Preferred Options consultation document

Please find enclosed the comments and objections of Wormegay Parish Council to the proposal of AOS E and J areas of search and to SIL 02, as requested under the Preferred Options Consultation on the Norfolk Minerals and Waste Local Plan (M&WLP).
Julian Snape Clerk Wormegay Parish Council
WORMEGAY PARISH COUNCIL October 2019.

Norfolk County Council Waste and Minerals Plan Consultation Comment
Wormegay Parish Council objects to the proposal of AOS E and J as areas of search, furthermore it objects to SIL 02, which although as a preferred site was removed from the plan in name following a significant object from the MOD, has in fact had almost a 1/3rd of it retained within the bounds of AOS E.
The Parish Council has listened to its residents, researched open source information and believes that there is compelling evidence and reasons from the perspective of health and wellbeing, climate change, recycling and preservation of finite minerals and that the economic case is significantly disproportionate in favour of industry rather than the wellbeing of the local community and wider population estimated to be in the thousands every year who use the Shouldham Warren for leisure, educational, Forest Church and a variety sporting activities. This is also underpinned in the Forestry
England Should ham and Bilney Forest Plan 2016-2026. The Forest Plan outlines the need to consider, people, economy and nature and is a fine balance that needs to be carefully sustained. AOS D (West Bilney) as well as AOS E (Should ham Warren) both fall under this Forestry England plan but they have not commented as a consultee nor has the plan been referred to in any of the County officer's responses to other nature related comments. Forestry England are a significant consultee and their 2016-2026 plan has seemingly been overlooked completely.
In addition, the infrastructure from a highways perspective would require significant improvements to make it safe for access and to prevent further adverse impact on the traffic flow along the entire proposed route, which is renowned for long delays at the Hardwick and Hospital roundabouts and roads leading to them. This would mean further roadworks with the associated cost to who? And the disruption and delays while it took place. Monitoring of the yellow hatch box on the Hardwick is already a iow priority and widely disregarded by locals, commercial and tourist traffic due to lack of enforcement and not serving to keep traffic flowing.
It should also be noted that this route increases the heavy goods traffic directly past Wormegay Primary School. This increased noise and associated pollution will only add to the further detriment of the health and wellbeing of both the pupils and staff. Another legacy that we as the guardians of the area cannot and should not burden future generations with.
The prime company (Sibelco) who would likely quarry the site for Silica Sand, if given the planning permission, have a poor track record as a neighbour and despite invitations to discuss what they would likely do by way of restoration have offered nothing, the County Officer's comments on restoration, quote policy and offer no detail or assurance as to how policy would be enforce. we would most likely be left with a scar on the landscape with low level land allowed to fill with water at best or used for landfill at worst; the Should ham mound would disappear along with the features that make it attractive, either way it will never be able to be returned to the positive asset that it represents today.
Climate Change
The UK has signed up to the Paris Agreement which in turn led to the Climate Change Act which commits the UK government by law to reducing greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050.
There is an urgent need to plant trees- the Woodland Trust estimates the UK needs to plant 1.5 billion trees by 2050 in order to reach net zero emissions. This is about 30000 hectares. In comparison, the Warren search area is 330 hectares of woodland. It is nonsensical to destroy
existing woodlands when we are not meeting targets for new plantings. A recent news report
detailed how West Norfolk alone had to plant in excess of 64,000 new trees within the next decade.
It takes time to establish woods and we are not in a position to take down any trees at this point in
time. See the Forestry England Plan.
Norfolk needs to play its part in meeting our international obligations, therefore the trees must stay.
It is also interesting to note that Norfolk County Council are in support of a re-wilding venture
currently underway on farm land just outside Kings Lynn. This was featured on BBC television "Inside
Out East". In essence, the scheme, currently funded by the EU and HMG, which will be maintained
after Brexit, aims to return farm land to the wild with the intent to encourage the return of wildlife
and combat climate change. The schemes ambition is to create pathways and "stepping stones" for
wildlife to naturally venture between the Brecks, Norfolk coast and the Fens. AOS E and J both sit in this "pathway". These proposed quarries, yet again, are in direct contrast to other local, national and international projects.
Health and Wellbeing
The Health and Social Care Act 2012 delegated duties to local authorities to improve public health and reduce health inequalities.
* There is a range of legislation that protects biodiversity and urban green spaces by regulating planning, contamination and conservation, including the Wildlife and Countryside Act 1981, Environmental Protection Act 1990 and the Planning Act 2008. * Section 12 of the 2012 Act 4 introduced a new duty for all upper-tier and unitary local authorities in England to take appropriate steps to improve the health of the people who live in their areas.
