2. The consultation process

Objection to AOS E (Land to the north of Shouldham) and SIL 02 (land at Shouldham and Marham)

I object to AOS E and SIL 02, including Shouldham Warren the overlap between these two sites in the Norfolk Minerals and Waste Local Plan (M&WLP). I strongly object to the fact that Norfolk County Council (NCC) continues to employ a public consultation process without scrutinising its efficiency and that is clearly not fit for purpose - a fact exacerbated by a steady stream of false or misleading information both directly from NCC, such as "SIL 02 has been designated as unsuitable" (when in fact a third of that "preferred area" has simply been re-classified as AOS E) or via NCC and Borough Councillors who have advised local residents with messages such as: "don't worry about the consultation phase, you want to keep your powder dry for planning permission phase", "no more than 3 people can object from any single address," "weighting is given to those objections from residents living within 250m of the proposed sites" Given the strong criticisms already levelled at NCC regarding this current consultation, the sheer breadth of misinformation now goes beyond the pale of honest mistakes or poor communication and starts to suggest a coordinated effort to dissuade members of the public from participating in this process.

All four "key principles" set out in NCC's adopted Statement of Community Involvement have been violated:

1) Accountability (taking citizens' views into account) - concerns raised in the 460 responses to the first consultation in August 2018 have been ignored. Residents raised concerns about impact on health, wellbeing, environment, biodiversity, their rights to peaceful enjoyment of their properties, no benefit to local communities, failure to improve recycling of glass already in circulation, lack of restoration plans, and failure to conduct an effective and transparent process by NCC. The August 2019 Mineral Plan states that the "responses received have been considered in the production of the second public consultation document, the Preferred Options", however the 'Preferred Options' only reflected the concerns of the MOD and Historical Environment Services. NONE of the concerns raised by residents were taken into account or addressed.

2) Accessibility (consultation is clear and genuinely accessible) - an accessible consultation should not be written in incomprehensible language and should not require 1000s of hours of effort to understand and participate. It should not rely on concerned members of the public informing the wider community or rallying various consultee groups to respond. It should not require the public to defend and ensure existing government policies are complied with. It should not require an MP's involvement to ensure that public concern is registered and addressed.

3) Inclusivity (groups of the community are not excluded) - NCC deemed it reasonable to only send 10 letters to residents within an arbitrary 250m boundary of the site, despite the proposed silica mine being the largest in the country and affecting thousands of people, including disadvantaged and minorities, and the thousands of people who come to the Warren to enjoy the little nature that is left in West Norfolk.

4) Efficiency (ensuring methodology delivers results) - NCC continues to use the same ineffective methodology for consultation: in the 2015 consultation, AOS E received 7 responses; in the 2018 consultation, due to the efforts of CATSS local campaign group, AOS E and SIL02 received 460 responses. Other areas resulted in the same low level response (SIL01 - 8, AOS F - 3, AOS I - 4, AOS J - 6), because NCC continues to use ineffective methods of engagement with the residents of Norfolk.

I will continue to outline the reasons for my objections, however it is clear that trust in the process, NCC and Borough Councils is gone, as NCC only does the bare minimum in order to meet what it perceives as its legal obligations, and there is no interest in ensuring genuine, meaningful public participation, nor any evidence of taking the feedback and public concerns into account.

Economic objections

I object to the proposal as it is detrimental to the local economy and financially unsound. There are no jobs created, the only economic benefit would be to the privately-owned Belgian company, Sibelco. The silica sand is not used in Norfolk, it entirely exported elsewhere, including overseas. Much of the SIL 02 overlap is high grade agricultural farmland, used for growing sugar beets, which does contribute to job creation and income in the local area. It is unsound to be destroying farmland to dig up minerals for export on the eve of Brexit, when the aim of national policies is to ensure food security. Parts of AOS E is a managed wood plantation, again creating jobs and a supporting low carbon biomass industry.

Loss of a large green space used by thousands of people in West Norfolk will have a real impact on human physical and mental health, putting more financial pressure on the already overstretched NHS.

Loss of such a large carbon sink, hundreds of hectares of woodland and topsoil, at a time when the country is already struggling to meet its legally binding carbon reduction commitments means more expensive investments in carbon reductions elsewhere.

This proposal goes completely against the Local Development Plan for West Norfolk (https://www.west-norfolk.gov.uk/homepage/257/local_development_plan), which has identified Marham as a growth area, and envisages a place where "people want to be part of the success story that is West Norfolk, drawn her to live, work, invest and visit... to take advantage of quality of life... supporting strong, vibrant, healthy communities... with a access to local services that support the health, social and cultural well-being of local communities... with new development located and designed to be better adapted to climate change and risk of flooding... protecting and enhancing our justifiable famous natural and historic environment and ensuring growth of the borough makes sustainability a central principle of our vision". Nobody wants to live next to a silica mine, and this proposal has already negatively affected the local area economically through dampening the housing market.

