Object

Preferred Options consultation document

Representation ID: 94357

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

Representation Summary:

We disagree with the following presumptions in the visions, policy and objectives and highlight our reasons in each case.

Vision to 2036
Self-sufficient in sand and gravel whilst making important contribution to the national production of silica sand.
Progressive restoration and enhancement of Norfolk's biodiversity and creation of high quality, locally distinctive landscapes.
More responsibility of public and business for waste prevention, re-use and recycling.
Norfolk will aim to be net self-sufficient in waste management, where practicable.
Mineral development will be located, designed and operated WITHOUT adverse impacts on the amenity of local communities, the natural, built and historic environment, the landscape and townscape of Norfolk. They will also minimise the impact of climate change.

There is no definitive demonstration that the UK needs to be self-sufficient in silica sand. The UK is not self-sufficient in defence - we buy equipment from around the world at a cost of billions of pounds; we are not self-sufficient in medicines; or food that we import at a cost of millions if not billions; we are not self-sufficient in energy production - gas, electricity and oil all imported from outside the UK. Yet somehow we have to be in sand and glass? Without this demonstration of the requirement to be self-sufficient in silica sand, extraction of minerals by quarrying is purely because there is no vision to change; it is a classic case of business as usual because it is the easy option for the County Council and profit-driven industry. If the UK was truly intent on maintaining its mineral reserves then Government, aided and guided by Mineral Planning Authorities, would be looking for ways to ensure the minerals are conserved. The National Planning Policy Framework (NPPF) states in (Ch 17, para 204.b) that authorities should 'take account of...recycled materials...before considering extraction of primary materials..'. NCC does not adhere to this as it does not have a glass recycling programme worthy of the name; NCC merely collects glass and transports it outside of Norfolk for processing. In the UK 28 billion glass bottles and jars end up in landfill each year; 14 billion from households (recyclingbins.co.uk). Bars, restaurants and clubs in the UK throw away 200 000 tonnes of glass every year to landfill. Overall it is estimated that the UK throws away 1.5 million tonnes of glass to landfill each year; conveniently approximately 1.5 million tonnes of sand go to the glass making industry. What happens to the collected glass once beyond the county borders seems to be of no consequence to NCC. Therefore, NCC is failing in its duty to look to recycle before extracting raw materials and their vision is not sound.

How can it be logical to say that you will enhance biodiversity if at first you allow it to be destroyed for decades by allowing mineral extraction in an already biodiverse area. In our case locally, there are over 150 different bird, animal, fish and insect seen on or near The Fen at Marham and The Warren at Shouldham, not to mention different plants, hedgerows and trees that support these diverse species. Sixty-four of the species are on conservation lists. We have birds that rely on farmland for foraging and nesting and some are already on the red or amber RSPB lists, these and other animals are protected by the Wildlife and Countryside Act 1981 (http://www.legislation.gov.uk/ukpga/1981/69).

Sibelco's record in the matter of post quarry restoration is appalling; one only has to look at Bawsey to see that their priority is not to enhance. It is not just Norfolk that has suffered, Sibelco has left behind a devastating legacy for the residents in and around Moneystone quarry, Staffs (this area has been a wasteland for many years). Sibelco, the owner and operator, when refused an extension to operate by the CC sold the land onto a property developer. The company, Laver Leisure's plans have been rejected by the CC, so the site is undeveloped. This is not opening up areas for the residents, this is about fee-paying amenities that are of no benefit to local people. The Mineral Products Association awards (see internet links at end of text), highlight how other mineral companies take restoration seriously. Not one of these awards were given to Sibelco. In addition, restoration of quarries in Norfolk is to man-made water-bodies which is hardly 'high quality, locally distinctive landscape'.

If the public and business are to be expected to take more responsibility for their waste management and recycling and re-use of their waste, why are NCC not investing in high technology glass recycling facilities? In order to reduce the amount of silica sand extracted from Norfolk, the amount of clear glass recycled and reused in clear glass manufacture needs to increase; the M&WLP makes no mention of how NCC intends to make this happen in order to fulfil their vision of being net self-sufficient in waste management in respect of glass.

NCC state mineral development will be located, designed and operated WITHOUT adverse impacts on communities and areas and will minimise the impact of climate change. This is impossible and NCC knows that. Every mineral extraction site will have adverse impacts on various parts of the communities and areas they are in. If NCC is truly wishing to minimise impacts and reduce the effects of climate change, they would be seriously involved in the vision of an improved glass recycling/ glass manufacturing loop that was joined up between Waste Management Authorities, recycling business partners, glass manufacturers, the public and food and drink producers. The outcome of such a vision would be less glass going to landfill, more clear glass being available for recycling and use in clear glass manufacture, less CO2 emission in the glass making industry and more jobs in Norfolk in both waste management and high tech glass recycling plant. Without this, the M&WLP Vision 2036 is not sound.

Without a sound glass recycling policy/plan NCC fails their own sustainability objectives SA1, SA3, SA4, SA5. SA6, SA8, SA9, SA11 and SA13 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).

https://mineralproducts.org/restoration_and_biodiversity_awards_2013.htm
https://www.cemex.co.uk/-/eversley-quarry-restoration-plan-is-runner-up-in-mpa-quarries-and-nature-awards
https://mineralproducts.org/15-release28.htm

Full text:

We disagree with the following presumptions in the visions, policy and objectives and highlight our reasons in each case.

