Initial Consultation document

Object

Representation ID: 91923

Received: 01/08/2018

Respondent: Fritton Action Rescue Group

The forest site was used by the army for 'live firing' exercises during both world wars.
Any descending 'dud' shells or mortar bombs would penetrate some distance into the sandy ground and in time get buried even deeper by the accumulation of compacted pine needles. The lost ordnance items could well have, by now, become sensitised by 'sweating' of the explosive charges.
Some two years ago one came to light near Staith Road track. After a police guard overnight, and residents having been warned, the bomb was detonated in situ by Army Bomb Disposal.
We advise, on health and safety grounds, that prior to any extraction a comprehensive 'mine clearance' of the site be carried out.

Object

Representation ID: 91924

Received: 01/08/2018

Respondent: Fritton Action Rescue Group

To gain some physical insight into how stringent requirements for air quality are now becoming please see attached figure. It begs the question what if they spilled two handfuls or more?
Try as you might to contain it a little stray dust goes a very long way. A handful of dust (about 200 grams) Is all it takes to impart a hazardous illegal level of contamination* to the volume of air contained in over seven R101 airship sheds.
Under more stringent air quality regulations soon to be introduced the volume will equate with twelve R101 airship sheds (about a quarter of the air contained within the whole Waveney Forest between ground level and tree top height).
*National air quality objectives and European Directive limit and target values for the protection of human health. - no more than forty millionths of a gram of dust to each cubic metre of air.

Object

Representation ID: 91925

Received: 01/08/2018

Respondent: Fritton Action Rescue Group

The applicants may suggest that deep belts of trees (if they survive progressive wind felling from exposed margins) may screen residents from noisy quarry activities.
However, local experience is that since the clear felling of some timber stands the forest has been even quieter than before.
This is not surprising as with belts of trees the space between the canopy and the ground acts as a wave guide for audio frequency sound, carrying forwards and perpetuating sound which would otherwise spread and attenuate.
Nor would the tree trunks themselves have a significant screening effect as their total horizontal cross section comprises only 500th part of the superficial ground area below the trees.

Object

Representation ID: 91926

Received: 01/08/2018

Respondent: Fritton Action Rescue Group

It is commonly observed that when the finer siliceousious minerals are tipped into a container from a bucket the air displaced upwards lofts the fine particulates to many times the original drop height from which should the wind blow they are apt to overtop any practicable 'screening'

Object

Representation ID: 91927

Received: 01/08/2018

Respondent: Fritton Action Rescue Group

If the quarry is permitted there is robust scientific evidence # (drawn from bona fide scientific journals subject to peer review) to show that many mainly elderly villagers, some with existing respiratory problems, will be exposed to wholly unacceptable, dangerous levels of airborne quarry dust. Also if the forest is allowed to continue the carbon sequestered would allow the minerals to be road hauled many, many miles from more suitable site on a lower carbon budget.
Recent national concerns about the harmful effects of breathing airborne particulates together with revised standards for air quality have prompted our Action group to reappraise available scientific data on pit generated dust plumes.
Consideration of California University's statistically robust study near a sand and gravel facility (Appendix 1) yields the PM10 dust fall-out plot shown in Figure 1 (left hand half). It is to be noted that the furthest data point is only 745 metres from source.
Quite extraordinarily the applicants themselves cited the Benchmark study (Using human test subjects and unlikely to be repeated on ethical grounds) which covered exactly 800 to 1400 metres from source (Appendix 2). See PM10 dust fall-out plot figure 1 (right hand half). It is notable that, as might be expected, the two halves of figure 1 are entirely consistent with each other forming the classical dust fall-out plume, akin to that of a major meteorite impact, volcanic eruption or nuclear detonation, albeit on a much smaller scale. That these independently sourced plots are consistent is a very strong indication of their scientific validity. Consideration of the left hand half of figure 1 indicates that properties within 300 metres of the proposed pit will be exposed to PM10 dust concentrations of over 40 micrograms/m3, being in excess of European limits.
It is probable that at greater distances the remaining airborne dust concentration will comprise mainly of particles up to PM2.5, originally contained within the initial PM10 concentration. The heavier factions, as the applicants rightly state, will already have fallen out as 'nuisance dust' in a comparatively short distance down range, leaving the smaller particles to dominate both gravimetrically and (more health critically) numerically vastly so - Figure 2. This being so the max allowable limit of 25 micrograms/m3 for airborne PM2.5 shortly to come into force* indicates that properties within some 500 metres of the proposed pit will be exposed to airborne dust concentrations in excess of U.K and European limits.*
*National air quality objectives and European Directive limit and target values for the protection of human health.
It now seems appropriate to go on to review the right hand half of Figure 1. Before this can be done, however, a number of issues must be considered. The wholly siliceousious dust from the Fritton pit is unlikely to be any less harmful to the exposed Fritton residents than the dust from the open-cast coal workings was to the exposed test subjects of the Newcastle University study.
Although the open-cast dust incorporates a carboniferous faction as well as the faction generally attributable to siliceousious overburden # both factions are likely to be similarly hazardous, having mutually consistent air dispersal characteristics with both Carbon and Silicon atoms having six electrons in the outer shell where, for reactivity, it counts. Breathing airborne dust will have a much greater impact on exposed Fritton residents many of whom are elderly, some with respiratory problems, than on the young healthy test subjects of the Newcastle University study. In the latter study customary mitigation measures to limit dust emissions at source would be required for a realistic outcome and to accord with Coal Authority recommendations. #Winning coal from open cast mines generally entails the excavation of significant tonnages of siliceousious overburden to ensure safety and stability. Depending on the price of coal this may range up to twenty times the tonnage of coal extracted:- H.M Dept. of Business Energy and Industrial Strategy (Coal Authority - Mines Licensing Dept.)
The right hand half of Figure 1 shows a PM10 concentration only a few micrograms/m3 above background. Despite this all determinations from 750 up to 1,400 metres from source were associated with an increase in respiratory related G.P. consultations of some 40% (Appendix 2). Placed within the context of the proposed Fritton quarry, assuming the applicants worked to the edge nearest to a given human receptor, which they would be entitled to do, the zone in which a markedly increased level of respiratory related G.P. consultations would be expected is as shown in Figure 3 (in-hatched portion). This includes a significant part of neighbouring St. Olaves. G.P. consultations could substantially exceed 40% because of the vulnerability of the mainly elderly population. Over 400 people reside within this zone. Even if, as an extreme measure of mitigation, the applicants were to work only a 100 metre wide strip on the edge of the site furthest from a given receptor, the zone of expected marked increased G.P. consultations would be shown in Figure 4 (un-hatched portion). Nearly 200 people reside within this zone. If the applicants were to work more than this the hazardous zone would be proportionately larger.
The Planning Environmental Division of H.M. Communities Dept. recognise that mineral extraction has an environmental impact and that planners should give very careful consideration to its likely effects on the surrounding area - and the views of local residents. Also L.A.s are now responsible for both the health and well being of their residents. Accordingly we ask that you reject the proposed application, amongst other reasons, to protect our mainly elderly, vulnerable, residents from dangerous levels of airborne particulates.
Also note that if the forest continued intact the carbon sequestered by the trees would enable the same mineral yield to be fetched many, many, miles by road from a more suitable site on a lower carbon budget!