Shouldham Warren and Nar Valley Way running along a Nar River SSSI are a major tourism and recreational destination, used by thousands of walkers, cyclists, horse riders and runners - contributing income to local tourism infrastructure and facilities. Pentney Priory Gatehouse, currently a wedding venue, overlooks the overlap are of AOS E and SIL 02 - this is an example of a specific business that would become non-viable if the view they currently experience over open land is turned into a working quarry.

MOD has already objected to the proposal given the risk of birdstrike to the aircraft at RAF Marham, the main operating base for the for the F35 Lightning II, an aircraft that costs £100+ million. The major damage to the singe engine of this aircraft, let alone loss of even one aircraft due to damage from a bird-strike would be financially intolerable and a major blow to the defence of the UK and our wider interests. The other costs of a crash landing of the aircraft to cover emergency services and long-term care and support to the affected people on the ground, are incalculable but would run into the tens if not hundreds of million pounds.

NCC has failed to consider other economically viable alternatives, such as investment in modern glass reuse and recycling as are practiced in mainland Europe. Reuse through glass deposit schemes and recycling would create new jobs and contribute to meeting the country's carbon commitments, preserve and sustain the stocks of silica sand, protect the biodiversity of the countryside and health of the residents of Norfolk.

Environmental objections

I object to the fact that the plan would destroy the local landscape and hundreds of hectares of woodland of Shouldham Warren and farmland of Marham Fen. These areas include designated country wildlife sites and are adjacent to a Nar River SSSI - they are important habitats for birds, animals, and insects. The Warren is home to 64 species of conservation concern, including endangered bats, nightjars and woodlarks. The government has declared a climate emergency, and stated that the UK will have to plant 1.5 billion trees if it is to meet its target of net zero emissions by 2050 - that's 50 million trees every year, so this plan goes against national policies.

I object to the unsustainable use of a finite mineral resource, when the county only recycles a fraction of the glass already in circulation. This allocation of this site places NCC in direct contravention of its own Environmental Policy (https://www.norfolk.gov.uk/what-we-do-and-how-we-work/policy-performance-andpartnerships/policies-and-strategies/natural-environment-policies/environmentalpolicy) - especially the following points:
1. Protect and enhance the county's wildlife and the quality and character of the Norfolk landscape and coast; encouraging the variety of habitats and species to deliver the aims of Biodiversity 2020.
2. Ensure nature contributes to the economic and social health of urban and rural areas in Norfolk for current and future generations.
3. Improve our environmental performance by reducing any actual or potential pollution and comply with all legislative, regulatory or other requirements, within the framework of an environmental management system.
4. Help, inspire and enable our residents to reduce, reuse and recycle much more of their waste so that they keep what's left over to a minimum.

Health Objections

I object to the negative impact on villagers'/visitors' health. According to Public Health Profile 2018, our villages have higher levels of respiratory problems and reduced respiratory function (Chronic Obstructive Pulmonary Disease, Asthma), silica particles will exacerbate these conditions. NCC has done nothing to address concerns about silicosis, which is presently only classified as an 'Industrial Disease'. Silica mine workers experience high-density, shortterm exposure to dust are at risk for acute silicosis, and occupational hazard. Chronic silicosis and other lung conditions, on the other hand, are known to occur with lowerlevel exposures over time and is more likely to be a Public Health threat (https://www.mnmed.org/MMA/media/Minnesota-Medicine-Magazine/CommentaryFeyereisn.pdf, https://www.ewg.org/research/danger-in-the-air, http://www.hazards.org/dust/silica.htm). This industrial categorisation allows companies like Sibelco to dismiss public health concerns. However, there is complete absence of any peer reviewed, independent research on the long-term health effects of lower dosage effects of silica exposure on the general public. It is unacceptable for NCC to locate large, long-term, extraction operations close to inhabited areas and put thousands of people at risk.

Furthermore, the loss of natural spaces has been proven to adversely affect health - mental and physical. Shouldham Warren and Marham Fen are Green Spaces for our community and for thousands of visitors who come here to run, cycle, horse ride and walk. There is no other space of this size in West Norfolk. Loss of this public amenity would have a detrimental effect on the physical and mental health of thousands of people. The social and emotional impact of losing our outdoor area and nature should not be underestimated and is unacceptable.

Historical Objections

Due in part to the heritage impact assessment 2/3 of the SIL 02 site has been 'not allocated' in the M&WLP. However, the remaining third, which forms the overlap with AOS E, is located directly South West of Pentney Priory Gatehouse, and has an unacceptable impact on the historical environment and the setting of this heritage asset, given that the flat fen landscape. There are unobstructed views all the way to Pentney Priory Gatehouse from the elevated position of Marham and from the Spring Lane that will presumably be used to get access the site. Any bunting or screening would be obstructive in its own right. The historical impact assessment proposed a 2Km exclusion Zone to the East of Pentney Priory Gatehouse as sufficient not to impinge on that landscape; the assessment cites that any bunding would impose an unacceptable constraint on that view. However, only 1Km is proposed to the South of this historic building; with a similar flat landscape over the Fen towards Spring Lane this is at odds with protecting the view towards or away from the Gatehouse.

