Object

Representation ID: 92298

Received: 12/08/2018

Respondent: Alec Seaman

I believe Norfolk County Council has failed to adequately safeguard the interests of residents, especially those vulnerable residents, affected by the process and in doing so, have invalidated the findings of this initial consultation.
I wish to lodge my objection to the proposed site SIL 02 as a preferred area for silica sand extraction.

I would also strongly protest at the shameful way in which the consultation was carried out. Norfolk County Council (NCC) invested the bare minimum of effort to inform affected residents, request feedback or facilitate objections and comments.

Indeed, from the very outset, it would appear that NCC's efforts have instead been focused on confusing residents, hiding information, providing contradicting advice, creating uncertainty around deadlines and possible extensions. It would seem that deadlines have been specifically planned to coincide with a period when maximum disruption and frustration would ensue for residents seeking advice, clarity and assurance from those charged with safeguarding our interests.

Indeed, I would go so far as to suggest that NCC has wilfully made a complete mockery of the spirit of the very rules designed to protect members of its constituency from the kind of underhand and distressing behaviour we are currently being subjected to. Certainly, NCC's conduct fails, by some considerable margin, to come even remotely close to adhering with the principles laid down in its own, existing, "Statement of Community Involvement".

I would also strongly reject any suggestion that my objection can be attributed to nimbyism. I understand the need to provide a future source of silica sand, however, I feel that this development will have a disproportionate and devastating impact on a rural community, already affected by a rapidly expanding, and increasingly disruptive RAF airbase of growing national strategic importance.

I would also like to note that the proposal put forward by Sibelco is an optimistic 'best case scenario' which doesn't downplay, but completely ignores the negative impact on the residents' wellbeing, our community, and the environment, especially considering the massive size of this site and time scales involved in the development.

I would also like to point out that the process has not adhered to the principles laid out in Norfolk County Council's own 'Statement of Community Involvement'. Residents were completely unaware of these plans, they were not notified of the consultation and had only a few days to prepare a response ahead of the deadline.

In particular, my objection is based on the following grounds:

Health/Safety & Environment

* 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.
* Prolonged exposure to silica dust present significant risk to vulnerable members of the community, particularly the elderly and young, given the village demographics
* No information has been provided regarding the impact of mineral extraction on local water supply/quality
* No restriction on site working hours is proposed
* This is the only proposal within Norfolk M&WLP that is in a high-risk flood area. Flood risks are further exacerbated by the removal of ancient drainage ditches

Economic

* No proposed economic benefit for the villages of Marham or Shouldham
* No additional job creation
* Reduction in house values
* Potential impact on home insurance due to increased flood risk
* Reduction in tourism and visitors to the Nar Valley Way
* Creation of 'trapped' residents unable to move due to the inevitable slowing of the housing market

Local Infrastructure

* Existing road infrastructure is unsuitable for HGV and plant access. Precedence has been established by RAF Marham who are prohibited from using village roads for access purposes.
* Local trunk roads will be negatively affected by increased traffic (A47 & A10)
* No proposal for Sibelco's preferred option for above ground pipeline between proposed site and their current site at Leziate taking into account natural and transport barriers

Ecology
* Destruction of habitat of endangered wildlife species including:
o Voles, Newts, scarce Emerald Damselfly, Moths including the Grizzled Skipper, Dingy Skipper
o Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet, Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge
* Dust deposition relating to the River Nar - a designated SSSI and a Core River valley
* No proposal as to how the Core River Valley will be enhanced following mineral extraction
* Detrimental impacts on ecology and biodiversity on nearby Country Wildlife Sites
* No restoration plan proposed for the entire site, which suggests there is no intention to remedy the harm caused, fears exacerbated by the very poor and dangerous condition of other Sibelco sites, such as Bawsey and Leziate

Landscape

* Marham village enjoys an elevated position relative to the proposed site, with beautiful long-reaching views across the fen landscape
o Bunds or screening will be ineffective and intrusive in their own right
o Proposed works will be visually detrimental and out of character with the local landscape
* Prevailing North and North West winds will aggravate noise and dust pollution concerns and impact on health
* Irreplaceable loss of agricultural land
* Destruction of ancient footpaths and relocation of rights of way (further than the stipulated 100m permitted) contained both within and adjacent to the proposed site, which are extensively used by local residents, schools and tourists
* Detrimental impact on the open nature of the landscape and to the setting of the scheduled monument Pentney Priory Gatehouse and other heritage assets
* No assurances have been received regarding the possibility of the site being used for Landfill in the future

Archaeology

* This area is potentially very rich in archaeological finds, from Pre-Historic to Roman to Medieval and any undiscovered sites would be destroyed permanently by the project
* Close proximity to Pentney Priory Gatehouse and the unexplored Cistercian Nunnery in Marham

My own home is situated less than 400m away from the proposed site and currently enjoys unobstructed views all the way to the River Nar. The proposed site and the prevailing winds will ensure that noise and silica dust will become a daily issue and mean that we will not be able to have windows open on the western side of the property.

In conclusion, nothing in this proposal addresses residents' concerns about the devastating impact the development will have on our community, quality of life, health and wellbeing for decades to come. No assurances have been given that the site will not be abandoned as industrial wasteland with zero potential for either leisure or ecological benefit.

If you require any clarification of the points raised, we would be happy to discuss the matter further.