Object

Representation ID: 98241

Received: 28/10/2019

Respondent: Ms Liz Brewer

RE: Objection to Quarrying in AOS E, SILO 02 in its entirety and the overlap with SIL 02 at Shouldham and Marham, Norfolk.

I object to AOS E, including Shouldham Warren and the overlap with formerly SIL 02, and the entire area of SIL 02 in the Norfolk Minerals and Waste Local Plan. I strongly object to the fact that Norfolk County Council has deliberately misled residents by announcing the removal of SIL 02 when in reality a third of it is now/still included in AOS E.

Please record my objection based on the following grounds:

Protect Environment
I object to protect the environment of AOS E and SIL 02.
I live with my family in Shouldham Warren. If these monstrous plans go ahead and NCC decide to destroy Shouldham Warren, we will be directly affected. We live and breathe this precious woodland environment and will do anything to protect it. I object to the presence of any Silica Sand Quarry. It will ruin the surrounding landscape between Shouldham Warren and Marham Fen, including habitats for endangered birds, animals, and insects. The Warren is home to 64 known species of conservation concern, including endangered bats, nightjars, woodlarks, cuckoos, adders, slow worms, barn owls and very likely badgers too. Evidence which has been recorded by the Norfolk Biodiversity Information Service, The British Trust for Ornithology (Bird Atlas 2007-11) and Forestry England.

Of note birds-wise, the key ones listed in Shouldham Warren area (by the Norfolk Biodiversity and British Trust of Ornithology) are the Nightjar and Woodlark. These are BD1-Birds Directive Annex 1, stating that "...Birds which are the subject of special conservation measures concerning their habitats in order to ensure their survival and reproduction in their area of distribution. As appropriate, 'Special Protection Areas' to be established to assist conservation measures ..." These birds are Breckland specialities and as such, this area will be important for them. Pg.10 in Forestry England's Shouldham and Bilney Forest Plan 2016 - 2026 says, 'Nightjars are ground nesting birds and Shouldham and Bilney Woods provide habitat between the population in Thetford Forest and North Norfolk. They are recording nesting in the transient open space." Open spaces, that need to be protected.

We hear Nightjars every summer in The Warren and have evidence that they are breeding. It's also worth noting that the records reflect more than just the odd bird, but a number of individuals. There are also a number of species (plants and birds) that are listed under the Bern Convention and as such it is illegal to knowingly kill them, as it is under the UK Wildlife Acts - this is an International convention. In general there are also records of a range of threatened farmland bird species, all of which are the focus of dedicated conservation measures and actions funded by the UK Government, via English Nature. Finally, all the bats in the area, from recent surveys, shows the importance of the area and bats have a great deal of legislation that protects them. Although this is more focused on roosts, by the many records noted in the 'Area of Search', I suspect many roosts are nearby.

We need nature and trees now more than ever to combat pollution and Climate Change. 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 and user groups.

With NCC's headquarters based in the east of Norfolk, you might not be aware that according to recent Government data, West Norfolk is responsible for more than a quarter of the County's CO2 emissions. The statistics from the Department for Business, Energy and Industrial Strategy, which are estimates of carbon dioxide emissions from 2005 to 2017, show that the Borough consistently had higher emissions of greenhouse gas than the other Local Authorities in Norfolk. Surely another critical reason to protect woodland areas, like Shouldham Warren more than ever and to not increase already over burdened roads with more and more quarry lorries.

Also stated in Forestry England's Shouldham and Bilney Forest Plan 2016 - 2026 pg 11. "District Council planning guidance is that large areas of plantations should be conserved and managed as striking landscape features and wildlife areas, and to seek to conserve, enhance and link patches of wet woodland."
Shouldham Warren is a sanctuary to rich and rare species that Norfolk County Council should be leading the way in protecting. Not planning to dig up and destroy forever. The wildlife already present is just the beginning. It should be your duty to protect them. The Norfolk Wildlife Trust are keen to explore designating the Warren as an Area of Special Interest. Norfolk County Council should be taking the lead in making this happen.

