Silica Sand Review

Norfolk Minerals and Waste Local Plan

Minerals Site Specific Allocations Development Plan Document (DPD) – Single Issue Silica Sand Review

Equality Impact Assessment

February 2016

www.norfolk.gov.uk

Norfolk Minerals and Waste Local Plan

Minerals Site Specific Allocations Development Plan Document (DPD) – Single Issue Silica Sand Review

Equality Impact Assessment February 2016

T. McCabe – Executive Director Community and Environmental Services Norfolk County Council Martineau Lane Norwich NR1 2SG

www.norfolk.gov.uk

If you would need this document in large print, audio, braille, an alternative format or a different language please contact Norfolk County Council on 0344 800 8020 or 0344 8008011 (textphone) and we will do our best to help.

Contents Page Introduction 3 Stage 1. Scope of the assessment 4 Stage 2. Assessor 5 Stage 3. Evidence and Analysis 5 Stage 4. Impact assessment 17 4.1 Consultation 18 Stage 5. Relevance to equality groups 20 Stage 6. Mitigation for adverse impacts 23 6.1 Improvement planning and recommendations 24 Glossary 25 Appendix 25

Introduction This equality impact assessment relates to the Single Issue Silica Sand Review of the Minerals Site Specific Allocations Development Plan Document (DPD). The statutory plans for mineral and waste planning in Norfolk are contained in the Norfolk Minerals and Waste Development Framework. This framework consists of four Planning Policy documents which form the Local Plan: - The Core Strategy and Mineral and Waste Development Management Policies DPD – (the ‘Core Strategy’) which contains policies for use in making decisions on planning applications for mineral extraction and associated development and for waste management development, and in the selection of the specific site allocations in Norfolk. This document was adopted in September 2011. - Minerals Site Specific Allocations DPD - allocates specific sites that are suitable as well as available for mineral extraction and associated development, to meet the requirements of Core Strategy Policy CS1, until the end of 2026. This document was adopted in October 2013. - Waste Site Specific Allocations DPD – allocates specific sites which are available and acceptable in principle for waste management facilities, to meet the requirements of Core Strategy Policy CS4, until the end of 2026. This document was adopted in October 2013. - Policies Map (previously referred to as a Proposals Map) – accompanies the adopted plans and is designed to act as a visual aid in interpreting the policies in the adopted Plans. Silica Sand Review of the Minerals Site Specific Allocations DPD The Minerals Site Specific Allocations DPD contains a requirement for a Silica Sand Review of the Plan to be completed by 2016. The purpose of the Silica Sand Review is to address a predicted shortfall, of 2.5 million tonnes, in the quantity of silica sand extraction sites allocated in the Plan. The production of the Silica Sand Review is subject to a number of stages: Initial Consultation stage: An Initial Consultation stage took place from 6 March to 20 April 2015. This consultation set out the scope and purpose of the Silica Sand Review of the Minerals Site Specific Allocations DPD and sought views on the potential methodology for identifying and assessing specific sites, preferred areas and/or areas of search for future silica sand extraction. The comments received were taken into account in the criteria used to define areas of search. Call for sites: In June 2015, the County Council made a ‘Call for Sites’ to land owners, developers and their agents to submit sites for silica sand extraction, which resulted in one proposed silica sand extraction site being submitted. Preferred Options: The Preferred Options Consultation document included one potential specific site and ten defined areas of search for silica sand extraction in Norfolk. The document contained an assessment of the proposed site and each area of search and described the County Council’s suggested way forward in terms of which site and areas of search were considered suitable for future silica sand extraction. The documents were published for a six week consultation period from 6 November to 21 December 2015. The comments received were taken into account in the production of the Pre-Submission document. Pre-Submission publication: The Pre-submission publication document includes one specific site and six defined areas of search for silica sand extraction in Norfolk. The

document contains a description and allocation policy for the specific site, a description of each area of search and a areas of search policy. The Pre-Submission document also contains other modifications to the adopted Minerals Site Specific Allocations Plan to address the fact that the requirement for a Silica Sand Review has been carried out. The Pre-Submission document will be published for a six week period for representations to be made on whether or not the document is legally compliant and ‘sound’ (positively prepared, justified, effective, and consistent with national policy. Submission: If no fundamental issues are raised during the Pre-Submission representations period, the Council will submit the plan and relevant background information, together with the representations received, to the Secretary of State for Examination in Public by an independent Planning Inspector. Assuming that the Planning Inspector’s report concludes that the plan is sound, legally compliant and should be adopted, the Council will then make the decision whether to adopt the document or not. The adopted document will form part of the Minerals SSA DPD. Equality Impact Assessment (EqIA) An Equality Impact Assessment was carried out on the Minerals and Waste Core Strategy, the Minerals Site Specific Allocations and the Waste Site Specific Allocations Development Plan Documents. This EqIA relates to the Single Issue Silica Sand Review of the Minerals Site Specific Allocations DPD only. An EqIA is one method which can be used to assess options for policy making to ensure equality issues are taken into account. It stems from the Equalities Act 2010 which placed a duty on public authorities through the Public Sector Equality Duty to have due regard to eliminate unlawful discrimination in carrying out its functions, and promote equality of opportunity between men and women, different racial groups and other equality groups. The Equality Act 2010 provides nine protected characteristics which cannot be used as a reason to treat people unfairly (these are listed in the appendix). The Act sets out the different ways in which it is unlawful to treat people such as direct and indirect discrimination, harassment and victimisation. The act prohibits unfair treatment in the workplace; when providing services; and exercising public functions. The EqIA has been prepared to satisfy all relevant legal and policy requirements for the assessment. It has been completed in line with the County Council’s own guidance for undertaking EqIAs. The Equality and Human Rights Commission has also published detailed guidance on the Equalities Act 2010, and how public bodies can comply with it.

