AOS E - land to the north of Shouldham

We are Tottenhill residents of 32 years standing.
We wish to register out joint objections to the proposed potential silica extraction site mostly within Tottenhill civil parish as shown on attached map. Our main reason for objection is the very close proximity of this site to Totten hill village. Silica extraction on this site will inevitably lead to high levels of noise, dust etc. to the detriment of residents of Tottenhill village.
Additionally extraction from this site will require the creation of a new access onto the A134 at a point close to Wormegay primary school with all the additional stopping and turning of traffic that this will entail. The road network to the immediate west of the proposed site, comprising entirely of single track roads, is wholly inadequate to cater for any additional heavy traffic.
For these reasons we wish to register our objections to mineral extraction from this site.

Objections to MIN 74, 76, 77 and 206 in Tottenhill and AOS I and AOS J
Objection to AOS E - land between Marham and Shouldham and includes Shouldham Warren

I object to AOS E, including Shouldham Warren and the overlap with formerly SIL 02, in the Norfolk Minerals and Waste Local Plan. I strongly object to the fact that Norfolk County Council has deliberately misled residents by announcing the removal of SIL 02 when in reality a third of it is now/still included in AOS E.
As a member of the community, I echoed the concerns held by the Ministry of Defence when they objected to these proposals, due to the fact that the plan of a wet working and restoration in close proximity to RAF Marham, well within the statutory 13 kms limit, will increase the risk of "bird strikes" or worst-case scenario, end in an aircraft crash and potential loss of life. The economic cost of such a mishap would be greater than £100M just to replace an F35 Lightning II; add to that the costs for the emergency services and for the immediate and subsequent treatments through the NHS for the physical and mental injuries caused, and the financial costs become an unaffordable risk.
Permanent loss of agricultural land will impact rural Norfolk, its farming jobs, jobs of local employees i.e. British Sugar, including the increased need for home grown food, due to the impact of Brexit.
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. Loss of natural spaces has been proven to adversely affect health, mental and physical. This fenland and forest (Shouldham Warren) is our community's public open space, our gym and our sanctuary, hundreds of people use it daily for physical recreation and social wellbeing interactions.
I object to the fact that the plan would ruin the Landscape, Shouldham Warren, the Countryside, including habitats for birds, animals, and insects. The Warren is home to 64 species of conservation concern, including endangered bats, nightjars and woodlarks. We need nature and trees now more than ever to combat pollution and climate change.
I object to the unsustainable use of a finite mineral resource, when the county only recycles a fraction of the glass already in circulation. There are national government policies and guidance including DEFRA and the Dept for Business Energy & Industrial Strategy that are clearly being ignored in order to allow a privately-owned Belgian company to profit from the devastation of our community asset, landscape and environment.
I further object to the worrying possibility of damage to our Public Water. It is very concerning that if quarrying was allowed to take place, whether through wet or dry working, the water supply could be affected, as the whole area of AOS E has very productive to moderately productive aquifers.
A further objection relates to the lack of restoration plans. Any restoration would take in excess of 30 years, until then the community would suffer from a devastated industrial landscape, increased flow of heavy articulated lorries, preventing any appreciation of its landscape and countryside. 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.
Lastly, I object to the fact that there would be no benefit to the local community or economy if this proposal goes through. What is clear is that a number of local communities will bear the brunt of a hugely disruptive and harmful industrial process; that a very popular public amenity enjoyed by a much larger section of the population will be permanently lost; and the only beneficiaries of this development will be a few landowners, Norfolk County Council, but principally the private owners of the Belgian company Sibelco.
Given that County Councils are responsible for the provision of public services for taxpayers and community wellbeing, and not the promotion of harmful and irresponsible businesses that present no local benefit, but with multiple risks, dictates that Norfolk County Council should put public interest before private profit.

* Tottenhill surrounded by quarries
* No of HGV/Traffic congestion
* Pollution
* Too near Wormegay school
Accident black spot A134/A10 roundabout and Wormegay school
Please record this as my objection

Proposed Site Min74
OBJECT
Reasons for objecting
M74.L
It states adverse dust impacts are uncommon beyond 250m the nearest property ls within 77m. The impact on the residents will be dust/noise/pollution from machinery. M74.16 States Sand and gravel will be transported by existing conveyor This means transporting materials to the conveyor along the back of all the Properties causing more disturbance pollution noise and dust. The foundations to these properties are minimal and close to the surface, vulnerable to subsidence, due to vibration and the water table dropping which is more noticeable in all of ' Tottenhill This last few years with all the quarrying going on in the area.
A quarry on this site would have an unacceptable impact to the area, the Tottenhill Row residents and residents along the A10 overlooking the site. Bunding would be intrusive to this conservation area.
Traffic going unto the roundabout A10 and A134 plus the private companies Collecting sand and gravel, 80 passes a day to and from safari park all coursing more congestion to these already over loaded roads impacting on the residents and all in the surrounding area who use these roads. Tottenhill Row is a conservation area an area of natural beauty this site would be intrusive. Quarrying in Tottenhill has been going on for a 100years or more the first planning application in the 1990s, 60 years disturbance and disruption in the area.
Taking Arable land out of the food chain which is needed more than ever.
Surly NCC you can see why Tottenhill and its residents have had enough and stop this being put Forward.

PROPOSED Site Min77

OBJECT
Reasons for objection
There are broad leave trees in this wood over 100+years old Cutting this wood down would devastate the area killing or moving all wildlife and habitat. Completely changing the landscape, Ecological impact would be great.
When Min76 came up for planning we asked if the conveyor belt could be moved To the north side of Watlington Road to be further away frbm the residents at Tottenhill Row the answer was no, one of the main reasons it would involve cutting down trees which were mainly saplings, now it is convenient to cut down a mature wood. ln this case the environment and conservation has conveniently been forgot.
We need to keep and maintain all the woodlands to help check pollution. Helping the small birds which are disappearing in the area, and the wildlife.
MIN77.16 It states sand and gravel will be transported to the existing processing plant by conveyor, the conveyor has been moved to Min76 the culvert under the road to the processing plant has been granted planning permission for-trafficking visitors to the Safari Park. Will this mean traffic to the Safari Park will go by road causing more congestion? 40 vehicles a day = 80 passes on the roads a day.
There is no mention how the site will be cleared and managed when cutting and clearing the trees, how hardwood and mature trees will be transported off site Which road and junction will be used. This means very large vehicles using the roads at the same time as vehicles from the plant site and safari park causing congestion on the roads.
M77.19 States the site is proposed to be restored to nature conservation comprising a mixture of ponds. wet woodland, and wet grass land etc., Combined with the vast area of open water we already have in Tottenhill we will lose even more water to open water evaporation, It is stressed we should save all the water we can, in the last few years with all the quarrying the whole area is drying out dropping the water table. The past planning applications for MIN 75 76 the PC has asked for an open water evaporation report. Not seen one to date. Tottenhill is being surrounded with quarries which are being left open and causing loss of water through evaporation and are intrusive to the landscape. lf this site is put forward Tottenhill has another Minimum of thirteen years of traffic/pollution/noiseland disruption on top of the 60 years we have already had, we have given our fair share of aggregates to Norfolk and surrounding counties. Tottenhíll and the residence say Enough ls Enough.


PROPOSED MIN 206
Object
Reasons for objecting
The nearest residents are well within the impact area of dust/ noise
Pollution and vibration, Running alongside Watlington road and the A10
This could course subsidence to properties and the A10
There will be a visual impact from the A10 and the Watlington road.
Whichever way you go from Tottenhill to Watl¡ngton all you can see is intrusive and unsightly earth bunds, screening this site will add even more.
M206.8 There are public footpaths shown on the map going from the 410 through to Tottenhill Row on this site. Have the residents lost this right of way. Planning permission has been granted on the site for car parking to the safari park, where will this parking be located?
M206.12 it states CWS 385 Tottenh¡ll Village Green it is an area of moderately species rich neutral grassland containing three small ponds which seasonally dry. These ponds very really dried up until the last Two to three years of intensive quarrying coursing the water table to drop and the whole area drying out. This site will put more traffic on the roads more pollution/noise dust. Affecting the water table even more, coursing the spring at Tottenhill Row conservation area to stop running and feeding the spring pit and destroy all the wildlife/habitat and plant life.
Tottenhill is virtually surrounded in old and recent quarries left open and not landscaped as planning permission granted Over 60 years of quarrying, Tottenhill has had enough.

ln the EXTRACTS NORFOLK MINERALS LOCAL PLAN policies.
It shows 3 and 4 reasons for each one of the sites Min74 77 and 206 that NCC should reject putting these sites forward for review

ASO J and A05L Land to the east of Tottenhill.

OBJECT
Reasons for objection.
AOSJ J.1 Tottenhill and Wormegay school is close to this site, the prevailing wind blows directly onto the school this could course the children to have breathing and lung problems in the future through dust and pollution blowing from the site onto the school. The noise from machinery coursing distraction in the classroom. This site would have a visual impact on the area from the site access along the A134 and from A134 to Tottenhill. There would be a visual impact along Deals Lane overlooking the site.
J.2 State access from the site could be via the southern track unto A134 subject to junction improvements, a dedicated access could be created to the A134 or the A10 with junction improvements. lf the junction unto the A134 is used it will course traffic to back up either side of the junction coursing further congestion and accidents, this road is used by heavy lorry's going to and from the Sugar Beet Factory. Going via the A134 it will be taking traffic by the school junction coursing more risk of accidents happening involving parents and children
Site traffic would go to the A134 and A10 roundabout, at the same time there would be site traffic from the quarry plant and safari park entering the Roundabout coursing more congestion and frustration to motorist.
AOSI Site traffic going via the junction onto the A10 at Thieves Bridge turning right and going through the accident black spot at the junction to Tottenhill and Watlington and onto the roundabout joining the A134 coursing the same situation as stated above.
A footpath going from Deals Lane and up to the A134 to Tottenhill church, this footpath is running through the south side of the proposed site and will be taken if put forward.
Cutting down a complete fir wood losing all the wild life and habitat, moving all the birdlife
Closer to Marham aerodrome This is a 100year old wood.
With these two sites small hamlet of Tottenhill will be surrounded with quarries.

Objection to AOS E - land between Marham and Shouldham and includes Shouldham Warren

I object to AOS Ë, including Shouldham Wanen and the overlap with formerly SIL 02, in the Norfolk Minerals and Waste Local Plan, I strongly object to the fact that Norfolk County Council has deliberately misled residents by announcing the removal of SIL 02 when in reality a third of it is now/still included in AOS E.
As a member of the community, I echoed the concerns held by the Ministry of Defence when they objected to these proposals, due to the fact that the plan of a wet working and restoration in close proximity to RAF Marham, well within the statutory 13 kms limit, will increase the risk of 'bird strikes' or worst case scenario, end in an aircraft crash and potential loss of life. The economic cost of such a mishap would be greater than £100M just to replace an F35 Lightning ll; add to that the costs for the emergency services and for the immediate and subsequent treatments through the NHS fur the physical and mental injuries caused, and the financial costs become an unaffordable risk.
Permanent loss of agricultural land will impact rural Norfolk, its farming jobs, jobs of local employees i.e. British Sugar, including the increased need for home grown food, due to the impact of Brexit.
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. Loss of natural spaces has been proven to adversely affect health, mental and physical. This fenland and forest (Shouldham Warren) is our community's public open space, our gym and our sanctuary, hundreds of people use it daily for physical recreation and social wellbeing interactions.
I object to the fact that the plan would ruin the Landscape, Shouldham Warren, the Countryside, including habitats for birds, animals, and insects. The Warren is home to 64 species of conservation concern, including endangered bats, nightjars and woodlarks. We need nature and trees now more than ever to combat pollution and climate change.
I object to the unsustainable use of a finite mineral resource, when the county only recycles a fraction of the glass already in circulation, There are national governmental policies and guidance including DEFRA and the Dept for Business Energy & industrial Strategy that are clearly being ignored in order to allow a privately-owned Belgian company to profit from the devastation of our community asset, landscape and environment.
f further object to the worrying possibility of damage to our Public Water. It is very concerning that if quarrying was allowed to take place, whether through wet or dry working, the water supply could be affected, as the whole area of AOS E has very productive to moderately productive aquifers.
A further objection relates to the lack of restoration plans. Any restoration would take in excess of 30 years, until then the community would suffer from a devastated industrial landscape, increased flow of heavy articulated lories, preventing any appreciation of its landscape and countryside. 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.
Lastly I object to the fact that there would be no benefit to the local community economy if this proposal goes through. What is clear is that a number of local communities will bear the brunt of a hugely disruptive and harmful industrial process; that a very popular public amenity enjoyed by a much larger section of the population will be permanently lost; and the only beneficiaries of this development will be a few landowners, Norfolk County Council, but principally the private owners of the Belgian company Sibelco.
Given that County Councils are responsible for the provision of public services for taxpayers and community wellbeing, and not the promotion of harmful and irresponsible businesses that present no local benefit, but with multiple risks, dictates that Norfolk County Council should put public interest before private profit
Please record this as my objection

Objections to MIN 74, 76, 77 and 206 in Tottenhill and AOS I and AOS J

* Tottenhill surrounded by quarries
*No of HGV / traffic congestion
* Pollution
*Too near Wormegay school
Accident black spot
A134 / A10 roundabout and Wormegay School

Please enter this letter as my economic objection to quarrying taking place in the areas of Area of Search (AOS) E and SIL 02 in the Preferred Consultation of the Mineral and Waste Local Plan (M&WLP) Review.
The very first paragraph of the Introduction to the M&WLP on pg 7 states, "The provision of a steady and adequate supply of minerals and the management of waste constitute essential infrastructure to support the economic development of the county". Since all silica sand quarried by Sibelco (the monopoly mineral operator for silica sand in Norfolk) is exported out of Norfolk, it cannot be 'supporting the economic development of the county'. Norfolk receives no benefit for allowing the countryside to be ripped apart and then the mineral only used outside of the county. Quarrying for silica sand or granting future planning applications to further quarry for silica sand in Norfolk cannot be argued, by NCC or Sibelco, to be supporting Norfolk's economic development. The current Sibeclo Leziate plant employs less than 50 people and any new quarry in AOS E or SIL 02 would only provide jobs for a couple of people, that is hardly supporting the economic development of Norfolk.
I also object to the fact there are no checks and balances of the amount of silica sand being quarried and where it goes to, other than NCC requesting Sibelco provide their annual production information on figures that Sibelco supplied to NCC as their requirement each year (a statement from the Cabinet member responsible for the M&WLP in an email reply of 25 June 2019 to a question I posed on this matter). Or to put it another way, Sibelco tell NCC what they want and that is then interpreted by NCC as the amount required for a 'steady and adequate supply' without any further independent investigation; those figures are then confirmed each year by Sibelco sending their production figures on request to NCC. That is what is colloquially known as 'marking your own home-work' and we all know where that got Volkswagen recently in their emissions data scandal. NCC is prepared to allow a privately owned, Belgian, multinational company to tear up the ground in West Norfolk for their own profit, just based on what that company says they need without any further robust independent checks. That is an abdication of duty to the tax-payers and residents of Norfolk and I object to it.
In the last consultation period, the MOD(DIO) objected to SIL 02 becoming a quarry due to the wet working and wet restoration that was proposed there and the increase in the birdstrike risk that would impose on RAF Marham. They also commented on AOS E (and AOS J) to say that they would have concerns if they were to be wet worked or wet restored for the same reason. On economic grounds alone a birdstrike that brought down an aircraft would cost the UK taxpayer, just to replace the aircraft, approximately as much as Sibelco turned over in the UK according to the figures in their last published accounts. That is just one birdstrike. Lesser catastrophic birdstrikes would cost £millions to repair each time. Add into the
equation the costs that would be incurred to clear up a crash, and the costs to treat people affected by it both physically and mentally. A quarry in the area of AOS E or SIL 02 will be wet worked because the water table is so high; it would be restored wet because it wouldn't be possible or economically viable to dry restore water-filled hole 30m or more deep - the total cost to the tax-payer from birdstrikes is eye-watering and an unacceptable risk to take.
Let's look at the economic costs of removing outdoor areas that the public use regularly for their recreational activities - walking, running, horse-riding, cycle-riding and general relaxation. The areas of AOS E, SIL 02 and areas around them are used by thousands of local residents and tourists alike. The Nar Valley Way, a national footpath and bridleway, is adjacent to the north of the areas and is used by people from all over the UK. By allowing quarrying to occur in AOS E or SIL 02 will take away amenities that are enjoyed by people from all over the country; local business would be affected by the downturn in tourists. Moreover, with the level of obesity rising in the UK and the proven positive effects that exercising or relaxing outdoors has on the physical and mental health of the population, it would be economic folly to take away such a facility. Just this week it was reported that the cost to the NHS in treating mental anxiety and depression is £70M - £100M per year; add to that the treatment for obesity and the secondary diseases it causes and the local NHS costs would rise as a direct result of quarrying in AOS E and SIL 02. In addition to the economic costs involved from removing the outdoor spaces in order to quarry is directly in opposition to the aim in NCC's 'Vision to 2036' (page 19, Sect 6) that "Mineral development and waste management facilities will be located, designed and operated without unacceptable adverse impacts on the amenity of local communities....'; on that aim alone the areas of AOS E and SIL 02 should be removed from the M&WLP now.
Further economic impacts from permitting quarrying in AOS E and SIL is the loss of prime agricultural land. This would lead to a loss of the local jobs working the land and in the local food processing industry; loss of many more jobs than the couple that Sibelco says it would create at any quarry. Neither does it makes sense nationally at a time when the Gov policy is to increase and improve our agricultural land so that the UK becomes more self-sufficient in our food production; swapping agricultural land for a quarry is economically unsound and against Gov policy.
I object to quarrying in AOS E and SIL 02, and to silica sand quarrying on the scale it happens in Norfolk, on the grounds that NCC is not pursuing how it will ensure that the dwindling resource is used efficiently and as sparingly as possible to maintain it for future generations in accordance with the Gov policy. What is NCC going to do when the silica runs out? There are no plans in place or being drafted to account for using mineral resources in a way that maintain them for future generations or what will be done when the sand runs out. NCC should be planning for these by pioneering for technologically advanced glass recycling, especially clear and flat glass recycling; however, you are not. There is nothing in M&WLP that even hints at trying to improve recycling of glass, in Norfolk and nationally, to reduce the amounts of raw materials required within the glass making industry; planning that would help to maintain supplies of silica sand for future generations and reduce the quarrying within Norfolk. As a Mineral Planning Authority, it should be NCC's duty to lead the way in this. Economically having the latest innovative glass recycling facility infrastructure start in Norfolk would create hundreds if not thousands of jobs. In Europe, Sibelco is a major proponent of technologically advanced recycling of glass including clear glass and therefore would make the ideal partner for Norfolk County Council to spearhead such a project - they have the knowledge and expertise with a ready-made area to house the infrastructure at their Leziate facility, which also includes access to a train line that could be used to import other counties glass for processing and then to export the cullet to the glass manufacturers. Sibelco's own literature says that recycling glass is a win-win situation, so why don't they do that in the UK instead of just quarrying for more raw material?
In summary, I object on economic grounds to quarrying in SIL 02 and AOS E with emphasis on the area of overlap with SIL 02, for the following reasons:
● The increased birdstrike risk that will cost the UK taxpayer millions of pounds to replace and /or repair our front-line aircraft.
● The costs to the NHS for the treatment from an aircraft crash due to a birdstrike.
● The costs to the NHS for the treatment of mental and physical conditions arising from the loss of outdoor amenities used by thousands locally.
● The loss of jobs in local agricultural work and the local food processing industry quarrying would cause.
● The lack of any plan to pioneer innovative advanced recycling of clear and flat glass to reduce the amount of silica sand required for the glassmaking industry and to create hundreds/thousands of local jobs.
● The lack of any independent oversight that allows a private profit-making company with the monopoly on quarrying silica sand in Norfolk to dictate the amount of sand required and being able to take as much as they want and sell it to whoever and wherever in the world they decide.

