Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council Objection to Quarrying in AOS E and the overlap with SIL 02 at Shouldham and Marham, Norfolk I object to silica sand mining taking place in the area of Area Of Search (AOS) E and its surroundings as proposed in the Norfolk County Council Mineral & Waste Local Plan, Preferred Options July 2019. It is used for outdoor exercise by 1000s of people; young and old. The loss of long-established woodlands would be devastating for mental health and physical well-being. It would be a disaster for the biodiversity of flora and fauna supported by that ecosystem. The destruction of woodland, never to be restored, is unacceptable at a time when Govt's policy (Clean Growth Strategy) is to increase the number of trees in the UK - "Establish a new network of forests in England... plant 11 million trees". We are facing a Climate Crisis. Shouldham Warren is one of our precious planet's lungs, capturing 11,000 tonnes of C02 per year. The Warren provides clean air, home to precious biodiversity, valuable educational space for children and a recreational area well used by so many people. The lack of an improved glass recycling plan to increase the amount of glass cullet available to UK glass manufacturers makes further quarrying for silica sand at the current rate morally wrong. Our environment is our most precious inheritance," says DEFRA, so I urge Norfolk County Council to not allocate the woodlands and agricultural farmland in AOS E and remove AOS E from the Mineral & Waste Local Plan. I also object to quarrying in SIL 02. It is false of Norfolk County Council to say SIL02 has not been allocated whilst retaining 1/3 of the area in Area Of Search, AOS E. It has known mineral deposits, there is a willing landowner, that defines a preferred area. MOD (DIO) objected to the WHOLE of SIL02, I demand that NCC removes this overlap area from their M&WLP.


Comments
I object to silica sand mining taking place in the area of Area Of Search (AOS) E and its surroundings as proposed in the Norfolk County Council Mineral & Waste Local Plan, Preferred Options July 2019.

I've known this woodland for many years, and it is a beautiful and varied landscape, with - unusually for the area - hilly woodland centre, with stunning red oak trees, other broadleaf and a variety of coniferous trees, with shady woodland rights, open sandy paths, and on the edge of watery fenland. This varied landscape is extremely valuable for local people and for people from further afield, and the variety of habitats it provides is extremely valuable for a wide variety of wildlife.

LEISURE
I know that it is used for outdoor exercise by 1000s of people, young and old, doing all sorts of activities, including walking with or without dogs, jogging, orienteering, horse riding, birdwatching, picnicking, and simply enjoying the woodland. East Anglia - apart from Thetford Forest - is very lacking in easily accessible places to walk in an intensively farmed landscape, and even more lacking in woodlands to do so. Woodlands are particularly valued for their variety and for the shade they give in summer and the shelter in winter or poor weather, and the beneficial effect on people's mental and physical health is well recorded and understood. The loss of long-established woodlands would be devastating for mental health and physical well-being.

WILDLIFE
Clearly the woodland is important for wildlife, and its loss would be a disaster for the biodiversity of flora and fauna supported by that ecosystem, including nightjar, raptors, bats, badgers and much more.

SUSTAINABLE FORESTRY
Shouldham Warren is a sustainable working forest, managed by Forestry England, who have well developed plans to harvest and plant trees in a cycle that ensures the best outcomes for wildlife as well as forestry. The forest is mixed, including conifers, birch, heathland remnant open space, and avenues of established broad leaf trees of considerable age and individual examples of veteran trees throughout.

Documents in the Norfolk Record Office show that planting long predates
management by the Forestry Commission, for example:

"Shouldham Warren, tree planting, 1847-1859. Further planting, 1873-1890"

"Estate correspondence inc. abstract of Bardolph Fen and Ouze Banks Commissioners' drainage accounts and sale catalogue of timber at Ling Hills and Shouldham Warren 1896"

Sustainable forestry is extremely important in many ways - to the economy, to the environment, for wildlife, and for people, and this is the ethos of Forestry Commission and Forestry England, and is the basis of international standards for sustainable forestry governed by FSC. In the UK, this is the UK Woodland Assurance Standard. In addition to all these benefits of trees, a working forest provides additional benefits to the economy.

