Object

Representation ID: 94437

Received: 22/10/2019

Respondent: Shouldham parish council

Summary: The destruction of Shouldham Warren is too high a price to pay in all respects for the silica sand it holds. There is no tangible benefit to West Norfolk communities. There are other areas nationally and internationally other than AOS E in the short term that can continue to be exploited by necessity that have less affect on a community while the country and NCC properly steps up to the requirement to recycle more effectively and find sustainable processes for the longer term. NCC and the Government should be convincing companies to evolve toward a more sustainable model.

SHOULDHAM PARISH COUNCIL
Norfolk County Council Waste and Minerals Plan Consultation Comment
Shouldham Parish Council objects to the proposal of AOS E as an area of search, furthermore it objects to SIL 02, which although as a preferred site was removed from the plan in name following a significant objection from the Defence Infrastructure Organisation (DIO), has in fact had almost a 1/3rd of it retained within the bounds of AOS E.
The Parish Council has listened to its residents, researched open source information and believes that there is compelling evidence and reasons from the perspective of health and wellbeing, climate change, recycling and preservation of finite minerals and that the economic case is significantly disproportionate in favour of industry rather than the wellbeing of the local community and wider population estimated to be in the thousands every year who use the Shouldham Warren for leisure, educational, Forest Church and a variety sporting activities. This is also underpinned in the Forestry England Shouldham and Bilney Forest Plan 2016-2026. The Forest Plan outlines the need to consider, people, economy and nature and is a fine balance that needs to be carefully sustained. AOS D (West Bilney) as well as AOS E (Shouldham Warren) both fall under this Forestry England plan but they have not commented as a consultee nor has the plan been referred to in any of the County officer's responses to other nature related comments. Forestry England are a significant consultee and their 2016-2026 plan has seemingly been overlooked completely.
In addition, the infrastructure from a highways perspective would require significant improvements to make it safe for access and to prevent further adverse impact on the traffic flow along the entire proposed route, which is renowned for long delays at the Hardwick and Hospital roundabouts and roads leading to them. This would mean further roadworks with the associated cost to who? And the disruption and delays while it took place. Monitoring of the yellow hatch box on the Hardwick is already a low priority and widely disregarded by locals, commercial and tourist traffic due to lack of enforcement and not serving to keep traffic flowing.
The prime company (Sibelco) who would likely quarry the site for Silica Sand, if given the planning permission, have a poor track record as a neighbour and despite invitations to discuss what they would likely do by way of restoration offer nothing, the County Officer's comments on restoration, quote policy and offer no detail or assurance as to how policy would be enforced, we would most likely be left with a scar on the landscape with low level land allowed to fill with water at best or used for landfill at worst; the Shouldham mound would disappear along with the features that make it attractive, either way it will never be able to be returned to the positive asset that it represents today.
Climate Change
The UK has signed up to the Paris Agreement which in turn led to the Climate Change Act which commits the UK government by law to reducing greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050.
The Norfolk Climate Change Partnership that NCC and the BC KL&WN are partners in published the 'Tomorrow's Norfolk, Today's Challenge' Climate Change Strategy and that states that in West Norfolk the per capita CO2 emissions is was 10.7 tonnes in 2006, far higher than the rest of Norfolk. The latest figures show a 16.3% increase in that figure between 2016 and 2017, 52% of which is from commercial and industry. Norfolk is not rising to its own challenge and as it said in 2006, the time to act is now!
Councillor Alex Kemp was quoted in a Lynn News article on 18 July 2019 with the following statements:
...it was "totally unsatisfactory" no new AQMAs had been set and the borough were "behind the times."
"There are 40,000 early deaths a year from air pollution and yet there is a reluctance to move forward and look properly at the health of the people of West Norfolk. That has got to change."
Ms Kemp said CO2 emissions were not mentioned during Tuesday's panel meeting.
And she also suggested more trees are planted in the area after deputy leader of the borough council, Elizabeth Nockolds, had said there was a pot of £35,000 a year for new trees.
The borough council report did state the King's Lynn Transport Study is considering many transport options in the town to help ease pollution.