There are other historical monuments including the remnants of an Augustinian Priory, which has not been studied with settlements and artefacts undiscovered and lost forever if quarrying was to take place. The centre of AOS E, Shoudham Warren, is a medieval landscape and an area of high archaeological possibility. The area rises above the landscape and is highly likely to be a medieval farmed network. The remnants of an ancient spring on the hill of the Warren with a Rhododendron avenue being an important area for archaeological study. Within the Warren itself, areas used in WW2 are preserved and a rifle butt within close proximity of the entrance; the historic links to our past evident and in need of protection.

Just to the south of Shouldham Warren and on the northeast extremity of Shouldham village, lie the earthworks of Shouldham. There are also buried remains of part of a gravel road that runs along the south side of Abbey farm. This road is potentially Roman; approx 5m wide. The road east of the adjacent field can be seen from the air. Roman pottery has been found in this area and archaeological remains are possible within the vicinity. There is also thought to be bronze age artefacts and the area should be protected for its historical setting and for archaeological study.

A quarry in AOS E and/or the overlap of SIL 02 the Preferred Area would irreversibly change the local landscape and affect the historical character of the area and the many historical monuments and their setting. This is supported by NCC's own Historic Environment Impact Assessment of AOS E and SIL 02.

Objections based on lack of road infrastructure

It is assumed that Sibelco's pipeline idea is no longer applicable, so any removal of spoil, trees, and eventually sand, will have to be by road. The construction phase and the sand transportation will require the movement of thousands of HGVs on the narrow rural and village lanes that are entirely unsuitable for heavy machinery. No proposals have been made about how the road infrastructure will be developed to address this, but it is clear that the villages would be suffer from the noise and pollution from any heavy machinery and additional traffic, and that other Norfolk roads would be detrimentally affected.

Objections based on lack of lack of restoration plans

A further objection relates to the lack of any restoration plans proposed by NCC. This development would blight the area for decades. There is no promise of any benefit to the community in terms of increased access, no biodiversity gains proposed, no landscape enhancements. Sibelco has a poor track record for restoration in the area, and have failed to ensure safety of sites after extraction - its Bawsey site was the cause of deaths by drowning. The company has not been a 'good neighbour' and has done nothing to engage with the community or alleviate residents' concerns.

Objections based on lack of recycling plans

I object because this plan contravenes national planning policies which demand that recycled materials are taken into account before considering extraction of primary materials. Silica sand is a finite material, and national policies call for their sustainable use and conservation for future generations. NCC has made no attempt within the M&WLP to discuss how improved reuse, including deposit schemes, or improved recycling of glass within Norfolk, nor indeed the rest of the country, would reduce the amount of silica sand (primary material) extracted each year. Improved glass recycling and reuse would ensure the reserves of silica sand are preserved, thereby extending the period of self-sufficiency in glass manufacturing within the UK and comply with national policies on waste management. Without a serious plan to implement glass reuse and recycling the M&WLP is fundamentally flawed.

Sibelco claims to be a leader in recycling in Europe and boasts state-of-the-art recycling technologies, however here in Norfolk show no leadership or business creativity, and just want to keep extract raw materials at the same rate, destroying communities and turning nature into industrial wastelands. It is a wasted opportunity for Sibelco to become a 'neighbour of choice' as they supposedly strive to be (https://www.sibelco.com/wp-content/uploads/code-of-sustainable-conduct.pdf)


Objection based on the fact that the plan inconsistent with national policies and NCC policies, and thus fundamentally unsound

The National Planning Policy Framework (NPPF) dictates that local plans should apply a presumption in favour of sustainable development and deliver economic, social and environmental objectives. The NCC M&WLP fails on all three objectives as discussed above. It also directly contravenes the following paragraphs of the NPPF - and is thus fundamentally unsound.

Section 3. Plan-Making. Paragraph 35 calls for local plans to be "examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound". The first section of this objection states how NCC did not follow procedural requirements of the consultation, specifically failing to consider the responses received in the first stage of consultation in preparing the Preferred Options, and violating their own Statement of Community Involvement Policy.

Plans are considered 'sound' if they are: "b) justified - taking into account reasonable alternatives". NCC has failed to take into account recycling or importing the silica as a reasonable alternative.
"d) consistent with national policy" - see further below.
Section 6. Building a strong, competitive economy. Supporting a prosperous rural economy. Paragraph 83 "b) the development and diversification of agricultural and other land-based rural businesses; c) sustainable rural tourism and leisure developments which respect the character of the countryside". The NCC M&WLP has the opposite objective - destroying productive agricultural land and killing off local tourism.

Section 8. Promoting healthy and safe communities. Paragraph 91 "Planning policies and decisions should aim to achieve healthy, inclusive and safe places which ... c) enable and support healthy lifestyles, especially where this would address identified local health and well-being needs - for example through provision of safe and accessible green infrastructure....layouts that encourage walking and cycling". The NCC M&WLP has the opposite objective - depriving the community of the green infrastructure for walking and cycling.

Open space and recreation. Paragraph 96 "Access to a network of high quality open space and opportunities for sport and physical activity is important for the health and well-being of communities". The NCC M&WLP goes against the communities' need for health and wellbeing.

