Object

Preferred Options consultation document

Representation ID: 98624

Received: 25/10/2019

Respondent: Campaigners Against Two Silica Sites

Representation Summary:

CATSS - The Economic Case Against Silica Sand Quarrying in Marham and Shouldham
We object to quarrying in AOS E and SIL 02 for the following economic reasons:

What would Sibelco, a Belgian owned company, bring to the area if they were granted planning permission to quarry silica sand in Shouldham and Marham?

● Employment Opportunities? - only perhaps 1 or 2 jobs created at the quarry site, as quoted by Mike Hurley, Sibelco Chief Ops Officer. Approx 45 jobs maintained at Leziate but no extra jobs created there (Sibelco only employ 389 people in the whole of the UK). Sibelco claim to support down-stream jobs in the glass making industry; however, it isn't Sibelco who support those jobs it is the raw silica sand and that could come from any other source including importation. There is no value to the sand for Norfolk, just profit for the Belgian owned company Sibelco. How do we 'take back control'?

● Norfolk County Council's (NCC) assertion that Sibelco bring and maintains jobs in Norfolk does not add up. As seen from an article in the EDP [Source: https://www.edp24.co.uk/news/meet-the-woman-who-helps-stop-our-fridges-running-out-of-beer-by-making-sure-the-sand-trains-run-on-time-from-a-quarry-near-king-s-lynn-in-norfolk-1-4048077] 75% of the sand is transported out of Norfolk by rail. The statements made by the Sibelco employee in the article mean that only a handful of HGV jobs are being supported by the transportation of sand in Norfolk. Sibelco estimate 800,000 - 900,000 tonnes of sand extracted per year; NCC figures are 735,000 - 750,000; so a train with 1000t = at least 2 trains per day to haul 75% of total 8 - 9k tonnes per yr. The remaining 25% at 28 tonnes per HGV = 8035 trips per yr, equating to 5 trips per day = 7-8 drivers jobs? Therefore, to retain a few jobs we must accept the destruction of the countryside, the wildlife, our villages, our property, our health and the small matter of national security and the well-being of one of our biggest employers in West Norfolk, RAF Marham. If however, we were to import sand to the glass manufacturers that would maintain glass making jobs in the North of England and presumably the transport jobs to move the sand to the glass factories, so no job loses in the north. Similarly, rather than sand haulage, transporting waste glass for recycling would maintain jobs in the haulage industry in Norfolk if there were to be an advanced glass recycling facility built in Norfolk. To offset any carbon emissions from that additional HGV traffic the train line at Leziate could still be used to bring glass into Norfolk for recycling and to carry the recycled glass cullet from the new, clean, green recycling facility at Leziate to the glass manufacturers. That is a win-win situation for everyone.

● Adding value to the local economy? - NO, they are only creating a couple of jobs (see above). Sibelco's representative has said at a public meeting there would be no economic benefit to the area of Shouldham and Marham. Is the sand used in industry here in Norfolk? NO, all of the sand is exported beyond Norfolk's borders to be used in glassmaking elsewhere. Therefore, Sibelco will add nothing extra to either the local economy or that of Norfolk in general. From Sibelco's latest published accounts (2017) we believe they paid £1.4M in UK tax and £245K in business rates (for the Leziate plant) as part of their claim of putting £15M into Norfolk economy. The 2017 Financial return shows £3.8M in total UK plant costs; Sibelco plant hire is from a Cheshire firm, D Wardle Plant hire - so nothing to Norfolk's economy. The average UK Sibelco wage was £37.5K in 2017 - Leziate supports 45 jobs only.

● Health Hazard - YES, Sibelco will be bringing a health hazard to the area. Health hazard to the physical and mental well being of the community. Both of these will have heavy financial consequences for the local NHS budget [Source: Anxiety and depression costs to NHS per year -Telegraph 09 Oct 2019 https://www.telegraph.co.uk/science/2019/10/08/go-woods-todayit-will-banish-winter-blues-say-healthexperts/], whilst Sibelco continue to make a profit from quarrying sand to send outside of Norfolk and not contributing to the local economy.

