Question 69: Area of Search AOS E

I would like to register my objection to proposed sites SIL 02 and AOS-E as preferred areas for silica sand extraction and understand our County Councillor, Graham Middleton, obtained an extension for responses from residents from Shouldham and Marham until today.

I understand the need to provide a future source of silica sand, however, I feel that this development will have a disproportionate and devastating impact on a rural community already affected by a rapidly expanding RAF base of strategic national importance.

I would also like to note that the proposal put forward by Sibelco is an optimistic 'best case scenario' which downplays the negative impact on the residents' wellbeing, our community and the environment, especially considering the massive size of this site and timescales involved in the development.

I would also like to point out that the process has not adhered to the principals laid out in Norfolk County Council's own 'Statement of Community Involvement'. Residents were completely unaware of these plans, they were not notified of the consultation and had only a few days to prepare a response ahead of the deadline.

In particular, my objection is based on the following grounds:

Health/Safety and Environment

* Unacceptable increase in noise, dust and light pollution as a direct result of the proposed extraction is in violation of local residents rights as per the European Convention on Human Rights, specifically Article 2 (right to life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 (respect for one's private and family life, home and correspondence), and Protocol 1 (right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents
* Prolonged exposure to silica dust presents significant risk to vulnerable members of the community, particularly the elderly and young, given the village demographics
* No information has been provided regarding the impact of mineral extraction on local water supply/quality
* No restriction on site working hours is proposed
* This is the only proposal within Norfolk M & WLP that is in a high-risk flood area. Flood risks are further exacerbated by the removal of ancient drainage ditches

Economic

* No proposed economic benefit for the village of Marham or Shouldham
* No additional job creation
* Reduction in house values
* Potential impact on home insurance due to increased flood risk
* Reduction in tourism and visitors to the Nar Valley Way
* Creation of 'trapped' residents unable to move due to the inevitable slowing of the housing market

Local Infrastructure

* Existing road infrastructure is unsuitable for HGV and plant access. Precedence has been established by RAF Marham who are prohibited from using village roads for access purposes.
* Local trunk roads will be negatively affected by increased traffic (A47 and A10)
* No proposal for Sibelco's preferred option for above ground pipeline between proposed sites and their current site at Leziate taking into account natural and transport barriers

Ecology

* Destruction of habitat of endangered wildlife species including:
Voles, Newts, scarce Emerald Damselfly, Moths including the Grizzled Skipper, Dingy Skipper
Birds on conservation priority list: Skylark, Lapwing, House Sparrow, Linnet, Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge
* Dust deposition relating to the River Nar - a designated SSSI and a Core River valley
* No proposal as to how the Core River Valley will be enhanced following mineral extraction
* Detrimental impacts on ecology and biodiversity on nearby County Wildlife Sites
* No restoration plan proposed for the entire site, which suggests there is no intention to remedy the harm caused. Fears exacerbated by the very poor and dangerous condition of other Sibelco sites such as Bawsey and Leziate

Landscape

* Marham village enjoys and elevated position relative to the proposed site, with beautiful long-reaching views across the fen landscape
Bunds or screening will be ineffective and intrusive in their own right
Proposed works will be visually detrimental and out of character with the local landscape
* Prevailing North and North West winds will aggravate noise and dust pollution concerns and impact on health
* Irreplaceable loss of agricultural land
* Destruction of ancient footpaths and relocation of rights of way (further than the stipulated 100m permitted) contained both within and adjacent to the proposed site, which are extensively used by local residents, schools and tourists
* Detrimental impact on the open nature of the landscape and to the setting of the scheduled monument Pentney Priory Gatehouse and other heritage assets
* No assurances have been received regarding the possibility of the site being used for Landfill in the future

Archaeology

* This area is potentially very rich in archaeological finds, from Pre-Historic to Roman to Medieval and any undiscovered sites would be destroyed permanently by the project
* Close proximity to Pentney Priory Gatehouse and the unexplored Cistercian Nunnery in Marham

In conclusion, nothing in this proposal addresses residents' concerns about the devastating impact the development will have on our community, quality of life, health and wellbeing for decades to come. No assurances have been given that the site will not be abandoned as industrial wasteland with zero potential for either leisure or ecological benefit.

I wish to lodge my objection to the proposed site SIL 02 and AOS E as a preferred areas for silica sand extraction in the vicinity of the villages of Shouldham and Marham.
I understand the need to provide a future source of silica sand, however, I feel that this development will have a disproportionate and devastating impact on our rural community.
I would also like to note that the proposal put forward by Sibelco is an optimistic 'best case
scenario' which downplays the negative impact on the residents' wellbeing, our community, and the environment, especially considering the massive size of these proposed sites and time scales involved in the development.
I would also like to point out that the process has not adhered to the principles laid out in Norfolk
County Council's own 'Statement of Community Involvement'. Residents were completely unaware of these plans, they were not notified of the consultation and had only a few days to prepare a response ahead of the deadline.
In particular, my objection is based on the following grounds:
Health/Safety & Environment
* A potentially unacceptable increase in Noise, Dust and Light pollution as a direct result of the proposed extraction is in violation of local residents' rights as per European Convention on
Human Rights, specifically Article 2 (right to life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 (respect for one's private and family life, home and correspondence), and Protocol 1 (right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents.
* Prolonged exposure to silica dust present significant risk to vulnerable members of the community, particularly the elderly and young, given the village demographics.
* No information has been provided regarding the impact of mineral extraction on local water supply/quality.
* No restriction on site working hours is proposed.
* This is the only proposal within Norfolk M&WLP that is in a high-risk flood area. Flood risks are further exacerbated by the removal of ancient drainage ditches.
Economic
* No proposed economic benefit for the villages of Marham or Shouldham.
* No additional job creation.
* Reduction in house values.
* Potential impact on home insurance due to increased flood risk.
* Reduction in tourism and visitors to the Nar Valley Way.
* Creation of 'trapped' residents unable to move due to the inevitable slowing of the housing market.
Local Infrastructure
* Existing road infrastructure is unsuitable for HGV and plant access. Precedence has been established by RAF Marham who are prohibited from using village roads for access purposes.
* Local trunk roads will be negatively affected by increased traffic (A47 & A10).
* No proposal for Sibelco's preferred option for above ground pipeline between proposed site and their current site at Leziate taking into account natural and transport barriers.
Ecology
* Destruction of habitat of endangered wildlife species including:
* Voles, Newts, scarce Emerald Damselfly, Moths including the Grizzled Skipper, Dingy
Skipper.
* Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet,
Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge.
* Dust deposition relating to the River Nar - a designated SSSI and a Core River valley.
* No proposal as to how the Core River Valley will be enhanced following mineral extraction.
* Detrimental impacts on ecology and biodiversity on nearby Country Wildlife Sites.
* No restoration plan proposed for the entire site, which suggests there is no intention to remedy the harm caused, fears exacerbated by the very poor and dangerous condition of other Sibelco sites, such as Bawsey and Leziate.
Landscape
* Marham village enjoys an elevated position relative to the proposed site, with beautiful longreaching views across the fen landscape:
* Bunds or screening will be ineffective and intrusive in their own right.
* Proposed works will be visually detrimental and out of character with the local landscape.
* Prevailing North and North West winds will aggravate noise and dust pollution concerns and impact on health.
* Irreplaceable loss of agricultural land.
* Destruction of ancient footpaths and relocation of rights of way (further than the stipulated
100m permitted) contained both within and adjacent to the proposed site, which are extensively used by local residents, schools and tourists.
* Detrimental impact on the open nature of the landscape and to the setting of the scheduled monument Pentney Priory Gatehouse and other heritage assets.
* No assurances have been received regarding the possibility of the site being used for Landfill in the future.
Archaeology
* This area is potentially very rich in archaeological finds, from Pre-Historic to Roman to Medieval and any undiscovered sites would be destroyed permanently by the project.
* Close proximity to Pentney Priory Gatehouse and the unexplored Cistercian Nunnery in Marham.
Summary
In conclusion, nothing in this proposal addresses residents' concerns about the devastating
impact the development will have on our community, quality of life, health and wellbeing for decades to come. No assurances have been given that the site will not be abandoned as industrial wasteland with zero potential for either leisure or ecological benefit. Whilst I am sure that many of the concerns raised here may be easily answered, there are some which will have a huge impact on our villages and feel the manner in which the proposal has thus far been dealt with has not allowed any concerns of the local residents to be involved in the process. I remain committed to be involved in this process such that the concerns can be addressed. If you require any clarification of the points raised, I would be happy to discuss the matter further.