CATSS - We Object to Quarrying in AOS E and the overlap of SIL 02 the Preferred Area On Historical Grounds

The Historic Environment Impact Assessment of AOS E and SIL 02 April 2019 with focus on Pentney Priory Gatehouse, suggested that a large area of SIL02 should be withdrawn from the plan as it was incompatible with the historic setting and context of this scheduled monument. What is not covered in this impact statement is the buried remains of part of this Augustinian Priory; there is nothing visible above ground but is revealed by crop marks, covering approximately 13.5 hectare area to the South towards the river Nar, and to the East and West. Surely this area should be designated as an area of historical importance? The finds could well stretch the length of the area of the former SIL02, now subsumed as part of AOS E, as the river Nar was diverted in the monastic period. Settlements and artefacts undiscovered would be lost forever if any quarrying was to take place. Given the significance and proximity to the six sites, three either side of the Nar, surely a very detailed historic analysis and archaeological study should be paramount and Norfolk County Council should exclude this area and remove it from their plan.

NCC Historic Environment Impact Assessment dated April 2019 of SIL02 cites from NPPF (2019), ' The surroundings in which ........ may change... evolve' . Does this suggest that the assessment isn't truly focussed on looking after our rich history but that 'progress' is quarrying under the banner of change and evolve? What is the point of NCC placing any restrictive criteria on any area of search in that case, or for that matter why not reveal all the deposits of silica sand in Norfolk as recorded by the British Geological Survey and say the whole of West Norfolk is open to be quarried? (It is interesting that NCC makes use of the NPPF in their favour when it suits their aim, in this case the citation above in favour of 'development' around heritage assets but ignores other important parts of NPPF that conserve minerals and primary materials - Sect 17, para 204.b.)

Additionally, the same assessment proposes a 2Km exclusion Zone to the East of Pentney Priory Gatehouse as sufficient not to impinge on that landscape; the assessment cites NPPF para 194 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 seems at odds with protecting the view towards or away from the Gatehouse. We appeal to NCC to look at this oversight again and propose the same restrictions to the South of Pentney Priory Gatehouse as there is to the East. This area SIL 02 was also objected to by MOD (DIO), so why has NCC seen fit to include it?

The centre of AOSE, 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 Priory (see chart on pg 28 of the Historic Environment Impact Assessment referred above). 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.

CATSS - Objections to Quarrying in AOS E and SIL 02 on Health Grounds

● The Ministry of Defence (MOD) has stated there is an unacceptable risk to aircraft with wet working in the area of AOS E; therefore, a dry worked quarry would be Sibelco's and NCC's plan for Shouldham Warren which would destroy this peaceful recreational area. The recommendation of the NCC Development and Infrastructure Committee (minutes of 17 July 19) stated with reference to AOS E, "a smaller area that is elevated (not wet) could come forward in this plan and not cause significant objections". Shouldham Warren is elevated and is approx 21m above sea level. That being the case the community should be very concerned for health implications arising from dry worked quarrying within Shouldham Warren. If wet working quarries is Sibelco's answer to the problem of dust, what is their answer to the destruction of an area that is our sanctuary from modern pressures? Three links, [https://www.mnmed.org/MMA/media/Minnesota-Medicine-Magazine/Commentary-Feyereisn.pdf] [https://www.ewg.org/research/danger-in-the-air] and [http://www.hazards.org/dust/silica.htm] to health implications of dry quarrying silica sand (respiratory problems and a higher risk of lung cancer) should be must-reads for the suits at County hall.

● Dry or wet worked (any) quarry in Shouldham Warren will have a devastating impact on the mental health of both villages' residents and for the other communities who use the Warren as their natural gym. Evidence shows natural outdoor spaces help with mental and physical health and social interactions. Shouldham Warren and Marham Fen both are used extensively by tourists and locals for experiencing the great outdoors which is backed up by the research of NHS Forest [https://nhsforest.org/evidence-benefits] and the Natural England Monitor of Engagement With The Natural Environment [https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/738891/Monitorof_Engagementwiththe_Natural_Environment_Headline_Report_March_2016to_February_2018.pdf].

● It cannot be argued against that the loss of outdoor space, reduced access to nature and the countryside has a negative effect on health and well-being.

DEFRA 25 year plan encourages access to green space to promote positive mental health and reduce obesity. Other health benefits include; resilience to stress, increased mobility, higher cognitive functioning and observation skills, reduction in Type2 diabetes and depression. Those with learning disability or Attention Deficit Hyperactivity Disorder (ADHD) also experience positive outcomes from being outdoors and closer to nature (MacFarlane as cited in People's Manifesto 2018). Public Health England (PHE) suggests that landscape may be referred to as a spatial unit as well as a socio-cultural asset. The fenland area between Shouldham and Marham is seen as an asset by the local people and all who visit and use it from all around Norfolk and the UK. Inactivity is the 4 th leading factor for global mortality accounting for 6% of deaths. Our local residents, old or young, benefit from the outdoor lifestyle afforded by Marham Fen and Shouldham Warren with regular walks enhancing our heart health, lowering blood pressure, improving weight control, while keeping joints and muscles strong and improving mood and mental well being.

● The social and emotional impact of losing our outdoor area and nature cannot
and should not be underestimated and is unacceptable .

CATSS - The Economic Case Against Silica Sand Quarrying in Marham and Shouldham
We object to quarrying in AOS E and SIL 02 for the following economic reasons:

What would Sibelco, a Belgian owned company, bring to the area if they were granted planning permission to quarry silica sand in Shouldham and Marham?

● Employment Opportunities? - only perhaps 1 or 2 jobs created at the quarry site, as quoted by Mike Hurley, Sibelco Chief Ops Officer. Approx 45 jobs maintained at Leziate but no extra jobs created there (Sibelco only employ 389 people in the whole of the UK). Sibelco claim to support down-stream jobs in the glass making industry; however, it isn't Sibelco who support those jobs it is the raw silica sand and that could come from any other source including importation. There is no value to the sand for Norfolk, just profit for the Belgian owned company Sibelco. How do we 'take back control'?

● Norfolk County Council's (NCC) assertion that Sibelco bring and maintains jobs in Norfolk does not add up. As seen from an article in the EDP [Source: https://www.edp24.co.uk/news/meet-the-woman-who-helps-stop-our-fridges-running-out-of-beer-by-making-sure-the-sand-trains-run-on-time-from-a-quarry-near-king-s-lynn-in-norfolk-1-4048077] 75% of the sand is transported out of Norfolk by rail. The statements made by the Sibelco employee in the article mean that only a handful of HGV jobs are being supported by the transportation of sand in Norfolk. Sibelco estimate 800,000 - 900,000 tonnes of sand extracted per year; NCC figures are 735,000 - 750,000; so a train with 1000t = at least 2 trains per day to haul 75% of total 8 - 9k tonnes per yr. The remaining 25% at 28 tonnes per HGV = 8035 trips per yr, equating to 5 trips per day = 7-8 drivers jobs? Therefore, to retain a few jobs we must accept the destruction of the countryside, the wildlife, our villages, our property, our health and the small matter of national security and the well-being of one of our biggest employers in West Norfolk, RAF Marham. If however, we were to import sand to the glass manufacturers that would maintain glass making jobs in the North of England and presumably the transport jobs to move the sand to the glass factories, so no job loses in the north. Similarly, rather than sand haulage, transporting waste glass for recycling would maintain jobs in the haulage industry in Norfolk if there were to be an advanced glass recycling facility built in Norfolk. To offset any carbon emissions from that additional HGV traffic the train line at Leziate could still be used to bring glass into Norfolk for recycling and to carry the recycled glass cullet from the new, clean, green recycling facility at Leziate to the glass manufacturers. That is a win-win situation for everyone.

● Adding value to the local economy? - NO, they are only creating a couple of jobs (see above). Sibelco's representative has said at a public meeting there would be no economic benefit to the area of Shouldham and Marham. Is the sand used in industry here in Norfolk? NO, all of the sand is exported beyond Norfolk's borders to be used in glassmaking elsewhere. Therefore, Sibelco will add nothing extra to either the local economy or that of Norfolk in general. From Sibelco's latest published accounts (2017) we believe they paid £1.4M in UK tax and £245K in business rates (for the Leziate plant) as part of their claim of putting £15M into Norfolk economy. The 2017 Financial return shows £3.8M in total UK plant costs; Sibelco plant hire is from a Cheshire firm, D Wardle Plant hire - so nothing to Norfolk's economy. The average UK Sibelco wage was £37.5K in 2017 - Leziate supports 45 jobs only.

● Health Hazard - YES, Sibelco will be bringing a health hazard to the area. Health hazard to the physical and mental well being of the community. Both of these will have heavy financial consequences for the local NHS budget [Source: Anxiety and depression costs to NHS per year -Telegraph 09 Oct 2019 https://www.telegraph.co.uk/science/2019/10/08/go-woods-todayit-will-banish-winter-blues-say-healthexperts/], whilst Sibelco continue to make a profit from quarrying sand to send outside of Norfolk and not contributing to the local economy.

● "Anxiety and depression costs the UK economy an estimated £70-£100 million a year yet studies have shown that spending as little as two hours a week in nature is an effective evidence based strategy for maintaining good mental health." - The Telegraph 09 Oct 2019

What would be lost if Sibelco, a Belgian owned company, were granted planning permission to quarry silica sand in Shouldham and Marham?

● Agricultural Land - the area surrounding Shouldham and Marham is high grade agricultural farmland. Much of the land is used to grow sugar beets, a huge industry here in Norfolk. The British Sugar [Source: British Sugar Wissington https://www.britishsugar.co.uk/about-sugar/our-factories] sugar beet processing plant at Wissington directly supports more than 500 jobs (270 are permanent) and trains 16 apprentices (remember Sibelco only employ 389 people nationally). British Sugar paid £200M in UK taxes in the last 5 years. British Sugar invested £250M in UK infrastructure over the last 5 years, actually boosting our local economy and creating, maintaining and sustaining significant local employment for Norfolk. Sibelco are not supporting the local economy of Norfolk to the same extent. The loss of farmland to quarry a mineral will impact the agricultural industry and the families it supports (processing plant and land workers). These are real Norfolk jobs. Once the land is lost it could never be recovered as any quarry would be left as a massive expanse of water. All this despite the fact that the UK is about to leave the EU and should be ensuring food security, and the farming industry is supported, maintained and expanded. Indeed the Government's own plans and policies are to increase self sufficiency in food production [Source: Developing a National Food Strategy
https://www.gov.uk/government/publications/developing-a-national-food-strategy-independent-review-2019/developing-a-national-food-strategy-independent-review-2019-terms-of-reference].

● Natural Open Spaces - the reduction of natural open spaces impacts on mental health [Source: A review of nature-based interventions for mental health care (NECR204)
http://publications.naturalengland.org.uk/publication/4513819616346112], physical health, and an increase in obesity with all the secondary health issues that brings (diabetes, heart problems, physical problems). These impacts would have a huge financial cost to the NHS in time and resources.

● Lack of Community Growth - with the prospect of a 1000 acre quarry next to your home, why would young families be enticed to come and settle in the area? Why will young families already here choose to stay and bring their children up next to a quarry? The answer to both questions is simply that they won't and that means the area will die economically. No community can survive without the next generations choosing to be in that community.

● Tourism - Shouldham Warren is directly adjacent to the remaining area of SIL 02 within the overlap with AOS E, it is also slap bang in the middle of AOS E. Currently used by several thousand walkers, cyclists, horse riders and runners each week; why would they want to continue to partake in outdoor pursuits next to a working quarry? They wouldn't and local business would feel the financial loss. The Nar Valley Way is to the north edge of AOS E and a PROW from there cuts through AOS E. Many walkers stay in local B&Bs whilst travelling the famous pathway, these business would be affected due to the fact that walkers would prefer to stay somewhere that isn't next to a working quarry. 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. These are all Norfolk business' that will be affected negatively financially for the good of Sibelco, a Belgian owned company.
What about the bird-strike risk to the aircraft at RAF Marham and the financial penalty that
would incur the UK tax payer?

● It is a fact that birds are a problem at any airport. However, RAF Marham isn't just 'any' airport; it is the Main Operating Base (MOB) for the F35 Lightning II, an aircraft that costs an eye-watering £100+ per basic aircraft. The loss of an aircraft due to the loss of an engine or major airframe 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. It would be argued that there is a set of small lakes very close to RAF Coningsby and that is allowed but, it should be noted that these quarries had been worked for many years previously and that this practise of allowing large man-made lakes near an airfield is no longer tolerated - a precautionary principle of risk applies. It should also be noted that the Typhoon at Coningsby has 2 engines as opposed to the ONE engine that the F35 has, which gives it a better chance to be able to land if one engine is damaged. This is not a luxury the F35 has and, since it isn't a glider, it will not be guided away from the school or the houses before it crashes due to the loss of its ONE and only engine. In other words you cannot compare the 2 places as like for like and overall, on finance alone, the extra risk due to the construction of a water filled quarry so close to RAF Marham is unacceptable to the tax-payer. MOD (DIO) have rightly objected to any quarry that will be wet worked or wet restored in SIL 02, AOS E and AOS J because of this increased risk of birdstrike it would bring. In fact, a recent report [Source: F35 birdstrike report https://thedefensepost.com/2019/05/16/us-f-35-bird-strike-japan/
http://www.aoa.org.uk/wp-content/uploads/2016/09/Advice-Note-1-Aerodrome-Safeguarding-An-Overview-2016.pdf] of a US Marine Corps F35 hitting a bird during the take-off roll caused the aircraft take-off to be aborted and the damage caused amounted to more than $2,000,000 to repair. It appears obvious to everyone except NCC and Sibelco that quarrying in this area of the Safeguarding Zone7 around RAF Marham is not acceptable. What about the cost of upgrading the transport infrastructure?

● The overburden needs to be removed from any proposed quarry site each time a new area is to be quarried. That overburden will need to be removed by HGV. The local roads are hardly fit for normal traffic and will require a significant uplift in expenditure to make them viable for HGV traffic loaded with tons of wet earth for approximately 16-20 weeks a year. Another unacceptable bill for the tax-payer. But what if the site is worked dry? Then the cost of the road infrastructure just increases as the raw sand will also need to be removed by HGV as well as the overburden. What could Sibelco add to the local Norfolk economy?

● They could invest in up to date glass recycling as they do in mainland Europe. Glass Recycling [Source: Cheaperwaste.co.uk - Glass Collection Services -http://www.cheaperwaste.co.uk/services/glass-collections/] contributes to British business as a whole: estimates indicate that 500 jobs are created for every 100,000 tonnes of glass collected for recycling. If we, as a country, recycled all the glass we currently throw away to landfill, it would create 7,500 sustainable new jobs overnight. NCC are failing to take the opportunity to create a vibrant local employment market in a green industry that at the same time will preserve and sustain the stocks of silica sand, protect the biodiversity of the countryside and health of the residents of Norfolk, whilst helping to reduce CO 2 emissions. A continuation of quarrying will not add to the jobs market in Norfolk; however, implementing a radical glass recycling programme will create jobs at all levels from manual labour through to technical skills, and graduate to management.

And remember Sibelco's own quote from their Feb 2012 brochure [Source: Pure Sense Recycling-Sibelco Green Solutionshttps://issuu.com/salez-poivrez/docs/sibelco.glassrecycling.brochure.feb2012_v4]:
○ "The environmental and economic case for glass recycling is clear.
Cullet helps glass producers drive down energy consumption and emissions, and means less landfill and waste disposal. It's a win-win equation that has created a dynamic, global glass recycling market with a number of national and international players. So how do you choose the right partner to help you achieve the full potential of recycling?" -
○ Sibelco supply, by far, the majority of glass making quality silica sand to glass manufacturers in England and Ireland but they are not involved at all in the recycling of glass in the UK. In summary, there is no positive economic case to allow any quarrying in or around the Marham and Shouldham area.

Additional Reference
1. HM Government - A Green Future: Our 25 Year Plan to Improve Our Environment
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/693158/25-year-environment-plan.pdf

1. Response to Draft Policies
1.1 Strategy - Vision and Objectives
1.1.1 Mineral Safeguarding should refer to paragraph 182 of the revised National Planning Policy Framework (NPPF) 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.

1.2 Mineral Strategic Objectives
1.2.1 The Mineral Strategic Objectives should be revised to properly reflect the wording of the NPPF.

1.2.2 MSO2
1.2.3 We suggest that MSO2 is amended to read (new text in CAPITALS):
"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 OR AT LEAST 15 YEARS WHERE SIGNIFICANT NEW CAPITAL IS CAPITAL IS REQUIRED and safeguarding existing infrastructure"

1.2.4 We suggest that MS04 is amended to read:
1.2.5 "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."

1.3 Policy MW3 Transport
1.3.1 Proposed amendment to bullet point 4 under part d) of the policy:
1.3.2 "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."

1.3.3 Policy MW4 Climate Change
1.3.4 Proposed change:
g) incorporate proposals for sustainable travel, including travel plans where PRACTICAL AND appropriate.
1.3.5 Due to the often-isolated nature of mineral workings public transport or cycling are not practical. Therefore, the additional wording is suggested to make the policy effective and preventing unnecessary work for the developer/applicant.

1.4 MW6: Agricultural Soils
1.4.1 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.

1.5 MP1: Provision for minerals extraction
1.5.1 Changes are required to make it clear that the landbanks levels have to be maintained so they are in place at the end of the plan period to make the policy accord with national policy and be effective. In respect of silica sand changes are needed to make the policy accord with NPPF .

1.5.2 Suggested changes as follows;
The strategy for minerals extraction is to allocate sufficient sites to meet the forecast need for both sand & gravel and hard rock (carstone).

For sand and gravel, specific sites to deliver at least 20,313,300 tonnes of resources will be allocated. The sand and gravel landbank will be maintained at a level of at least 7 years supply THROUGHOUT THE PLAN PERIOD (excluding any contribution from borrow pits for major construction projects).

Mineral extraction for sand and gravel outside of allocated sites will be resisted by the Mineral Planning Authority unless the applicant can demonstrate: a) There is an overriding justification and/or overriding benefit for the proposed extraction, and b) The proposal is consistent with all other relevant policies set out in the Development Plan.

For carstone, a site or sites to deliver at least 340,200 tonnes of resources will be allocated.
The landbank for carstone will be maintained at a level of at least 10 years' supply
THROUGHOUT THE PLAN PERIOD.

For silica sand, sufficient sites and/or areas to deliver at least 10,500,000 tonnes of silica sand
will be allocated. The landbank STOCKS OF PERMITTED RESERVES FOR SILICA SAND WILL BE
MAINTAINED AT A LEVEL OF AT LEAST 10 YEARS' SUPPLY PRODUCTION FOR EACH INDIVIDUAL SILICA SAND SITE OR AT LEAST 15 YEARS WHERE SIGNIFICANT NEW CAPITAL IS REQUIRED [DELETE: Where practicable]. Planning applications for silica sand extraction located outside of allocated sites or areas of search, which would address the shortfall in permitted reserves, will be determined on their own merits in accordance with the policies in this Local Plan, including the requirements contained within Policy MP13.

1.6 Policy MP2: Spatial Strategy for mineral extraction - strategic policy

1.6.1 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 and the development management process. Arbitrary buffers risk the sterilisation of workable mineral when they could be satisfactorily worked without impact.

1.6.2 There is no evidential basis for the buffers and the policy is unsound as it is not effective and is not positive planning.

1.7 Policy MP11: Mineral Safeguarding Areas and Mineral Consultation Areas

1.7.1 The policy wording should be altered to incorporate the 'agent of change' principle:
The County Council will safeguard existing, permitted and allocated mineral extraction sites from inappropriate development proposals. Minerals Consultation Areas are delineated on the Policies Map and extend to 250 metres from each safeguarded site. Development proposals within 250 metres of a safeguarded site should demonstrate that they would not prevent or prejudice the use of the safeguarded site for mineral extraction, AND THE AGENT OF CHANGE PRINCIPLE WILL BE APPLIED IN ALL SUCH CASES. The County Council will object to development proposals which would prevent or prejudice the use of safeguarded sites for mineral extraction.