● "Anxiety and depression costs the UK economy an estimated £70-£100 million a year yet studies have shown that spending as little as two hours a week in nature is an effective evidence based strategy for maintaining good mental health." - The Telegraph 09 Oct 2019

What would be lost if Sibelco, a Belgian owned company, were granted planning permission to quarry silica sand in Shouldham and Marham?

● Agricultural Land - the area surrounding Shouldham and Marham is high grade agricultural farmland. Much of the land is used to grow sugar beets, a huge industry here in Norfolk. The British Sugar [Source: British Sugar Wissington https://www.britishsugar.co.uk/about-sugar/our-factories] sugar beet processing plant at Wissington directly supports more than 500 jobs (270 are permanent) and trains 16 apprentices (remember Sibelco only employ 389 people nationally). British Sugar paid £200M in UK taxes in the last 5 years. British Sugar invested £250M in UK infrastructure over the last 5 years, actually boosting our local economy and creating, maintaining and sustaining significant local employment for Norfolk. Sibelco are not supporting the local economy of Norfolk to the same extent. The loss of farmland to quarry a mineral will impact the agricultural industry and the families it supports (processing plant and land workers). These are real Norfolk jobs. Once the land is lost it could never be recovered as any quarry would be left as a massive expanse of water. All this despite the fact that the UK is about to leave the EU and should be ensuring food security, and the farming industry is supported, maintained and expanded. Indeed the Government's own plans and policies are to increase self sufficiency in food production [Source: Developing a National Food Strategy
https://www.gov.uk/government/publications/developing-a-national-food-strategy-independent-review-2019/developing-a-national-food-strategy-independent-review-2019-terms-of-reference].

● Natural Open Spaces - the reduction of natural open spaces impacts on mental health [Source: A review of nature-based interventions for mental health care (NECR204)
http://publications.naturalengland.org.uk/publication/4513819616346112], physical health, and an increase in obesity with all the secondary health issues that brings (diabetes, heart problems, physical problems). These impacts would have a huge financial cost to the NHS in time and resources.

● Lack of Community Growth - with the prospect of a 1000 acre quarry next to your home, why would young families be enticed to come and settle in the area? Why will young families already here choose to stay and bring their children up next to a quarry? The answer to both questions is simply that they won't and that means the area will die economically. No community can survive without the next generations choosing to be in that community.

● Tourism - Shouldham Warren is directly adjacent to the remaining area of SIL 02 within the overlap with AOS E, it is also slap bang in the middle of AOS E. Currently used by several thousand walkers, cyclists, horse riders and runners each week; why would they want to continue to partake in outdoor pursuits next to a working quarry? They wouldn't and local business would feel the financial loss. The Nar Valley Way is to the north edge of AOS E and a PROW from there cuts through AOS E. Many walkers stay in local B&Bs whilst travelling the famous pathway, these business would be affected due to the fact that walkers would prefer to stay somewhere that isn't next to a working quarry. Pentney Priory Gatehouse, currently a wedding venue, overlooks the overlap are of AOS E and SIL 02 - this is an example of a specific business that would become non-viable if the view they currently experience over open land is turned into a working quarry. These are all Norfolk business' that will be affected negatively financially for the good of Sibelco, a Belgian owned company.
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 small lakes very close to RAF Coningsby and that is allowed 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 birdstrike it would bring. In fact, a recent report [Source: F35 birdstrike report https://thedefensepost.com/2019/05/16/us-f-35-bird-strike-japan/
http://www.aoa.org.uk/wp-content/uploads/2016/09/Advice-Note-1-Aerodrome-Safeguarding-An-Overview-2016.pdf] of a US Marine 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 appears obvious to everyone except NCC and Sibelco that quarrying in this area of the Safeguarding Zone7 around RAF Marham is not acceptable. What about the cost of upgrading the transport infrastructure?