Stage 1: Scope of the assessment What is being assessed?

The Single Issue Silica Sand Review of the Minerals Site Specific Allocations DPD: Pre- Submission document is being assessed. Once adopted, the specific site and areas of search allocated through the Silica Sand Review process will become part of the Minerals Site Specific Allocations DPD which forms part of the Development Plan for Norfolk.

For each site specific allocation and area of search, the Silica Sand Review contains: 1. Characteristics of the site/area of search, including: location, size, distance from the nearest properties or settlements, agricultural land grade, flood risk zone, distance from environmental designated sites, and distance from heritage assets. 2. Policy: contains details on the requirements that would need to be satisfied at the planning application stage, for example: access routes, landscaping, restoration, archaeological work, and assessment and mitigation measures to address potential amenity, landscape, environmental and heritage impacts.

Stage 2: Assessor Who is carrying out the assessment?

Name Job Title Role Nick Johnson Planning Services Manager, Norfolk Overall project manager County Council and decision maker Caroline Jeffery Principal Planning and Policy Officer, Assessment Norfolk County Council Richard Drake Senior Planner, Norfolk County Assessment Council

Stage 3: Evidence and analysis All silica sand resources in Norfolk occur within a relatively narrow band which is located entirely with the administrative area of King’s Lynn and West Norfolk. The resource is present from just south of Hunstanton in the north to just south of Hilgay in the south. A processing plant and railhead is located at Leziate. What does the evidence tell us about potential impacts?

An assessment of potential impacts of the Silica Sand Review on each of the following equality characteristics will be conducted: • race • religion • disability • age • gender

It is considered that the location of the specific site or areas of search contained in the Silica Sand Review will not have any differential impacts on the following equality characteristics and therefore they are not discussed further in this Equality Impact Assessment: • marriage and civil partnership • pregnancy and maternity • gender reassignment • sexual orientation

3.1 Racial Groups - Visible Minority Ethnic Population The ‘visible minority ethnic’ (VME) group as defined by the Office of National Statistics (ONS) is made up of groups of the population other than those self-classifying as ‘white’.

As shown in Table 1, Norfolk has a low level of population diversity, with the percentage of those classified within the VME group being significantly lower than both the East of England and England.

In 2011 the VME group represented 2.9% of the total population in the Borough Council of King’s Lynn and West Norfolk area, this is below an already low proportion of just 3.6% of the total population of Norfolk. By comparison, in the East of England the percentage represented 9.1% in 2011. In England, the percentage of the VME group represented 14.5% of the total population in 2011.

At district level there are significant differences in the percentage of the population within Norfolk which are self-classifying as part of the VME group. The smallest percentage of the district population within the VME group occurs in North Norfolk (1.4%). Norwich City has the greatest concentration of people within the VME group (9.1%).

- ‘White Other’ Ethnic Population The largest minority group within Norfolk’s population is the ‘White Other’ group. This group is a sub-set of the ‘white’ group and comprises Europeans and those people of a European descent who do not fall within the groups ‘White British’, White Irish’ or ‘White Gypsy or Irish Traveller’.

In 2011 this group comprised 4.5% of the total population in the Borough Council of King’s Lynn and West Norfolk area, this is greater than the 3.5% of Norfolk’s total population. However, the percentage in the Borough Council area is roughly equivalent to the percentages in the East of England (4.5%) and England (4.6%)

The districts in 2011 show significant differences in the percentage of the population within this group from the lowest in Broadland (1.4%) to the highest in Breckland (5.6%).

