SIL02 - land at Shouldham and Marham

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Object

Preferred Options consultation document

Representation ID: 93245

Received: 23/09/2019

Respondent: Mrs Carolyn Etherington

Representation Summary:

I live in a neighbouring village and visit the Warren most days, it is beautiful area that is visited regularly by 100's of people, it is the perfect setting for dog walks, cycling or just a gentle stroll, I take my grandson there to help him learn about nature and the importance of the environment, we watch the squirrels and often get a fantastic close up view of the deer that inhabit the forest. The Warren was the place that attracted me to the area and to think it may be lost is sacrilege to an area of outstanding beauty that should be protected and not destoyed. Its destruction is not the only concern, please see below for the very practical reasons why this area should be removed from consideration

E1/E2 - Highways - The Highways approved route for HGVs from the Warren proposed, accessing the A134 to the west will create an accident black spot without significant adaptation of the road to allow traffic to enter a fast flowing stretch; a roundabout would be required to mitigate the right turn across traffic and into a fast flow. The extra HGV traffic on the A10 through West Winch onto the Hardwick roundabout at peak times will cause further delays, disruption and wear and tear on an already very heavily used route; this will impact on the travel time for commuting, access for emergency vehicles, commercial traffic, public transport and tourism. The Hardwick yellow box system is already widely disregarded with police not resourced to enforce the road traffic act. Furthermore, it will increase vehicle emission pollution directly impacting residents of West Winch. The bottle neck at the QE Hospital roundabout will impact in the same way as the Hardwick. Shouldham is completely unsuitable for commercial traffic or commuting employees of a silica quarry; the local bus company have already ceased a route through the village for that reason.
Loss of local amenities - the Warren is used by a wide range of local clubs and groups for leisure and sport as well as providing local residents with a safe, clean and peaceful environment to walk, cycle and ride, there are very few of these peaceful havens so accessible to the general public at no cost and the loss of the Warren would significantly impact on the wellbeing and health of residents of Shouldham, Marham and the surrounding villages, affecting many thousands of people who would get no direct benefit from the site, indeed they would suffer the dust (assuming MOD will object to wet extraction) and noise pollution with the detrimental effects.

Full text:

I live in a neighbouring village and visit the Warren most days, it is beautiful area that is visited regularly by 100's of people, it is the perfect setting for dog walks, cycling or just a gentle stroll, I take my grandson there to help him learn about nature and the importance of the environment, we watch the squirrels and often get a fantastic close up view of the deer that inhabit the forest. The Warren was the place that attracted me to the area and to think it may be lost is sacrilege to an area of outstanding beauty that should be protected and not destoyed. Its destruction is not the only concern, please see below for the very practical reasons why this area should be removed from consideration

E1/E2 - Highways - The Highways approved route for HGVs from the Warren proposed, accessing the A134 to the west will create an accident black spot without significant adaptation of the road to allow traffic to enter a fast flowing stretch; a roundabout would be required to mitigate the right turn across traffic and into a fast flow. The extra HGV traffic on the A10 through West Winch onto the Hardwick roundabout at peak times will cause further delays, disruption and wear and tear on an already very heavily used route; this will impact on the travel time for commuting, access for emergency vehicles, commercial traffic, public transport and tourism. The Hardwick yellow box system is already widely disregarded with police not resourced to enforce the road traffic act. Furthermore, it will increase vehicle emission pollution directly impacting residents of West Winch. The bottle neck at the QE Hospital roundabout will impact in the same way as the Hardwick. Shouldham is completely unsuitable for commercial traffic or commuting employees of a silica quarry; the local bus company have already ceased a route through the village for that reason.
Loss of local amenities - the Warren is used by a wide range of local clubs and groups for leisure and sport as well as providing local residents with a safe, clean and peaceful environment to walk, cycle and ride, there are very few of these peaceful havens so accessible to the general public at no cost and the loss of the Warren would significantly impact on the wellbeing and health of residents of Shouldham, Marham and the surrounding villages, affecting many thousands of people who would get no direct benefit from the site, indeed they would suffer the dust (assuming MOD will object to wet extraction) and noise pollution with the detrimental effects.

Object

Preferred Options consultation document

Representation ID: 93587

Received: 02/10/2019

Respondent: Mr JJ Gallagher

Representation Summary:

Summary: MOD (DIO) objected to the whole of SIL 02 as an area for quarrying silica sand. Despite agreeing with this objection, NCC has decided not to remove all of SIL 02 from the plan but to allow a third of it to remain where it overlaps with AOS E. I pointed this out to the Infra and Dev Committee and the Cabinet before both sat and approved the Preferred Options Plan for public consultation. Is NCC consciously misleading the public over this? I agree with the MOD objection and object to ANY of SIL 02 remaining in the plan.

I objected to SIL 02 in the Initial Consultation phase and was pleased to read that SIL 02 was not allocated in this Preferred Options stage. That was until it became apparent that, despite the MOD (DIO) objection to the increased birdstrike risk that SIL 02 would cause and agreed by NCC, only part of SIL 02 was to be removed from the allocation with a substantial area remaining (approximately a third of the original area of SIL 02) under the name of AOS E. I wrote to the Chair of the Infrastructure and Development Committee and to Cllr Andy Grant prior to the meeting of that committee in July to point out this obvious anomaly for consideration before they agreed to send the Preferred Options M&WLP draft to Cabinet for ratification and publication in a consultation phase. When this point was ignored I wrote to the Chair of the Cabinet and Cllr Grant to make them aware before the Cabinet meeting of August where the M&WLP was to be an agenda item for ratification and agreement to go ahead with the Preferred Options Consultation. Again it fell on deaf ears and the whole of SIL 02 was not removed from the plan. Nowhere in the Preferred Options documents does it allude to any overlap of area between AOS E and SIL 02; it certainly does not point the reader to the fact that there is any overlap of the areas and that SIL 02, in part, remains in the plan. NCC state in the summary of SIL 02, "S2.28 Conclusion: The site is considered to be unsuitable for allocation because:

Due to the size of the extraction site proposed within 5km of RAF Marham and the likelihood of the site being restored to open water, there is a high risk of unacceptable adverse impacts on aviation safety and the Ministry of Defence (Defence Infrastructure Organisation) has objected to the proposal." The MOD (DIO) objection is very clear - they object to the whole of SIL 02, not part of it. Therefore, if NCC is to leave this overlap area of AOS E and SIL 02 in the M&WLP, despite the very strong objection from MOD (DIO) and NCC's agreement with that objection, are NCC consciously misleading the public?