Studies have conclusively proven that exposure to forests and trees:
* boosts the immune system
* lowers blood pressure
* reduces stress
* improves mood
* increases ability to focus, even in children with ADHD
* accelerates recovery from surgery or illness
* increases energy level
* improves sleep
The Natural Environment White Paper addresses the importance of accessible green space and links to human health.
At a time when 1 in 5 children leaving primary school in West Norfolk are obese, the importance of doing all that we can as a society to encourage a healthier lifestyle cannot be underestimated.
West Norfolk is one of the highest areas in the country for GP prescribing of antidepressants, an indication of a high prevalence of depression and anxiety in the local population.
The NHS is under huge strain already trying to treat people, and the county council must do
everything in its power to enable people to lead healthier lives, to reduce the burden on health
services.
Shouldham Warren is used by a very large number of people from the surrounding areas to walk,
cycle, and 'forest bathe'. It is used by cycling groups and of the Ryston Runners have their races here
every winter which are attended by a very large number of children and adults from far and wide.
There is no other wooded area in this part of West Norfolk which could be used instead, and there is
no doubt in my mind that people's health will suffer if they are denied access to these woods.
Norfolk County Council should also be made aware that there is local anecdotal evidence to suggest
that the area of wood known as Mow Fen has been used as a route for the monks to camp and rest
whilst travelling between various abbeys and religious festivals within the west Norfolk area. This
would suggest that this fen would be of historic interest. This should be coupled with the fact that
the small bridge near thee pumping station at Wormegay and Mow Fen was built by the Canadian
forces during World War 2. The bridge and the Mission room within Wormegay were gifted to the
village. Therefore, one would suggest that this bridge on the approach of Mow Fen is also of
significant historical value.
If NCC goes ahead with giving permission to explore the area for sand quarrying, it will demonstrate
a disregard for the population today and, perhaps more importantly, future generations; Norfolk
County Council will fail in its obligations to look after the health of the people of Norfolk.
Recycling and Preservation of Finite Mineral Resource.
The Ministry of Housing Communities and Local Government document, the 'National Planning Policy Framework', sets out the Government's planning policies for England and how these should be applied. The document states (Section 2: Achieving Sustainable Development, at para 7), "The purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs" - Resolution 42/187 of the United Nations General Assembly. The document also states (Section 17: Facilitating the Sustainable Use of Minerals, at para 203), "It is essential that there is a sufficient supply of minerals to provide the infrastructure, buildings, energy and goods that the country needs. Since minerals are a finite natural resource, and can only be worked where they are found, best use needs to be made of them to secure their long-term conservation." As stated, sustainable development should not compromise future generations to meet their own needs, and that minerals are a finite natural resource; quarrying is not sustainable and committing to it for the next generation is to show neglect of duty. Here in Norfolk, as we do in many fields, we should look to model best practice for the UK strategy and have the vision to ensure we do not compromise future generations. The NPPF states, 'Planning policies should: .... so far as practicable, take account of the contribution that suitable or secondary and recycled materials and minerals waste would make to the supply of materials, before considering extraction of primary materials ... ' (Sect 17, para 204. b). There is no attempt within the NCC M&WLP to discuss how improved recycling or reuse of glass within Norfolk, nor indeed the rest of the country, would reduce the amount of silica sand (primary material) extracted each year.
Economics
What are the employment opportunities? I believe that only 1 or 2 jobs will be created at the quarry site, as quoted by Mike Hurley, Sibelco Chief Ops Officer. Approximately 45 jobs will maintained at the Leziate site but no extra jobs will be created there (Sibelco only employ 389 people in the whole
of the UK). Sibelco claim to support down-stream jobs in the glass making industry; however, it isn't Sibelco who support those jobs it is the raw silica sand and that could come from any other source including importation. There is no value to the sand for Norfolk, just profit for the Belgian owned company Sibelco.
Norfolk County Council's (NCC) assertion that Sibelco bring and maintains jobs in Norfolk does not hold water. As seen from an article in the EDP 75% of the sand is transported out of Norfolk by rail. The statements made by the Sibelco employee in the article mean that only a handful of HGV jobs are being supported by the transportation of sand in Norfolk. Sibelco estimate 800,000 - 900,000 tonnes of sand will be extracted per year; NCC figures are 735,000 - 750,000; therefore a train with l000t = at least 2 trains per day to haul 75% of total 8 - 9k tonnes per yr. The remaining 25% at 28 tonnes per HGV equates to 8035 road trips per year, equating to 5 trips per day, which in turn equals 7-8 drivers.
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. This would have the positive outcome of no further job losses in the north of England.
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.
Surely, that is a win - win situation?
It has been stated that the proposal will be adding value to the local economy? As previously stated, they are only creating a couple of jobs. Sibelco does not, at present, use local plant hire companies since they contract from D. Wardle Plant Hire, a company in Cheshire. Indeed, Sibelco's representative, Mr Hurley, has said at public meetings that there would be no economic benefit to the area of Should ham and the surrounding area.