I wish to lodge my objection to the proposed site SIL 02 and AOS E as a preferred areas for silica sand extraction in the vicinity of the villages of Shouldham and Marham.
I understand the need to provide a future source of silica sand, however, I feel that this development will have a disproportionate and devastating impact on our rural community.
I would also like to note that the proposal put forward by Sibelco is an optimistic 'best case
scenario' which downplays the negative impact on the residents' wellbeing, our community, and the environment, especially considering the massive size of these proposed sites and time scales involved in the development.
I would also like to point out that the process has not adhered to the principles laid out in Norfolk
County Council's own 'Statement of Community Involvement'. Residents were completely unaware of these plans, they were not notified of the consultation and had only a few days to prepare a response ahead of the deadline.
In particular, my objection is based on the following grounds:
Health/Safety & Environment
* A potentially unacceptable increase in Noise, Dust and Light pollution as a direct result of the proposed extraction is in violation of local residents' rights as per European Convention on
Human Rights, specifically Article 2 (right to life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 (respect for one's private and family life, home and correspondence), and Protocol 1 (right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents.
* Prolonged exposure to silica dust present significant risk to vulnerable members of the community, particularly the elderly and young, given the village demographics.
* No information has been provided regarding the impact of mineral extraction on local water supply/quality.
* No restriction on site working hours is proposed.
* This is the only proposal within Norfolk M&WLP that is in a high-risk flood area. Flood risks are further exacerbated by the removal of ancient drainage ditches.
Economic
* No proposed economic benefit for the villages of Marham or Shouldham.
* No additional job creation.
* Reduction in house values.
* Potential impact on home insurance due to increased flood risk.
* Reduction in tourism and visitors to the Nar Valley Way.
* Creation of 'trapped' residents unable to move due to the inevitable slowing of the housing market.
Local Infrastructure
* Existing road infrastructure is unsuitable for HGV and plant access. Precedence has been established by RAF Marham who are prohibited from using village roads for access purposes.
* Local trunk roads will be negatively affected by increased traffic (A47 & A10).
* No proposal for Sibelco's preferred option for above ground pipeline between proposed site and their current site at Leziate taking into account natural and transport barriers.
Ecology
* Destruction of habitat of endangered wildlife species including:
* Voles, Newts, scarce Emerald Damselfly, Moths including the Grizzled Skipper, Dingy
Skipper.
* Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet,
Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge.
* Dust deposition relating to the River Nar - a designated SSSI and a Core River valley.
* No proposal as to how the Core River Valley will be enhanced following mineral extraction.
* Detrimental impacts on ecology and biodiversity on nearby Country Wildlife Sites.
* No restoration plan proposed for the entire site, which suggests there is no intention to remedy the harm caused, fears exacerbated by the very poor and dangerous condition of other Sibelco sites, such as Bawsey and Leziate.
Landscape
* Marham village enjoys an elevated position relative to the proposed site, with beautiful longreaching views across the fen landscape:
* Bunds or screening will be ineffective and intrusive in their own right.
* Proposed works will be visually detrimental and out of character with the local landscape.
* Prevailing North and North West winds will aggravate noise and dust pollution concerns and impact on health.
* Irreplaceable loss of agricultural land.
* Destruction of ancient footpaths and relocation of rights of way (further than the stipulated
100m permitted) contained both within and adjacent to the proposed site, which are extensively used by local residents, schools and tourists.
* Detrimental impact on the open nature of the landscape and to the setting of the scheduled monument Pentney Priory Gatehouse and other heritage assets.
* No assurances have been received regarding the possibility of the site being used for Landfill in the future.
Archaeology
* This area is potentially very rich in archaeological finds, from Pre-Historic to Roman to Medieval and any undiscovered sites would be destroyed permanently by the project.
* Close proximity to Pentney Priory Gatehouse and the unexplored Cistercian Nunnery in Marham.
Summary
In conclusion, nothing in this proposal addresses residents' concerns about the devastating
impact the development will have on our community, quality of life, health and wellbeing for decades to come. No assurances have been given that the site will not be abandoned as industrial wasteland with zero potential for either leisure or ecological benefit. Whilst I am sure that many of the concerns raised here may be easily answered, there are some which will have a huge impact on our villages and feel the manner in which the proposal has thus far been dealt with has not allowed any concerns of the local residents to be involved in the process. I remain committed to be involved in this process such that the concerns can be addressed. If you require any clarification of the points raised, I would be happy to discuss the matter further.

Proposed Site SIL 02 As A Preferred Area for Silica Sand Extraction by SIBELCO UK Ltd Behind Spring Lane and Mere Plot Near Marham and Shouldham, Kings Lynn, NORFOLK. AOS E
Please accept this letter as a formal objection to the above.
As a resident of Marham living in close proximity to this planned development I, like most other residents, was totally unaware or advised of such a scheme until a neighbour informed me of it a few days ago. Apparently only 10 letters were sent out to properties closest to the site. It also appears that this plan has been discussed by the County Council for over three years. The consultation period for this development ends in the next few days giving the residents of Marham and Shouldham minimal time to review and comment on such a scheme. Considering the size and nature of this planned development this is totally unacceptable and unprofessional. Why have we not been made aware of this plan earlier?
Fortunately a meeting was held by Shouldham Parish Council 06 August 2018 and the following key points identified;
* If approved, the first phase of the project will involve the stripping of all vegetation, soil and clay from the fields to allow quarrying equipment access to the sand below. This will involve the use of heavy duty earth moving equipment.
* The second phase will involve the flooding of the land and dredging on the sand, operating 24 hours a day, 7 days a week. No restriction on working hours has been planned. There are also concerns as this type of dredging has not been carried out by Sibelco in the UK before.
* Planned start date 2026 for a period in excess of 20 years.
The reasons for my objection to the above are as follows;
1. Environmental issues
a. Stripping such a large plot of land for over 20 years will totally destroy the wildlife in this area. The Fen in Marham and the woods in Shouldham Warren will become isolated.
b. Mow Fen, a country Wildlife site, is located within this area.
c. The Carbon Footprint of the area will be greatly affected by the removal of such a large area of crops. Nearly 400 hectares of good quality agricultural farmland will be lost forever at a time where, as a nation, we need to be considering growing more crops.
d. Any screening or binding of the site to reduce noise and light pollution will ruin this beautiful landscape and the views currently seen across the fen. Where will all the removed soil be stored from the land stripping process?

2. Health and safety
The dust created by such a development will cause health and safety issues.
Smaller particles of sand and dust will travel long distances and easily reach properties in Marham and Shouldham. This area of land is extremely flat with no natural barriers to slow or prevent the movement of dust and fine particles from the site to the adjacent properties. The effects of this on the health of the elderly, asthma sufferers and those with breathing issues will be significant.
The government website states the following;
www.hse.gov.uk/construction/healthrisks/cancer-and-construction/silica-dust.htm

Silica is the biggest risk to construction workers after asbestos. Heavy and prolonged exposure to RCS can cause lung cancer and other serious respiratory diseases. HSE commissioned estimates it was responsible for the death of over 500 construction workers in 2005. In addition to the risks from lung cancer, silica is also linked to other serious lung diseases:

* Silicosis can cause severe breathing problems and increases the risk of lung infections. Silicosis usually follows exposure to RCS over many years, but extremely high exposures can cause acute silicosis more quickly.
* Chronic obstructive pulmonary disease is a group of lung diseases including bronchitis and emphysema. It results in severe breathlessness, prolonged coughing and chronic disability. It can be very disabling and is a leading cause of death.

The NHS website also states; www.nhs.uk/conditions/silicosis/

Silicosis
Silicosis is a long-term lung disease caused by inhaling large amounts of crystalline silica dust, usually over many years.
Silica is a substance naturally found in certain types of stone, rock, sand and clay. Working with these materials can create a very fine dust that can be easily inhaled. Once inside the lungs, the dust particles are attacked by the immune system.
This causes swelling (inflammation) and gradually leads to areas of hardened and scarred lung tissue (fibrosis). Lung tissue that's scarred in this way doesn't function properly.
People who work in the following industries are particularly at risk:
* stone masonry and stone cutting - especially with sandstone
* construction and demolition - as a result of exposure to concrete and paving materials
* pottery, ceramics and glass manufacturing
* MINING AND QUARRYING
* sand blasting

3. Noise, dust and light pollution
The area under consideration is extremely flat with no natural noise, light or dust barriers. The entire site will be visible to the majority of the residents of Marham due to Marham being on higher ground than the proposed site. Screening will, therefore, be ineffective or so tall as to block all views across the Fen from both Marham and Shouldham. There is no Bunding large enough to provide a barrier against the noise and light pollution this work will cause. The noise, dust and light pollution from the estimated 11 hour day land stripping and 24 hour a day 7 days a week dredging is totally unacceptable.

4. Access to site
The local road network is poor and insufficient for such a project. I believe there is a possibility of installing an overland pipeline from this site to transport the sand for processing after wet dredging but no allowance has been made for the heavy duty equipment necessary for land stripping to prepare the site for each new dredge. Neither has consideration been given to the lack of appropriate roads for the necessary plant and HGV that would be required to transport the raw material to the Leziate processing plant should it be decided to dry dredge the site instead.

5. The Water Table / Flood plain
a. The majority of the land under review is currently part of a HIGH RISK flood plain. The plan by Sibelco is to flood this area in order to dredge the sand. This will only increase the chance of future flooding in the area in the absence of the flood plain. Any Bunding and piles of surface soil and clay will only reduce the natural flow of water and increase the risk of flooding further.
b. Anglian Water have a sewage pumping station in close proximity to the site. Theyalso have a number of bore holes across Marham Fen for the extraction of clean water. How will these be affected by the plan?
c. Concerns have already been expressed and documented by the Council on a restoration plan after the 20 year period involving the creation of a lake and wetlands. The concern is the increase in birds and wild fowl resulting in potential bird strikes on aircraft in close proximity to RAF Marham, with the risk of a major catastrophe from an aircraft crashing into a local built up area. The initial flooding of the land for the dredging will also cause this issue.

6. Value to the community.
a. What is the value of such a project to the local community and Britain? Sibelco is not a British company, its head offices are based in Belgium. The value of this type of sand is extremely high and profits made from the sale of this material will be of great value to BELGIUM and not the UK.
b. There will also be no job benefits to the local community as the manpower required to run the planned dredging operations is less than the current services of those working the land. There will therefore be a reduction in jobs and absolutely no value or benefit of such a scheme to the local community.

7. Property Value
This site will significantly reduce the value of properties in and around Marham and Shouldham for at least 28 years. Who wants to live near and look at a Silica sand
extraction plant that will be in opened from 2026 and in operation for at least 20 years, possibly longer?

Please accept the above points as a formal objection to the proposed silica sand extraction site SIL 02 proposed by Sibelco UK Ltd

I wish to lodge my objection to the proposed site AOS E.
I believe the 'best case scenario' does nothing to counteract the negative impact on the residents wellbeing, the community, and the environment.
Health and safety-
Noise, dust and light pollution which is in violation of the right to life human rights.
Health concerns to respiratory diseases and silicosis which, at least could inflict the elderly and young.
Impact on local water supply.
24 hours working.
Flood risk area and removal of drains could put the villages at risk and increase insurance.
The economic benefits only favour the company which is detrimental to villages with no job value, house price decreased, reduction in tourism.
No infrastructure able to accommodate this. The A47 and A10 both being very busy roads.
Destruction of habitat. Priority red list birds, endangered wildlife and the important river Bar. The damage to these areas could be irreversible and certainly not on the agenda from sibelco.
All views for local residents will be destroyed. Heritage assets, ancient footpaths and rights of way would be destroyed..
The Warren wildlife would be in serious danger of decline..
I feel this would crate wasteland with no ecological or leisure benefits.

