Preferred Options consultation document

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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. The detailed reasons are set out below.

Objection to Quarrying In SIL 02 and AOS E and the overlap of both areas, in favour of recycling/reusing glass - CATSS (Campaign Against Two Silica Sites)

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; therefore, it is clear that quarrying is not the future. So what is the UK strategy and vision to ensure we do not compromise future generations ability to meet their own needs, and make the best use and secure the long-term conservation of minerals, in particular, silica sand for glass making? And locally, what are Norfolk County Council (NCC) doing via their Mineral and Waste Local Plan (M&WLP) to do the same and correct this cognisant failure with respect to the scarcity of high purity silica sand?

"The environmental and economic case for glass recycling(1) is clear. Cullet helps glass producers drive down energy consumption and emissions, and means less landfill and waste disposal. It's a win-win equation that has created a dynamic, global glass recycling market with a number of national and international players. So how do you choose the right partner to help you achieve the full potential of recycling?" - Quote from Sibelco's brochure(2) on recycling glass in Feb 2012. Sibelco supply, by far, the majority of glass making quality silica sand to glass manufacturers in England and Ireland but they are not involved at all in the recycling of glass in the UK.

(1) For clarity, wherever the word 'recycling' is used in this document it is referring to the act of sorting collected glass into different colour streams, processing it into high-quality glass cullet that is subsequently used in the manufacture of high-quality glass material including clear and flat glass.
(2) Pure Sense Recycling-Sibelco Green Solutions- https://issuu.com/salez-poivrez/docs/sibelco.glassrecycling.brochure.feb2012_v4

NCC uses the National Planning Policy Framework (NPPF) document as one source for updating its M&WLP. 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. Improved glass recycling and reuse would ensure the reserves of silica sand are preserved, (fulfilling mineral strategic objective MSO3 on pg 21 of the NCC M&WLP, Preferred Options July 2019) thereby extending the period of self sufficiency in glass manufacturing within the UK and show serious intent to endorse and implement the latest DEFRA (Department for Environment Food and Rural Affairs) policy document on waste management(3). Expanding the country's glass recycling ability in both efficient collection and up to date processing of the collected glass, especially clear glass, would vastly increase the number of jobs available in the UK and particularly Norfolk if it led the way in developing such a policy. In addition, NCC would be leading the way for innovative strategies to fulfil the Department for Business Energy and Industrial Strategy's 'Clean Growth Strategy'(4) document, in particular towards the ambition of Zero Avoidable Waste. The NCC M&WLP document 'Waste and Management Capacity Assessment', refers to EU legislation, the Waste Hierarchy, the principal of self-sufficiency in waste management and the National Planning Policy guidance for waste management; however, there is no attempt within the M&WLP to satisfy or comply with any of the above policies or advice with respect to recycling glass from within Norfolk. Additionally on pg 58 at section W13 of the M&WLP (Landfill Mining and Reclamation), there is mention of the 'circular economy' with respect to waste; however, it is not referring to glass recycling which is the ultimate circular economy due to glass being 100% recyclable. Overall, without a serious plan to upgrade glass recycling then the M&WLP is fundamentally flawed.

(A summary of the policies and objectives from the M&WLP that are not complied with can be found at pgs 8+9 of this document).

(3)Our Waste, Our Resources: A Strategy for England- https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/765914/resources-waste-strategy-dec-2018.pdf
(4)Clean growth Strategy - https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/700496/clean-growth-strategy-correction-april-2018.pdf

NCC should also be considering promoting glass reuse(5) which has the advantage of a reduction in local council services requirement for collection of glass(6) because less glass would be thrown away; plus, reuse would mean less raw material requiring to be supplied to the glass manufacturing industry. This would fulfil waste policy WP1 (pg 45) of M&WLP Initial Consultation and W0.2 Pg 41 of preferred options draft plan July 19 but only with a rewording to deliver a technically advanced facility that recycles as well as reuses glass. During the period where improved glass recycling and reuse is introduced, the UK could import silica sand for glass manufacture to bolster the currently available cullet and existing quarrying, thereby saving further unnecessary destruction of the countryside from the allocation of new areas for silica sand extraction. Indeed without championing and implementing a vastly different, technologically advanced glass recycling policy within Norfolk, then NCC fail their own M&WLP Preferred Options ' Vision to 2036' (pg19) in every respect.

