Object
Preferred Options consultation document
Representation ID: 98931
Received: 31/10/2019
Respondent: Miss L Smith
In accordance with your advertised Public Consultation I wish to object to the inclusion of AoS-E as a Preferred Option for Silica Sand Quarrying.
My reasons are as follows:-
i) Biodiversity
Given that AoS-E is predominantly a Forestry England working plantation, we have here a well regulated environment with conifers and birch variously harvested in a fell and plant cycle. In addition there are avenues of established broad leaf trees of considerable age and individual examples of veteran trees throughout.
The soil conditions allow all the native British snakes to thrive, habitats for many English mammals exist here and the mature forest areas are used as breeding habitat by raptors, and other woodland birds. There are several badger setts amongst the plantations.
The area includes a designated County Wildlife Site.
On the adjacent Button Fen, within AoS-E, is the Ten Acre ancient woodland.
In the event of quarrying, Natural England imposes an obligation for restoration to make a net gain in Biodiversity terms which would clearly be impossible and AoS-E should therefore be removed from consideration.
ii) Geodiversity
The 300 acre, 20m high hill at Shouldham Warren is described by the Norfolk Geodiversity Partnership, to which the County Council is affiliated, as:
"The hill is a notable outlier of early Cretaceous Carstone with a capping of glacial deposits; it is one of the southernmost outcrops of the Carstone in Norfolk. It is an eroded relict scarp feature shaped by the passage of the Anglian ice sheet about 440,000 years ago. Before that time the scarp would have been more prominent, perhaps as a range of hills. It contributes to the geodiversity of the county."
Again, in the event of quarrying, Natural England imposes an obligation for restoration to make a net gain in Geodiversity terms which would clearly be impossible and AoS-E should be removed from consideration.
iii) Archaeological and Historical Context
To quote from the Forestry England survey and assessment:
"Shouldham Woods are situated on the edge of the fens, in 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. In the Roman era Shouldham appears to have been a centre of some importance. Features associated with previous land use survive in the woods. For example, there are Mediaevel warren boundaries, the presence of rhododendron suggests an association with adjacent listed parkland, and there are earthworks and brickwork from a WWII rifle range."
Shouldham Warren has enormous archaeological potential and its destruction would clearly be in contradiction of paragraph E6 of your Preferred Options document:
"The Norfolk Historic Environment Service recommend that proposals for extraction avoid areas of palaeoenvironmental potential, the former barrow and the areas of former settlement. The Norfolk Historic Environment Service would not support proposals that result in the destruction of historic earthworks."
Again AoS-E should therefore be removed from consideration.
iv) Landscape Value
Without doubt Shouldham Warren has intrinsic landscape value as a hill feature and to lose it would significantly detract from the area's landscape character. It rises dramatically out of the surrounding, almost sea-level, fen and farm land to a height of more than 20m. The notion expressed in paragraph E8 that PRoWs could be diverted and reinstated as part of the Warren's future restoration is quite absurd.
Be in no doubt that if Shouldham Warren is excavated it will be lost forever.
Again I submit that AoS-E should therefore be removed from consideration.
v) Leisure, Recreation and Well-being
It is impossible to overstate the value of Shouldham Warren to local and regional populations for leisure and recreation. It is used extensively for walking and running, and by cyclists, horse riders and dog-owners. One can scarcely visit the Warren in daylight hours without meeting other people enjoying and making use of the area for exercise, and gaining a sense of well-being thereby. The community value is inestimable and gives every reason why AoS-E should be removed from your considerations.
vi) Officer Comments
Much has been made of the statement by Natural England in response to the Initial Consultation, viz, "agree with the conclusions regarding the designated sites"
This remark is however prefaced by a list of conditions, stipulations and requirements with which in the case of AoS-E, and Shouldham Warren in particular, compliance is literally impossible.
Natural England call for a net increase in Geodiversity and Biodiversity over the industrialised period of any quarry site which is clearly unachievable.
Were this geological, topographical and geographical feature to be destroyed it cannot in any sense be restored or re-created.
Please note that the inclusion of AoS-E specifically contradicts Norfolk County Council's Environmental Policy of April 2016 where is stated:-
"As part of its commitment to foster the environmental, social and economic well-being of the community, Norfolk County Council will work towards enabling people in Norfolk to benefit from an enhanced environment and quality of life. The County Council will ensure that these principles are
integrated into the decisions of all its services and will:
1. Protect and enhance the county's wildlife and the quality and character of the Norfolk landscape and coast; encouraging the variety of habitats and species to deliver the aims of Biodiversity 2020.
2. Ensure nature contributes to the economic and social health of urban and rural areas in Norfolk for current and future generations."
The inclusion of AoS-E also specifically contradicts the National Planning Policy Framework, section 15, Conserving and Enhancing the Natural Environment, paragraphs 170, 174 and 175, which mandates planning refusal in the circumstances which apply to Shouldham Warren.
In conclusion I would say that, taking together the unique features of AoS-E, Norfolk County Council would be going against its own and national environmental policies if it continues with this proposal.
It would be breaking faith with its own affiliated organisations: The Norfolk Biodiversity and Geodiversity Partnerships.
It would be permitting an act of the most appalling vandalism and, perhaps most importantly of all, it would be failing in its Duty of Stewardship of the County for future generations.
I understand that you are required to provide some areas in Norfolk for silica sand extraction.
We are no strangers here to quarries.
However, there are many locations where smaller, less intrusive, less damaging and destructive sites could be created, without perhaps the economies of scale and increased profitability that could be earned here, though still economically viable.