A sobering recent report by a group of more than 70 conservation charities, research institutions and government bodies, called the 'State of Nature' 2019 highlights a sharp decline in wildlife, plants and fungi caused by a variety of factors that range from climate change to urbanisation. Further reason to protect the biodiversity living in AOS E and SIL 02.

Rosie Hails, Nature and Science Director at the National Trust said: 'We are now at a crossroads when we need to pull together with actions rather than words to stop and reverse the decline of those species at risk as well as protecting and creating new habitats in which they can thrive.'

In Norfolk County Council's, 'Together for Norfolk' research publication titled, 'AN AMBITIOUS PLAN FOR OUR COUNTY 2019-2025'. You state that, "here at Norfolk County Council, we have a clear ambition: for our County to be a place where we put people first, where everyone works together to create a better place to live. A place of opportunity: where we can fulfil our potential and lead productive, healthy and independent lives. A place where we all have the chance to contribute to and benefit from economic growth and regeneration, as well as protecting our unique environment."

Isn't it time you deliver on your ambitious plans? Why not start with Protecting the unique environment of Shouldham Warren by removing AOS E and SIL 02 from the Norfolk Waste and Minerals Plan.

Protect Wellbeing
I to object to protect the wellbeing that just 'being' in Shouldham Warren brings to 1,000's of users as an incredibly valuable recreational space.

You only have to visit https://www.facebook.com/NorfolkCATSS and look at all the comments and pictures from over a thousand people who LOVE the Warren. From horse riders, walkers, families, mountain bikers, runners, dog walkers, photographers, painters...All engage, enjoy and feel connected with nature. To breathe in the fresh air and immerse themselves in the healing energy a woodland provides.

Shouldham Warren makes people feel safe to explore freely.

The British Horse Society, stated that between Nov 2010 - Mar 2019 there have been 3737 reported road incidents - the reality is that only 10% of incidents are reported to BHS. In that time 315 horses have died and 43 humans. This is why recreational spaces like Shouldham Warren are so important to preserve public access too.

Dry or wet worked (any) quarry in Shouldham Warren will have a devastating impact on the mental health of both villages' residents and for the other communities who use the Warren as their natural gym. Evidence shows natural outdoor spaces help with mental and physical health and social interactions. Shouldham Warren and Marham Fen both are used extensively by tourists and locals for experiencing the great outdoors which is backed up by the research of NHS Forest and the Natural England Monitor of 4 Engagement With The Natural Environment.



Protect our villages
I object to protect our surrounding villages from the detrimental impact a quarry will bring to communities.

Referencing NCC's quote in your 'Together for Norfolk' publication you state that '...our County to be a place where we put people first, where everyone works together to create a better place to live.' Living right next to a quarry is hardly creating a better place for people to live. Obviously house prices will be affected and not in a positive sense, in fact, they are already being reduced just from the threat of a quarry. A quarry in the Warren will kill the village (Shouldam) as young families will not want to move here and existing residents will want to leave. Destroying the heart of a desirable, sought after village. Would you move to live next to a quarry for the next 20-30 years and why would you want to stay?

What about the HGV and heavy plant movements? Surely they can't come through our village? Maybe not, but how close they get will depend on the landowners nearby granting permission to run a cross-country road to the quarry from the A134 across their land for a pretty-penny. So the peacefulness of my village would be ruined by the continuous HGV traffic close to the village - noise, pollution, dust will replace the clean air and tranquillity that is here now. Another killer blow to the village. Not to mention the additional pressure of HGV's on the current road system that is already crippling surrounding villages on the trunk roads that lead to and from Kings Lynn, Downham Market /Ely and on to Norwich and wider afield.
Shouldham Warren wraps around neighbouring villages A haven for people and wildlife alike. Even thinking about being there reduces the stresses of the day. Knowing that an outdoor space as beautiful as that is available to local people at the drop of a hat any time - is a gift that cannot be replaced. Taking this away changes village life forever. More stress, poor health, a dying community - that's why I wish to object to protect our village life.

Protect our natural resources
I object to protect the finite natural mineral resource - Silica Sand.


