Preferred Options consultation document

Object

Representation ID: 94356

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

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.

Object

Representation ID: 94357

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

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 (see internet links at end of text), highlight how other 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 CO2 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).

https://mineralproducts.org/restoration_and_biodiversity_awards_2013.htm
https://www.cemex.co.uk/-/eversley-quarry-restoration-plan-is-runner-up-in-mpa-quarries-and-nature-awards
https://mineralproducts.org/15-release28.htm

Object

Representation ID: 94358

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

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 A- Scoping (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 the 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 the 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).

Object

Representation ID: 94360

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

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 the 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 CO2 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 fulfil 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 fulfil 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 is 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 the restoration of quarries it has operated is extremely poor (see first internet link at end of text). 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' (see second internet link at end of text). Due to Sibelco's proven poor record for the restoration of previously 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 has 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 Moneystone (see third internet link at end of text) 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).

https://www.bbc.com/news/uk-england-norfolk-23354729
https://mineralproducts.org/restoration_and_biodiversity_awards_2013.htm http://moderngov.staffordshire.gov.uk/documents/s47001/Planning%20Cttee%2006%2003%202014%20Moneystone%20Quarry%20rept.pdf

Object

Representation ID: 94361

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

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).
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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.

Object

Representation ID: 94362

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

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.

Object

Representation ID: 94363

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

MW3 - Transport. We agree with the NCC policy on transport in regards to 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.

Object

Representation ID: 94364

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

NCC has no plans in place to account for reducing CO2 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 CO2 emissions from both quarrying and glass manufacturing (more recycled glass used in manufacture reduces CO2 emitted and the energy required). MW4 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).

Object

Representation ID: 94365

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

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.

Object

Representation ID: 94366

Received: 21/10/2019

Respondent: Campaigners Against Two Silica Sites

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).