Further to this, the sand is not used in industry here in Norfolk. 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 hire plant from a Cheshire firm, D Wardle Plant hire, as stated, this is not beneficial to Norfolk's economy. The average UK Sibelco wage was £37.SK in 2017. The Leziate site supports 45 jobs and SIL 02 would have equalled 1 or 2 jobs created equating to a £1.76M wage bill in Norfolk. These figures do not add up to anything close to the £15M that Sibelco claim to put into Norfolk's economy each year.
Aircraft Bird strike Hazard
It is a fact that birds are a problem at any airport. However, RAF Marham isn't just 'any' airport; it is the Main Operating Base (MOB) for the F35 Lightning II, an aircraft that costs flO0M+ per aircraft. The loss of an aircraft due to the loss of an engine or major airframe damage from a bird-strike would be financially intolerable and a major blow to the defence of the UK and our wider interests.
The other costs of a crash landing of the aircraft to cover emergency services and long term care and support to the affected people on the ground, are incalculable but would run into the tens if not hundreds of million pounds. It could be argued that there is a set of lakes very close to RAF Coningsby and that is tolerated but, it should be noted that these quarries had been worked for many years previously and that this practise of allowing large man-made lakes near an airfield is no longer tolerated - a precautionary principle of risk applies. It should also be noted that the Typhoon at Coningsby has 2 engines as opposed to the ONE engine that the F35 has, which gives it a better chance to be able to land if one engine is damaged. This is not a luxury the F35 has and, since it isn't a glider, it cannot not be guided away from the school or the houses before it crashes due to the loss of its ONE and only engine. In other words you cannot compare the 2 places as like for like and overall, on finance alone, the extra risk due to the construction of a water filled quarry so close to RAF Marham is unacceptable to the tax-payer.
It should be remembered that the large element of SIL 02 left in AOS E is a low-lying area and would be left as a wetland and that the entire AOS E & J are within the statutory 13 km exclusion zone for airfields. It should also be noted that wetland birds migrate in large numbers, are unfamiliar with the very loud F-35 engine noise and will be 'spooked to flight' in a dense mass that is unavoidable by the pilot. It should also be noted that the migration routes of such large birds will alter to take advantage of new feeding grounds left by a quarry and their flightpath will not be known until they arrive or depart and they do not file flight plans for traffic deconfliction !
Summary The destruction of Should ham Warren is too high a price to pay in all respects for the silica sand it holds. There is no tangible benefit to West Norfolk communities. There are other areas nationally and internationally other than AOS E & J. In the short term existing sites can continue to be exploited by necessity that have less effect on a community. This will allow the country and Norfolk County Council to address the longer term and legacy issues demonstrated. It will also give the opportunity to properly address the requirement to recycle more effectively and find sustainable processes for the longer term.
Norfolk County Council and the Government should be convincing companies like Sibelco to evolve toward a more sustainable model, perhaps by providing incentives and punitive measures to encourage it on that essential journey rather than adopting the path of least resistance currently being demonstrated by utilising what can only be described as damaging and everlasting "smash and grab" tactics.

Please find enclosed the comments and objections of Wormegay Parish Council to the proposal of AOS E and J areas of search and to SIL 02, as requested under the Preferred Options Consultation on the Norfolk Minerals and Waste Local Plan (M&WLP).
Julian Snape Clerk Wormegay Parish Council
WORMEGAY PARISH COUNCIL October 2019.

Norfolk County Council Waste and Minerals Plan Consultation Comment
Wormegay Parish Council objects to the proposal of AOS E and J as areas of search, furthermore it objects to SIL 02, which although as a preferred site was removed from the plan in name following a significant object from the MOD, has in fact had almost a 1/3rd of it retained within the bounds of AOS E.
The Parish Council has listened to its residents, researched open source information and believes that there is compelling evidence and reasons from the perspective of health and wellbeing, climate change, recycling and preservation of finite minerals and that the economic case is significantly disproportionate in favour of industry rather than the wellbeing of the local community and wider population estimated to be in the thousands every year who use the Shouldham Warren for leisure, educational, Forest Church and a variety sporting activities. This is also underpinned in the Forestry
England Should ham and Bilney Forest Plan 2016-2026. The Forest Plan outlines the need to consider, people, economy and nature and is a fine balance that needs to be carefully sustained. AOS D (West Bilney) as well as AOS E (Should ham Warren) both fall under this Forestry England plan but they have not commented as a consultee nor has the plan been referred to in any of the County officer's responses to other nature related comments. Forestry England are a significant consultee and their 2016-2026 plan has seemingly been overlooked completely.
