Object
Preferred Options consultation document
Representation ID: 98616
Received: 18/10/2019
Respondent: Mr JJ Gallagher
Please enter this letter as my economic objection to quarrying taking place in the areas of Area of Search (AOS) E and SIL 02 in the Preferred Consultation of the Mineral and Waste Local Plan (M&WLP) Review.
The very first paragraph of the Introduction to the M&WLP on pg 7 states, "The provision of a steady and adequate supply of minerals and the management of waste constitute essential infrastructure to support the economic development of the county". Since all silica sand quarried by Sibelco (the monopoly mineral operator for silica sand in Norfolk) is exported out of Norfolk, it cannot be 'supporting the economic development of the county'. Norfolk receives no benefit for allowing the countryside to be ripped apart and then the mineral only used outside of the county. Quarrying for silica sand or granting future planning applications to further quarry for silica sand in Norfolk cannot be argued, by NCC or Sibelco, to be supporting Norfolk's economic development. The current Sibeclo Leziate plant employs less than 50 people and any new quarry in AOS E or SIL 02 would only provide jobs for a couple of people, that is hardly supporting the economic development of Norfolk.
I also object to the fact there are no checks and balances of the amount of silica sand being quarried and where it goes to, other than NCC requesting Sibelco provide their annual production information on figures that Sibelco supplied to NCC as their requirement each year (a statement from the Cabinet member responsible for the M&WLP in an email reply of 25 June 2019 to a question I posed on this matter). Or to put it another way, Sibelco tell NCC what they want and that is then interpreted by NCC as the amount required for a 'steady and adequate supply' without any further independent investigation; those figures are then confirmed each year by Sibelco sending their production figures on request to NCC. That is what is colloquially known as 'marking your own home-work' and we all know where that got Volkswagen recently in their emissions data scandal. NCC is prepared to allow a privately owned, Belgian, multinational company to tear up the ground in West Norfolk for their own profit, just based on what that company says they need without any further robust independent checks. That is an abdication of duty to the tax-payers and residents of Norfolk and I object to it.
In the last consultation period, the MOD(DIO) objected to SIL 02 becoming a quarry due to the wet working and wet restoration that was proposed there and the increase in the birdstrike risk that would impose on RAF Marham. They also commented on AOS E (and AOS J) to say that they would have concerns if they were to be wet worked or wet restored for the same reason. On economic grounds alone a birdstrike that brought down an aircraft would cost the UK taxpayer, just to replace the aircraft, approximately as much as Sibelco turned over in the UK according to the figures in their last published accounts. That is just one birdstrike. Lesser catastrophic birdstrikes would cost £millions to repair each time. Add into the
equation the costs that would be incurred to clear up a crash, and the costs to treat people affected by it both physically and mentally. A quarry in the area of AOS E or SIL 02 will be wet worked because the water table is so high; it would be restored wet because it wouldn't be possible or economically viable to dry restore water-filled hole 30m or more deep - the total cost to the tax-payer from birdstrikes is eye-watering and an unacceptable risk to take.
Let's look at the economic costs of removing outdoor areas that the public use regularly for their recreational activities - walking, running, horse-riding, cycle-riding and general relaxation. The areas of AOS E, SIL 02 and areas around them are used by thousands of local residents and tourists alike. The Nar Valley Way, a national footpath and bridleway, is adjacent to the north of the areas and is used by people from all over the UK. By allowing quarrying to occur in AOS E or SIL 02 will take away amenities that are enjoyed by people from all over the country; local business would be affected by the downturn in tourists. Moreover, with the level of obesity rising in the UK and the proven positive effects that exercising or relaxing outdoors has on the physical and mental health of the population, it would be economic folly to take away such a facility. Just this week it was reported that the cost to the NHS in treating mental anxiety and depression is £70M - £100M per year; add to that the treatment for obesity and the secondary diseases it causes and the local NHS costs would rise as a direct result of quarrying in AOS E and SIL 02. In addition to the economic costs involved from removing the outdoor spaces in order to quarry is directly in opposition to the aim in NCC's 'Vision to 2036' (page 19, Sect 6) that "Mineral development and waste management facilities will be located, designed and operated without unacceptable adverse impacts on the amenity of local communities....'; on that aim alone the areas of AOS E and SIL 02 should be removed from the M&WLP now.
Further economic impacts from permitting quarrying in AOS E and SIL is the loss of prime agricultural land. This would lead to a loss of the local jobs working the land and in the local food processing industry; loss of many more jobs than the couple that Sibelco says it would create at any quarry. Neither does it makes sense nationally at a time when the Gov policy is to increase and improve our agricultural land so that the UK becomes more self-sufficient in our food production; swapping agricultural land for a quarry is economically unsound and against Gov policy.