● The overburden needs to be removed from any proposed quarry site each time a new area is to be quarried. That overburden will need to be removed by HGV. The local roads are hardly fit for normal traffic and will require a significant uplift in expenditure to make them viable for HGV traffic loaded with tons of wet earth for approximately 16-20 weeks a year. Another unacceptable bill for the tax-payer. But what if the site is worked dry? Then the cost of the road infrastructure just increases as the raw sand will also need to be removed by HGV as well as the overburden. What could Sibelco add to the local Norfolk economy?

● They could invest in up to date glass recycling as they do in mainland Europe. Glass
Recycling [Source: Cheaperwaste.co.uk - Glass Collection Services -http://www.cheaperwaste.co.uk/services/glass-collections/] contributes to British business as a whole: estimates indicate that 500 jobs are created for every 100,000 tonnes of glass collected for recycling. If we, as a country, recycled all the glass we currently throw away to landfill, it would create 7,500 sustainable new jobs overnight. NCC are failing to take the opportunity to create a vibrant local employment market in a green industry that at the same time will preserve and sustain the stocks of silica sand, protect the biodiversity of the countryside and health of the residents of Norfolk, whilst helping to reduce CO 2 emissions. A continuation of quarrying will not add to the jobs market in Norfolk; however, implementing a radical glass recycling programme will create jobs at all levels from manual labour through to technical skills, and graduate to management.

And remember Sibelco's own quote from their Feb 2012 brochure [Source: Pure Sense Recycling-Sibelco Green Solutionshttps://issuu.com/salez-poivrez/docs/sibelco.glassrecycling.brochure.feb2012_v4]:
○ "The environmental and economic case for glass recycling is clear.
Cullet helps glass producers drive down energy consumption and emissions, and means less landfill and waste disposal. It's a win-win equation that has created a dynamic, global glass recycling market with a number of national and international players. So how do you choose the right partner to help you achieve the full potential of recycling?" -
○ Sibelco supply, by far, the majority of glass making quality silica sand to glass manufacturers in England and Ireland but they are not involved at all in the recycling of glass in the UK. In summary, there is no positive economic case to allow any quarrying in or around the Marham and Shouldham area.

Additional Reference
1. HM Government - A Green Future: Our 25 Year Plan to Improve Our Environment
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/693158/25-year-environment-plan.pdf

Full text:

CATSS - The Economic Case Against Silica Sand Quarrying in Marham and Shouldham
We object to quarrying in AOS E and SIL 02 for the following economic reasons:

What would Sibelco, a Belgian owned company, bring to the area if they were granted planning permission to quarry silica sand in Shouldham and Marham?

● Employment Opportunities? - only perhaps 1 or 2 jobs created at the quarry site, as quoted by Mike Hurley, Sibelco Chief Ops Officer. Approx 45 jobs maintained at Leziate but no extra jobs created there (Sibelco only employ 389 people in the whole of the UK). Sibelco claim to support down-stream jobs in the glass making industry; however, it isn't Sibelco who support those jobs it is the raw silica sand and that could come from any other source including importation. There is no value to the sand for Norfolk, just profit for the Belgian owned company Sibelco. How do we 'take back control'?

● Norfolk County Council's (NCC) assertion that Sibelco bring and maintains jobs in Norfolk does not add up. As seen from an article in the EDP [Source: https://www.edp24.co.uk/news/meet-the-woman-who-helps-stop-our-fridges-running-out-of-beer-by-making-sure-the-sand-trains-run-on-time-from-a-quarry-near-king-s-lynn-in-norfolk-1-4048077] 75% of the sand is transported out of Norfolk by rail. The statements made by the Sibelco employee in the article mean that only a handful of HGV jobs are being supported by the transportation of sand in Norfolk. Sibelco estimate 800,000 - 900,000 tonnes of sand extracted per year; NCC figures are 735,000 - 750,000; so a train with 1000t = at least 2 trains per day to haul 75% of total 8 - 9k tonnes per yr. The remaining 25% at 28 tonnes per HGV = 8035 trips per yr, equating to 5 trips per day = 7-8 drivers jobs? Therefore, to retain a few jobs we must accept the destruction of the countryside, the wildlife, our villages, our property, our health and the small matter of national security and the well-being of one of our biggest employers in West Norfolk, RAF Marham. If however, we were to import sand to the glass manufacturers that would maintain glass making jobs in the North of England and presumably the transport jobs to move the sand to the glass factories, so no job loses in the north. Similarly, rather than sand haulage, transporting waste glass for recycling would maintain jobs in the haulage industry in Norfolk if there were to be an advanced glass recycling facility built in Norfolk. To offset any carbon emissions from that additional HGV traffic the train line at Leziate could still be used to bring glass into Norfolk for recycling and to carry the recycled glass cullet from the new, clean, green recycling facility at Leziate to the glass manufacturers. That is a win-win situation for everyone.