2. Proposed Mineral Extraction Sites

2.1 MIN 40 land east of Grandcourt Farm, East Winch
2.1.1 Sibelco supports the specific site allocation of MIN 40.
2.1.2 Sibelco submitted a planning application accompanied by an environmental impact assessment which determines that there will be no significant impacts from the continued working of Grandcourt quarry.

2.2 SIL01 land at Mintlyn South, Bawsey
2.2.1 Sibelco supports the specific site allocation of SIL01.

2.3 AOS E land to the north of Shouldham.
2.3.1 Sibelco supports the inclusion of Area of Search E, land to the north of Shouldham.

2.3.2 We disagree with the updated plans of the area which identify an arbitrarily drawn heritage setting standoff. The standoffs are based on a Heritage Impact Assessment (Percival, 2019) which by its own admission is incomplete. There is not 'clear and convincing justification' for these arbitrarily drawn standoffs. Any application forthcoming within the Areas of Search should be determined on its own merits and supported by a detailed environmental impact assessment.

2.4 AOS F land to the north of Stow Bardolph
2.4.1 Sibelco supports the inclusion of Area of Search F.

2.5 AOS I land to the east of South Runcton
2.5.1 Sibelco supports the inclusion of Area of Search I.

2.6 AOS J land to the east of Tottenhill
2.6.1 Sibelco supports the inclusion of Area of Search J.

2.7 Policy MP13: Areas of Search for silica sand extraction
2.7.1 Sibelco supports policy MP13. 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.

2.8 SIL02: land at Shouldham and Marham
2.8.1 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
2.8.2 The National Planning Practice Guidance says:
"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..."
2.8.3 This definition applies to SIL02.
2.8.4 The Mineral Planning Authorities conclusion (paragraph 2.28) is subjective. It would be for any planning application coming forward on the site to proposed a method of working and restoration to satisfy concerns regarding bird hazard.
2.8.5 In the context of NPPF paragraph 16 the plan as written is not positively prepared and there remains a significant shortfall in silica sand supply. SIL02 should be allocated as a specific site with any subsequent planning application required to evidence the effective mitigation measure in relation to concerns regarding bird hazard.

Thank you for consulting DIO Safeguarding on the Norfolk Minerals and Waste preferred options consultation paper. This office previously commented on the Norfolk Minerals and Waste Local Plan in December 2018.

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.
The preferred options paper identifies sites deemed viable for sand and gravel extraction. 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. The MODs original representation dated the 10th December remains extant:

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.

MIN 6 - Land East of Winch Road,Mill Drove Middleton
This site occupies the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The proposed restoration for this site is low level heathland. The MOD has no safeguarding objection to this site being used subject to dry restoration.

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.

AOS E Land north of Shouldham
The sites use is already constrained by Historic England. Therefore, the land to the south, east and west of AOS E is being identified for mineral extraction.
The area of search is approximately 6km west from the centre of the main runway at RAF Marham. 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.

AOS F Land to the North of Stow Bardolph
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.

AOS I Land to the East of South Runcton
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.

The MOD note site SIL 02 Land at Shouldham and Marham has been deemed to be an unviable site option. This site is approximately 4.8km north west from RAF Marham. The proposed extraction 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 support the removal of this site based on current restoration plans.

In summary, MIN 40 and MIN 6 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, F, J and I the MOD has concerns and would require further information to determine whether the sites could be managed with design principles and a BMP. This is supported by policy NP13 'if a planning application were to be submitted for these sites the applicant must submit a bird hazard management plan and bird hazard assessment.'

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

Norfolk Minerals & Waste Local Plan Review 2019

Policies
Vision
* We support the progressive restoration schemes and enhancement of Norfolk's biodiversity. Where the third paragraph makes reference to the enhancement of Norfolk's biodiversity, we recommend this is expanded to incorporate the upcoming mandatory requirement for biodiversity net gain, as set out in the Environment Bill and supported by the NPPF.
* Recognising the negative impacts a changing climate will have on the future for wildlife in Norfolk, we recommend that the Vision's target for minimising the impact of minerals development and waste management on climate change is made more ambitious, by changing it to at least a target of net zero or net positive where possible. Opportunities exist for gains for both wildlife and carbon sequestration through appropriate habitat restoration and creation as part of proposals, as already noted in Minerals Strategic Objective MS08.

MW2 - Development Management Criteria
* We support the policy requirement to ensure that development will not have a damaging effect on the natural environment, in particular for locally designated sites (I.e. the County Wildlife Site network).
* However, the aim of the policy appears to focus on a no net loss principle, with enhancements only being sought 'where appropriate'. We recommend that in order to conform with the NPPF, the policy makes reference to the requirement for biodiversity net gain. Reference can also be made to the recent publications by DEFRA on its implementation.

MW4 - Climate change adaptation and mitigation
We support the inclusion of targets for emissions minimisation and renewable energy provision. Given the overlap between new habitat creation, the upcoming mandatory provision of biodiversity net gain and carbon sequestration, we recommend that the policy and supporting text is expanded to note the role habitat creation and restoration can provide in climate change mitigation.

MP2 - Spatial strategy for minerals extraction
We recommend that in addition to the existing defining areas of search, that County Wildlife Sites are also excluded from the Areas of Search for silica sand extraction. We are concerned at the overlap between some proposed minerals sites and the County Wildlife Site network and we do not believe that allocating minerals extraction on CWSs is compatible with the plan's Vision to enhance Norfolk's biodiversity.

MP5 - Core river valleys
We support the approach taken by this policy to safeguard these important key corridors for wildlife through the county, in particular through the requirement for development in these areas to demonstrate that it will enhance the biodiversity of the river valley either immediately or on restoration.

MP7 - Progressive working, restoration and after-use
* Notwithstanding any site specific concerns regarding loss of wildlife sites or indirect impacts (e.g. dust and hydrology), we strongly support the restoration of mineral sites to priority habitats. Such measures offer a rare opportunity to create new habitats that can help Norfolk's wildlife recover from the significant and ongoing declines which it faces.
* Restoration plans should be included at the planning application stage to ensure that the strategic contribution of the site to landscape scale conservation and delivery of biodiversity net gain can be considered.
* Wherever possible, restoration proposals should be matched to existing priority habitats in proximity, to allow for greater connectivity through the landscape for local species. This will also help create a more permeable landscape for the movement of species' ranges in response to climate change in the future.
* Wherever possible, if there is the potential for native species seeds to be present in the seed bank at the start of the working period, then such soils should be stored appropriately to ensure that it can be used in any restoration scheme and allow for recolonization by native flora.

MP8 - Aftercare
We support the aftercare of restored mineral sites in order to ensure that their target habitats are achieved. We strongly support the requirement for longer aftercare provision to ensure successful establishment and maintenance of the approved after-use. As habitat creation/ restoration offers the opportunity to also provide carbon sequestration and contribute to climate change mitigation targets, their establishment may also require longer aftercare periods to demonstrate successful delivery.

Minerals Site Allocations

Silica Sand

MIN40
* We note the potential dewatering risk to East Winch Common SSSI and CWS 140 East Winch Common. This site should only be included in the plan if the Council is confident that such issues can be dealt with satisfactorily through hydrological studies at planning permission, in order to avoid risks to delivery of the plan.
* We therefore support the recommendation that any permission will require a detailed hydrological assessment to determine the safe extent of working that can occur without risking impacts on nearby SSSIs and CWSs.
* We recommend that the restoration proposals include heathland due to the proximity to heathland habitats on East Winch Common, as this will provide ecological connectivity and allow for more movement of wildlife through the landscape.
* The site also has the potential to provide new green infrastructure for the adjoining settlement through provision of wildlife rich public open space as part of restoration proposals.

SIL01 (land at Mintlyn South Bawsey)
* During the previous consultation phase we highlighted that part of the proposed allocation overlaps with CWS 416 '70 & 100 Plantations' and recommended that these areas are safeguarded. The supporting text correctly identifies potential adverse impacts to this CWS and the adjacent CWS 418 Haverlesse Manor Plantation, but makes no attempt to safeguard these. The most appropriate way to ensure that impacts to the CWS are avoided is to exclude it from the minerals allocation, therefore we strongly recommend that CWS 416 is completely excluded from the proposed allocation. In addition, in order to safeguard from any indirect impacts to CWS from impacts such as dust, any allocation would need to include a non-worked buffer between it and both CWS.
* We support the recommendations in the policy text for noise, dust, air quality and hydrology assessments which will help inform ecological assessments of potential impacts on nearby wildlife sites. We recommend that any restoration plan ensures that the existing ecological connectivity between the adjacent wildlife sites is maintained through progressive working and that restoration post-extraction complements the adjoining habitats.
* We also note in the supporting text that the land use of the proposed allocation is classed as non-agricultural land, however we understand that this is likely to be incorrect as the southern part of the site has been in regular use as grazed grassland for at least twenty years. This area is likely to be of ecological significance, with anecdotal records of several protected species present as well as a number of mature oak trees on the southern boundary. In the absence of further information on the ecological value of this area and the potential impacts on a range of protected species (and any consequent impacts on delivery) as a precaution we recommend that this part of the site is removed from the allocation.

AoS E
* We are concerned at the large scale of this AoS and its proximity to multiple CWS. Any application within the AoS would need to be accompanied by a detailed ecological appraisal and hydrological assessment where appropriate.
* Mow Fen CWS is within the AoS and not suitable for minerals extraction, therefore we strongly recommend its removal from AoS and the provision of a buffer around it to avoid impacts such as dust.
* The AoS lies adjacent to CWS 373, species-rich grassland which will need buffering from the AoS.

AoS F
* We note the proximity of the northern area of the AoS to CWS 365, Broad Meadow Plantation. We strongly recommend a stand-off or buffer between any proposal in the AoS and the CWS in order to safeguard from indirect impacts.
* Proposals in proximity to any CWS would need to be accompanied by dust and hydrology assessments.
* We note from the maps provided that there appear to be a high number of ponds within the AoS and in the wider landscape. The potential for impacts on protected species and the likely requirements for ecological restoration will need to be considered as part of any application in this AoS.

AoS J
Due to the proximity to wildlife sites, we support the requirement for ecology and hydrology assessments as part of any application within this AoS.

SIL02 - land at Shouldham and Marham (silica sand)
Due to the unknown potential scale of minerals development that this Area of Search would support and the number of CWS in close proximity in particular Marham Fen CWS, we are concerned at the potential for significant impacts on wildlife and therefore support the Council's recommendation that this site is not progressed in the plan.

Carstone

MIN6 - Land off East Winch Road, Mill Drove, Middleton
We support the working of this site dry to avoid hydrology impacts, and the proposed restoration of this site to heathland habitat.

Breckland

MIN51&MIN13
We support the creation of new wet woodland habitat around retained wetland areas, as well as new hedgerows and oak standards alongside the northern boundary.

MIN200
We support the restoration proposals for this site.

MIN 102
We support the exclusion of this site from further consideration in the plan due to the adverse impacts likely on the adjacent Swangey Fen SSSI, a component of the Norfolk Valley Fens SAC.

Broadland

MIN202
* We previously raised concerns that this allocation overlaps with CWS 1344 'Triumph and Foxburrow Plantations' and repeat our recommendation that, in order to safeguard the CWS, the allocation boundary should be modified, with a stand-off area between any mineral working and wildlife sites (the CWS and ancient woodland at Mileplain Plantation) in order to mitigate for any indirect impacts such as dust.
* We support the restoration to a mosaic of acid grassland, woodland and wetland [check policy text] and recommend that the potential for heathland to be added.

MIN37 & MIN64
We hold no specific information on the proposed sites MIN 37 and MIN 64, but note their proximity to two County Wildlife Sites and strongly recommend that any restoration proposals for these sites, if allocated, are targeted to match wherever possible the habitats present in the nearby CWS in order to maximize ecological connectivity.

MIN96
We note the proximity to CWS 2205, Spixworth Bridge Meadows, and CWS 1396, Spixworth Meadows, and support the requirement for this site to only be worked dry in order to avoid any potential impacts on the CWSs through changes in local hydrology. We also support the requirement for a dust assessment.


MIN213
* We note that this allocation is adjacent to CWS 2204, Hevingham Park, a replanted ancient woodland with pingos and rich ground flora in places, as well as an additional area of ancient woodland outside the CWS. These habitats will be vulnerable to typical impacts from minerals operations and any application will need to be supported by a dust assessment, with appropriate mitigation including vegetative screening for the extraction period.
* The policy text indicates that the site would be worked wet. We support the policy requirement for a hydrogeological assessment to be provided as part of any application, and note this should also cover impacts on the ecology of adjacent wildlife sites. In addition, we also recommend that the Council will need to be sure that the site can be worked wet without leading to adverse impacts on adjacent wildlife sites (after mitigation) in order to ensure that it is deliverable.
* We support the restoration proposals to heathland where opportunities around the existing holiday park consent allow.
* We have been made aware of the likely presence of great crested newts on the site. In addition, given the extensive woodland on site, the presence of other protected species such as bats are also likely. As a result we would expect any application to be accompanied by a detailed ecological appraisal. Should such populations be present, then any progressive working programme is likely to require retention of sufficient areas of habitat at any one time to allow for their retention.
* Given the proximity of pingos to the north, the potential for this site to include pingos should also be investigated.

MIN48
Due to the proximity to Swannington Upgate Common SSSI and likely impacts, we support the removal of this from the plan.

Great Yarmouth

MIN38 - land at Waveney Forest, Fritton
We support the exclusion of this site from further consideration in the plan due to the likely impacts on the Waveney Forest and Fritton Warren South County Wildlife Sites (CWS), in particular the remnant heathland elements of the Forest and the adjoining wetland habitats at Fritton Warren. Should the Council proceed with this site in the plan, then we would expect further evidence on ecology and hydrology to demonstrate that it is deliverable whilst avoiding impacts on the adjacent CWSs. Given the potential for the areas adjacent to the CWSs to support protected species and be of similar ecological value, any application would need to be accompanied by detailed ecological and hydrological appraisals, including restoration plans that complement the adjacent wildlife sites.

King's Lynn & West Norfolk

MIN 206 - land at Oak Field, west of Lynn Road, Tottenhill
We support the requirements for hydrological assessment in the supporting text as part of any ecological appraisal accompanying an application for this site, and recommend that this is also included in the policy text for clarity.

MIN 45
We support the exclusion of this site from further consideration in the plan due to its location on ancient woodland, defined as an irreplaceable habitat in the NPPF.

MIN19&205
We support the exclusion of these sites from further consideration in the plan due to the proximity to the River Nar SSSI.

MIN74
We support the exclusion of this site from further consideration in the plan due to the adverse impacts predicted on wildlife sites.

MIN77
We support the exclusion of this site from further consideration in the plan due to the adverse impacts predicted on wildlife sites.

North Norfolk

MIN69 - north of Holt Road, Aylmerton
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 only be worked dry in order to avoid hydrological impacts on the nearby Norfolk Valley Fens SAC and be subject to high quality restoration and formal aftercare, creating a large new area of heathland with benefits both for wildlife and green infrastructure provision. We support the precautionary requirement for noise and dust assessments as part of any application in order to evaluate potential impacts on nearby wildlife sites and the requirement to demonstrate that adverse effects on the Norfolk Valley Fens SAC would be avoided.

MIN115 - land at Lord Anson's Wood, near North Walsham
Due to the proximity of two SSSIs and Weaver's Way County Wildlife Site (CWS) which include wetland habitats, the site should only be worked dry in order to avoid any impacts. We support the requirement for dust assessments and identification of appropriate mitigation measures to ensure that nearby CWSs are not impacted by this allocation. We support the proposed restoration to woodland and heathland and recommend that restoration proposals are secured as part of any application.

MIN207 - land at Pinkney Field, Briston
We note the proposed restoration to reservoir and agricultural grassland which we understand is linked to existing adjacent planning consents. However, we recommend that any allocation should demonstrate it can deliver biodiversity net gain in its own right and should include sufficient areas of priority habitats as set out in policy MP7 (see supporting text MP7.5, for example woodland and heathland) to ensure this can be delivered in addition to compensating for displaced features from existing consents.

MIN208 - land south of Holt Road, East Beckham
We support the proposed restoration of the site to a mosaic of native woodland, scrub and acid grassland.

MIN71- land west of Norwich Road, Holt
We agree with the Council's evaluation that this site is unsuitable for allocation due to the likely impacts to Holt Lowes SSSI, a component of the Norfolk Valley Fens SAC, as well as to the multiple County Wildlife Sites in close proximity. In the absence of a detailed hydrological assessment it is not clear that this site can be worked without an adverse effect on the SAC, therefore there is a risk that the site would not be deliverable if retained in the plan.

South Norfolk

MIN209
We support the proposed restoration scheme for this site.

MIN210
We support the proposed restoration scheme for this site.

MIN211
* We support the requirement for dust assessment and mitigation proposals as part of any application given the proximity to CWSs and ancient woodland.
* We support the proposed restoration scheme for this site.

MIN25
* We support the requirement for dust and hydrology assessments and mitigation proposals as part of any application given the proximity to CWSs.
* We support the proposed restoration scheme for this site.

MIN212
We support the proposed restoration scheme for this site.

MIN92
We support the exclusion of this site from further consideration in the plan due to the adverse impacts predicted on wildlife sites.

Preferred Options Plan
Thank you for the opportunity to comment on the Preferred Options stage of the Norfolk Minerals and Waste Local Plan. We have commented on the policies and allocated sites in the same format as the Local Plan itself below.

The Process so far
We are pleased to see water resources are mentioned in this section. However, this section could be strengthened by making reference to whether working beneath the water table is required and whether dewatering is required. This could potentially pose a challenge to sites moving forward so it should have a stronger mention in this section.

Policy MW2: Development Management Criteria
We are pleased to see that point k in this policy makes reference to the natural and geological environment. This point could be enhanced by also making reference to the hydrogeological environment including maintaining groundwater dependent wetlands, surface water flows, groundwater quantity and flow regime.

The policy makes no reference to local air quality regarding waste developments, be it from gas utilisation units or fugitive emissions from landfilled areas and their perimeter. This is especially key where development is close to sensitive receptors or such receptors are developed close to the sites.

We welcome the inclusion of point D in the policy. This could be enhanced to state
"flood risk TO THOSE WORKING on site or an increase in flood risk elsewhere" (addition in CAPITALS ). The policy could also be improved by requiring a Flood Response Plan to manage the safety of the people on site.

Pollution and Local Amenity Impacts
We agree with the inclusion of paragraph 8.12 that lighting levels should be assessed with consideration given to the impact lighting will have on European Protected species. Mitigation could include limiting the operational hours of the site and using down lighting.

We fully support the protection of Local Wildlife sites (county wildlife sites, local nature reserves and local wildlife sites) highlighted in paragraph 8.20 as well as priority habitats and species. We agree that any proposal should only be permitted where it can be demonstrated that the activities will not significantly harm the site, and will require submission of appropriate ecological surveys, carried out by an appropriately qualified ecologist, at the correct time of year as described in paragraph 8.21. We recommend the rewording of the final sentence of paragraph 8.20 to state "Development that may affect Water Framework Directive waterbodies e.g. rivers, streams, lakes will require a WFD compliance assessment".

Water Framework Directive
The plan should make reference to the fact that any development that could impact the status of a water body, whether WFD or not, should be subject to a WFD assessment.

Flooding, Water resources and water quality
We agree with the reference this section makes to flood risk betterment after restoration, reducing flood risk elsewhere and acknowledgement that climate change needs to be considered. However this section does not refer to ensuring there is no increase in flood risk elsewhere through the duration of the works. In addition there is no mention of the flood risk to people on site and the need for management to ensure their safety with a Flood Response Plan. The plan should therefore be updated to this effect.