In addition, the infrastructure from a highways perspective would require significant improvements to make it safe for access and to prevent further adverse impact on the traffic flow along the entire proposed route, which is renowned for long delays at the Hardwick and Hospital roundabouts and roads leading to them. This would mean further roadworks with the associated cost to who? And the disruption and delays while it took place. Monitoring of the yellow hatch box on the Hardwick is already a iow priority and widely disregarded by locals, commercial and tourist traffic due to lack of enforcement and not serving to keep traffic flowing.
It should also be noted that this route increases the heavy goods traffic directly past Wormegay Primary School. This increased noise and associated pollution will only add to the further detriment of the health and wellbeing of both the pupils and staff. Another legacy that we as the guardians of the area cannot and should not burden future generations with.
The prime company (Sibelco) who would likely quarry the site for Silica Sand, if given the planning permission, have a poor track record as a neighbour and despite invitations to discuss what they would likely do by way of restoration have offered nothing, the County Officer's comments on restoration, quote policy and offer no detail or assurance as to how policy would be enforce. we would most likely be left with a scar on the landscape with low level land allowed to fill with water at best or used for landfill at worst; the Should ham mound would disappear along with the features that make it attractive, either way it will never be able to be returned to the positive asset that it represents today.
Climate Change
The UK has signed up to the Paris Agreement which in turn led to the Climate Change Act which commits the UK government by law to reducing greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050.
There is an urgent need to plant trees- the Woodland Trust estimates the UK needs to plant 1.5 billion trees by 2050 in order to reach net zero emissions. This is about 30000 hectares. In comparison, the Warren search area is 330 hectares of woodland. It is nonsensical to destroy
existing woodlands when we are not meeting targets for new plantings. A recent news report
detailed how West Norfolk alone had to plant in excess of 64,000 new trees within the next decade.
It takes time to establish woods and we are not in a position to take down any trees at this point in
time. See the Forestry England Plan.
Norfolk needs to play its part in meeting our international obligations, therefore the trees must stay.
It is also interesting to note that Norfolk County Council are in support of a re-wilding venture
currently underway on farm land just outside Kings Lynn. This was featured on BBC television "Inside
Out East". In essence, the scheme, currently funded by the EU and HMG, which will be maintained
after Brexit, aims to return farm land to the wild with the intent to encourage the return of wildlife
and combat climate change. The schemes ambition is to create pathways and "stepping stones" for
wildlife to naturally venture between the Brecks, Norfolk coast and the Fens. AOS E and J both sit in this "pathway". These proposed quarries, yet again, are in direct contrast to other local, national and international projects.
Health and Wellbeing
The Health and Social Care Act 2012 delegated duties to local authorities to improve public health and reduce health inequalities.
* There is a range of legislation that protects biodiversity and urban green spaces by regulating planning, contamination and conservation, including the Wildlife and Countryside Act 1981, Environmental Protection Act 1990 and the Planning Act 2008. * Section 12 of the 2012 Act 4 introduced a new duty for all upper-tier and unitary local authorities in England to take appropriate steps to improve the health of the people who live in their areas.
Studies have conclusively proven that exposure to forests and trees:
* boosts the immune system
* lowers blood pressure
* reduces stress
* improves mood
* increases ability to focus, even in children with ADHD
* accelerates recovery from surgery or illness
* increases energy level
* improves sleep
The Natural Environment White Paper addresses the importance of accessible green space and links to human health.
At a time when 1 in 5 children leaving primary school in West Norfolk are obese, the importance of doing all that we can as a society to encourage a healthier lifestyle cannot be underestimated.
West Norfolk is one of the highest areas in the country for GP prescribing of antidepressants, an indication of a high prevalence of depression and anxiety in the local population.
The NHS is under huge strain already trying to treat people, and the county council must do
everything in its power to enable people to lead healthier lives, to reduce the burden on health
services.
Shouldham Warren is used by a very large number of people from the surrounding areas to walk,
cycle, and 'forest bathe'. It is used by cycling groups and of the Ryston Runners have their races here
every winter which are attended by a very large number of children and adults from far and wide.
There is no other wooded area in this part of West Norfolk which could be used instead, and there is
no doubt in my mind that people's health will suffer if they are denied access to these woods.
Norfolk County Council should also be made aware that there is local anecdotal evidence to suggest
that the area of wood known as Mow Fen has been used as a route for the monks to camp and rest
whilst travelling between various abbeys and religious festivals within the west Norfolk area. This
would suggest that this fen would be of historic interest. This should be coupled with the fact that
the small bridge near thee pumping station at Wormegay and Mow Fen was built by the Canadian
forces during World War 2. The bridge and the Mission room within Wormegay were gifted to the
village. Therefore, one would suggest that this bridge on the approach of Mow Fen is also of
significant historical value.