(5)Study on impact of deposit return scheme - https://feve.org/study-on-impact-assessment-of-deposit-return-schemes/
(6)Environmental Protection Act 1990 Schedule 22A - https://www.legislation.gov.uk/ukpga/1990/43/schedule/2AA

Glass recycling(7) also contributes to British business as a whole: estimates indicate that 500 jobs are created for every 100,000 tonnes of glass collected for recycling. If we, as a country, recycled all the glass we currently throw away to landfill, it would create 7,500 sustainable new jobs overnight. NCC is failing to take the opportunity to create a vibrant local employment market in a green industry that at the same time will preserve and sustain the stocks of silica sand, protect the biodiversity of the countryside and health of the residents of Norfolk, whilst helping to reduce CO2 emissions. A continuation of quarrying will not add to the jobs market in Norfolk; however, implementing a radical glass recycling programme will create jobs at all levels from manual labour through to technical skills, and graduate to management. In addition, no jobs would be lost from the haulage industry as they would be required to move glass rather than silica sand.

(7) Cheaperwaste.co.uk - Glass Collection Services - http://www.cheaperwaste.co.uk/services/glass-collections/

Sibelco, the global company who proposed the extraction of silica sand from AOS E, including the overlap from SIL02 , and who currently extract silica sand within Norfolk, is a major partner in glass recycling in other countries around Europe (see Sibelco statement at the top of pg 1 and linked at footnote 2). On their company webpage, they make a heavy pitch for their green recycling credentials in respect of glass and how they are in partnership with High 5(8), a glass recycling company boasting the most up to date recycled glass processing plant in Europe that revolutionises glass recycling. However, Sibelco makes no attempt to do the same in the UK. Despite policy WP11 (pg56 of M&WLP) that states disposal of inert waste to landfill is the least preferred option, NCC think it is appropriate to allow the vast majority of glass waste in Norfolk to go to inert waste landfills or to refill previous cavernous extraction sites with the very material that was quarried in the first place. They think it is appropriate to destroy a rural setting through deep quarrying for silica sand for the convenience and profit of a private Belgian company, and the perceived need to continue to supply raw materials at the same rate as they always have. Policy WP11 plus many others (summarised at the end) would be fulfilled if NCC were to forge a coherent glass recycling policy leading to less raw silica sand required, less destruction of our countryside and less landfill.

Additionally, Sibelco with its expertise in recycling abroad and the fact that they have a railhead at Leziate, could be the perfect provider of this clean green industry by investing in the infrastructure required for a technologically advanced glass recycling facility at their Leziate plant. This would bring the jobs West Norfolk deserves. The arrival of glass bottles etc and the departure of the processed cullet via the railhead at Leziate would fulfill the aims stated in the M&WLP, para 9 'Transport' on pg34, by alleviating the impacts of HGV transport that surround the mining of minerals, such as silica sand, which places a heavy burden on the road transport system. It also has the added bonus of the reduction in pollution. Whilst transport by HGV may be unavoidable in some circumstances, rail transport would help to fight climate change and fulfil Government and NCC policy to reduce CO2 emissions.

(8)Sibelco Glass Recycling Video - https://vimeo.com/242176163

Glass is 100% recyclable(9) - it can be melted and made into new containers again and again with no loss of quality or performance. However, demand for cullet(10) often outstrips supply. Glass manufacturing is necessarily a continuous process and a lack of cullet can mean manufacturers must use a higher proportion of raw material (silica sand) than they would otherwise choose(11). In line with the UK Climate Change Act, British Glass is co-ordinating the endeavours of the glass manufacturers, the mineral industry and food/drinks industry to reduce CO2 emissions through enhanced glass recycling plus a move toward more green coloured glass usage(12). NCC and Sibelco cannot ignore this but are making no plans to aid this legal obligation for the UK to reduce CO2 emissions.

