Object

Background documents

Representation ID: 94691

Received: 27/10/2019

Respondent: Mrs LDT Gallagher

Representation Summary:

The plan is not sound.
Without a sound glass recycling policy/plan Including flat glass recycling 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).

Full text:

The Vision Policy and Objectives fail for the following reasons

If Norfolk County Council adhered to NPPF for guidance it would look conserve minerals as it states in (Ch 17, para 204.b) that authorities should 'take account of...recycled materials...before considering extraction of primary materials..'. NCC is failing to recycle before extracting raw materials and therefore their plan to 2036 is not sound.

Waste Management Objectives 1-8 - How do NCC intend to prevent and minimise waste without the ability to recycle or a system of reuse within the county? Further reductions in CO2 emissions from collections and distribution of waste can only be achieved by a World class glass recycling centre in Norfolk with a good train-line link. You cannot have net self sufficiency if you export waste from within Norfolk to outside those County boundaries; landfill is not the answer as this exacerbates both the need for areas to fill and the emissions that will inevitably be caused by transport to those sites. Recycling glass will fulfil WSO8 in generating employment. Recycling glass could lead to a clean green industry within West Norfolk with the potential of hundreds of jobs.

Mineral Strategic Objectives 1-10 - Quantify 'adequate' in MSO2. This figure is calculated by profit driven industry not 'the need'. This forecast 'need' is based on continuing to extract raw materials before considering better recycling. This reduces the need to 'winning over' large swathes of countryside to quarrying and would reduce the areas needed fulfilling MSO6. MSO7 could be fulfilled by recycling glass; thereby ensuring the residents of West Norfolk will not need to fear for their deteriorating health from Cancers to obesity, from respiratory disease and mental health issues caused by quarrying. The road network in this part of Norfolk is saturated already, that cannot mitigate against the increase of CO2 risking the health and wellbeing of residents.

Reducing the amount of mineral extraction and championing a World beating glass recycling plant NCC could fulfil MSO8 objective. In order to do this NCC needs to plan to recycle glass more efficiently and to a better quality within Norfolk. NCC need to comply with the Climate Change Act and the UK's legal obligations to reduce greenhouse gas emissions.

NCC has failed objective MSO9 this in part is due to Sibelco's proven poor record for restoration of previous worked sites, in the case of AOSE the area is already biodiverse.

MSO10 states- Increase public access to the countryside .... through enhancing the amenity value of the land when restoring excavation sites. AOS E and the ⅓ of SIL 02 which remains in the plan is not owned by NCC, therefore the operator; Sibelco, nor the landowner/s, can be compelled by NCC to enhance access for the public as it will not revert to flat open farmland.

Policies MW1-6 There are no sustainable economic or social benefits to be had for the local areas around Marham and Shouldham from any quarrying in Shouldham Warren or Marham Fen. There would only be a couple of jobs created but the siting of a quarry will deter people visiting the area for recreation and tourism and will also stop any local growth, such as that being planned by the Borough Council of King's Lynn and West Norfolk in their Local Plan. Quarrying these areas will remove the social benefits currently enjoyed by residents and visitors to Shouldham Warren and the Nar Valley Way; this is hardly following the NPPF.

MW2 - SA1-13 In AOS E and the area of SIL 02 that it still contains, cannot not be mitigated against, especially the bird-strike risk highlighted by the MOD (DIO) objection, the cumulative effect of all these objectives in short, medium and long term is unacceptable.

MW3 - Transport. We agree with the NCC policy on transport in regards of mineral and waste developments. However, we fail to see how any mitigation measures would be sufficient to not generate all of the unacceptable outcomes listed in MW3 if any mineral development were to be granted permission in AOS E and the area of SIL 02 that it still encompasses.

MW4 - Climate change mitigation and adaptation. NCC has no plans in place to account for reducing CO2 emissions from the quarrying of silica sand. It should put in place a plan that increases the quantity and quality of glass recycling; this will reduce the amount of raw material (silica sand) required to be quarried, which reduces the CO2 emissions from both quarrying and glass manufacturing (more recycled glass used in manufacture reduces CO2 emitted and the energy required).

MW5 - The Brecks Protected Habitats and Species. We note here that birds are afforded a greater buffer zone than that considered acceptable for people close to any proposed or actual mineral development. That is unacceptable. However, there are breeding pairs of Nightjars within The Warren (AOSE) and possibly Woodlarks too, therefore, the Warren should be afforded a 400m buffer as per MW5.