I object to the plan continuing to include the overlap area of SIL 02 and AOS E despite the MOD (DIO) objection to the whole of SIL 02 as an area for silica sand quarrying.

Full text:

I objected to SIL 02 in the Initial Consultation phase and was pleased to read that SIL 02 was not allocated in this Preferred Options stage. That was until it became apparent that, despite the MOD (DIO) objection to the increased birdstrike risk that SIL 02 would cause and agreed by NCC, only part of SIL 02 was to be removed from the allocation with a substantial area remaining (approximately a third of the original area of SIL 02) under the name of AOS E. I wrote to the Chair of the Infrastructure and Development Committee and to Cllr Andy Grant prior to the meeting of that committee in July to point out this obvious anomaly for consideration before they agreed to send the Preferred Options M&WLP draft to Cabinet for ratification and publication in a consultation phase. When this point was ignored I wrote to the Chair of the Cabinet and Cllr Grant to make them aware before the Cabinet meeting of August where the M&WLP was to be an agenda item for ratification and agreement to go ahead with the Preferred Options Consultation. Again it fell on deaf ears and the whole of SIL 02 was not removed from the plan. Nowhere in the Preferred Options documents does it allude to any overlap of area between AOS E and SIL 02; it certainly does not point the reader to the fact that there is any overlap of the areas and that SIL 02, in part, remains in the plan. NCC state in the summary of SIL 02, "S2.28 Conclusion: The site is considered to be unsuitable for allocation because:

Due to the size of the extraction site proposed within 5km of RAF Marham and the likelihood of the site being restored to open water, there is a high risk of unacceptable adverse impacts on aviation safety and the Ministry of Defence (Defence Infrastructure Organisation) has objected to the proposal." The MOD (DIO) objection is very clear - they object to the whole of SIL 02, not part of it. Therefore, if NCC is to leave this overlap area of AOS E and SIL 02 in the M&WLP, despite the very strong objection from MOD (DIO) and NCC's agreement with that objection, are NCC consciously misleading the public?

I object to the plan continuing to include the overlap area of SIL 02 and AOS E despite the MOD (DIO) objection to the whole of SIL 02 as an area for silica sand quarrying.

Object

Preferred Options consultation document

Representation ID: 93816

Received: 06/10/2019

Respondent: Mrs LDT Gallagher

Representation Summary:

It is duplicitous of Norfolk County Council to say SIL02 has not been allocated whilst retaining 1/3 of the area and re-badging as an Area Of Search AOS E. Is this part of AOS E STILL a preferred area? Sibelco has drilled,found silica sand, there is a willing landowner; so what would stop Sibelco putting in a planning application on that area now? Both criteria above are the definition of a preferred area, with NCC likely to give planning permission. MOD (DIO) have been ignored and their agreed objection to the WHOLE of SIL02 has not been implemented -utterly contemptible.

Full text:

It is duplicitous of Norfolk County Council to say SIL02 has not been allocated whilst retaining 1/3 of the area and re-badging as an Area Of Search AOS E. Is this part of AOS E STILL a preferred area? Sibelco has drilled,found silica sand, there is a willing landowner; so what would stop Sibelco putting in a planning application on that area now? Both criteria above are the definition of a preferred area, with NCC likely to give planning permission. MOD (DIO) have been ignored and their agreed objection to the WHOLE of SIL02 has not been implemented -utterly contemptible.

Object

Preferred Options consultation document

Representation ID: 94171

Received: 14/10/2019

Respondent: Ms A Money

Representation Summary:

we need to protect the earth from exploitation and find other non invasive ways of providing for human needs or learn to live differently.

This is not sustainable for the planet which means it's not sustainable for the human race

Full text:

we need to protect the earth from exploitation and find other non invasive ways of providing for human needs or learn to live differently.

This is not sustainable for the planet which means it's not sustainable for the human race

Object

Preferred Options consultation document

Representation ID: 94274

Received: 16/10/2019

Respondent: Marham Parish Council

Representation Summary:

Marham Parish Council objects to the area of search (AOS E) that lies within or close to the Parish boundary, and its overlapping area with the remainder of SIL 02. It also objects for the following reasons:

Marham village has had a strong association with RAF Marham for many decades. While the closeness of the airfield brings the type of noise that most villages in the UK do not hear, the residents understand the strategic significance RAF Marham has played and continues to play in the defence of the UK and employment in the Borough (it is the largest front-line RAF base in the UK and supplies 1 in 12 jobs in the Borough and an estimated £130 million to the local economy). Every resident in Marham made a choice to live in the village with the knowledge of the noise the airbase produced. None of them chose to live and raise families in the village to be close to a quarry that will last for many decades. The cumulative effect of the jet noise to one side of the village, combined with the potential of a silica sand quarry on the other is not a quality of life position that Norfolk County Council could think is acceptable to visit upon the residents.

A quarry would bring an increased risk of birdstrikes and the Council agrees with the MOD DIO objection in the Initial Consultation phase. The initial plan for SIL 02 was to be a wet dredge; the area of AOS E that was previously known as SIL 02 has a high-water table; no dewatering licence will be granted; the remainder of AOS E in most part also has a high-water table and presumably would have to be wet dredged. This is a high-risk strategy for a catastrophic event; it would be a human disaster if an F-35 Lightning II were to be brought down on or near to the village due to a terminal failure of its engine caused by a bird attracted to a wet quarry working and/or restoration in the village.

The toll of such an occurrence on the spirit of the community and its individual inhabitants is immeasurable. Add to that the tangible concerns that can be measured - the cost to the taxpayer for initial disaster, the rebuilding, NHS treatment, and replacing aircraft - an increase in the risk of a birdstrike in the village is not acceptable as 80% of bird strikes occur at take off and landing.

