SIL02 - land at Shouldham and Marham

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

1. Response to Draft Policies
1.1 Strategy - Vision and Objectives
1.1.1 Mineral Safeguarding should refer to paragraph 182 of the revised National Planning Policy Framework (NPPF) such that the applicant for adjacent development ('agent of change') should be required to provide suitable mitigation to take account of existing and allocated development.

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

1.2.2 MSO2
1.2.3 We suggest that MSO2 is amended to read (new text in CAPITALS):
"To provide a steady and adequate supply of industrial minerals by identifying adequate mineral extraction sites/areas within Norfolk sufficient to meet the forecast need AND STOCKS OF PERMITTED RESERVES OF SILICA SAND OF AT LEAST 10 YEARS PRODUCTION FOR INDIVIDUAL SILICA SITES OR AT LEAST 15 YEARS WHERE SIGNIFICANT NEW CAPITAL IS CAPITAL IS REQUIRED and safeguarding existing infrastructure"

1.2.4 We suggest that MS04 is amended to read:
1.2.5 "To safeguard silica sand, carstone, and sand and gravel resources for future use. Avoiding unnecessary sterilisation by encouraging the extraction of minerals prior to other development taking place where practicable and using minerals in construction on the land from which they are extracted. THE 'AGENT OF CHANGE' PRINCIPLE WILL BE APPLIED TO ANY NEW PROPOSED DEVELOPMENT IMPACTING ON SAFEGUARDED AREAS OR SITES."

1.3 Policy MW3 Transport
1.3.1 Proposed amendment to bullet point 4 under part d) of the policy:
1.3.2 "Where practical and realistic measures to reduce car travel to the site by workers and visitors and encourage walking, cycling and use of public transport."

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

1.4 MW6: Agricultural Soils
1.4.1 This policy should be applied flexibly since minerals can clearly only be worked where they exist and for silica sand for glass making the potential land is further restricted by virtue of the scarcity of this mineral.

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

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

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

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

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

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

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

1.6.1 There should be no buffers applied to the so-called planning constraints. The acceptability or not of approaching such constraints will be a matter for the EIA and the development management process. Arbitrary buffers risk the sterilisation of workable mineral when they could be satisfactorily worked without impact.

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

1.7 Policy MP11: Mineral Safeguarding Areas and Mineral Consultation Areas

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

2. Proposed Mineral Extraction Sites

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

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

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

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

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

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

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

2.7 Policy MP13: Areas of Search for silica sand extraction
2.7.1 Sibelco supports policy MP13. This policy should be applied flexibly since minerals can clearly only be worked where they exist and for silica sand for glass making the potential land is further restricted by virtue of the scarcity of this mineral.

2.8 SIL02: land at Shouldham and Marham
2.8.1 Sibelco supports the inclusion of SIL02 as an allocated site and would propose that given the promoters knowledge of the local geology, the site should be allocated as a Specific Site.
Further silica sand provision will be required at the end of the Plan period
2.8.2 The National Planning Practice Guidance says:
"designating Specific Sites - where viable mineral resources are known to exist, landowners are supportive of minerals development and the proposal is likely to be acceptable in planning terms..."
2.8.3 This definition applies to SIL02.
2.8.4 The Mineral Planning Authorities conclusion (paragraph 2.28) is subjective. It would be for any planning application coming forward on the site to proposed a method of working and restoration to satisfy concerns regarding bird hazard.
2.8.5 In the context of NPPF paragraph 16 the plan as written is not positively prepared and there remains a significant shortfall in silica sand supply. SIL02 should be allocated as a specific site with any subsequent planning application required to evidence the effective mitigation measure in relation to concerns regarding bird hazard.

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

The sites identified as part of the Norfolk Minerals and Waste Local Plan occupy the statutory birdstrike safeguarding consultation zone surrounding RAF Marham. The MODs main concern regarding mineral schemes is the phased working, proposed restoration and aftercare of the site. As the creation of open water bodies in this area has the potential to increase birdstrike risk to aircraft operations.
The preferred options paper identifies sites deemed viable for sand and gravel extraction. Please note each planning application is assessed on their individual merits at present there is limited information for a full detailed assessment to be carried out. The MODs original representation dated the 10th December remains extant:

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

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

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

AOS E Land north of Shouldham
The sites use is already constrained by Historic England. Therefore, the land to the south, east and west of AOS E is being identified for mineral extraction.
The area of search is approximately 6km west from the centre of the main runway at RAF Marham. It is difficult to determine the risk of wet restoration in this location without any plans illustrating the extent and design of open water bodies.
The MOD have safeguarding concerns to the wet working and restoration of this site due to its potential to attract and support hazardous waterfowl closer within critical airspace. Therefore, further information would be required before a definitive response can be made.

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

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

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

The MOD note site SIL 02 Land at Shouldham and Marham has been deemed to be an unviable site option. This site is approximately 4.8km north west from RAF Marham. The proposed extraction is a considerable area which is planned to be restored with large areas of open water.

A development of this nature in such proximity to the aerodrome is of great concern to aircraft safety.

Even if the site were to be reduced in scale this would be of serious concern to the MOD. Therefore, we support the removal of this site based on current restoration plans.

