Object

Preferred Options consultation document

Representation ID: 94356

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

Representation Summary:

The very first paragraph of the M&WLP (pg 7) states, "The provision of a steady and adequate supply of minerals.......constitute essential infrastructure to support the economic development of the county". All of the silica sand quarried in Norfolk is taken out of the county for use elsewhere in the UK. Therefore, there is no argument that NCC can demonstrate that the extraction of silica sand is to 'support the economic development of the county'. NCC is also unable to define what a 'steady and adequate' supply is since at pg 8 of the introduction section of the M&WLP it states the proposed plan is to extract 750K tonnes per annum of silica sand based on the average sales data. This is in conflict with the statement by Sibelco, on pg 245 at the 4th bullet point under 'Site Characteristics' of SIL 02, that they would intend to extract 800-900K tonnes per annum from SIL 02 alone. So what is an adequate supply? Which figure is correct? If it is the 750K tonnes quoted by NCC then what are Sibelco intending to do with the extra 50-150K tonnes per annum from SIL 02? (Coincidentally this is the amount used in fracking in the UK at this time) It throws doubt on Sibelco's claim that the silica sand sole use is in the manufacture of clear glass. Interestingly, we were told the area SIL 02 contained approx 16,000,000 tonnes of silica sand. Two thirds of SIL02 has been removed in the preferred Options Plan but the NCC notice for the preferred options phase of consultation attached to Wessex BLD telegraph pole on Spring Lane at grid ref; X:5698, Y:3110, indicates the same amount,16,000,000 tonnes for extraction in the area which has only ⅓ of the original area remaining. How can that be?

The National Planning Policy Framework states that Mineral Planning Authorities should look to recycle before they start extracting raw materials. Norfolk (2014 figures) accounts for 20% of all silica sand extraction in the UK and 60% of the silica sand for clear glass manufacture. That is a huge amount of raw material being extracted yet the M&WLP does not make any mention of recycling glass, nor does it contain any figures of how much glass is recycled in Norfolk. The only figures available are for generic waste recycling of on average 46.7% (2016-17) described on the Norfolk Recycles web site. Norfolk Recycles is described as "the public facing brand of Norfolk Waste Partnership and Norfolk County, District, Borough and City Councils working together to improve waste and recycling services for Norfolk's residents and visitors". Therefore, when it comes to recycling glass before extracting raw materials the M&WLP is not sound.

Full text:

The very first paragraph of the M&WLP (pg 7) states, "The provision of a steady and adequate supply of minerals.......constitute essential infrastructure to support the economic development of the county". All of the silica sand quarried in Norfolk is taken out of the county for use elsewhere in the UK. Therefore, there is no argument that NCC can demonstrate that the extraction of silica sand is to 'support the economic development of the county'. NCC is also unable to define what a 'steady and adequate' supply is since at pg 8 of the introduction section of the M&WLP it states the proposed plan is to extract 750K tonnes per annum of silica sand based on the average sales data. This is in conflict with the statement by Sibelco, on pg 245 at the 4th bullet point under 'Site Characteristics' of SIL 02, that they would intend to extract 800-900K tonnes per annum from SIL 02 alone. So what is an adequate supply? Which figure is correct? If it is the 750K tonnes quoted by NCC then what are Sibelco intending to do with the extra 50-150K tonnes per annum from SIL 02? (Coincidentally this is the amount used in fracking in the UK at this time) It throws doubt on Sibelco's claim that the silica sand sole use is in the manufacture of clear glass. Interestingly, we were told the area SIL 02 contained approx 16,000,000 tonnes of silica sand. Two thirds of SIL02 has been removed in the preferred Options Plan but the NCC notice for the preferred options phase of consultation attached to Wessex BLD telegraph pole on Spring Lane at grid ref; X:5698, Y:3110, indicates the same amount,16,000,000 tonnes for extraction in the area which has only ⅓ of the original area remaining. How can that be?

The National Planning Policy Framework states that Mineral Planning Authorities should look to recycle before they start extracting raw materials. Norfolk (2014 figures) accounts for 20% of all silica sand extraction in the UK and 60% of the silica sand for clear glass manufacture. That is a huge amount of raw material being extracted yet the M&WLP does not make any mention of recycling glass, nor does it contain any figures of how much glass is recycled in Norfolk. The only figures available are for generic waste recycling of on average 46.7% (2016-17) described on the Norfolk Recycles web site. Norfolk Recycles is described as "the public facing brand of Norfolk Waste Partnership and Norfolk County, District, Borough and City Councils working together to improve waste and recycling services for Norfolk's residents and visitors". Therefore, when it comes to recycling glass before extracting raw materials the M&WLP is not sound.