It is encouraging to see that paragraph 8.40 makes it clear that dewatering for mineral abstraction purposes requires a water abstraction licence from the Environment Agency. However, it should be noted that an abstraction licence for dewatering may not be granted and it is likely that any de-watering water will need to be returned to the aquifer close to where it is abstracted and in a timely manner after the abstraction takes place. Our current Catchment Area Management Strategy (CAMS) policy for issuing abstraction licences intervening use of this water for activities such as mineral washing and dust suppression which have a consumptive element will not be permitted, this be a challenge for sites going forward if alternative sources of water for associated activities such as mineral washing and dust suppression cannot be found.

Paragraph 8.40 refers to the Water Framework directive. A WFD assessment is a good addition and we welcome the suggestion to protect the designated drinking water source protection zones. We also support the use of pollution prevention measures, to prevent pollution of surface and groundwater. This paragraph should also state that the assessment should determine if there could be a deterioration in WFD status. Activities should not allow any deterioration in any of the WFD elements. Minerals and waste management developments should not cause deterioration or prevent a water body from achieving Good Ecological Status/Potential, and whenever possible, help to implement environmental improvement measures to improve waterbodies.

Policy MW4: Climate Change mitigation and adaptation
Paragraph 10.2 states the need to minimise demands on potable water resources. The sentence should continue by saying 'and water resources in general'. As stated above, we are not issuing new consumptive abstraction licences.

A possible linkage could be made between point's b and c - on site renewable energy (both electricity and hot water) could well be provided from captured landfill gas emissions. Any excess energy could then be fed into the local networks.
It would be beneficial to update the wording of point 3 to state "...including rising sea levels, LARGER RIVER FLOWS, and coastal erosion..." (addition in CAPITALS).

Waste Management Specific Policies
In terms of paragraph W0.3, you should ensure that you plan for sites that will 'Prepare for Re-use' as it has been stated that greater weight is being put to the management methodology at the top of the waste hierarchy.

W1.12
The plan states "The latest Defra estimate of C&I waste growth for England is 0.6% per annum, therefore an alternative option would be to forecast C&I waste growth over the Plan period at 0.6% per annum instead of 1.5% per annum. However, it is considered that it is more appropriate to use the Norfolk specific figure of 12.5% per annum". We are unsure where and how this figure of 12.5% has been calculated and why it is so different to DEFRA's estimate. Sustainable economic growth will need enough commercial and industrial waste processing capacity to deal with this increase in waste generation.

Policy WP2: Spatial Strategy for Waste Management Facilities
We support the policy WP2 regarding the location of Water Recycling Centres. It should be noted that the decision, ultimately, remains with Anglian Water Services.

Policy WP3: Land potentially suitable for waste management facilities
This policy should state that waste management facilities (aggregate recycling) also need to consider consumptive water use and where this water will come from.

Policy WP6: Transfer, Storage, Processing and treatment of hazardous waste
It is highly likely that any proposals for the discharge of hazardous waste to surface water or groundwater will require a discharge permit, if allowed. The policy could be improved by saying that under no circumstances, should there be a discharge of treated hazardous waste/materiel to surface waters or groundwater without prior consultation with the EA.

Policy WP9: Anaerobic Digestion
The policy could be improved by making reference to Emergency Planning. Proposals for Anaerobic Digestion (AD) facilities should include a detailed emergency plan should there be an incident, such as a major leak or fire for example. AD leachate is extremely rich in nutrients, which if entering a watercourse, could cause significant environmental harm. We suggest the emergency pan includes nearby watercourses, overlying geology, depth to water table, detailed site drainage plan for example. If possible, an emergency plan should be provided for the Environment Agency to review.

W12: Non-hazardous and hazardous waste landfill
Along with section 5.35, we question whether allowing planning permission for Blackborough End to become an inert landfill and reducing the county's non-hazardous landfill waste capacity to just 1.53 million cubic metres is sufficient for residual waste disposal over the plan period. It is unclear from the Local Plan what the options for residual waste disposal will actually be, except reliance on Refuse Derived Fuel (RDF) and its export. Bearing in mind NCC are keen for sustainable waste management, then the export of RDF by definition its potential energy, does not appear the best long term option. Although waste management options higher up the waste hierarchy are always preferable, there will always be waste streams that can only be disposed in landfill.

Policy WP13: Landfill Mining and Reclamation
Please note that such a proposal will require detailed input and agreement from the Environment Agency.

Policy WP15: Whitlingham Water Recycling Centre
We have previously provided comments stating that we welcomed that the WRC has a long term policy to ensure that further capacity is provided in line with growth. We continue to support long term plans being developed for Whittingham and other WRCs.
W15.2 mentions the sites location is close to the Broads and the associated 'landscape and flood risk concerns'. The location also means there are concerns for water quality due to the close proximity of sensitive protected sites of conservation importance. A statement to acknowledge that water quality needs to be protected should therefore be added to the plan here or in this policy.

Policy MP2: Spatial Strategy for mineral extraction
Point e makes reference to the hydrological catchment around Roydon Common SSSI and Dersingham Bog SSSI. It should be ensured that it is mentioned that it is the hydrological and hydrogeological catchment around Roydon Common and Dersingham bog which should be avoided.
We support the policy to provide a 250m buffer around ancient woodland and designated sites.

Policy MP5: Core River Valleys
This policy should also include "the impact of mineral development on groundwater and the potential to need to work beneath the water table".
Any proposal for quarrying activity within a core river valley should not be approved unless the applicant can demonstrate no adverse effect on the WFD status of the river water body, or its tributaries. A Full WFD assessment (as outlined above) will be required for any proposal for this activity to be carried out within a floodplain.

Policy MP7: Progressive working, restoration and after-use
We are fully supportive of supporting paragraph 7.3 which states there may be suitable ark sites to protect wild-clawed crayfish. Such sites need to be identified well in advance of de-commissioning to that the site can remain bio-secure.
The first bullet point in policy MP7 refers to BAP habitat. Please note that this has been superseded by Priority Habitat (S41 NERC Act, 2006).

Policy MP12: Conventional and unconventional oil and gas development
Unconventional oil and gas production requires a lot of water to be used so it is likely an abstraction licence will be required. In addition, much of this water ends up as wastewater so the appropriate storage, treatment and disposal methods will be required. Discharge to any surface waters or groundwater will likely require a discharge permit and an application will need to be submitted. Having said this, the local plan indicates it is highly unlikely there will be hydrocarbon exploration in Norfolk in the foreseeable future so these comments may not be necessary at this point in time.

Policy MP13: Areas of search for silica sand extraction
As stated in our previous response, policy MP13 needs to address the need for an FRA. An FRA is vital if any of the allocations are located in Flood Zones.
Site Allocations

MIN38: Land at Waveney Forest, Fritton
Following our previous comments, we are welcome the conclusions drawn in this document which state the allocation is unsuitable for allocation.

MIN200: Land West of Cuckoo Land, Carbrooke
The site allocation text mentions that the site will be worked dry above the water table several times. If this is the case then this would alleviate our concerns on impacts on Scoulton Mere SSSI. This however is not included within the policy on page 124 and must be included.

MIN40: Land East of Grandcourt Farm, East Winch
We have concerns regarding this site. In the existing site, permeant dewatering of Carstone is proposed in restoration which goes against our previously raised comments. We would recommend not allocating this site.
Any depth of extraction should be severely limited to minimise de-watering. This could impact of the amount of mineral which can be recovered. As this is a principal aquifer, any de-watering water would need to be returned to the aquifer from which it is taken. An appropriate hydrogeological impact assessment will be required and it may well be that de-watering is not considered suitable at this site, which could limit the amount of mineral that could be recovered.

MIN35: Land at Heath Road, Quidenham
Our comments that we gave to the 2018 consultation remain valid.We have no concerns as it is proposed to work above the water table. This may need to be a planning condition on any application submitted.

MIN102: Land at North Farm, Snetterton
This site is adjacent to Swangey Fen SSSI. We previously stated that we do not consider the site suitable for mineral extraction. We are therefore supportive of the conclusions drawn in this consultation document stating that it is considered unsuitable for allocation

MIN201: Land at North Farm, Snetterton
This site is adjacent to Swangey Fen SSSI. We previously stated that we do not consider the site suitable for mineral extraction. We are therefore supportive of the conclusions drawn in this consultation document stating that it is considered unsuitable for allocation.

MIN6: Land off East Winch Road, Middleton
We are pleased to see that the specific site allocation policy for MIN 6 states the need to work above the water table. However, a hydrogeological impact assessment (not impact assessment) would be required to establish the depth of working.

Min204: Land off Lodge Road, Feltwell
Our previous comments raised within the issues and options stage of the consultation remain valid.

MIN74: Land at Turf Field, Watlington Road, Tottenhill
We agree with the conclusion that this site is unsuitable to be carried forward. If the site were to be taken forward, we would want to see a suitable hydrogeological impact assessment.

MIN76: Land at West Field, Watlington Road, Tottebhill
We are already aware of the planning application that has been submitted in terms of this application and have no further comments to make.

MIN77: Land at Runns Wood, South of Whin Common, Tottenhill
We agree with the conclusion that this site is unsuitable to be carried forward. If the site were to be taken forward, we would want to see a suitable hydrogeological impact assessment.

MIN206: Land at Oak Field, west of Lynn Road, Tottenhill
We consider this site suitable for sands and gravel extraction. The need for a hydrogeological impact assessment must be included within a bullet point in the specific site allocation policy. It's likely that de-watering will be required here.

MIN32: Land west of Lime Kiln Road, West Dereham
We agree with the conclusion that the site is unsuitable to be carried forward. We would want to see a suitable hydrogeological impact assessment if the site was carried forward and, as it is sands and gravels overlying chalk bedrock, it is possible that de-watering would not be considered a suitable option.

Area of search for AOE E
Given previous issues we have had with silica sand extraction in the vicinity of this site, we would expect all extraction to be above the watertable. This is likely to limit the amount of resource that can be recovered. It should be noted that the silica sand is part of a principal aquifer.


SIL01, AOS F, AOS I and AOSJ
The starting position should be not to allow de-watering as outlined in our comments to site allocation MIN40.

Silica Sand search locations
If de-watering is not to occur at the silica sand search locations as mentioned in our response above, this can heavily impact on the amount of resource available.

We trust this advice is useful.

I object to the inclusion of AOSE as a WHOLE; including the overlap area of SIL02. I also object to AOS J. Economically you cannot afford to ignore the reasons set out below.
MOD DIO - The birdstrike risk will greatly increase the potential of loss of aircraft and lives in the air and on the ground. As the area is in a flood risk zone 2 and 3 (3 being the highest) with a high water table and, as stated in MOD (DIO) ignored objection by NCC to the initial consultation, the proximity to RAF Marham makes any 'wet working or restoration' a hazard to the capability of the UK's defence and operational effectiveness of the base and the bird strike risk is proven, any size of water body will attract waterfowl and birds various. 80% of bird strikes occur at take-off and landing, I have provided 3 links for clarity;
https://www.caa.co.uk/Safetyinitiatives-and-resources/Aviation-safety-review/Birdstrikes/
http://www.aoa.org.uk/wp-content/uploads/2016/09/Advice-Note-1-Aerodrome-Safeguarding-An-Overview-2016.pdf
https://mineralproducts.org/documents/MPA_Birdstrike_Guidance.pdf
The area of SIL02 that is now the eastern part of AOS E lies directly under the flight path of runway 01/19 at RAF MArham. The F-35 Lighting II is a single-engine aircraft and if it fails due to a bird strike it would be catastrophic in terms of monetary loss and to the UK's strategic capabilities. F-35 Lighting II has been bought at considerable cost to the British taxpayer at approx £100m per aircraft, is there enough budget to replace aircraft? Many aircraft without ejection seats, including passenger carrying aircraft from other bases use RAF Marham. If any aircraft crashes, the clear up operation encompassing emergency services, loss of life in the air and on the ground and the ongoing mental health issues ensuing from the tragedy would be immense; £50 million was put aside for the aftermath of Grenfell Tower to treat this costly avoidable health burden. The Precautionary Principle of risk must surely be applied in this case.
The default position of Sibelco is to restore wet great areas of former quarries; even smallish bodies of water within 13Km of RAF Marham presents problems due to the increase of potential birdstrike. Even if Sibelco 'dry' worked an area, look at the restoration plan for East Winch, a significant part of that restoration plan is to wet restoration. The water table in SIL02, the preferred area and the whole of AOSE is high and situated in the majority in the highest flood risk zone. If one looks at areas of Bawsey that have been dry worked, the area has been left as a dust bowl with very little flora and fauna. How is that making our county more attractive and wealthy? I refer you to NPPF Sect 17. 204. h. and 205 b and e.
Misuse of Land - To allow quarrying of SIL02 is a misuse of land. It is noted within the preferred options consultation paper at Pg15 section 5.9, that NCC acknowledges some areas in the county are comparable with the worst deprived areas of the country. DEFRA issued guidance in 2017 to guide policy makers on how to lessen the impact of their policies on rural areas (Rural Proofing, practical guide to access impacts of policies on rural areas). If you allow valuable farmland and rural jobs to be traded for silica sand extraction for glass manufacturing in other parts of the country, you are not using the guidance that government policy affords you and are neglecting the needs of your own constituents. Farming may only be 1% of employment in Norfolk but, it is a vital part of the rural economy for Norfolk and the UK nationally. Food security is paramount as we leave the EU and getting Brexit done, so supporting British farming and jobs is vital if we are to take back control (see NPPF Sect 11. Para 118. b. food production and carbon storage). The spurious claim about supporting glass manufacturing jobs is just that; those jobs would still be there without Sibelco as sand for glass making could be imported and recycled cullet would reduce the need for so much sand.
These areas are open farmland and wooded landscape. Rural areas and farming are symbiotic. When visiting the countryside that is exactly what one expects to see; farmland, open spaces, woodland, not industrial sites for 30+ years, then fee paying water parks; exactly how is that opening up the area for locals? Sect 6. Para 83. C and D plus para 84 NPPF should guide you in respecting the character of rural areas.
Recycling - The government states that they require you as a Mineral Planning Authority to achieve "a steady and adequate supply of minerals" as seen in the initial consultation document Pg 20 sect 6 The Strategy - vision to 2036; they, the government do not demand a quota. NPPF Sect 17 para 203 "secure their long term conservation", Sibelco supply you with figures for what THEY say is required but who checks that this is the correct amount for the UK glass industry? If we were to recycle glass this would diminish the need for large amounts of raw material, protecting those finite resources for the future and preserve agricultural land and OUR homes. Sibelco are a major player in the recycling of glass within Europe, is that because they mandated in those countries to save those country's resources? I quote from their own brochure from 2012, "the environmental and economic case for glass recycling is clear....it's a win win equation" (https://slideplayer.com/slide/4056140/). Sibelco should concentrate on waste instead of mineral extraction and invest a world class glass recycling centre at their Leziate plant in West Norfolk, securing hundreds of new jobs for the local economy and using their train line to import glass from other areas of the country and export glass cullet to glass manufacturers who reside outside of Norfolk. Instead, Sibelco make huge profits from the destruction of the UK through quarrying which you facilitate. Flat glass recycling is achievable contrary to our County Councillors' belief and whoever advised him; flat glass is easily recycled. It is accomplished to great effect in Germany, saving silica sand resources. Careful handling of old flat glass is the only consideration, but of course quarrying will be easier and make more profit for Sibelco, a Belgian company with no long term future investment in UK PLC. Let's take back control and cut out the middle man, import the amount of silica sand we truly need and invest in recycling to save an environmental disaster.
The Health Implications of destruction of Open Spaces - The loss of the natural open spaces that provide the opportunity for exercise and help our mental wellbeing will be enormously damaging. There are extortionate costs for the NHS associated with mental health and wellbeing, with spending by CCGs in England totalling £9.15 billion in 2015/16, according to figures published by NHS England. This had gone up to £9.72 billion in 2016/17. That's an increase of around £575 million or 6.3%. I refer you to Sect.8 para 91 b and c. NPPF of your obligation to promote healthy, safe communities.

CATSS - Objection to Quarrying in AOS E and SIL 02 on the grounds of poor process conducted by NCC

The process of public consultation conducted by NCC was conducted poorly, lacked transparency and inclusivity, and failed to reflect the views of residents. Specific deficiencies in the management of the Silica Sand Review and the Consultation on the Norfolk Minerals and Waste Local Plan Review are:

1) Despite NCC's commitment to consult with the community as set out in their Statement of Community Involvement (SCI), the process to date has lacked transparency and was executed so poorly, that communities of Marham and Shouldham were denied a fair and reasonable chance to be involved and most people had no knowledge of the on-going process and had little or no time to respond - despite the process starting before 2015.

2) The SCI sets out four "key principles" by which any consultation process should be judged:
Accountability (taking citizens' views into account), Accessibility (consultation is clear and genuinely accessible), Inclusivity (groups of the community are not excluded), and Efficiency (ensuring methodology delivers results). NCC failed on all four principles. An accessible consultation 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 not violated. It should not require an MP's involvement to ensure that public concern is registered and addressed.

3) Some specific examples of the shortfalls in the consultation process are: a) 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; b) using 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, 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.

4) 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 of residents were taken into account.

5) Despite NCC announcing that SIL 02 has not been allocated, a third of it is now/still included in AOS E. The overlap of the two sites is entirely misleading to residents and statutory consultees, created unnecessary confusion and wasted people's time in trying to understand the boundaries and consequences for consultees. It is clear that NCC needs to do a lot more beyond merely satisfying the minimum legal obligations in this process, to ensure public participation given the magnitude, longevity, and detrimental impact of the projects proposed.

I am extremely concerned by the proposal to include Shouldham Warren as a possible site for future silica quarrying, as per the Norfolk Local Minerals and Waste review, preferred options. Shouldham Warren is a unique and special area, part of a mediaeval warren in mature woodland. The flora and fauna along with the wildlife create a wonderful environment enjoyed by many including cyclists, bird watchers and walkers. I share local residents concerns that this location has been included as a potential future quarrying site. RAF Marham has already raised their objections to neighbouring location Sil 02 by Marham due to the potential for a bird strike and I am therefore at a loss why Shouldham Warren is still under consultation. In previous correspondence I have had with the Secretary of State at MHCLG, reference was made that the government does not set out how much silica sand the country needs, I would be therefore grateful if Shouldham Warren could be removed from the preferred options.

Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019

Thank you for consulting Historic England on the Norfolk Minerals and Waste Local Plan - Further Consultation Draft. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 31st August 2018. Please also see our detailed comments in the attached table, Appendix 1. [ATTACHED]

SUMMARY
Whilst we consider many aspects of the plan to be sound we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan.

Under paragraph 35 of the NPPF some aspects of this Plan are unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound. In summary we highlight the following issues:

a) Insufficient Historic Environment Policy
It is our view that there is currently insufficient policy provision for the historic environment in the Plan. We note that the historic environment is addressed in bullet point l of policy MW2. We remain very concerned that criterion l does not provide sufficient protection for the historic environment. Normally we would expect to see a specific separate policy for the historic environment in a Minerals and Waste Local Plan. This policy is insufficient as it stands. Further detail is set out in the attached table.

b) AOS E and SIL2 - HIA
Whilst we welcome the completion of an HIA for AOSE and site SIL2, we have identified a number of shortcomings in the assessment, particularly the need to address non-designated heritage assets and the wider historic environment and inter-relationship between the various assets in this complex medieval landscape. Our concerns are set out in more detail in the attached table. We suggest that the HIA is revised accordingly to provide a robust evidence base for the Plan. We also suggest that the Plan should not simply mark areas with purple hatching that have been identified by the HIA as unsuitable for extraction, but actually delete those areas from the areas of search and site allocation in the Plan altogether.

c) Other allocations requiring further assessment/proportionate evidence
We have identified a number of site allocations where we continue to have concerns regarding the potential impact on the historic environment, perhaps due to proximity of heritage assets or the highly graded nature of some of these assets. These sites are set out in the attached table and include MIN65, MIN96, MIN213, MIN 209/10/11, MIN25 AND MIN40. For these sites we recommend an HIA is prepared now in advance of the next draft of the Plan. This should provide a robust evidence base for the plan. Any evidence needs to be proportionate, and need not necessarily be particularly onerous. .For most of these sites a fairly brief HIA will suffice. Our site allocations advice note <https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/> provides further advice in this respect and we would be happy to discuss the matter further and advise on a suitable way forward.

d) MIN 207 Land at Pinkney Field, Briston
We recommend that site is deleted from the Plan due to the impact on the historic environment.