Object

Representation ID: 91944

Received: 01/08/2018

Respondent: Fritton Action Rescue Group

Changes since previous application
Summary
1. Re-surfacing of the A143 and speed reductions due to Fritton's 'speedwatch' have reduced traffic sounds and will render the noise impact of any quarry generated sound more intrusive.
2. Erosion of timber stands by progressive wind-felling of exposed margins shows that 'shelter belts' are not practicable.
3. Recurrent, intractable, underground fires demonstrate the extreme dryness of the forest terrain.
4. The potential danger of unexploded ordnance has been shown by the required service of Amy Bomb Disposal.
5. A channel has been cleared, with planning consent, to allow eels from the River Waveney to access Fritton Lake. This channel is potentially vulnerable to changes in the water table and runoff contamination.
6. Numerous vulnerable horses and cattle in a nearby animal sanctuary are now placed closer to potential sources of harmful particulates than hitherto.
If you require further details of the points above read on:
1. Changes to the A143
Since the previous quarry noise impact assessment the Fritton section of the A143 has been resurfaced with 'silent running' tarmac with a very noticeable (>20dB?) reduction in traffic noise. Also traffic speed and noise has been reduced by the actions of local Speedwatch. These changes will make the noise impact of quarry generated sound greater and more intrusive.
2. The vulnerability of screening 'belts'
Due to the general elevation of Waveney Forest relative to some surrounding terrain, and due in particular to the broad fetch between Haddiscoe and the forest, there is a significant level of wind exposure. Also, because of the sandy nature of the soil, trees are not firmly rooted, and so particularly likely to be felled by the wind.
In recent years mature stands of timber have been harvested by clear felling prior to replanting. Single lines of trees were let along one section of the western edge of the forest and close by forest lodge. In both cases these trees were felled by the wind within a matter of days.
Since the clear fell harvesting of the mature timber stands, remaining stands have suffered progressive erosion by the wind felling of trees along their exposed margins. These losses already total upwards of sixty trees with the remaining trees becoming vulnerable, as they in turn, become exposed on the margin.
Local experience indicates that further wind felling is likely whenever maximum gust speed (measured 10 metres above the ground) exceeds 50 knots. This usually happens several times a year.
3. Dryness of the site terrain
In the last few years numerous fires have occurred. Many of these penetrated below ground, some requiring multiple visits by the Fire Brigade to finally extinguish them.
Some five years ago one such fire was attended by over ten different fire appliances, needed two separate 200mm hose lines totalling 1.4km in length drawing from the river Waveney, and still took longer to extinguish then the Great Fire of London (four days).
Since that time Fire Brigades have held training exercises in the forest which should enable them to deal more effectively with future serious outbreaks.
4. Unexploded ordnance
The forest site was used by the army for 'live firing' exercises during both world wars.
Any descending 'dud' shells or mortar bombs would penetrate some distance into the sandy ground and in time get buried even deeper by the accumulation of compacted pine needles. The lost ordnance items could well have, by now, become sensitised by 'sweating' of the explosive charges.
Some two years ago one such same to light near the Staithe Road track. After having a policy guard overnight, and residents having been warned, the bomb was detonated in situ by Army Bomb Disposal.
It is advised, on health and safety grounds, that prior to any excavation, a comprehensive 'mine clearance' of the site be carried out.
5. Eel channel - As instigated by Lord Somerleyton.
6. Animal Sanctuary
We previously warned of the dangerous effect of particulates affecting not only the villagers but the horses at Redwings horse sanctuary at Redwings if the wind was from the west. Since the last application Hillside animal sanctuary has moved in to the west and southwest immediately adjacent to the woods boundary and horses and cattle (many hundreds) some with special needs are even closer to the quarry. Many of these are old abused and delicate animals in need of quiet sanctuary not the noise dust and disturbance of a massive quarry.