(9)Brit Glass - Recycling - https://www.britglass.org.uk/our-work/recycling
(10)Waste glass that has been sorted and cleaned for re-melt.
(11)Brit Glass - Recycled content - packaging - https://www.britglass.org.uk/sites/default/files/1709_0001-E1-17_Recycled%20content_0.pdf
(12)Department for Business, Energy and Industrial Strategy's Decarbonisation and energy efficiency action plans - https://www.gov.uk/government/publications/industrial-decarbonisation-and-energy-efficiency-action-plans

Recycling of glass needs to be split into several discussions: coloured glass, clear flint and flat glass, and reuse. These discussions are not mutually exclusive. Recycling coloured glass is relatively well established in the UK and we produce a surplus, much of which we export but could be put to better use in the manufacture of food and drinks packaging(13), aggregates, sports arenas and horticulture. A green recycled bottle can contain up to 90% recycled glass. Clear glass jars and containers may contain 0-25% of recycled flint glass. The difference in the amounts of recycled glass used in coloured vice clear glass jars and containers is because the producers14 of food and drinks packaging insist on having very high quality (colour clarity - clear) in their jars and containers. Studies(15) have shown that the general public (~73-98%) do not need or expect their foodstuffs to be packaged in clear jars and containers of such high quality. Indeed when presented with the facts that, a) by packaging products in coloured glass instead of clear glass there is a demonstrable reduction in the energy and water consumption required to produce the glass, plus a reduction in the CO2 emitted, and b) the economic benefit of generating more jobs in the recycling industry, then any negative impact the public has to the use of coloured glass jars and containers, instead of the clear glass equivalent, is further reduced. Unbelievably, in 2010 instant coffee was the largest consumer of glass jars by weight at 700 000 tonnes, all of which was clear glass! (See pg 30 of footnote 15). Therefore, in addition to recycling our glass jars and containers better, there also needs to be a re-education of the manufacturers of food and drinks who insist on high-quality clear glass for their products' packaging - it is neither required or needed. The public have been persuaded, quite rightly, that the amount of plastic they consume needed to be reduced; it would not take much to persuade them about the need to package products in non-clear/less clear glass jars and containers, which in turn would put pressure on the producers to reduce the amount of raw silica sand they consume. Whilst our food and drinks manufacturers continue to insist on high-quality clear glass the problem is compounded by the products we import in clear glass packaging which is glass of an inferior quality to that manufactured in the UK. This means we are exporting high-quality clear glass containers that other countries can recycle and use in new glass manufacture, whilst we receive inferior quality clear glass containers that, at present, cannot be recycled for use in high-quality clear glass manufacture in the UK and the majority goes to landfill. As a result, the UK has to extract more raw silica sand if it is to continue to sustain the use of high-quality clear glass packaging for the majority of our food and drinks produce. Instead, we should be importing silica sand to make up the shortfall in raw materials for clear glass production due to our inadequate glass recycling industry. NCC pat themselves on the back at their 44.9% recycling rate which masks the fact that this is for all recyclable materials; however, their recycling of glass is woefully inadequate(16). The summary at W1.7 on pg 44 of the M&WLP states, 'The waste forecasts do not take into account potential improvements in waste reduction and prevention' - this is a deficit in forward planning by NCC in regard to advancements in glass recycling.

(13)This requires manufacturers of food and drinks products currently packaged in high-quality clear glass containers to be 'persuaded' that the public would accept their produce in a lesser quality glass package or even in a different colour (see link at footnote 15)
(14)Feasibility Study For The Reduction of Colour Within the Glass Furnace - https://www.glass-ts.com/userfiles/files/2004%20-%20WRAP%20-%20Feasibility%20Study%20for%20the%20Reduction%20of%20Colour%20within%20the%20Glass%20Furnace.pdf
(15)Going Green - A consumer trial to identify opportunities for maximising the use of green glass for wine and spirit bottles - http://www.wrap.org.uk/sites/files/wrap/Going_Green_report_Full_version_3_.ae138c43.10768.pdf

Flat glass recycling is more problematic due to the way industry disposes of it. For flat glass to be successfully recycled in the quality and quantity that it could be, it needs to be kept clear of contaminants, i.e. it cannot be thrown in with rubble and other waste on development sites. Flat glass requires a ceed change in the building industry and waste recycling centres throughout the UK in how it should be handled to ensure it remains usable to recycle for use in the manufacture of new clear flat glass. There are many examples in Europe of how this is achieved to good effect (Reiling in Germany, for example(17) and (18)).