Further details of each of these main areas are set out in the attached table.
We have suggested a series of other changes to the Plan. Many of these changes do not go to the heart of the Plan's soundness, but instead are intended to improve upon it. We believe that these comments can be addressed by changes to wording in the plan.

Sustainability Appraisal
We do not have the capacity to review the Sustainability Appraisal report in any detail but did note on quickly skimming the report some surprising conclusions in the report. For example in relation to site MIN 40 - land east of Grandcourt Farm, East Winch where it was concluded that there would be 'No effects expected during the extraction phase' despite a grade II* listed church being located just 50m from the site boundary.

We consider that with such proximity there is likely to be some effects on the setting of this asset. On this brief observation we must question the some of the assessment in the SA.

In preparation of the forthcoming 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 a policy, allocation or document in this letter does not mean that Historic England is content that the policy, allocation or document is devoid of historic environment issues. We should like to stress that this response 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 as a result of this plan, where we consider that these would have an adverse effect upon the historic environment.

If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues.

Original draft response received 30.10.2019
Revised response received 08.11.2019

Highway Authority comments regarding sites proposed for allocation only

MIN 12 - North of Chapel Lane, Beetley
Acceptable subject to continued use of conveyor

MIN 51 & MIN 13 - West of Bilney Road, Beetley
Acceptable subject to suitable access strategy. MIN51 to be accessed via MIN13

MIN 200 - West of Cuckoo Lane, Carbrooke
Acceptable subject to provision of acceptable access at Mill Lane along with provision of passing places between the site and the B1108. Existing haul route and Mill Lane crossing to processing plant to be utilised, or appropriate alternative to be provided. Routing agreement required along with weight limit to protect Carbrooke settlement north of the site.

MIN 202 - South of Reepham Road, Attlebridge
Acceptable subject to use of existing access at Reepham Road and lorry routing via A1270 Broadland Northway

MIN 37 - Mayton Wood, Coltishall Rd, Buxton
Acceptable subject to provision of satisfactory temporary access at C494 Coltishall Road with acceptable visibility. Local highway improvements including widening required, to be delivered via S278 agreement. Temporary access to be removed on restoration of site. Routing agreement required.

MIN 64 - Grange Farm, Buxton Rd, Horstead
Acceptable subject to provision of satisfactory temporary access at C494 Coltishall Road with acceptable visibility. Local highway improvements including widening required, to be delivered via S278 agreement. Temporary access to be removed on restoration of site. Routing agreement required.

MIN 65 - North of Stanninghall Quary
Acceptable subject to access via existing site and routing agreement.

MIN 96 - Grange Farm (between Spixworth Rd & Coltishall La), Spixworth
Acceptable subject to access via A1270 Broadland Northway roundabout at Norwich Airport. Improvements required at the roundabout to formalise access to site, along with relocation of access gates to provide sufficient space for 2 HGVs to stop clear of the roundabout. Relocation of processing plant to south of C250 Church Lane required. Removal of HGV access at Buxton Road also required.

MIN 213 - Mansom Plantation, Stratton Strawless
Acceptable subject to acceptable access at Shortthorn Road and routing agreement via A140.

MIN 206 - Oak Field west of Lynn Road, Tottenhill
Acceptable subject to access via land to north, then A10. Routing agreement required.

MIN 69 - North of Holt Road, Aylmerton
Acceptable subject to provision of right hand turn lane at A148 junction with Briton's Lane, visibility improvements at site access, improvements to Britons Lane and routing agreement, in accordance with the existing allocation.

MIN 115 - Lord Anson's Wood, North Walsham
Acceptable subject to site access being via private haul route to acceptable access at B1150

MIN 207 - Pinkney Field, Briston
Acceptable subject to continuation of existing haul route

MIN 208 - South of Holt Road, East Beckham
Acceptable subject to access via existing right turn facility. Right turn lane to be removed following completion of extraction/restoration.

MIN 209 - Adjacent to A143 (Extension Area 1), Earsham
Acceptable subject to appropriate highway access and local highway improvements at Hall Road

MIN 210 - Adjacent to A143 (Extension Area 2), Earsham
Acceptable subject to site access via Site MIN 209 along with any appropriate improvements to the local highway at Hall Road and the site access. Material conveyor required.

MIN 211 - West of Bath Hills Rd (Extension Area 2), Earsham
Acceptable subject to site access via Site MIN 209 along with any appropriate improvements to the local highway at Hall Road and the site access. Material conveyor required.

MIN 25 - Manor Farm (between Loddon Rd & Thorpe Rd), Haddiscoe
Acceptable subject to suitable access strategy either via Crab Apple Lane, or direct to B1136. Access via Crab Lane would require local highway improvements to include widening to the access and visibility at the B1136 junction in accordance with DMRB. Direct access via B1136 to include visibility in accordance with DMRB.

MIN 212 - Mundham Rd, Mundham
The Highway Authority would not wish to comment regarding the proposed mineral extraction site. However, the location of the processing site is a concern and in particular the routing of HGVs through Trowse village. It would be desirable if the material could be processed at source.

MIN 6 - East Winch Rd, Mill Drove, Middleton
Acceptable subject to use of internal haul route, existing processing facilities, acceptable visibility at access and routing agreement. The allocation would result in a continuation of turning movements at the A47, Highways England should have the opportunity to comment.

MIN 40 - East of Grandcourt Farm, East Winch
Acceptable subject to material processing at existing plant, use of existing internal haul-route required and continued use of rail for material transportation.

SIL 01 - Mintlyn South, Bawsey
Acceptable subject to extraction phased with MIN 40, submission of Transport Assessment with acceptable access strategy. Material transportation to existing processing plant via internal haul route and acceptbale crossing / conveyor of highway and utilise existing rail facilities.

AOS E - North of Shouldham
Subject to submission of Transport Assessment including delivery of acceptable highway improvements. Access to be via A143 with right turn lane with suitable levels of visibility. Access via West Briggs Drove would not be appropriate without significant improvement. Movement of material using off-highway routes, or conveyor/pipeline etc. preferred. Should material be conveyed by highway, a suitable access to the processing facility shall be provided shall be provided at B1145, to an acceptable standard including visibility. Highways England should be consulted regarding vehicle movements at Hardwick Interchange. Material extraction to be phased such that no more than one Silica site at any one time will transport material by road.

AOS F - North of Stow Bardolph
Subject to submission of Transport Assessment including delivery of acceptable highway improvements. Northern site, access via Runcton Road, widening may be required along with improvements at its junction with A10 to include right turn lane. Southern site, access to be via A10 with right turn lane with suitable levels of visibility. Movement of material using off-highway routes, or conveyor/pipeline etc. preferred. Should material be conveyed by highway, a suitable access to the processing facility shall be provided shall be provided at B1145, to an acceptable standard including visibility. Highways England should be consulted regarding vehicle movements at Hardwick Interchange. Material extraction to be phased such that no more than one Silica site at any one time will transport material by road.

AOS I - East of South Runcton
Subject to submission of Transport Assessment including delivery of acceptable highway improvements. Runcton Road would require widening along with improvements at its junction with A10, or A134 to include right turn lane. Movement of material using off-highway routes, or conveyor/pipeline etc. preferred. Should material be conveyed by highway, a suitable access to the processing facility shall be provided shall be provided at B1145, to an acceptable standard including visibility. Highways England should be consulted regarding vehicle movements at Hardwick Interchange. Material extraction to be phased such that no more than one Silica site at any one time will transport material by road.

AOS J - East of Tottenhill
Subject to submission of Transport Assessment including delivery of acceptable highway improvements. Access via A134 to include right turn lane. Movement of material using off-highway routes, or conveyor/pipeline etc. preferred. Should material be conveyed by highway, a suitable access to the processing facility shall be provided shall be provided at B1145, to an acceptable standard including visibility. Highways England should be consulted regarding vehicle movements at Hardwick Interchange. Material extraction to be phased such that no more than one Silica site at any one time will transport material by road.

Response to the Preferred Options Consultation for the Proposed Silica Extraction Site at Land north of Stow Bardolph within the Norfolk Minerals Local Plan Review
October 2019
Prepared by Fisher German LLP on behalf of Mr and Mrs Plaxton

01 Introduction
These representations have been prepared on behalf of Mr and Mrs Plaxton in respect of their land interests at the Wallington Hall Estate. The Wallington Hall Estate is situated within the Borough of Kings Lynn and West Norfolk and is located 8 miles to the south of Kings Lynn town centre. The Estate is situated between South Runcton to the north and Stow Bardolph to the south and is bounded by Lynn Road (A10) to the east and Woodlakes Park to the west.

A proportion of our client's land has been included as an area of search for proposed silica sand extraction within the draft Preferred Options Document produced by Norfolk County Council. The draft Preferred Options document was presented to Norfolk County Council's Cabinet meeting on 5 August 2019 with a recommendation for public consultation to take place between the 18 September 2019 until the 30 October 2019. The recommendation was taken forward and this representation is submitted in response to the Preferred Options document public consultation.
Our clients have not been consulted in any way regarding the proposed inclusion of their land within an area of search for mineral extraction sites by the proposed operator or the County Council. They wish to object to the inclusion of their land, and the wider proposed allocation. This representation proposes that the site referenced as AOS F 'Land north of Stow Bardolph' should be removed as an emerging allocation in the Norfolk Minerals Local Plan. There are specific factors which indicate this site is not suitable and that there are more appropriate site allocations that should be progressed instead that will more than meet the requirements of the Plan.

Site Context
The relevant part of our client's land is shown in Figure 1 [attached] edged red and comprises the Wallington Hall Estate. The black edged plot represents the area of land which has been included as an area of search for minerals extraction.
The plan included at Figure 2 [attached] shows the extent of the proposed area of search (AOS F) which includes land to the north of Stow Bardolph. The parcel affecting our clients land is one of two being considered under this reference and extends to 30 hectares in size. The land comprises a mixture of forestry and agricultural uses and is around 17 kilometres from the Leziate processing plant.
These representations seek to demonstrate that there is compelling justification to remove the AOS F site from further consideration. There are more appropriate options for the proposed silica sand extraction sites that should be investigated further within Norfolk rather than AOS F.

Policy Context
Norfolk County Council are in the process of preparing the Norfolk Minerals and Waste Local Plan Review to consolidate the three adopted Development Plan Documents into one Local Plan in order to extend the plan period to the end of the 2036. It is noted that the Minerals and Waste Local Plan Review is currently at the Preferred Options Public Consultation stage.
The Core Strategy and Minerals and Waste Development Management Policies Development Plan Document (DPD) sets out the Norfolk Minerals and Waste Development Framework for the county. The Mineral Site Specific Allocations Development Plan Document was adopted in 2017 by Norfolk County Council and the Waste Site Specific Allocations Development Plan Document was adopted in October 2013.
The next section of the report provides extensive justification to support the view that Area of Search F should not be taken forward for silica sand extraction site in the Norfolk Minerals and Waste Local Plan review.

02 Area of Search- AOS F Land to the north of Stow Bardolph: Proposed removal of the area for further assessment.
This section of the report sets out the reasoning behind the request for the AOS F removal as an Area of Search for silica sand extraction sites in West Norfolk.
Landowner consent/support

As previously indicated, our client's land constitutes a substantial proportion of the area of search and landowner consent and approval for inclusion as an area of search has not been sought. Our client does not support the inclusion of their land within this area of search and as such extraction in this location is undeliverable. Deliverability is a key test for emerging plan allocations and this area of search fails to meet this test. This area comprises woodland which is valued by the Estate and those in the local area as set out later in this report.

Heritage Impact
There are two Grade I listed buildings situated within 1km of this area of search which importantly includes Wallington Hall, which is located 0.68km from the proposed site, and Church of the Holy Trinity (1km). The Grade I listed Hall is located approximately half a kilometre from the proposed site, and land within the same ownership as the Hall is proposed for inclusion within the area of search. Grade I listed status is particularly special and only buildings which are of exceptional national, architectural or historical importance are designated as Grade I. Such buildings represent only 2.5% of listed buildings. At such close proximity, significant heritage impact is expected if mineral extraction were to occur on land within or adjoining the estate.
The Grade II listed buildings located within 1km of the proposed silica site include the kitchen and service range for Wallington Hall (0.70km), the walled garden to Wallington Hall (0.72km), Almhouses (0.74km), the Cottage (0.74km), the Hare Arms (0.78km), the forecourt wall and gate piers to Wallington Hall enclosing rectangle to south of house (0.79km) and the remains of Church of St Margaret (0.86km). The northern section of the area of search also encroaches within the curtilage of the Wallington Hall Estate. There are a number of listed buildings within close proximity and these would be adversely affected by mineral extraction.
Paragraph 194 of the National Planning Policy Framework (NPPF) states that 'Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification. Substantial harm to or loss of: a) grade II listed buildings, or grade II registered parks or gardens, should be exceptional; b) assets of the highest significance, notably scheduled monuments, protected wreck sites, registered battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional' . Given the proximity of the area of search to both Grade I and II listed buildings a significant impact would be expected from mineral extraction on the buildings and their setting.

Amenity
Residential amenity is a key issue given that the area of search is located approximately 17 km from the Leziate processing plant which is where extracted silica would need to be transported for processing into a marketable product. Therefore, all the properties within 100m of the 17km road network would be impacted by dust, air quality impacts and noise impacts stemming from the HGV vehicle movements in order to move the extracted silica from the site to the processing plant. This would represent extensive impacts spread over a considerable geographical area and impact upon multiple sensitive receptors and residential areas.

Highway Access:
The highways access route from the proposed silica extraction site to the Silbelco processing Plant at Leziate is 17 km in distance. This means that the proposed silica sand extraction site at the land north of Stow Bardolph is located the second furthest distance away from the processing plant, when compared to the other proposed silica sand extraction sites. Additionally, the volume of traffic on the A10 is likely to increase as a result of the number of HGVs required to transport the silica from the proposed site to the processing plant at Leziate. Paragraph 109 of the NPPF states that development should be prevented if there is an 'unacceptable impact on highway safety'. Local information is that there have been a number of accidents along this section of the A10 in recent years and the additional traffic is likely to increase the risk of this.
This factor has not been adequately considered when proposing the area of search and should mean that the site is not taken forward for further consideration. The processing plant is a considerable distance from the area of search and there are more suitable sites significantly closer. The additional movements would potentially have amenity, highway safety and other adverse impacts on the transport route and adjoining areas which has not been adequately assessed to date. Forecast production of 900,000 tonnes per annum would require over 64,000 HGV movements at the site (assuming an average load of 28t per HGV) or 256 per day (assuming 50 working weeks per annum.) This would place an unacceptable burden on an already busy road.

Community/Neighbourhood Value
A proportion of the Wallington Estate is currently used for charity work, in providing horse riding activities for people with disabilities through the woodland. These activities are able to take place through the Magpie Centre and are based from Wallington Hall. The charity gives people with disabilities the opportunity to horse ride and has been operating as a dedicated Riding for the Disabled Association Riding Centre for over 30 years Figures 4 and 5 show the horse riding opportunities that take place at Wallington Hall through the Magpie Centre, which operates 5 days per week.
The centre provides 130 riding and carriage driving lessons a week and is supported by over 50 volunteers from the local community who help with the ponies, lessons, field maintenance and fundraising. This shows that the centre is a valued asset to the local community and is a resource used by a significant number of people, including volunteers and people with disabilities. The implementation of the proposed silica sand extraction site would have a detrimental impact on the ability of the horse riding activities for people with disabilities to continue in the future. The mineral extraction site located adjacent to the area of woodland would generate visual, noise and air quality impacts that would adversely affect the environment in which the horses ride, to the detriment of the community that utilise this space. Therefore, the proposed silica site should be removed as an allocation. This is a valued local community use and mineral extraction would render this location no longer suitable and would be to the detriment of the riding school and all those associated with it. This Estate is a special and tranquil environment for the riding school and it is very important that this facility is retained.

Archaeology:
The area is largely unstudied in terms of archaeology and a more detailed assessment of archaeological remains should therefore be undertaken through an archaeological survey. Sites such as the remains of St Margaret's Church situated 0.86km from the proposed silica extraction site show that there could be historic assets that have not yet been uncovered. Planning policy supports the view that a more detailed assessment of the archaeology in King's Lynn and Surrounding Area should be conducted through a heritage assets assessment which includes a review of the submitted information and relevant on-site investigations. Without such information there is uncertainty regarding suitability and deliverability which means that the allocation is potentially unsound as it cannot be taken forward with confidence that archaeology is not present.

Hydrogeology:
A hydrogeological risk assessment is required and has not been undertaken and therefore the potential impact of extraction on local hydrology is completely unknown. Again, this reinforces the point that the proposed area of search has not been investigated sufficiently and without it being considered suitable, developable and deliverable the allocation would be unsound.

Landscape:
Chiswick's Wood is an ancient woodland situated 1.4km to the east and unnamed ancient woodlands are located 1.2km south east and 1.7km north east of the of the proposed silica sand extraction site.
The area of search boundary includes woodland within the Wallington Estate which is valuable to the setting of the Grade I listed Hall and the local area. National policy seeks to protect woodland and in this case the woodland provides a valuable heritage; landscape and community benefit which should be protected from the adverse impacts associated with mineral extraction.

Ecology:
The proposed silica extraction site situated at the land north of Stow Bardolph includes an area of woodland which could have a potential adverse impact on protected species within this habitat. In addition, paragraph 174 part b) of the NPPF states that plans should 'promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity'. In this case, the potential allocation of a substantial area of woodland could have adverse impact contrary to the aims of national policy.

Summary
Overall, there are substantial grounds to justify the removal of the proposed silica sand extraction allocation on land north of Stow Bardolph. These include the adverse heritage impact on the Grade I listed Wallington Hall and surrounding Estate; the loss of the woodland for use by the Riding for the Disabled Association Charity; adverse impacts on potential ecology within the woodland and landscape impacts associated with the loss of the woodland. The loss of the woodland also has impacts on the wider park and setting, as well as the circular routes used by the RDA. Additionally, the potential for archaeology; potential for hydrological impacts and the noise and dust impacts on the amenity of local residents along the 17km route from the area of search to the processing plant shows the impacts on the surrounding area within West Norfolk.

Moreover, the distance between the land at Stow Bardolph and the processing plant at Leziate is 17km and is a greater distance than all but one of the other proposed silica extraction sites. The greater distance required to transport the silica between the extraction site and the processing plant is likely to have a negative impact on the surrounding road network and contribute to increased traffic flow and congestion, because of the number of heavy goods vehicles required to transport the silica between the proposed silica sand extraction site and the processing plant.
The next section of the report identifies other silica sand extraction sites that are more suitable and sequentially preferable to the AOS_F.

03 Other Silica Extraction Site Options
The following section of the report sets out the alternative silica sand extraction site options available within West Norfolk. It is argued that alternative silica sand extraction sites would be more appropriate to be allocated than the proposed silica extraction site AOS F situated at the land north of Stow Bardolph, which includes a proportion of the Wallington Hall Estate and should be removed from further consideration.

MIN40- Land east of Grandcourt Farm, East Winch
The proposed silica extraction site located at land east of Grandcourt Farm is deemed to be more suitable than the land north of Stow Bardolph. The MIN40 allocation is situated only 1.8km from the Leziate processing plant which would make the transportation process of the silica between the extraction site and the processing plant more sustainable and minimise impacts on the highway and amenity of residents. The silica would also be transported by an internal haul route to the processing plant which would avoid any impact on the local roads. In comparison the AOS_F land north of Stow Bardolph is situated 17km from the processing plant at Leziate and is a much greater distance for transportation between the extraction site and processing plant. The proposed transportation route from AOS F would primarily use the A10 and would have greater impacts on the local roads in terms of congestion and traffic.
The MIN40 site has been put forward by Sibelco UK as an extension to an existing silica extraction site. This is not the case for the AOS_F land north of Stow Bardolph which would be a completely new silica sand extraction site.

