Object
Preferred Options consultation document
Representation ID: 94929
Received: 29/10/2019
Respondent: Mr JJ Gallagher
I object to Norfolk's M&WLP for the following reasons. NPPF para 35, lists the four criteria that are the basis of a sound plan; Positively Prepared, Justified, Effective, and Consistent with National Policy. This plan is unsound based on these four criteria especially relating to SIL02 overlap in AOSE.
1. Positively Prepared - Norfolk County Council does not take into account Ch.17 para 204.b NPPF. There is no forward-thinking in respect of recycling glass, especially flat glass that would preserve minerals for future generations. Without glass recycling at the forefront of planning, there is no positive or preparedness in this plan and it is unsound on that basis; "the benefits of glass recycling are clear" to quote Sibelco. Norfolk, especially West Norfolk would benefit from job creation, ensuring finite resources are protected for the future and the wellbeing of residents are given paramount importance over business that takes profit from the County. Quarrying is not the answer, it's environmentally unfriendly; to offset any CO2 emissions HGV transport needs to be avoided if we want to be carbon neutral in the timescale the Govt. has mandated.
2. Justified - NCC give favourable status to areas that have already been developed by quarry operators and in Sibelco's case, they are granted extension after extension under the premise that you can only work where silica sand is found. This is true to an extent, however, you cannot justify the area around RAF Marham due to bird strike risk. There are other areas that already have bird populations that could be worked without risking RAF Marham personnel and surrounding villages. There is no justification for the area of SIL02, 390 hectares and AOSE nearly 1000 hectares. The Climate Change Act requires reductions in CO2 emissions with the aim of being carbon neutral by 2050, that cannot be achieved by quarrying no matter how it is worked. No justification for the misuse of good agricultural land and forest. No justification that allows Pentney Priory Gatehouse historic landscape to be destroyed. If we fail to import silica sand, we will lose our own reserves of this finite material and fail to preserve the heritage, health, and wealth of the nation for future generations.
3. Effective - This plan is not compliant with DEFRA's 25 Year Plan, with BEIS Clean Growth Strategy, or NPPG Refs : 27-012,013,017 and 045-20140306 , or NPPF guidance to look to recycle before extraction of raw materials. How can you say this plan is effective when you have no vision to change the past destructive practices of quarrying and continue with the status quo? Only a forward-thinking plan that includes recycling glass, especially flat glass would make the plan effective. NCC has a duty of care to the taxpayers of Norfolk to ensure that our homes and lives are not affected to our detriment. How is this plan effective if NCC is not abiding by the Climate Change Act; DEFRAs 25 Year Plan, BEIS Green Energy Plan, the need to be more self-sufficient in growing food-stuffs for the nation and the practice of ignoring NPPF on the need to reserve finite resources effectively?
4. Consistent with National Policy - This plan is NOT compliant with DEFRAs 25 Year Plan to Improve the Environment, the Gov plan for Rural Proofing, the NPPW, BEIS Clean Growth Strategy, NPPG Refs : 27-012,013,017 and 045-20140306, or NPPF looking to recycle before extraction of raw materials; therefore, this plan is not consistent with National Policy and is unsound.
I object to Norfolk's M&WLP for the following reasons. NPPF para 35, lists the four criteria that are the basis of a sound plan; Positively Prepared, Justified, Effective, and Consistent with National Policy. This plan is unsound based on these four criteria especially relating to SIL02 overlap in AOSE.
1. Positively Prepared - Norfolk County Council does not take into account Ch.17 para 204.b NPPF. There is no forward-thinking in respect of recycling glass, especially flat glass that would preserve minerals for future generations. Without glass recycling at the forefront of planning, there is no positive or preparedness in this plan and it is unsound on that basis; "the benefits of glass recycling are clear" to quote Sibelco. Norfolk, especially West Norfolk would benefit from job creation, ensuring finite resources are protected for the future and the wellbeing of residents are given paramount importance over business that takes profit from the County. Quarrying is not the answer, it's environmentally unfriendly; to offset any CO2 emissions HGV transport needs to be avoided if we want to be carbon neutral in the timescale the Govt. has mandated.
2. Justified - NCC give favourable status to areas that have already been developed by quarry operators and in Sibelco's case, they are granted extension after extension under the premise that you can only work where silica sand is found. This is true to an extent, however, you cannot justify the area around RAF Marham due to bird strike risk. There are other areas that already have bird populations that could be worked without risking RAF Marham personnel and surrounding villages. There is no justification for the area of SIL02, 390 hectares and AOSE nearly 1000 hectares. The Climate Change Act requires reductions in CO2 emissions with the aim of being carbon neutral by 2050, that cannot be achieved by quarrying no matter how it is worked. No justification for the misuse of good agricultural land and forest. No justification that allows Pentney Priory Gatehouse historic landscape to be destroyed. If we fail to import silica sand, we will lose our own reserves of this finite material and fail to preserve the heritage, health, and wealth of the nation for future generations.
3. Effective - This plan is not compliant with DEFRA's 25 Year Plan, with BEIS Clean Growth Strategy, or NPPG Refs : 27-012,013,017 and 045-20140306 , or NPPF guidance to look to recycle before extraction of raw materials. How can you say this plan is effective when you have no vision to change the past destructive practices of quarrying and continue with the status quo? Only a forward-thinking plan that includes recycling glass, especially flat glass would make the plan effective. NCC has a duty of care to the taxpayers of Norfolk to ensure that our homes and lives are not affected to our detriment. How is this plan effective if NCC is not abiding by the Climate Change Act; DEFRAs 25 Year Plan, BEIS Green Energy Plan, the need to be more self-sufficient in growing food-stuffs for the nation and the practice of ignoring NPPF on the need to reserve finite resources effectively?
4. Consistent with National Policy - This plan is NOT compliant with DEFRAs 25 Year Plan to Improve the Environment, the Gov plan for Rural Proofing, the NPPW, BEIS Clean Growth Strategy, NPPG Refs : 27-012,013,017 and 045-20140306, or NPPF looking to recycle before extraction of raw materials; therefore, this plan is not consistent with National Policy and is unsound.