The Borough Council is reviewing its own Local Plan which has, as a main highlight, Marham village as one of two Growth Key Rural Centres to support families and employees at RAF Marham through building at least 75 houses over two sites. RAF Marham is expected to grow from a community of 8000 to 10000 over the coming years.

The Council cannot understand how the Borough Council plan for housing, and the County Council plan for quarrying, could ever be compatible.

The proposed area of search close to the village will have no beneficial effect on the local economy other than to drive people out (cumulative effect of the airbase and the quarry) to find alternative places to live and raise a family. In turn, this will reduce spending within the local businesses, causing those to close and leave too.

And then there is the matter of at least 75 new houses (Local Plan) that may not be bought and so remain empty.

Any quarrying would remove the natural spaces that are Shouldham Warren and Marham Fen, used daily by hundreds of people, locals and tourists alike. At a time when the problems of obesity and mental health are an almost daily news story and problems that can be reduced through outdoor exercise, there is a high incidence of depression within the communities and it is well documented that stress, depression and anxiety are relieved by being in the great outdoors.

It does not make any sense to consider AOS E as an area to quarry silica sand that could be sourced another way - it could be imported. The country is not self-sufficient in many commodities in the UK and continues to import goods, especially food stuffs, at extortionate cost, so why the rush to be self sufficient in glass and therefore sand? This country could also recycle its glass better to reduce the raw materials required and have to quarry them from the landscapes in vast quantities.

The irrevocable changes to the rich historic landscape and character of the local area surrounding the many Scheduled Monuments and Heritage Assets that any quarrying would cause in this area would be an act of vandalism.

It is noted that from Norfolk County Council's own Historic Environmental Impact Assessment (HEIA), such is the significance of Pentney Priory Gatehouse, that the recommendation in the report is to exclude an area approximately 2km to the East of the monument to lessen the risk of visual intrusion in its setting and historical context. It is disappointing that the HEIA only saw fit to exclude an area to the south of Pentney Priory Gatehouse out to only approximately 1km, despite the monument being clearly visible from Spring Lane over 2km away and looking directly over the former area of SIL 02, now part of AOS E overlap.

The Council objects to this arbitrary 1km and requests that at least 2km is imposed to the South of Pentney Priory Gatehouse to afford the same view and distance in both directions.

There are no sensible, logical or humane arguments in favour of silica sand quarrying in the area when compared with the points above. Marham Parish Council objects to the proposal to quarry silica sand in AOS E and its overlapping area with SIL 02.

Full text:

Marham Parish Council objects to the area of search (AOS E) that lies within or close to the Parish boundary, and its overlapping area with the remainder of SIL 02. It also objects for the following reasons:

Marham village has had a strong association with RAF Marham for many decades. While the closeness of the airfield brings the type of noise that most villages in the UK do not hear, the residents understand the strategic significance RAF Marham has played and continues to play in the defence of the UK and employment in the Borough (it is the largest front-line RAF base in the UK and supplies 1 in 12 jobs in the Borough and an estimated £130 million to the local economy). Every resident in Marham made a choice to live in the village with the knowledge of the noise the airbase produced. None of them chose to live and raise families in the village to be close to a quarry that will last for many decades. The cumulative effect of the jet noise to one side of the village, combined with the potential of a silica sand quarry on the other is not a quality of life position that Norfolk County Council could think is acceptable to visit upon the residents.

A quarry would bring an increased risk of birdstrikes and the Council agrees with the MOD DIO objection in the Initial Consultation phase. The initial plan for SIL 02 was to be a wet dredge; the area of AOS E that was previously known as SIL 02 has a high-water table; no dewatering licence will be granted; the remainder of AOS E in most part also has a high-water table and presumably would have to be wet dredged. This is a high-risk strategy for a catastrophic event; it would be a human disaster if an F-35 Lightning II were to be brought down on or near to the village due to a terminal failure of its engine caused by a bird attracted to a wet quarry working and/or restoration in the village.

The toll of such an occurrence on the spirit of the community and its individual inhabitants is immeasurable. Add to that the tangible concerns that can be measured - the cost to the taxpayer for initial disaster, the rebuilding, NHS treatment, and replacing aircraft - an increase in the risk of a birdstrike in the village is not acceptable as 80% of bird strikes occur at take off and landing.

The Borough Council is reviewing its own Local Plan which has, as a main highlight, Marham village as one of two Growth Key Rural Centres to support families and employees at RAF Marham through building at least 75 houses over two sites. RAF Marham is expected to grow from a community of 8000 to 10000 over the coming years.

The Council cannot understand how the Borough Council plan for housing, and the County Council plan for quarrying, could ever be compatible.

The proposed area of search close to the village will have no beneficial effect on the local economy other than to drive people out (cumulative effect of the airbase and the quarry) to find alternative places to live and raise a family. In turn, this will reduce spending within the local businesses, causing those to close and leave too.

And then there is the matter of at least 75 new houses (Local Plan) that may not be bought and so remain empty.

Any quarrying would remove the natural spaces that are Shouldham Warren and Marham Fen, used daily by hundreds of people, locals and tourists alike. At a time when the problems of obesity and mental health are an almost daily news story and problems that can be reduced through outdoor exercise, there is a high incidence of depression within the communities and it is well documented that stress, depression and anxiety are relieved by being in the great outdoors.

It does not make any sense to consider AOS E as an area to quarry silica sand that could be sourced another way - it could be imported. The country is not self-sufficient in many commodities in the UK and continues to import goods, especially food stuffs, at extortionate cost, so why the rush to be self sufficient in glass and therefore sand? This country could also recycle its glass better to reduce the raw materials required and have to quarry them from the landscapes in vast quantities.

The irrevocable changes to the rich historic landscape and character of the local area surrounding the many Scheduled Monuments and Heritage Assets that any quarrying would cause in this area would be an act of vandalism.

