Object
Preferred Options consultation document
Representation ID: 94360
Received: 21/10/2019
Respondent: Campaigners Against Two Silica Sites
MSO2 - To provide a steady and adequate supply of industrial minerals NCC & Gov need to quantify 'adequate' and not rely on the arbitrary figure of yesteryears' production of glass without consideration for the benefits of better recycling to produce high-quality cullet to meet forecast need. NCC base the forecast need only on continuing to extract raw materials before considering better recycling of those raw materials, i.e. glass, which contravenes the NPPF (Ch 17, para 204.b). This objective also fails sustainability objective SA11 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 16 of Part B (Jun 2019).
MSO3 - To encourage sustainable use of minerals by utilising secondary and recycled aggregates. This is the NPPF guidance that states mineral planning authorities(MPA) should look to recycle before extracting raw materials (Ch 17, para 204.b); however, NCC is failing in its duty in this respect with ref to silica sand for clear glass production. NCC does not currently consider increased and more efficient recycling of glass, particularly clear glass, in its plan in order to reduce the amount of extraction of raw material required from Norfolk. Nor is it considering a policy of glass reuse. Therefore, this objective fails ref the NPPF and NCC's own Waste Strategic Objectives and fails sustainability objective SA11 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 16 of Part B (Jun 2019).
MSO6 - Expedient delivery of mineral extraction while..... positively contributing to the natural environment. NCC currently fails in this objective since the areas it plans to excavate silica sand from already have biodiverse natural environments and it is illogical to allow those to be destroyed if your Strategic Objective is to 'positively contribute to the natural environment'. MSO6 fails sustainability objective SA8 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 16 of Part B (Jun 2019). (In the case of SIL 02, (rebadged as part of AOS E) it cannot be described as expedient delivery since it is planned to leave this area in limbo until 2027; plus, mining for 20-30+ yrs followed by an unknown restoration is hardly 'positively contributing to the natural environment'). AOS E and that part of AOS E formally known as SIL 02 is a vast area. Whilst NCC says a small area could come forward, repeatedly after Sibelco gains a foothold in an area it continues to extend the area, aided by a county council who in its own plan and literature look positively at extending sites that have already been worked. We can forecast that Sibelco would be mining in this area for longer than the 20-30 years they promote.
MSO7 - To ensure impacts on the amenity of those people living close to mineral developments are effectively controlled, minimised and mitigated. NCC cannot fulfil this objective without an unbiased health study data that shows the extraction of minerals, especially silica sand, does not have a health impact on people. With respect to the ⅓ of SIL 02 that remains within AOS E, it cannot control, minimise or mitigate the impact on the view; residents of Upper Marham will have a clear view of any mineral workings from their elevated position. The local school overlooks this site; this is not an enhanced learning environment for the children of the area. NCC cannot control, minimise or mitigate for the imposed additional noise from HGV traffic and dredging, even if electric dredged, nor from a pipeline with wet sand being pumped over 6-8 km. Neither can NCC control the prevailing winds being towards Marham on which any noise and dust will travel. NCC cannot mitigate the loss of footpaths (PROW in our area). NCC cannot mitigate against the loss of biodiversity for 20-30+ yrs. NCC cannot mitigate against the fact that important yet uninvestigated archaeological sites lie within SIL 02/AOS E that wet dredging will disturb and lose forever. Although SIL 02 is not to be allocated in the M&WLP approximately ⅓ of its geographical area is remaining as part of AOS E; therefore, the comments of the Sibelco representative stated at public meetings remain relevant, that "the site (SIL 02) will be minimally manned"; so any mitigation that Sibelco proffer to say they will stop excavation if important areas are found is just wishful thinking and disingenuous by the operator, based on the lack of manning and the dredging is underwater and out of sight. If any quarry had to be dry worked the area that NCC would permit is a well-loved and well-used area known as the Warren and Sincks. The health implications then are not just physical and mental wellbeing; they would include risks of respiratory problems as well as certain cancers and will be at the forefront of residents concerns. NCC would be failing in its duty of care to the council taxpayer to ignore the evidence from other countries who have studies linking serious diseases to silica sand - see http://www.hazards.org/dust/silica.htm.
The road network is already under strain; off-road haulage routes will still end up on rural roads to get to the Leziate plant, and NCC cannot mitigate against the increase of CO2 in this scenario. MSO7 fails sustainability objective SA2, SA8 and SA9 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).
