Preferred Options consultation document

Object

Representation ID: 94712

Received: 27/10/2019

Respondent: Campaigners Against Two Silica Sites

NCC's M&WLP Vision plus Policies WP1 and WP2, Objectives WSO1,2,4,6 and 8 and MSO2,3,8 and 10, all fail without a plan for a coherent, modern glass (especially flat and clear glass) recycling plan investing with industry partners in a technologically advanced infrastructure that will save raw minerals and energy, reduce the emission of greenhouse gases, create 100s of jobs in Norfolk and, just as importantly, stop the wanton destruction of the Norfolk landscape and biodiversity with a 'business as usual' attitude to mineral extraction in our county. More detail in Representation ID:94688, selecting the link 'More detail about Representation ID:94688

Object

Representation ID: 94713

Received: 27/10/2019

Respondent: Campaigners Against Two Silica Sites

A SERIOUS glass recycling plan would ensure increased local employment that far outweighs the numbers and level of jobs generated through quarrying alone, as well as reducing the size and number of areas required for silica sand extraction and aiding the reduction of greenhouse gas emissions. Without such a plan the M&WLP fails the economic and environmental objectives of the Presumption in favour of sustainable development. A more in-depth analysis can be found in Representation ID:94688 and selecting the link More detail about Representation ID:94688

Object

Representation ID: 94714

Received: 27/10/2019

Respondent: Campaigners Against Two Silica Sites

The M&WLP is not considering a radical overhaul of glass recycling in Norfolk that would lead to vastly increased reductions in greenhouse gasses to support reducing the effects on climate change. Without that overhaul, and by continuing to allow quarrying for silica sand on a 'business as usual' basis the M&WLP is not serious in its intent to minimise climate change and fails MW4. Detailed analysis can be read in Representation ID:94688 and selecting the link 'More about Representation ID:94688

Object

Representation ID: 94715

Received: 27/10/2019

Respondent: Campaigners Against Two Silica Sites

The M&WLP is not considering a radical overhaul of glass recycling. There are no plans to radically increase the amount of glass recycled within the waste management capacity to be provided, despite all of the positive factors that would bring to Norfolk - increased employment in a green industry; less CO2 emissions; increased time for self-sufficiency in silica sand; protection of the Norfolk countryside (biodiversity, geology, archaeology, public access). Without an overhaul the M&WLP is unsound. Detailed analysis can be read in Representation ID:94688 and select 'More about Representation ID:94688

Object

Representation ID: 94716

Received: 27/10/2019

Respondent: Campaigners Against Two Silica Sites

Without a radical overhaul of the glass recycling plan in Norfolk, NCC is failing the NPPF to 'look to recycle before extracting raw materials'. The planned extraction figures quoted here are flawed as they are only based on figures supplied by the mineral extraction companies as their 'required need'; there is no other independent oversight of the figures to confirm them. Increased recycling of glass, especially clear glass, would reduce the 'required need' for raw silica sand - a fact agreed by Sibelco in their own publicity. Detailed analysis is in Representation ID:94688 under 'More about Representation ID:94688

Object

Representation ID: 94717

Received: 27/10/2019

Respondent: Campaigners Against Two Silica Sites

Without a radical overhaul of the glass recycling infrastructure in Norfolk, especially for clear and flat glass, the following Strategic Objectives are not being fulfilled and the plan is unsound:

WSO 1 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, is required to support the objective to prevent/minimise waste in line with the Waste Hierarchy.
WSO 2 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, is required to support the aim of increasing the amount of waste reused, recycled and recovered.
WSO 4 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, is required to enable the aim of self-sufficiency in waste management (Vision 2036).
WSO 6 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, is required to support the reduction of greenhouse gas emissions (a legally binding objective), minimise landfill (in Norfolk and nationally), and reduce waste transport distances.
WSO 8 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, is required to recognise the importance of waste management as a generator of local employment.
MSO 2 - A radical overhaul of glass recycling in Norfolk is required, especially clear and flat glass, to increase the future timescale of providing a steady and adequate supply of silica sand by reducing the quantity of raw material required for the manufacture of glass due to an increase in the quantity and quality of recycled glass, especially clear and flat glass (Vision 2036).
MSO3 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, is required to encourage the sustainable use of minerals by using secondary and recycled aggregates (NPPF, Ch 17, para 204.b).
MSO 8 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, to minimise the impact of climate change through the reduction of CO2 emissions due to increased use of high quality recycled glass cullet, especially clear and flat glass, in glass manufacturing.
MSO 10 - A radical overhaul of glass recycling in Norfolk, especially clear and flat glass, that ensures more public access to the countryside due to the decrease in quarrying area required for silica sand because of the increased use of high quality recycled glass cullet.