In summary, MIN 40 and MIN 6 the MOD has no safeguarding concerns subject to the implementation of a robust Bird Hazard Management Plan approved by the MOD as part of any planning permission granted.

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

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

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

Norfolk Minerals & Waste Local Plan Review 2019

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

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

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

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

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

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

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

Minerals Site Allocations

Silica Sand

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

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

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

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

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

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

Carstone

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

Breckland

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

MIN200
We support the restoration proposals for this site.

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

Broadland

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

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

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


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

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

Great Yarmouth

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

King's Lynn & West Norfolk

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

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

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

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

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

North Norfolk

MIN69 - north of Holt Road, Aylmerton
Whilst we are unable to comment on the wider impacts of this proposal as they are outside of our remit, should this site be progressed, then we strongly support the Council's recommendations that this site should only be worked dry in order to avoid hydrological impacts on the nearby Norfolk Valley Fens SAC and be subject to high quality restoration and formal aftercare, creating a large new area of heathland with benefits both for wildlife and green infrastructure provision. We support the precautionary requirement for noise and dust assessments as part of any application in order to evaluate potential impacts on nearby wildlife sites and the requirement to demonstrate that adverse effects on the Norfolk Valley Fens SAC would be avoided.

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

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

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

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

South Norfolk

MIN209
We support the proposed restoration scheme for this site.

MIN210
We support the proposed restoration scheme for this site.

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

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

MIN212
We support the proposed restoration scheme for this site.

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

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

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

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

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

2) The SCI sets out four "key principles" by which any consultation process should be judged:
Accountability (taking citizens' views into account), Accessibility (consultation is clear and genuinely accessible), Inclusivity (groups of the community are not excluded), and Efficiency (ensuring methodology delivers results). NCC failed on all four principles. An accessible consultation should not require 1000s of hours of effort to understand and participate. It should not rely on concerned members of the public informing the wider community or rallying various consultee groups to respond. It should not require the public to defend and ensure existing government policies are not violated. It should not require an MP's involvement to ensure that public concern is registered and addressed.

3) Some specific examples of the shortfalls in the consultation process are: a) NCC deemed it reasonable to only send 10 letters to residents within an arbitrary 250m boundary of the site, despite the proposed silica mine being the largest in the country and affecting thousands of people; b) using the same ineffective methodology for consultation: in the 2015 consultation, AOS E received 7 responses; in the 2018 consultation, due to the efforts of CATSS, AOS E and SIL02 received 460 responses. Other areas resulted in the same low level response (SIL01 - 8, AOS F - 3, AOS I - 4, AOS J - 6), because NCC continues to use ineffective methods of engagement with the residents of Norfolk.

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

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

Norfolk Minerals and Waste Local Plan - Preferred Options Draft 2019

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

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

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

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

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

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

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

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

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

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

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

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

Please note that absence of a comment on a policy, allocation or document in this letter does not mean that Historic England is content that the policy, allocation or document is devoid of historic environment issues. We should like to stress that this response is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise as a result of this plan, where we consider that these would have an adverse effect upon the historic environment.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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.

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.

Objection to AOS E - Land between Marham and Shouldham, including Shouldham Warren.

I wish to object to the proposed Silica extraction sites, namely: (SIL 02) at Marham and (AOS E) adjacent to Shouldham Warren.
I write this as a 71 year old man who [redacted text - personal data] therefore probably won't be around before the commencement of this devastating work. However, my conscience won't let me ignore this.
My wife and I moved to Shouldham in 2006. We have moved around from London, Essex, Kent and finally to Shouldham, where we have escaped the madness of increasing population and development of our green and pleasant land.
For this development to take place would be a travesty of common sense and a betrayal of the authorities obligation to it's population, that you are elected to serve.
The official campaigners have explained in eloquent terms, just had this will affect wildlife, the people in Marham and Shouldham, for years to come. This is a life changing event that will go on for years. The younger people in this area and their families, who are invested for the long haul by choice, will be forever affected.
This is without a doubt, a severe case of development vandalism. We know progress depends on change, but in this area the proposed change is overwhelming and irreversible.
I appeal that this be taken off of the Norfolk Minerals and Waste Plan, for the good of the community that you serve.

Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Mineral Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Submitted noise assessments and air quality/dust assessments should consider and include mitigation measures to deal appropriately with any potential health impacts, such as operational practices, separation/standoff areas and screening and/or bunding in line with Development Management Policies DM12 and DM13.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework.

Lighting:
Lighting is not included in the document as this is generally something which can be considered at any proposed planning application stage; however we would hope that any proposed lighting for site security and worker safety would be carefully considered prior to the planning stage so details can be submitted with any planning application. We would assume lighting would be pole mounted in elevated positions, and therefore the throw and spread of this should be assessed to ensure that there is no impact on residents. Light should be contained within the confines of sites and positioned appropriately. If necessary lighting is located near dwellings, this should be angled away and hooded/cowled to prevent any adverse impact on residents.

Vibrations:
The potential impact from vibrations should also be considered at any future planning stage, if sites are chosen close to residential receptors - including vibrations from site operations and associated transportation of extracted materials.