● Adding value to the local economy? - NO, they are only creating a couple of jobs (see above). Sibelco's representative has said at a public meeting there would be no economic benefit to the area of Shouldham and Marham. Is the sand used in industry here in Norfolk? NO, all of the sand is exported beyond Norfolk's borders to be used in glassmaking elsewhere. Therefore, Sibelco will add nothing extra to either the local economy or that of Norfolk in general. From Sibelco's latest published accounts (2017) we believe they paid £1.4M in UK tax and £245K in business rates (for the Leziate plant) as part of their claim of putting £15M into Norfolk economy. The 2017 Financial return shows £3.8M in total UK plant costs; Sibelco plant hire is from a Cheshire firm, D Wardle Plant hire - so nothing to Norfolk's economy. The average UK Sibelco wage was £37.5K in 2017 - Leziate supports 45 jobs only.

● Health Hazard - YES, Sibelco will be bringing a health hazard to the area. Health hazard to the physical and mental well being of the community. Both of these will have heavy financial consequences for the local NHS budget [Source: Anxiety and depression costs to NHS per year -Telegraph 09 Oct 2019 https://www.telegraph.co.uk/science/2019/10/08/go-woods-todayit-will-banish-winter-blues-say-healthexperts/], whilst Sibelco continue to make a profit from quarrying sand to send outside of Norfolk and not contributing to the local economy.

● "Anxiety and depression costs the UK economy an estimated £70-£100 million a year yet studies have shown that spending as little as two hours a week in nature is an effective evidence based strategy for maintaining good mental health." - The Telegraph 09 Oct 2019

What would be lost if Sibelco, a Belgian owned company, were granted planning permission to quarry silica sand in Shouldham and Marham?

● Agricultural Land - the area surrounding Shouldham and Marham is high grade agricultural farmland. Much of the land is used to grow sugar beets, a huge industry here in Norfolk. The British Sugar [Source: British Sugar Wissington https://www.britishsugar.co.uk/about-sugar/our-factories] sugar beet processing plant at Wissington directly supports more than 500 jobs (270 are permanent) and trains 16 apprentices (remember Sibelco only employ 389 people nationally). British Sugar paid £200M in UK taxes in the last 5 years. British Sugar invested £250M in UK infrastructure over the last 5 years, actually boosting our local economy and creating, maintaining and sustaining significant local employment for Norfolk. Sibelco are not supporting the local economy of Norfolk to the same extent. The loss of farmland to quarry a mineral will impact the agricultural industry and the families it supports (processing plant and land workers). These are real Norfolk jobs. Once the land is lost it could never be recovered as any quarry would be left as a massive expanse of water. All this despite the fact that the UK is about to leave the EU and should be ensuring food security, and the farming industry is supported, maintained and expanded. Indeed the Government's own plans and policies are to increase self sufficiency in food production [Source: Developing a National Food Strategy
https://www.gov.uk/government/publications/developing-a-national-food-strategy-independent-review-2019/developing-a-national-food-strategy-independent-review-2019-terms-of-reference].

● Natural Open Spaces - the reduction of natural open spaces impacts on mental health [Source: A review of nature-based interventions for mental health care (NECR204)
http://publications.naturalengland.org.uk/publication/4513819616346112], physical health, and an increase in obesity with all the secondary health issues that brings (diabetes, heart problems, physical problems). These impacts would have a huge financial cost to the NHS in time and resources.