The County and Borough Council's are identifying the issues but failing to take a coherent approach to resolving them, indeed if AOS E was progressed it would be contrary to the Council's strategy on Climate Change. This is your chance to address this and show a proper commitment to climate change.
There is an urgent need to plant trees- the Woodland Trust estimates the UK needs to plant 1.5 billion trees by 2050 in order to reach net zero emissions. This is about 30000 hectares. In comparison, the Warren search area is 330 hectares of woodland. It is nonsensical to destroy existing woodlands when we are not meeting targets for new plantings.
It takes time to establish woods and we are not in a position to take down any trees at this point in time. See the Forestry England Plan.
Norfolk needs to play its part in meeting our international obligations, so the trees must stay.
Health and Wellbeing
The Health and Social Care Act 2012 delegated duties to local authorities to improve public health and reduce health inequalities.
* There is a range of legislation that protects biodiversity and urban green spaces by regulating planning, contamination and conservation, including the Wildlife and Countryside Act 1981, Environmental Protection Act 1990 and the Planning Act 2008.
* Section 12 of the 2012 Act 4 introduced a new duty for all upper-tier and unitary local authorities in England to take appropriate steps to improve the health of the people who live in their areas.
Studies have conclusively proven that exposure to forests and trees:
* boosts the immune system
* lowers blood pressure
* reduces stress
* improves mood
* increases ability to focus, even in children with ADHD
* accelerates recovery from surgery or illness
* increases energy level
* improves sleep
The Natural Environment White Paper addresses the importance of accessible green space and links to human health.
At a time when 1 in 5 children leaving primary school in West Norfolk are obese, the importance of doing all that we can as a society to encourage a healthier lifestyle cannot be underestimated.
West Norfolk is one of the highest areas in the country for GP prescribing of antidepressants, indication a high prevalence of depression and anxiety in the population.
The NHS is under huge strain already trying to treat people, and the county council must do everything in its power to enable people to lead healthier lives, to reduce the burden on health services.
Shouldham Warren is used by a very large number of people from the surrounding areas to walk, cycle, and 'forest bathe'. It is used by cycling groups and of the Ryston Runners have their races here every winter which are attended by a very large number of children and adults from far and wide. There is no other wooded area in this part of West Norfolk which could be used instead, and there is no doubt in my mind that people's health will suffer if they are denied access to these woods.
If NCC goes ahead with giving permission to explore the area for sand quarrying, it will demonstrate a disregard for the population today and future generations; Norfolk County Council will fail in its obligations to look after the health of the people of Norfolk.
Recycling and Preservation of Finite Mineral Resource.
The Ministry of Housing Communities and Local Government document, the
'National Planning Policy Framework', sets out the Government's planning policies
for England and how these should be applied. The document states (Section 2:
Achieving Sustainable Development, at para 7), "The purpose of the planning system
is to contribute to the achievement of sustainable development.
At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs" - Resolution 42/187 of the United Nations General Assembly. The document also states (Section 17: Facilitating the Sustainable Use of Minerals, at para 203), "It is essential that there is a sufficient supply of minerals to provide the infrastructure, buildings, energy and goods that the country's needs. Since minerals are a finite natural resource, and can only be worked where they are found, best use needs to be made of them to secure their long-term conservation." As stated,
sustainable development should not compromise future generations to meet their own needs, and that minerals are a finite natural resource; quarrying is not sustainable and committing to it for the next generation is to show neglect of duty.
Here in Norfolk, as we do in many fields, we should look to model best practice for the UK strategy and have the vision to ensure we do not compromise future generations.
The NPPF states, 'Planning policies should: .... so far as practicable, take account of the contribution that suitable or secondary and recycled materials and minerals waste would make to the supply of materials, before considering extraction of primary materials...' (Sect 17, para 204. b). There is no
attempt within the NCC M&WLP to discuss how improved recycling or reuse of glass within Norfolk, nor indeed the rest of the country, would reduce the amount of silica sand (primary material) extracted each year.



