Object

Preferred Options consultation document

Representation ID: 94371

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

Representation Summary:

MP2 - The area of 250m around sensitive receptors, etc is completely arbitrary and has no basis in research. In fact, data from research in other countries ref silica sand and its effects show that the dust particles that are of a size that can be inhaled deep into the respiratory system can be detected up to a mile away. There has been much talk from the Sibelco representative about the 'wet dredge' and how this mitigates any worries the public should have on the matter of particulates in the air and breathable silica sand dust. There is no information from Sibelco on the effects that stripping the top layers (overburden) has when it is removed. To be able to 'work' the mine the top layers will be removed to a depth of approximately 8m to expose the silica sand. The 'window' of deadly quartz particulates in the air from the disturbance of the soil is worst in the first six hours of removal. So this will directly affect those living in close proximity, i.e. those in a 1-mile radius. There have been no studies conducted in the UK, therefore, a 250m zone to mitigate against respiratory dust is unsound. MP2 fails sustainability objective SA2 and SA9 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015). In addition, it is noted that in policy MW5 a buffer of 1500m from a mineral site is mandated for areas supporting a bird (Stone Curlew) yet a buffer of merely 250m, or less, is deemed acceptable for humans. This also makes the M&WLP unsound.

Full text:

MP2 - The area of 250m around sensitive receptors, etc is completely arbitrary and has no basis in research. In fact, data from research in other countries ref silica sand and its effects show that the dust particles that are of a size that can be inhaled deep into the respiratory system can be detected up to a mile away. There has been much talk from the Sibelco representative about the 'wet dredge' and how this mitigates any worries the public should have on the matter of particulates in the air and breathable silica sand dust. There is no information from Sibelco on the effects that stripping the top layers (overburden) has when it is removed. To be able to 'work' the mine the top layers will be removed to a depth of approximately 8m to expose the silica sand. The 'window' of deadly quartz particulates in the air from the disturbance of the soil is worst in the first six hours of removal. So this will directly affect those living in close proximity, i.e. those in a 1-mile radius. There have been no studies conducted in the UK, therefore, a 250m zone to mitigate against respiratory dust is unsound. MP2 fails sustainability objective SA2 and SA9 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015). In addition, it is noted that in policy MW5 a buffer of 1500m from a mineral site is mandated for areas supporting a bird (Stone Curlew) yet a buffer of merely 250m, or less, is deemed acceptable for humans. This also makes the M&WLP unsound.