Paragraph 98 "Planning policies and decisions should protect and enhance public rights of way and access... and adding links to existing rights of way including National Trails". AOS E and SIL02 have over 10 miles of public footpaths and bridleways that will be destroyed if the plan goes ahead. Even if the PROWs are moved, nobody would want to walk around a working quarry, or let their children play anywhere near the area.

Paragraph 100 "Local Green Spaces" - Shouldham Warren and Marham Fen most definitely satisfy the criteria of a Local Green Space:

a) in reasonably close proximity to the community it serves;
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b) demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and c) local in character and is not an extensive tract of land.

The community will be looking to designate this space through local and neighbourhood plans - NCC needs to take heed of the strength of feeling that exists in West Norfolk and beyond at their ill-considered plans.
Section 14. Meeting the challenge of climate change, flooding and coastal change. Paragraph 148 "The planning systems should support the transition to a low carbon future in a changing climate... it should shape places in way that contribute to radical reductions in greenhouse gas emissions... encourage the reuse of existing resources..." - Destroying hundreds of hectares of trees and top soil that are the most effective carbon sinks, whilst having no credible reuse or recycling scheme for glass is unsound based on NPPF.

Section 15. Conserving and enhancing the natural environment. Paragraph 170 "a) protecting and enhancing valued landscapes, sites of biodiversity and soils ... b) recognising the intrinsic character and beauty of the countryside, and the wider benefit from natural capital and ecosystem services, including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland." The whole plan violates this clause entirely.

Paragraph 180 "Planning policies and decisions should also ensure that new development is appropriate for its location taking into account cumulative effects of pollution on health, living conditions and the natural environment... in doing so, they should b) identify and protect tranquil areas which have remained relatively undisturbed by noise and prized for their recreational amenity value for this reason". There is no comparable tranquil recreational amenity of this size in West Norfolk.

Section 17. Facilitating the sustainable use of minerals. Paragraph 204 Planning policies should:

"b) so far as practicable, take account of the contribution that substitute or secondary and recycled materials and minerals waste would make to the supply of materials, before considering extraction of primary materials, whilst aiming to source minerals supplies indigenously". This plans shows abject failure by NCC to provide for any recycling plans and consideration for alternatives.
"f) set out criteria or requirements to ensure that permitted and proposed operations do not have unacceptable adverse impacts on the natural and historic environment or human health, taking into account the cumulative effects of multiple impacts from individual sites and/or a number of sites in a locality." There is no definition of 'unacceptable adverse impacts' - from the perspective of the local residents and taxpayers - the impacts are unacceptable, especially taking into account the cumulative effects of living next to an active airbase.

"h) ensure that worked land is reclaimed at the earliest opportunity, taking account of aviation safety, and that high quality restoration and aftercare of mineral sites takes place". The NCC M&WLP failed to take out the entirely of SIL 02 despite the strong MOD objection based on aviation safety. NCC certainly has no high quality, or any in fact, restoration plans proposed.

Paragraph 205 "When determining planning applications, great weight should be given to the benefits of mineral extraction, including to the economy". See above for evidence that there is no benefit to the economy, in fact there is detriment to existing industries that provide local jobs.

Paragraph 207 "Minerals planning authorities should plan for a steady and adequate supply of aggregates by: a) preparing an annual Local Aggregate Assessment, either individually or jointly, to forecast future demand, based on a rolling average of 10 years' sales data and other relevant local information, and an assessment of all supply options (including marine dredged, secondary and recycled sources)". There is no provision for recycled sources in the plan or in the assessment of 'needs'.
NCC M&WLP plan is unsound and entirely inconsistent with national planning policies.

Furthermore, the M&WLP contravenes a huge number NCC's own policies, including its Vision to 2036, Sustainability Appraisal Report (SA1, SA3, SA4, SA5, SA6, SA8, SA9, SA11 and SA13), Waste Management Strategic Objectives (WSO1, WSO 2, WSO 4, WSO 6, WSO8), Minerals Strategic Objectives (MSO2, MSO3, MSO6, MSO7, MSO8, MSO9, MSO10).

In conclusion, the M&WLP proposed by NCC is ill-conceived, fails to comply with national and local policies, provides no economic, social or environmental benefit, and is fundamentally unsound. NCC has conducted an appalling consultation process that has lost the trust of its constituents. NCC should be reminded that their responsibility is the provision of public services for both current and future generations of residents and taxpayers, safeguarding national interests and the environment - not promoting the harmful short-term business interests of one private overseas company.

Objection to AOS E (Land to the north of Shouldham) and SIL 02 (land at Shouldham and Marham)

I object to AOS E and SIL 02, including Shouldham Warren the overlap between these two sites in the Norfolk Minerals and Waste Local Plan (M&WLP). I strongly object to the fact that Norfolk County Council (NCC) continues to employ a public consultation process without scrutinising its efficiency and that is clearly not fit for purpose - a fact exacerbated by a steady stream of false or misleading information both directly from NCC, such as "SIL 02 has been designated as unsuitable" (when in fact a third of that "preferred area" has simply been re-classified as AOS E) or via NCC and Borough Councillors who have advised local residents with messages such as: "don't worry about the consultation phase, you want to keep your powder dry for planning permission phase", "no more than 3 people can object from any single address," "weighting is given to those objections from residents living within 250m of the proposed sites" Given the strong criticisms already levelled at NCC regarding this current consultation, the sheer breadth of misinformation now goes beyond the pale of honest mistakes or poor communication and starts to suggest a coordinated effort to dissuade members of the public from participating in this process.