I hope I have been able to give you every reason why you should now reprieve
Shouldham Warren and remove AoS-E from your considerations.
In accordance with your advertised Public Consultation I wish to object to the inclusion of AoS-E as a Preferred Option for Silica Sand Quarrying.
My reasons are as follows:-
i) Biodiversity
Given that AoS-E is predominantly a Forestry England working plantation, we have here a well regulated environment with conifers and birch variously harvested in a fell and plant cycle. In addition there are avenues of established broad leaf trees of considerable age and individual examples of veteran trees throughout.
The soil conditions allow all the native British snakes to thrive, habitats for many English mammals exist here and the mature forest areas are used as breeding habitat by raptors, and other woodland birds. There are several badger setts amongst the plantations.
The area includes a designated County Wildlife Site.
On the adjacent Button Fen, within AoS-E, is the Ten Acre ancient woodland.
In the event of quarrying, Natural England imposes an obligation for restoration to make a net gain in Biodiversity terms which would clearly be impossible and AoS-E should therefore be removed from consideration.
ii) Geodiversity
The 300 acre, 20m high hill at Shouldham Warren is described by the Norfolk Geodiversity Partnership, to which the County Council is affiliated, as:
"The hill is a notable outlier of early Cretaceous Carstone with a capping of glacial deposits; it is one of the southernmost outcrops of the Carstone in Norfolk. It is an eroded relict scarp feature shaped by the passage of the Anglian ice sheet about 440,000 years ago. Before that time the scarp would have been more prominent, perhaps as a range of hills. It contributes to the geodiversity of the county."
Again, in the event of quarrying, Natural England imposes an obligation for restoration to make a net gain in Geodiversity terms which would clearly be impossible and AoS-E should be removed from consideration.
iii) Archaeological and Historical Context
To quote from the Forestry England survey and assessment:
"Shouldham Woods are situated on the edge of the fens, in 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. In the Roman era Shouldham appears to have been a centre of some importance. Features associated with previous land use survive in the woods. For example, there are Mediaevel warren boundaries, the presence of rhododendron suggests an association with adjacent listed parkland, and there are earthworks and brickwork from a WWII rifle range."
Shouldham Warren has enormous archaeological potential and its destruction would clearly be in contradiction of paragraph E6 of your Preferred Options document:
"The Norfolk Historic Environment Service recommend that proposals for extraction avoid areas of palaeoenvironmental potential, the former barrow and the areas of former settlement. The Norfolk Historic Environment Service would not support proposals that result in the destruction of historic earthworks."
Again AoS-E should therefore be removed from consideration.
iv) Landscape Value
Without doubt Shouldham Warren has intrinsic landscape value as a hill feature and to lose it would significantly detract from the area's landscape character. It rises dramatically out of the surrounding, almost sea-level, fen and farm land to a height of more than 20m. The notion expressed in paragraph E8 that PRoWs could be diverted and reinstated as part of the Warren's future restoration is quite absurd.
Be in no doubt that if Shouldham Warren is excavated it will be lost forever.
Again I submit that AoS-E should therefore be removed from consideration.
v) Leisure, Recreation and Well-being
It is impossible to overstate the value of Shouldham Warren to local and regional populations for leisure and recreation. It is used extensively for walking and running, and by cyclists, horse riders and dog-owners. One can scarcely visit the Warren in daylight hours without meeting other people enjoying and making use of the area for exercise, and gaining a sense of well-being thereby. The community value is inestimable and gives every reason why AoS-E should be removed from your considerations.
vi) Officer Comments
Much has been made of the statement by Natural England in response to the Initial Consultation, viz, "agree with the conclusions regarding the designated sites"
This remark is however prefaced by a list of conditions, stipulations and requirements with which in the case of AoS-E, and Shouldham Warren in particular, compliance is literally impossible.
Natural England call for a net increase in Geodiversity and Biodiversity over the industrialised period of any quarry site which is clearly unachievable.
Were this geological, topographical and geographical feature to be destroyed it cannot in any sense be restored or re-created.
Please note that the inclusion of AoS-E specifically contradicts Norfolk County Council's Environmental Policy of April 2016 where is stated:-
"As part of its commitment to foster the environmental, social and economic well-being of the community, Norfolk County Council will work towards enabling people in Norfolk to benefit from an enhanced environment and quality of life. The County Council will ensure that these principles are
integrated into the decisions of all its services and will:
1. Protect and enhance the county's wildlife and the quality and character of the Norfolk landscape and coast; encouraging the variety of habitats and species to deliver the aims of Biodiversity 2020.
2. Ensure nature contributes to the economic and social health of urban and rural areas in Norfolk for current and future generations."
The inclusion of AoS-E also specifically contradicts the National Planning Policy Framework, section 15, Conserving and Enhancing the Natural Environment, paragraphs 170, 174 and 175, which mandates planning refusal in the circumstances which apply to Shouldham Warren.
In conclusion I would say that, taking together the unique features of AoS-E, Norfolk County Council would be going against its own and national environmental policies if it continues with this proposal.
It would be breaking faith with its own affiliated organisations: The Norfolk Biodiversity and Geodiversity Partnerships.
It would be permitting an act of the most appalling vandalism and, perhaps most importantly of all, it would be failing in its Duty of Stewardship of the County for future generations.
I understand that you are required to provide some areas in Norfolk for silica sand extraction.
We are no strangers here to quarries.
However, there are many locations where smaller, less intrusive, less damaging and destructive sites could be created, without perhaps the economies of scale and increased profitability that could be earned here, though still economically viable.
I hope I have been able to give you every reason why you should now reprieve
Shouldham Warren and remove AoS-E from your considerations.