Soil Stripping:
Soil stripping operations must be effectively controlled through mitigation methods (e.g. buffer zones and bunding) to reduce fugitive emissions, which pose short term health impacts on nearby residents. These mitigation measures must be included in any future planning application.

Haul Roads:
Fugitive emissions from haul roads need to be addressed in any future planning application, with mitigation planned where necessary such as wheel washing.

[see attached table for comments on individual sites]

Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Waste Site Specific Allocations October 2019

Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Any future applications for waste sites should be accompanied by noise, odour, dust, and air quality management schemes, which should identify potential sources and mitigation/control measures to prevent nuisance issues and health impacts (e.g. emissions from as gas flaring).
Where sites are likely to be illuminated for safety/security, lighting plans and details should also be submitted which should include where lights will be located, their heights and angle/orientation, the type of lighting and the throw and spill of light across the site, and measures to ensure light spill is contained within site boundaries.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework

Existing Waste Site Specific Allocation Policies:
We note that WAS 05, WAS 25, WAS 36, WAS 40, WAS 37, WAS 45 and WAS 65 are no longer required and would therefore be deleted. There is therefore no risk to residential amenity from these sites.

Odour:
An odour impact assessment should be included within any future planning applications for allocated waste sites, along with suitable mitigation measures where appropriate.

Climate Change:
Climate change mitigation should be considered with regards to methane emissions (a greenhouse gas) released from allocated landfill sites.

[see attached table for comments on individual sites]

Comments sought on Preferred Options Consultation on the Norfolk Minerals and
Waste Local Plan (M&WLP).
Thank you for your consultation on the above site, received on 16th September 2019.
We were previously consulted on 28th June 2018 and responded under the following
reference, FWS/18/8/6750 -2, dated 30th July 2018. Our comments at that time are
included below:
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.

Policy MW4: We welcome that this policy supports policy MW2 with the provision of flood
risk assessments (FRA) and although not specifically stated we assume that this policy's
intention is that any FRA will include appropriate consideration of the most up to date
climate change allowances.
It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts
should be considered during a planning application and appropriate measures. These
measures may not be required until reinstatement when post development ground levels
are considered in detail.

With regard to specific sites put forward we have the following comments:

MIN12 - Beetly - We would like to highlight that we are aware of reports of external
flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.

MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems

SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

It is noted that our recommendation that policy MW2 is changed for point d) to
include groundwater flooding has not been taken forward. Our advice remains that
this should be changed.

Our comments on MW4, MIN12, MIN37 and SIL02 also remain.

CATSS Objection to the Vision, Policies and Objectives of The Preferred Options M&WLP 2019.

Please process this letter as an objection to both AOS E and SIL 02 in the M&WLP Preferred Options due to various policies and objectives that would not be fulfilled if they remain in the plan for consideration for quarrying in the future.

The very first paragraph of the M&WLP (pg 7) states, "The provision of a steady and adequate supply of minerals.......constitute essential infrastructure to support the economic development of the county". All of the silica sand quarried in Norfolk is taken out of the county for use elsewhere in the UK. Therefore, there is no argument that NCC can demonstrate that the extraction of silica sand is to 'support the economic development of the county'. NCC is also unable to define what a 'steady and adequate' supply is since at pg 8 of the introduction section of the M&WLP it states the proposed plan is to extract 750K tonnes per annum of silica sand based on the average sales data. This is in conflict with the statement by Sibelco, on pg 245 at the 4th bullet point under 'Site Characteristics' of SIL 02, that they would intend to extract 800-900K tonnes per annum from SIL 02 alone. So what is an adequate supply? Which figure is correct? If it is the 750K tonnes quoted by NCC then what are Sibelco intending to do with the extra 50-150K tonnes per annum from SIL 02? (Coincidentally this is the amount used in fracking in the UK at this time) It throws doubt on Sibelco's claim that the silica sand sole use is in the manufacture of clear glass. Interestingly, we were told the area SIL 02 contained approx 16,000,000 tonnes of silica sand. Two thirds of SIL02 has been removed in the preferred Options Plan but the NCC notice for the preferred options phase of consultation attached to Wessex BLD telegraph pole on Spring Lane at grid ref; X:5698, Y:3110, indicates the same amount,16,000,000 tonnes for extraction in the area which has only ⅓ of the original area remaining. How can that be?

The National Planning Policy Framework states that Mineral Planning Authorities should look to recycle before they start extracting raw materials. Norfolk (2014 figures) accounts for 20% of all silica sand extraction in the UK and 60% of the silica sand for clear glass manufacture. That is a huge amount of raw material being extracted yet the M&WLP does not make any mention of recycling glass, nor does it contain any figures of how much glass is recycled in Norfolk. The only figures available are for generic waste recycling of on average 46.7% (2016-17) described on the Norfolk Recycles web site. Norfolk Recycles is described as "the public facing brand of Norfolk Waste Partnership and Norfolk County, District, Borough and City Councils working together to improve waste and recycling services for Norfolk's residents and visitors". Therefore, when it comes to recycling glass before extracting raw materials the M&WLP is not sound .