If NCC goes ahead with giving permission to explore the area for sand quarrying, it will demonstrate
a disregard for the population today and, perhaps more importantly, future generations; Norfolk
County Council will fail in its obligations to look after the health of the people of Norfolk.
Recycling and Preservation of Finite Mineral Resource.
The Ministry of Housing Communities and Local Government document, the 'National Planning Policy Framework', sets out the Government's planning policies for England and how these should be applied. The document states (Section 2: Achieving Sustainable Development, at para 7), "The purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs" - Resolution 42/187 of the United Nations General Assembly. The document also states (Section 17: Facilitating the Sustainable Use of Minerals, at para 203), "It is essential that there is a sufficient supply of minerals to provide the infrastructure, buildings, energy and goods that the country needs. Since minerals are a finite natural resource, and can only be worked where they are found, best use needs to be made of them to secure their long-term conservation." As stated, sustainable development should not compromise future generations to meet their own needs, and that minerals are a finite natural resource; quarrying is not sustainable and committing to it for the next generation is to show neglect of duty. Here in Norfolk, as we do in many fields, we should look to model best practice for the UK strategy and have the vision to ensure we do not compromise future generations. The NPPF states, 'Planning policies should: .... so far as practicable, take account of the contribution that suitable or secondary and recycled materials and minerals waste would make to the supply of materials, before considering extraction of primary materials ... ' (Sect 17, para 204. b). There is no attempt within the NCC M&WLP to discuss how improved recycling or reuse of glass within Norfolk, nor indeed the rest of the country, would reduce the amount of silica sand (primary material) extracted each year.
Economics
What are the employment opportunities? I believe that only 1 or 2 jobs will be created at the quarry site, as quoted by Mike Hurley, Sibelco Chief Ops Officer. Approximately 45 jobs will maintained at the Leziate site but no extra jobs will be created there (Sibelco only employ 389 people in the whole
of the UK). Sibelco claim to support down-stream jobs in the glass making industry; however, it isn't Sibelco who support those jobs it is the raw silica sand and that could come from any other source including importation. There is no value to the sand for Norfolk, just profit for the Belgian owned company Sibelco.
Norfolk County Council's (NCC) assertion that Sibelco bring and maintains jobs in Norfolk does not hold water. As seen from an article in the EDP 75% of the sand is transported out of Norfolk by rail. The statements made by the Sibelco employee in the article mean that only a handful of HGV jobs are being supported by the transportation of sand in Norfolk. Sibelco estimate 800,000 - 900,000 tonnes of sand will be extracted per year; NCC figures are 735,000 - 750,000; therefore a train with l000t = at least 2 trains per day to haul 75% of total 8 - 9k tonnes per yr. The remaining 25% at 28 tonnes per HGV equates to 8035 road trips per year, equating to 5 trips per day, which in turn equals 7-8 drivers.
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. This would have the positive outcome of no further job losses in the north of England.
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.
Surely, that is a win - win situation?
It has been stated that the proposal will be adding value to the local economy? As previously stated, they are only creating a couple of jobs. Sibelco does not, at present, use local plant hire companies since they contract from D. Wardle Plant Hire, a company in Cheshire. Indeed, Sibelco's representative, Mr Hurley, has said at public meetings that there would be no economic benefit to the area of Should ham and the surrounding area.
Further to this, the sand is not used in industry here in Norfolk. 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 hire plant from a Cheshire firm, D Wardle Plant hire, as stated, this is not beneficial to Norfolk's economy. The average UK Sibelco wage was £37.SK in 2017. The Leziate site supports 45 jobs and SIL 02 would have equalled 1 or 2 jobs created equating to a £1.76M wage bill in Norfolk. These figures do not add up to anything close to the £15M that Sibelco claim to put into Norfolk's economy each year.
Aircraft Bird strike Hazard
It is a fact that birds are a problem at any airport. However, RAF Marham isn't just 'any' airport; it is the Main Operating Base (MOB) for the F35 Lightning II, an aircraft that costs flO0M+ per aircraft. The loss of an aircraft due to the loss of an engine or major airframe damage from a bird-strike would be financially intolerable and a major blow to the defence of the UK and our wider interests.
The other costs of a crash landing of the aircraft to cover emergency services and long term care and support to the affected people on the ground, are incalculable but would run into the tens if not hundreds of million pounds. It could be argued that there is a set of lakes very close to RAF Coningsby and that is tolerated but, it should be noted that these quarries had been worked for many years previously and that this practise of allowing large man-made lakes near an airfield is no longer tolerated - a precautionary principle of risk applies. It should also be noted that the Typhoon at Coningsby has 2 engines as opposed to the ONE engine that the F35 has, which gives it a better chance to be able to land if one engine is damaged. This is not a luxury the F35 has and, since it isn't a glider, it cannot not be guided away from the school or the houses before it crashes due to the loss of its ONE and only engine. In other words you cannot compare the 2 places as like for like and overall, on finance alone, the extra risk due to the construction of a water filled quarry so close to RAF Marham is unacceptable to the tax-payer.