Detailed analysis can be found in the Preferred Options consultation section at Representation ID:94688 and select 'More about Representation ID:94688'

Object

Representation ID: 98619

Received: 25/10/2019

Respondent: Campaigners Against Two Silica Sites

CATSS - We Object to Quarrying in AOS E and the overlap of SIL 02 the Preferred Area On Historical Grounds

The Historic Environment Impact Assessment of AOS E and SIL 02 April 2019 with focus on Pentney Priory Gatehouse, suggested that a large area of SIL02 should be withdrawn from the plan as it was incompatible with the historic setting and context of this scheduled monument. What is not covered in this impact statement is the buried remains of part of this Augustinian Priory; there is nothing visible above ground but is revealed by crop marks, covering approximately 13.5 hectare area to the South towards the river Nar, and to the East and West. Surely this area should be designated as an area of historical importance? The finds could well stretch the length of the area of the former SIL02, now subsumed as part of AOS E, as the river Nar was diverted in the monastic period. Settlements and artefacts undiscovered would be lost forever if any quarrying was to take place. Given the significance and proximity to the six sites, three either side of the Nar, surely a very detailed historic analysis and archaeological study should be paramount and Norfolk County Council should exclude this area and remove it from their plan.

NCC Historic Environment Impact Assessment dated April 2019 of SIL02 cites from NPPF (2019), ' The surroundings in which ........ may change... evolve' . Does this suggest that the assessment isn't truly focussed on looking after our rich history but that 'progress' is quarrying under the banner of change and evolve? What is the point of NCC placing any restrictive criteria on any area of search in that case, or for that matter why not reveal all the deposits of silica sand in Norfolk as recorded by the British Geological Survey and say the whole of West Norfolk is open to be quarried? (It is interesting that NCC makes use of the NPPF in their favour when it suits their aim, in this case the citation above in favour of 'development' around heritage assets but ignores other important parts of NPPF that conserve minerals and primary materials - Sect 17, para 204.b.)

Additionally, the same assessment proposes a 2Km exclusion Zone to the East of Pentney Priory Gatehouse as sufficient not to impinge on that landscape; the assessment cites NPPF para 194 that any bunding would impose an unacceptable constraint on that view. However, only 1Km is proposed to the South of this historic building; with a similar flat landscape over the Fen towards Spring Lane this seems at odds with protecting the view towards or away from the Gatehouse. We appeal to NCC to look at this oversight again and propose the same restrictions to the South of Pentney Priory Gatehouse as there is to the East. This area SIL 02 was also objected to by MOD (DIO), so why has NCC seen fit to include it?

The centre of AOSE, Shoudham Warren, is a medieval landscape and an area of high archaeological possibility. The area rises above the landscape and is highly likely to be a medieval farmed network. The remnants of an ancient spring on the hill of the Warren with a Rhododendron avenue being an important area for archaeological study. Within the Warren itself, areas used in WW2 are preserved and a rifle butt within close proximity of the entrance; the historic links to our past evident and in need of protection.

Just to the south of Shouldham Warren and on the northeast extremity of Shouldham village, lie the earthworks of Shouldham Priory (see chart on pg 28 of the Historic Environment Impact Assessment referred above). There are also buried remains of part of a gravel road that runs along the south side of Abbey farm. This road is potentially Roman; approx 5m wide. The road east of the adjacent field can be seen from the air. Roman pottery has been found in this area and archaeological remains are possible within the vicinity. There is also thought to be bronze age artefacts and the area should be protected for its historical setting and for archaeological study.

A quarry in AOS E and/or the overlap of SIL 02 the Preferred Area would irreversibly change the local landscape and affect the historical character of the area and the many historical monuments and their setting. This is supported by NCC's own Historic Environment Impact Assessment of AOS E and SIL 02.

Object

Representation ID: 98620

Received: 25/10/2019

Respondent: Campaigners Against Two Silica Sites

CATSS - We Object to Quarrying in AOS E and the overlap of SIL 02 the Preferred Area On Historical Grounds

The Historic Environment Impact Assessment of AOS E and SIL 02 April 2019 with focus on Pentney Priory Gatehouse, suggested that a large area of SIL02 should be withdrawn from the plan as it was incompatible with the historic setting and context of this scheduled monument. What is not covered in this impact statement is the buried remains of part of this Augustinian Priory; there is nothing visible above ground but is revealed by crop marks, covering approximately 13.5 hectare area to the South towards the river Nar, and to the East and West. Surely this area should be designated as an area of historical importance? The finds could well stretch the length of the area of the former SIL02, now subsumed as part of AOS E, as the river Nar was diverted in the monastic period. Settlements and artefacts undiscovered would be lost forever if any quarrying was to take place. Given the significance and proximity to the six sites, three either side of the Nar, surely a very detailed historic analysis and archaeological study should be paramount and Norfolk County Council should exclude this area and remove it from their plan.