The concept of sustainable multipurpose forestry has been understood by policymakers for many decades, and put into practice by the Forestry Commission and other woodland managers. This is well explained in the Forestry Commission's Shouldham and Bilney Forest Plan, and by other organisations, including the Woodland Trust, https://www.woodlandtrust.org.uk/blog/2018/07/what-is-a-sustainable-forest/ and Confor (which represents forestry managers), http://www.confor.org.uk/our-story/.

It is hard to imagine how anyone could think it acceptable to plan to destroy this woodland. If these plans went ahead, it would never be replaced, and its destruction would be unacceptable in the light of the whole raft of environmental policies of the government, local government, and organisations such as Natural England and the Forestry Commission - most importantly for combating climate change.

You just have to read the Forestry Commission's Shouldham and Bilney Forest Plan to see how important these policies are and how the management of this forest contributes massively to important objectives for the environment in terms of wildlife and climate change, for people and for the economy.

The destruction of woodland, never to be restored, is unacceptable at a time when Govt's policy (Clean Growth Strategy) is to increase the number of trees in the UK - "Establish a new network of forests in England... plant 11 million trees". We are facing a Climate Crisis. Shouldham Warren is one of our precious planet's lungs, capturing 11,000 tonnes of C02 per year.

HISTORY AND ARCHAEOLOGY
Shouldham Warren is of great historic importance in the region, and contains archaeological interest yet to be fully explored. Its destruction to create a quarry would destroy this heritage forever before it is fully understood.

The Norfolk Geodiversity Partnership advised that Shouldham Warren is a
"Special hill with high landscape value and part of a Mediaeval warren", and they advise that it is likely that the hill has high archaeological potential, and investigation could reveal evidence of ancient monuments on the hill would be very important, both of prehistoric settlement as well as mediaeval and possibly earlier rabbit warrening. It is likely that the hill contains remnants of historic rabbit warrening structures - as in Thetford Forest and surrounding areas, where 20 warrens have been protected or partially protected from destruction by agriculture by having been planted as forests.

As yet, the warrening history of Shouldham Warren has not been fully investigated, but the Norfolk Record Office includes documents suggesting that it was important. For example:
"1848 The parish comprises about 3500 acres, of which 600 are occupied by a rabbit-warren, and 100 form a fen belonging to the poor; the soil varies, but the greater portion is fertile, intermixed with light heath."
and
"20 Jun 1634
Sir John Hare of Stowbardolff, Kt. 2) John Cowper the elder of Billney, wariner. Warren of conyes in Shouldham called Harden Hill. Rent £6 13s. 4d. 'two hundred of good and merchantable coneys serviceable for his own table' had to be delivered to Sir John Hare on demand."

In addition, in the Norfolk Record Office is this information about historic features:

"On Mr. Catton's estate is a chalybeate spring called the Silver Well, and near it another spring, both possessing properties similar to those of the waters at Tonbridge-Wells.
"Remnants of an historic spring on top of the hill are indicated by a Rhododendron avenue, there is also a World War II rifle butt close to the entrance."


The lack of an improved glass recycling plan to increase the amount of glass cullet available to UK glass manufacturers makes further quarrying for silica sand at the current rate morally wrong.

"Our environment is our most precious inheritance," says DEFRA, so I urge Norfolk County Council to not allocate the woodlands and agricultural farmland in AOS E and remove AOS E from the Mineral & Waste Local Plan. The Warren provides clean air, home to precious biodiversity, important historical features, and valuable educational space for children and a recreational area well used by so many people.

I also object to quarrying in SIL 02. It is false of Norfolk County Council to say SIL02 has not been allocated whilst retaining 1/3 of the area in Area Of Search, AOS E. It has known mineral deposits, there is a willing landowner, that defines a preferred area. MOD (DIO) objected to the WHOLE of SIL02, I demand that NCC removes this overlap area from their M&WLP.