Object
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99512
Received: 16/12/2022
Respondent: Dr L David Ormerod
Legally compliant? No
Sound? No
Duty to co-operate? No
Unconsidered Regional Vulnerability to Uncontrolled Silica Sand Mining
When considering the landscape implications of silica sand mining, almost all documents in the N.C.C. silica sand library and in the NMWLP document, May 2022, consider only the implications of active and proposed silica sand extraction sites, and mainly from the perspective of considerations of local amenity (village) impacts and from the problem of regulating HGV transports. The historical realities are largely being disregarded.
Within and directly adjacent to West Norfolk, there are the widespread, cumulative scars of several hundred years of sand and gravel (aggregates) mining and at least 200 years of silica sand mining for glass, foundry, ceramics, and other industries. New mining sites are selected with almost no consideration of the surrounding blight; many of these sites remain unremediated and many have been reduced to lakes. The NMWLPA misleads in its discussion of cumulative adverse effects. claiming that only current mining sites are involved. In fact the National Planning Policy Minerals Guidance (2014) states, "Mineral planning authorities should include appropriate policies in their minerals local plan where appropriate. to ensure that the cumulative impact of a proposed mineral development on the community and the environment will be acceptable. The cumulative impact of mineral development is also capable of being a material consideration when determining individual planning applications" There is no preoccupation with the impacts of active sites in the NPPG or NPPF. It is the true cumulative impacts of local mining that is the pertinent factor.
Indeed, the systematic restoration of old sites would allay some of the widespread public Concerns, but there has been no interest from N.C.C. or from mining groups. Virtually all the sites that have come under consideration in the last decade are adjacent to old workings. The logical approach to this situation is for N.C.C.to contract a map maker to develop (for the first time) a map of historical and current sand mining sites in West Norfolk. The purpose would be to establish more sustainable choices of silica sand extraction sites.
The richness of the Leziate deposits of the Sandringham sand classification has meant that this resource has been preferentially mined, with the extensive blight in Leziate, Mintlyn, Bawsey, Roydon, Middleton, West Winch, Wolferton, Sandringham, and elsewhere. There is an official preference for proposed sites close to the Leziate Factory, which is concentrating the scarring of landscape. even if newly-finished mining sites are now being reclaimed. but there is little evidence that the abundance of old mining sites will not just remain as unreclaimed and often useless landforms.
Sibelco UK, from the evidence of their application history remain quite unconcerned. yet in Belgium, their HQ, the company have a vaunted reputation for both site reclamation and the substitution of significant silica sand inputs with reclaimed glass, but not here in England. N.C.C. are not encouraging or mandating either.
Another unreported impediment to mining in the region is the very high level of governmental neutralisation of large swathes of the countryside. Since 1942, 121 square km have been appropriated as the STANTA military area for the British Army. Since the 1920s, 45,000 acres of the Brecks and West Norfolk have been planted as primarily monocultural Forestry England plantations, the largest lowland forest in Britain. There are three major airforce bases adjacent to the limited regional silica sand resource, RAF Marham, RAF Lakenheath, and RAF Mildenhall; the former in particular may invalidate significant potential sites under its statutory 13 km radius of bird-strike zone, although there are already appreciable numbers of lakes in old mining sites within this zone. There are also scattered areas of residual fen and wet woodland throughout the area. A review of the website, Who Owns Norfolk, shows the vast areas of privately-owned country estates, including the 20,000 acre Sandringham Estate and large Crown Commissioner landholdings. These facts appear never to be considered by N.C.C. in its support and adjudication of the nationally important silica sand industry.
Facts are facts and should not be disregarded. The facts speak to the necessity of a more nuanced approach to silica sand mining, the importance of restoring large swathes of the countryside damaged historically by sand mining, and not just the current mines, a determined consciousness of adjacent damaged areas. and the requirement for a more systematic approach to the identification and selection of new silica sand extraction sites. Familiarity with the cumulative documents on N.C.C. silica sand site selection ought to lead to the conclusion that perhaps a process with greater discretion and success in the identification of appropriate silica sand resources might be achievable. yet the ambient culture seems to expect different results from doing the same thing. It is clear that the public interests must be part of the solution.
Soundness test: not effective, not positively prepared, not consistent with national policy
Unconsidered Regional Vulnerability to Uncontrolled Silica Sand
Mining B
1. The occasional recreational public land-use interests are unrecognised in the planning structure informing silica sand extraction site selection in the NMWLP, May 2022. They are of particular importance because of the local landscape blight associated with historical sand mining and governmental programmes. Shouldham Warren, part of AOS E, the jewel of West Norfolk countryside recreation, is perhaps the best example. Public interests cannot be excluded from planning decisions, and evidence suggests that this absence in NMWLP was systematic. Resets are required in a number of the Plan processes to accommodate this legitimate public interest before the NMWLP can be considered legally compliant.
2. A comprehensive West Norfolk region-specific mapping of both historical and current active and suspended mining sites - for silica sand, sand sand and gravel, and carstone - should be created to help inform further planning, and restoration. An independent cartographer should be engaged. This needs to be undertaken with some urgency. The purpose is to introduce greater granularity into the process that is currently available to aid specific site selection and to avoid areas of blight.
3. Restoration of the many old neglected sand mining sites, including areas of cumulative industrial blight, is an important issue for the general public as they see additional mining sites proposed for a battered landscape. Public rural recreational areas are now scarce. If the industry will not accept any responsibility, it has to be the responsibility of local government, possibly with private sponsorship.
The Bawsey Lakes area is a classical example with fenced (in disrepair) areas of heavy metal contamination, sinking sands, and chemical contamination, and several unsafe lakes, some with unsecured, below-surface obstructions. The huge site has required surveying and restoration for over 50 years. It ought to be a major regional resource, if funded properly. Ignoring the extensive heritage mining blight in West Norfolk in the execution of planning for silica sand mining is a fundamental and self-inflicted problem. I request consideration of this aspect in the adjudication of the "soundness" of the NMWLP to 2038.
4. The MPA claim that the selection of putative AOS sites may not be a useful approach in the Leziate beds anymore may well be realistic. A greater granularity of approach, aided by the mechanisms suggested, and allied with an improved collaborative endeavour with minerals firms may aid in the recognition of specific sites, and even of multiple smaller sites.