Object

Representation ID: 92996

Received: 01/08/2018

Respondent: Fritton Action Rescue Group

Noise impact of proposed quarry at Fritton
Where noise impact assessment is concerned the quieter the location considered the less acceptable is any additional sound.
It is not surprising, therefore, that in a quiet rural community like Fritton the predicted noise impact of a nearby mineral extraction and processing facility would be wholly unacceptable, and would, indeed, in some habited areas, be well in excess of the normal measurement scale.
Local Authorities are required to take such environmental impacts on surrounding areas very seriously (HM DCLG Planning and Environment Division). Accordingly we request that the quarry proposal be rejected.

Previously the applicants assessed the potential noise impact of their road haulage activities but not that of the much noisier extraction and processing operations.
On this occasion our team has, on a conservative basis, assessed the noise impact of the proposed quarry on Fritton and its environs.
For this assessment the sound of quarry activity is taken to be akin to that of a lorry at 40mph at a range of 50ft (15.24 metres), namely 84dB. This is very conservative estimate in that the sound output of road vehicles is very strictly regulated, as compared to quarry machinery. Furthermore, although quarries may seek to control their noise footprint, independent quantitative assessment of their control measures is advised. Pervasive low frequency 'rumble', apt to characterise their activities, is hard to mitigate, both at source and at the receiving end.
We next need to select an ambient sound level to represent that normally experienced by the community FIGURE 1 shows, on a 0.5km x 0.5km grid, tranquillity determinations from the CPRA's 2007 survey. Most of the forest area is highly tranquil (coded green), near the metalled roads moderately tranquil (coded yellow) and the grid square containing the main concentration of Fritton dwellings least tranquil (coded tan). Again, on a conservative basis we will take the ambient sound level in this noisiest grid square (previously determined by the applicants as 42dB) to represent this community as a whole.
Using the above sound levels we can proceed to determine the corresponding noise impact levels for the area surrounding the mineral extraction zone (assuming the applicants conduct their activities up to the edge - which is their right). To do this we determine the predicted ambient sound levels due to our 84dB source using the inverse square way, addition logarithmically the original 42dB ambient (see appendix 1 and appendix 2). We can then determine noise impact values (simply the difference between the existing ambient sound level and the predicted sound level). The distances from source for convenient noise impact levels 5dB, 7dB, 10dB etc. can be determined by interpolation from Appendix 1 to yield the sound impact footprint shown in Figure 2.
From Figure 2 it can be seen that the Fritton community would suffer a noise impact of at least 5dB, and near the quarry over 30dB. On the accepted basis of a doubling of perceived sound for every 10dB increase such impact levels are clearly unacceptable. This noise will affect not only our resident community but also the many hundreds of people who visit Fritton's vehicle free Waveney amenity forest to escape the hubbub of the port conurbations of Lowestoft and Gt Yarmouth and to enjoy some rural tranquillity.
We understand that the threshold of the noisiest impact category mooted (guidelines for Environmental Noise Impact Assessment 2014) termed 'major' is a mere 10dB. If so, given that below this, category impact scale intervals are at most only 5dB in width, it is plain that the noise impact levels shown in Figure 2 arrange well below the normal expected scale of measurement.

Furthermore the Figure 2 noise impact footprint is conservative for much of the area covered. For the quieter parts, broadly corresponding with the green coded part of Figure 1, a 'wilderness' ambient of 35dB would be more appropriate than the 42dB used in which case the noise impact contours would stand higher by some 7dB.

Also for the quiet properties deep within the forest, namely 'Roundhouse' and 'Forest Lodge' where, on occasion no sound is audible beyond one's own breathing and heartbeat, ambient sound of 25dB, used to determine when a receding sound has passed out of earshot, would be a realistic basis for assessment. On this basis, working minerals 500 metres away would cause a noise impact at the properties of some 30dB, and, what is more, minerals could possibly be worked as close as 120 metres, yielding an impact of some 40dB. On the accepted basis of doubling for each 10dB increase this represents a perceived sound level (2 x 2 x 2 = 8 times) the threshold of noise mooted as 'major'.
Such a noise impact would surely constitute some form of record.
Taking account of the guidance of HM Communities Planning and Environment Division we ask that the proposal for a quarry at Fritton be rejected on noise impact grounds.