Object

Preferred Options consultation document

Representation ID: 98219

Received: 28/10/2019

Respondent: Ms Christine Wilson-Low

Representation Summary:

I object to mining proposals in AOS E and the area known as SIL 02, including the overlap of both areas which I will refer to in this objection as 'the overlap of SIL 02'. I object under the following headings:
● Economic
● Environmental
● Historical assets
● Health

Economic- I object to the planned proposal in AOS E and the overlap of SIL 02 on economic grounds namely-
1. The enormous increased risk of birdstrikes to the aircraft flying at RAF Marham. The sums of money that would be required to replace just one F35 aircraft is more than Sibelco's annual turnover in the UK. The cost of a repair from a birdstrike can run to £millions. There has been a very relevant objection from the DIO/RAF this was given serious consideration which led to SIL 02 being taken off the proposal/consultation plan .However, this was a deceptive move by the NCC because 1) the SIL 02 was not completely removed, some is still in AOS E and 2)There is a Aerodromes Safeguarding Zone with a 13 km restriction to safe guard airports/air bases. If SIL 02 has been removed, due to the military objection then why hasn't AOS E also been eradicated? I object to the complete lack of consistency and transparency in the policy or the procedures of the NCC. As both SIL 02 and AOS E are both within a 13 km Zone surely, they should both be removed. This directly contravenes the National Planning Policy Framework Point 17 h) relating to Aerodrome Safeguarding Zones.
2. There is a minimal increase in employment opportunities.
3. Debatable claims of adding value to the local economy.
4. No independent scrutiny of the amounts of silica sand required; Sibelco, the company with the monopoly for silica sand extraction in Norfolk supply the figures. If they supply the figures, I ask who is monitoring/reviewing their findings/results? For if the figures are not checked how on earth can they be credible? Do the NCC or the Government blindly believe Sibelco? If so, this is extremely concerning when the Government go to great lengths to monitor the Public Sector Institutions. With this in mind it stands to reason that if only one company is used by the NCC/Government to mine for Silica Sand there can be no comparative and therefore they monopolise the market. This is certainly not fair or just and it enables Sibelco to basically hold the Government to ransom, particularly if there are no checks and balances.
5. The loss of prime agricultural land with the loss of local jobs and damage to the local agricultural industry the loss of the land would cause. This at a time when the UK should be looking to increase our own food production with our imminent departure from the EU. It is believed that the overlap area on AOS E and formally SIL 02 is Agricultural land graded 3. It is my understanding that such land should be used for farming.
6. The loss of the natural open spaces that provide the opportunity for exercise and aid with our mental well-being, which in turn decreases the call on medical intervention and a decrease in cost for the NHS.
7. The stunting of community growth that the siting of a quarry would inevitably cause at a time when our Borough Council's Local Plan proposes Marham as one of its primary growth areas.
9. The sites are adjacent to Nar Valley Way, a long-distance public right of way along the Nar River SSSI, which brings many tourists to the area - tourism revenue for local business will be detrimentally affected. Many thousands of pounds have recently been spent upgrading the River Narr and its walkway so where is the economic sense in wrecking something that has so recently been upgraded to ensure the improvement of the community's health and wellbeing in walking it, and encouraging tourism and thus enhancing the economy of the area.
10.The only economic winners are Sibelco, a private Belgian company whom NCC have no obligation to, unlike their obligation to the economic prosperity of the taxpaying Norfolk population and the populations surrounding the proposed areas, and the landowners, who will no doubt be massive financial gainers and who in at least one case don't even use their farm as a main residence .It is believed they stay for the minimum time to claim farming subsidies and have no interaction or interest in the community.

Environmental -I object to the planned proposal in AOS E and the overlap of SIL 02 on environmental grounds -
5. The quarrying of silica sand within AOS E and SIL 02 has great potential to pollute the primary and secondary aquifers that lie beneath the area. This would be an ecological disaster for our drinking water.
6. Adverse impacts on the hydro-ecology of the Nar River SSSI, a spring-fed chalk river with high conservation value.
7. What is the NCC plan for when this 'finite' resource runs out? Without such a plan how can NCC possibly make any decision to allow quarrying for minerals that will devastate our environment irrevocably?
8.Shouldham Warren AOS E and its overlap with SIL O2 is predominately private land most of which is leased to the Forestry Commission, this area has been maintained well for years and provides important economic and material (wood) production, I object to the proposal because it sets one Government Department against another and with this in mind surely another area should and definitely could be identified. The NCC have been "lazy" in their approach to the Waste and Mineral Plan, relying purely on Sibelco who have no interest in the local community to identify silica sand sites which definitely cannot be justified. "Our environment is our most precious inheritance" - DEFRA This is certainly not Sibelcos' understanding as their restoration on previous quarry's' have been diabolical.

