Object
Preferred Options consultation document
Representation ID: 98746
Received: 21/10/2019
Respondent: Loreto DT Gallagher
I object to the inclusion of AOSE as a WHOLE; including the overlap area of SIL02. I also object to AOS J. Economically you cannot afford to ignore the reasons set out below.
MOD DIO - The birdstrike risk will greatly increase the potential of loss of aircraft and lives in the air and on the ground. As the area is in a flood risk zone 2 and 3 (3 being the highest) with a high water table and, as stated in MOD (DIO) ignored objection by NCC to the initial consultation, the proximity to RAF Marham makes any 'wet working or restoration' a hazard to the capability of the UK's defence and operational effectiveness of the base and the bird strike risk is proven, any size of water body will attract waterfowl and birds various. 80% of bird strikes occur at take-off and landing, I have provided 3 links for clarity;
https://www.caa.co.uk/Safetyinitiatives-and-resources/Aviation-safety-review/Birdstrikes/
http://www.aoa.org.uk/wp-content/uploads/2016/09/Advice-Note-1-Aerodrome-Safeguarding-An-Overview-2016.pdf
https://mineralproducts.org/documents/MPA_Birdstrike_Guidance.pdf
The area of SIL02 that is now the eastern part of AOS E lies directly under the flight path of runway 01/19 at RAF MArham. The F-35 Lighting II is a single-engine aircraft and if it fails due to a bird strike it would be catastrophic in terms of monetary loss and to the UK's strategic capabilities. F-35 Lighting II has been bought at considerable cost to the British taxpayer at approx £100m per aircraft, is there enough budget to replace aircraft? Many aircraft without ejection seats, including passenger carrying aircraft from other bases use RAF Marham. If any aircraft crashes, the clear up operation encompassing emergency services, loss of life in the air and on the ground and the ongoing mental health issues ensuing from the tragedy would be immense; £50 million was put aside for the aftermath of Grenfell Tower to treat this costly avoidable health burden. The Precautionary Principle of risk must surely be applied in this case.
The default position of Sibelco is to restore wet great areas of former quarries; even smallish bodies of water within 13Km of RAF Marham presents problems due to the increase of potential birdstrike. Even if Sibelco 'dry' worked an area, look at the restoration plan for East Winch, a significant part of that restoration plan is to wet restoration. The water table in SIL02, the preferred area and the whole of AOSE is high and situated in the majority in the highest flood risk zone. If one looks at areas of Bawsey that have been dry worked, the area has been left as a dust bowl with very little flora and fauna. How is that making our county more attractive and wealthy? I refer you to NPPF Sect 17. 204. h. and 205 b and e.
Misuse of Land - To allow quarrying of SIL02 is a misuse of land. It is noted within the preferred options consultation paper at Pg15 section 5.9, that NCC acknowledges some areas in the county are comparable with the worst deprived areas of the country. DEFRA issued guidance in 2017 to guide policy makers on how to lessen the impact of their policies on rural areas (Rural Proofing, practical guide to access impacts of policies on rural areas). If you allow valuable farmland and rural jobs to be traded for silica sand extraction for glass manufacturing in other parts of the country, you are not using the guidance that government policy affords you and are neglecting the needs of your own constituents. Farming may only be 1% of employment in Norfolk but, it is a vital part of the rural economy for Norfolk and the UK nationally. Food security is paramount as we leave the EU and getting Brexit done, so supporting British farming and jobs is vital if we are to take back control (see NPPF Sect 11. Para 118. b. food production and carbon storage). The spurious claim about supporting glass manufacturing jobs is just that; those jobs would still be there without Sibelco as sand for glass making could be imported and recycled cullet would reduce the need for so much sand.
These areas are open farmland and wooded landscape. Rural areas and farming are symbiotic. When visiting the countryside that is exactly what one expects to see; farmland, open spaces, woodland, not industrial sites for 30+ years, then fee paying water parks; exactly how is that opening up the area for locals? Sect 6. Para 83. C and D plus para 84 NPPF should guide you in respecting the character of rural areas.