I am writing to formally object to the proposed Silica Sand Extraction proposal as detailed under SIL 02 and AOS-E (located between Shouldham and Marham villages).
I was unware of this significant planning proposal and feel uneasy with a rushed approached to gather assurances and information before permission is considered. This major industrial site, so close to my residence and leisure space, will clearly have impact to my family.
Areas of Objection in no particular order are:
Scenic Views. The proposed area sits next to the river Nar and Shouldham Warren,
surrounded by prime agriculture land. The introduction of an industrial site in this area will devastate this beautiful views, both during operations and when decommissioned in the future. The area is used by not only villagers by a significant number of people for both walking and our pursuits such a mountain biking. Impact on footpaths and entry and exit to the Warren is unknown.
Environment Pollution. There are no guarantees or assurances of the impact to the village of Shouldham on the pollution this site will generate. This industrial complex will generated dust, noise and light population which has not been quantified accurately. The village's idyllic rural setting will likely be heavily tarnished by the presence of a pollution generating site within such close proximity.
The impact to the beautiful river Nar, the wildlife is all undetermined and at least requires a significate survey to understand the impact.
Financial/ Monetary. The value of property and land in the area is now in freefall, based on the uncertainty of this proposal and its potential impact.
Villagers of both Shouldham and Marham have purchased premium property under the indeed justified assumption it's tranquil and non-industrial surroundings remain intact. The proposed threat to this will certainly affect property values in the foreseeable future.
Vehicle Impact to Shouldham. Access to this site, both during construction and during operations, is unknown. Shouldham village access is extremely limited with narrow roads, a large elderly population and a well-established and increasingly popular primary school. We already suffer from large buses and speeding agriculture vehicles just about navigating their way safely through the village. Apart from the clear logistical and safety issues for the site vehicles, the village and surrounding warren are a popular destination for walkers, cyclists, horse-riders and others wishing to enjoy the countryside. This community would almost certainly be affected by increased traffic.
Unknown Future/ Decommission. The site has a limited period of effective use, the future is unknown and this unsettles the local residences. Although there may be promises of restoring the site back to farm land, this can never be guaranteed. The fear is the area will be turned into a Land Fill site which would have a clearly devastating impact on all.
Heath Concerns. Silica Sand and the particle's in dust are reported to have health
concerns. These concerns need quantifying and local residents require credible
independent assurances that they will not be effected.
Admittedly, I am not a professional on any of the areas listed above, however through research into your project and others I feel it necessary to raise these issues. As a resident of Shouldham for over 15 years, I would be devasted if your proposal lead to the eventual diminishing of vibrant village. Transparency is primarily what us, as residents, require in order to make our individual assessments on what you are proposing. Without the facts, we cannot begin to do so.

Submission Norfolk Minerals and Waste Local Plan Consultation
Thank you for consulting the Ministry of Defence (MOD) in relation to the above referenced consultation document.
DIO Safeguarding main concern when reviewing Mineral and Waste local plan, relates to the proposed site allocations and the restoration/aftercare scheme.
The county of Norfolk has several statutory safeguarding sites within its authority area, these being RAF Lakenheath, RAF Lakenheath, RAF Mildenhall and RAF Marham.
On reviewing the proposed mineral sites the following occupy statutory birdstrike safeguarding consultation zones for RAF Marham: MIN 19 & 205;76;77;40; SIL01 SIL02; AOS E &J.
Therefore, DIO Safeguarding is concerned with the development of open water bodies, the creation of wetland habitat, refuse and landfill sites. These types of development have the potential to attract large flocking bird species hazardous to aviation safety. Therefore, we would recommend dry restoration and dry phased working.
The following sites MIN 6; MIN 204; MIN 74; MIN 206 and MIN 32 the restoration is dry using inert waste or imported inert materials. If this were to change to wet restoration or there was potential for wet working as part of the extraction scheme, DIO Safeguarding would need to be consulted.
Please note the remaining sites fall outside of the statutory safeguarding areas and we have no concerns regarding these allocations.
Please note the above comments are purely related to the DIO Statutory Safeguarding interests. I trust this adequately explains our position on this matter.

Thank you for consulting Norfolk Wildlife Trust on the Minerals and Waste Local Plan Review, and for granting us an extension to the consultation period.
Owing to the lack of information that we hold on the ecological value of the wider countryside we have largely restricted our comments to impacts from proposed allocations on County Wildlife Sites and our reserves. In the wider countryside where possible we have made suggestions on restoration proposals based on sites' locations within our Living Landscapes .
Policies
Vision and Objectives
We strongly support the requirement in the Vision for progressive restoration schemes that enhance biodiversity. Equally, we support the positive contribution minerals planning makes to biodiversity improvements in the county promoted in MSO9 and the creation of opportunities for wider public engagement with nature in MSO10.
MW2: We strongly support this policy, which provides important protection for locally designated sites, as well as supporting net gains for biodiversity through planning in section k, which encourages wherever possible that enhancement of the environment will be sought, as per paragraph 170 of the NPPF.
MP 7: We support the restoration requirements included in this policy, in particular the recommendation that sites that are to be restored to agriculture can still include biodiversity enhancements alongside their primary use. We also support the reference to the county's priority habitats and species and recommend that the policy makes further reference in the supporting text to the specific habitats and species that are present in the county for the benefit of plan users.
MP 8: We support the inclusion of an aftercare policy to ensure that restoration habitats are established to a sufficient standard post-extraction.

Sites
Our comments below relate specifically to sites in proximity to our reserves, SSSIs, CWSs and ancient woodland sites.
Where sites are proposed adjacent to or in close proximity to County Wildlife Sites, we strongly recommend that these are only chosen sequentially after other sites have been selected, that they are only taken forward if it can be demonstrated that they are deliverable whilst providing sufficient stand off from the allocation boundary to account for hydrological and dust impacts, that any planning application will be accompanied by an ecological impact assessment and that restoration will be to habitats in support to those existing nearby, for example expanding existing habitats where adjacent and providing greater connectivity in the wider countryside between existing sites. We note that several proposed allocations are situated close to multiple CWS, and in these locations it would be very beneficial to co-ordinate restoration proposals in order to maximise the gains for wildlife through improving landscape scale connectivity. We would be happy to offer further advice on this in later plan consultations, if that would be helpful.

MIN 35: We support the inclusion of nature conservation in the restoration proposals for this site.

MIN 202: We are concerned that this proposed site partially overlaps with CWS 1344, 'Triumph and Foxburrow Plantations'. We recommend that either the allocation boundary is redrawn to avoid the CWS, or that the site policy includes a requirement for a stand-off area around the edge that includes that part that overlaps the CWS. In addition, given the proximity to the CWS, we would expect the site to be worked dry to avoid any impacts on hydrogeology and a stand-off area sufficient to avoid any impacts on the CWS from dust. We support the proposed restoration to a mosaic of acid grassland, woodland and wetland, and also support the Council's recommendation that the site could support new heathland when restored.

MIN 37: We support the Council's restoration recommendations for the inclusion of acid grassland/ heathland on this site, which would complement the nearby CWS 1411 'Disused Gravel Pit', which supports similar habitats.

MIN 76, MIN 206
We support the Council's proposals for conservation led restoration at MIN 76 and the inclusion of wide field margins and hedgerow planting at MIN 206. Given the proximity of these proposals to several CWS, we recommend that co-ordinated restoration to enhance landscape connectivity between all the nearby CWS should be supported in the site policy.

MIN 40: Given the location within a kilometre of East Winch Common SSSI, restoration of this site to heathland has the potential to enhance the connections of the SSSI with the wider landscape. Therefore we support the Council's recommendation that the restoration proposals for this site should include heathland. Additionally, given the proximity to King's Lynn, the site has the potential to support the provision of new green infrastructure.

SIL 01: We are concerned at the proposal to include part of CWS 416 '70 & 100 Plantations' in this allocation and recommend that as part of any mitigation that these areas are not excavated and are safeguarded as part of any restoration proposals. Provided that suitable mitigation can be provided to ensure the CWS are safeguarded, we support the restoration of the site to habitat types similar to the surroundings to provide connectivity and note the potential for the site to provide green infrastructure with links to the nearby country park.

SIL 02: We note the Council identifies SIL 02 as a Preferred Area, within which a smaller area could be subject to an application at a later date. We note the proximity of several CWS to the boundary of SIL 02 and recommend as with all other proposals near CWS that any application would need to demonstrate it could avoid adverse impacts on these sites. We would support any restoration proposals that enhance the landscape connectivity of the CWS network locally.

MIN 69: Whilst we are unable to comment on the wider impacts of this proposal as they are outside of our remit, should this site be progressed, then we strongly support the Council's recommendations that this site should be subject to high quality restoration creating a large new area of heathland with benefits both for wildlife and for green infrastructure provision.

MIN 71: We are concerned about this proposal due to its close proximity to the Norfolk Valley Fens SAC and Holt Lowes SSSI. The plan will need to demonstrate that it would not result in an adverse effect on the SAC in order to demonstrate that it is deliverable, and in addition to any project level HRA that would be required to accompany any planning application. Should the site be considered deliverable in the local plan HRA, then we strongly recommend that the site is restored to nature conservation with public access, given the significant potential the site has to make landscape scale connections with the multiple designated and county wildlife sites in the area, as well as provide valuable new green infrastructure on the edge of Holt.

MIN 115: We note the proximity of this proposal to several CWS, including CWS 1170 'Lord Anson's Wood'. We support the Council's recommendations for ecological assessment to accompany any application, due to the proximity to the CWS as well as for protected species, and also support the restoration recommendations for a mix of deciduous woodland and heathland, to complement the habitats in nearby CWS.

MIN 207, MIN 208, MIN 209, MIN 210, MIN 211, MIN 212, MIN 79, MIN 80
We support the Council's recommendations for restoration to nature conservation after use on these sites.

MIN 25
Provided potential ecological impacts on the nearby CWS 2221, 'Devil's End Meadow' can be avoided, we support the restoration proposals to acid grassland, woodland and wetland.

Other sites
Whilst we hold no specific knowledge on the following sites, we broadly support the restoration proposals proposed for MIN 12, 13, 51, 200 and 65. Additionally, sites 79 and 80 being close to the Norwich growth area may support restoration that includes specifically includes green infrastructure provision.

Proposed sites for removal
We support the Council's proposed to remove the following sites from further consideration in the plan on the grounds of adverse impacts on wildlife sites, namely MIN 102, 201, 48, 45, 19, 205, 74 and 77.
Areas of Search E, F, I, J
We note that in previous iterations of the Minerals plan, it has been considered acceptable to modify Areas of Search to exclude CWS and their immediate surroundings. In order to safeguard multiple CWS from both direct and indirect impacts of minerals extraction, we recommend that similar provisions are made and the Areas of Search are modified to provide sufficient stand off from these CWS to safeguard them from adverse impacts. In particular we note CWS 425 'Mow Fen' which is within AoS E, CWS 424 'Westbrigg's Wood' and CWS 373 'Adj. Adams Plantation' which are both adjacent to AoS E and CWS 365 'Broad Meadow Plantation' which is adjacent to AoS F.

We trust that these comments are helpful. Should you wish to discuss them in any more detail whilst preparing the next iteration of the plan, please do not hesitate to contact me.