All four "key principles" set out in NCC's adopted Statement of Community Involvement have been violated:

1) Accountability (taking citizens' views into account) - concerns raised in the 460 responses to the first consultation in August 2018 have been ignored. Residents raised concerns about impact on health, wellbeing, environment, biodiversity, their rights to peaceful enjoyment of their properties, no benefit to local communities, failure to improve recycling of glass already in circulation, lack of restoration plans, and failure to conduct an effective and transparent process by NCC. The August 2019 Mineral Plan states that the "responses received have been considered in the production of the second public consultation document, the Preferred Options", however the 'Preferred Options' only reflected the concerns of the MOD and Historical Environment Services. NONE of the concerns raised by residents were taken into account or addressed.

2) Accessibility (consultation is clear and genuinely accessible) - an accessible consultation should not be written in incomprehensible language and should not require 1000s of hours of effort to understand and participate. It should not rely on concerned members of the public informing the wider community or rallying various consultee groups to respond. It should not require the public to defend and ensure existing government policies are complied with. It should not require an MP's involvement to ensure that public concern is registered and addressed.

3) Inclusivity (groups of the community are not excluded) - NCC deemed it reasonable to only send 10 letters to residents within an arbitrary 250m boundary of the site, despite the proposed silica mine being the largest in the country and affecting thousands of people, including disadvantaged and minorities, and the thousands of people who come to the Warren to enjoy the little nature that is left in West Norfolk.

4) Efficiency (ensuring methodology delivers results) - NCC continues to use the same ineffective methodology for consultation: in the 2015 consultation, AOS E received 7
responses; in the 2018 consultation, due to the efforts of CATSS local campaign group, AOS E and SIL02 received 460 responses. Other areas resulted in the same low level response (SIL01 - 8, AOS F - 3, AOS I - 4, AOS J - 6), because NCC continues to use ineffective methods of engagement with the residents of Norfolk.

I will continue to outline the reasons for my objections, however it is clear that trust in the process, NCC and Borough Councils is gone, as NCC only does the bare minimum in order to meet what it perceives as its legal obligations, and there is no interest in ensuring genuine, meaningful public participation, nor any evidence of taking the feedback and public concerns into account.

Economic objections

I object to the proposal as it is detrimental to the local economy and financially unsound. There are no jobs created, the only economic benefit would be to the privately-owned Belgian company, Sibelco. The silica sand is not used in Norfolk, it entirely exported elsewhere, including overseas. Much of the SIL 02 overlap is high grade agricultural farmland, used for growing sugar beets, which does contribute to job creation and income in the local area. It is unsound to be destroying farmland to dig up minerals for export on the eve of Brexit, when the aim of national policies is to ensure food security. Parts of AOS E is a managed wood plantation, again creating jobs and a supporting low carbon biomass industry.

Loss of a large green space used by thousands of people in West Norfolk will have a real impact on human physical and mental health, putting more financial pressure on the already overstretched NHS.

Loss of such a large carbon sink, hundreds of hectares of woodland and topsoil, at a time when the country is already struggling to meet its legally binding carbon reduction commitments means more expensive investments in carbon reductions elsewhere.

This proposal goes completely against the Local Development Plan for West Norfolk (https://www.west-norfolk.gov.uk/homepage/257/local_development_plan), which has identified Marham as a growth area, and envisages a place where "people want to be part of the success story that is West Norfolk, drawn her to live, work, invest and visit... to take advantage of quality of life... supporting strong, vibrant, healthy communities... with a access to local services that support the health, social and cultural well-being of local communities... with new development located and designed to be better adapted to climate change and risk of flooding... protecting and enhancing our justifiable famous natural and historic environment and ensuring growth of the borough makes sustainability a central principle of our vision". Nobody wants to live next to a silica mine, and this proposal has already negatively affected the local area economically through dampening the housing market.

Shouldham Warren and Nar Valley Way running along a Nar River SSSI are a major tourism and recreational destination, used by thousands of walkers, cyclists, horse riders and runners - contributing income to local tourism infrastructure and facilities. Pentney Priory Gatehouse, currently a wedding venue, overlooks the overlap are of AOS E and SIL 02 - this is an example of a specific business that would become non-viable if the view they currently experience over open land is turned into a working quarry.

MOD has already objected to the proposal given the risk of birdstrike to the aircraft at RAF Marham, the main operating base for the for the F35 Lightning II, an aircraft that costs £100+ million. The major damage to the singe engine of this aircraft, let alone loss of even one aircraft due to damage
from a bird-strike would be financially intolerable and a major blow to the defence of the UK and our wider interests. The other costs of a crash landing of the aircraft to cover emergency services and long-term care and support to the affected people on the ground, are incalculable but would run into the tens if not hundreds of million pounds.