MSO8 - Address and minimise impacts on climate change. Only by reducing the amount of mineral extraction can NCC fulfil this objective. In order to do this NCC needs to plan to recycle glass more efficiently and to a better quality within Norfolk. This will comply with the NPPF directive on recycling first, plus comply with the Climate Change Act and the UK's legal obligations to reduce greenhouse gas emissions. Currently, NCC has no plans in place to fulfil this legal obligation with respect to quarrying for silica sand. (However, if Sibelco were to plan for an up to date glass recycling facility at Leziate then the railhead existing there could be used to deliver glass for recycling and take away the processed cullet for use in glass manufacturing, thereby reducing the carbon footprint of HGV to the plant). Sibelco is in partnership with leading glass recycling companies in Europe, why not the UK?. MSO8 fails sustainability objective SA1 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 15 of Part B (Jun 2019).
MSO9 - Restoration. In respect of silica sand extraction within Norfolk to date, NCC has failed in this objective by allowing Sibelco to operate within Norfolk. Sibelco's historical record for the restoration of quarries it has operated is extremely poor (see first internet link at end of text). Add the fact that the proposed areas are already extremely biodiverse, then making a statement about after use enhancing biodiversity is illogical if you need to destroy it for decades prior to any 'possible improvement' (see second internet link at end of text). Due to Sibelco's proven poor record for the restoration of previously worked sites, in reference to silica sand extraction, MSO9 fails sustainability objective SA6, SA7 and SA8 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 16 of Part B (Jun 2019).
MSO10 - Increase public access to the countryside .... through enhancing the amenity value of the land when restoring excavation sites. In terms of AOS E and the ⅓ of SIL 02 which remains in the plan as the eastern edge of AOS E, this objective is not in NCC's gift as it does not own the land. After allowing the land to be quarried by profit-making developers who are only leasing it anyway, it will revert to the landowners who will in all likelihood sell it onto a developer as they will be unable to farm the land or replant it as a forest since it will not be restored, as it should be, back to the type of land it was previously. Sibelco has stated their intention would be to leave any quarry sites in SIL 02, and by extension now to the eastern edge of AOS E, as water bodies. Property developers akin to those at Moneystone (see third internet link at end of text) whose legal wranglings take many years to resolve will not increase public access to the countryside; it will, in fact, reduce it. So how does NCC plan to fulfil this objective in respect to the proposed remaining portion of the 'Preferred Area' of SIL 02 that remains within AOS E and any other area of AOS E? MSO10 fails sustainability objective SA4 and SA9 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).
https://www.bbc.com/news/uk-england-norfolk-23354729
https://mineralproducts.org/restoration_and_biodiversity_awards_2013.htm http://moderngov.staffordshire.gov.uk/documents/s47001/Planning%20Cttee%2006%2003%202014%20Moneystone%20Quarry%20rept.pdf
MSO2 - To provide a steady and adequate supply of industrial minerals NCC & Gov need to quantify 'adequate' and not rely on the arbitrary figure of yesteryears' production of glass without consideration for the benefits of better recycling to produce high-quality cullet to meet forecast need. NCC base the forecast need only on continuing to extract raw materials before considering better recycling of those raw materials, i.e. glass, which contravenes the NPPF (Ch 17, para 204.b). This objective also fails sustainability objective SA11 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 16 of Part B (Jun 2019).
MSO3 - To encourage sustainable use of minerals by utilising secondary and recycled aggregates. This is the NPPF guidance that states mineral planning authorities(MPA) should look to recycle before extracting raw materials (Ch 17, para 204.b); however, NCC is failing in its duty in this respect with ref to silica sand for clear glass production. NCC does not currently consider increased and more efficient recycling of glass, particularly clear glass, in its plan in order to reduce the amount of extraction of raw material required from Norfolk. Nor is it considering a policy of glass reuse. Therefore, this objective fails ref the NPPF and NCC's own Waste Strategic Objectives and fails sustainability objective SA11 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 16 of Part B (Jun 2019).
MSO6 - Expedient delivery of mineral extraction while..... positively contributing to the natural environment. NCC currently fails in this objective since the areas it plans to excavate silica sand from already have biodiverse natural environments and it is illogical to allow those to be destroyed if your Strategic Objective is to 'positively contribute to the natural environment'. MSO6 fails sustainability objective SA8 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 16 of Part B (Jun 2019). (In the case of SIL 02, (rebadged as part of AOS E) it cannot be described as expedient delivery since it is planned to leave this area in limbo until 2027; plus, mining for 20-30+ yrs followed by an unknown restoration is hardly 'positively contributing to the natural environment'). AOS E and that part of AOS E formally known as SIL 02 is a vast area. Whilst NCC says a small area could come forward, repeatedly after Sibelco gains a foothold in an area it continues to extend the area, aided by a county council who in its own plan and literature look positively at extending sites that have already been worked. We can forecast that Sibelco would be mining in this area for longer than the 20-30 years they promote.