We disagree with the following presumptions in the visions, policy and objectives and highlight our reasons in each case .
● Vision to 2036
○ Self-sufficient in sand and gravel whilst making important contribution to the national production of silica sand.
○ Progressive restoration and enhancement of Norfolk's biodiversity and creation of high quality, locally distinctive landscapes.
○ More responsibility of public and business for waste prevention, re-use and recycling.
○ Norfolk will aim to be net self-sufficient in waste management, where practicable.
○ Mineral development will be located, designed and operated WITHOUT adverse impacts on the amenity of local communities, the natural, built and historic environment, the landscape and townscape of Norfolk. They will also minimise the impact of climate change.

● There is no definitive demonstration that the UK needs to be self-sufficient in silica sand. The UK is not self-sufficient in defence - we buy equipment from around the world at a cost of billions of pounds; we are not self sufficient in medicines; or food that we import at a cost of millions if not billions; we are not self-sufficient in energy production - gas, electricity and oil all imported from outside the UK. Yet somehow we have to be in sand and glass? Without this demonstration of the requirement to be self-sufficient in silica sand, extraction of minerals by quarrying is purely because there is no vision to change; it is a classic case of business as usual because it is the easy option for the County Council and profit-driven industry. If the UK was truly intent on maintaining its mineral reserves then Government, aided and guided by Mineral Planning Authorities, would be looking for ways to ensure the minerals are conserved. 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..'. NCC does not adhere to this as it does not have a glass recycling programme worthy of the name; NCC merely collects glass and transports it outside of Norfolk for processing. In the UK 28 billion glass bottles and jars end up in landfill each year; 14 billion from households (recyclingbins.co.uk). Bars, restaurants and clubs in the UK throw away 200 000 tonnes of glass every year to landfill. Overall it is estimated that the UK throws away 1.5 million tonnes of glass to landfill each year; conveniently approximately 1.5 million tonnes of sand go to the glass making industry. What happens to the collected glass once beyond the county borders seems to be of no consequence to NCC. Therefore, NCC is failing in its duty to look to recycle before extracting raw materials and their vision is not sound.

● How can it be logical to say that you will enhance biodiversity if at first you allow it to be destroyed for decades by allowing mineral extraction in an already biodiverse area. In our case locally, there are over 150 different bird, animal, fish and insect seen on or near The Fen at Marham and The Warren at Shouldham, not to mention different plants, hedgerows and trees that support these diverse species. Sixty-four of the species are on conservation lists. We have birds that rely on farmland for foraging and nesting and some are already on the red or amber RSPB lists, these and other animals are protected by the Wildlife and Countryside Act 1981
( http://www.legislation.gov.uk/ukpga/1981/69 ).

Sibelco's record in the matter of post quarry restoration is appalling; one only has to look at Bawsey to see that their priority is not to enhance. It is not just Norfolk that has suffered, Sibelco has left behind a devastating legacy for the residents in and around Moneystone quarry, Staffs (this area has been a wasteland for many years). Sibelco, the owner and operator, when refused an extension to operate by the CC sold the land onto a property developer. The company, Laver Leisure's plans have been rejected by the CC, so the site is undeveloped. This is not opening up areas for the residents, this is about fee-paying amenities that are of no benefit to local people.
The Mineral Products Association awards , , highlight how other 1 2 3 mineral companies take restoration seriously. Not one of these awards were given to Sibelco. In addition, restoration of quarries in Norfolk is to man-made water-bodies which is hardly 'high quality, locally distinctive landscape'.

● If the public and business are to be expected to take more responsibility for their waste management and recycling and re-use of their waste, why are NCC not investing in high technology glass recycling facilities? In order to reduce the amount of silica sand extracted from Norfolk, the amount of clear glass recycled and reused in clear glass manufacture needs to increase; the M&WLP makes no mention of how NCC intends to make this happen in order to fulfil their vision of being net
self-sufficient in waste management in respect of glass.

● NCC state mineral development will be located, designed and operated WITHOUT adverse impacts on communities and areas and will minimise the impact of climate change. This is impossible and NCC knows that. Every mineral extraction site will have adverse impacts on various parts of the communities and areas they are in. If NCC is truly wishing to minimise impacts and reduce the effects of climate change, they would be seriously involved in the vision of an improved glass recycling/ glass manufacturing loop that was joined up between Waste Management Authorities, recycling business partners, glass manufacturers, the public and food and drink producers. The outcome of such a vision would be less glass going to landfill, more clear glass being available for recycling and use in clear glass manufacture, less CO 2 emission in the glass making industry and more jobs in Norfolk in both waste management and high tech glass recycling plant. Without this, the M&WLP Vision 2036 is not sound.

● Without a sound glass recycling policy/plan NCC fails their own sustainability objectives SA1, SA3, SA4, SA5. SA6, SA8, SA9, SA11 and SA13 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).