(16)Brit_Glass Maximising the Recyclability of Glass Packaging- https://www.britglass.org.uk/sites/default/files/00017-E2-19_Maximising_the_recyclability_of_glass_packaging_WEB.pdf
(17)Reiling Glass Recycling Video - https://www.youtube.com/watch?v=zTfrumfUisU
(18)Reiling Flat Glass Recycling Document - https://reiling.de/de/flachglas

Some benefits of recycling our glass more efficiently are as follows:

For every tonne of glass recycled it saves 1.2 tonnes of raw material; therefore, less silica sand needs to be quarried, saving our countryside and preserving the minerals.

The energy saved from recycling 1 glass bottle is enough to power a light bulb for 4 hours.

Glass is 100% recyclable and can be reused over and over again.

Glass that is thrown into landfills will never decompose, putting a great strain on landfills with too much glass content. In the UK 28 billion glass bottles and jars end up in landfills each year; 14 billion from households. More recycling = less landfill + less quarrying + less destruction of the countryside.

Bottles and jars recycled saved around 385,000 tonnes of CO2 emissions over the past year, equivalent to taking more than 120,000 cars off the road. This reduction in emissions of greenhouse gas could be further reduced by more efficient recycling.

A higher content of recycled glass cullet used in the manufacture of new glass jars and bottles reduces the temperature required in the manufacturing process using 30% less energy. This also extends the life of the furnace.

Every 100 000 tonnes of glass recycled creates 500 new jobs. Any perceived job losses from the silica sand extraction industry would be far outweighed by the number of new, environmentally sound jobs in the glass recycling industry. The UK throws away nearly 1.5M tonnes of glass bottles and jars which, if recycled, could create 7500 new jobs overnight.

Producing new glass using recycled glass reduces air pollution by 20% and water pollution by 50%.

Sibelco's own literature for the environmental and economic case for glass recycling is linked here(19). Their own conclusion, on slide 11, leads one to ask the question, 'why aren't they leading glass recycling here in the UK?'. The assumption has to be because they aren't mandated to, therefore why would they if it impacts their profit margin.

A complimentary system to recycling is reuse(20). Bottles and jars can be reused many times before, due to wear and tear, the requirement to go through the waste cycle for recycling. This is not a new idea as it was the norm for many bottle types during the 1950s, 60s and 70s, prior to the introduction of single-use plastics and aluminium cans. To reintroduce the reuse of glass containers now would require a change within the psyche of the general public, producers and retailers. However, as recently seen with the introduction of a charge for plastic bags the public can be persuaded to reuse their own bags; a similar scheme could be adapted for glass containers. This type of system is already in use in countries such as Germany, Denmark, Sweden, Australia and the USA, saving raw materials, reducing litter, and saving costs for local councils in refuse collection.

(19)Sibelco Nov 2012 - Glass recycling: environmental and economic case
(20)Study on impact of deposit return scheme - https://feve.org/study-on-impact-assessment-of-deposit-return-schemes/