MW6 - In respect of the remaining ⅓ of SIL 02 that is within AOS E, this objective cannot be met since Sibelco (the company proposing the site) state the site would be restored to a lake and not returned to grade 3 agricultural land.

Waste Management WP1 - WP4, SA1-13 NCC states that 'new facilities.... which help to achieve the targets for recycling.....will be encouraged'. NCC should be pursuing itself. Also, the policy mentions that 'initiatives to reduce waste and improve recycling are largely outside the scope of this Plan', however, whilst individual initiatives may be outside the scope they are not exclusive from the Plan. NCC currently ignores the fact that recycling glass more efficiently would not only reduce the amount of CO2 emissions in Norfolk and lessen the requirement for quarrying silica sand and destroying the Norfolk landscape, but would also vastly increase the local economy through the number of jobs created. This is a dereliction of duty to the taxpayers of Norfolk and not fulfilling the UK legal obligation to reduce CO2 emissions. NCC should also be planning to recover the glass from construction sites for recycling to improve the quality of cullet available for the manufacture of new flat glass. This would reduce the amount of raw material (silica sand) required to be quarried from the Norfolk countryside for use elsewhere. By not planning for this glass recovery and recycling NCC is not mitigating to reduce CO2.

Mineral Specific Policies- Forecast need for 13.5M tonnes of silica 2019-36; permitted reserves 3.0M tonnes, therefore, 10.5M tonnes required. All of this is based on no increase in the recycling of clear glass than is already happening.

MP1 -Flawed in respect of silica sand as it assumes that clear glass recycling will not improve, which would reduce the amount of CO2 produced to extract silica sand and during the manufacture of new glass with use of additional high quality cullet. This conflicts with MSO3 and NPPF Guidance (Ch 17, para 204.b) that states to look to recycle before extracting raw material.

MP2 - The area of 250m around sensitive receptors, etc is completely arbitrary and has no basis in research. There have been no studies conducted in the UK, therefore, a 250m zone to mitigate against respiratory dust is unsound.

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.

MP5 - There needs to be a specific time scale added to this statement as to destroy biodiversity for profit under the guise of enhancing it later (20-30+ years hence) through restoration is an illogical step and unacceptable. Also the M&WLP at section MP5 on page 76 describes Core River Valleys in Norfolk as 'vital ecological habitats and corridors, supporting a variety of biodiversity habitats and species. In this respect, Core River Valleys are a key component in the development of Norfolk's identified Green Infrastructure corridors. Sand and gravel resources are commonly found in river valleys and many of Norfolk's river valleys have therefore been quarried for aggregate extensively over many years. This has led to many large bodies of open water left on restoration of past mineral workings which are not in keeping with the general character of Norfolk's river valleys. Although not formally designated, safeguarding the Core River Valleys will help preserve the unique and rich quality of Norfolk's landscape and natural heritage'. With ref to AOS E, including the overlap area that includes a part of SIL 02, with a water bodies already at Pentney and at the Middleton aggregate works just to the north of the river Nar SSSI, then the addition of a much larger water body (e.g.such as the aftermath of SIL 02 as described by Sibelco previously) so close would be exactly what this paragraph explicitly says we shouldn't be doing.

MP6 - Whilst MP6 is about cumulative impacts from other concurrent mineral extraction sites, (we are surrounded by mineral sites and plants in West Norfolk already), and Middleton aggregates is just across the river Nar, it fails to address the other potential cumulative impacts in an area, e.g. a close military airbase with the persistent jet noise. Neither does it mention the cumulative impacts of the period of time for working an area if it is to be prolonged.

MP7 - Restoration - the local community suffer the losses of amenity for the benefit of the mineral operator, the landowner and kudos for the MPA, with a mineral extraction site for many years and even generations being blighted. Neither does it address the timescale that some sites may be actively quarried before greater public access is potentially achievable. Finally, it does not specify that the restoration will be for the benefit of the local community and not a fee paying public for a development by a private company.

MP11 - States on pg 83 of the M&WLP that minerals are a finite natural resource; therefore, NCC's M&WLP is flawed without plans to extend the life of the silica sand resources in Norfolk through an advanced glass recycling policy and plan.

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).