Draft Waste Management Strategic Objectives
● WSO1 - To support the prevention and minimisation of waste generation in line with the Waste Hierarchy, NCC needs to have a plan that enables more glass to be recycled/processed more efficiently to push it up the Waste Hierarchy, and not just collected and sorted. This is required so that more recycled material is made available to the glass making industry which, in turn, reduces the need for raw materials and the need to quarry silica sand. Currently, NCC does not have this in
their plan and this is out of step with the NPPF (Ch 17, para 204.b) and fails sustainability objective SA1 on pg 9 of the Sustainability Appraisal Report - Part AScoping (Oct 2015) and pg 15 of Part B (Jun 2019).

● WSO2 - To support the amount of waste reused, recycled and recovered NCC need to have a plan that includes glass waste to recycle and reuse. Currently NCC does not have this in their plan and this is contrary to the NPPF (Ch 17, para 204.b) and fails sustainability objective SA11 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 15 of Part B (Jun 2019).

● WSO4 - To achieve net self-sufficiency in waste management by 2036 NCC needs to include a plan to ensure more efficient glass recycling and reuse. Currently NCC does not have this in their M&WLP.

● WSO6 - To support reduction of greenhouse gases, minimise landfill and minimise waste transport distances, NCC needs to invest/champion a policy to have the infrastructure to be able to collect and process clear and coloured glass in greater quantity and quality. NCC currently does not have a plan to do this and this is contrary to the Climate Change Act 2008. Also, without a glass recycling policy NCC fails their own sustainability objective SA1 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 15 of Part B (Jun 2019).

● WSO8 - Recognise the importance of waste sector in the local community as a generator of employment and its provision of infrastructure which supports business and communities. There are plans to do this for waste streams other than glass. NCC needs to plan for glass within this objective and currently it does not. A high tech glass recycling plant in Norfolk would not only go towards fulfilling WSO8 but would also facilitate fulfilling WSO 1, 2, 4 and 6. It would also increase the employment opportunities in Norfolk and mitigate any job losses from the current mineral extraction and ancillary industries. Currently without a glass recycling plan NCC is failing their SA4 and SA13 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).

Draft Minerals Strategic Objectives
● MSO2 - To provide a steady and adequate supply of industrial minerals NCC & Gov need to quantify 'adequate' and not rely on the arbitrary figure of yesteryears' production of glass without consideration for the benefits of better recycling to produce high quality cullet to meet forecast need. NCC base the forecast need only on continuing to extract raw materials before considering better recycling of those raw materials, i.e. glass, which contravenes the NPPF (Ch 17, para 204.b). This objective also fails sustainability objective SA11 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 16 of Part B (Jun 2019).

● MSO3 - To encourage sustainable use of minerals by utilising secondary and recycled aggregates. This is the NPPF guidance that states mineral planning authorities(MPA) should look to recycle before extracting raw materials (Ch 17, para 204.b); however, NCC is failing in its duty in this respect with ref to silica sand for clear glass production. NCC does not currently consider increased and more efficient recycling of glass, particularly clear glass, in its plan in order to reduce the amount of extraction of raw material required from Norfolk. Nor is it considering a policy of glass reuse. Therefore, this objective fails ref the NPPF and NCC's own Waste Strategic Objectives and fails sustainability objective SA11 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 16 of Part B (Jun 2019).

● MSO6 - Expedient delivery of mineral extraction while..... positively contributing to the natural environment. NCC currently fails in this objective since the areas it plans to excavate silica sand from already have biodiverse natural environments and it is illogical to allow those to be destroyed if your Strategic Objective is to 'positively contribute to the natural environment'. MSO6 fails sustainability objective SA8 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 16 of Part B (Jun 2019). (In the case of SIL 02, (rebadged as part of AOS E) it cannot be described as expedient delivery since it is planned to leave this area in limbo until 2027; plus, mining for 20-30+ yrs followed by an unknown restoration is hardly 'positively contributing to the natural environment'). AOS E and that part of AOS E formally known as SIL 02 is a vast area. Whilst NCC says a small area could come forward, repeatedly after Sibelco gains a foothold in an area it continues to extend the area, aided by a county council who in its own plan and literature look positively at extending sites that have already been worked. We can forecast that Sibelco would be mining in this area for longer than the 20-30 years they promote.

● MSO7 - To ensure impacts on the amenity of those people living close to mineral developments are effectively controlled, minimised and mitigated. NCC cannot fulfil this objective without an unbiased health study data that shows the extraction of minerals, especially silica sand, does not have a health impact on people. With respect to the ⅓ of SIL 02 that remains within AOS E it cannot control, minimise or mitigate the impact on the view; residents of Upper Marham will have a clear view of any mineral workings from their elevated position. The local school overlooks this site; this is not an enhanced learning environment for the children of the area. NCC cannot control, minimise or mitigate for the imposed additional noise from HGV traffic and dredging, even if electric dredged, nor from a pipeline with wet sand being pumped over 6-8 km. Neither can NCC control the prevailing winds being towards Marham on which any noise and dust will travel. NCC cannot mitigate the loss of footpaths (PROW in our area). NCC cannot mitigate against loss of biodiversity for 20-30+ yrs. NCC cannot mitigate against the fact that important yet uninvestigated archaeological sites lie within SIL 02/AOS E that wet dredging will disturb and lose forever. Although SIL 02 is not to be allocated in the M&WLP approximately ⅓ of its geographical area is remaining as part of AOS E; therefore, the comments of the Sibelco representative stated at public meetings remain relevant, that "the site (SIL 02) will be minimally manned"; so any mitigation that Sibelco proffer to say they will stop excavation if important areas are found is just wishful thinking and disingenuous by the operator, based on the lack of manning and the dredging is underwater and out of sight. If any quarry had to be dry worked the area that NCC would permit is a well loved and well used area known as the Warren and Sincks. The health implications then are not just physical and mental wellbeing; they would include risks of respiratory problems as well as certain cancers and will be at the forefront of residents concerns. NCC would be failing in its duty of care to the council taxpayer to ignore the evidence from other countries who have studies linking serious diseases to silica sand - see http://www.hazards.org/dust/silica.htm.

