Norfolk County Council's (NCC) Mineral and Waste Local Plan (M&WLP) fails its Vision, Policies and Objectives. Let me expand below.

The National Planning Policy Framework (NPPF) clearly states in Chap 17, para 204 b, that Mineral Planning Authorities (MPA) should look conserve minerals and 'take account of...recycled materials...before considering extraction of primary materials. The current proposed Preferred Options M&WLP shows no sign of adhering to this part of the NPPF and therefore the plan must be unsound

I now reference the Waste Management Objectives. Without forging a robust, advanced clear and flat glass recycling facility here in Norfolk NCC will fail to prevent and minimise waste within the county, and fail to support reductions in CO2 emissions that such a facility would bring to the glassmaking industry. To even suggest that Norfolk could be net self-sufficient in waste management is incredible if waste continues to be exported from within Norfolk to outside our boundaries. NCC could get close to net self-sufficiency in glass waste recycling if they had the vision to lead the way, nationally, in advanced glass recycling facilities, facilities that would fulfil WSO8 by generating jobs for Norfolk by the hundreds and potentially thousands.

Mineral Strategic Objectives - In order for MSO 2 to be sound it must quantify what is an 'adequate' supply. Currently, in the case of silica sand, the figures that NCC use to quantify adequate are based on the 'need' that Sibelco, the monopoly company extracting silica sand in Norfolk, tell NCC is the need. There is no independent verification by NCC of these figures; they do not know where the extracted silica sand goes to once it leaves Norfolk; they do not know if any glassmaking sand from Leziate is exported; they do not have independent verification of the actual quantities extracted each year. An extremely loose set of affairs that makes the plan for silica sand extraction in Norfolk unsound.

MSO 6 could be fulfilled by planning and instigating a world-class glass recycling infrastructure in Norfolk. It would reduce the need to quarry huge areas of countryside. MSO7 could also be fulfilled by the plan for recycling glass above because the areas required would be reduced meaning fewer people living within proximity of a silica sand quarry.

NCC is poorly placed to argue that MSO 8 is being fulfilled without planning to introduce a world-class recycling infrastructure in Norfolk. Without this, they are not fulfilling their obligation to The Climate Change Act or supporting the UK's legal obligations to reduce the production of greenhouse gases. Recycling as suggested here reduces the amount of raw material required in glass manufacture, which reduces the CO2 produced in the process and uses less energy. Without more efficient clear and flat glass recycling at greater rates than present NCC fail MSO 8.

In respect of MSO 9, it is illogical and unsound to try and defend destroying already richly diverse habitats for generations to come in order to quarry for minerals, by stating that your objective is, "The after use will protect and enhance the environment, including landscape and biodiversity improvements". The areas in question are already biodiverse, if they need improving then do that now not pretend that quarries will be returned to an idyllic wonderland. That statement in MSO 9 is at best wishful thinking and history proves it is unenforceable. Without a doubt, MSO 9 is unsound.

Similarly, MSO10 is unsound and illogical if the plan is to give over to quarrying areas of countryside that are already accessible to the public. Such areas exist within the M&WLP and whilst they remain the plan is unsound.
Policies MW - There are no sustainable economic or social benefits to be had for the local areas from quarrying in Shouldham Warren or Marham Fen. For a couple of jobs created by a quarry there, more agricultural working jobs would be lost Tourists to the Nar Valley Way and Shouldham Warren would be deterred - why would they wish to spend their recreational outdoor leisure time next to a working silica sand quarry? Those tourists deterred then impact local businesses. The area is specifically designated in the local Borough Council's Local Development Plan as an area for new housing to support the RAF Main Operating Base for the Lightning II at RAF Marham, but why would families locate there to live beside a working silica sand quarry? The answer is they wouldn't. Quarrying in these areas will not enhance the social benefits or amenity currently enjoyed by residents and visitors to Shouldham Warren and the Nar Valley Way; it will remove them and that is not following the NPPF.