SIL01- land at Mintlyn South Bawsey
Firstly, the proposed silica extraction site SIL01 land at Mintlyn South Bawsey is part of a former mineral working which was partially extracted. This shows that the area previously has a history of mineral working, which is not the case for the land allocated at AOS_F north of Stow Bardolph which would be a new greenfield location.
Secondly, the allocation at SIL01 is situated only 700m from the processing plant at Leziate and is much closer to the processing plant than the allocation at AOS_F north of Stow Bardolph, which is located 17km away from the processing plant. Therefore, the proposed allocation at SIL01 would be able to be transported by conveyor from the extraction site to the processing plant and would not impact on the local road network at all. Contrastingly the proposed silica extraction site at AOS_F north of Stow Bardolph would have to be transported by road and this would have far greater implications on the road network.
In addition, the Agricultural Land Classification scheme classifies the land at SIL01 Mintlyn, South Bawsey as being in 'Non- Agricultural' use whereas the land at AOS_F north of Stow Bardolph is classified as being in Agricultural use.

AOS_E Land to the north of Shouldham
The area of search covers 815 hectares which is almost 25 times the size of the AOS_F proposed silica sand extraction site allocation to the north of Stow Bardolph,. The proposed mineral extraction sites information produced by Norfolk County Council show that the MIN 40 land east of Grandcourt Farm proposed silica sand extraction site has an estimated resource of 3,000,000 tonnes for a 33 hectare site.
It is evident that no detailed information was put forward regarding the potential yield of AOS E and that estimated mineral tonnages are not able to be extrapolated accurately. However, there is a possibility given the very large area that this designation covers, that the estimated resource that could be derived from the proposed silica sand extraction site at AOS_E could more than satisfy the forecast need of 10,500,000 tonnes of silica sand required during the plan period. This means there is an argument to only allocate the proposed silica sand extraction site AOS_E to the north of Shouldham because it would satisfy the need for the required silica sand needed during the plan period.
The AOS_E site allocation is situated 2km closer to the processing plant at Leziate than the AOS_F site which is another reason why the AOS_E proposed silica extraction site is a more favourable option. In addition, the AOS_E proposed silica sand extraction site is adjacent to previous and current mineral workings and close to a sand and gravel allocation. This means that the AOS_E site could be seen as an extension to existing mineral operations, which the NPPF would prefer to the opening of a new site. In comparison the surrounding land at AOS_F for the land north of Stow Bardolph has no previous history of mineral extraction.

AOS_I Land to the east of South Runcton
The proposed silica sand extraction site AOS_I land to the east of South Runcton is situated 16km from the processing plant at Leziate, which is 1km closer than the AOS_F allocation. Although this does not seem a significant difference, when the number of HGV movements that will be required to transport the resource between the silica sand extraction site and the processing plant each year is considered, it creates a noticeable increase in impact. This means that the proposed silica sand extraction site AOS_ should be considered a more favourable allocation than the AOS_F land because it is situated in closer proximity to the processing plant at Leziate.
Moreover, the proposed silica sand extraction AOS_I site covers 47 hectares which is over 15 hectares larger than the AOS_F site that incorporates part of the Wallington Hall Estate. This means that the potential resource that could be derived from the AOS_I site is likely to be greater than the AOS_F site. Therefore, the proposed silica sand extraction for AOS_I land to the east of South Runcton is more favourable to be used as a site allocation than the AOS_F land to the north of Stow Bardolph.

AOS_J Land to the east of Tottenhill
The proposed silica sand extraction site AOS_J land to the east of Tottenhill is situated 15km from the processing plant at Leziate, which is 2km closer than the distance between the proposed site AOS_F . Similarly to the point in the previous section (AOS_ I land to the east of South Runcton), although this distance does not seem a significant difference, when it is considered the number of HGVs that will be required to transport the resource between the silica sand extraction site and the processing plant each year, the impact is more significant than it may appear. Therefore the distance in the transportation of the silica between the AOS_J site and the processing plant at Leziate makes it a more favourable option than the AOS_F site allocation.

SIL02 Land at Shouldham and Marham
Although this site has not been allocated as a proposed silica sand extraction site by Norfolk County Council it has been considered as a potential 'Preferred Area'. The estimated resource in tonnes for silica that could be extracted from this site is believed to be 16,000,000 tonnes, which could more than satisfy the forecast need of 10,500,000 tonnes of silica sand during the plan period. There is an argument which supports the idea that if the proposed silica sand extraction situated at SIL02 land at Shouldham and Marham was allocated, then the other allocations would not be needed as forecast for the required silica sand within the plan period would already have been met.
However, the proposed silica sand extraction sites in West Norfolk document prepared by Norfolk County Council suggests that the proposer of the site has given a potential start date of 2027 and estimated the extraction rate to be 800,000 to 900,000 tonnes per annum. Using this information, the full mineral resource at Site SIL02 could be extracted within 20 years and means 9,000,000 tonnes could be extracted within the plan period. This means that if the SIL02 site was allocated as a proposed silica sand extraction site it would go a long way towards securing the silica required during the plan period.
Furthermore the SIL02 proposed silica extraction site should be preferred to the AOS_F site because the SIL02 site is situated only 6km from the Leziate processing plant and this enables the mineral to have the potential to be transported by pipeline rather than road. In comparison the AOS_F proposed silica sand extraction site is situated 17km from the Leziate processing plant and would need to be transported by road. For these reasons, it is evident that the SIL02 proposed silica sand extraction is a more favourable allocation than the AOS_F site.

04 Conclusion
To summarise, the preferred option document for the Minerals and Waste Local Plan Review is currently under review. The proposed area of search AOS F for silica sand extraction includes part of the Wallington Hall Estate. These representations seek to remove this area of search entirely from the local plan review process. There are alternative sequentially preferable areas under consideration and potentially significant site specific impacts associated with AOS F which justify its removal. A further point is that the landowner had not been consulted prior to the allocation of AOS F and does not approve of the submission.
Overall, there are substantial grounds in terms of potential impact to justify the removal of the proposed silica sand extraction allocation on land north of Stow Bardolph. These include the adverse heritage impact on the Grade I listed Wallington Hall and surrounding Estate; the loss of the RDA group use of the woodland; adverse impacts on potential ecology within the woodland and landscape impacts associated with the loss of the woodland; the potential for archaeology; potential for hydrological impacts and the noise and dust impacts on the amenity of local residents along the 17km route from the area of search to the processing plant.
It is appropriate to allocate sequentially preferable areas of search instead of area of search F which is not required in the extended plan period for proposed silica sand extraction and because of its size would not make a significant contribution to the tonnage required to meet the Plan's needs. There are sites situated substantially closer to the processing plant at Leziate that have a greater potential to extract a higher tonnage of silica through being larger site allocations in terms of area. Therefore, the proposed silica sand AOS_F extraction site should be removed.

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

We object to the planned proposal in AOS E and the overlap of SIL 02 on economic grounds -
1. The enormous increased risk of birdstrikes to the aircraft flying at RAF Marham. The sums of money that would be required to replace just one F35 aircraft is more than Sibelco's annual turnover in the UK. The cost of a repair from a birdstrike can run to £millions.
2. There is a minimal increase in employment opportunities.
3. Debatable claims of adding value to the local economy.
4. No independent scrutiny of the amounts of silica sand required; Sibelco, the company with the monopoly for silica sand extraction in Norfolk supply the figures.
5. The loss of prime agricultural land with the loss of local jobs and damage to the local agricultural industry the loss of the land would cause. This at a time when the UK should be looking to increase our own food production with our imminent departure from the EU.
6. The loss of the natural open spaces that provide the opportunity for exercise and aid with our mental well-being, which in turn decreases the call on medical intervention and a decrease in cost for the NHS.
7. The stunting of community growth that the siting of a quarry would inevitably cause at a time when our Borough Council's Local Plan proposes Marham as one of its primary growth areas.
8. The lack of any plan to improve the recycling of glass, especially clear and flat glass, in order to reduce the amounts of raw materials required, and increase the amount of recycled clear glass cullet used in the manufacture of new glass, is an economic and environmental mistake. Economically improved recycling would increase the employment opportunities in Norfolk; environmentally, it would ensure less land (agricultural or otherwise) is destroyed unnecessarily when there are alternatives.
9. The sites are adjacent to Nar Valley Way, a long-distance public right of way along the Nar River SSSI, which brings many tourists to the area - tourism revenue for local business will be detrimentally affected.
10. The only economic winner is Sibelco, a private Belgian company whom NCC have no obligation to, unlike their obligation to the economic prosperity of the taxpaying Norfolk population and the populations surrounding the proposed areas.
Overall, quarrying for silica sand in AOS E and the overlap of SIL 02 do not make economic sense for Norfolk or the UK and a more detailed objection will be forthcoming.

We object to the planned proposal in AOS E and the overlap of SIL 02 on environmental grounds -
1. The removal of the forests in AOS E ignores the Government's current plan to increase the number of trees in the UK for the benefits to the atmosphere that trees possess.
2. The removal of the forests in AOS E will remove the environment that supports the myriad of flora and fauna they contain, including may species on conservation lists.
3. The removal of the forests in AOS E would be an action against the reduction of C02 and is in contravention of the Climate Change Act 2008 and the UK Government's stated aim of reducing to net-zero (1990 level) the volume of greenhouse gases in our atmosphere by 2050. It is also in opposition to the Government's '25 Year Plan to Improve the Environment' - "Planting more trees provides not just new habitats for wildlife - it also helps reduce carbon dioxide levels and can reduce flood risk." - Secretary of State.
4. The removal of the forests in AOS E would change the local environment such that the people who currently use them for physical recreation and well-being will be denied that connection with nature which has been proven to promote physical and mental health.
5. The quarrying of silica sand within AOS E and SIL 02 has great potential to pollute the primary and secondary aquifers that lie beneath the area. This would be an ecological disaster for our drinking water.
6. Adverse impacts on the hydroecology of the Nar River SSSI, a spring-fed chalk river with high conservation value.
7. What is the NCC plan for when this 'finite' resource runs out? Without such a plan how can NCC possibly make any decision to allow quarrying for minerals that will devastate our
environment irrevocably?
8. "Our environment is our most precious inheritance" - DEFRA
Overall, NCC does not have a sound plan to ensure the protection of our environment. The current M&WLP plan is juxtaposed with the Government's stated objectives for the environment.

We object to the planned proposal in AOS E and the overlap of SIL 02 on historical grounds -
1. A quarry in AOS E and/or the overlap of SIL 02 would irreversibly change the local landscape and affect the historical character of the area and the many historical monuments and their setting. This is supported by NCC's own Historic Environment Impact Assessment of AOS E and SIL 02.

We object to the planned proposal in AOS E and the overlap of SIL 02 on health grounds -
1. To quarry in AOS E or the overlap of SIL 02 would remove an outdoor area used by thousands as their recreational area for physical exercise.
2. Outdoor exercise in areas such as AOS E and the overlap of SIL 02 are proven by research to improve the nations physical and mental health. To lose such areas to mineral quarrying would amount to a contemptuous act on the population and a cost to the tax-payer via the increased workload on the NHS that would be an inevitable consequence.

Additionally, the consultation process undertaken by NCC has lacked transparency and engagement with the community and was executed poorly - i.e letters sent to only 10 households within an arbitrary boundary of the site, ineffective methodologies for consultation, residents' concerns raised in the first consultation have been ignored. NCC is deliberately obfuscating the issue and misleading consultees by announcing the removal of SIL 02 when in reality a third of it is now/still included in AOS E.

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

NCC's M&WLP Vision plus Policies WP1 and WP2, Objectives WSO1,2,4,6 and 8 and MSO2,3,8 and 10, all fail without a plan for a coherent, modern glass (especially flat and clear glass) recycling plan investing with industry partners in a technologically advanced infrastructure that will save raw minerals and energy, reduce the emission of greenhouse gases, create 100s of jobs in Norfolk and, just as importantly, stop the wanton destruction of the Norfolk landscape and biodiversity with a 'business as usual' attitude to mineral extraction in our county. The detailed reasons are set out below.

Objection to Quarrying In SIL 02 and AOS E and the overlap of both areas, in favour of recycling/reusing glass - CATSS (Campaign Against Two Silica Sites)

The Ministry of Housing Communities and Local Government document, the 'National Planning Policy Framework', sets out the Government's planning policies for England and how these should be applied. The document states (Section 2: Achieving Sustainable Development, at para 7), "The purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs" - Resolution 42/187 of the United Nations General Assembly. The document also states (Section 17: Facilitating the Sustainable Use of Minerals, at para 203), "It is essential that there is a sufficient supply of minerals to provide the infrastructure, buildings, energy and goods that the country needs. Since minerals are a finite natural resource, and can only be worked where they are found, best use needs to be made of them to secure their long-term conservation." As stated, sustainable development should not compromise future generations to meet their own needs, and that minerals are a finite natural resource; therefore, it is clear that quarrying is not the future. So what is the UK strategy and vision to ensure we do not compromise future generations ability to meet their own needs, and make the best use and secure the long-term conservation of minerals, in particular, silica sand for glass making? And locally, what are Norfolk County Council (NCC) doing via their Mineral and Waste Local Plan (M&WLP) to do the same and correct this cognisant failure with respect to the scarcity of high purity silica sand?

"The environmental and economic case for glass recycling(1) is clear. Cullet helps glass producers drive down energy consumption and emissions, and means less landfill and waste disposal. It's a win-win equation that has created a dynamic, global glass recycling market with a number of national and international players. So how do you choose the right partner to help you achieve the full potential of recycling?" - Quote from Sibelco's brochure(2) on recycling glass in Feb 2012. Sibelco supply, by far, the majority of glass making quality silica sand to glass manufacturers in England and Ireland but they are not involved at all in the recycling of glass in the UK.

(1) For clarity, wherever the word 'recycling' is used in this document it is referring to the act of sorting collected glass into different colour streams, processing it into high-quality glass cullet that is subsequently used in the manufacture of high-quality glass material including clear and flat glass.
(2) Pure Sense Recycling-Sibelco Green Solutions- https://issuu.com/salez-poivrez/docs/sibelco.glassrecycling.brochure.feb2012_v4

NCC uses the National Planning Policy Framework (NPPF) document as one source for updating its M&WLP. The NPPF states, 'Planning policies should: .... so far as practicable, take account of the contribution that suitable or secondary and recycled materials and minerals waste would make to the supply of materials, before considering extraction of primary materials...' (Sect 17, para 204. b). There is no attempt within the NCC M&WLP to discuss how improved recycling or reuse 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, (fulfilling mineral strategic objective MSO3 on pg 21 of the NCC M&WLP, Preferred Options July 2019) thereby extending the period of self sufficiency in glass manufacturing within the UK and show serious intent to endorse and implement the latest DEFRA (Department for Environment Food and Rural Affairs) policy document on waste management(3). Expanding the country's glass recycling ability in both efficient collection and up to date processing of the collected glass, especially clear glass, would vastly increase the number of jobs available in the UK and particularly Norfolk if it led the way in developing such a policy. In addition, NCC would be leading the way for innovative strategies to fulfil the Department for Business Energy and Industrial Strategy's 'Clean Growth Strategy'(4) document, in particular towards the ambition of Zero Avoidable Waste. The NCC M&WLP document 'Waste and Management Capacity Assessment', refers to EU legislation, the Waste Hierarchy, the principal of self-sufficiency in waste management and the National Planning Policy guidance for waste management; however, there is no attempt within the M&WLP to satisfy or comply with any of the above policies or advice with respect to recycling glass from within Norfolk. Additionally on pg 58 at section W13 of the M&WLP (Landfill Mining and Reclamation), there is mention of the 'circular economy' with respect to waste; however, it is not referring to glass recycling which is the ultimate circular economy due to glass being 100% recyclable. Overall, without a serious plan to upgrade glass recycling then the M&WLP is fundamentally flawed.

(A summary of the policies and objectives from the M&WLP that are not complied with can be found at pgs 8+9 of this document).

(3)Our Waste, Our Resources: A Strategy for England- https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/765914/resources-waste-strategy-dec-2018.pdf
(4)Clean growth Strategy - https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/700496/clean-growth-strategy-correction-april-2018.pdf

NCC should also be considering promoting glass reuse(5) which has the advantage of a reduction in local council services requirement for collection of glass(6) because less glass would be thrown away; plus, reuse would mean less raw material requiring to be supplied to the glass manufacturing industry. This would fulfil waste policy WP1 (pg 45) of M&WLP Initial Consultation and W0.2 Pg 41 of preferred options draft plan July 19 but only with a rewording to deliver a technically advanced facility that recycles as well as reuses glass. During the period where improved glass recycling and reuse is introduced, the UK could import silica sand for glass manufacture to bolster the currently available cullet and existing quarrying, thereby saving further unnecessary destruction of the countryside from the allocation of new areas for silica sand extraction. Indeed without championing and implementing a vastly different, technologically advanced glass recycling policy within Norfolk, then NCC fail their own M&WLP Preferred Options ' Vision to 2036' (pg19) in every respect.

(5)Study on impact of deposit return scheme - https://feve.org/study-on-impact-assessment-of-deposit-return-schemes/
(6)Environmental Protection Act 1990 Schedule 22A - https://www.legislation.gov.uk/ukpga/1990/43/schedule/2AA

Glass recycling(7) also contributes to British business as a whole: estimates indicate that 500 jobs are created for every 100,000 tonnes of glass collected for recycling. If we, as a country, recycled all the glass we currently throw away to landfill, it would create 7,500 sustainable new jobs overnight. NCC is failing to take the opportunity to create a vibrant local employment market in a green industry that at the same time will preserve and sustain the stocks of silica sand, protect the biodiversity of the countryside and health of the residents of Norfolk, whilst helping to reduce CO2 emissions. A continuation of quarrying will not add to the jobs market in Norfolk; however, implementing a radical glass recycling programme will create jobs at all levels from manual labour through to technical skills, and graduate to management. In addition, no jobs would be lost from the haulage industry as they would be required to move glass rather than silica sand.

(7) Cheaperwaste.co.uk - Glass Collection Services - http://www.cheaperwaste.co.uk/services/glass-collections/

Sibelco, the global company who proposed the extraction of silica sand from AOS E, including the overlap from SIL02 , and who currently extract silica sand within Norfolk, is a major partner in glass recycling in other countries around Europe (see Sibelco statement at the top of pg 1 and linked at footnote 2). On their company webpage, they make a heavy pitch for their green recycling credentials in respect of glass and how they are in partnership with High 5(8), a glass recycling company boasting the most up to date recycled glass processing plant in Europe that revolutionises glass recycling. However, Sibelco makes no attempt to do the same in the UK. Despite policy WP11 (pg56 of M&WLP) that states disposal of inert waste to landfill is the least preferred option, NCC think it is appropriate to allow the vast majority of glass waste in Norfolk to go to inert waste landfills or to refill previous cavernous extraction sites with the very material that was quarried in the first place. They think it is appropriate to destroy a rural setting through deep quarrying for silica sand for the convenience and profit of a private Belgian company, and the perceived need to continue to supply raw materials at the same rate as they always have. Policy WP11 plus many others (summarised at the end) would be fulfilled if NCC were to forge a coherent glass recycling policy leading to less raw silica sand required, less destruction of our countryside and less landfill.

Additionally, Sibelco with its expertise in recycling abroad and the fact that they have a railhead at Leziate, could be the perfect provider of this clean green industry by investing in the infrastructure required for a technologically advanced glass recycling facility at their Leziate plant. This would bring the jobs West Norfolk deserves. The arrival of glass bottles etc and the departure of the processed cullet via the railhead at Leziate would fulfill the aims stated in the M&WLP, para 9 'Transport' on pg34, by alleviating the impacts of HGV transport that surround the mining of minerals, such as silica sand, which places a heavy burden on the road transport system. It also has the added bonus of the reduction in pollution. Whilst transport by HGV may be unavoidable in some circumstances, rail transport would help to fight climate change and fulfil Government and NCC policy to reduce CO2 emissions.