● The road network is already under strain; off-road haulage routes will still end up on rural roads to get to the Leziate plant, and NCC cannot mitigate against the increase of CO 2 in this scenario. MSO7 fails sustainability objective SA2, SA8 and SA9 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).

● MSO8 - Address and minimise impacts on climate change. Only by reducing the amount of mineral extraction can NCC fulfill this objective. In order to do this NCC needs to plan to recycle glass more efficiently and to a better quality within Norfolk.
This will comply with the NPPF directive on recycling first, plus comply with the Climate Change Act and the UK's legal obligations to reduce greenhouse gas emissions. Currently NCC has no plans in place to fulfill this legal obligation with respect to quarrying for silica sand. (However, if Sibelco were to plan for an up to date glass recycling facility at Leziate then the railhead existing there could be used to deliver glass for recycling and take away the processed cullet for use in glass manufacturing, thereby reducing the carbon footprint of HGV to the plant). Sibelco are in partnership with leading glass recycling companies in Europe, why not the UK?. MSO8 fails sustainability objective SA1 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 15 of Part B (Jun 2019).

● MSO9 - Restoration. In respect of silica sand extraction within Norfolk to date NCC has failed in this objective by allowing Sibelco to operate within Norfolk. Sibelco's historical record for restoration of quarries it has operated is extremely poor4. Add the fact that the proposed areas are already extremely biodiverse, then making a statement about after use enhancing biodiversity is illogical if you need to destroy it for decades prior to any 'possible improvement'5. Due to Sibelco's proven poor record for restoration of previous worked sites, in reference to silica sand extraction MSO9 fails sustainability objective SA6, SA7 and SA8 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pg 16 of Part B (Jun 2019).

● MSO10 - Increase public access to the countryside .... through enhancing the amenity value of the land when restoring excavation sites. In terms of AOS E and the ⅓ of SIL 02 which remains in the plan as the eastern edge of AOS E, this objective is not in NCC's gift as it does not own the land. After allowing the land to be quarried by profit making developers who are only leasing it anyway, it will revert to the landowners who will in all likelihood sell it onto a developer as they will be unable to farm the land or replant it as a forest since it will not be restored, as it should be, back to the type of land it was previously. Sibelco have stated their intention would be to leave any quarry sites in SIL 02, and by extension now to the eastern edge of AOS E, as water bodies. Property developers akin to those at Moneystone6 whose legal wranglings take many years to resolve will not increase public access to the countryside; it will in fact reduce it. So how does NCC plan to fulfil this objective in respect to the proposed remaining portion of the 'Preferred Area' of SIL 02 that remains within AOS E and any other area of AOS E? MSO10 fails sustainability objective SA4 and SA9 on pg 9 of the Sustainability Appraisal Report - Part A Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).

General Policies
Presumption in favour of sustainable development as per Pg 6 para 11 NPPF
● The NPPF has 3 dimensions to sustainable development - economic, social and environmental.

● NCC's plan does not consider the infrastructure required for ensuring that the economic, social and environmental dimensions of sustainable development are accounted for in Norfolk with regard to glass recycling and the associated reduced mineral extraction. Therefore, the plan does not contribute to a strong, competitive economy (in Norfolk); support the health, social and cultural well-being of communities; and contribute to protecting and enhancing our natural environment, biodiversity, use of natural resources prudently, minimise waste and pollution and mitigate against climate change by moving to a low carbon economy through an innovative and technologically advanced glass recycling policy. Without this the plan fails sustainability objective SA1, SA4, SA6, SA8, SA9, SA11 and SA13 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015).

● There are no sustainable economic or social benefits to be had for the local areas around Marham and Shouldham from any quarrying in Shouldham Warren or Marham Fen. There would only be a couple of jobs created but the siting of a quarry will deter people visiting the area for recreation and tourism and will also stop any local growth, such as that being planned by the Borough Council of King's Lynn and West Norfolk in their Local Plan. Quarrying these areas will remove the social benefits currently enjoyed by residents and visitors to Shouldham Warren and the Nar Valley Way; this is hardly following the NPPF.

● MW2 - Development criteria. The policy lists 13 subjects, listed as a-m, that mineral development or waste management development should not have an unacceptable impact upon, including cumulative impact. In the case of AOS E and the area of SIL 02 that it still contains, only the subjects in points c. and j. may be able to be mitigated against. The other 11 points could not be mitigated against satisfactorily, especially the bird-strike risk already highlighted by the MOD (DIO) objection, and they would amount to a cumulative impact that isn't acceptable in any situation.