Table 1: Ethnicity of usual resident population (2011 census) %

White: British White: Irish White: Gypsy or Irish Traveller White: Other and Mixed: White CaribbeanBlack and Mixed: White African Black and Mixed: White Asian mixedMixed: Other Asian: Indian Asian: Pakistani Asian: Bangladeshi Asian: Chinese Asian: other Asian African Black: Black: Caribbean Black: Other Black Other: Arab other Other: any ethnic group Breckland 91.2 0.5 0.2 5.6 0.3 0.2 0.3 0.4 0.2 0.1 0.1 0.2 0.3 0.2 0.2 0.1 0 0.1 Broadland 95.9 0.3 0 1.4 0.2 0.1 0.3 0.2 0.3 0 0.1 0.2 0.3 0.2 0.1 0 0.1 0.1 Great 92.8 0.4 0.1 3.6 0.3 0.3 0.3 0.3 0.5 0.1 0 0.2 0.4 0.3 0.1 0.1 0.1 0.2 Yarmouth King’s 92.2 0.4 0.2 4.5 0.2 0.2 0.3 0.3 0.5 0.1 0 0.3 0.4 0.2 0.1 0.1 0.1 0.1 Lynn and West Norfolk North 96.6 0.3 0 1.7 0.2 0.1 0.2 0.1 0.1 0 0.1 0.1 0.2 0.1 0.1 0 0 0.1 Norfolk Norwich 84.7 0.7 0.1 5.4 0.5 0.5 0.7 0.6 1.3 0.2 0.4 1.3 1.3 1.3 0.2 0.1 0.5 0.4 South 95.2 0.4 0.1 1.9 0.3 0.1 0.3 0.2 0.3 0.1 0 0.3 0.3 0.2 0.1 0 0.1 0.1 Norfolk Norfolk 92.4 0.4 0.1 3.5 0.3 0.2 0.3 0.3 0.5 0.1 0.1 0.4 0.5 0.4 0.1 0.1 0.1 0.1 East of 85.3 1 0.1 4.5 0.6 0.6 0.6 0.5 1.5 1.1 0.6 0.6 1 1.2 0.6 0.2 0.2 0.3 England England 79.8 1 0.1 4.6 0.8 0.3 0.6 0.5 2.6 2.1 0.8 0.7 1.5 1.8 1.1 0.5 0.4 0.6 Source: 1 Norfolk Insight (2011 Census)

Table 2: number of National Insurance Number registrations to Adult Overseas Nationals 2014-2015

Apr 14- Jul 14 – Oct 14 – Jan 15 – Total 14-15 June 14 Sept 14 Dec 14 Mar 15 Breckland 164 437 414 413 1,428 Broadland 24 78 62 64 228 Great Yarmouth 121 327 308 340 1,096 King’s Lynn and 101 367 385 354 1,207 West Norfolk North Norfolk 35 131 238 73 477 Norwich 242 624 804 650 2,320 South Norfolk 47 150 120 149 466 Norfolk 734 2,114 2,331 2,043 7,222 Source: 2 Department of Work and Pensions

Table 2 shows the number of registrations for National Insurance by overseas nationals, this gives a measure of the inflow into Norfolk districts by migrant workers. The data shows that Norwich has the greatest inflow of workers; as the peak of registrations occurs in October to December this may be partly as a result of the arrival of overseas students seeking part-time employment. Breckland and King’s Lynn and West Norfolk also experience significant levels of registrations. Indications are that numbers of overseas workers in these areas are working in food processing and agricultural activities. Table 3 shows the proportion of the economically active population based on country of birth. Norwich has the highest overall proportion of workers born in countries other than the United Kingdom, and the highest proportion from countries other than Europe. The lowest proportion of workers from outside Europe is in North Norfolk. Breckland has the highest proportion of European workers in Norfolk, and the lowest proportion is in Broadland.

Table 3: Proportion of economically active population by country of birth (2011 census) % Europe: Europe: Europe: EU EU Accession Rest Rest United Ireland Other countries: countries: countries of of the Kingdom Europe: Total Member April 2001 Europe World Total countries in to March March 2011 2001 Breckland 88.40% 0.34% 7.62% 7.33% 2.84% 4.49% 0.30% 3.64% Broadland 94.79% 0.22% 2.04% 1.83% 0.99% 0.84% 0.21% 2.94% Great 91.28% 0.30% 5.03% 4.68% 2.05% 2.62% 0.35% 3.39% Yarmouth King`s Lynn 89.54% 0.23% 6.31% 5.89% 1.62% 4.27% 0.42% 3.92% and West Norfolk North 94.78% 0.20% 2.76% 2.53% 1.09% 1.44% 0.23% 2.26% Norfolk Norwich 84.82% 0.47% 7.12% 6.45% 2.38% 4.07% 0.67% 7.59% South 93.87% 0.23% 2.57% 2.35% 1.26% 1.10% 0.22% 3.33% Norfolk Source 3: ONS

3.2 Religion The 2011 census provides the most complete picture of religion within Norfolk. The largest percentage of the population in Norfolk, who gave an answer to this question, stated Christianity (61%); this is slightly above the figure given for the East of England (59.7%) or for England as a whole (59.4). In Norfolk, the next largest percentage of the population stated no religion (24.8%), slightly below the figures for the East of England (27.9%) but slightly higher than the percentage for England (24.7%). For the individual religions other than Christianity, the largest percentage of the population in Norfolk who gave an answer specified that they were Muslim (0.6%); this is a significantly lower percentage than for the East of England (2.5%) or England (5%). For all other specified religions Norfolk has a lower percentage than both the East of England and England. In Norfolk the number of people who stated that they defined themselves as another religion other than those defined was (0.5%), higher than both the East of England (0.4%) or England (0.4%).