(8)Sibelco Glass Recycling Video - https://vimeo.com/242176163

Glass is 100% recyclable(9) - it can be melted and made into new containers again and again with no loss of quality or performance. However, demand for cullet(10) often outstrips supply. Glass manufacturing is necessarily a continuous process and a lack of cullet can mean manufacturers must use a higher proportion of raw material (silica sand) than they would otherwise choose(11). In line with the UK Climate Change Act, British Glass is co-ordinating the endeavours of the glass manufacturers, the mineral industry and food/drinks industry to reduce CO2 emissions through enhanced glass recycling plus a move toward more green coloured glass usage(12). NCC and Sibelco cannot ignore this but are making no plans to aid this legal obligation for the UK to reduce CO2 emissions.

(9)Brit Glass - Recycling - https://www.britglass.org.uk/our-work/recycling
(10)Waste glass that has been sorted and cleaned for re-melt.
(11)Brit Glass - Recycled content - packaging - https://www.britglass.org.uk/sites/default/files/1709_0001-E1-17_Recycled%20content_0.pdf
(12)Department for Business, Energy and Industrial Strategy's Decarbonisation and energy efficiency action plans - https://www.gov.uk/government/publications/industrial-decarbonisation-and-energy-efficiency-action-plans

Recycling of glass needs to be split into several discussions: coloured glass, clear flint and flat glass, and reuse. These discussions are not mutually exclusive. Recycling coloured glass is relatively well established in the UK and we produce a surplus, much of which we export but could be put to better use in the manufacture of food and drinks packaging(13), aggregates, sports arenas and horticulture. A green recycled bottle can contain up to 90% recycled glass. Clear glass jars and containers may contain 0-25% of recycled flint glass. The difference in the amounts of recycled glass used in coloured vice clear glass jars and containers is because the producers14 of food and drinks packaging insist on having very high quality (colour clarity - clear) in their jars and containers. Studies(15) have shown that the general public (~73-98%) do not need or expect their foodstuffs to be packaged in clear jars and containers of such high quality. Indeed when presented with the facts that, a) by packaging products in coloured glass instead of clear glass there is a demonstrable reduction in the energy and water consumption required to produce the glass, plus a reduction in the CO2 emitted, and b) the economic benefit of generating more jobs in the recycling industry, then any negative impact the public has to the use of coloured glass jars and containers, instead of the clear glass equivalent, is further reduced. Unbelievably, in 2010 instant coffee was the largest consumer of glass jars by weight at 700 000 tonnes, all of which was clear glass! (See pg 30 of footnote 15). Therefore, in addition to recycling our glass jars and containers better, there also needs to be a re-education of the manufacturers of food and drinks who insist on high-quality clear glass for their products' packaging - it is neither required or needed. The public have been persuaded, quite rightly, that the amount of plastic they consume needed to be reduced; it would not take much to persuade them about the need to package products in non-clear/less clear glass jars and containers, which in turn would put pressure on the producers to reduce the amount of raw silica sand they consume. Whilst our food and drinks manufacturers continue to insist on high-quality clear glass the problem is compounded by the products we import in clear glass packaging which is glass of an inferior quality to that manufactured in the UK. This means we are exporting high-quality clear glass containers that other countries can recycle and use in new glass manufacture, whilst we receive inferior quality clear glass containers that, at present, cannot be recycled for use in high-quality clear glass manufacture in the UK and the majority goes to landfill. As a result, the UK has to extract more raw silica sand if it is to continue to sustain the use of high-quality clear glass packaging for the majority of our food and drinks produce. Instead, we should be importing silica sand to make up the shortfall in raw materials for clear glass production due to our inadequate glass recycling industry. NCC pat themselves on the back at their 44.9% recycling rate which masks the fact that this is for all recyclable materials; however, their recycling of glass is woefully inadequate(16). The summary at W1.7 on pg 44 of the M&WLP states, 'The waste forecasts do not take into account potential improvements in waste reduction and prevention' - this is a deficit in forward planning by NCC in regard to advancements in glass recycling.

(13)This requires manufacturers of food and drinks products currently packaged in high-quality clear glass containers to be 'persuaded' that the public would accept their produce in a lesser quality glass package or even in a different colour (see link at footnote 15)
(14)Feasibility Study For The Reduction of Colour Within the Glass Furnace - https://www.glass-ts.com/userfiles/files/2004%20-%20WRAP%20-%20Feasibility%20Study%20for%20the%20Reduction%20of%20Colour%20within%20the%20Glass%20Furnace.pdf
(15)Going Green - A consumer trial to identify opportunities for maximising the use of green glass for wine and spirit bottles - http://www.wrap.org.uk/sites/files/wrap/Going_Green_report_Full_version_3_.ae138c43.10768.pdf

Flat glass recycling is more problematic due to the way industry disposes of it. For flat glass to be successfully recycled in the quality and quantity that it could be, it needs to be kept clear of contaminants, i.e. it cannot be thrown in with rubble and other waste on development sites. Flat glass requires a ceed change in the building industry and waste recycling centres throughout the UK in how it should be handled to ensure it remains usable to recycle for use in the manufacture of new clear flat glass. There are many examples in Europe of how this is achieved to good effect (Reiling in Germany, for example(17) and (18)).

(16)Brit_Glass Maximising the Recyclability of Glass Packaging- https://www.britglass.org.uk/sites/default/files/00017-E2-19_Maximising_the_recyclability_of_glass_packaging_WEB.pdf
(17)Reiling Glass Recycling Video - https://www.youtube.com/watch?v=zTfrumfUisU
(18)Reiling Flat Glass Recycling Document - https://reiling.de/de/flachglas

Some benefits of recycling our glass more efficiently are as follows:

For every tonne of glass recycled it saves 1.2 tonnes of raw material; therefore, less silica sand needs to be quarried, saving our countryside and preserving the minerals.

The energy saved from recycling 1 glass bottle is enough to power a light bulb for 4 hours.

Glass is 100% recyclable and can be reused over and over again.

Glass that is thrown into landfills will never decompose, putting a great strain on landfills with too much glass content. In the UK 28 billion glass bottles and jars end up in landfills each year; 14 billion from households. More recycling = less landfill + less quarrying + less destruction of the countryside.

Bottles and jars recycled saved around 385,000 tonnes of CO2 emissions over the past year, equivalent to taking more than 120,000 cars off the road. This reduction in emissions of greenhouse gas could be further reduced by more efficient recycling.

A higher content of recycled glass cullet used in the manufacture of new glass jars and bottles reduces the temperature required in the manufacturing process using 30% less energy. This also extends the life of the furnace.

Every 100 000 tonnes of glass recycled creates 500 new jobs. Any perceived job losses from the silica sand extraction industry would be far outweighed by the number of new, environmentally sound jobs in the glass recycling industry. The UK throws away nearly 1.5M tonnes of glass bottles and jars which, if recycled, could create 7500 new jobs overnight.

Producing new glass using recycled glass reduces air pollution by 20% and water pollution by 50%.

Sibelco's own literature for the environmental and economic case for glass recycling is linked here(19). Their own conclusion, on slide 11, leads one to ask the question, 'why aren't they leading glass recycling here in the UK?'. The assumption has to be because they aren't mandated to, therefore why would they if it impacts their profit margin.

A complimentary system to recycling is reuse(20). Bottles and jars can be reused many times before, due to wear and tear, the requirement to go through the waste cycle for recycling. This is not a new idea as it was the norm for many bottle types during the 1950s, 60s and 70s, prior to the introduction of single-use plastics and aluminium cans. To reintroduce the reuse of glass containers now would require a change within the psyche of the general public, producers and retailers. However, as recently seen with the introduction of a charge for plastic bags the public can be persuaded to reuse their own bags; a similar scheme could be adapted for glass containers. This type of system is already in use in countries such as Germany, Denmark, Sweden, Australia and the USA, saving raw materials, reducing litter, and saving costs for local councils in refuse collection.

(19)Sibelco Nov 2012 - Glass recycling: environmental and economic case
(20)Study on impact of deposit return scheme - https://feve.org/study-on-impact-assessment-of-deposit-return-schemes/

Finally, Norfolk County Council is required to preserve the raw minerals in their county. In the case of silica sand, this is not being achieved by defaulting to quarrying; which, in turn, is not fulfilling the NPPF guidance quoted above - to look to recycle before extracting raw materials. NCC certainly do not do this; they do not recycle glass at all, they merely collect it, call that recycling and transport it to other counties for onward processing, whilst continuing to quarry raw materials. This is neither intelligent nor eco-friendly, it doesn't fulfil objective SA11 of the Initial Sustainability Report (pgs 14+16), nor promotes sustainable use of minerals. Additionally, it doesn't fulfill the Waste Strategic Objective, WS01- minimise waste, or the Mineral Strategic Objective, MSO3 - encourage sustainable use (pgs 20 and 21 of the M&WLP Preferred Options document). Without a technologically advanced glass recycling policy NCC's M&WLP also fails their own policies WSO 2, 4, 6, and 8; MSO 6, 8 and 10 (pg 20 +21 M&WLP); MW4 (pg36, M&WLP); and MP1 (pgs 66/67 M&WLP). In addition and perhaps most importantly, the UK Government signed up to The Paris Agreement on climate change in 2015. This accord legally binds the UK to reduce its CO2 emissions by 80% by 2050 (against the 1990 baseline). In terms of AOS E, including the overlap area with SIL 02 that still remains in the M&WLP, there is no mention of how the CO2 emissions are to be reduced or mitigated for compared to the standard silica sand quarry. The suggested wet dredging by electric barge in SIL 02, and hence by extension to the remaining portion of SIL 02 as part of AOS E, then pumping the slurry by pipeline over a distance of 6-8km must have nearly as large a carbon footprint as alternative transport by HGV. The power required for the barge and the pumps for such a long pipeline will not be an insignificant amount. The further away from Leziate silica sand is quarried only highlights the lack of a serious recycling policy through which NCC can comply with the NPPF guidance (to use recycling before raw materials) and the legal obligations to reduce greenhouse gas emissions (aided by recycled cullet use in making new glass).

The aggregate mineral industry has played its part in improving resource use efficiency (reducing CO2 emissions) by helping to increase the amount of previously used construction material that is recovered and reprocessed to create recycled aggregate. The proportion of recycled and secondary aggregate used in UK construction has increased over the last 20 years (MPA, 2015). If that industry can recycle better why can't the glass industry, with a product that is 100% recyclable, improve and strive for 100% recycling of glass and reduce their reliance on quarrying raw materials?

Whilst there is currently enough silica sand reserve in Norfolk until 2027, the legally binding commitment to the Paris Agreement and subsequent UK Climate Change Act should require NCC to cease committing any further areas for silica sand extraction until the Government and British Glass complete their initial studies into improved recycling and increased use of green glass products. In the meantime the UK glass industry could import glass quality silica sand through a just-in-time principle, if required, to bolster the current cullet available for glass manufacture.

Summary of the Policies and Objectives that are flawed due to the lack of any SERIOUS glass recycling plan for Norfolk within the M&WLP Preferred Options July 2019


The National Planning Policy Framework (NPPF) states in (Ch 17, para 204.b) that authorities should 'take account of...recycled materials...before considering extraction of primary materials..'. The NCC M&WLP does not take this into consideration as it has no SERIOUS glass recycling plan.

NCC Vision 2036 - M&WLP

No SERIOUS glass recycling plan in place to ensure the longevity of self- sufficiency in silica sand.
No SERIOUS glass recycling plan in place to enable the aim of self- sufficiency in waste management.
No SERIOUS glass recycling plan in place to enable the aim of making the public and business take more responsibility for waste prevention, reuse and recycling.

Waste Strategic Objectives - Initial Sustainability Report Part B May 2018 and M&WLP Preferred Options Jul 2019

WSO 1 - No SERIOUS glass recycling plan in place to support the objective to prevent/minimise waste in line with the Waste Hierarchy.
WSO 2 - No SERIOUS glass recycling plan in place to support the aim of increasing the amount of waste reused, recycled and recovered.
WSO 4 - No SERIOUS glass recycling plan in place to enable the aim of self-sufficiency in waste management (Vision 2036).
WSO 6 - No SERIOUS glass recycling plan in place to support the reduction of greenhouse gas emissions (a legally binding objective), minimise landfill (in Norfolk and nationally), and reduce waste transport distances.
WSO 8 - No SERIOUS glass recycling plan in place to recognise the importance of waste management as a generator of local employment.


Mineral Strategic Objectives - Initial Sustainability Report Part B May 2018 and M&WLP Preferred Options Jul 2019

MSO 2 - No SERIOUS glass recycling plan in place to increase the timescale of providing a steady and adequate supply of silica sand by reducing the quantity of raw material required for the manufacture of glass due to an increase in the quantity and quality of recycled glass (Vision 2036).
MSO3 - No SERIOUS glass recycling plan in place to encourage the sustainable use of minerals by using secondary and recycled aggregates (NPPF, Ch 17, para 204.b).
MSO 8 - No SERIOUS glass recycling plan in place to minimise the impact of climate change through the reduction of CO2 emissions due to an increased use of high quality recycled glass cullet in glass manufacturing.
MSO 10 - No SERIOUS glass recycling plan in place that ensures more public access to the countryside due to the decrease in quarrying area required for silica sand because of the increased use of high quality recycled glass cullet.

Presumption in Favour of Sustainable Development - M&WLP Preferred Options Jul 2019

A SERIOUS glass recycling plan would ensure increased local employment that far outweighs the numbers and level of jobs generated through quarrying alone, as well as reducing the size and number of areas required for silica sand extraction and aiding the reduction of greenhouse gas emissions.
MW 4 - No SERIOUS glass recycling plan in place to support reductions in greenhouse gasses to reduce climate change.

Waste Management Specific Policies - M&WLP Preferred Options Jul 2019

WP 1 - No SERIOUS glass recycling plan in place to increase the amount of glass recycled within the waste management capacity to be provided despite all of the positive factors that would bring to Norfolk - increased employment in a green industry; less CO2 emissions; increased time for self-sufficiency in silica sand; protection of the Norfolk countryside (biodiversity, geology, archaeology, public access).

Mineral Specific Policies - M&WLP Preferred Options Jul 2019

MP 1 - No SERIOUS glass recycling plan in place without which the planned extraction figures are flawed as they are based on what the mineral extraction companies supply to NCC as the 'required need'. With increased recycling of glass, especially clear glass the figure of 'required need' for silica sand would be reduced.

I object to AOS E, including Shouldham Warren and the overlap with formerly SIL 02, in the Norfolk Minerals and Waste Local Plan, I strongly object to the fact that Norfolk Country Council has deliberately misled residents by announcing the removal of SIL 02 when in reality a third of it is now/still included in AOS E.

As a member of the community, I echoed the concerns held by the MOD when they objected to these proposals, due to the fact that the plan of a wet working and restoration in close proximity to RAF Marham. well within the statutory 13 kms limit, will increase the risk of "bird strikes" or worse case scenario, end in an aircraft crash and potential loss of life. The economic cost of such a mishap would be far greater than £100M just to replace an F35 Lightening 11: add to that the costs for the emergency services and for the immediate and subsequent treatments through the NHS for the physical and Mental injuries, and the financial costs become an unaffordable risk.

I object to the negative impact on villages/visitors health, According to Public Health Profile 2018, our villages have higher levels or respiratory problems and reduced respiratory function ( COPD Asthma ), silica particles will exacerbate these conditions. Loss of natural spaces has been proven to adversely affect health, mental and physical, This fenland and forest ( Shouldham Warren ) is our community's public open space, our gym and our sanctuary, hundreds of people use it daily for physical recreation and social wellbeing interactions.

I object to the fact that the plan would ruin the Landscape, Shouldham Warren, the Countryside, including habitats for Birds, Animals, and Insects. The Warren is home to 64 species of conservation concern. including endangered species like Bats, Nightjars and Woodlarks. We need nature and tree's now more than ever to combat pollution and climate change.

I object to the unsustainable use of a finite mineral resource, when the county only recycles a fraction of the glass already in circulation. There are national government policies and guidance including DEFRA and the Dept for Business Energy & Industrial Strategy that are clearly being ignored.

I further object to the worrying possibility of damage to, our Public Water, it is very concerning that if quarrying was allowed to take place, whether through wet or dry working, the water supply could be affected, as the whole area of AOS E has very productive to moderate productive aquifers.

A further objection relates to the lack of restoration plans. Any restoration would take in excess of 30 years, until then the community would suffer from a devastated industrial landscape, increased flow of heavy articulate lorries, preventing any appreciation of its landscape and countryside. Sibelco has a poor track record for restoration in the area, and have failed to ensure safety of sites after extraction - it's Bawsey site was the cause of deaths by drowning. The company has not been a 'good neighbour' and had done nothing to engage witht the community or alleviate residents' concerns.

Lastly, I object to the fact that there would be no benefit to the local community or economy if this proposal goes through. What is clear is that a number of local communities will bear the brunt of a hugely disruptive and harmful industrial process; that a very popular public amenity enjoyed by a much larger section of the population will be permanently lost, and the only beneficiaries of this development will be a few landownders, Norfolk County Council, but principally the private owners of the Belgian compact Sibelco.

Given the County Councils are responsible for the private provision of public services for taxpayers and community wellbeing, and not the promotion of harmful and irresponsible businesses that present no local benefit, but with multiple risks, dictates that Norfolk County Council should put public interest before private profit.

I personally walk my daughter to school in Wormegay everyday. The A134 is already hugely used by industrialised traffic, with this additional traffic, this would make this road leading to the Watlington roundabout an accident hotspot, increase pollution near the school, and do nothing to enhance the health and wellbieng of those living in this area. In a time of increased focus on environmental responsibility and health and wellbeing, to allow this quarry would be a disruptive and retrograde step, rather than the responsible action required at this stage in the 21st century.

Please accept this e-mail as a record of my objection.