There are national government policies and guidance including DEFRA and the Dept for Business Energy & Industrial Strategy that are clearly being ignored in order to allow a privately-owned Belgian company to profit from the devastation of our community asset, landscape and environment.

Sand is a finite resource and to say there is a 'need' for sand is inconsiderate short term thinking. What will happen when the sand in this part of the world when it has been extracted in 20-30 years' time? Surely we should be protecting Norfolk's precious resources with our lives! When will we come to accept that what is needed is a circular economy where nothing goes to waste, and everything is recycled or reused?

Norfolk County Council only recycles a fraction of the glass already in circulation and we bury more glass than we recycle. Isn't it time to say enough is enough. To say no, to further extraction of resources and to start mining landfills for materials and to have a county-(country-and world-) wide extensive glass collection and recycling mechanism.
NCC's preferred mining privately owned Belgium company, says there is a need for Silica Sand, but then they're the ones who will profit from the destruction of our countryside and the exploitation of our finite mineral wealth. What I want to know is:

* Is there any independent oversight of how much sand is actually being excavated, who it goes to and what it is used for? Is this regulated / audited - if so by who?
* Will any of that sand, our valuable resource, be exported or used for FRACKING?
* Will any of our sand be held in stockpile to create artificial scarcity and drive demand as is practice in both the oil and gas and mineral, most famously diamond, extraction industries?
* In other words, is our countryside and precious woodlands being exploited not for actual demand but to ensure Sibelco's continued profitability?

And, if you think overseas interest in our resources stops there, think again. Sibelco then supply 'Norfolk' silica sand to glass manufacturers owned by Japanese, French, Spanish, Irish and American companies. Are their profits principally enjoyed here in the UK or by private overseas shareholders?

I question, why instead of digging up more of our precious and finite mineral resources aren't Norfolk County Council driving recycling up the political agenda. Especially, in a County where such a high percentage of our glass currently goes to landfill...

Protect our heritage
I object to protect the heritage of Shouldham and Marham Fen.

As reported in Oct 2017 by the Planning Inspectorate in the Examination of the Norfolk Minerals Site Specific Allocations DPD: Single Issue Silica Sand Review. He comments that 'whilst the Historic Landscape Characterisation study is high-level, it is sufficient to establish that an area of some 20 hectares has the potential to come forward within the AoS boundary without resulting in unacceptable harm to the historic landscape.' Surely this is like finding a needle in a haystack, once all the necessary exclusion areas around protect wildlife and ancient trees is researched, public right of ways are protected, safeguarding zones around private property enforced, aquifers protected and all the ancient settlements left untouched.The complexity of implementing any quarry in AOS E, under these terms, must surely become an impossible task. Why not put UK taxpayers money to better use and protect this area of search, and look elsewhere for Silica Sand. If this is a 'resource of national importance' - who says that it is?

Norfolk County Council should be safeguarding the heritage of Shouldham Warren and around Marham Fen. This is an area with a long history of settlement throughout human history. Flint artefacts, including a flint "anvil-stone" found at the highest point of Shouldham Warren, reveal prehistoric activity. Cropmarks and finds indicate Bronze Age habitation, and there were Iron Age smelting pits at East Winch. In the Roman era Shouldham appears to have been a centre of some importance. Later, Anglo-Danish nobles held land in the area and there is evidence for habitation in the Early and Late Saxon periods, with well-established agricultural settlements by the time of Domesday (1086).

The Historic Environment Impact Assessment of AOS E and SIL 02 April 2019 with focus on Pentney Priory Gatehouse, suggested that a large area of SIL02 should be withdrawn from the plan as it was incompatible with the historic setting and context of this scheduled monument. What is not covered in this impact statement is the buried remains of part of this Augustinian Priory; there is nothing visible above ground but is revealed by crop marks, covering approximately 13.5 hectare area to the South towards the river Nar, and to the East and West. Surely this area should be designated as an area of historical importance? The finds could well stretch the length of the area of the former SIL02, now subsumed as part of AOS E, as the river Nar was diverted in the monastic period. Settlements and artefacts undiscovered would be lost forever if any quarrying was to take place. Given the significance and proximity to the six sites, three either side of the Nar, surely a very detailed historic analysis and archaeological study should be paramount and Norfolk County Council should exclude this area and remove it from their plan.