● MW3 - Transport. We agree with the NCC policy on transport in regards of mineral and waste developments. However, we fail to see how any mitigation measures would be sufficient to not generate all of the unacceptable outcomes listed in MW3 if any mineral development were to be granted permission in AOS E and the area of SIL 02 that it still encompasses.

● MW4 - Climate change mitigation and adaptation. NCC has no plans in place to account for reducing CO 2 emissions from the quarrying of silica sand. It should put in place a plan that increases the quantity and quality of glass recycling; this will reduce the amount of raw material (silica sand) required to be quarried, which reduces the CO 2 emissions from both quarrying and glass manufacturing (more recycled glass used in manufacture reduces CO 2 emitted and the energy required). MW4 fails sustainability objective SA1 on pg 9 of the Sustainability Appraisal Report - Part AScoping (Oct 2015) and pg 15 of Part B (Jun 2019).

● MW5 - The Brecks Protected Habitats and Species. We note here that birds are afforded a greater buffer zone than that considered acceptable for people close to any proposed or actual mineral development. That is unacceptable. However, there are breeding pairs of Nightjars within The Warren (AOSE) and possibly Woodlarks too, therefore, the Warren should be afforded a 400m buffer as per MW5.

● MW6 - In respect of the remaining ⅓ of SIL 02 that is within AOS E, this objective cannot be met since Sibelco (the company proposing the site) state the site would be restored to a lake and not returned to grade 3 agricultural land. In that case MW6 fails, in respect of the geographical area SIL 02 that remains as AOS E. MW6 fails sustainability objective SA10 on pg 9 of the Sustainability Appraisal Report - Part A Scoping (Oct 2015) and pg 16 of Part B (Jun 2019).

Waste Management Specific Policies
National Planning Policy for Waste
● WP1 - NCC states that 'new facilities.... which help to achieve the targets for recycling.....will be encouraged'. This is a policy that NCC should be pursuing itself and not relying on the private recycling companies to come forward with solutions. Also, the policy mentions that 'initiatives to reduce waste and improve recycling are largely outside the scope of this Plan', however, whilst individual initiatives may be outside the scope they are not exclusive from the Plan. NCC currently ignores the fact that recycling glass more efficiently would not only reduce the amount of CO 2 emissions in Norfolk and lessen the requirement for quarrying silica sand and destroying the Norfolk landscape, but would also vastly increase the local economy through the number of jobs created. This is a dereliction of duty to the taxpayers of Norfolk and not fulfilling the UK legal obligation to reduce CO 2 emissions. WP1 fails sustainability objective SA1, SA11 and SA13 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019).

● WP4 - NCC should also be planning to recover the glass from construction sites for recycling to improve the quality of cullet available for the manufacture of new flat glass. This would reduce the amount of raw material (silica sand) required to be quarried from the Norfolk countryside for use elsewhere. By not planning for this glass recovery and recycling NCC is not mitigating to reduce CO 2 emissions from quarrying the extra raw minerals and the reduction of CO 2 in glass manufacture from the inclusion of better quality glass cullet. In addition, NCC should also remind itself of the bullet points in para W0.8 about ensuring residents and businesses understand the importance of recycling, reuse etc, and its objective to increase the availability of waste reduction, reuse, repair and recycling centres - both of these are vital alongside an innovative glass recycling strategy as described at para W0.11, " a flexible approach to waste technologies so that innovation within the market is encouraged". WP4 fails sustainability objective SA1, SA11 and SA13 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) and pgs 15-16 of Part B (Jun 2019)..

Mineral Specific Policies
Forecast need for 13.5M tonnes of silica 2019-36; permitted reserves 3.0M tonnes, therefore, 10.5M tonnes required. All of this is based on no increase in the recycling of clear glass than is already happening

● MP1 -Flawed in respect of silica sand as it assumes that clear glass recycling will not improve, which would reduce the amount of CO 2 produced to extract silica sand and during the manufacture of new glass with use of additional high quality cullet. This conflicts with MSO3 and NPPF Guidance (Ch 17, para 204.b) that states to look to recycle before extracting raw material. MP1 fails sustainability objective SA1 and SA11 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015).

● MP2 - The area of 250m around sensitive receptors, etc is completely arbitrary and has no basis in research. In fact, data from research in other countries ref silica sand and its effects show that the dust particles that are of a size that can be inhaled deep into the respiratory system can be detected up to a mile away. There has been much talk from the Sibelco representative about the 'wet dredge' and how this mitigates any worries the public should have on the matter of particulates in the air and breathable silica sand dust. There is no information from Sibelco on the effects that stripping the top layers (overburden) has when it is removed. To be able to 'work' the mine the top layers will be removed to a depth of approximately 8m to expose the silica sand. The 'window' of deadly quartz particulates in the air from the disturbance of the soil is worst in the first six hours of removal. So this will directly affect those living in close proximity, i.e. those in a 1 mile radius. There have been no studies conducted in the UK, therefore, a 250m zone to mitigate against respiratory dust is unsound. MP2 fails sustainability objective SA2 and SA9 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015). In addition it is noted that in policy MW5 a buffer of 1500m from a mineral site is mandated for areas supporting a bird (Stone Curlew) yet a buffer of merely 250m, or less, is deemed acceptable for humans. This also makes the M&WLP unsound.