Question 1: 'Minerals and Waste Local Plan Vision'
The Vision should refer the provision of minerals supply to be in accordance with and as required by National Policy
Mineral Safeguarding should refer to paragraph 182 of the revised National Planning Policy Framework such that the applicant for adjacent development ('agent of change') should be required to provide suitable mitigation to take account of existing and allocated development.

Question 3: 'Minerals Strategic Objectives'
The following amendments are proposed (in CAPITALS):
MSO2. To provide a steady and adequate supply of industrial minerals by identifying adequate mineral extraction sites/areas within Norfolk sufficient to meet the forecast need AND STOCKS OF PERMITTED RESERVES OF SILICA SAND OF AT LEAST 10 YEARS PRODUCTION FOR INDIVIDUAL SILICA SITES AND AT LEAST 15 YEARS FOR SILICA SAND SITES WHERE SIGNIFICANT NEW CAPITAL IS REQUIRED and safeguarding existing infrastructure. (To accord with NPPF 2018 paragraph 208 footnote 68)

MSO4. To safeguard silica sand, carstone, and sand and gravel resources for future use. Avoiding unnecessary sterilisation by encouraging the extraction of minerals prior to other development taking place where practicable and using minerals in construction on the land from which they are extracted. THE 'AGENT OF CHANGE' PRINCIPLE WILL BE APPLIED TO ANY NEW PROPOSED DEVELOPMENT IMPACTING ON SAFEGUARDED AREAS OR SITES.

MSO5. To promote the sustainable transport of minerals by rail, road and water, including the safeguarding of railheads and wharfs for the import of minerals to and export of minerals from Norfolk. THE 'AGENT OF CHANGE' PRINCIPLE WILL BE APPLIED TO ANY NEW PROPOSED DEVELOPMENT IMPACTING ON SAFEGUARDED SITES.

MSO8. To ensure that mineral development addresses and minimises the impacts it will have on climate change by: REDUCING greenhouse gas emissions during the winning, working and handling of minerals, SEEK TO PROVIDE sustainable patterns of minerals transportation, and WHERE POSSIBLE integrating features consistent with climate change mitigation and adaption into the design of restoration and aftercare proposals.
MSO9. To positively contribute to the natural, built and historic environments with high quality, progressive and expedient restoration to achieve a beneficial after use. The after use will protect and enhance the environment, including landscape and biodiversity improvements.

Comment: the restoration of mineral sites can deliver landforms to facilitate different after uses of land, however mineral planning has no role in the after use of itself.

MSO10. WHERE PRACTICAL to increase public access to the countryside and enhance biodiversity through enhancing the amenity value of land when restoring extraction sites.

Question 4: Policy MW1 'Presumption in favour of sustainable development'
This policy is supported including the recognition in the preamble that the three pillars of sustainability have equal standing.
 
Question 5: Policy MW2 'Development Management Criteria'
Where appropriate AND PRACTICAL, enhancement of the environment would be sought, including, but not exclusively, the enhancement of the Public Rights of Way Network, creation of recreation opportunities and enhancement of the natural, historic and built environment and surrounding landscapes.

Question 6: Policy MW3 'transport'
WHERE PRACTICAL AND REALISTIC measures to reduce car travel to the site by workers and visitors and encourage walking, cycling and use of public transport.

Question 7: Policy MW4 'climate change mitigation and adaption'
b) be planned so as to REDUCE carbon dioxide and methane emissions ON A SITE UNIT BASIS
c) endeavour to SOURCE a minimum of 10 per cent of the energy used on site from decentralised and renewable or low-carbon sources.
d) WHERE PRACTICAL AND RELEVANT to demonstrate the use of sustainable drainage systems, water harvesting from impermeable surfaces and layouts that accommodate waste water recycling
e) WHERE RELEVANT TO take account of potential changes in climate including rising sea levels and coastal erosion
g) incorporate proposals for sustainable travel, including travel plans where PRACTICAL AND appropriate.

Question 9: Policy MW6 'agricultural soils'
This policy should be applied flexibly since minerals can clearly only be worked where they exist and for silica sand for glass making the potential land is further restricted by virtue of the scarcity of this mineral.

Question 27: Policy MP1 'Provision for minerals extraction'
No as it does not accord with National Policy and is unsound. Suggested wording for silica sand:
STOCKS OF PERMITTED RESERVES for silica sand will be maintained at 10 years' PRODUCTION FOR EACH SILICA SAND SITE. Sufficient sites and/or areas to deliver at least 12,380,000 tonnes of silica sand will be allocated TO THE END OF THE PLAN PERIOD WITH FURTHER PROVISION TO ENSURE A STOCK OF PERMITTED RESERVES BEYOND THE PLAN PERIOD.
In the table on page 63 in the preamble to Policy MP1 is should read:
B Silica sand permitted reserve at 31/12/2016

Question 28: Policy MP2 'Spatial strategy for minerals extraction'
"Within the resource areas identified on the key diagram, specific sites or preferred areas for silica sand extraction should be located where they are able to access the existing processing plant and railhead at Leziate via conveyor, pipeline or off-public highway routes". This contradicts wording in proposed Policy MP13 and the Single Issue Silica Sand Review of the Minerals Site Specific Allocations DPD (adopted in December 2017) which discussed highway routes from Areas of Search to the Leziate processing site.
There should be no buffers applied to the so-called planning constraints. The acceptability or not of approaching such constraints will be a matter for the EIA.
Agricultural land grades 1 and 2 should not be excluded. This contradicts Policy MW6 which should in all circumstances be adopted and applied flexibly.

Question 33: Policy MP7 'Progressive working, restoration and after-use'
After use is noted several times in the policy but after use is not a matter for mineral planning.
There is no mention of restoration to agricultural land
Any important geology or geomorphology on the site will be retained in sample exposures for study purposes ONLY WHERE PRACTICAL AND SAFE TO DO SO

Question 36: Policy MP10 'Safeguarding of port and rail facilities, and facilities for the manufacture of concrete, asphalt and recycled materials'
The 'agent of change' principle will be applied to all development in proximity to safeguarded sites.


Question 37: Policy M11 'Mineral Safeguarding Areas and Mineral Consultation Areas'
The 'agent of change' principle will be applied to all development in proximity to safeguarded sites.

Question 67: Proposed Site MIN 40 'land east of Grandcourt Farm, East Winch'
The site is allocated as a specific site for silica sand extraction in the Adopted in the Core Strategy and Minerals and Waste Development Management Policies Development Plan Document 2010-2026 (adopted September 2011) and identified in the Minerals Site Specific Allocations Development Plan Document (DPD) (adopted October 2013, amendments adopted December 2017).

The Initial conclusion on the MIN40 site in the May 2018 consultation document notes that "the site is considered suitable for allocation for silica sand extraction, subject to any planning application addressing the requirements below: [requirements are detailed in the Initial Consultation document]

Sibelco has submitted a planning application for an extension of Grandcourt Quarry into the MIN40 site and has the following comments on some of the "requirements" noted in the Initial Consultation document.

* Opportunities during working for any geodiversity assets to be studied, and if compatible with the landscape and ecology objectives, an open face to be retained as part of the restoration scheme

Sibelco will examine working faces during operation and can take photographic records of any features of note observed, if any. Following extraction being completed in each phase, Carstone material will be used to cover and stabilise the Leziate Sand faces to create safe long term slopes as described in Appendix 9 to the submitted Planning Statement (Geotechnical Design and Assessment).
Opportunities could be afforded during working to geology students to inspect and study open faces and overburden areas under supervision where consistent with health and safety of the site. Bearing in mind the proposed open water restoration with peripheral broadleaved woodland and shrub/grassland it is not been possible to incorporate any open face in the restoration, which would in addition be difficult to maintain safely due to the nature of the geology, which makes it vulnerable to erosion and a potential safety hazard.

* A restoration scheme incorporating heathland or a heathland/arable mix with blocks of woodland which provides biodiversity gains and does not result in permanent dewatering of a perched water table in the carstone aquifer if one is identified in a hydrogeological risk assessment
*
The lodged planning application proposes a combination of restored areas of open water (51.4%), native broadleaved woodland (8.8%), hedgerows (increase of 920 linear metres), scrub & species rich grassland (20.7%), agricultural land (15.2%) and public rights of way for the restored site with biodiversity gains. The hydrogeological assessment of the site showed there were no significant impacts on the perched water table in the Carstone as a result of working and restoration.

The proposed restoration is primarily to water since the excavation will be several metres below the natural groundwater level in order to release the proven mineral. It will not be possible to deliver a dry restoration using on-site overburden materials. For the same reason it will not be possible to deliver a requirement of MIN40, which is to incorporate heathland into the restoration. The proposed site for the former Site Specific Allocations DPD was considerably reduced in area at examination which removed land which may have been suitable for heathland restoration. The much reduced currently allocated area reflects very closely the area of excavation. Once the restored margin areas are accounted for, the remaining area of land restoration is at the lake margins on mostly slopes to the water's edge, which is not suitable for heathland. Significant heathland restoration has been delivered by the Applicant on former mineral sites to the north of Middleton Stop Drain.

The proposed restoration scheme is shown on the submitted restoration drawings. This scheme has been designed with due regard for the precise setting of the site; the local geology; local topography; position of the natural groundwater table and the volumes of different overburden materials identified within the site by drilling programmes.

Policy Min 40 states that a restoration scheme for the site should seek to incorporate heathland or a heathland/arable mix with blocks of woodland which provides biodiversity gains. Given the volumes of sand and overburden materials present and the position of the local groundwater table this is not possible in its entirety in this case.

Sibelco has restored former mineral extraction area locally to heathland (for example Wicken North and Wicken South), however, these areas have very different physical parameters which allowed such restoration to be designed and implemented. Wicken North and Wicken South are located on lower ground and had relatively low sand to overburden ratios which allowed significant areas to be restored to generally level ground above the local groundwater level. Grandcourt Quarry extension is located on higher ground, has a different ratio of sand to overburden (higher ratio) and a different relationship of ground levels to groundwater level. Final restored slopes must be stable in the long term and at the same time utilise only suitable overburden materials from the site (there are no proposals to import any materials from elsewhere to effect the restoration). Tailings materials from the mineral washing (silts and lays) are unsuitable for restoration in this area due to high water content of the tailings and distance from the processing plant. The company has sufficient permitted tailings space elsewhere on the wider site.

The restoration scheme proposed for the extension area in the lodged planning application does include agricultural land, woodland blocks and scrub with a lake of some 9.2 hectares representing the natural groundwater level. The proposed restoration of the MIN40 site reflects the permitted restoration of the existing Grandcourt Quarry site and has been designed to complement and fit in with this overall restoration which is dictated by the geotechnical assessment and local geological circumstances.