It is noted that from Norfolk County Council's own Historic Environmental Impact Assessment (HEIA), such is the significance of Pentney Priory Gatehouse, that the recommendation in the report is to exclude an area approximately 2km to the East of the monument to lessen the risk of visual intrusion in its setting and historical context. It is disappointing that the HEIA only saw fit to exclude an area to the south of Pentney Priory Gatehouse out to only approximately 1km, despite the monument being clearly visible from Spring Lane over 2km away and looking directly over the former area of SIL 02, now part of AOS E overlap.

The Council objects to this arbitrary 1km and requests that at least 2km is imposed to the South of Pentney Priory Gatehouse to afford the same view and distance in both directions.

There are no sensible, logical or humane arguments in favour of silica sand quarrying in the area when compared with the points above. Marham Parish Council objects to the proposal to quarry silica sand in AOS E and its overlapping area with SIL 02.

Comment

Preferred Options consultation document

Representation ID: 94291

Received: 17/10/2019

Respondent: CPRE Norfolk

Representation Summary:

CPRE Norfolk is pleased to note that this site is considered to be unsuitable for allocation, although is disappointed to see that various environmental and historic environment factors are not given as the reasons for this exclusion.

Full text:

CPRE Norfolk is pleased to note that this site is considered to be unsuitable for allocation, although is disappointed to see that various environmental and historic environment factors are not given as the reasons for this exclusion.

Object

Preferred Options consultation document

Representation ID: 94437

Received: 22/10/2019

Respondent: Shouldham parish council

Representation Summary:

Summary: The destruction of Shouldham Warren is too high a price to pay in all respects for the silica sand it holds. There is no tangible benefit to West Norfolk communities. There are other areas nationally and internationally other than AOS E in the short term that can continue to be exploited by necessity that have less affect on a community while the country and NCC properly steps up to the requirement to recycle more effectively and find sustainable processes for the longer term. NCC and the Government should be convincing companies to evolve toward a more sustainable model.

SHOULDHAM PARISH COUNCIL
Norfolk County Council Waste and Minerals Plan Consultation Comment
Shouldham Parish Council objects to the proposal of AOS E as an area of search, furthermore it objects to SIL 02, which although as a preferred site was removed from the plan in name following a significant objection from the Defence Infrastructure Organisation (DIO), has in fact had almost a 1/3rd of it retained within the bounds of AOS E.
The Parish Council has listened to its residents, researched open source information and believes that there is compelling evidence and reasons from the perspective of health and wellbeing, climate change, recycling and preservation of finite minerals and that the economic case is significantly disproportionate in favour of industry rather than the wellbeing of the local community and wider population estimated to be in the thousands every year who use the Shouldham Warren for leisure, educational, Forest Church and a variety sporting activities. This is also underpinned in the Forestry England Shouldham and Bilney Forest Plan 2016-2026. The Forest Plan outlines the need to consider, people, economy and nature and is a fine balance that needs to be carefully sustained. AOS D (West Bilney) as well as AOS E (Shouldham Warren) both fall under this Forestry England plan but they have not commented as a consultee nor has the plan been referred to in any of the County officer's responses to other nature related comments. Forestry England are a significant consultee and their 2016-2026 plan has seemingly been overlooked completely.
In addition, the infrastructure from a highways perspective would require significant improvements to make it safe for access and to prevent further adverse impact on the traffic flow along the entire proposed route, which is renowned for long delays at the Hardwick and Hospital roundabouts and roads leading to them. This would mean further roadworks with the associated cost to who? And the disruption and delays while it took place. Monitoring of the yellow hatch box on the Hardwick is already a low priority and widely disregarded by locals, commercial and tourist traffic due to lack of enforcement and not serving to keep traffic flowing.
The prime company (Sibelco) who would likely quarry the site for Silica Sand, if given the planning permission, have a poor track record as a neighbour and despite invitations to discuss what they would likely do by way of restoration offer nothing, the County Officer's comments on restoration, quote policy and offer no detail or assurance as to how policy would be enforced, we would most likely be left with a scar on the landscape with low level land allowed to fill with water at best or used for landfill at worst; the Shouldham mound would disappear along with the features that make it attractive, either way it will never be able to be returned to the positive asset that it represents today.
Climate Change
The UK has signed up to the Paris Agreement which in turn led to the Climate Change Act which commits the UK government by law to reducing greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050.
The Norfolk Climate Change Partnership that NCC and the BC KL&WN are partners in published the 'Tomorrow's Norfolk, Today's Challenge' Climate Change Strategy and that states that in West Norfolk the per capita CO2 emissions is was 10.7 tonnes in 2006, far higher than the rest of Norfolk. The latest figures show a 16.3% increase in that figure between 2016 and 2017, 52% of which is from commercial and industry. Norfolk is not rising to its own challenge and as it said in 2006, the time to act is now!
Councillor Alex Kemp was quoted in a Lynn News article on 18 July 2019 with the following statements:
...it was "totally unsatisfactory" no new AQMAs had been set and the borough were "behind the times."
"There are 40,000 early deaths a year from air pollution and yet there is a reluctance to move forward and look properly at the health of the people of West Norfolk. That has got to change."
Ms Kemp said CO2 emissions were not mentioned during Tuesday's panel meeting.
And she also suggested more trees are planted in the area after deputy leader of the borough council, Elizabeth Nockolds, had said there was a pot of £35,000 a year for new trees.
The borough council report did state the King's Lynn Transport Study is considering many transport options in the town to help ease pollution.
The County and Borough Council's are identifying the issues but failing to take a coherent approach to resolving them, indeed if AOS E was progressed it would be contrary to the Council's strategy on Climate Change. This is your chance to address this and show a proper commitment to climate change.
There is an urgent need to plant trees- the Woodland Trust estimates the UK needs to plant 1.5 billion trees by 2050 in order to reach net zero emissions. This is about 30000 hectares. In comparison, the Warren search area is 330 hectares of woodland. It is nonsensical to destroy existing woodlands when we are not meeting targets for new plantings.
It takes time to establish woods and we are not in a position to take down any trees at this point in time. See the Forestry England Plan.
Norfolk needs to play its part in meeting our international obligations, so the trees must stay.
Health and Wellbeing
The Health and Social Care Act 2012 delegated duties to local authorities to improve public health and reduce health inequalities.
* There is a range of legislation that protects biodiversity and urban green spaces by regulating planning, contamination and conservation, including the Wildlife and Countryside Act 1981, Environmental Protection Act 1990 and the Planning Act 2008.
* Section 12 of the 2012 Act 4 introduced a new duty for all upper-tier and unitary local authorities in England to take appropriate steps to improve the health of the people who live in their areas.
Studies have conclusively proven that exposure to forests and trees:
* boosts the immune system
* lowers blood pressure
* reduces stress
* improves mood
* increases ability to focus, even in children with ADHD
* accelerates recovery from surgery or illness
* increases energy level
* improves sleep
The Natural Environment White Paper addresses the importance of accessible green space and links to human health.
At a time when 1 in 5 children leaving primary school in West Norfolk are obese, the importance of doing all that we can as a society to encourage a healthier lifestyle cannot be underestimated.
West Norfolk is one of the highest areas in the country for GP prescribing of antidepressants, indication a high prevalence of depression and anxiety in the population.
The NHS is under huge strain already trying to treat people, and the county council must do everything in its power to enable people to lead healthier lives, to reduce the burden on health services.
Shouldham Warren is used by a very large number of people from the surrounding areas to walk, cycle, and 'forest bathe'. It is used by cycling groups and of the Ryston Runners have their races here every winter which are attended by a very large number of children and adults from far and wide. There is no other wooded area in this part of West Norfolk which could be used instead, and there is no doubt in my mind that people's health will suffer if they are denied access to these woods.
If NCC goes ahead with giving permission to explore the area for sand quarrying, it will demonstrate a disregard for the population today and future generations; Norfolk County Council will fail in its obligations to look after the health of the people of Norfolk.
Recycling and Preservation of Finite Mineral Resource.
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's 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; quarrying is not sustainable and committing to it for the next generation is to show neglect of duty.
Here in Norfolk, as we do in many fields, we should look to model best practice for the UK strategy and have the vision to ensure we do not compromise future generations.
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.