● MP5 - There needs to be a specific time scale added to this statement as to destroy biodiversity for profit under the guise of enhancing it later (20-30+ years hence) through restoration is an illogical step and unacceptable. Also the M&WLP at section MP5 on page 76 describes Core River Valleys in Norfolk as ' vital ecological habitats and corridors, supporting a variety of biodiversity habitats and species. In this respect, Core River Valleys are a key component in the development of Norfolk's identified Green Infrastructure corridors. Sand and gravel resources are commonly found in river valleys and many of Norfolk's river valleys have therefore been quarried for aggregate extensively over many years. This has led to many large bodies of open water left on restoration of past mineral workings which are not in keeping with the general character of Norfolk's river valleys. Although not formally designated, safeguarding the Core River Valleys will help preserve the unique and rich quality of Norfolk's landscape and natural heritage '. With ref to AOS E, including the overlap area that includes a part of SIL 02, with a water bodies already at Pentney and at the Middleton aggregate works just to the north of the river Nar SSSI, then the addition of a much larger water body (e.g.such as the aftermath of SIL 02 as described by Sibelco previously) so close would be exactly what this paragraph explicitly says we shouldn't be doing. Therefore, to continue to include AOS E and its overlap with SIL 02 in the M&WLP would be a flawed decision by NCC. For AOS E and the overlap of SIL 02 that it includes, MP5 fails sustainability objective SA5 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015) for the amount of time it is a visual intrusion; fails SA8 because of the excessive time-scale involved and the after use proposed; and SA9 due to the time-scale involved.

● MP6 - Whilst MP6 is about cumulative impacts from other concurrent mineral extraction sites, (we are surrounded by mineral sites and plants in West Norfolk already), and Middleton aggregates is just across the river Nar, it fails to address the other potential cumulative impacts in an area, e.g. a close military airbase with the comings and goings of HGV in the build up of the base to support the new F35 and the daily deliveries needed to support our national security or other industrial process, plus the persistent jet noise. Neither does it mention the cumulative impacts mentioned on pg 31 at 8.46 - amenity, the economy, the natural and built environment, the local road network and the period of time for working an area if it is to be prolonged. This policy requires a complete rewording to include the points missed from pg 31. For AOS E and the overlap of SIL 02 that it includes, MP6 fails sustainability objective SA3, SA4 and SA9 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015).

● MP7 - Restoration of a site relies on the operator being the owner. Where this isn't
the case then MP7 does not account for the landowner denying opportunities for greater public access after gleaning the financial benefits from the mineral extraction whilst the local community suffer the losses of amenity involved with a mineral extraction site for many years and even generations. Neither does it address the timescale that some sites may be actively quarried before greater public access is potentially achievable. Finally, it does not specify that the restoration will be for the benefit of the local community and not a fee paying public for a development by a private company. MP7 fails sustainability objective SA4, SA8 and SA9 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015).

● MP11 - States on pg 83 of the M&WLP that minerals are a finite natural resource; therefore, NCC's M&WLP is flawed without plans to extend the life of the silica sand resources in Norfolk through an advanced glass recycling policy and plan. MP11 fails sustainability objective SA11 on pg 9 of the Sustainability Appraisal Report - Part A- Scoping (Oct 2015)

 
● Finally, comment on Sustainability Appraisal Report (SAR) Part A - Scoping (2015) . I specifically include here section 2.2 Approach to the SA/SEA Process
○ In applying SA/SEA to the Silica Sand Review of the Minerals Site Specific Allocations DPD and the Minerals and Waste Core Strategy Review, Norfolk County Council aims to:
■ Identify alternative options for delivering sustainable minerals development in Norfolk;
■ Identify alternative options for delivering sustainable waste management facilities in Norfolk;
■ Further enhance positive environmental, social and economic effects of the plan; and
■ Reduce and minimise the negative environmental, social and economic effects that may result from the implementation of the plan.

Nothing in the NCC Silica Sand Review addresses the aims stated in section 2.2 with respect to 'alternative options for delivering sustainable minerals development in Norfolk, or 'further enhance .... economic effects'. As discussed throughout this paper only an up to date, efficient glass recycling programme for Norfolk will address the aims stated in the SAR section 2.2. At this moment the M&WLP fails this section.

References
1 https://mineralproducts.org/restoration_and_biodiversity_awards_2013.htm
2 https://www.cemex.co.uk/-/eversley-quarry-restoration-plan-is-runner-up-in-mpa-quarries-and-natureawards
3 https://mineralproducts.org/15-release28.htm
4 https://www.bbc.com/news/uk-england-norfolk-23354729
5 https://mineralproducts.org/restoration_and_biodiversity_awards_2013.htm
6 http://moderngov.staffordshire.gov.uk/documents/s47001/Planning%20Cttee%2006%2003%202014%20Moneystone%20Quarry%20rept.pdf