● Lack of Community Growth - with the prospect of a 1000 acre quarry next to your home, why would young families be enticed to come and settle in the area? Why will young families already here choose to stay and bring their children up next to a quarry? The answer to both questions is simply that they won't and that means the area will die economically. No community can survive without the next generations choosing to be in that community.

● Tourism - Shouldham Warren is directly adjacent to the remaining area of SIL 02 within the overlap with AOS E, it is also slap bang in the middle of AOS E. Currently used by several thousand walkers, cyclists, horse riders and runners each week; why would they want to continue to partake in outdoor pursuits next to a working quarry? They wouldn't and local business would feel the financial loss. The Nar Valley Way is to the north edge of AOS E and a PROW from there cuts through AOS E. Many walkers stay in local B&Bs whilst travelling the famous pathway, these business would be affected due to the fact that walkers would prefer to stay somewhere that isn't next to a working quarry. Pentney Priory Gatehouse, currently a wedding venue, overlooks the overlap are of AOS E and SIL 02 - this is an example of a specific business that would become non-viable if the view they currently experience over open land is turned into a working quarry. These are all Norfolk business' that will be affected negatively financially for the good of Sibelco, a Belgian owned company.
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 small lakes very close to RAF Coningsby and that is allowed 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 birdstrike it would bring. In fact, a recent report [Source: F35 birdstrike report https://thedefensepost.com/2019/05/16/us-f-35-bird-strike-japan/
http://www.aoa.org.uk/wp-content/uploads/2016/09/Advice-Note-1-Aerodrome-Safeguarding-An-Overview-2016.pdf] of a US Marine 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 appears obvious to everyone except NCC and Sibelco that quarrying in this area of the Safeguarding Zone7 around RAF Marham is not acceptable. What about the cost of upgrading the transport infrastructure?

● The overburden needs to be removed from any proposed quarry site each time a new area is to be quarried. That overburden will need to be removed by HGV. The local roads are hardly fit for normal traffic and will require a significant uplift in expenditure to make them viable for HGV traffic loaded with tons of wet earth for approximately 16-20 weeks a year. Another unacceptable bill for the tax-payer. But what if the site is worked dry? Then the cost of the road infrastructure just increases as the raw sand will also need to be removed by HGV as well as the overburden. What could Sibelco add to the local Norfolk economy?

● They could invest in up to date glass recycling as they do in mainland Europe. Glass Recycling [Source: Cheaperwaste.co.uk - Glass Collection Services -http://www.cheaperwaste.co.uk/services/glass-collections/] contributes to British business as a whole: estimates indicate that 500 jobs are created for every 100,000 tonnes of glass collected for recycling. If we, as a country, recycled all the glass we currently throw away to landfill, it would create 7,500 sustainable new jobs overnight. NCC are failing to take the opportunity to create a vibrant local employment market in a green industry that at the same time will preserve and sustain the stocks of silica sand, protect the biodiversity of the countryside and health of the residents of Norfolk, whilst helping to reduce CO 2 emissions. A continuation of quarrying will not add to the jobs market in Norfolk; however, implementing a radical glass recycling programme will create jobs at all levels from manual labour through to technical skills, and graduate to management.

And remember Sibelco's own quote from their Feb 2012 brochure [Source: Pure Sense Recycling-Sibelco Green Solutionshttps://issuu.com/salez-poivrez/docs/sibelco.glassrecycling.brochure.feb2012_v4]:
○ "The environmental and economic case for glass recycling is clear.
Cullet helps glass producers drive down energy consumption and emissions, and means less landfill and waste disposal. It's a win-win equation that has created a dynamic, global glass recycling market with a number of national and international players. So how do you choose the right partner to help you achieve the full potential of recycling?" -
○ Sibelco supply, by far, the majority of glass making quality silica sand to glass manufacturers in England and Ireland but they are not involved at all in the recycling of glass in the UK. In summary, there is no positive economic case to allow any quarrying in or around the Marham and Shouldham area.

Additional Reference
1. HM Government - A Green Future: Our 25 Year Plan to Improve Our Environment
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/693158/25-year-environment-plan.pdf