NCC has failed to consider other economically viable alternatives, such as investment in modern glass reuse and recycling as are practiced in mainland Europe. Reuse through glass deposit schemes and recycling would create new jobs and contribute to meeting the country's carbon commitments, preserve and sustain the stocks of silica sand, protect the biodiversity of the countryside and health of the residents of Norfolk.

Environmental objections

I object to the fact that the plan would destroy the local landscape and hundreds of hectares of woodland of Shouldham Warren and farmland of Marham Fen. These areas include designated country wildlife sites and are adjacent to a Nar River SSSI - they are important habitats for birds, animals, and insects. The Warren is home to 64 species of conservation concern, including endangered bats, nightjars and woodlarks. The government has declared a climate emergency, and stated that the UK will have to plant 1.5 billion trees if it is to meet its target of net zero emissions by 2050 - that's 50 million trees every year, so this plan goes against national policies.

I object to the unsustainable use of a finite mineral resource, when the county only recycles a fraction of the glass already in circulation. This allocation of this site places NCC in direct contravention of its own Environmental Policy (https://www.norfolk.gov.uk/what-we-do-andhow-we-work/policy-performance-and-partnerships/policies-and-strategies/naturalenvironment-policies/environmental-policy) - especially the following points:
1. Protect and enhance the county's wildlife and the quality and character of the Norfolk landscape and coast; encouraging the variety of habitats and species to deliver the aims of Biodiversity 2020.
2. Ensure nature contributes to the economic and social health of urban and rural areas in Norfolk for current and future generations.
3. Improve our environmental performance by reducing any actual or potential pollution and comply with all legislative, regulatory or other requirements, within the framework of an environmental management system.
4. Help, inspire and enable our residents to reduce, reuse and recycle much more of their waste so that they keep what's left over to a minimum.

Health Objections

I object to the negative impact on villagers'/visitors' health. According to Public Health Profile 2018, our villages have higher levels of respiratory problems and reduced respiratory function (Chronic Obstructive Pulmonary Disease, Asthma), silica particles will exacerbate these conditions. NCC has done nothing to address concerns about silicosis, which is presently only classified as an 'Industrial Disease'. Silica mine workers experience high-density, short-term exposure to dust are at risk for acute silicosis, and occupational hazard. Chronic silicosis and other lung
conditions, on the other hand, are known to occur with lower-level exposures over time and is more likely to be a Public Health threat (https://www.mnmed.org/MMA/media/MinnesotaMedicine-Magazine/Commentary-Feyereisn.pdf, https://www.ewg.org/research/danger-inthe-air, http://www.hazards.org/dust/silica.htm). This industrial categorisation allows companies like Sibelco to dismiss public health concerns. However, there is complete absence of any peer reviewed, independent research on the long-term health effects of lower dosage effects of silica exposure on the general public. It is unacceptable for NCC to locate large, long-term, extraction operations close to inhabited areas and put thousands of people at risk.

Furthermore, the loss of natural spaces has been proven to adversely affect health - mental and physical. Shouldham Warren and Marham Fen are Green Spaces for our community and for thousands of visitors who come here to run, cycle, horse ride and walk. There is no other space of this size in West Norfolk. Loss of this public amenity would have a detrimental effect on the physical and mental health of thousands of people. The social and emotional impact of losing our outdoor area and nature should not be underestimated and is unacceptable.

Historical Objections

Due in part to the heritage impact assessment 2/3 of the SIL 02 site has been 'not allocated' in the M&WLP. However, the remaining third, which forms the overlap with AOS E, is located directly South West of Pentney Priory Gatehouse, and has an unacceptable impact on the historical environment and the setting of this heritage asset, given that the flat fen landscape. There are unobstructed views all the way to Pentney Priory Gatehouse from the elevated position of Marham and from the Spring Lane that will presumably be used to get access the site. Any bunting or screening would be obstructive in its own right. The historical impact assessment proposed a 2Km exclusion Zone to the East of Pentney Priory Gatehouse as sufficient not to impinge on that landscape; the assessment cites that any bunding would impose an unacceptable constraint on that view. However, only 1Km is proposed to the South of this historic building; with a similar flat landscape over the Fen towards Spring Lane this is at odds with protecting the view towards or away from the Gatehouse.

There are other historical monuments including the remnants of an Augustinian Priory, which has not been studied with settlements and artefacts undiscovered and lost forever if quarrying was to take place. The centre of AOS E, Shoudham Warren, is a medieval landscape and an area of high archaeological possibility. The area rises above the landscape and is highly likely to be a medieval farmed network. The remnants of an ancient spring on the hill of the Warren with a Rhododendron avenue being an important area for archaeological study. Within the Warren itself, areas used in WW2 are preserved and a rifle butt within close proximity of the entrance; the historic links to our past evident and in need of protection.

Just to the south of Shouldham Warren and on the northeast extremity of Shouldham village, lie the earthworks of Shouldham. There are also buried remains of part of a gravel road that runs along the south side of Abbey farm. This road is potentially Roman; approx 5m wide. The road east of the adjacent field can be seen from the air. Roman pottery has been found in this area and archaeological remains are possible within the vicinity. There is also thought to be bronze age artefacts and the area should be protected for its historical setting and for archaeological study.