I object to quarrying in AOS E and SIL 02, and to silica sand quarrying on the scale it happens in Norfolk, on the grounds that NCC is not pursuing how it will ensure that the dwindling resource is used efficiently and as sparingly as possible to maintain it for future generations in accordance with the Gov policy. What is NCC going to do when the silica runs out? There are no plans in place or being drafted to account for using mineral resources in a way that maintain them for future generations or what will be done when the sand runs out. NCC should be planning for these by pioneering for technologically advanced glass recycling, especially clear and flat glass recycling; however, you are not. There is nothing in M&WLP that even hints at trying to improve recycling of glass, in Norfolk and nationally, to reduce the amounts of raw materials required within the glass making industry; planning that would help to maintain supplies of silica sand for future generations and reduce the quarrying within Norfolk. As a Mineral Planning Authority, it should be NCC's duty to lead the way in this. Economically having the latest innovative glass recycling facility infrastructure start in Norfolk would create hundreds if not thousands of jobs. In Europe, Sibelco is a major proponent of technologically advanced recycling of glass including clear glass and therefore would make the ideal partner for Norfolk County Council to spearhead such a project - they have the knowledge and expertise with a ready-made area to house the infrastructure at their Leziate facility, which also includes access to a train line that could be used to import other counties glass for processing and then to export the cullet to the glass manufacturers. Sibelco's own literature says that recycling glass is a win-win situation, so why don't they do that in the UK instead of just quarrying for more raw material?
In summary, I object on economic grounds to quarrying in SIL 02 and AOS E with emphasis on the area of overlap with SIL 02, for the following reasons:
● The increased birdstrike risk that will cost the UK taxpayer millions of pounds to replace and /or repair our front-line aircraft.
● The costs to the NHS for the treatment from an aircraft crash due to a birdstrike.
● The costs to the NHS for the treatment of mental and physical conditions arising from the loss of outdoor amenities used by thousands locally.
● The loss of jobs in local agricultural work and the local food processing industry quarrying would cause.
● The lack of any plan to pioneer innovative advanced recycling of clear and flat glass to reduce the amount of silica sand required for the glassmaking industry and to create hundreds/thousands of local jobs.
● The lack of any independent oversight that allows a private profit-making company with the monopoly on quarrying silica sand in Norfolk to dictate the amount of sand required and being able to take as much as they want and sell it to whoever and wherever in the world they decide.
Please enter this letter as my economic objection to quarrying taking place in the areas of Area of Search (AOS) E and SIL 02 in the Preferred Consultation of the Mineral and Waste Local Plan (M&WLP) Review.
The very first paragraph of the Introduction to the M&WLP on pg 7 states, "The provision of a steady and adequate supply of minerals and the management of waste constitute essential infrastructure to support the economic development of the county". Since all silica sand quarried by Sibelco (the monopoly mineral operator for silica sand in Norfolk) is exported out of Norfolk, it cannot be 'supporting the economic development of the county'. Norfolk receives no benefit for allowing the countryside to be ripped apart and then the mineral only used outside of the county. Quarrying for silica sand or granting future planning applications to further quarry for silica sand in Norfolk cannot be argued, by NCC or Sibelco, to be supporting Norfolk's economic development. The current Sibeclo Leziate plant employs less than 50 people and any new quarry in AOS E or SIL 02 would only provide jobs for a couple of people, that is hardly supporting the economic development of Norfolk.
I also object to the fact there are no checks and balances of the amount of silica sand being quarried and where it goes to, other than NCC requesting Sibelco provide their annual production information on figures that Sibelco supplied to NCC as their requirement each year (a statement from the Cabinet member responsible for the M&WLP in an email reply of 25 June 2019 to a question I posed on this matter). Or to put it another way, Sibelco tell NCC what they want and that is then interpreted by NCC as the amount required for a 'steady and adequate supply' without any further independent investigation; those figures are then confirmed each year by Sibelco sending their production figures on request to NCC. That is what is colloquially known as 'marking your own home-work' and we all know where that got Volkswagen recently in their emissions data scandal. NCC is prepared to allow a privately owned, Belgian, multinational company to tear up the ground in West Norfolk for their own profit, just based on what that company says they need without any further robust independent checks. That is an abdication of duty to the tax-payers and residents of Norfolk and I object to it.