A quarry in AOS E and/or the overlap of SIL 02 the Preferred Area 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.

Protect our defence personnel
I object to protect our defence personnel directly affected by the increased risk of bird-strikes from an open wet quarry.

So, what about the bird-strike risk to the aircraft at RAF Marham and the financial penalty that would incur the UK tax payer?

It is a fact that birds are a problem at any airport. However, RAF Marham isn't just 'any' airport; it is the Main Operating Base (MOB) for the F35 Lightning II, an aircraft that costs an eye-watering £100+ per basic aircraft. The loss of an aircraft due to the loss of an engine or major airframe damage from a bird-strike would be financially intolerable and a major blow to the defence of the UK and our wider interests. The other costs of a crash landing of the aircraft to cover emergency services and long term care and support to the affected people on the ground, are incalculable but would run into the tens if not hundreds of million pounds.

It would be argued that there is a set of lakes very close to RAF Coningsby and that is tolerated but, it should be noted that these quarries had been worked for many years previously and that this practise of allowing large man-made lakes near an airfield is no longer tolerated - a precautionary principle of risk applies.

It should also be noted that the Typhoon at Coningsby has 2 engines as opposed to the ONE engine that the F35 has, which gives it a better chance to be able to land if one engine is damaged. This is not a luxury the F35 has and, since it isn't a glider, it will not be guided away from the school or the houses before it crashes due to the loss of its ONE and only engine. In other words you cannot compare the 2 places as like for like and overall, on finance alone, the extra risk due to the construction of a water filled quarry so close to RAF Marham is unacceptable to the tax-payer. MOD (DIO) have rightly objected to any quarry that will be wet worked or wet restored in SIL 02, AOS E and AOS J because of this increased risk of bird-strike it would bring. In fact, a recent report of a US Marine 5 Corps F35 hitting a bird during the take-off roll caused the aircraft take-off to be aborted and the damage caused amounted to more than $2,000,000 to repair. It 5 F35 bird-strike report 3 appears obvious to everyone except NCC and Sibelco that quarrying in this area of the Safeguarding Zone around RAF Marham is not acceptable.

And it's not just accidents we need worry about - the seasonal movements of large flocks of water birds could mean that RAF MARHAM is actually unable to safely operate aircraft to counter threats to UK security at certain times of the year. Imagine, not being able to secure our own borders because a European company has been granted permission to mine in the UK.

Finally, let's not forget that our Armed Forces already take huge risks for us when we deploy them. Exposing them to entirely avoidable risks at home, merely for private profit, seems reprehensible.


Protect health
I object to protect the health of my family and surrounding local community from the exposure to Silica Sand Dust.

What reassurance can the NCC give my family - myself, my husband [redacted text - personal data] and our two young children will not be exposed to Silica Dust if a quarry is granted permission?

We all know there are health risks associated with silica sand and dust associated with it; health risks created by mining, quarrying, construction and demolition. Indeed, silicosis is the oldest known environmental lung disease and is caused by inhaling tiny particles of silica that are so fine that they can travel long distances in even a light breeze - which is hardly reassuring in a famously windy county.

The symptoms of silicosis can appear anything from a few weeks to many years after exposure and typically worsen over time. Now well researched, the risks within Industry where employees can be exposed to acute levels of silica are well known and legislation exists to protect workers. What isn't known is the impact of chronic exposure particularly amongst vulnerable sections of the community such as young children whose lungs are still developing and the infirm who may already have compromised respiratory systems.

The industry it appears (after hours of research) has a very poor track record of self-regulation or placing public health before profit - one only need look at the tobacco industry and years of denying and even suppressing the health risks of smoking, of the petrochemical industry and the use of lead, of the building industry and asbestos (including Eurogrit BV, a company owned by Sibelco) and big agri-industry and DDT to see a clear pattern of 'profit first' forming.