It should be remembered that the large element of SIL 02 left in AOS E is a low-lying area and would be left as a wetland and that the entire AOS E & J are within the statutory 13 km exclusion zone for airfields. It should also be noted that wetland birds migrate in large numbers, are unfamiliar with the very loud F-35 engine noise and will be 'spooked to flight' in a dense mass that is unavoidable by the pilot. It should also be noted that the migration routes of such large birds will alter to take advantage of new feeding grounds left by a quarry and their flightpath will not be known until they arrive or depart and they do not file flight plans for traffic deconfliction !
Summary The destruction of Should ham Warren is too high a price to pay in all respects for the silica sand it holds. There is no tangible benefit to West Norfolk communities. There are other areas nationally and internationally other than AOS E & J. In the short term existing sites can continue to be exploited by necessity that have less effect on a community. This will allow the country and Norfolk County Council to address the longer term and legacy issues demonstrated. It will also give the opportunity to properly address the requirement to recycle more effectively and find sustainable processes for the longer term.
Norfolk County Council and the Government should be convincing companies like Sibelco to evolve toward a more sustainable model, perhaps by providing incentives and punitive measures to encourage it on that essential journey rather than adopting the path of least resistance currently being demonstrated by utilising what can only be described as damaging and everlasting "smash and grab" tactics.

Please find enclosed the comments and objections of Wormegay Parish Council to the proposal of AOS E and J areas of search and to SIL 02, as requested under the Preferred Options Consultation on the Norfolk Minerals and Waste Local Plan (M&WLP).
Julian Snape Clerk Wormegay Parish Council
WORMEGAY PARISH COUNCIL October 2019.

Norfolk County Council Waste and Minerals Plan Consultation Comment
Wormegay Parish Council objects to the proposal of AOS E and J as areas of search, furthermore it objects to SIL 02, which although as a preferred site was removed from the plan in name following a significant object from the MOD, has in fact had almost a 1/3rd of it retained within the bounds of AOS E.
The Parish Council has listened to its residents, researched open source information and believes that there is compelling evidence and reasons from the perspective of health and wellbeing, climate change, recycling and preservation of finite minerals and that the economic case is significantly disproportionate in favour of industry rather than the wellbeing of the local community and wider population estimated to be in the thousands every year who use the Shouldham Warren for leisure, educational, Forest Church and a variety sporting activities. This is also underpinned in the Forestry
England Should ham and Bilney Forest Plan 2016-2026. The Forest Plan outlines the need to consider, people, economy and nature and is a fine balance that needs to be carefully sustained. AOS D (West Bilney) as well as AOS E (Should ham Warren) both fall under this Forestry England plan but they have not commented as a consultee nor has the plan been referred to in any of the County officer's responses to other nature related comments. Forestry England are a significant consultee and their 2016-2026 plan has seemingly been overlooked completely.
In addition, the infrastructure from a highways perspective would require significant improvements to make it safe for access and to prevent further adverse impact on the traffic flow along the entire proposed route, which is renowned for long delays at the Hardwick and Hospital roundabouts and roads leading to them. This would mean further roadworks with the associated cost to who? And the disruption and delays while it took place. Monitoring of the yellow hatch box on the Hardwick is already a iow priority and widely disregarded by locals, commercial and tourist traffic due to lack of enforcement and not serving to keep traffic flowing.
It should also be noted that this route increases the heavy goods traffic directly past Wormegay Primary School. This increased noise and associated pollution will only add to the further detriment of the health and wellbeing of both the pupils and staff. Another legacy that we as the guardians of the area cannot and should not burden future generations with.
The prime company (Sibelco) who would likely quarry the site for Silica Sand, if given the planning permission, have a poor track record as a neighbour and despite invitations to discuss what they would likely do by way of restoration have offered nothing, the County Officer's comments on restoration, quote policy and offer no detail or assurance as to how policy would be enforce. we would most likely be left with a scar on the landscape with low level land allowed to fill with water at best or used for landfill at worst; the Should ham mound would disappear along with the features that make it attractive, either way it will never be able to be returned to the positive asset that it represents today.
Climate Change
The UK has signed up to the Paris Agreement which in turn led to the Climate Change Act which commits the UK government by law to reducing greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050.
There is an urgent need to plant trees- the Woodland Trust estimates the UK needs to plant 1.5 billion trees by 2050 in order to reach net zero emissions. This is about 30000 hectares. In comparison, the Warren search area is 330 hectares of woodland. It is nonsensical to destroy
existing woodlands when we are not meeting targets for new plantings. A recent news report
detailed how West Norfolk alone had to plant in excess of 64,000 new trees within the next decade.