MW2 There are 13 impacts listed that mineral development must not have an unacceptable impact upon. For AOS E and the area of SIL 02 that it still contains all of the impacts listed are present and cannot be mitigated against The bird-strike risk alone highlighted by the MOD (DIO) objection in the Initial Consultation, should be enough to have these areas removed from the M&WLP; however, add the cumulative effect of all the objectives and in any timeframe quarrying in these areas is an unacceptable risk.

MW3 - NCC policy on transport in regards to mineral and waste developments is agreeable in general. However, if any mineral development were to be granted permission in AOS E and the area of SIL 02 that it still contains, it is difficult to see what mitigation measures would be sufficient against all of the unacceptable outcomes listed.

MW4 - Without forging a robust, advanced clear and flat glass recycling facility here in Norfolk, which would reduce the CO2 emissions from both quarrying and glass manufacturing (more recycled glass used in manufacture reduces CO2 emissions and the energy required), the M&WLP is unsound in not accounting for the reductions that are available but not planned for as set out in MW4.

MW5 - The Brecks Protected Habitats and Species. How can it be acceptable to place a greater protection buffer zone around a species of bird than that considered acceptable for people who live close to any proposed or actual mineral development? Providing protection to wildlife from the adverse impacts of humans is right and proper. There are breeding pairs of Nightjars within Shouldham 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. Therefore, AOS E and SIL 02 should be removed from the plan going forward.

Waste Management WP1 - WP4, SA1-13 NCC states that 'new facilities.... which help to achieve the targets for recycling.....will be encouraged' but also says, 'initiatives to reduce waste and improve recycling are largely outside the scope of this Plan'. This makes the plan unsound as you cannot have it both ways; if you want to encourage recycling then new initiatives cannot be outside the scope of the plan. NCC should be pursuing a radical overhaul to their current system of glass recycling with a view to leading the field nationally in forging ahead with an innovative plan to ensure Norfolk sets the standards for clear and flat glass recycling. 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. Not engaging in this is a dereliction of duty to the taxpayers of Norfolk and is not fulfilling the UK legal obligation to reduce CO2 emissions.

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

MP1 -The policy is flawed because it assumes, for silica sand, that clear glass recycling will not improve, which in turn conflicts with MSO3 and NPPF Guidance (Ch 17, para 204.b) that states to look to recycle before extracting raw material.

MP2 - Where is the research that shows an area of 250m around sensitive receptors, etc is a reasonable and sound distance? It is completely arbitrary and has no basis in research, therefore the figure assumed is unsound. In addition, it is noted that in policy MW5 a protection zone of 1500m from a mineral site is mandated for any area supporting a bird (Stone Curlew) but a buffer of merely 250m, or less, is deemed acceptable for humans. This also makes the M&WLP unsound.

MP5 - This policy is unsound without the addition of an acceptable timescale. It is too open-ended and could allow for quarrying for several generations before any 'enhancement' occurs; that is 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 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 - The areas around Shouldham and Marham have a plethora of mineral sites and plants already, and whilst MP6 is to address cumulative impacts of phased workings the M&WLP 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. Without these consideration being added to the policy, it is unsound.

MP7 - Restoration - Once again there is no timeframe bounding how long communities must suffer quarrying in their area before it will be restored. The statement "that worked land is reclaimed at the earliest opportunity" is open to interpretation in favour of the quarrying company and the disadvantage of the local residents. That makes the policy flawed, unacceptable and unsound. As it currently stands the policy means a local community suffers the loss of amenity for the benefit of the mineral operator, the landowner and the kudos for the MPA, for a mineral extraction site that lasts for many years and even generations. 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. Without a definitive timescale to restoration and guarantees that land will be returned freely for the amenity of the local community, this policy is unsound.

MP11 - States on pg 83 of the M&WLP that minerals are a finite natural resource; therefore, NCC's M&WLP is unsound 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 the NCC M&WLP 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).