accept the above points as part of our formal objection to the planned sand extraction by Sibelco,