Finally, Norfolk County Council is required to preserve the raw minerals in their county. In the case of silica sand, this is not being achieved by defaulting to quarrying; which, in turn, is not fulfilling the NPPF guidance quoted above - to look to recycle before extracting raw materials. NCC certainly do not do this; they do not recycle glass at all, they merely collect it, call that recycling and transport it to other counties for onward processing, whilst continuing to quarry raw materials. This is neither intelligent nor eco-friendly, it doesn't fulfil objective SA11 of the Initial Sustainability Report (pgs 14+16), nor promotes sustainable use of minerals. Additionally, it doesn't fulfill the Waste Strategic Objective, WS01- minimise waste, or the Mineral Strategic Objective, MSO3 - encourage sustainable use (pgs 20 and 21 of the M&WLP Preferred Options document). Without a technologically advanced glass recycling policy NCC's M&WLP also fails their own policies WSO 2, 4, 6, and 8; MSO 6, 8 and 10 (pg 20 +21 M&WLP); MW4 (pg36, M&WLP); and MP1 (pgs 66/67 M&WLP). In addition and perhaps most importantly, the UK Government signed up to The Paris Agreement on climate change in 2015. This accord legally binds the UK to reduce its CO2 emissions by 80% by 2050 (against the 1990 baseline). In terms of AOS E, including the overlap area with SIL 02 that still remains in the M&WLP, there is no mention of how the CO2 emissions are to be reduced or mitigated for compared to the standard silica sand quarry. The suggested wet dredging by electric barge in SIL 02, and hence by extension to the remaining portion of SIL 02 as part of AOS E, then pumping the slurry by pipeline over a distance of 6-8km must have nearly as large a carbon footprint as alternative transport by HGV. The power required for the barge and the pumps for such a long pipeline will not be an insignificant amount. The further away from Leziate silica sand is quarried only highlights the lack of a serious recycling policy through which NCC can comply with the NPPF guidance (to use recycling before raw materials) and the legal obligations to reduce greenhouse gas emissions (aided by recycled cullet use in making new glass).

The aggregate mineral industry has played its part in improving resource use efficiency (reducing CO2 emissions) by helping to increase the amount of previously used construction material that is recovered and reprocessed to create recycled aggregate. The proportion of recycled and secondary aggregate used in UK construction has increased over the last 20 years (MPA, 2015). If that industry can recycle better why can't the glass industry, with a product that is 100% recyclable, improve and strive for 100% recycling of glass and reduce their reliance on quarrying raw materials?

Whilst there is currently enough silica sand reserve in Norfolk until 2027, the legally binding commitment to the Paris Agreement and subsequent UK Climate Change Act should require NCC to cease committing any further areas for silica sand extraction until the Government and British Glass complete their initial studies into improved recycling and increased use of green glass products. In the meantime the UK glass industry could import glass quality silica sand through a just-in-time principle, if required, to bolster the current cullet available for glass manufacture.

Summary of the Policies and Objectives that are flawed due to the lack of any SERIOUS glass recycling plan for Norfolk within the M&WLP Preferred Options July 2019


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..'. The NCC M&WLP does not take this into consideration as it has no SERIOUS glass recycling plan.

NCC Vision 2036 - M&WLP

No SERIOUS glass recycling plan in place to ensure the longevity of self- sufficiency in silica sand.
No SERIOUS glass recycling plan in place to enable the aim of self- sufficiency in waste management.
No SERIOUS glass recycling plan in place to enable the aim of making the public and business take more responsibility for waste prevention, reuse and recycling.

Waste Strategic Objectives - Initial Sustainability Report Part B May 2018 and M&WLP Preferred Options Jul 2019

WSO 1 - No SERIOUS glass recycling plan in place to support the objective to prevent/minimise waste in line with the Waste Hierarchy.
WSO 2 - No SERIOUS glass recycling plan in place to support the aim of increasing the amount of waste reused, recycled and recovered.
WSO 4 - No SERIOUS glass recycling plan in place to enable the aim of self-sufficiency in waste management (Vision 2036).
WSO 6 - No SERIOUS glass recycling plan in place 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 - No SERIOUS glass recycling plan in place to recognise the importance of waste management as a generator of local employment.


Mineral Strategic Objectives - Initial Sustainability Report Part B May 2018 and M&WLP Preferred Options Jul 2019

MSO 2 - No SERIOUS glass recycling plan in place to increase the 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 (Vision 2036).
MSO3 - No SERIOUS glass recycling plan in place to encourage the sustainable use of minerals by using secondary and recycled aggregates (NPPF, Ch 17, para 204.b).
MSO 8 - No SERIOUS glass recycling plan in place to minimise the impact of climate change through the reduction of CO2 emissions due to an increased use of high quality recycled glass cullet in glass manufacturing.
MSO 10 - No SERIOUS glass recycling plan in place 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.