Vision to 2036
Self-sufficient in sand and gravel whilst making important contribution to the national production of silica sand.
Progressive restoration and enhancement of Norfolk's biodiversity and creation of high quality, locally distinctive landscapes.
More responsibility of public and business for waste prevention, re-use and recycling.
Norfolk will aim to be net self-sufficient in waste management, where practicable.
Mineral development will be located, designed and operated WITHOUT adverse impacts on the amenity of local communities, the natural, built and historic environment, the landscape and townscape of Norfolk. They will also minimise the impact of climate change.

There is no definitive demonstration that the UK needs to be self-sufficient in silica sand. The UK is not self-sufficient in defence - we buy equipment from around the world at a cost of billions of pounds; we are not self-sufficient in medicines; or food that we import at a cost of millions if not billions; we are not self-sufficient in energy production - gas, electricity and oil all imported from outside the UK. Yet somehow we have to be in sand and glass? Without this demonstration of the requirement to be self-sufficient in silica sand, extraction of minerals by quarrying is purely because there is no vision to change; it is a classic case of business as usual because it is the easy option for the County Council and profit-driven industry. If the UK was truly intent on maintaining its mineral reserves then Government, aided and guided by Mineral Planning Authorities, would be looking for ways to ensure the minerals are conserved. The National Planning Policy Framework (NPPF) states in (Ch 17, para 204.b) that authorities should 'take account of...recycled materials...before considering extraction of primary materials..'. NCC does not adhere to this as it does not have a glass recycling programme worthy of the name; NCC merely collects glass and transports it outside of Norfolk for processing. In the UK 28 billion glass bottles and jars end up in landfill each year; 14 billion from households (recyclingbins.co.uk). Bars, restaurants and clubs in the UK throw away 200 000 tonnes of glass every year to landfill. Overall it is estimated that the UK throws away 1.5 million tonnes of glass to landfill each year; conveniently approximately 1.5 million tonnes of sand go to the glass making industry. What happens to the collected glass once beyond the county borders seems to be of no consequence to NCC. Therefore, NCC is failing in its duty to look to recycle before extracting raw materials and their vision is not sound.

How can it be logical to say that you will enhance biodiversity if at first you allow it to be destroyed for decades by allowing mineral extraction in an already biodiverse area. In our case locally, there are over 150 different bird, animal, fish and insect seen on or near The Fen at Marham and The Warren at Shouldham, not to mention different plants, hedgerows and trees that support these diverse species. Sixty-four of the species are on conservation lists. We have birds that rely on farmland for foraging and nesting and some are already on the red or amber RSPB lists, these and other animals are protected by the Wildlife and Countryside Act 1981 (http://www.legislation.gov.uk/ukpga/1981/69).

Sibelco's record in the matter of post quarry restoration is appalling; one only has to look at Bawsey to see that their priority is not to enhance. It is not just Norfolk that has suffered, Sibelco has left behind a devastating legacy for the residents in and around Moneystone quarry, Staffs (this area has been a wasteland for many years). Sibelco, the owner and operator, when refused an extension to operate by the CC sold the land onto a property developer. The company, Laver Leisure's plans have been rejected by the CC, so the site is undeveloped. This is not opening up areas for the residents, this is about fee-paying amenities that are of no benefit to local people. The Mineral Products Association awards (see internet links at end of text), highlight how other mineral companies take restoration seriously. Not one of these awards were given to Sibelco. In addition, restoration of quarries in Norfolk is to man-made water-bodies which is hardly 'high quality, locally distinctive landscape'.

If the public and business are to be expected to take more responsibility for their waste management and recycling and re-use of their waste, why are NCC not investing in high technology glass recycling facilities? In order to reduce the amount of silica sand extracted from Norfolk, the amount of clear glass recycled and reused in clear glass manufacture needs to increase; the M&WLP makes no mention of how NCC intends to make this happen in order to fulfil their vision of being net self-sufficient in waste management in respect of glass.

NCC state mineral development will be located, designed and operated WITHOUT adverse impacts on communities and areas and will minimise the impact of climate change. This is impossible and NCC knows that. Every mineral extraction site will have adverse impacts on various parts of the communities and areas they are in. If NCC is truly wishing to minimise impacts and reduce the effects of climate change, they would be seriously involved in the vision of an improved glass recycling/ glass manufacturing loop that was joined up between Waste Management Authorities, recycling business partners, glass manufacturers, the public and food and drink producers. The outcome of such a vision would be less glass going to landfill, more clear glass being available for recycling and use in clear glass manufacture, less CO2 emission in the glass making industry and more jobs in Norfolk in both waste management and high tech glass recycling plant. Without this, the M&WLP Vision 2036 is not sound.

Without a sound glass recycling policy/plan NCC fails their own sustainability objectives SA1, SA3, SA4, SA5. SA6, SA8, SA9, SA11 and SA13 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).

https://mineralproducts.org/restoration_and_biodiversity_awards_2013.htm
https://www.cemex.co.uk/-/eversley-quarry-restoration-plan-is-runner-up-in-mpa-quarries-and-nature-awards
https://mineralproducts.org/15-release28.htm