Object

Preferred Options consultation document

Representation ID: 98918

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

Representation Summary:

The Campaigners Against Two Silica Sites (CATSS) object to mining proposals in AOS E and the area known as SIL 02, including the overlap of both areas which we will refer to in this objection as 'the overlap of SIL 02'. We object under the following topic headings:
● Economic
● Environmental
● Historical assets
● Health
For clarity, we will be relatively brief here and will submit more detailed reasoning for each topic via subsequent submissions.

We object to the planned proposal in AOS E and the overlap of SIL 02 on economic grounds -
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.
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.
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.
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. 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.
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.
10. The only economic winner is 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.
Overall, quarrying for silica sand in AOS E and the overlap of SIL 02 do not make economic sense for Norfolk or the UK and a more detailed objection will be forthcoming.

We 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 hydroecology 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. "Our environment is our most precious inheritance" - DEFRA
Overall, NCC does not have a sound plan to ensure the protection of our environment. The current M&WLP plan is juxtaposed with the Government's stated objectives for the environment.

We 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.

We 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.

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 now/still included in AOS E.

Overall, we object to the proposals to quarry in AOS E and SIL 02.

Full text:

The Campaigners Against Two Silica Sites (CATSS) object to mining proposals in AOS E and the area known as SIL 02, including the overlap of both areas which we will refer to in this objection as 'the overlap of SIL 02'. We object under the following topic headings:
● Economic
● Environmental
● Historical assets
● Health
For clarity, we will be relatively brief here and will submit more detailed reasoning for each topic via subsequent submissions.

We object to the planned proposal in AOS E and the overlap of SIL 02 on economic grounds -
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.
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.
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.
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. 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.
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.
10. The only economic winner is 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.
Overall, quarrying for silica sand in AOS E and the overlap of SIL 02 do not make economic sense for Norfolk or the UK and a more detailed objection will be forthcoming.

We 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.
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.
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 hydroecology 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. "Our environment is our most precious inheritance" - DEFRA
Overall, NCC does not have a sound plan to ensure the protection of our environment. The current M&WLP plan is juxtaposed with the Government's stated objectives for the environment.

We 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.

We 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.

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 now/still included in AOS E.

Overall, we object to the proposals to quarry in AOS E and SIL 02.