The overburden volumes in the Grandcourt extension area and volumes required to restore the site as per the submitted proposed restoration scheme are as follows:

Overburden materials identified by drilling programmes:
Soils 78,000m3
Carstone 1,300,000 m3
Clay 420,000 m3
Material required to create the proposed landform in the MIN40 site:
Material required to create 1:4 slopes on final sand and overburden faces 1,020,000 m3
Material required to create embankment for bridleway and farm access 736,000 m3
Given the material balance for the site as shown above and with no proposal to import any material for restoration or other purposes, the final landform and restoration scheme proposed is the only one which can reasonably be implemented. The MIN40 site is not suitable for heathland restoration.

The submitted Environmental Statement contains a hydrogeological risk assessment which identifies potential impacts on groundwater including the perched water table in the Carstone. The proposed eastern extension will have little or no additional significant impacts to the north, south and west. The area over which drawdown in groundwater levels will occur will increase to the east, but no water sensitive receptors have been identified within the predicted area of influence in this direction. It is proposed that the potential additional impacts to surface and groundwater are monitored and controlled via a minor revision of the existing Water Management Plan.
There is electricity infrastructure within MIN40 site
Subject to the above comments Sibelco supports the inclusion of MIN40 as a Specific Site.

Question 68: Proposed Site SIL 01 'land at Mintlyn South, Bawsey'
Sibelco supports the inclusion of SIL01 as a Specific Site

Question 69: Area of Search AOS E 'land to the north of Shouldham'
Area of Search E
Sibelco supports the inclusion of Area E as an Area of Search for silica sand

Question 73: Policy MP13: 'Areas of Search for silica sand extraction'
Sibelco supports Policy MP13 on Areas of Search for silica sand, subject to our response to Question 9

Question 74: Proposed Site SIL 02 'land at Shouldham and Marham'
Sibelco supports the inclusion of SIL02 as an allocated site and would propose that given the promoters knowledge of the local geology, the site should be allocated as a Specific Site. Further silica sand provision will be required at the end of the Plan period
The National Planning Practice Guidance says:
a) designating Specific Sites - where viable mineral resources are known to exist, landowners are supportive of minerals development and the proposal is likely to be acceptable in planning terms ....

This definition applies to SIL02

As the Government's adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully taken into account at all stages and levels of the local planning process. Our comments below should be read with our detailed comments in the attached table.

Summary
At this early stage in the plan process, we have identified in detail in the attached table the changes that we recommend. However, looked at as a whole we have identified two key issues to address for the next iteration of the plan, which we summarise below:

a) Evidence-based allocations: the aim should be to avoid harm in the first instance before minimising or mitigating (Planning Practice Guidance, paragraph 019 reference ID 18a-019-20140306 revision date 06 03 2014). A proposed allocation needs to be based on evidence and should seek to avoid harm to heritage assets in the first instance, then set out how it could be mitigated against if the harm is unavoidable and the public benefits justify that harm under paragraphs 194, 195, or 196 of the National Planning Policy Framework. The following sites do not meet that threshold: MIN 79 and 80, SIL 02, MIN 40, MIN 32, MIN 19 and 205, MIN 48 and MIN 116. Of those, SIL 02 (a large preferred area immediately abutting a complex of highly graded heritage assets) along with AOS E, MIN 19 and MIN 205; MIN 48 (which incorporates a scheduled monument) and MIN 79 (with other development considerations) are most concerning. We would expect some level of heritage impact assessment to be done on the most sensitive sites in order for them to be allocated.

When areas are included in allocations, preferred areas or areas of search which cannot be developed adds confusion and complexity to the planning system. Once the principle of development is established through inclusion within a site allocation, preferred area or area of search, it is more difficult to rebut the presumption in favour of development owing to the assumption that, in an evidence and plan-led system, these aspects are factored into the allocation. As such all sensitive sites should be assessed and the results of that assessment inform whether or not there is an allocation, preferred area or area of search; what size and location it can be and what policy requirements, including mitigation measures, need to be embedded to conserve or enhance the historic environment.

b) Lack of specific local historic environment policy protection: policy MW2 is too generic to provide specific local criteria and/or requirements against which planning applications will be assessed. This could be addressed through an historic environment policy or through specific site allocation policies that specify requirements such as impact assessments, avoidance and mitigation measures, archaeological investigation, progressive working, and aftercare requirements. Many of these already have been identified in the Sustainability Appraisal Annex B. This particularly affects sites MIN 35, MIN 38, and MIN 203, though we have identified where many more proposed allocations should incorporate this information.

Conclusion
As you develop the minerals and waste plan, we would welcome discussing further the points raised in our representations.

In preparation of the forthcoming minerals and waste local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

Technological progress and change are a feature of modern life and all communities can expect to be subject to some impact from these forces as time moves on. What really matters is the scale of the development under consideration and it's consequent impact. The communities of Shouldham and Marham might reasonably be expected to accommodate a silica sand extraction site a quarter of the proposed size of approximately 1000 acres involving instead 5 years of work and disruption with an area that could be discreetly absorbed. Instead they are confronted with no less than 20 years of blight arising from a massive project scale that will nudge against the boundaries of both communities. The scheme map gives the impression that the only thing stopping it's desired expansion is the physical existence of Shouldham and Marham which are inconveniently in the way. Whilst acknowledging the need for Norfolk County Council to extract mineral resources in appropriate areas - these sites of extraction should be commensurate with the needs of existing communities rather than simply bludgeoning them aside. I feel that the scale of this proposed development is unreasonable given its immediate proximity to the communities involved. The appraisal in the Initial Consultation Area of Search E (Land north of Shouldham) document is thorough in its consideration of the physical impact silica sand extraction will have on historical geographical features. It gives scant regard to the impact on the residents of the disruption arising from a huge amount of excavation that is likely to involve significant noise pollution including the use of explosives and heavy machinery. The light at the end of a very long tunnel will be the promise of recreational resource rich in natural biodiversity including I would expect significantly increased numbers of wading birds and wildfowl. There is no mention of RAF Marham in the Area of Search but hopefully the RAF has been invited to comment on the increased risk of bird strike that will accrue for aircraft landing and taking off at the air station, in addition to the risk for low flying aircraft negotiating routes over and around this proposed site. I would be grateful if you could take my comments into consideration.

I am a keen ornithologist and bird ringer for the British trust of ornithology. I have monitor, reported on and watched birds all over the world and ring birds at Marham little fen.
it is with total horror that i see there are plans in place to extract sand and gravel from this area.
The area around Button fen and around the back of the warren has had breeding Lapwing, Yellowhammer, Linnet and Grey partridge on this year. All these birds are on the RED list of the RSPB birds of concern. They are struggling enough with yet more land being turn into a dust bowl of quarries.

Reed Bunting, Mute Swan, Little Grebe, Black headed Gull all nest around here to and are on the amber list of British birds of concern.

I was born in Marham in 1963 and have watched the destruction of the little fen over the years as they drained it and lost a fantastic habitat for Marsh Harrier, Reed warbler and other species.

The amount of noise dust and disturbance is intolerable and the proposed plans as to what they replace it with is utterly useless for birds. Deep sided lakes no good for swans or waders they do this to prevent encouraging birds down because of the bird strike threat to RAF Marham. So you dig up a fantastic habitat and replace with something utterly useless for the species that use to use it.

I now live in leziate near to the silica quarry. I can not imaging the traffic using these small roads to ferry sand back to leziate its bad enough on the A roads.

THIS PROPOSED PLAN HAS TO BE STOPPED.

Thank you for consulting me on the Norfolk Minerals and Waste Local Plan. The plan is very thorough and I broadly feel that Landscape has been considered in an accurate and suitable manner.

MIN51 / MIN13 The landscape features within this site, including hedgerow oaks and blocks of woodland are significant in the landscape and should be protected during working of the site. These should also be used as focal points for restoration. The restoration should reflect and strengthen the retained features.

MIN23 I support the conclusion that this site would be unsuitable due to landscape impacts. Screening or bunding used to mitigate these impacts would be intrusive and due to the sloping topography, would be unlikely to be effective.

MIN200 Screening will be particularly important with this site so as to minimise views and retain the setting of nearby listed buildings.

MIN116 I am in support of the initial conclusion for this site. Impacts on nearby dwellings/ Public Rights of Way and the local landscape would be unacceptable. Although bunding and advanced planting is proposed, I feel this would not be sufficient and the bunding itself is likely to be unnecessarily intrusive.

MIN55 The deep extraction proposed on this site would make it hard to restore to a suitable landform that could be sinuous with the surrounding landscape. I agree with the conclusion that this would make the site unsuitable for allocation.

MIN202 The deep extraction proposed on this site would make it hard to restore to a suitable landform that could be sinuous with the surrounding landscape. I agree with the conclusion that the site would be suitable for allocation with a shallower depth of extraction.

MIN 37 Screening should be carefully considered, with native species chosen where possible. The extensive use of conifers should be avoided where possible. Advance planting is required to mitigate views.

MIN64 It is important to retain field boundary hedgerows and trees, the removal of these will have a major impact on the landscape. In addition any planting proposed should strengthen the existing with hedgerow and tree belts and form part of the restoration after the site has been worked.

MIN203 The landscape impacts of this extension site would be negligible.

MIN38 Although screening trees would be retained, there are large areas of woodland within the site which, although not characteristic of the area, form an identifiable part of the landscape. Although loss of woodland in this area would not cause a large impact on the wider landscape the immediate effects from within the woodland would be noticeable.

MIN45 In support of my Arboriculture colleagues comments, I am in agreement that this site is unsuitable for allocation.

MIN204 I support the requirement for a detailed landscaping scheme to mitigate impacts on Feltwell Gate Lodge and surrounding landscape.

MIN19 and MIN205 Whilst the removal of the plant is now not a consideration in the issue of landscape gain, with the right restoration these sites could provide other landscape gain.

MIN77 In support of my Arboriculture colleagues comments, I am in agreement that this site is unsuitable for allocation due to the importance of Runs Wood.

AOS E This area contains a large amount of woodland, which is intrinsic within the overall landscape, providing important visual and biodiversity connections. Where possible woodland should be retained, but where loss is unavoidable suitable mitigation should be provided during the working of any site within the area of search, and the planting of woodland should be considered as part of any restoration.

AOS I There are a number of viewpoints which will need to be considered within this area of search, it may be that only part of the area of search is suitable for mineral extraction.

SIL02 Bunding for this site has the potential to be intrusive. There are a number of views/settings and impacts on the wider landscape that will need to be carefully considered. A combination of advanced planting and bunding may be suitable, but care needs to be taken that the mitigation in itself doesn't have further impacts.