A quarry in AOS E and/or the overlap of SIL 02 the Preferred Area would irreversibly change the local landscape and affect the historical character of the area and the many historical
monuments and their setting. This is supported by NCC's own Historic Environment Impact Assessment of AOS E and SIL 02.

Objections based on lack of road infrastructure

It is assumed that Sibelco's pipeline idea is no longer applicable, so any removal of spoil, trees, and eventually sand, will have to be by road. The construction phase and the sand transportation will require the movement of thousands of HGVs on the narrow rural and village lanes that are entirely unsuitable for heavy machinery. No proposals have been made about how the road infrastructure will be developed to address this, but it is clear that the villages would be suffer from the noise and pollution from any heavy machinery and additional traffic, and that other Norfolk roads would be detrimentally affected.

Objections based on lack of lack of restoration plans

A further objection relates to the lack of any restoration plans proposed by NCC. This development would blight the area for decades. There is no promise of any benefit to the community in terms of increased access, no biodiversity gains proposed, no landscape enhancements. Sibelco has a poor track record for restoration in the area, and have failed to ensure safety of sites after extraction - its Bawsey site was the cause of deaths by drowning. The company has not been a 'good neighbour' and has done nothing to engage with the community or alleviate residents' concerns. Objections based on lack of recycling plans

I object because this plan contravenes national planning policies which demand that recycled materials are taken into account before considering extraction of primary materials. Silica sand is a finite material, and national policies call for their sustainable use and conservation for future generations. NCC has made no attempt within the M&WLP to discuss how improved reuse, including deposit schemes, or improved recycling of glass within Norfolk, nor indeed the rest of the country, would reduce the amount of silica sand (primary material) extracted each year. Improved glass recycling and reuse would ensure the reserves of silica sand are preserved, thereby extending the period of self-sufficiency in glass manufacturing within the UK and comply with national policies on waste management. Without a serious plan to implement glass reuse and recycling the M&WLP is fundamentally flawed.

Sibelco claims to be a leader in recycling in Europe and boasts state-of-the-art recycling technologies, however here in Norfolk show no leadership or business creativity, and just want to keep extract raw materials at the same rate, destroying communities and turning nature into industrial wastelands. It is a wasted opportunity for Sibelco to become a 'neighbour of choice' as they supposedly strive to be (https://www.sibelco.com/wp-content/uploads/codeof-sustainable-conduct.pdf)











Objection based on the fact that the plan inconsistent with national policies and NCC policies, and thus fundamentally unsound

The National Planning Policy Framework (NPPF) dictates that local plans should apply a presumption in favour of sustainable development and deliver economic, social and environmental objectives. The NCC M&WLP fails on all three objectives as discussed above. It also directly contravenes the following paragraphs of the NPPF - and is thus fundamentally unsound.

Section 3. Plan-Making. Paragraph 35 calls for local plans to be "examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound". The first section of this objection states how NCC did not follow procedural requirements of the consultation, specifically failing to consider the responses received in the first stage of consultation in preparing the Preferred Options, and violating their own Statement of Community Involvement Policy.

Plans are considered 'sound' if they are: "b) justified - taking into account reasonable alternatives". NCC has failed to take into account recycling or importing the silica as a reasonable alternative. "d) consistent with national policy" - see further below. Section 6. Building a strong, competitive economy. Supporting a prosperous rural economy. Paragraph 83 "b) the development and diversification of agricultural and other land-based rural businesses; c) sustainable rural tourism and leisure developments which respect the character of the countryside". The NCC M&WLP has the opposite objective - destroying productive agricultural land and killing off local tourism.

Section 8. Promoting healthy and safe communities. Paragraph 91 "Planning policies and decisions should aim to achieve healthy, inclusive and safe places which ... c) enable and support healthy lifestyles, especially where this would address identified local health and well-being needs - for example through provision of safe and accessible green infrastructure....layouts that encourage walking and cycling". The NCC M&WLP has the opposite objective - depriving the community of the green infrastructure for walking and cycling.

Open space and recreation. Paragraph 96 "Access to a network of high quality open space and opportunities for sport and physical activity is important for the health and well-being of communities". The NCC M&WLP goes against the communities' need for health and well-being.

Paragraph 98 "Planning policies and decisions should protect and enhance public rights of way and access... and adding links to existing rights of way including National Trails". AOS E and SIL02 have over 10 miles of public footpaths and bridleways that will be destroyed if the plan goes ahead. Even if the PROWs are moved, nobody would want to walk around a working quarry, or let their children play anywhere near the area.

Paragraph 100 "Local Green Spaces" - Shouldham Warren and Marham Fen most definitely satisfy the criteria of a Local Green Space:

a) in reasonably close proximity to the community it serves;
b) demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and c) local in character and is not an extensive tract of land.