Economics

Employment Opportunities? - only perhaps 1 or 2 jobs created at the quarry site, as quoted by Mike Hurley, Sibelco Chief Ops Officer. Approx 45 jobs maintained at Leziate but no extra jobs created there (Sibelco only employ 389 people in the whole of the UK). Sibelco claim to support down-stream jobs in the glass making industry; however, it isn't Sibelco who support those jobs it is the raw silica sand and that could come from any other source including importation. There is no value to the sand for Norfolk, just profit for the Belgian owned company Sibelco.

Norfolk County Council's (NCC) assertion that Sibelco bring and maintains jobs in Norfolk does not add up. As seen from an article in the EDP 75% of the sand is transported out of Norfolk by rail. The statements made by the Sibelco employee in the article mean that only a handful of HGV jobs are being supported by the transportation of sand in Norfolk. Sibelco estimate 800,000 - 900,000 tonnes of sand extracted per year; NCC figures are 735,000 - 750,000; so a train with 1000t = at least 2 trains per day to haul 75% of total 8 - 9k tonnes per yr. The remaining 25% at 28 tonnes per HGV = 8035 trips per yr, equating to 5 trips per day = 7-8 drivers(approx). Therefore, to retain a few jobs we must accept the destruction of the countryside, the wildlife, our villages, our property, our health and the small matter of national security and the well-being of one of our biggest employers in West Norfolk, RAF Marham. If however, we were to import sand to the glass manufacturers that would maintain glass making jobs in the North of England and presumably the transport jobs to move
the sand to the glass factories, so no job loses in the north. Similarly, rather than sand haulage, transporting waste glass for recycling would maintain jobs in the haulage industry in Norfolk if there were to be an advanced glass recycling facility built in Norfolk. To offset any carbon emissions from that additional HGV traffic the train line at Leziate could still be used to bring glass into Norfolk for recycling and to carry the recycled glass cullet from the new, clean, green recycling facility at Leziate
to the glass manufacturers. That is a win-win situation for everyone.

Adding value to the local economy? - No, they are only creating a couple of jobs (see above). Sibelco does not even use local plant hire since they contract from D. Wardle Plant Hire, a company in Cheshire. Sibelco's representative, Mr Hurley, has said at public meetings that there would be no economic benefit to the area of Shouldham and Marham. Is the sand used in industry here in Norfolk? No, all of the sand is exported beyond Norfolk's borders to be used in glassmaking elsewhere. Therefore, Sibelco will add nothing extra to either the local economy or that of Norfolk in
general. From Sibelco's latest published accounts (2017) we believe they paid £1.4M in UK tax and £245K in business rates (for the Leziate plant) as part of their claim of putting £15M into Norfolk economy. The 2017 Financial return shows £3.8M in total UK plant costs; Sibelco plant hire is from a Cheshire firm, D Wardle Plant hire - so nothing to Norfolk's economy. The average UK Sibelco wage was £37.5K in 2017 - Leziate supports 45 jobs, SIL 02 would have equalled 1 or 2 jobs created = £1.76M wage bill in Norfolk. The figures do not add up to anything close to the £15M that Sibelco claim to put into Norfolk's economy each year.

Aircraft Birdstrike Hazard

It is a fact that birds are a problem at any airport. However, RAF Marham isn't just 'any' airport; it is the Main Operating Base (MOB) for the F35 Lightning II, an aircraft that costs £100M+ per aircraft. The loss of an aircraft due to the loss of an engine or major airframe damage from a bird-strike would be financially intolerable and a major blow to the defence of the UK and our wider interests. The other costs of a crash landing of the aircraft to cover emergency services and long term care and support to the affected people on the ground, are incalculable but would run into the tens if not hundreds of million pounds. It could be argued that there is a set of lakes very close to RAF Coningsby and that is tolerated but, it should be noted that these quarries had been worked for many years previously and that this practise of allowing large man-made lakes near an airfield is no longer tolerated - a precautionary principle of risk applies. It should also be noted that the Typhoon at Coningsby has 2 engines as opposed to the ONE engine that the F35 has, which gives it a better chance to be able to land if one engine is damaged. This is not a luxury the F35 has and, since it isn't a glider, it will not be guided away from the school or the houses before it crashes due to the loss of its ONE and only engine. In other words you cannot compare the 2 places as like for like and overall, on finance alone, the extra risk due to the construction of a water filled quarry so close to RAF
Marham is unacceptable to the tax-payer. It should be remembered that the large element of SIL 02 left in AOS E is a low-lying area and would be left as a wetland. It should also be noted that wetland birds migrate in large numbers, are unfamiliar with the very loud F-35 engine noise and will be 'spooked to flight' in a dense mass that is unavoidable by the pilot. It should also be noted that the migration routes of such large birds will alter to take advantage of new feeding grounds left by a quarry and their flightpath will not be known until they arrive or depart and they do not file flight plans for traffic deconfliction!

Summary
The destruction of Shouldham Warren is too high a price to pay in all respects for the silica sand it holds. There is no tangible benefit to West Norfolk communities. There are other areas nationally and internationally (Sibelco are a global company) other than AOS E in the short term that can continue to be exploited by necessity that have less affect on a community than this one while the country and Norfolk County Council properly steps up to the requirement to recycle more effectively and find sustainable processes for the longer term. Norfolk County Council and the Government should be convincing companies like Sibelco to evolve toward a more sustainable model perhaps by providing incentives and punitive measures to encourage it on that essential journey.