Recycling - The government states that they require you as a Mineral Planning Authority to achieve "a steady and adequate supply of minerals" as seen in the initial consultation document Pg 20 sect 6 The Strategy - vision to 2036; they, the government do not demand a quota. NPPF Sect 17 para 203 "secure their long term conservation", Sibelco supply you with figures for what THEY say is required but who checks that this is the correct amount for the UK glass industry? If we were to recycle glass this would diminish the need for large amounts of raw material, protecting those finite resources for the future and preserve agricultural land and OUR homes. Sibelco are a major player in the recycling of glass within Europe, is that because they mandated in those countries to save those country's resources? I quote from their own brochure from 2012, "the environmental and economic case for glass recycling is clear....it's a win win equation" (https://slideplayer.com/slide/4056140/). Sibelco should concentrate on waste instead of mineral extraction and invest a world class glass recycling centre at their Leziate plant in West Norfolk, securing hundreds of new jobs for the local economy and using their train line to import glass from other areas of the country and export glass cullet to glass manufacturers who reside outside of Norfolk. Instead, Sibelco make huge profits from the destruction of the UK through quarrying which you facilitate. Flat glass recycling is achievable contrary to our County Councillors' belief and whoever advised him; flat glass is easily recycled. It is accomplished to great effect in Germany, saving silica sand resources. Careful handling of old flat glass is the only consideration, but of course quarrying will be easier and make more profit for Sibelco, a Belgian company with no long term future investment in UK PLC. Let's take back control and cut out the middle man, import the amount of silica sand we truly need and invest in recycling to save an environmental disaster.
The Health Implications of destruction of Open Spaces - The loss of the natural open spaces that provide the opportunity for exercise and help our mental wellbeing will be enormously damaging. There are extortionate costs for the NHS associated with mental health and wellbeing, with spending by CCGs in England totalling £9.15 billion in 2015/16, according to figures published by NHS England. This had gone up to £9.72 billion in 2016/17. That's an increase of around £575 million or 6.3%. I refer you to Sect.8 para 91 b and c. NPPF of your obligation to promote healthy, safe communities.
I object to the inclusion of AOSE as a WHOLE; including the overlap area of SIL02. I also object to AOS J. Economically you cannot afford to ignore the reasons set out below.
MOD DIO - The birdstrike risk will greatly increase the potential of loss of aircraft and lives in the air and on the ground. As the area is in a flood risk zone 2 and 3 (3 being the highest) with a high water table and, as stated in MOD (DIO) ignored objection by NCC to the initial consultation, the proximity to RAF Marham makes any 'wet working or restoration' a hazard to the capability of the UK's defence and operational effectiveness of the base and the bird strike risk is proven, any size of water body will attract waterfowl and birds various. 80% of bird strikes occur at take-off and landing, I have provided 3 links for clarity;
https://www.caa.co.uk/Safetyinitiatives-and-resources/Aviation-safety-review/Birdstrikes/
http://www.aoa.org.uk/wp-content/uploads/2016/09/Advice-Note-1-Aerodrome-Safeguarding-An-Overview-2016.pdf
https://mineralproducts.org/documents/MPA_Birdstrike_Guidance.pdf
The area of SIL02 that is now the eastern part of AOS E lies directly under the flight path of runway 01/19 at RAF MArham. The F-35 Lighting II is a single-engine aircraft and if it fails due to a bird strike it would be catastrophic in terms of monetary loss and to the UK's strategic capabilities. F-35 Lighting II has been bought at considerable cost to the British taxpayer at approx £100m per aircraft, is there enough budget to replace aircraft? Many aircraft without ejection seats, including passenger carrying aircraft from other bases use RAF Marham. If any aircraft crashes, the clear up operation encompassing emergency services, loss of life in the air and on the ground and the ongoing mental health issues ensuing from the tragedy would be immense; £50 million was put aside for the aftermath of Grenfell Tower to treat this costly avoidable health burden. The Precautionary Principle of risk must surely be applied in this case.