It takes time to establish woods and we are not in a position to take down any trees at this point in
time. See the Forestry England Plan.
Norfolk needs to play its part in meeting our international obligations, therefore the trees must stay.
It is also interesting to note that Norfolk County Council are in support of a re-wilding venture
currently underway on farm land just outside Kings Lynn. This was featured on BBC television "Inside
Out East". In essence, the scheme, currently funded by the EU and HMG, which will be maintained
after Brexit, aims to return farm land to the wild with the intent to encourage the return of wildlife
and combat climate change. The schemes ambition is to create pathways and "stepping stones" for
wildlife to naturally venture between the Brecks, Norfolk coast and the Fens. AOS E and J both sit in this "pathway". These proposed quarries, yet again, are in direct contrast to other local, national and international projects.
Health and Wellbeing
The Health and Social Care Act 2012 delegated duties to local authorities to improve public health and reduce health inequalities.
* There is a range of legislation that protects biodiversity and urban green spaces by regulating planning, contamination and conservation, including the Wildlife and Countryside Act 1981, Environmental Protection Act 1990 and the Planning Act 2008. * Section 12 of the 2012 Act 4 introduced a new duty for all upper-tier and unitary local authorities in England to take appropriate steps to improve the health of the people who live in their areas.
Studies have conclusively proven that exposure to forests and trees:
* boosts the immune system
* lowers blood pressure
* reduces stress
* improves mood
* increases ability to focus, even in children with ADHD
* accelerates recovery from surgery or illness
* increases energy level
* improves sleep
The Natural Environment White Paper addresses the importance of accessible green space and links to human health.
At a time when 1 in 5 children leaving primary school in West Norfolk are obese, the importance of doing all that we can as a society to encourage a healthier lifestyle cannot be underestimated.
West Norfolk is one of the highest areas in the country for GP prescribing of antidepressants, an indication of a high prevalence of depression and anxiety in the local population.
The NHS is under huge strain already trying to treat people, and the county council must do
everything in its power to enable people to lead healthier lives, to reduce the burden on health
services.
Shouldham Warren is used by a very large number of people from the surrounding areas to walk,
cycle, and 'forest bathe'. It is used by cycling groups and of the Ryston Runners have their races here
every winter which are attended by a very large number of children and adults from far and wide.
There is no other wooded area in this part of West Norfolk which could be used instead, and there is
no doubt in my mind that people's health will suffer if they are denied access to these woods.
Norfolk County Council should also be made aware that there is local anecdotal evidence to suggest
that the area of wood known as Mow Fen has been used as a route for the monks to camp and rest
whilst travelling between various abbeys and religious festivals within the west Norfolk area. This
would suggest that this fen would be of historic interest. This should be coupled with the fact that
the small bridge near thee pumping station at Wormegay and Mow Fen was built by the Canadian
forces during World War 2. The bridge and the Mission room within Wormegay were gifted to the
village. Therefore, one would suggest that this bridge on the approach of Mow Fen is also of
significant historical value.
If NCC goes ahead with giving permission to explore the area for sand quarrying, it will demonstrate
a disregard for the population today and, perhaps more importantly, future generations; Norfolk
County Council will fail in its obligations to look after the health of the people of Norfolk.
Recycling and Preservation of Finite Mineral Resource.
The Ministry of Housing Communities and Local Government document, the 'National Planning Policy Framework', sets out the Government's planning policies for England and how these should be applied. The document states (Section 2: Achieving Sustainable Development, at para 7), "The purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs" - Resolution 42/187 of the United Nations General Assembly. The document also states (Section 17: Facilitating the Sustainable Use of Minerals, at para 203), "It is essential that there is a sufficient supply of minerals to provide the infrastructure, buildings, energy and goods that the country needs. Since minerals are a finite natural resource, and can only be worked where they are found, best use needs to be made of them to secure their long-term conservation." As stated, sustainable development should not compromise future generations to meet their own needs, and that minerals are a finite natural resource; quarrying is not sustainable and committing to it for the next generation is to show neglect of duty. Here in Norfolk, as we do in many fields, we should look to model best practice for the UK strategy and have the vision to ensure we do not compromise future generations. The NPPF states, 'Planning policies should: .... so far as practicable, take account of the contribution that suitable or secondary and recycled materials and minerals waste would make to the supply of materials, before considering extraction of primary materials ... ' (Sect 17, para 204. b). There is no attempt within the NCC M&WLP to discuss how improved recycling or reuse of glass within Norfolk, nor indeed the rest of the country, would reduce the amount of silica sand (primary material) extracted each year.