Table 4: Religion by district in 2011 (% of usual resident population)

Christian Buddist Hindu Jewish Muslim Sikh Other No Not religion religion stated Breckland 63.8 0.2 0.1 0.1 0.3 0 0.5 27.6 7.4 Broadland 63.3 0.3 0.2 0.1 0.3 0.1 0.4 28 7.4 Great 61 0.2 0.3 0.1 0.5 0 0.3 30.3 7.2 Yarmouth King’s Lynn 66.4 0.3 0.2 0.1 0.4 0.1 0.4 24.8 7.4 and West Norfolk North 66 0.3 0.1 0.1 0.2 0 0.5 25.2 7.6 Norfolk Norwich 44.9 0.7 0.8 0.2 2 0.1 0.7 42.5 8.2 South 62.3 0.3 0.2 0.1 0.3 0 0.4 28.7 7.7 Norfolk Norfolk 61 0.3 0.3 0.1 0.6 0.1 0.5 29.6 7.6 East of 59.7 0.4 0.9 0.6 2.5 0.3 0.4 27.9 7.3 England England 59.4 0.5 1.5 0.5 5 0.8 0.4 24.7 7.2 Source: Norfolk Insight (census 2011)

The districts show significant variations in religion. The highest proportion of Norfolk residents stating they are Christian is in King’s Lynn and West Norfolk (66.4%) and the lowest is in Norwich (44.9%). The proportion of the population self-defining as Muslim also shows significant variances between districts, the highest proportion of the population being resident in Norwich (2%) and the lowest in North Norfolk (0.2%).

The census data indicates a higher proportion of residents practicing a religion other than Christianity within those districts (see Figure 1 and Table 4) which have greater proportions of their populations from a visible minority ethnic group, this is unsurprising given the place given to religion as part of a cultural heritage.

3.3 Indices of deprivation The latest version of English Index of Multiple Deprivation (IMD) was published on the 30 September 2015, previous versions were published in 2010, 2007, 2004 and 2000. The IMD is the official measure of relative deprivation for small areas.

The IMD uses Lower Super Output Areas (LSOAs) as an area of geography. LSOAs consist of an area containing approximately 1,500 residents or 650 households. As a relative measure the index of deprivation ranks LSOAs compared to all other LSOAs in England. Each LSOA is ranked across the 32,844 LSOAs in England, with a rank of 1 for the most deprived LSOA in England and a rank of 32,844 for the least deprived LSOA. The boundaries of the LSOAs were redefined for the 2011 Census, and the number of areas increased from 32,482 in previous versions.

To aid interpretation LSOAs the indices also includes deprivation ‘deciles’ dividing LSOAs into 10 equal groups from the 10% most deprived to the 10% least deprived.

The Indices of Multiple deprivation includes seven measures of deprivation known as domains, these are grouped together to form the IMD. Each domain is made up of a number of different measures

The seven domains of deprivation are:

• Income Deprivation • Employment Deprivation • Education, Skills and Training Deprivation • Health Deprivation and Disability • Crime • Barriers to Housing and Services • Living Environment Deprivation

There are also two supplementary domains which measure income deprivation affecting children and older people.

Figure 1 shows the deciles of the IMD, the LSOAs within the 10% most deprived are shown in red and the 10% least deprived in dark green. It can be seen that the most deprived areas occur mainly within the urban areas of Norwich, King’s Lynn, Thetford and Great Yarmouth.

Figure 1 Index of Multiple Deprivation (2015)

3.4 Health deprivation and disability

Figure 2: Health and Disability deprivation domain Figure 2 shows a measure of health deprivation across the County. This is a measure of premature death and the impairment of quality of life by poor health. In 2015, 34 LSOAs (5.8%) were in the 10% most health deprived nationally, this is a significant change from 2010 when 13 LSOAs (2.4%) were in the same category. These LSOAs were in the local authority areas of Norwich, King’s Lynn and West Norfolk, and Great Yarmouth. This is clearly displayed on the map; with the red, orange and yellow shading (representing the most health deprived LSOAs) concentrated to the urban areas and West Norfolk. In consideration of the 20% most health deprived LSOAs nationally, 81 of these are in Norfolk (13.9%) and again they occur mainly in local authorities which contain the largest urban areas (Norwich City, Great Yarmouth and King’s Lynn and West Norfolk), however pockets of health deprivation in this category also occur in some urban areas of Breckland and North Norfolk. There are 22 LSOAs in the 10% least health deprived nationally (3.8%) this is a significant reduction from the 62 LSOAs in the 2010 index of deprivation. In 2015, 98 LSOAs were in the 20% least deprived. These were in the local authority areas of South Norfolk, North Norfolk, Broadland and Breckland. Therefore by comparison, the general trend shows the least health deprived areas to be the rural LSOAs, with the exclusion of King’s Lynn and West Norfolk. While the general pattern shows a rural/ urban divide in terms of health deprivation, there are areas of health deprivation within the rural areas. For example, as well as rural West Norfolk, the coastal areas of Sheringham, Cromer and Hunstanton have higher levels of health deprivation.

There are 89 LSOAs within the Borough Council of King’s Lynn and West Norfolk administrative area. In 2015, 8 LSOAs were in the 10% most health deprived nationally, and 16 LSOAs in the 20% most deprived. In comparison there were no LSOAs in 20%

least heath deprived areas. The most health deprived areas in West Norfolk occurred mainly in the urban areas of King’s Lynn, although there were also pockets of significant health deprivation in parts of Hunstanton, Heacham and rural areas to the east of Wisbech.