NCC Historic Environment Impact Assessment dated April 2019 of SIL02 cites from NPPF (2019), ' The surroundings in which ........ may change... evolve' . Does this suggest that the assessment isn't truly focussed on looking after our rich history but that 'progress' is quarrying under the banner of change and evolve? What is the point of NCC placing any restrictive criteria on any area of search in that case, or for that matter why not reveal all the deposits of silica sand in Norfolk as recorded by the British Geological Survey and say the whole of West Norfolk is open to be quarried? (It is interesting that NCC makes use of the NPPF in their favour when it suits their aim, in this case the citation above in favour of 'development' around heritage assets but ignores other important parts of NPPF that conserve minerals and primary materials - Sect 17, para 204.b.)

Additionally, the same assessment proposes a 2Km exclusion Zone to the East of Pentney Priory Gatehouse as sufficient not to impinge on that landscape; the assessment cites NPPF para 194 that any bunding would impose an unacceptable constraint on that view. However, only 1Km is proposed to the South of this historic building; with a similar flat landscape over the Fen towards Spring Lane this seems at odds with protecting the view towards or away from the Gatehouse. We appeal to NCC to look at this oversight again and propose the same restrictions to the South of Pentney Priory Gatehouse as there is to the East. This area SIL 02 was also objected to by MOD (DIO), so why has NCC seen fit to include it?

The centre of AOSE, Shoudham Warren, is a medieval landscape and an area of high archaeological possibility. The area rises above the landscape and is highly likely to be a medieval farmed network. The remnants of an ancient spring on the hill of the Warren with a Rhododendron avenue being an important area for archaeological study. Within the Warren itself, areas used in WW2 are preserved and a rifle butt within close proximity of the entrance; the historic links to our past evident and in need of protection.

Just to the south of Shouldham Warren and on the northeast extremity of Shouldham village, lie the earthworks of Shouldham Priory (see chart on pg 28 of the Historic Environment Impact Assessment referred above). There are also buried remains of part of a gravel road that runs along the south side of Abbey farm. This road is potentially Roman; approx 5m wide. The road east of the adjacent field can be seen from the air. Roman pottery has been found in this area and archaeological remains are possible within the vicinity. There is also thought to be bronze age artefacts and the area should be protected for its historical setting and for archaeological study.

A quarry in AOS E and/or the overlap of SIL 02 the Preferred Area would irreversibly change the local landscape and affect the historical character of the area and the many historical monuments and their setting. This is supported by NCC's own Historic Environment Impact Assessment of AOS E and SIL 02.

Object

Representation ID: 98621

Received: 25/10/2019

Respondent: Campaigners Against Two Silica Sites

CATSS - Objections to Quarrying in AOS E and SIL 02 on Health Grounds

● The Ministry of Defence (MOD) has stated there is an unacceptable risk to aircraft with wet working in the area of AOS E; therefore, a dry worked quarry would be Sibelco's and NCC's plan for Shouldham Warren which would destroy this peaceful recreational area. The recommendation of the NCC Development and Infrastructure Committee (minutes of 17 July 19) stated with reference to AOS E, "a smaller area that is elevated (not wet) could come forward in this plan and not cause significant objections". Shouldham Warren is elevated and is approx 21m above sea level. That being the case the community should be very concerned for health implications arising from dry worked quarrying within Shouldham Warren. If wet working quarries is Sibelco's answer to the problem of dust, what is their answer to the destruction of an area that is our sanctuary from modern pressures? Three links, [https://www.mnmed.org/MMA/media/Minnesota-Medicine-Magazine/Commentary-Feyereisn.pdf] [https://www.ewg.org/research/danger-in-the-air] and [http://www.hazards.org/dust/silica.htm] to health implications of dry quarrying silica sand (respiratory problems and a higher risk of lung cancer) should be must-reads for the suits at County hall.