Economics
What are the employment opportunities? I believe that only 1 or 2 jobs will be created at the quarry site, as quoted by Mike Hurley, Sibelco Chief Ops Officer. Approximately 45 jobs will maintained at the Leziate site but no extra jobs will be created there (Sibelco only employ 389 people in the whole
of the UK). Sibelco claim to support down-stream jobs in the glass making industry; however, it isn't Sibelco who support those jobs it is the raw silica sand and that could come from any other source including importation. There is no value to the sand for Norfolk, just profit for the Belgian owned company Sibelco.
Norfolk County Council's (NCC) assertion that Sibelco bring and maintains jobs in Norfolk does not hold water. As seen from an article in the EDP 75% of the sand is transported out of Norfolk by rail. The statements made by the Sibelco employee in the article mean that only a handful of HGV jobs are being supported by the transportation of sand in Norfolk. Sibelco estimate 800,000 - 900,000 tonnes of sand will be extracted per year; NCC figures are 735,000 - 750,000; therefore a train with l000t = at least 2 trains per day to haul 75% of total 8 - 9k tonnes per yr. The remaining 25% at 28 tonnes per HGV equates to 8035 road trips per year, equating to 5 trips per day, which in turn equals 7-8 drivers.
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. This would have the positive outcome of no further job losses in the north of England.
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.
Surely, that is a win - win situation?
It has been stated that the proposal will be adding value to the local economy? As previously stated, they are only creating a couple of jobs. Sibelco does not, at present, use local plant hire companies since they contract from D. Wardle Plant Hire, a company in Cheshire. Indeed, Sibelco's representative, Mr Hurley, has said at public meetings that there would be no economic benefit to the area of Should ham and the surrounding area.
Further to this, the sand is not used in industry here in Norfolk. 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 hire plant from a Cheshire firm, D Wardle Plant hire, as stated, this is not beneficial to Norfolk's economy. The average UK Sibelco wage was £37.SK in 2017. The Leziate site supports 45 jobs and SIL 02 would have equalled 1 or 2 jobs created equating to a £1.76M wage bill in Norfolk. These figures do not add up to anything close to the £15M that Sibelco claim to put into Norfolk's economy each year.
Aircraft Bird strike Hazard
It is a fact that birds are a problem at any airport. However, RAF Marham isn't just 'any' airport; it is the Main Operating Base (MOB) for the F35 Lightning II, an aircraft that costs flO0M+ per aircraft. The loss of an aircraft due to the loss of an engine or major airframe damage from a bird-strike would be financially intolerable and a major blow to the defence of the UK and our wider interests.
The other costs of a crash landing of the aircraft to cover emergency services and long term care and support to the affected people on the ground, are incalculable but would run into the tens if not hundreds of million pounds. It could be argued that there is a set of lakes very close to RAF Coningsby and that is tolerated but, it should be noted that these quarries had been worked for many years previously and that this practise of allowing large man-made lakes near an airfield is no longer tolerated - a precautionary principle of risk applies. It should also be noted that the Typhoon at Coningsby has 2 engines as opposed to the ONE engine that the F35 has, which gives it a better chance to be able to land if one engine is damaged. This is not a luxury the F35 has and, since it isn't a glider, it cannot not be guided away from the school or the houses before it crashes due to the loss of its ONE and only engine. In other words you cannot compare the 2 places as like for like and overall, on finance alone, the extra risk due to the construction of a water filled quarry so close to RAF Marham is unacceptable to the tax-payer.
It should be remembered that the large element of SIL 02 left in AOS E is a low-lying area and would be left as a wetland and that the entire AOS E & J are within the statutory 13 km exclusion zone for airfields. It should also be noted that wetland birds migrate in large numbers, are unfamiliar with the very loud F-35 engine noise and will be 'spooked to flight' in a dense mass that is unavoidable by the pilot. It should also be noted that the migration routes of such large birds will alter to take advantage of new feeding grounds left by a quarry and their flightpath will not be known until they arrive or depart and they do not file flight plans for traffic deconfliction !
Summary The destruction of Should ham Warren is too high a price to pay in all respects for the silica sand it holds. There is no tangible benefit to West Norfolk communities. There are other areas nationally and internationally other than AOS E & J. In the short term existing sites can continue to be exploited by necessity that have less effect on a community. This will allow the country and Norfolk County Council to address the longer term and legacy issues demonstrated. It will also give the opportunity to properly address the requirement to recycle more effectively and find sustainable processes for the longer term.
Norfolk County Council and the Government should be convincing companies like Sibelco to evolve toward a more sustainable model, perhaps by providing incentives and punitive measures to encourage it on that essential journey rather than adopting the path of least resistance currently being demonstrated by utilising what can only be described as damaging and everlasting "smash and grab" tactics.