3.5 Age

Table 5: Norfolk age structure estimates (% of total population) 2014

Location 0-15 16-29 30-44 45-64 65-79 80+ Breckland 17.4 15.45 16.91 26.56 17.28 6.4 Broadland 16.28 13.4 17.05 28.57 17.81 6.89 Great 17.58 16.72 16.37 26.39 16.84 6.1 Yarmouth King’s Lynn 16.9 15.29 16.37 26.68 18.04 6.71 and West Norfolk North 14 12.67 13.6 28.52 22.33 8.88 Norfolk Norwich 16.89 26.78 20.96 20.59 10.17 4.61 South 17.98 13.52 17.49 27.54 17.26 6.21 Norfolk Norfolk 16.78 16.44 17.11 26.29 16.91 6.47 East of 18.99 16.8 19.37 25.87 13.71 5.26 England England 18.97 18.28 19.9 25.29 12.79 4.77 Source: Norfolk Insight population estimates (ONS data)

Table 6: Parishes containing areas of search: age structure (% of total population) 2014

Parish % % % % % % % population population population population population population population aged 0 to aged 16 to aged 30 to aged 45 to aged 65 to aged 85 aged 45 15 29 44 64 84 plus plus Shouldham 15.04% 8.60% 13.88% 28.76% 27.11% 6.61% 62.48% Dersingham 13.23% 9.18% 14.55% 28.02% 30.06% 4.96% 63.04% Snettisham 12.72% 9.65% 12.96% 30.23% 30.47% 3.97% 64.67% Stow 18.78% 12.76% 17.48% 32.28% 17.72% 0.98% 50.98% Bardolph Wormegay 20.89% 13.09% 16.16% 31.48% 15.88% 2.51% 49.86% Pentney 18.57% 12.32% 17.65% 32.17% 18.01% 1.29% 51.47% East Winch 15.02% 12.07% 17.07% 32.48% 20.67% 2.70% 55.84% Runcton 11.87% 10.20% 13.85% 39.88% 23.14% 1.07% 64.08% Holme Shouldham 13.94% 13.33% 13.33% 36.97% 20.00% 2.42% 59.39% Thorpe Marham 21.81% 37.18% 24.02% 10.76% 5.89% 0.34% 16.99% Tottenhill 12.79% 12.33% 17.35% 33.33% 22.37% 1.83% 57.53% Ingoldisthorpe 13.31% 7.18% 13.31% 33.45% 28.98% 3.77% 66.20% Source: Norfolk Insight population estimates (ONS data)

Table 5 shows the spatial distribution of the population by age, across Norfolk. Norfolk has an aging population with a higher than average proportion of the population in over 45 age groups compared to the East of England and England. North Norfolk has the lowest proportion of the population aged 15 or under (14%) and South Norfolk has the highest proportion (18%).

King’s Lynn and West Norfolk has a higher proportion of the population aged 45 or over (51.43%) than the Norfolk average (49.67%).

The Parishes which contain proposed Areas of Search all have a higher proportion of the population aged 45 or over than either Norfolk or the Borough Council of King’s Lynn and West Norfolk, with the exception of Marham parish. Marham has a higher proportion of the population aged between 16 and 29; this is likely to be the result of the service personnel stationed at RAF Marham. The highest proportion of older residents occurs in the parish of Ingoldisthorpe, although the highest proportion of retirees occurs in the parish of Dersingham where just over 35% of the population is aged 65 or over. The figures below show the age distribution of the parishes in which the specific site and areas of search are located, together with the average mean age of residents, which shows the generally high proportion of older residents.

Figure 3: Age distribution of parishes for areas of search AOS D, E, F, I & J

Figure 4: Age distribution of parishes for areas of search AOS A

Figure 5: Age distribution of parish for specific site SIL 01

3.6 Gender

Table 7: Gender of population % in 2011

Area Male Female Breckland 49.5 50.5 Broadland 48.8 51.2 Great Yarmouth 49.1 50.9 King’s Lynn and West 48.9 51.1 Norfolk North Norfolk 48.5 51.5 Norwich 49.3 50.7 South Norfolk 48.8 51.2 Norfolk 49.0 51.0 East of England 49.2 50.8 England 49.2 50.8 Source: ONS – 2011 census

Generally gender is not spatially diverse to any great degree. Approximately 51% of Norfolk’s population is female. There are minor variations across districts and urban areas but these variations are generally within the range of a few tenths of a percent, and are not felt to be significant. Generally the highest variation in the proportion of male to female tend to be within areas with the highest proportion of people above retirement age, where the proportion of women tends to be higher, which is likely to be due to the comparatively greater life expectancy of women.

3.7 Accessibility Accessibility to services is a key part of ensuring social cohesion. The availability and quality of public transport is a vital component to improving accessibility. Another important factor is the location of services in relation to public transport corridors; it is this factor which is most important when examining the impact that the sites and areas of search in the Silica Sand Review will have upon accessibility.

The nature of mineral extraction sites means that they can only be located where there are viable resources. Therefore site are often located within rural areas which are not serviced by high quality public transport. However, the general public does not normally have a need to access these sites and the nature of the products does not favour carriage by public transport. Therefore the impact on individuals, caused by not being able to easily access these sites, is not significant. Silica sand is an industrial mineral, and the deposits which are extracted in Norfolk all have specialist end-uses. Glass making is the most significant end-use for the sand processed at the Leziate plant and this is predominately shipped to glass works by train, making use of the rail-head located at the processing plant.