● Dry or wet worked (any) quarry in Shouldham Warren will have a devastating impact on the mental health of both villages' residents and for the other communities who use the Warren as their natural gym. Evidence shows natural outdoor spaces help with mental and physical health and social interactions. Shouldham Warren and Marham Fen both are used extensively by tourists and locals for experiencing the great outdoors which is backed up by the research of NHS Forest [https://nhsforest.org/evidence-benefits] and the Natural England Monitor of Engagement With The Natural Environment [https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/738891/Monitorof_Engagementwiththe_Natural_Environment_Headline_Report_March_2016to_February_2018.pdf].

● It cannot be argued against that the loss of outdoor space, reduced access to nature and the countryside has a negative effect on health and well-being.

DEFRA 25 year plan encourages access to green space to promote positive mental health and reduce obesity. Other health benefits include; resilience to stress, increased mobility, higher cognitive functioning and observation skills, reduction in Type2 diabetes and depression. Those with learning disability or Attention Deficit Hyperactivity Disorder (ADHD) also experience positive outcomes from being outdoors and closer to nature (MacFarlane as cited in People's Manifesto 2018). Public Health England (PHE) suggests that landscape may be referred to as a spatial unit as well as a socio-cultural asset. The fenland area between Shouldham and Marham is seen as an asset by the local people and all who visit and use it from all around Norfolk and the UK. Inactivity is the 4 th leading factor for global mortality accounting for 6% of deaths. Our local residents, old or young, benefit from the outdoor lifestyle afforded by Marham Fen and Shouldham Warren with regular walks enhancing our heart health, lowering blood pressure, improving weight control, while keeping joints and muscles strong and improving mood and mental well being.

● The social and emotional impact of losing our outdoor area and nature cannot and should not be underestimated and is unacceptable.

Object

Representation ID: 98622

Received: 25/10/2019

Respondent: Campaigners Against Two Silica Sites

CATSS - Objections to Quarrying in AOS E and SIL 02 on Health Grounds

● The Ministry of Defence (MOD) has stated there is an unacceptable risk to aircraft with wet working in the area of AOS E; therefore, a dry worked quarry would be Sibelco's and NCC's plan for Shouldham Warren which would destroy this peaceful recreational area. The recommendation of the NCC Development and Infrastructure Committee (minutes of 17 July 19) stated with reference to AOS E, "a smaller area that is elevated (not wet) could come forward in this plan and not cause significant objections". Shouldham Warren is elevated and is approx 21m above sea level. That being the case the community should be very concerned for health implications arising from dry worked quarrying within Shouldham Warren. If wet working quarries is Sibelco's answer to the problem of dust, what is their answer to the destruction of an area that is our sanctuary from modern pressures? Three links, [https://www.mnmed.org/MMA/media/Minnesota-Medicine-Magazine/Commentary-Feyereisn.pdf] [https://www.ewg.org/research/danger-in-the-air] and [http://www.hazards.org/dust/silica.htm] to health implications of dry quarrying silica sand (respiratory problems and a higher risk of lung cancer) should be must-reads for the suits at County hall.

● Dry or wet worked (any) quarry in Shouldham Warren will have a devastating impact on the mental health of both villages' residents and for the other communities who use the Warren as their natural gym. Evidence shows natural outdoor spaces help with mental and physical health and social interactions. Shouldham Warren and Marham Fen both are used extensively by tourists and locals for experiencing the great outdoors which is backed up by the research of NHS Forest [https://nhsforest.org/evidence-benefits] and the Natural England Monitor of Engagement With The Natural Environment [https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/738891/Monitorof_Engagementwiththe_Natural_Environment_Headline_Report_March_2016to_February_2018.pdf].

● It cannot be argued against that the loss of outdoor space, reduced access to nature and the countryside has a negative effect on health and well-being.

DEFRA 25 year plan encourages access to green space to promote positive mental health and reduce obesity. Other health benefits include; resilience to stress, increased mobility, higher cognitive functioning and observation skills, reduction in Type2 diabetes and depression. Those with learning disability or Attention Deficit Hyperactivity Disorder (ADHD) also experience positive outcomes from being outdoors and closer to nature (MacFarlane as cited in People's Manifesto 2018). Public Health England (PHE) suggests that landscape may be referred to as a spatial unit as well as a socio-cultural asset. The fenland area between Shouldham and Marham is seen as an asset by the local people and all who visit and use it from all around Norfolk and the UK. Inactivity is the 4 th leading factor for global mortality accounting for 6% of deaths. Our local residents, old or young, benefit from the outdoor lifestyle afforded by Marham Fen and Shouldham Warren with regular walks enhancing our heart health, lowering blood pressure, improving weight control, while keeping joints and muscles strong and improving mood and mental well being.

● The social and emotional impact of losing our outdoor area and nature cannot and should not be underestimated and is unacceptable .