MSO7 - To ensure impacts on the amenity of those people living close to mineral developments are effectively controlled, minimised and mitigated. NCC cannot fulfil this objective without an unbiased health study data that shows the extraction of minerals, especially silica sand, does not have a health impact on people. With respect to the ⅓ of SIL 02 that remains within AOS E, it cannot control, minimise or mitigate the impact on the view; residents of Upper Marham will have a clear view of any mineral workings from their elevated position. The local school overlooks this site; this is not an enhanced learning environment for the children of the area. NCC cannot control, minimise or mitigate for the imposed additional noise from HGV traffic and dredging, even if electric dredged, nor from a pipeline with wet sand being pumped over 6-8 km. Neither can NCC control the prevailing winds being towards Marham on which any noise and dust will travel. NCC cannot mitigate the loss of footpaths (PROW in our area). NCC cannot mitigate against the loss of biodiversity for 20-30+ yrs. NCC cannot mitigate against the fact that important yet uninvestigated archaeological sites lie within SIL 02/AOS E that wet dredging will disturb and lose forever. Although SIL 02 is not to be allocated in the M&WLP approximately ⅓ of its geographical area is remaining as part of AOS E; therefore, the comments of the Sibelco representative stated at public meetings remain relevant, that "the site (SIL 02) will be minimally manned"; so any mitigation that Sibelco proffer to say they will stop excavation if important areas are found is just wishful thinking and disingenuous by the operator, based on the lack of manning and the dredging is underwater and out of sight. If any quarry had to be dry worked the area that NCC would permit is a well-loved and well-used area known as the Warren and Sincks. The health implications then are not just physical and mental wellbeing; they would include risks of respiratory problems as well as certain cancers and will be at the forefront of residents concerns. NCC would be failing in its duty of care to the council taxpayer to ignore the evidence from other countries who have studies linking serious diseases to silica sand - see http://www.hazards.org/dust/silica.htm.
The road network is already under strain; off-road haulage routes will still end up on rural roads to get to the Leziate plant, and NCC cannot mitigate against the increase of CO2 in this scenario. MSO7 fails sustainability objective SA2, SA8 and SA9 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).
MSO8 - Address and minimise impacts on climate change. Only by reducing the amount of mineral extraction can NCC fulfil this objective. In order to do this NCC needs to plan to recycle glass more efficiently and to a better quality within Norfolk. This will comply with the NPPF directive on recycling first, plus comply with the Climate Change Act and the UK's legal obligations to reduce greenhouse gas emissions. Currently, NCC has no plans in place to fulfil this legal obligation with respect to quarrying for silica sand. (However, if Sibelco were to plan for an up to date glass recycling facility at Leziate then the railhead existing there could be used to deliver glass for recycling and take away the processed cullet for use in glass manufacturing, thereby reducing the carbon footprint of HGV to the plant). Sibelco is in partnership with leading glass recycling companies in Europe, why not the UK?. MSO8 fails sustainability objective SA1 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 15 of Part B (Jun 2019).
MSO9 - Restoration. In respect of silica sand extraction within Norfolk to date, NCC has failed in this objective by allowing Sibelco to operate within Norfolk. Sibelco's historical record for the restoration of quarries it has operated is extremely poor (see first internet link at end of text). Add the fact that the proposed areas are already extremely biodiverse, then making a statement about after use enhancing biodiversity is illogical if you need to destroy it for decades prior to any 'possible improvement' (see second internet link at end of text). Due to Sibelco's proven poor record for the restoration of previously worked sites, in reference to silica sand extraction, MSO9 fails sustainability objective SA6, SA7 and SA8 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 16 of Part B (Jun 2019).
MSO10 - Increase public access to the countryside .... through enhancing the amenity value of the land when restoring excavation sites. In terms of AOS E and the ⅓ of SIL 02 which remains in the plan as the eastern edge of AOS E, this objective is not in NCC's gift as it does not own the land. After allowing the land to be quarried by profit-making developers who are only leasing it anyway, it will revert to the landowners who will in all likelihood sell it onto a developer as they will be unable to farm the land or replant it as a forest since it will not be restored, as it should be, back to the type of land it was previously. Sibelco has stated their intention would be to leave any quarry sites in SIL 02, and by extension now to the eastern edge of AOS E, as water bodies. Property developers akin to those at Moneystone (see third internet link at end of text) whose legal wranglings take many years to resolve will not increase public access to the countryside; it will, in fact, reduce it. So how does NCC plan to fulfil this objective in respect to the proposed remaining portion of the 'Preferred Area' of SIL 02 that remains within AOS E and any other area of AOS E? MSO10 fails sustainability objective SA4 and SA9 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).
https://www.bbc.com/news/uk-england-norfolk-23354729
https://mineralproducts.org/restoration_and_biodiversity_awards_2013.htm http://moderngov.staffordshire.gov.uk/documents/s47001/Planning%20Cttee%2006%2003%202014%20Moneystone%20Quarry%20rept.pdf