Presumption in Favour of Sustainable Development - M&WLP Preferred Options Jul 2019

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.
MW 4 - No SERIOUS glass recycling plan in place to support reductions in greenhouse gasses to reduce climate change.

Waste Management Specific Policies - M&WLP Preferred Options Jul 2019

WP 1 - No SERIOUS glass recycling plan in place to 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).

Mineral Specific Policies - M&WLP Preferred Options Jul 2019

MP 1 - No SERIOUS glass recycling plan in place without which the planned extraction figures are flawed as they are based on what the mineral extraction companies supply to NCC as the 'required need'. With increased recycling of glass, especially clear glass the figure of 'required need' for silica sand would be reduced.

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

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

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

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

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

● There is no definitive demonstration that the UK needs to be self-sufficient in silica sand. The UK is not self-sufficient in defence - we buy equipment from around the world at a cost of billions of pounds; we are not self sufficient in medicines; or food that we import at a cost of millions if not billions; we are not self-sufficient in energy production - gas, electricity and oil all imported from outside the UK. Yet somehow we have to be in sand and glass? Without this demonstration of the requirement to be self-sufficient in silica sand, extraction of minerals by quarrying is purely because there is no vision to change; it is a classic case of business as usual because it is the easy option for the County Council and profit-driven industry. If the UK was truly intent on maintaining its mineral reserves then Government, aided and guided by Mineral Planning Authorities, would be looking for ways to ensure the minerals are conserved. The National Planning Policy Framework (NPPF) states in (Ch 17, para 204.b) that authorities should 'take account of...recycled materials...before considering extraction of primary materials..'. NCC does not adhere to this as it does not have a glass recycling programme worthy of the name; NCC merely collects glass and transports it outside of Norfolk for processing. In the UK 28 billion glass bottles and jars end up in landfill each year; 14 billion from households (recyclingbins.co.uk). Bars, restaurants and clubs in the UK throw away 200 000 tonnes of glass every year to landfill. Overall it is estimated that the UK throws away 1.5 million tonnes of glass to landfill each year; conveniently approximately 1.5 million tonnes of sand go to the glass making industry. What happens to the collected glass once beyond the county borders seems to be of no consequence to NCC. Therefore, NCC is failing in its duty to look to recycle before extracting raw materials and their vision is not sound.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

● There is no definitive demonstration that the UK needs to be self-sufficient in silica sand. The UK is not self-sufficient in defence - we buy equipment from around the world at a cost of billions of pounds; we are not self sufficient in medicines; or food that we import at a cost of millions if not billions; we are not self-sufficient in energy production - gas, electricity and oil all imported from outside the UK. Yet somehow we have to be in sand and glass? Without this demonstration of the requirement to be self-sufficient in silica sand, extraction of minerals by quarrying is purely because there is no vision to change; it is a classic case of business as usual because it is the easy option for the County Council and profit-driven industry. If the UK was truly intent on maintaining its mineral reserves then Government, aided and guided by Mineral Planning Authorities, would be looking for ways to ensure the minerals are conserved. The National Planning Policy Framework (NPPF) states in (Ch 17, para 204.b) that authorities should 'take account of...recycled materials...before considering extraction of primary materials..'. NCC does not adhere to this as it does not have a glass recycling programme worthy of the name; NCC merely collects glass and transports it outside of Norfolk for processing. In the UK 28 billion glass bottles and jars end up in landfill each year; 14 billion from households (recyclingbins.co.uk). Bars, restaurants and clubs in the UK throw away 200 000 tonnes of glass every year to landfill. Overall it is estimated that the UK throws away 1.5 million tonnes of glass to landfill each year; conveniently approximately 1.5 million tonnes of sand go to the glass making industry. What happens to the collected glass once beyond the county borders seems to be of no consequence to NCC. Therefore, NCC is failing in its duty to look to recycle before extracting raw materials and their vision is not sound.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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