The default position of Sibelco is to restore wet great areas of former quarries; even smallish bodies of water within 13Km of RAF Marham presents problems due to the increase of potential birdstrike. Even if Sibelco 'dry' worked an area, look at the restoration plan for East Winch, a significant part of that restoration plan is to wet restoration. The water table in SIL02, the preferred area and the whole of AOSE is high and situated in the majority in the highest flood risk zone. If one looks at areas of Bawsey that have been dry worked, the area has been left as a dust bowl with very little flora and fauna. How is that making our county more attractive and wealthy? I refer you to NPPF Sect 17. 204. h. and 205 b and e.
Misuse of Land - To allow quarrying of SIL02 is a misuse of land. It is noted within the preferred options consultation paper at Pg15 section 5.9, that NCC acknowledges some areas in the county are comparable with the worst deprived areas of the country. DEFRA issued guidance in 2017 to guide policy makers on how to lessen the impact of their policies on rural areas (Rural Proofing, practical guide to access impacts of policies on rural areas). If you allow valuable farmland and rural jobs to be traded for silica sand extraction for glass manufacturing in other parts of the country, you are not using the guidance that government policy affords you and are neglecting the needs of your own constituents. Farming may only be 1% of employment in Norfolk but, it is a vital part of the rural economy for Norfolk and the UK nationally. Food security is paramount as we leave the EU and getting Brexit done, so supporting British farming and jobs is vital if we are to take back control (see NPPF Sect 11. Para 118. b. food production and carbon storage). The spurious claim about supporting glass manufacturing jobs is just that; those jobs would still be there without Sibelco as sand for glass making could be imported and recycled cullet would reduce the need for so much sand.
These areas are open farmland and wooded landscape. Rural areas and farming are symbiotic. When visiting the countryside that is exactly what one expects to see; farmland, open spaces, woodland, not industrial sites for 30+ years, then fee paying water parks; exactly how is that opening up the area for locals? Sect 6. Para 83. C and D plus para 84 NPPF should guide you in respecting the character of rural areas.
Recycling - The government states that they require you as a Mineral Planning Authority to achieve "a steady and adequate supply of minerals" as seen in the initial consultation document Pg 20 sect 6 The Strategy - vision to 2036; they, the government do not demand a quota. NPPF Sect 17 para 203 "secure their long term conservation", Sibelco supply you with figures for what THEY say is required but who checks that this is the correct amount for the UK glass industry? If we were to recycle glass this would diminish the need for large amounts of raw material, protecting those finite resources for the future and preserve agricultural land and OUR homes. Sibelco are a major player in the recycling of glass within Europe, is that because they mandated in those countries to save those country's resources? I quote from their own brochure from 2012, "the environmental and economic case for glass recycling is clear....it's a win win equation" (https://slideplayer.com/slide/4056140/). Sibelco should concentrate on waste instead of mineral extraction and invest a world class glass recycling centre at their Leziate plant in West Norfolk, securing hundreds of new jobs for the local economy and using their train line to import glass from other areas of the country and export glass cullet to glass manufacturers who reside outside of Norfolk. Instead, Sibelco make huge profits from the destruction of the UK through quarrying which you facilitate. Flat glass recycling is achievable contrary to our County Councillors' belief and whoever advised him; flat glass is easily recycled. It is accomplished to great effect in Germany, saving silica sand resources. Careful handling of old flat glass is the only consideration, but of course quarrying will be easier and make more profit for Sibelco, a Belgian company with no long term future investment in UK PLC. Let's take back control and cut out the middle man, import the amount of silica sand we truly need and invest in recycling to save an environmental disaster.
The Health Implications of destruction of Open Spaces - The loss of the natural open spaces that provide the opportunity for exercise and help our mental wellbeing will be enormously damaging. There are extortionate costs for the NHS associated with mental health and wellbeing, with spending by CCGs in England totalling £9.15 billion in 2015/16, according to figures published by NHS England. This had gone up to £9.72 billion in 2016/17. That's an increase of around £575 million or 6.3%. I refer you to Sect.8 para 91 b and c. NPPF of your obligation to promote healthy, safe communities.