Evidence provided by mineral operators, in response to previous consultations on the Core Strategy and Minerals Site Specific Allocations DPD, indicates that mineral extraction and processing sites do not provide large scale employment opportunities and therefore the impacts of limited accessibility are unlikely to be significant.

3.8 Stage 3 Conclusions: Potential impacts on Equality Groups The preceding analysis has shown that Norfolk does have some spatial variation in the distribution of some equality groups. The broad picture shows differences between urban and rural locations, in terms of age, racial groups, religion, and health deprivation. Urban areas of Norfolk are more ethnically diverse, with a greater range of racial and religious groups. Similarly they tend to hold younger populations. Higher proportions of older populations tend to occur in rural areas. In terms of health deprivation, urban areas have the highest levels of deprivation, but there are rural areas which also exhibit high levels of health deprivation, principally in parts of Borough Council areas of West Norfolk and Great Yarmouth. In West Norfolk, the higher levels of health deprivation may be as a result of the higher than average proportion of older residents, who may have more age related health conditions than the general population. In terms of accessibility, rural locations have greater difficulties as they are less well served by public transport, and services may be more sparsely located. While the 2011 census found that there is a higher proportion of the minority ethnic population in urban areas, the rural areas are not homogenous, and therefore differential impacts to minority ethnic groups are unlikely to be caused by silica sand extraction. The parishes containing the areas of search and the specific site have a higher proportion of older residents than the Norfolk average, and higher than average levels of health deprivation. However, the accessible silica sand resource occurs mainly in rural areas in West Norfolk which also generally have a higher proportion of older residents that the Norfolk average and higher than average levels of health deprivation. Further analysis will be conducted to assess any potential impact caused by the specific site and each of the areas of search proposed for silica sand extraction.

Stage 4: Impact Assessment It has been established from the evidence in the preceding section that different equality groups have spatial distributions in Norfolk. In particular, minority ethnic and minority religious groups, younger people and people experiencing health deprivation are to be found in higher proportions in the larger urban areas, in comparison with the county average figures.

All silica sand resources in Norfolk occur within a relatively narrow band which is located entirely with the administrative area of King’s Lynn and West Norfolk. The resource is present from just south of Hunstanton in the north to just south of Hilgay in the south. A processing plant and railhead is located at Leziate. The Core Strategy policies, which are used in the selection of silica sand sites and areas of search, guide the spatial distribution of mineral extraction. As well as the adopted Core Strategy policies, a sieve mapping process has been used to define the areas of search. The sieve mapping process is based on a methodology which was consulted on in the Initial Consultation document. This set out a number of parameters used to define locations potentially suitable as areas of search. One of these parameters was to exclude areas within 250 metres of permanent dwellings. The reasoning was that while appropriate mitigation measures can make amenity impacts acceptable at distances closer than 250 metres, it would be likely that no unacceptable amenity impacts would occur at 250 metres with minimal mitigation.

The minority ethnic groups and the minority religious group are concentrated within the urban areas, with the urban fringe exhibiting a demographic structure far closer to the average. Silica sand extraction can only occur where viable resources are found and it would be unusual for sites to be located within an urban area. Therefore, differential impacts to minority ethnic groups and minority religious groups are unlikely to occur, due to the allocation of silica sand extraction sites and areas of search, in accordance with Core Strategy locational policies, and the sieve mapping methodology. Therefore, impacts on race and religion from the Silica Sand Review have not been assessed further. 4.1 Consultation The Initial Consultation and Preferred Options Consultation of the Silica Sand Review were carried out in accordance with the adopted Statement of Community Involvement as follows:

Who was consulted? Specific consultation bodies, general consultation bodies and other consultation bodies are detailed in the Town and Country Planning (Local Development) (England) Regulations 2004 (as amended) and in the adopted Statement of Community Involvement. Details of all the consultees can be found in the ‘Statement of Consultation (February 2016)’. The general consultation bodies include: • Bodies which represent the interests of different racial, ethnic or national groups • Bodies which represent the interests of different religious groups • Bodies which represent the interests of disabled persons

Methods used Responses were made to the Initial Consultation and the Preferred Options Consultation through the electronic consultation system (accessed via a website), or by letter, email or fax submission. The consultation documents could be viewed by the public in all Norfolk libraries, at each of the main Local Planning Authority offices, at County Hall, and on Norfolk County Council’s website www.norfolk.gov.uk/nmwdf.

The consultation stages were advertised by public notice in the press. Emails or letters were sent to individuals who had responded to previous consultations regarding proposed silica sand extraction sites during the production of the adopted Minerals Site Specific Allocations DPD. Letters were also sent to addresses outside a settlement and in close proximity to one of the ten proposed areas of search. Emails or letters were also sent to the specific, general and other consultees, including all parish councils in Norfolk and adjacent to Norfolk. When did the consultations take place? Initial Consultation: 9 March to 20 April 2015 Preferred Options Consultation: 6 November to 21 December 2015

How was the feedback given? The comments received in response to the Initial Consultation, including Norfolk County Council’s Planning Officer responses to the issues raised, were published in a Feedback Report in June 2015. The comments received in response to the Preferred Options Consultation, including Norfolk County Council Planning Officer responses to the issues raised, were published in a Feedback Report in January 2016. These documents were made available on the Norfolk County Council website. Respondents to each consultation stage were emailed to advise them of the publication of the Feedback Reports and where to view them.