In accordance with your advertised Public Consultation I wish to object to the inclusion of AoS-E as a Preferred Option for Silica Sand Quarrying.
My reasons are as follows:-
i) Biodiversity
Given that AoS-E is predominantly a Forestry England working plantation, we have here a well regulated environment with conifers and birch variously harvested in a fell and plant cycle. In addition there are avenues of established broad leaf trees of considerable age and individual examples of veteran trees throughout.
The soil conditions allow all the native British snakes to thrive, habitats for many English mammals exist here and the mature forest areas are used as breeding habitat by raptors, and other woodland birds. There are several badger setts amongst the plantations.
The area includes a designated County Wildlife Site.
On the adjacent Button Fen, within AoS-E, is the Ten Acre ancient woodland.
In the event of quarrying, Natural England imposes an obligation for restoration to make a net gain in Biodiversity terms which would clearly be impossible and AoS-E should therefore be removed from consideration.

ii) Geodiversity
The 300 acre, 20m high hill at Shouldham Warren is described by the Norfolk Geodiversity Partnership, to which the County Council is affiliated, as:
"The hill is a notable outlier of early Cretaceous Carstone with a capping of glacial deposits; it is one of the southernmost outcrops of the Carstone in Norfolk. It is an eroded relict scarp feature shaped by the passage of the Anglian ice sheet about 440,000 years ago. Before that time the scarp would have been more prominent, perhaps as a range of hills. It contributes to the geodiversity of the county."
Again, in the event of quarrying, Natural England imposes an obligation for restoration to make a net gain in Geodiversity terms which would clearly be impossible and AoS-E should be removed from consideration.

iii) Archaeological and Historical Context
To quote from the Forestry England survey and assessment:
"Shouldham Woods are situated on the edge of the fens, in an area with a long history of settlement throughout human history. Flint artefacts, including a flint "anvil-stone" found at the highest point of Shouldham Warren, reveal prehistoric activity. Cropmarks and finds indicate Bronze Age habitation. In the Roman era Shouldham appears to have been a centre of some importance. Features associated with previous land use survive in the woods. For example, there are Mediaevel warren boundaries, the presence of rhododendron suggests an association with adjacent listed parkland, and there are earthworks and brickwork from a WWII rifle range."
Shouldham Warren has enormous archaeological potential and its destruction would clearly be in contradiction of paragraph E6 of your Preferred Options document:
"The Norfolk Historic Environment Service recommend that proposals for extraction avoid areas of palaeoenvironmental potential, the former barrow and the areas of former settlement. The Norfolk Historic Environment Service would not support proposals that result in the destruction of historic earthworks."
Again AoS-E should therefore be removed from consideration.

iv) Landscape Value
Without doubt Shouldham Warren has intrinsic landscape value as a hill feature and to lose it would significantly detract from the area's landscape character. It rises dramatically out of the surrounding, almost sea-level, fen and farm land to a height of more than 20m. The notion expressed in paragraph E8 that PRoWs could be diverted and reinstated as part of the Warren's future restoration is quite absurd.
Be in no doubt that if Shouldham Warren is excavated it will be lost forever.
Again I submit that AoS-E should therefore be removed from consideration.

v) Leisure, Recreation and Well-being
It is impossible to overstate the value of Shouldham Warren to local and regional populations for leisure and recreation. It is used extensively for walking and running, and by cyclists, horse riders and dog-owners. One can scarcely visit the Warren in daylight hours without meeting other people enjoying and making use of the area for exercise, and gaining a sense of well-being thereby. The community value is inestimable and gives every reason why AoS-E should be removed from your considerations.

vi) Officer Comments
Much has been made of the statement by Natural England in response to the Initial Consultation, viz, "agree with the conclusions regarding the designated sites"
This remark is however prefaced by a list of conditions, stipulations and requirements with which in the case of AoS-E, and Shouldham Warren in particular, compliance is literally impossible.
Natural England call for a net increase in Geodiversity and Biodiversity over the industrialised period of any quarry site which is clearly unachievable.
Were this geological, topographical and geographical feature to be destroyed it cannot in any sense be restored or re-created.

Please note that the inclusion of AoS-E specifically contradicts Norfolk County Council's Environmental Policy of April 2016 where is stated:-
"As part of its commitment to foster the environmental, social and economic well-being of the community, Norfolk County Council will work towards enabling people in Norfolk to benefit from an enhanced environment and quality of life. The County Council will ensure that these principles are
integrated into the decisions of all its services and will:
1. Protect and enhance the county's wildlife and the quality and character of the Norfolk landscape and coast; encouraging the variety of habitats and species to deliver the aims of Biodiversity 2020.
2. Ensure nature contributes to the economic and social health of urban and rural areas in Norfolk for current and future generations."

The inclusion of AoS-E also specifically contradicts the National Planning Policy Framework, section 15, Conserving and Enhancing the Natural Environment, paragraphs 170, 174 and 175, which mandates planning refusal in the circumstances which apply to Shouldham Warren.

In conclusion I would say that, taking together the unique features of AoS-E, Norfolk County Council would be going against its own and national environmental policies if it continues with this proposal.
It would be breaking faith with its own affiliated organisations: The Norfolk Biodiversity and Geodiversity Partnerships.
It would be permitting an act of the most appalling vandalism and, perhaps most importantly of all, it would be failing in its Duty of Stewardship of the County for future generations.
I understand that you are required to provide some areas in Norfolk for silica sand extraction.
We are no strangers here to quarries.
However, there are many locations where smaller, less intrusive, less damaging and destructive sites could be created, without perhaps the economies of scale and increased profitability that could be earned here, though still economically viable.

I hope I have been able to give you every reason why you should now reprieve
Shouldham Warren and remove AoS-E from your considerations.

Objection to Quarrying in AOS E at Shouldham and Marham, Norfolk I object to silica sand mining taking place in the area of Area Of Search (AOS) E and its surroundings as proposed in the Norfolk County Council Mineral & Waste Local Plan, Preferred Options July 2019. It is used for outdoor exercise by 1000s of people; young and old. The loss of long-established woodlands would be devastating for mental health and physical well-being. It would be a disaster for the biodiversity of flora and fauna supported by that ecosystem. The destruction of woodland, never to be restored, is unacceptable at a time when Govt's policy (Clean Growth Strategy) is to increase the number of trees in the UK - "Establish a new network of forests in England... plant 11 million trees". We are facing a Climate Crisis. Shouldham Warren is one of our precious planet's lungs, capturing 11,000 tonnes of C02 per year. The Warren provides clean air, home to precious biodiversity and valuable educational space for children. The lack of an improved glass recycling plan to increase the amount of glass cullet available to UK glass manufacturers makes further quarrying for silica sand at the current rate morally wrong. "Our environment is our most precious inheritance," says DEFRA, so I urge Norfolk County Council to not allocate the woodlands and agricultural farmland in AOS E and remove AOS E from the Mineral & Waste Local Plan.

Objection to Quarrying in AOS E and the overlap with SIL 02 at Shouldham and Marham, Norfolk I object to silica sand mining taking place in the area of Area Of Search (AOS) E and its surroundings as proposed in the Norfolk County Council Mineral & Waste Local Plan, Preferred Options July 2019. It is used for outdoor exercise by 1000s of people; young and old. The loss of long-established woodlands would be devastating for mental health and physical well-being. It would be a disaster for the biodiversity of flora and fauna supported by that ecosystem. The destruction of woodland, never to be restored, is unacceptable at a time when Govt's policy (Clean Growth Strategy) is to increase the number of trees in the UK - "Establish a new network of forests in England... plant 11 million trees". We are facing a Climate Crisis. Shouldham Warren is one of our precious planet's lungs, capturing 11,000 tonnes of C02 per year. The Warren provides clean air, home to precious biodiversity, valuable educational space for children and a recreational area well used by so many people. The lack of an improved glass recycling plan to increase the amount of glass cullet available to UK glass manufacturers makes further quarrying for silica sand at the current rate morally wrong. Our environment is our most precious inheritance," says DEFRA, so I urge Norfolk County Council to not allocate the woodlands and agricultural farmland in AOS E and remove AOS E from the Mineral & Waste Local Plan. I also object to quarrying in SIL 02. It is false of Norfolk County Council to say SIL02 has not been allocated whilst retaining 1/3 of the area in Area Of Search, AOS E. It has known mineral deposits, there is a willing landowner, that defines a preferred area. MOD (DIO) objected to the WHOLE of SIL02, I demand that NCC removes this overlap area from their M&WLP.

-- i would like to register my objection to the proposed quarry to be opened in Shouldham Warren.
I find it unbelievable that Norfolk County Council could give permission to a private Belgian company to destroy such a beautiful area as Shouldham Warren. It appears that there will be no benefit to the local area with regard to jobs etc, but there is lots of disadvantages, what with extra traffic through Shouldham ( has anyone at N C C tried to get H G Vs through Shouldham, even the buses have stopped trying to get round the village) The warren is a county asset and is used by hundreds of people every week. It would be some consolation if a British company was involved because lets face it Belgium has done us no favours with regard to brexit. Please reconsider this plan as it will cause untold disruption and loss of a wonderful amenity to the local area. Thankyou

Objection to Quarrying in AOS E at Shouldham and Marham, Norfolk I object to silica sand mining taking place in the area of Area Of Search (AOS) E and its surroundings as proposed in the Norfolk County Council Mineral & Waste Local Plan, Preferred Options July 2019. It is used for outdoor exercise by 1000s of people; young and old. The loss of long-established woodlands would be devastating for mental health and physical well-being. It would be a disaster for the biodiversity of flora and fauna supported by that ecosystem. The destruction of woodland, never to be restored, is unacceptable at a time when Govt's policy (Clean Growth Strategy) is to increase the number of trees in the UK - "Establish a new network of forests in England... plant 11 million trees". We are facing a Climate Crisis. Shouldham Warren is one of our precious planet's lungs, capturing 11,000 tonnes of C02 per year. The Warren provides clean air, home to precious biodiversity and valuable educational space for children. The lack of an improved glass recycling plan to increase the amount of glass cullet available to UK glass manufacturers makes further quarrying for silica sand at the current rate morally wrong. "Our environment is our most precious inheritance," says DEFRA, so I urge Norfolk County Council to not allocate the woodlands and agricultural farmland in AOS E and remove AOS E from the Mineral & Waste Local Plan.

Objection to Quarrying in AOS E and the overlap with SIL 02 at Shouldham and Marham, Norfolk I object to silica sand mining taking place in the area of Area Of Search (AOS) E and its surroundings as proposed in the Norfolk County Council Mineral & Waste Local Plan, Preferred Options July 2019. It is used for outdoor exercise by 1000s of people; young and old. The loss of long-established woodlands would be devastating for mental health and physical well-being. It would be a disaster for the biodiversity of flora and fauna supported by that ecosystem. The destruction of woodland, never to be restored, is unacceptable at a time when Govt's policy (Clean Growth Strategy) is to increase the number of trees in the UK - "Establish a new network of forests in England... plant 11 million trees". We are facing a Climate Crisis. Shouldham Warren is one of our precious planet's lungs, capturing 11,000 tonnes of C02 per year. The Warren provides clean air, home to precious biodiversity, valuable educational space for children and a recreational area well used by so many people. The lack of an improved glass recycling plan to increase the amount of glass cullet available to UK glass manufacturers makes further quarrying for silica sand at the current rate morally wrong. Our environment is our most precious inheritance," says DEFRA, so I urge Norfolk County Council to not allocate the woodlands and agricultural farmland in AOS E and remove AOS E from the Mineral & Waste Local Plan. I also object to quarrying in SIL 02. It is false of Norfolk County Council to say SIL02 has not been allocated whilst retaining 1/3 of the area in Area Of Search, AOS E. It has known mineral deposits, there is a willing landowner, that defines a preferred area. MOD (DIO) objected to the WHOLE of SIL02, I demand that NCC removes this overlap area from their M&WLP.

Shouldham Warren.
Please don't destroy the woodland. We are all trying to plant more trees, even in our own gardens. If we don't try to do our bit with the current situation, what will it be like for our children and grandchildren in a very few years. I take great delight in seeing pictures of my grandchildren playing in woods and forests. Not one mobile to be seen. Thank you for taking the time to read this short but important message.

To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council
Objection to Quarrying in AOS E at Shouldham and Marham, Norfolk
I object to silica sand mining taking place in the area of Area of Search (AOS) E and its surroundings as proposed in the Norfolk County Council Minerals& Waste Local Plan Preferred Options July 2019.
It is used for outdoor exercise by 1000s of people ; young and old. The loss of long-established woodlands would be devastating for mental health and physical well-being. It would be a disaster for the biodiversity of flora and fauna supported by that ecosystem.
The destruction of woodland, never to be restored, is unacceptable at a time when Gov'ts policy (Clean Growth strategy) is to increase the number of trees in the UK - "establish a new network of forests in England...plant 11 million trees." We are facing a Climate Crisis. Shouldham Warren is one of our precious plant's lungs, capturing 11,000 tonnes of CO2 per year. The Warren provides clean air, home to precious biodiversity, valuable educational space for children and a recreational area well used by so many people.
"Our environment is our most precious inheritance", says DEFRA, so I urge Norfolk County Council to not allocate the woodlands and agricultural farmland in AOS E and remove AOS E from the Minerals & Waste Local Plan.

Comments
Please leave the woods and their creatures alone.

Objection to AOS E - Land Between Marham and Shouldham and includes Shouldham Warren

I object to AOS E, including Shouldham Warren and the overlap with formerly SIL 02, in the Norfolk Minerals and Waste Local Plan. I strongly object to the fact that Norfolk County Council has deliberately misled residents by announcing the removal of SIL 02 when in reality a third of it is now/still included in AOS E.
As a member of the community, I echoed the concerns held by the Ministry of Defence when they objected to these proposals, due to the fact that the plan of a wet working and restoration in close proximity to RAF Marham, well within the statutory 13 kms limit, will increase the risk of "bird strikes" or worst-case scenario, end in an aircraft crash and potential loss of life. The economic cost of such a mishap would be greater than £100M just to replace an F35 Lightning II; add to that the costs for the emergency services and for the immediate and subsequent treatments through the NHS for the physical and mental injuries caused, and the financial costs become an unaffordable risk.

Permanent loss of agricultural land will impact rural Norfolk, its farming jobs, jobs of local employees i.e. British Sugar, including the increased need for home grown food, due to the impact of Brexit.

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. Loss of natural spaces has been proven to adversely affect health, mental and physical. This fenland and forest (Shouldham Warren) is our community's public open space, our gym and our sanctuary, hundreds of people use it daily for physical recreation and social wellbeing interactions.

I object to the fact that the plan would ruin the Landscape, Shouldham Warren, the Countryside, including habitats for birds, animals, and insects. The Warren is home to 64 species of conservation concern, including endangered bats, nightjars and woodlarks. We need nature and trees now more than ever to combat pollution and climate change.

I object to the unsustainable use of a finite mineral resource, when the county only recycles a fraction of the glass already in circulation. There are national government policies and guidance including DEFRA and the Dept for Business Energy & Industrial Strategy that are clearly being ignored in order to allow a privately-owned Belgian company to profit from the devastation of our community asset, landscape and environment.

I further object to the worrying possibility of damage to our Public Water. It is very concerning that if quarrying was allowed to take place, whether through wet or dry working, the water supply could be affected, as the whole area of AOS E has very productive to moderately productive aquifers.

A further objection relates to the lack of restoration plans. Any restoration would take in excess of 30 years, until then the community would suffer from a devastated industrial landscape, increased flow of heavy articulated lorries, preventing any appreciation of its landscape and countryside. 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.

Lastly, I object to the fact that there would be no benefit to the local community or economy if this proposal goes through. What is clear is that a number of local communities will bear the brunt of a hugely disruptive and harmful industrial process; that a very popular public amenity enjoyed by a much larger section of the population will be permanently lost; and the only beneficiaries of this development will be a few landowners, Norfolk County Council, but principally the private owners of the Belgian company Sibelco.

Given that County Councils are responsible for the provision of public services for taxpayers and community wellbeing, and not the promotion of harmful and irresponsible businesses that present no local benefit, but with multiple risks, dictates that Norfolk County Council should put public interest before private profit.
Please record this as my objection,

Objection to AOS E - Land Between Marham and Shouldham and includes Shouldham Warren
I object to AOS E, including Shouldham Warren and the overlap with formerly SIL 02, in the Norfolk Minerals and Waste Local Plan. I strongly object to the fact that Norfolk County Council has deliberately misled residents by announcing the removal of SIL 02 when in reality a third of it is now/still included in AOS E.
As a member of the community, I echoed the concerns held by the Ministry of Defence when they objected to these proposals, due to the fact that the plan of a wet working and restoration in close proximity to RAF Marham, well within the statutory 13 kms limit, will increase the risk of "bird strikes" or worst-case scenario, end in an aircraft crash and potential loss of life. The economic cost of such a mishap would be greater than £100M just to replace an F35 Lightning II; add to that the costs for the emergency services and for the immediate and subsequent treatments through the NHS for the physical and mental injuries caused, and the financial costs become an unaffordable risk.
Permanent loss of agricultural land will impact rural Norfolk, its farming jobs, jobs of local employees i.e. British Sugar, including the increased need for home grown food, due to the impact of Brexit.
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. Loss of natural spaces has been proven to adversely affect health, mental and physical. This fenland and forest (Shouldham Warren) is our community's public open space, our gym and our sanctuary, hundreds of people use it daily for physical recreation and social wellbeing interactions.
I object to the fact that the plan would ruin the Landscape, Shouldham Warren, the Countryside, including habitats for birds, animals, and insects. The Warren is home to 64 species of conservation concern, including endangered bats, nightjars and woodlarks. We need nature and trees now more than ever to combat pollution and climate change.
I object to the unsustainable use of a finite mineral resource, when the county only recycles a fraction of the glass already in circulation. There are national government policies and guidance including DEFRA and the Dept for Business Energy & Industrial Strategy that are clearly being ignored in order to allow a privately-owned Belgian company to profit from the devastation of our community asset, landscape and environment.
I further object to the worrying possibility of damage to our Public Water. It is very concerning that if quarrying was allowed to take place, whether through wet or dry working, the water supply could be affected, as the whole area of AOS E has very productive to moderately productive aquifers.
A further objection relates to the lack of restoration plans. Any restoration would take in excess of 30 years, until then the community would suffer from a devastated industrial landscape, increased flow of heavy articulated lorries, preventing any appreciation of its landscape and countryside. 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.
Lastly, I object to the fact that there would be no benefit to the local community or economy if this proposal goes through. What is clear is that a number of local communities will bear the brunt of a hugely disruptive and harmful industrial process; that a very popular public amenity enjoyed by a much larger section of the population will be permanently lost; and the only beneficiaries of this development will be a few landowners, Norfolk County Council, but principally the private owners of the Belgian company Sibelco.
Given that County Councils are responsible for the provision of public services for taxpayers and community wellbeing, and not the promotion of harmful and irresponsible businesses that present no local benefit, but with multiple risks, dictates that Norfolk County Council should put public interest before private profit.
Please record this as my objection,

Objection to AOS E - Land Between Marham and Shouldham and includes Shouldham Warren
I object to AOS E, including Shouldham Warren and the overlap with formerly SIL 02, in the Norfolk Minerals and Waste Local Plan. I strongly object to the fact that Norfolk County Council has deliberately misled residents by announcing the removal of SIL 02 when in reality a third of it is now/still included in AOS E.
As a member of the community, I echoed the concerns held by the Ministry of Defence when they objected to these proposals, due to the fact that the plan of a wet working and restoration in close proximity to RAF Marham, well within the statutory 13 kms limit, will increase the risk of "bird strikes" or worst-case scenario, end in an aircraft crash and potential loss of life. The economic cost of such a mishap would be greater than £100M just to replace an F35 Lightning II; add to that the costs for the emergency services and for the immediate and subsequent treatments through the NHS for the physical and mental injuries caused, and the financial costs become an unaffordable risk.
Permanent loss of agricultural land will impact rural Norfolk, its farming jobs, jobs of local employees i.e. British Sugar, including the increased need for home grown food, due to the impact of Brexit.
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. Loss of natural spaces has been proven to adversely affect health, mental and physical. This fenland and forest (Shouldham Warren) is our community's public open space, our gym and our sanctuary, hundreds of people use it daily for physical recreation and social wellbeing interactions.
I object to the fact that the plan would ruin the Landscape, Shouldham Warren, the Countryside, including habitats for birds, animals, and insects. The Warren is home to 64 species of conservation concern, including endangered bats, nightjars and woodlarks. We need nature and trees now more than ever to combat pollution and climate change.
I object to the unsustainable use of a finite mineral resource, when the county only recycles a fraction of the glass already in circulation. There are national government policies and guidance including DEFRA and the Dept for Business Energy & Industrial Strategy that are clearly being ignored in order to allow a privately-owned Belgian company to profit from the devastation of our community asset, landscape and environment.
I further object to the worrying possibility of damage to our Public Water. It is very concerning that if quarrying was allowed to take place, whether through wet or dry working, the water supply could be affected, as the whole area of AOS E has very productive to moderately productive aquifers.
A further objection relates to the lack of restoration plans. Any restoration would take in excess of 30 years, until then the community would suffer from a devastated industrial landscape, increased flow of heavy articulated lorries, preventing any appreciation of its landscape and countryside. 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.
Lastly, I object to the fact that there would be no benefit to the local community or economy if this proposal goes through. What is clear is that a number of local communities will bear the brunt of a hugely disruptive and harmful industrial process; that a very popular public amenity enjoyed by a much larger section of the population will be permanently lost; and the only beneficiaries of this development will be a few landowners, Norfolk County Council, but principally the private owners of the Belgian company Sibelco.
Given that County Councils are responsible for the provision of public services for taxpayers and community wellbeing, and not the promotion of harmful and irresponsible businesses that present no local benefit, but with multiple risks, dictates that Norfolk County Council should put public interest before private profit.
Please record this as my objection,