Economics

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.

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 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(approx). 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 does not even use local plant hire since they contract from D. Wardle Plant Hire, a company in Cheshire. Sibelco's representative, Mr Hurley, has said at public meetings that 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, SIL 02 would have equalled 1 or 2 jobs created = £1.76M wage bill in Norfolk. The figures do not add up to anything close to the £15M that Sibelco claim to put into Norfolk's economy each year.

Aircraft Birdstrike Hazard

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 £100M+ per 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 could be argued that there is a set of lakes very close to RAF Coningsby and that is tolerated 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. It should be remembered that the large element of SIL 02 left in AOS E is a low-lying area and would be left as a wetland. It should also be noted that wetland birds migrate in large numbers, are unfamiliar with the very loud F-35 engine noise and will be 'spooked to flight' in a dense mass that is unavoidable by the pilot. It should also be noted that the migration routes of such large birds will alter to take advantage of new feeding grounds left by a quarry and their flightpath will not be known until they arrive or depart and they do not file flight plans for traffic deconfliction!

Summary
The destruction of Shouldham Warren is too high a price to pay in all respects for the silica sand it holds. There is no tangible benefit to West Norfolk communities. There are other areas nationally and internationally (Sibelco are a global company) other than AOS E in the short term that can continue to be exploited by necessity that have less affect on a community than this one while the country and Norfolk County Council properly steps up to the requirement to recycle more effectively and find sustainable processes for the longer term. Norfolk County Council and the Government should be convincing companies like Sibelco to evolve toward a more sustainable model perhaps by providing incentives and punitive measures to encourage it on that essential journey.

Full text:

SHOULDHAM PARISH COUNCIL
Norfolk County Council Waste and Minerals Plan Consultation Comment
Shouldham Parish Council objects to the proposal of AOS E as an area of search, furthermore it objects to SIL 02, which although as a preferred site was removed from the plan in name following a significant objection from the Defence Infrastructure Organisation (DIO), has in fact had almost a 1/3rd of it retained within the bounds of AOS E.
The Parish Council has listened to its residents, researched open source information and believes that there is compelling evidence and reasons from the perspective of health and wellbeing, climate change, recycling and preservation of finite minerals and that the economic case is significantly disproportionate in favour of industry rather than the wellbeing of the local community and wider population estimated to be in the thousands every year who use the Shouldham Warren for leisure, educational, Forest Church and a variety sporting activities. This is also underpinned in the Forestry England Shouldham and Bilney Forest Plan 2016-2026. The Forest Plan outlines the need to consider, people, economy and nature and is a fine balance that needs to be carefully sustained. AOS D (West Bilney) as well as AOS E (Shouldham Warren) both fall under this Forestry England plan but they have not commented as a consultee nor has the plan been referred to in any of the County officer's responses to other nature related comments. Forestry England are a significant consultee and their 2016-2026 plan has seemingly been overlooked completely.
In addition, the infrastructure from a highways perspective would require significant improvements to make it safe for access and to prevent further adverse impact on the traffic flow along the entire proposed route, which is renowned for long delays at the Hardwick and Hospital roundabouts and roads leading to them. This would mean further roadworks with the associated cost to who? And the disruption and delays while it took place. Monitoring of the yellow hatch box on the Hardwick is already a low priority and widely disregarded by locals, commercial and tourist traffic due to lack of enforcement and not serving to keep traffic flowing.
The prime company (Sibelco) who would likely quarry the site for Silica Sand, if given the planning permission, have a poor track record as a neighbour and despite invitations to discuss what they would likely do by way of restoration offer nothing, the County Officer's comments on restoration, quote policy and offer no detail or assurance as to how policy would be enforced, we would most likely be left with a scar on the landscape with low level land allowed to fill with water at best or used for landfill at worst; the Shouldham mound would disappear along with the features that make it attractive, either way it will never be able to be returned to the positive asset that it represents today.
Climate Change
The UK has signed up to the Paris Agreement which in turn led to the Climate Change Act which commits the UK government by law to reducing greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050.
The Norfolk Climate Change Partnership that NCC and the BC KL&WN are partners in published the 'Tomorrow's Norfolk, Today's Challenge' Climate Change Strategy and that states that in West Norfolk the per capita CO2 emissions is was 10.7 tonnes in 2006, far higher than the rest of Norfolk. The latest figures show a 16.3% increase in that figure between 2016 and 2017, 52% of which is from commercial and industry. Norfolk is not rising to its own challenge and as it said in 2006, the time to act is now!
Councillor Alex Kemp was quoted in a Lynn News article on 18 July 2019 with the following statements:
...it was "totally unsatisfactory" no new AQMAs had been set and the borough were "behind the times."
"There are 40,000 early deaths a year from air pollution and yet there is a reluctance to move forward and look properly at the health of the people of West Norfolk. That has got to change."
Ms Kemp said CO2 emissions were not mentioned during Tuesday's panel meeting.
And she also suggested more trees are planted in the area after deputy leader of the borough council, Elizabeth Nockolds, had said there was a pot of £35,000 a year for new trees.
The borough council report did state the King's Lynn Transport Study is considering many transport options in the town to help ease pollution.
The County and Borough Council's are identifying the issues but failing to take a coherent approach to resolving them, indeed if AOS E was progressed it would be contrary to the Council's strategy on Climate Change. This is your chance to address this and show a proper commitment to climate change.
There is an urgent need to plant trees- the Woodland Trust estimates the UK needs to plant 1.5 billion trees by 2050 in order to reach net zero emissions. This is about 30000 hectares. In comparison, the Warren search area is 330 hectares of woodland. It is nonsensical to destroy existing woodlands when we are not meeting targets for new plantings.
It takes time to establish woods and we are not in a position to take down any trees at this point in time. See the Forestry England Plan.
Norfolk needs to play its part in meeting our international obligations, so the trees must stay.
Health and Wellbeing
The Health and Social Care Act 2012 delegated duties to local authorities to improve public health and reduce health inequalities.
* There is a range of legislation that protects biodiversity and urban green spaces by regulating planning, contamination and conservation, including the Wildlife and Countryside Act 1981, Environmental Protection Act 1990 and the Planning Act 2008.
* Section 12 of the 2012 Act 4 introduced a new duty for all upper-tier and unitary local authorities in England to take appropriate steps to improve the health of the people who live in their areas.
Studies have conclusively proven that exposure to forests and trees:
* boosts the immune system
* lowers blood pressure
* reduces stress
* improves mood
* increases ability to focus, even in children with ADHD
* accelerates recovery from surgery or illness
* increases energy level
* improves sleep
The Natural Environment White Paper addresses the importance of accessible green space and links to human health.
At a time when 1 in 5 children leaving primary school in West Norfolk are obese, the importance of doing all that we can as a society to encourage a healthier lifestyle cannot be underestimated.
West Norfolk is one of the highest areas in the country for GP prescribing of antidepressants, indication a high prevalence of depression and anxiety in the population.
The NHS is under huge strain already trying to treat people, and the county council must do everything in its power to enable people to lead healthier lives, to reduce the burden on health services.
Shouldham Warren is used by a very large number of people from the surrounding areas to walk, cycle, and 'forest bathe'. It is used by cycling groups and of the Ryston Runners have their races here every winter which are attended by a very large number of children and adults from far and wide. There is no other wooded area in this part of West Norfolk which could be used instead, and there is no doubt in my mind that people's health will suffer if they are denied access to these woods.
If NCC goes ahead with giving permission to explore the area for sand quarrying, it will demonstrate a disregard for the population today and future generations; Norfolk County Council will fail in its obligations to look after the health of the people of Norfolk.
Recycling and Preservation of Finite Mineral Resource.
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's 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; quarrying is not sustainable and committing to it for the next generation is to show neglect of duty.
Here in Norfolk, as we do in many fields, we should look to model best practice for the UK strategy and have the vision to ensure we do not compromise future generations.
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.



Economics

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.

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 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(approx). 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 does not even use local plant hire since they contract from D. Wardle Plant Hire, a company in Cheshire. Sibelco's representative, Mr Hurley, has said at public meetings that 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, SIL 02 would have equalled 1 or 2 jobs created = £1.76M wage bill in Norfolk. The figures do not add up to anything close to the £15M that Sibelco claim to put into Norfolk's economy each year.

Aircraft Birdstrike Hazard

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 £100M+ per 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 could be argued that there is a set of lakes very close to RAF Coningsby and that is tolerated 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. It should be remembered that the large element of SIL 02 left in AOS E is a low-lying area and would be left as a wetland. It should also be noted that wetland birds migrate in large numbers, are unfamiliar with the very loud F-35 engine noise and will be 'spooked to flight' in a dense mass that is unavoidable by the pilot. It should also be noted that the migration routes of such large birds will alter to take advantage of new feeding grounds left by a quarry and their flightpath will not be known until they arrive or depart and they do not file flight plans for traffic deconfliction!

Summary
The destruction of Shouldham Warren is too high a price to pay in all respects for the silica sand it holds. There is no tangible benefit to West Norfolk communities. There are other areas nationally and internationally (Sibelco are a global company) other than AOS E in the short term that can continue to be exploited by necessity that have less affect on a community than this one while the country and Norfolk County Council properly steps up to the requirement to recycle more effectively and find sustainable processes for the longer term. Norfolk County Council and the Government should be convincing companies like Sibelco to evolve toward a more sustainable model perhaps by providing incentives and punitive measures to encourage it on that essential journey.

Object

Preferred Options consultation document

Representation ID: 94687

Received: 26/10/2019

Respondent: Dr Pallavi Devulapalli

Representation Summary:

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.

My objections are for the following reasons:

Climate Change
The UK has signed up to the Paris Agreement which in turn led to the Climate Change Act which commits the UK government by law to reducing greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050.
There is an urgent need to plant trees- the Woodland Trust estimates the UK needs to plant 1.5 billion trees by 2050 in order to reach net zero emissions. This is about 30000 hectares. In comparison, the Warren search area is 330 hectares of woodland. It is nonsensical to destroy existing woodlands when we are not meeting targets for new plantings.
It takes time to establish woods and we are not in a position to take down any trees at this point in time.
Norfolk needs to play its part in meeting our international obligations, so the trees must stay.