Relevant issues raised in the Initial Consultation Stage At the Initial Consultation stage, one individual, King’s Lynn and West Norfolk Borough Council, Sibelco UK Ltd and the Environment Agency made consultation responses related to health and amenity issues. The Borough Council and the Environment Agency raised no objections to a distance of 125 metres from sensitive receptors to amenity impacts (such as residential dwellings), being excluded from defined areas of search. An individual considered that 500 metres from sensitive receptors to amenity impacts should be excluded from defined areas of search, whilst Sibelco UK Ltd considered that a shorter distance should be used. Following the consultation, it was concluded that a distance of 250 metres would be used which is consistent with the consultation area used in Core Strategy Policy CS16-safeguarding.

Relevant issues raised in the Preferred Options Consultation Stage At the Preferred Options stage, one individual, King’s Lynn and West Norfolk Borough Council, and Norfolk Public Health made consultation responses related to health and amenity issues. The Borough Council and the Norfolk Public Health raised no objections to the proposed areas of search on the grounds of health or amenity. The individual raised a number of concerns including the potential for health impacts, from the extraction operation and onward transportation. Full responses to these can be found in the Preferred Options Consultation Feedback Report. In summary, the Health and Safety Executive have found that silica sand extraction does not pose a risk to the general public, and the potential for impacts from transportation would be assessed and mitigation put in place by condition as part of any future planning application.

Diversity of respondents to the consultation Information was not gathered on the diversity of respondents to the consultations on the Silica Sand Review. We received comments on the Initial Consultation stage from the 17 organisations and one individual. We received comments on the Preferred Options Consultation stage from 18 organisations and 11 individuals.

Stage 5 (i) Relevance to Equality Groups As the area required for silica sand extraction to meet the shortfall in the plan up to 2026 is around 40 hectares, to come from a combination of any Area of Search and the Specific Site allocation, it is considered that subsequent extraction locations could be chosen from within the Areas of Search to minimise the potential for any differential impacts to equality groups.

Table 8: Characteristics of each allocated site or area of search

Site/area of Reference Key characteristics Groups search location potentially (Parish) affected Bawsey SIL01 The size of the site is 21 hectares. People The estimated silica sand resource at the site is with 1,200,000 tonnes. The site is part of a former disabilities mineral working which was partially extracted. The Older site is located in an area which has a history of people mineral working and is adjacent to restored and permitted workings. The nearest residential property is approximately 280 metres from the site boundary. The site is approximately 700 metres from the Leziate processing plant and the proposer of the site has indicated that it is intended that mineral will be transferred by conveyor to the processing plant. Ingoldisthorpe, AOS A The size of the AoS is 328 hectares. People Snettisham The AoS is an area of agricultural land with small with and areas of woodland. It is located east of an area of disabilities Dersingham previous mineral workings which now form part of Older a bird reserve, and south of Snettisham Common people which contains a previous silica sand pit extracted for glass manufacture. The nearest residential property is approximately 250 metres from the AoS boundary. The settlements of Snettisham, Ingoldisthorpe, Dersingham and Shepherd’s Port are all 250 metres from the boundary of the AoS. The southern extent of the area of search is approximately 20km from the Leziate processing plant and it is likely that any extraction site would transfer mineral to the processing plant by road. East Winch, AOS D The size of the AoS is 109 hectares. People Pentney The AoS is an area of agricultural use with with commercial plantation and other woodland. The disabilities AoS is adjacent to areas of previous and current Older mineral workings and close to a sand and gravel people allocation. One of the previous workings has been restored to a holiday park use. The nearest residential property is approximately 250 metres from the AoS boundary. The area of search is approximately 9km from the Leziate processing plant. It is likely that any extraction site would transfer mineral to the processing plant by road, although there is the potential that other transportation options such as a conveyor, or

Site/area of Reference Key characteristics Groups search location potentially (Parish) affected pipeline may be considered. Wormegay, AOS E The size of the AoS is 816 hectares. People Shouldham, The AoS is an area of agricultural use with with Marham, commercial plantation and other woodland. The disabilities Shouldham area of search is adjacent to areas of previous and Older Thorpe current mineral workings and close to a sand and people gravel allocation. The nearest residential property is approximately 250 metres from the AoS boundary. The settlements of Shouldham and Wormegay are 250 metres from the boundary of the AoS. The area of search is approximately 15km from the Leziate processing plant and it is likely that any extraction site would transfer mineral to the processing plant by road. Runcton AOS F The size of the AoS is 61 hectares. People Holme, Stow The AoS is a mixture of forestry and agricultural with Bardolph uses. The nearest residential property is disabilities approximately 250 metres from the AoS boundary. Older The settlement of Stow Bardolph is 250 metres people from the AoS boundary and South Runcton is less than 400 metres from the AoS boundary. The area of search is approximately 17km from the Leziate processing plant and it is likely that any extraction site would transfer mineral to the processing plant by road. The area of search is located on the A10. Shouldham AOS I The size of the AoS is 47 hectares. People Thorpe, The area of search is a mixture of small blocks of with Runcton woodland and agricultural uses between the A10 disabilities Holme, and A134. The nearest residential property is Older Tottenhill approximately 250 metres from the AoS boundary. people The area of search is approximately 16km from the Leziate processing plant and it is likely that any extraction site would transfer mineral to the processing plant by road. Tottenhill, AOS J The size of the AoS is 23 hectares. People Wormegay The area of search is a mixture of small blocks of with woodland and agricultural uses between the A10 disabilities and A134. The nearest residential property is Older approximately 250 metres from the AOS boundary people and the settlement of Tottenhill is less than 300 metres from the boundary of the AoS. The area of search is approximately 15km from the Leziate processing plant and it is likely that any extraction site would transfer mineral to the processing plant by road.