In the last consultation period, the MOD(DIO) objected to SIL 02 becoming a quarry due to the wet working and wet restoration that was proposed there and the increase in the birdstrike risk that would impose on RAF Marham. They also commented on AOS E (and AOS J) to say that they would have concerns if they were to be wet worked or wet restored for the same reason. On economic grounds alone a birdstrike that brought down an aircraft would cost the UK taxpayer, just to replace the aircraft, approximately as much as Sibelco turned over in the UK according to the figures in their last published accounts. That is just one birdstrike. Lesser catastrophic birdstrikes would cost £millions to repair each time. Add into the
equation the costs that would be incurred to clear up a crash, and the costs to treat people affected by it both physically and mentally. A quarry in the area of AOS E or SIL 02 will be wet worked because the water table is so high; it would be restored wet because it wouldn't be possible or economically viable to dry restore water-filled hole 30m or more deep - the total cost to the tax-payer from birdstrikes is eye-watering and an unacceptable risk to take.
Let's look at the economic costs of removing outdoor areas that the public use regularly for their recreational activities - walking, running, horse-riding, cycle-riding and general relaxation. The areas of AOS E, SIL 02 and areas around them are used by thousands of local residents and tourists alike. The Nar Valley Way, a national footpath and bridleway, is adjacent to the north of the areas and is used by people from all over the UK. By allowing quarrying to occur in AOS E or SIL 02 will take away amenities that are enjoyed by people from all over the country; local business would be affected by the downturn in tourists. Moreover, with the level of obesity rising in the UK and the proven positive effects that exercising or relaxing outdoors has on the physical and mental health of the population, it would be economic folly to take away such a facility. Just this week it was reported that the cost to the NHS in treating mental anxiety and depression is £70M - £100M per year; add to that the treatment for obesity and the secondary diseases it causes and the local NHS costs would rise as a direct result of quarrying in AOS E and SIL 02. In addition to the economic costs involved from removing the outdoor spaces in order to quarry is directly in opposition to the aim in NCC's 'Vision to 2036' (page 19, Sect 6) that "Mineral development and waste management facilities will be located, designed and operated without unacceptable adverse impacts on the amenity of local communities....'; on that aim alone the areas of AOS E and SIL 02 should be removed from the M&WLP now.
Further economic impacts from permitting quarrying in AOS E and SIL is the loss of prime agricultural land. This would lead to a loss of the local jobs working the land and in the local food processing industry; loss of many more jobs than the couple that Sibelco says it would create at any quarry. Neither does it makes sense nationally at a time when the Gov policy is to increase and improve our agricultural land so that the UK becomes more self-sufficient in our food production; swapping agricultural land for a quarry is economically unsound and against Gov policy.
I object to quarrying in AOS E and SIL 02, and to silica sand quarrying on the scale it happens in Norfolk, on the grounds that NCC is not pursuing how it will ensure that the dwindling resource is used efficiently and as sparingly as possible to maintain it for future generations in accordance with the Gov policy. What is NCC going to do when the silica runs out? There are no plans in place or being drafted to account for using mineral resources in a way that maintain them for future generations or what will be done when the sand runs out. NCC should be planning for these by pioneering for technologically advanced glass recycling, especially clear and flat glass recycling; however, you are not. There is nothing in M&WLP that even hints at trying to improve recycling of glass, in Norfolk and nationally, to reduce the amounts of raw materials required within the glass making industry; planning that would help to maintain supplies of silica sand for future generations and reduce the quarrying within Norfolk. As a Mineral Planning Authority, it should be NCC's duty to lead the way in this. Economically having the latest innovative glass recycling facility infrastructure start in Norfolk would create hundreds if not thousands of jobs. In Europe, Sibelco is a major proponent of technologically advanced recycling of glass including clear glass and therefore would make the ideal partner for Norfolk County Council to spearhead such a project - they have the knowledge and expertise with a ready-made area to house the infrastructure at their Leziate facility, which also includes access to a train line that could be used to import other counties glass for processing and then to export the cullet to the glass manufacturers. Sibelco's own literature says that recycling glass is a win-win situation, so why don't they do that in the UK instead of just quarrying for more raw material?
In summary, I object on economic grounds to quarrying in SIL 02 and AOS E with emphasis on the area of overlap with SIL 02, for the following reasons:
● The increased birdstrike risk that will cost the UK taxpayer millions of pounds to replace and /or repair our front-line aircraft.
● The costs to the NHS for the treatment from an aircraft crash due to a birdstrike.
● The costs to the NHS for the treatment of mental and physical conditions arising from the loss of outdoor amenities used by thousands locally.
● The loss of jobs in local agricultural work and the local food processing industry quarrying would cause.
● The lack of any plan to pioneer innovative advanced recycling of clear and flat glass to reduce the amount of silica sand required for the glassmaking industry and to create hundreds/thousands of local jobs.
● The lack of any independent oversight that allows a private profit-making company with the monopoly on quarrying silica sand in Norfolk to dictate the amount of sand required and being able to take as much as they want and sell it to whoever and wherever in the world they decide.