Biodiversity and tree cover:
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.

Health Benefits of Forests and the duties of the council vis a vis health of residents:
Studies have conclusively proven that exposure to forests and trees:
* boosts the immune system
* lowers blood pressure
* reduces stress
* improves mood
* increases ability to focus, even in children with ADHD
* accelerates recovery from surgery or illness
* increases energy level
* improves sleep
Section 12 of the 2012 Act 4 introduced a new duty for all upper-tier and unitary local authorities in England to take appropriate steps to improve the health of the people who live in their areas
The Health and Social Care Act 2012 delegated duties to local authorities to improve public health and reduce health inequalities. There is a range of legislation that protects biodiversity and urban green spaces by regulating planning, contamination and conservation, including the Wildlife and Countryside Act 1981, Environmental Protection Act 1990 and the Planning Act 2008. 
The Natural Environment White Paper addresses the importance of accessible green space and links to human health. The Health and Wellbeing Board has named prevention of ill health one of its top priorities and several studies have shown that £1 spent on enabling access to green spaces gives a return of £6 or more in benefits.
At a time when 1 in 5 children leaving primary school in West Norfolk are obese, the importance of doing all that we can as a society to encourage a healthier lifestyle cannot be underestimated.
West Norfolk is one of the highest areas in the country for GP prescribing of antidepressants, indicating a high prevalence of depression and anxiety in the population.
The NHS is under huge strain already trying to treat people, and the county council must do everything in its power to enable people to lead healthier lives, to reduce the burden on health services.
Shouldham Warren is used by a very large number of people from the surrounding areas to walk, cycle, and 'forest bathe'. It is used by cycling groups and the Ryston Runners have their races here every winter which are attended by a very large number of children and adults from far and wide. There is no other wooded area in this part of West Norfolk which could be used instead, and there is no doubt that people's health will suffer if they are denied access to these woods- a situation we can ill afford as a county.
If it goes ahead with giving permission to explore the area for sand quarrying, and thereby take down these woods, Norfolk County Council will fail in its obligations to look after the health of the people of Norfolk.

Traffic burden:
Increased traffic through the village will make it inhospitable, and increase noise and dust pollution and endanger the lives of people (elderly, children) as well as pets in the village.
The roads are not fit for carrying great loads of traffic.
There will be increased congestion on minor and major roads, and this in turn, will affect economic productivity.

Rationale for a quarry is not fit for purpose in this day and age
Sand is a finite resource and to say there is a 'need' for sand is short term thinking in the extreme. What will happen when the sand in this part of the world has been extracted in 20-30 years' time? What is the point of kicking the can a bit further down the road?
When will we come to accept that what is needed is a circular economy where nothing goes to waste, and everything is recycled or reused?
Its time to say enough is enough. To say no to further extraction of resources and to start mining landfills for materials and to have a county- (country- and world-) wide extensive glass collection and recycling mechanism.
It is clear that there are no benefits of the proposed quarry to anyone apart from the quarry company itself.
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.

Full text:

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.

My objections are for the following reasons:

Climate Change
The UK has signed up to the Paris Agreement which in turn led to the Climate Change Act which commits the UK government by law to reducing greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050.
There is an urgent need to plant trees- the Woodland Trust estimates the UK needs to plant 1.5 billion trees by 2050 in order to reach net zero emissions. This is about 30000 hectares. In comparison, the Warren search area is 330 hectares of woodland. It is nonsensical to destroy existing woodlands when we are not meeting targets for new plantings.
It takes time to establish woods and we are not in a position to take down any trees at this point in time.
Norfolk needs to play its part in meeting our international obligations, so the trees must stay.

Biodiversity and tree cover:
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.

Health Benefits of Forests and the duties of the council vis a vis health of residents:
Studies have conclusively proven that exposure to forests and trees:
* boosts the immune system
* lowers blood pressure
* reduces stress
* improves mood
* increases ability to focus, even in children with ADHD
* accelerates recovery from surgery or illness
* increases energy level
* improves sleep
Section 12 of the 2012 Act 4 introduced a new duty for all upper-tier and unitary local authorities in England to take appropriate steps to improve the health of the people who live in their areas
The Health and Social Care Act 2012 delegated duties to local authorities to improve public health and reduce health inequalities. There is a range of legislation that protects biodiversity and urban green spaces by regulating planning, contamination and conservation, including the Wildlife and Countryside Act 1981, Environmental Protection Act 1990 and the Planning Act 2008. 
The Natural Environment White Paper addresses the importance of accessible green space and links to human health. The Health and Wellbeing Board has named prevention of ill health one of its top priorities and several studies have shown that £1 spent on enabling access to green spaces gives a return of £6 or more in benefits.
At a time when 1 in 5 children leaving primary school in West Norfolk are obese, the importance of doing all that we can as a society to encourage a healthier lifestyle cannot be underestimated.
West Norfolk is one of the highest areas in the country for GP prescribing of antidepressants, indicating a high prevalence of depression and anxiety in the population.
The NHS is under huge strain already trying to treat people, and the county council must do everything in its power to enable people to lead healthier lives, to reduce the burden on health services.
Shouldham Warren is used by a very large number of people from the surrounding areas to walk, cycle, and 'forest bathe'. It is used by cycling groups and the Ryston Runners have their races here every winter which are attended by a very large number of children and adults from far and wide. There is no other wooded area in this part of West Norfolk which could be used instead, and there is no doubt that people's health will suffer if they are denied access to these woods- a situation we can ill afford as a county.
If it goes ahead with giving permission to explore the area for sand quarrying, and thereby take down these woods, Norfolk County Council will fail in its obligations to look after the health of the people of Norfolk.

Traffic burden:
Increased traffic through the village will make it inhospitable, and increase noise and dust pollution and endanger the lives of people (elderly, children) as well as pets in the village.
The roads are not fit for carrying great loads of traffic.
There will be increased congestion on minor and major roads, and this in turn, will affect economic productivity.

