Object
Initial Consultation document
Representation ID: 92209
Received: 15/08/2018
Respondent: Miss E Greene
RE: PROPOSED SITE SIL 02 AS A PREFERRED AREA FOR SILICA SAND EXTRACTION
I wish to lodge my objection to the proposed site SIL 02 as a preferred area for silica sand extraction.
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. 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. The amount of soil and clay to be removed to access the sand is significant and not just a simple surface scrape.
c. The land in question is high quality agricultural land. 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. Due to the depth of the dig and volume of material to be removed it is doubtful if the site will ever be returned to agricultural land.
e. 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?
f. Detrimental impacts on ecology and biodiversity on nearby Country Wildlife Sites
g. Destruction of habitat of endangered wildlife species including:
I. Voles, Newts, scarce Emerald Damselfly, Moths including the Grizzled Skipper, Dingy Skipper
II. Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet, Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge
2. Health and safety
a. The dust created by such a development will cause health and safety issues. The wind typically blows from this site directly towards Marham. Under these circumstances the 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.
b. Unacceptable increase in Noise, Dust and Light pollution as a direct result of the proposed extraction is in violation of local residents' rights as per European Convention on Human Rights, specifically Article 2 (right to life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 (respect for one's private and family life, home and correspondence), and Protocol 1 (right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents.
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.
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.
b. Any Bunding and piles of surface soil and clay will only reduce the natural flow of water and increase the risk of flooding further.
c. 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.
6. Increased risk of Bird Strikes on aircraft
a. 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. In accordance with government guidelines there should be a 13km radius from the centre point of RAF Marham designated as a safeguarding area against bird strike, industrial lighting etc. This area is prone to flooding and will flood once material is extracted. The flooding of the area either during the dredging process or on completion of the sand removal is of concern as this will increase the number of birds and wild fowl resulting in potential bird strikes on aircraft in close proximity to RAF Marham.
7. 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.
c. No proposed economic benefit for the villages of Marham or Shouldham
8. 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?
b. Potential increase on home insurance due to increased flood risk
Please accept the above points as part of our formal objection to the planned sand extraction at Site SIL 02, Marham and Shouldham,
RE: PROPOSED SITE SIL 02 AS A PREFERRED AREA FOR SILICA SAND EXTRACTION
I wish to lodge my objection to the proposed site SIL 02 as a preferred area for silica sand extraction.
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. 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. The amount of soil and clay to be removed to access the sand is significant and not just a simple surface scrape.
c. The land in question is high quality agricultural land. 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. Due to the depth of the dig and volume of material to be removed it is doubtful if the site will ever be returned to agricultural land.
e. 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?
f. Detrimental impacts on ecology and biodiversity on nearby Country Wildlife Sites
g. Destruction of habitat of endangered wildlife species including:
I. Voles, Newts, scarce Emerald Damselfly, Moths including the Grizzled Skipper, Dingy Skipper
II. Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet, Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge
2. Health and safety
a. The dust created by such a development will cause health and safety issues. The wind typically blows from this site directly towards Marham. Under these circumstances the 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.
b. Unacceptable increase in Noise, Dust and Light pollution as a direct result of the proposed extraction is in violation of local residents' rights as per European Convention on Human Rights, specifically Article 2 (right to life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 (respect for one's private and family life, home and correspondence), and Protocol 1 (right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents.
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.
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.
b. Any Bunding and piles of surface soil and clay will only reduce the natural flow of water and increase the risk of flooding further.
c. 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.
6. Increased risk of Bird Strikes on aircraft
a. 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. In accordance with government guidelines there should be a 13km radius from the centre point of RAF Marham designated as a safeguarding area against bird strike, industrial lighting etc. This area is prone to flooding and will flood once material is extracted. The flooding of the area either during the dredging process or on completion of the sand removal is of concern as this will increase the number of birds and wild fowl resulting in potential bird strikes on aircraft in close proximity to RAF Marham.
7. 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.
c. No proposed economic benefit for the villages of Marham or Shouldham
8. 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?
b. Potential increase on home insurance due to increased flood risk
Please accept the above points as part of our formal objection to the planned sand extraction at Site SIL 02, Marham and Shouldham,