Historical- I object to the planned proposal in AOS E and the overlap of SIL 02 on historical grounds -
1. A quarry in AOS E and/or the overlap of SIL 02 would irreversibly change the local landscape and affect the historical character of the area and the many historical monuments and their setting. This is supported by NCC's own Historic Environment Impact Assessment of AOS E and SIL 02.
Health-I object to the planned proposal in AOS E and the overlap of SIL 02 on health grounds -
The company that are the proposers Sibelco have done few studies on the health impact on surrounding communities, particularly sensitive receptors, By failing to do such studies they remain unaccountable for any health issues that occur relating to people living close to the quarry. The only studies have been in relation to the workforce which in itself implies there are unforeseen health issues. I object to the quarry because I believe it is incumbent on the NCC to safeguard the health and welfare of the local community's. The ECHR Article 2 states "Right to life" which could most definitely be affected by a lack of investigation regarding medical/health and safety illness' caused by a quarry.
Article 8 and Protocol 1 Article 1 protects your right to enjoy your property peacefully. This process alone has adversely affected the mental health of the community by stressing residents. I believe that NCC have not been transparent or lawful in relation to their methodology relating to this consultation. NCC have not taken into account the general interests of the society/the local community and the adverse impact on it. I would argue because of the NCCs lack of addressing the recycling problem their actions if the plan is progressed will not be in the public interest
Additionally, the consultation process undertaken by NCC has lacked transparency and engagement with the community and was executed poorly - i.e. letters sent to only 10 households within an arbitrary boundary of the site, ineffective methodologies for consultation, residents' concerns raised in the first consultation have been ignored. NCC is deliberately obfuscating the issue and misleading consultees by announcing the removal of SIL 02 when in reality a third of it is still there within AOS E.
The Communities of Shouldham and Marham already deal with the RAF noise pollution, Shouldham Warren, all of AOS E and SIL 02 is an area of beauty and solace, it is absolutely unjust to also consider putting a quarry in the area.

Full text:

Phase 2 Consultation. AOS E & SIL 02 & OVERLAP.
Please accept this e mail as my objection.

I object to mining proposals in AOS E and the area known as SIL 02, including the overlap of both areas which I will refer to in this objection as 'the overlap of SIL 02'. I object under the following headings:
● Economic
● Environmental
● Historical assets
● Health