Despite Sibelco's (NCC's preferred mining company) seemingly baseless assurances of safety we must remember that a lack of research-based evidence is not the same as a lack of risk. Contrary to Mike Hurley's (Sibelco's representative) assertion the Silica dust doesn't travel far, studies from the USA and Australia suggest particulates of PM2.5 (the ones you can breathe deep into the lungs) reach many miles beyond the quarry and there is specific research being conducted outside the UK, examining the impact of chronic exposure to silica dust in communities neighbouring mines and quarries.

The Ministry of Defence (MOD) has stated there is an unacceptable risk to aircraft with wet working in the area of AOS E; therefore, a dry worked quarry would be Sibelco and NCC's plan for Shouldham Warren which would destroy this peaceful recreational area. The recommendation of the NCC Development and Infrastructure Committee (minutes of 17 July 19) stated with reference to AOS E, "a smaller area that is elevated (not wet) could come forward in this plan and not cause significant objections". Shouldham Warren is elevated and is approx 21m above sea level. That being the case I am very concerned about health implications arising from dry worked quarrying within Shouldham Warren.

Might I also remind you that, The Health and Social Care Act 2012 delegated duties to Local Authorities to improve public health and reduce health inequalities. Section 12, of the 2012 Act 4 introduced a new duty for all upper-tier and unitary Local Authorities in England to take appropriate steps to improve the health of the people who live in their areas. There is a range of legislation that protects biodiversity and urban green spaces by regulating planning, contamination and conservation, including the Wildlife and Countryside Act 1981, Environmental Protection Act 1990 and the Planning Act 2008. The Natural Environment White Paper addresses the importance of accessible green space and links to human health. The Health and Wellbeing Board has named prevention of ill health one of its top priorities and several studies have shown that £1 spent on enabling access to green spaces gives a return of £6 or more in benefits.

Our local residents, old or young, benefit from the outdoor lifestyle afforded by Marham Fen and Shouldham Warren with regular walks enhancing our heart health, lowering blood pressure, improving weight control, while keeping joints and muscles strong and improving mood and mental wellbeing and improving our health.

Protect our children's future
I object to protect the area's future of AOS E and SIL 02 for many generations to come.

On 20th September 2019, millions of children all over the world took part in the largest global climate change protest because they think that adults, politicians and big companies aren't doing enough to tackle climate change, and they're right, we're not doing enough.

So, Norfolk County Council - are you listening? As our 7yr old son said to me 'I hope they listen, that would be nice, as I really don't want a nasty, horrible quarry here in the beautiful Warren.'

At a time when 1 in 5 children leaving primary school in West Norfolk are obese, the importance of doing all that we can as a society to encourage a healthier lifestyle cannot be underestimated. The local primary school - St. Martin of Shouldham, regularly visits the Warren for educational purposes where the children learn through Forest School all about the wonders of the natural world.

Today's young people will be the stewards of our planet in the years to come, and the future of all life depends on them gaining the knowledge, skills and passion for nature necessary to transform humanity's relationship with the natural world and build a more sustainable future. But let's look at future regeneration. What reputation does NCC's preferred mining company have with regeneration? Bawsey Lake spring to mind and the tragic drownings? You only have to do a quick Google search to see the negative press following the aftermath of a quarry owned by Sibelco.

Even if we ignore the sorry state of Bawsey here in Norfolk, we need only look at Moneystone Quarry in Staffordshire to see another example of Sibelco's restoration gone wrong or how in Heerlen in the Netherlands, Sibelco extended their licence from the original closure and restoration date of 2000, to 2020 and now out to 2033. We can even look as far as the other side of the world in Australia, where Sibelco extracted all the mineral wealth from a site and rather than completing the restoration they promised, they simply sold the site to another developer.

Sibelco give us no reason to place our confidence and trust in them. Sibelco does nothing to make us believe they will safeguard our health, or the health of our children.

If we continue to take more from our planet than we put back then we risk its very survival. But this could also be an epoch of opportunity. We understand what is happening and how we can change the way we live to shape a better future for our planet, where human beings can thrive alongside nature. By making the right choices now we can nurture our planet's special qualities and protect the Earth for many generations to come.

''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 SIL02 and remove both areas from the Mineral & Waste Local Plan.

Please record this as my objection.