The community will be looking to designate this space through local and neighbourhood plans - NCC needs to take heed of the strength of feeling that exists in West Norfolk and beyond at their illconsidered plans. Section 14. Meeting the challenge of climate change, flooding and coastal change. Paragraph 148 "The planning systems should support the transition to a low carbon future in a changing climate... it should shape places in way that contribute to radical reductions in greenhouse gas emissions... encourage the reuse of existing resources..." - Destroying hundreds of hectares of trees and top soil that are the most effective carbon sinks, whilst having no credible reuse or recycling scheme for glass is unsound based on NPPF.

Section 15. Conserving and enhancing the natural environment. Paragraph 170 "a) protecting and enhancing valued landscapes, sites of biodiversity and soils ... b) recognising the intrinsic character and beauty of the countryside, and the wider benefit from natural capital and ecosystem services, including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland." The whole plan violates this clause entirely.

Paragraph 180 "Planning policies and decisions should also ensure that new development is appropriate for its location taking into account cumulative effects of pollution on health, living conditions and the natural environment... in doing so, they should b) identify and protect tranquil areas which have remained relatively undisturbed by noise and prized for their recreational amenity value for this reason". There is no comparable tranquil recreational amenity of this size in West Norfolk.

Section 17. Facilitating the sustainable use of minerals. Paragraph 204 Planning policies should:

"b) so far as practicable, take account of the contribution that substitute or secondary and recycled materials and minerals waste would make to the supply of materials, before considering extraction of primary materials, whilst aiming to source minerals supplies indigenously". This plans shows abject failure by NCC to provide for any recycling plans and consideration for alternatives. "f) set out criteria or requirements to ensure that permitted and proposed operations do not have unacceptable adverse impacts on the natural and historic environment or human health, taking into account the cumulative effects of multiple impacts from individual sites and/or a number of sites in a locality." There is no definition of 'unacceptable adverse impacts' - from the perspective of the local residents and taxpayers - the impacts are unacceptable, especially taking into account the cumulative effects of living next to an active airbase.

"h) ensure that worked land is reclaimed at the earliest opportunity, taking account of aviation safety, and that high quality restoration and aftercare of mineral sites takes place". The NCC M&WLP failed to take out the entirely of SIL 02 despite the strong MOD objection based on aviation safety. NCC certainly has no high quality, or any in fact, restoration plans proposed. Paragraph 205 "When determining planning applications, great weight should be given to the benefits of mineral extraction, including to the economy". See above for evidence that there is no benefit to the economy, in fact there is detriment to existing industries that provide local jobs.

Paragraph 207 "Minerals planning authorities should plan for a steady and adequate supply of aggregates by: a) preparing an annual Local Aggregate Assessment, either individually or jointly, to forecast future demand, based on a rolling average of 10 years' sales data and other relevant local information, and an assessment of all supply options (including marine dredged, secondary and recycled sources)". There is no provision for recycled sources in the plan or in the assessment of 'needs'.

NCC M&WLP plan is unsound and entirely inconsistent with national planning policies.

Furthermore, the M&WLP contravenes a huge number NCC's own policies, including its Vision to 2036, Sustainability Appraisal Report (SA1, SA3, SA4, SA5, SA6, SA8, SA9, SA11 and SA13), Waste Management Strategic Objectives (WSO1, WSO 2, WSO 4, WSO 6, WSO8), Minerals Strategic Objectives (MSO2, MSO3, MSO6, MSO7, MSO8, MSO9, MSO10).


In conclusion, it is abundantly clear that NCC is determined to ram these proposals through, despite the overwhelming objections of the public, general and statutory consultees and furthermore, that NCC views the public consultation as nothing more than an inconvenience rather than an active and productive process. This is evidenced by the sheer lack of resource they have assigned to its successful completion, the minimum effort undertaken in order to comply with the legal requirement and absolutely no analysis as to whether the process has been successful (either now or in the past, and following the debacle of the King's Lynn Incinerator Project that is nothing short of negligent). Yet despite all these factors, and even though NCC even stacks the cards against the public by restricting what it considers a 'valid objection', the public has spoken in unprecedented numbers and their voice has been supported by those of the general and statutory consultees.

This process has given the public nothing more than the opportunity to research national and regional policies on everything ranging from your own Statement of Community Involvement (with which you do not comply), to those policies covering economics, environmental protection and safeguarding, health and wellbeing, local history, road infrastructure, restoration and enrichment, recycling and even the NPPF - policies NCC should be enforcing even before proposal like these come to the public venue.

There is not a single area, where this proposal and the many like it, complies or meets with the requirements already contained within your policies nor does it demonstrate any value to the local community whatsoever and the fact that NCC has forwarded these proposals knowing that, is shameful. NCC are public servants, you have the policies and mandate to protect our communal best interests, when the national requirement is not known (as it is not in this case), when the demand, extraction and final usage of this finite resource is obscured by private interest, what possible justification could NCC have for funding this process at public expense when the outcome is clear Norfolk will be left poorer, less beautiful, less healthy, historically impoverished, and nothing more than a spattering of lonely communities no longer dotted across green space and a patchwork of fields, and wooded areas, but isolated by gaping chasms and toxic ponds shrouded in security fences and abandoned by Sibelco as they simply move their operations to the next area in a process facilitated by NCC.

I join the many voices that object.