Economic- I object to the planned proposal in AOS E and the overlap of SIL 02 on economic grounds namely-
1. The enormous increased risk of birdstrikes to the aircraft flying at RAF Marham. The sums of money that would be required to replace just one F35 aircraft is more than Sibelco's annual turnover in the UK. The cost of a repair from a birdstrike can run to £millions. There has been a very relevant objection from the DIO/RAF this was given serious consideration which led to SIL 02 being taken off the proposal/consultation plan .However, this was a deceptive move by the NCC because 1) the SIL 02 was not completely removed, some is still in AOS E and 2)There is a Aerodromes Safeguarding Zone with a 13 km restriction to safe guard airports/air bases. If SIL 02 has been removed, due to the military objection then why hasn't AOS E also been eradicated? I object to the complete lack of consistency and transparency in the policy or the procedures of the NCC. As both SIL 02 and AOS E are both within a 13 km Zone surely, they should both be removed. This directly contravenes the National Planning Policy Framework Point 17 h) relating to Aerodrome Safeguarding Zones.
2. There is a minimal increase in employment opportunities.
3. Debatable claims of adding value to the local economy.
4. No independent scrutiny of the amounts of silica sand required; Sibelco, the company with the monopoly for silica sand extraction in Norfolk supply the figures. If they supply the figures, I ask who is monitoring/reviewing their findings/results? For if the figures are not checked how on earth can they be credible? Do the NCC or the Government blindly believe Sibelco? If so, this is extremely concerning when the Government go to great lengths to monitor the Public Sector Institutions. With this in mind it stands to reason that if only one company is used by the NCC/Government to mine for Silica Sand there can be no comparative and therefore they monopolise the market. This is certainly not fair or just and it enables Sibelco to basically hold the Government to ransom, particularly if there are no checks and balances.
5. The loss of prime agricultural land with the loss of local jobs and damage to the local agricultural industry the loss of the land would cause. This at a time when the UK should be looking to increase our own food production with our imminent departure from the EU. It is believed that the overlap area on AOS E and formally SIL 02 is Agricultural land graded 3. It is my understanding that such land should be used for farming.
6. The loss of the natural open spaces that provide the opportunity for exercise and aid with our mental well-being, which in turn decreases the call on medical intervention and a decrease in cost for the NHS.
7. The stunting of community growth that the siting of a quarry would inevitably cause at a time when our Borough Council's Local Plan proposes Marham as one of its primary growth areas.
8. The lack of any plan to improve the recycling of glass, especially clear and flat glass, in order to reduce the amounts of raw materials required, and increase the amount of recycled clear glass cullet used in the manufacture of new glass, is an economic and environmental mistake, without a radical overhaul of the glass recycling plan in Norfolk, NCC is failing the NPPF to "look to recycle before extracting raw materials" The figures are flawed as mentioned previously. The extraction is Not justified as recycling is a reasonable alternative. Economically improved recycling would increase the employment opportunities in Norfolk; environmentally, it would ensure less land (agricultural or otherwise) is destroyed unnecessarily when there are alternatives. This point has been made very strongly on numerous occasions and has never been addressed in any form, 17/10/19 www.norolkcatss.co.uk Objection to Silica Sand Mining in AOS E & SIL 02- Preferred Options Consultation 1.
9. The sites are adjacent to Nar Valley Way, a long-distance public right of way along the Nar River SSSI, which brings many tourists to the area - tourism revenue for local business will be detrimentally affected. Many thousands of pounds have recently been spent upgrading the River Narr and its walkway so where is the economic sense in wrecking something that has so recently been upgraded to ensure the improvement of the community's health and wellbeing in walking it, and encouraging tourism and thus enhancing the economy of the area.
10.The only economic winners are Sibelco, a private Belgian company whom NCC have no obligation to, unlike their obligation to the economic prosperity of the taxpaying Norfolk population and the populations surrounding the proposed areas, and the landowners, who will no doubt be massive financial gainers and who in at least one case don't even use their farm as a main residence .It is believed they stay for the minimum time to claim farming subsidies and have no interaction or interest in the community.
I again object because the NCC Waste and Mineral Plan again directly contravenes Point 17 of the NPPF para 205 states when determining planning applications, great weight should be given to the benefits of mineral extraction including to the economy. The quarry would negatively impact our economy, there would be no benefits to the local economy, in fact there would in this instance be a detrimental effect to existing industries that provide local jobs.
It also contravenes NPPF point 17 para 207 relating to the Minerals Planning authorities and the fact that a plan for a steady and adequate supply of aggregates by: preparing an annual Local Aggregate Assessment, either individually or jointly to forecast future demand, based on a rolling average of 10 years' sales data and other relevant local information, and assessment of all supply options(including marine dredged secondary and recycled sources); It is my understanding that there are NO provisions for recycled sources in the plan or in the assessments of "needs". This means that I again object because this plan by the NCC is unsound and entirely inconsistent with National Planning Policies.

Overall, quarrying for silica sand in AOS E and the overlap of SIL 02 do not make economic sense for Norfolk or the UK
Environmental -I object to the planned proposal in AOS E and the overlap of SIL 02 on environmental grounds -
1. The removal of the forests in AOS E ignores the Government's current plan to increase the number of trees in the UK for the benefits to the atmosphere that trees possess.
2. The removal of the forests in AOS E will remove the environment that supports the myriad of flora and fauna they contain, including may species on conservation lists.
2a. In the area AOS E and its overlap, protected bird species such as "woodlark" are present I object to the fact that these will be lost if a quarry is allowed. Presently many children attend the Warren to learn about the outdoors, wildlife and our environment there are few such open spaces in West Norfolk and to grant permission for a quarry is to deny the local community their important recreational opportunity
3. The removal of the forests in AOS E would be an action against the reduction of C02 and is in contravention of the Climate Change Act 2008 and the UK Government's stated aim of reducing to net-zero (1990 level) the volume of greenhouse gases in our atmosphere by 2050. It is also in opposition to the Government's '25 Year Plan to Improve the Environment' - "Planting more trees provides not just new habitats for wildlife - it also helps reduce carbon dioxide levels and can reduce flood risk." - Secretary of State. Destroying hundreds of Hectares of trees and topsoil that are the most effective carbon sinks, whilst having no credible reuse or recycling scheme is unsound, "based on the National Planning Policy Framework"
4. The removal of the forests in AOS E would change the local environment such that the people who currently use them for physical recreation and well-being will be denied that connection with nature which has been proven to promote physical and mental health.
5. The quarrying of silica sand within AOS E and SIL 02 has great potential to pollute the primary and secondary aquifers that lie beneath the area. This would be an ecological disaster for our drinking water.
6. Adverse impacts on the hydro-ecology of the Nar River SSSI, a spring-fed chalk river with high conservation value.
7. What is the NCC plan for when this 'finite' resource runs out? Without such a plan how can NCC possibly make any decision to allow quarrying for minerals that will devastate our environment irrevocably?
8.Shouldham Warren AOS E and its overlap with SIL O2 is predominately private land most of which is leased to the Forestry Commission, this area has been maintained well for years and provides important economic and material (wood) production, I object to the proposal because it sets one Government Department against another and with this in mind surely another area should and definitely could be identified. The NCC have been "lazy" in their approach to the Waste and Mineral Plan, relying purely on Sibelco who have no interest in the local community to identify silica sand sites which definitely cannot be justified. "Our environment is our most precious inheritance" - DEFRA This is certainly not Sibelcos' understanding as their restoration on previous quarry's' have been diabolical.
9. The Badgers Trust believe that Badgers may well be settled in the area of Shouldham Warren and surely the NCC must ensure that this is not the case.