MIN69 This site lays within the Norfolk Coast AONB therefore screening will be of utmost importance. Restoration would need to demonstrate that after the site has been worked it could become exceptionally beneficial to both the landscape and the public.

MIN71 This site has the potential to have detrimental impact on residential amenity, a suitably designed strategy will need to demonstrate that this amenity can be protected and views minimised. I would agree with conclusions that a buffer for Holt itself will be required.

MIN115 I am in agreement with my Arboriculture colleague that this site is not suitable for allocation. Should the allocation remain in place it would be necessary to ensure a suitable tree belt screen is maintained to minimise views from adjacent Public Rights of Way.

MIN209/MIN210/MIN211 I would support the movement of the processing plant to an area to be worked over the choice to relocate it to an already restored area.

MIN92 The retention of the hedgerow oaks is important with their place in the landscape being intrinsic in the attractiveness of the area. I agree that this combined with the location adjacent to the Broads Authority Executive Area make the site unsuitable for allocation.

MIN79 Sprow's pit copse should be retained throughout the works and become a focus on in the restoration scheme. The restoration scheme should incorporate and extend the copse and strengthen the boundary planting.

Public Rights of Way - Where PRoW are adjacent or within the site, consideration should be given to insure that impacts are minimal. Where works will have a direct impact on the PRoW, discussions will need to take place with NCC to agree a suitable temporary diversion and subsequent reinstatement.

In our opinion the plan is fit for purpose. We have a few comments/ recommendations regarding the plan as follows:

SIL 02 Land at Shouldham and Marham
This site is located adjacent to the River Narr SSSI, we would advise no extraction takes place outside of the 'reduced development area' between the proposed site and River Narr SSSI to reduce the likelihood of impacts on the River Narr SSSI and its qualifying features.
We agree that an assessment of potential impacts on the River Narr SSSI and Marham Fen, including from dust deposition and hydrogeology, together with appropriate mitigation would be required as part of any planning application.
It should be noted in the 'initial conclusion' that an ecological assessment to determine baseline conditions on the site must be prepared which may lead to the need for further surveys and mitigation measures, if necessary. (This should always be the case with 'greenfield sites'. I know this was mentioned in the wider document, however it would be good if this could be included in the 'initial conclusions' for new sites). It would also be useful in the initial conclusions to ensure it is clear that a restoration scheme to protect and enhance biodiversity will be put in place post extraction.

MIN45 land North of Coxford Quarry and MIN 77 Runs Wood Tottenhill
We are in agreement with the conclusions that the sites are unsuitable for allocation in accordance with Section 15 of the NPPF.

MIN40 land east of Grandcourt Farm, East Winch
We agree with the Arboricultural officers comments for land east of Grandcourt Farm. It should also be noted that if avoidance measures are not possible and these veteran trees are removed, an assessment of the value of these trees for wildlife in particular bats and nesting birds must be undertaken prior to any works on these trees.

Search: AOS E land to the North of Shouldham and MIN115 Lord Anson's Wood near North Walsham
Woodland is located within the allocated area for these sites. These woodland areas are of ecological value and likely support protected species and other wildlife. We would like to see woodland areas retained where possible. Where woodland areas are proposed for removal then an ecological assessment needs to be undertaken and any further surveys need to be carried out or mitigation proposed, if necessary.

MIN 92 Land east of Ferry Lane, Heckingham
We agree with the Arboricultural officers comments that this site is unsuitable for allocation.

Overall the Norfolk Minerals and Waste Local Plan is a very thorough and accurate document. My only comments are that trees have been considered under the headings of landscape or ecology throughout the document, rather than under a separate arboriculture heading. Having said this, I am happy for the document to remain as it is.

However as far as I can see, no reference has been made with regards to Arboricultural Impact Assessments (AIA) in the initial conclusions. I feel that where hedgerow trees or woodlands are adjacent to a proposed site that the offset from them needs to be determined at the very least by an annotated Tree Protection Plan or a full AIA to ensure root protection for the long term retention of the trees. For sites where an LVIA has been recommended (e.g MIN71) this would also need to include a full AIA.

For MIN45 land North of Coxford Quarry and MIN 77 Runs Wood Tottenhill, the initial conclusions recommend that that the sites are unsuitable for allocation in accordance with Section 15 of the NPPF. I am in agreement with these conclusions, particularly as Runs Wood is not ancient woodland but is still considered important due to its high biodiversity value.

MIN40 land east of Grandcourt Farm, East Winch - there appear to be trees within the proposed site at the NW corner which would have to be removed unless the site boundaries are amended. Bearing in mind that there were requirements regarding retaining veteran trees on land at Grandcourt Farm previously, I feel that an AIA would be required for this site to determine the categorisation of the trees in this area to determine if they are worthy of retention.

AOS E land to the North of Shouldham - this area encompasses a large amount of woodland centred on Shouldham Warren that when viewed from a satellite image shows that this is a large block of woodland within a largely arable landscape that forms a connecting feature with the woodland centred on West Bilney Wood to the NE. As such, although the woodland is undesignated in any way, it is a vital connecting feature within the landscape and where possible should be retained. If any of the woodland area is removed, appropriate planting of a similar size of broadleaved woodland should be included as part of the restoration scheme.

MIN115 Lord Anson's Wood near North Walsham - I would disagree that this site is suitable for allocation, in accordance with section 170b of the NPPF. The removal of this section of woodland would degrade the overall capital value, ecosystem services and recreational values provided by the woodland.

The landscape paragraph details mature trees and woodland that are to be retained and enhanced. The initial conclusion also states that a wide screen of trees is to be left around the site. I therefore propose that if this site remains allocated that a full AIA is required to achieve this and this should be listed in the initial conclusion.

MIN 92 Land east of Ferry Lane, Heckingham - I agree with the conclusion that this site is unsuitable for allocation due to the line of mature oaks in the centre of the site.

MIN 204 land north of Lodge Road Feltwell - this site is surrounded by coniferous woodland and hedgerows and would require an AIA to ensure sufficient standoff from the adjacent trees to ensure their roots are protected for their safe long term retention.

The residents of Marham and Shouldham live in a quiet rural community that has provided a peaceful home for the RAF and their families for 100 years. For the community this is an area of natural beauty that is highly valued.
A proposed development of this scale and impact must be put to a democratic vote via a local referendum. The proposals will blight the community, ruin the environment, and reduce the community amenity. The financial beneficiaries of this development have no long term interest in the local community or the condition of the environment.
There are many specific reasons why this this development proposal should be rejected, I anticipate these will be covered in detail by others. In addition to this the current consultation documentation is unacceptable, it is vague, not legally binding and therefore subject to variation. The reality is once this kind of development begins the terms of reference change and developments expanded both in scale and duration. It is also very concerning that there is no agreed restoration plan for this site. I would have thought that this a fundamental issue that underpins the sustainability and suitability of any development of this kind.

Whilst I recognise this is a consultation document the reality is that it will be used as the basis for going forward and as such the suggestion that the local community has been fully consulted will be inferred. I therefore oppose the proposals in principle as the primary stakeholder (the community) has not been fully informed or consulted. The consultation process has not been set out in detail. Guidance on the rights of the community to determine how they can shape decision making has not been provided.

Once a consultation process has been properly completed and due process seen to be done the County Council must undertake and fund a local referendum on this matter. The reason why the United Kingdom voted to leave the European Union can be expressed in three words: 'To Take Back Control'. Local people must have control over the decisions that impact and shape their communities and environment. Elected representatives, Borough Councillors, County Councillors and Members of Parliament, must support and respect the democratic will of local people.

I would like to add further to my original objection that I oppose both SIL 02 and AOS E. If you note this on my original objection.

Proposed Site SIL 02 As A Preferred Area for Silica Sand Extraction by SIBELCO UK Ltd Behind Spring Lane and Mere Plot Near Marham and Shouldham, Kings Lynn, NORFOLK. AOS E

Please accept this email as an objection to the above proposal.
I reside in the village of Marham I object to this planned development for the following reasons;

1. Environmental issues

If approved, the project will strip all vegetation, soil and clay from the fields to allow quarrying equipment access to the sand below. This will involve heavy duty equipment brought to the site - congestion and damage to already badly repaired/maintained roads, plus the noise, pollution and disruption to the villages affected by this project.

This large plot of land will be 'mined' for over 20 years, this WILL totally destroy the flora and fauna of this area and the landscape changed forever.

Nearly 400 hectares of good quality agricultural farmland will be destroyed. With an ever increasing population we as a nation, need to consider this land for agricultural rather than industrial uses.

Any screening or bunding of the site to mitigate noise and light pollution will ruin this beautiful landscape.
What will happen to the removed soil from the land stripping process?

2. Health and safety

The sand/silica/dust created has health and safety concerns. Sand and dust will easily reach properties in Marham and Shouldham, significantly affecting the health of the elderly, our children and those with pre-existing breathing difficulties.

3. Noise, dust and light pollution
The area is flat and this site will be visible to the majority of the residents of Marham, Marham being on higher ground than the proposed site. Screening will, therefore, be ineffective or so tall as to block all views across the Fen from both Marham and Shouldham. There is no bunding large enough to provide a barrier against the noise and light pollution this work will cause. The noise, dust and light pollution from the estimated 11 hour day land stripping and 24 hour a day 7 days a week dredging is totally unacceptable

4. The Water Table / Flood plain

The land is currently part of a HIGH RISK flood plain. The plan by Sibelco is to flood this area in order to dredge the sand. This will only increase the chance of future flooding in the area.
Any bunding and piles of surface soil and clay will only reduce the natural flow of water and increase the risk of flooding further.

5. Local community.

What is the value of the proposal to the local community and Britain? Sibelco is not a British company, its head offices are based in Belgium. The value of this type of sand is extremely profitable.

There will be no job benefits to the local community as the manpower required to run the planned dredging operations is less than the current services of those working the land. There will therefore be a reduction in jobs and absolutely no value or benefit of such a scheme to the local community.

6. Property Value
This site will significantly reduce the value of properties in and around Marham and Shouldham for at least the next 28 years.


7. Other
The proximity to RAF Marham and the danger to aircraft from increased bird activity due to the excavation and subsequent flooding of the site. This would be a catastrophic event for the aircrew, the aircraft and the community if there is a crash and a total waste of taxpayers money to replace or repair the aircraft.