Rationale for a quarry is not fit for purpose in this day and age
Sand is a finite resource and to say there is a 'need' for sand is short term thinking in the extreme. What will happen when the sand in this part of the world has been extracted in 20-30 years' time? What is the point of kicking the can a bit further down the road?
When will we come to accept that what is needed is a circular economy where nothing goes to waste, and everything is recycled or reused?
Its time to say enough is enough. To say no to further extraction of resources and to start mining landfills for materials and to have a county- (country- and world-) wide extensive glass collection and recycling mechanism.
It is clear that there are no benefits of the proposed quarry to anyone apart from the quarry company itself.
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.

Object

Preferred Options consultation document

Representation ID: 94688

Received: 26/10/2019

Respondent: Campaigners Against Two Silica Sites

Representation Summary:

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

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.

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.

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.

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.

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.

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.
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.

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)).

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.

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.

REFERENCES:
(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
(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
(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
(7) Cheaperwaste.co.uk - Glass Collection Services - http://www.cheaperwaste.co.uk/services/glass-collections/
(8) Sibelco Glass Recycling Video - https://vimeo.com/242176163
(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
(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
(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
(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/

Full text:

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.

Object

Preferred Options consultation document

Representation ID: 94958

Received: 23/10/2019

Respondent: Mr Tim Pink

Representation Summary:

I object to quarrying in SIL 02. It is false of Norfolk County Council to say SIL 02 has not been allocated whilst retaining 1/3 of the area and re-badging as an Area of Search AOS E. This area has known mineral deposits and there is a willing landowner. These are the criteria that define a preferred area. NCC has agreed with the MOD (DIO) objection to SIL 02 that the WHOLE of SIL 02 should be removed but has consciously chosen to ignore it by not removing the overlap area of SIL 02 and AOS entirely. I object to this and demand that NCC removes this overlap area from their M&WLP. Please record this as my objection.

Full text:

I object to quarrying in SIL 02. It is false of Norfolk County Council to say SIL 02 has not been allocated whilst retaining 1/3 of the area and re-badging as an Area of Search AOS E. This area has known mineral deposits and there is a willing landowner. These are the criteria that define a preferred area. NCC has agreed with the MOD (DIO) objection to SIL 02 that the WHOLE of SIL 02 should be removed but has consciously chosen to ignore it by not removing the overlap area of SIL 02 and AOS entirely. I object to this and demand that NCC removes this overlap area from their M&WLP. Please record this as my objection.

Object

Preferred Options consultation document

Representation ID: 94961

Received: 23/10/2019

Respondent: Mrs Tina Pink

Representation Summary:

I object to quarrying in SIL 02. It is false of Norfolk County Council to say SIL 02 has not been allocated whilst retaining 1/3 of the area and re-badging as an Area of Search AOS E. This area has known mineral deposits and there is a willing landowner. These are the criteria that define a preferred area. NCC has agreed with the MOD (DIO) objection to SIL 02 that the WHOLE of SIL 02 should be removed but has consciously chosen to ignore it by not removing the overlap area of SIL 02 and AOS entirely. I object to this and demand that NCC removes this overlap area from their M&WLP. Please record this as my objection.

Full text:

I object to quarrying in SIL 02. It is false of Norfolk County Council to say SIL 02 has not been allocated whilst retaining 1/3 of the area and re-badging as an Area of Search AOS E. This area has known mineral deposits and there is a willing landowner. These are the criteria that define a preferred area. NCC has agreed with the MOD (DIO) objection to SIL 02 that the WHOLE of SIL 02 should be removed but has consciously chosen to ignore it by not removing the overlap area of SIL 02 and AOS entirely. I object to this and demand that NCC removes this overlap area from their M&WLP. Please record this as my objection.

Object

Preferred Options consultation document

Representation ID: 95123

Received: 15/10/2019

Respondent: Ms Alice Jordan

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95125

Received: 15/10/2019

Respondent: Ms Amanda Whiley

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Comment: Please look at this

Object

Preferred Options consultation document

Representation ID: 95127

Received: 15/10/2019

Respondent: Ms Amy Ranger

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95129

Received: 15/10/2019

Respondent: Ms Amy Taylor

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95131

Received: 15/10/2019

Respondent: Ms Annamarie Steer

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95133

Received: 15/10/2019

Respondent: Mr Anthony Collins

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95137

Received: 15/10/2019

Respondent: Ms Brooke May

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95141

Received: 15/10/2019

Respondent: Ms Catherine Heywood

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95143

Received: 15/10/2019

Respondent: Ms Christina Lee

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Comment: This is an area of outstanding beauty for all to enjoy and shouldn't be ruined.

Object

Preferred Options consultation document

Representation ID: 95145

Received: 15/10/2019

Respondent: Mr Christopher Webb

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95147

Received: 15/10/2019

Respondent: Ms Danielle Welham-Smith

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95149

Received: 15/10/2019

Respondent: Ms Diane McLucas

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Comment: Used to enjoy running through Shoudham woods and it's a beautiful place for walks.

Object

Preferred Options consultation document

Representation ID: 95151

Received: 15/10/2019

Respondent: Ms Emma Gallagher

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Comments
I have updated my objection due to new information.

Object

Preferred Options consultation document

Representation ID: 95153

Received: 15/10/2019

Respondent: Ms Helen Godfrey

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95157

Received: 15/10/2019

Respondent: Mr Jack Rolfe

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95160

Received: 15/10/2019

Respondent: Ms Jenna Corley

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95163

Received: 15/10/2019

Respondent: Ms Julie Wilmerson

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Object

Preferred Options consultation document

Representation ID: 95166

Received: 15/10/2019

Respondent: Ms Karen Burton

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.

Comment: I love to take my dogs over to Shouldham. This should definitely not go ahead!

Object

Preferred Options consultation document

Representation ID: 95168

Received: 15/10/2019

Respondent: Ms Karen Pledge

Representation Summary:

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.

Full text:

Objection to NCC
To: Caroline Jeffery, Principal Planner (Minerals and Waste Policy) Norfolk County Council 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.