I object to the fact that overall NCC does not have a sound plan to ensure the protection of our environment. The current M&WLP plan directly contradicts the Government's stated objectives for the environment. Paragraph 180 NPPF," Planning policies and decision's" should also ensure that a new development is appropriate for its location taking into account the cumulative effects of pollution on health, living conditions and the natural environment. In doing so, they should b) identify and protect tranquil areas which have remained relatively undisturbed by noise and prized for their recreational amenity value for this reason-THERE IS NO OTHER COMPARABLE TRANQUIL AREA/AMENITY OF THIS SIZE IN WEST NORFOLK.
Point 17 of NPPF states that planning policies should b) as far as possible, take account of the contribution that substitute or secondary and recycled materials and minerals waste would make the supply of materials , before considering extraction of primary minerals, whilst aiming to source mineral supplies indigenously; -I object because the NCC has failed to have any modern innovative recycling plans.
Point 17 NPPF f) states that criteria should be set out to ensure that permitted and proposed operations do not have unacceptable adverse impacts on the natural and historic environment or human health, taking into account the cumulative effects of multiple impacts from individual sites and/or a number of sites in a locality; there is no definition of "unacceptable adverse impacts" that relate to or share the perspective of the local community/taxpayers- the impacts of a quarry, are numerous, many health impacts have not even been investigated (probably deliberately by Sibelco, because then they and the NCC would be accountable) this impact cannot be acceptable.
I further object to the quarry in relation to point 17 NPPF h) which states "ensure that worked land is reclaimed at the earliest opportunity, taking into account of aviation safety, and that high quality restoration and aftercare of mineral sites takes place:
Point 17 of the NPPF para 205 states when determining planning applications, great weight should be given to the benefits of mineral extraction including to the economy.

Historical- I object to the planned proposal in AOS E and the overlap of SIL 02 on historical grounds -
1. A quarry in AOS E and/or the overlap of SIL 02 would irreversibly change the local landscape and affect the historical character of the area and the many historical monuments and their setting. This is supported by NCC's own Historic Environment Impact Assessment of AOS E and SIL 02.
Health-I object to the planned proposal in AOS E and the overlap of SIL 02 on health grounds -
1. To quarry in AOS E or the overlap of SIL 02 would remove an outdoor area used by thousands as their recreational area for physical exercise. 2. Outdoor exercise in areas such as AOS E and the overlap of SIL 02 are proven by research to improve the nations physical and mental health. To lose such areas to mineral quarrying would amount to a contemptuous act on the population and a cost to the tax-payer via the increased workload on the NHS that would be an inevitable consequence.
The company that are the proposers Sibelco have done few studies on the health impact on surrounding communities, particularly sensitive receptors, By failing to do such studies they remain unaccountable for any health issues that occur relating to people living close to the quarry. The only studies have been in relation to the workforce which in itself implies there are unforeseen health issues. I object to the quarry because I believe it is incumbent on the NCC to safeguard the health and welfare of the local community's. The ECHR Article 2 states "Right to life" which could most definitely be affected by a lack of investigation regarding medical/health and safety illness' caused by a quarry.
Article 8 and Protocol 1 Article 1 protects your right to enjoy your property peacefully. This process alone has adversely affected the mental health of the community by stressing residents. I believe that NCC have not been transparent or lawful in relation to their methodology relating to this consultation. NCC have not taken into account the general interests of the society/the local community and the adverse impact on it. I would argue because of the NCCs lack of addressing the recycling problem their actions if the plan is progressed will not be in the public interest
Additionally, the consultation process undertaken by NCC has lacked transparency and engagement with the community and was executed poorly - i.e. letters sent to only 10 households within an arbitrary boundary of the site, ineffective methodologies for consultation, residents' concerns raised in the first consultation have been ignored. NCC is deliberately obfuscating the issue and misleading consultees by announcing the removal of SIL 02 when in reality a third of it is still there within AOS E.
The Communities of Shouldham and Marham already deal with the RAF noise pollution, Shouldham Warren, all of AOS E and SIL 02 is an area of beauty and solace, it is absolutely unjust to also consider putting a quarry in the area.