In conclusion; the destruction of this rural setting, reduced appeal to visitors and residents in the future and quality of life for residents of both villages now, will be impacted severely with little to gain for the local population/area who will bear the brunt of this project. This project will make the area poorer but considerable profit for SIBELCO.
Please accept the above points as a formal objection to the proposed silica sand extraction site SIL 02 proposed by Sibelco UK Ltd.

I wish to lodge my objection to the proposed site SIL. 02 as a preferred area for silica sand extraction. And also object to the proposed site AOS E - Shouldham Warren for the same reasons.

I understand the need to provide a future source of silica sand, however, I feel that this development will have a disproportionate and devastating impact on a rural community, already affected by a rapidly expanding RAF airbase of strategic national importance.

I would also like to note that the proposal put forward by Sibelco is an optimistic 'best case scenario' which downplays the negative impact on the residents wellbeing, our community, and the environment, especially considering the massive size and time scales involved in the development.

I would also like to point out that the process has not adhered to the principles laid out in Norfolk County Council's own Statement of Community Involvement. Residents were completely unaware of these plans, they were not notified of the consultation and had only a few days to prepare a response ahead of the deadline.

In particular, my objection is based on the following grounds:

Health / Safety & Environment

a) Unacceptable increase in Noise, Dust and Light pollution as a direct result of the proposed extraction is in violation of local residents' rights as per European Convention on Human Rights, specifically Article 2 (right of life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 ( respect for one's private and family life, home and correspondence ), and Protocol 1 ( right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents.
b) Prolonged exposure to Silica dust present significant risk to vulnerable members of the community, particularly the elderly and young, given the village demographics.
c) No information has been provided regarding the impact of mineral extraction on local water supply/quality.
d) No restriction on site working hours is proposed.
e) This is the only proposal within Norfolk M&WLP that is in a high-risk flood area. Flood risks are further exacerbated by the removal of ancient drainage ditches.

Economic.

a) No proposed economic benefit for the villages of Marham or Shouldham.
b) No additional job creation.
c) Reduction in house values.
d) Potential impact on home insurance due to increased flood risk.
e) Reduction in tourism and visitors to the Nar Valley Way.
f) Creation of trapped residents unable to move due to the inevitable slowing of the housing market.

Local Infrastructure

a) Existing road infrastructure is unsuitable for HGV and plant access. Precedence has been established by RAF Marham who are prohibited from using village roads for access purposes.
b) Local trunk roads will be negatively affected by increased traffic (A47 & A10 ).
c) No proposal for Sibelco's preferred option for above ground pipelines between proposed site and their current site at Leziate taking into account natural and transport barriers.

Ecology

a) Destruction of habitat of endangered wildlife species including:
a1) Voles, Newts, scarce Emerald Damselfly, Mayfly, Moths including the Grizzled Skipper, Dingy Skipper.
a2) Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet, Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge.
b) Dust deposition relating to the River Nar - a designated SSSI and Core River Valley.
d) No proposal as to how the Core River Valley will be enhanced following mineral extraction.
e) Detrimental impact on ecology and biodiversity on nearby Country Wildlife Sites.
f) No restoration plan proposed for the entire site, which suggests there is no intention to remedy the harm caused, fears exacerbated by the very poor and dangerous condition of other Sibelco sites, such as Bawsey and Leziate.

Landscape

a) Marham village enjoys an elevated position relative to the proposed site, with beautiful long-reaching views across the fen landscape.
a1) Bunds or screening will be ineffective and intrusive in their own right.
a1) Proposed works will be visually detrimental and out of character with the local landscape.
b) Prevailing North and North West winds will aggravate noise and dust pollution concerns and impact on health.
c) Irreplaceable loss of agricultural land.
d) Destruction of ancient footpaths and relocation of rights of way (further than the stipulated 100m permitted) contained both within and adjacent to the proposed site, which are extensively used by local residents, schools and tourists.
e) Detrimental impact on the open nature of the landscape and to the setting of the scheduled monuments Pentney Priory Gatehouse and other heritage assets.
f) No assurances have been received regarding the possibility of the site being used for Landfill in the future.

Archaeology

a) This area is potentially very rich in archaeological finds, from Pre-Historic to Roman to Medieval and any undiscovered sites would be destroyed permanently by the project.
b) Close proximity to Pentney Priory Gatehouse and the unexplored Cistercian Nunnery in Marham.

In conclusion, nothing in this proposal addresses residents' concerns about the devastating impact the development will have on our community, quality of life, health and wellbeing for decades to come. No assurances have been given that the site will not be abandoned as industrial wasteland with zero potential for leisure or ecological benefit.

If you require any clarification of the points raised, we would be happy to discuss the matter further.

I wish to lodge my objection to the proposed site SIL. 02 and AOS E as a preferred area for silica sand extraction.

I understand the need to provide a future source of silica sand, however, I feel that this development will have a disproportionate and devastating impact on a rural community, already affected by a rapidly expanding RAF airbase of strategic national importance.

I would also like to note that the proposal put forward by Sibelco is an optimistic 'best case scenario' which downplays the negative impact on the residents wellbeing, our community, and the environment, especially considering the massive size and time scales involved in the development.

I would also like to point out that the process has not adhered to the principles laid out in Norfolk County Council's own Statement of Community Involvement. Residents were completely unaware of these plans, they were not notified of the consultation and had only a few days to prepare a response ahead of the deadline.

In particular, my objection is based on the following grounds:

Health / Safety & Environment

a) Unacceptable increase in Noise, Dust and Light pollution as a direct result of the proposed extraction is in violation of local residents' rights as per European Convention on Human Rights, specifically Article 2 (right of life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 ( respect for one's private and family life, home and correspondence ), and Protocol 1 ( right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents.
b) Prolonged exposure to Silica dust present significant risk to vulnerable members of the community, particularly the elderly and young, given the village demographics.
c) No information has been provided regarding the impact of mineral extraction on local water supply/quality.
d) No restriction on site working hours is proposed.
e) This is the only proposal within Norfolk M&WLP that is in a high-risk flood area. Flood risks are further exacerbated by the removal of ancient drainage ditches.

Economic.

a) No proposed economic benefit for the villages of Marham or Shouldham.
b) No additional job creation.
c) Reduction in house values.
d) Potential impact on home insurance due to increased flood risk.
e) Reduction in tourism and visitors to the Nar Valley Way.
f) Creation of trapped residents unable to move due to the inevitable slowing of the housing market.

Local Infrastructure

a) Existing road infrastructure is unsuitable for HGV and plant access. Precedence has been established by RAF Marham who are prohibited from using village roads for access purposes.
b) Local trunk roads will be negatively affected by increased traffic (A47 & A10 ).
c) No proposal for Sibelco's preferred option for above ground pipelines between proposed site and their current site at Leziate taking into account natural and transport barriers.

Ecology

a) Destruction of habitat of endangered wildlife species including:
a1) Voles, Newts, scarce Emerald Damselfly, Mayfly, Moths including the Grizzled Skipper, Dingy Skipper.
a2) Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet, Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge.
b) Dust deposition relating to the River Nar - a designated SSSI and Core River Valley.
d) No proposal as to how the Core River Valley will be enhanced following mineral extraction.
e) Detrimental impact on ecology and biodiversity on nearby Country Wildlife Sites.
f) No restoration plan proposed for the entire site, which suggests there is no intention to remedy the harm caused, fears exacerbated by the very poor and dangerous condition of other Sibelco sites, such as Bawsey and Leziate.

Landscape

a) Marham village enjoys an elevated position relative to the proposed site, with beautiful long-reaching views across the fen landscape.
a1) Bunds or screening will be ineffective and intrusive in their own right.
a1) Proposed works will be visually detrimental and out of character with the local landscape.
b) Prevailing North and North West winds will aggravate noise and dust pollution concerns and impact on health.
c) Irreplaceable loss of agricultural land.
d) Destruction of ancient footpaths and relocation of rights of way (further than the stipulated 100m permitted) contained both within and adjacent to the proposed site, which are extensively used by local residents, schools and tourists.
e) Detrimental impact on the open nature of the landscape and to the setting of the scheduled monuments Pentney Priory Gatehouse and other heritage assets.
f) No assurances have been received regarding the possibility of the site being used for Landfill in the future.

Archaeology

a) This area is potentially very rich in archaeological finds, from Pre-Historic to Roman to Medieval and any undiscovered sites would be destroyed permanently by the project.
b) Close proximity to Pentney Priory Gatehouse and the unexplored Cistercian Nunnery in Marham.

In conclusion, nothing in this proposal addresses residents' concerns about the devastating impact the development will have on our community, quality of life, health and wellbeing for decades to come. No assurances have been given that the site will not be abandoned as industrial wasteland with zero potential for leisure or ecological benefit.

If you require any clarification of the points raised, we would be happy to discuss the matter further.

I wish to lodge my objection to the proposed site SIL. 02 and AOS E as a preferred area for silica sand extraction.

I understand the need to provide a future source of silica sand, however, I feel that this development will have a disproportionate and devastating impact on a rural community, already affected by a rapidly expanding RAF airbase of strategic national importance.

I would also like to note that the proposal put forward by Sibelco is an optimistic 'best case scenario' which downplays the negative impact on the residents wellbeing, our community, and the environment, especially considering the massive size and time scales involved in the development.

I would also like to point out that the process has not adhered to the principles laid out in Norfolk County Council's own Statement of Community Involvement. Residents were completely unaware of these plans, they were not notified of the consultation and had only a few days to prepare a response ahead of the deadline.

In particular, my objection is based on the following grounds:

Health / Safety & Environment

a) Unacceptable increase in Noise, Dust and Light pollution as a direct result of the proposed extraction is in violation of local residents' rights as per European Convention on Human Rights, specifically Article 2 (right of life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 ( respect for one's private and family life, home and correspondence ), and Protocol 1 ( right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents.
b) Prolonged exposure to Silica dust present significant risk to vulnerable members of the community, particularly the elderly and young, given the village demographics.
c) No information has been provided regarding the impact of mineral extraction on local water supply/quality.
d) No restriction on site working hours is proposed.
e) This is the only proposal within Norfolk M&WLP that is in a high-risk flood area. Flood risks are further exacerbated by the removal of ancient drainage ditches.

Economic.

a) No proposed economic benefit for the villages of Marham or Shouldham.
b) No additional job creation.
c) Reduction in house values.
d) Potential impact on home insurance due to increased flood risk.
e) Reduction in tourism and visitors to the Nar Valley Way.
f) Creation of trapped residents unable to move due to the inevitable slowing of the housing market.

Local Infrastructure

a) Existing road infrastructure is unsuitable for HGV and plant access. Precedence has been established by RAF Marham who are prohibited from using village roads for access purposes.
b) Local trunk roads will be negatively affected by increased traffic (A47 & A10 ).
c) No proposal for Sibelco's preferred option for above ground pipelines between proposed site and their current site at Leziate taking into account natural and transport barriers.

Ecology

a) Destruction of habitat of endangered wildlife species including:
a1) Voles, Newts, scarce Emerald Damselfly, Mayfly, Moths including the Grizzled Skipper, Dingy Skipper.
a2) Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet, Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge.
b) Dust deposition relating to the River Nar - a designated SSSI and Core River Valley.
d) No proposal as to how the Core River Valley will be enhanced following mineral extraction.
e) Detrimental impact on ecology and biodiversity on nearby Country Wildlife Sites.
f) No restoration plan proposed for the entire site, which suggests there is no intention to remedy the harm caused, fears exacerbated by the very poor and dangerous condition of other Sibelco sites, such as Bawsey and Leziate.

Landscape

a) Marham village enjoys an elevated position relative to the proposed site, with beautiful long-reaching views across the fen landscape.
a1) Bunds or screening will be ineffective and intrusive in their own right.
a1) Proposed works will be visually detrimental and out of character with the local landscape.
b) Prevailing North and North West winds will aggravate noise and dust pollution concerns and impact on health.
c) Irreplaceable loss of agricultural land.
d) Destruction of ancient footpaths and relocation of rights of way (further than the stipulated 100m permitted) contained both within and adjacent to the proposed site, which are extensively used by local residents, schools and tourists.
e) Detrimental impact on the open nature of the landscape and to the setting of the scheduled monuments Pentney Priory Gatehouse and other heritage assets.
f) No assurances have been received regarding the possibility of the site being used for Landfill in the future.

Archaeology

a) This area is potentially very rich in archaeological finds, from Pre-Historic to Roman to Medieval and any undiscovered sites would be destroyed permanently by the project.
b) Close proximity to Pentney Priory Gatehouse and the unexplored Cistercian Nunnery in Marham.

In conclusion, nothing in this proposal addresses residents' concerns about the devastating impact the development will have on our community, quality of life, health and wellbeing for decades to come. No assurances have been given that the site will not be abandoned as industrial wasteland with zero potential for leisure or ecological benefit.

If you require any clarification of the points raised, we would be happy to discuss the matter further.

I wish to lodge my objection to the proposed site SIL. 02 and AOS E as preferred areas for silica sand extraction.

I understand the need to provide a future source of silica sand, however, I feel that this development will have a disproportionate and devastating impact on a rural community, already affected by a rapidly expanding RAF airbase of strategic national importance.

I would also like to note that the proposal put forward by Sibelco is an optimistic 'best case scenario' which downplays the negative impact on the residents wellbeing, our community, and the environment, especially considering the massive size and time scales involved in the development.

I would also like to point out that the process has not adhered to the principles laid out in Norfolk County Council's own Statement of Community Involvement. Residents were completely unaware of these plans, they were not notified of the consultation and had only a few days to prepare a response ahead of the deadline.

In particular, my objection is based on the following grounds:

Health / Safety & Environment

a) Unacceptable increase in Noise, Dust and Light pollution as a direct result of the proposed extraction is in violation of local residents' rights as per European Convention on Human Rights, specifically Article 2 (right of life), given health concerns about silica dust and links to silicosis and respiratory diseases, Article 8 ( respect for one's private and family life, home and correspondence ), and Protocol 1 ( right to peaceful enjoyment of your property), considering the 'excessive burden' placed on thousands of individual residents.
b) Prolonged exposure to Silica dust present significant risk to vulnerable members of the community, particularly the elderly and young, given the village demographics.
c) No information has been provided regarding the impact of mineral extraction on local water supply/quality.
d) No restriction on site working hours is proposed.
e) This is the only proposal within Norfolk M&WLP that is in a high-risk flood area. Flood risks are further exacerbated by the removal of ancient drainage ditches.

Economic.

a) No proposed economic benefit for the villages of Marham or Shouldham.
b) No additional job creation.
c) Reduction in house values.
d) Potential impact on home insurance due to increased flood risk.
e) Reduction in tourism and visitors to the Nar Valley Way.
f) Creation of trapped residents unable to move due to the inevitable slowing of the housing market.

Local Infrastructure

a) Existing road infrastructure is unsuitable for HGV and plant access. Precedence has been established by RAF Marham who are prohibited from using village roads for access purposes.
b) Local trunk roads will be negatively affected by increased traffic (A47 & A10 ).
c) No proposal for Sibelco's preferred option for above ground pipelines between proposed site and their current site at Leziate taking into account natural and transport barriers.

Ecology

a) Destruction of habitat of endangered wildlife species including:
a1) Voles, Newts, scarce Emerald Damselfly, Mayfly, Moths including the Grizzled Skipper, Dingy Skipper.
a2) Birds - conservation priority red list: Skylark, Lapwing, House Sparrow, Linnet, Yellowhammer, Song Thrush, Grey Wagtail, Tree Pipit, Nightjar, Woodlark, Grey Partridge.
b) Dust deposition relating to the River Nar - a designated SSSI and Core River Valley.
d) No proposal as to how the Core River Valley will be enhanced following mineral extraction.
e) Detrimental impact on ecology and biodiversity on nearby Country Wildlife Sites.
f) No restoration plan proposed for the entire site, which suggests there is no intention to remedy the harm caused, fears exacerbated by the very poor and dangerous condition of other Sibelco sites, such as Bawsey and Leziate.

Landscape

a) Marham village enjoys an elevated position relative to the proposed site, with beautiful long-reaching views across the fen landscape.
a1) Bunds or screening will be ineffective and intrusive in their own right.
a1) Proposed works will be visually detrimental and out of character with the local landscape.
b) Prevailing North and North West winds will aggravate noise and dust pollution concerns and impact on health.
c) Irreplaceable loss of agricultural land.
d) Destruction of ancient footpaths and relocation of rights of way (further than the stipulated 100m permitted) contained both within and adjacent to the proposed site, which are extensively used by local residents, schools and tourists.
e) Detrimental impact on the open nature of the landscape and to the setting of the scheduled monuments Pentney Priory Gatehouse and other heritage assets.
f) No assurances have been received regarding the possibility of the site being used for Landfill in the future.

Archaeology

a) This area is potentially very rich in archaeological finds, from Pre-Historic to Roman to Medieval and any undiscovered sites would be destroyed permanently by the project.
b) Close proximity to Pentney Priory Gatehouse and the unexplored Cistercian Nunnery in Marham.

In conclusion, nothing in this proposal addresses residents' concerns about the devastating impact the development will have on our community, quality of life, health and wellbeing for decades to come. No assurances have been given that the site will not be abandoned as industrial wasteland with zero potential for leisure or ecological benefit.

If you require any clarification of the points raised, we would be happy to discuss the matter further.

The MOD previously commented on the Norfolk Minerals and Waste Local Plan in August 2018. However, based on safeguarding comments regarding birdstrike, the policy team submitted additional information to determine the viability of the proposed sites.
The sites identified as part of the Norfolk Minerals and Waste Local Plan occupy the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The MODs main concern regarding mineral schemes is the phased working, proposed restoration and aftercare of the site. As the creation of open water bodies in this area has the potential to increase birdstrike risk to aircraft operations.
Please note each planning application is assessed on their individual merits at present there is limited information for a full detailed assessment to be carried out. However, please see below the MODs comments based on the additional
information received on the 18/11/18:

MIN 19 & 205 Land north of the River Nar, Pentney
The site is approximately 6km north west of RAF Marham. The restoration plan for this site shows a series of lakes, which are deep and steep sided surrounded by wet woodland with reed fringes. The design also includes 2 proposed walkways consisting of grassy glades which lie above water level.
Therefore, the MOD would have no safeguarding concerns subject to open water being kept to a minimum; the lakes are designed to be less than 200mx200m with steep bank sides as per restoration plan. A robust Bird Hazard Management Plan (BHMP) to be approved by the MOD should be applied to manage the hazardous birds i.e. waterfowl, gulls, heron etc. and applied to the adjacent site if owned by the same company.

MIN 76 Land at West Field, Watlington Road, Tottenhill
The MOD have recently reviewed this planning consultation and submitted conditional response citing subject to a BHMP being implemented we have no safeguarding concerns as part of planning consent.

MIN 40 - Land East of Grandcourt Farm, East Winch
The MOD commented on this application and the proposed extension to Grandcourt Farm at planning stages. There is an existing BMP in place which includes the extension site. Therefore, the MOD stated no objection subject to the BMP being implemented as part of planning consent.

SIL 01 Land at Mintlyn South, Bawsey
This site is approximately 12.4km north by north west from RAF Marham, any proposed water bodies would need to be designed to the following principles:
 No islands- as they provide safe predator free environment for roosting and nesting birds
 The bank margins are planted with dense goose proof barrier of emergent vegetation (common reed), or fenced to prevent easy access between open water and nearby short grass areas.
 A BHMP to remove or treat any feral goose nests and eggs to prevent feral geese successfully breeding on site
The above is based on the information available at present.

SIL 02 Land at Shouldham and Marham
This site is approximately 4.8km north west from RAF Marham. The proposed extraction site is a considerable area which is planned to be restored with large areas of open water.
A development of this nature in such proximity to the aerodrome is of great concern to aircraft safety.
Even if the site were to be reduced in scale this would be of serious concern to the MOD. Therefore, we would object to this site based on current plans.

AOS E Land north of Shouldham
It is difficult to determine the risk of wet restoration in this location without any plans illustrating the extent and design of open water bodies.
The MOD have safeguarding concerns to the wet working and restoration of this site due to its potential to attract and support hazardous waterfowl closer within critical airspace. Therefore, further information would be required before a definitive response can be made.

AOS J Land east of Tottenhill
In line with my comments above wet working and restoration at this location would have the potential to attract and support hazardous waterfowl. The MOD is unable to determine the extent of our concerns without knowing the restoration scheme.

In summary, MIN 19, 205, 76 & 40 the MOD has no safeguarding concerns subject to the implementation of a robust Bird Hazard Management Plan approved by the MOD as part of any planning permission granted.

With regards to SIL 01 at present this site is of concern to the MOD. However, due
to its location depending on the nature and scale of the restoration should be manageable with the right restoration and a BHMP in place.

AOS E and AOS J the MOD has concerns and would require further information to determine whether the sites could be managed with design principles and a BMP.
Finally, SIL 02 the MOD object to this site being implemented on its current design and scale.

I trust this is clear however should you have any questions please do not hesitate to contact me.