The areas of search and specific site are all for future silica sand extraction. Due to the methodology used to define the areas of search, all the allocated areas of search are located at least 250 metres from the nearest residential property. The specific site is also located more than 250 metres from the nearest residential property. Due to the rural locations of the site and areas of search within West Norfolk, the equality groups that could potentially be

affected are people with disabilities and older people. Due to the similarities in the land use and locations of the specific site and all areas of search, the impacts to equality groups are also found to be similar for the specific site and all areas of search. There is limited opportunity for public transport, however due to the nature of silica sand extraction operations; it is very unlikely that access by the general public is required. There would therefore be no differential impact to equality groups. As the site and areas of search are at a distance from residential dwellings where minimal mitigation measures would be effective, health and amenity impacts (caused by noise and dust) are limited and therefore unlikely to affect any equality group differentially. Visual impact is limited and therefore is unlikely to impact any equality group differentially. There may be increased emissions to air caused by associated transport to and from the areas of search but this will not cause a differential impact to any equality group given the widespread nature of emissions.

Stage 5 (ii) Relevance to Equality Groups Cumulative impacts caused by the sites and areas of search Health and amenity impacts such as noise, dust and visual impact are site specific, and therefore these impacts have already been considered for each site and area of search in the previous section.

In parishes where more than one area of search is located there could be a greater cumulative impact if silica sand extraction takes place in more than one area of search; however there would not be any additional impacts to those which have already been raised in table 8. Air emissions caused by the HGV traffic could have a cumulative impact upon the more vulnerable members of society, if multiple extraction locations were in close proximity. However given the relatively small extraction area required and the comparatively large size of the Areas of Search there would be significant opportunities for extraction areas to be appropriately spaced apart.

The parishes containing the areas of search and the specific site have a higher proportion of older residents than the Norfolk average, and higher than average levels of health deprivation. However, the accessible silica sand resource occurs mainly in rural areas which also generally have a higher proportion of older residents that the Norfolk average and higher than average levels of health deprivation. Mitigation measures required by the Core Strategy, the Specific Site and Areas of Search policies in the Silica Sand Review for any future planning applications for silica sand extraction, will mean there is little differential impact upon these groups. Is the Silica Sand Review discriminating unlawfully, such as denying anyone their human rights? The Human Rights Act 1998 contains a list of Articles. Each Article sets out a right which is protected, for example, Article 8 – the right to respect for private and family life, which includes businesses. Most Articles then set out an exception to that protection, usually in the interests of public safety or the prevention of crime or other public interest issues.

The Articles most likely to apply in relation to silica sand extraction are Article 8 and Article 1 of the First Protocol (FP). This Article protects the peaceful enjoyment of

possessions. Largely, it may be expected to be invoked where compulsory acquisitions without compensation are in play. Adverse impacts on property values, for example, because of the proximity of a mineral extraction site, have been found not to be an interference under either Article 8 or Article 1 of the FP. Does the Silica Sand Review adequately promote the principles of equality and community cohesion? Equality groups could have improved employment opportunities by virtue of accessibility to silica sand extraction sites. However, these developments are geographically spread and the accessibility of employment opportunities will depend upon the location of the development. Silica sand extraction does not create significant employment, and so the focus of the rest of this EqIA is on the adverse impacts as captured in Table 8, rather than the more marginal issue of employment.

Stage 6: Mitigation of adverse impacts Stage 5 identified that the specific site and areas of search could have some impact, albeit low, upon some equality groups. The only issues identified were possible health and amenity impacts to more vulnerable groups i.e. older people or disabled people. The most likely impacts are noise and dust which have been identified for the Areas of Search and Specific Site allocation and will be assessed at the planning application stage, when suitable mitigation will be identified.

The Area of Search and Specific Site allocation policies include requirements to address potential impacts, including to equality groups. • A programme of mitigation measures (e.g. standoff areas, screening and/or bunding) to deal appropriately with any potential amenity impacts, including noise and dust, to comply with the requirements of policy DM12; • A Transport Assessment or Statement which considers the potential for transport impacts and identifies appropriate mitigation measures, including highway improvements where appropriate, to address these impacts. • An air quality assessment of the potential for any emissions, including dust, will be required, together with suitable mitigation measures to address these potential impacts on humans, flora and fauna. The Air Quality Assessment will need to be compliant with Policy DM13

As well as the policies in the Silica Sand Review, the following Core Strategy policies aim to mitigate adverse impacts from mineral extraction and associated development: CS14 – Environmental protection This policy states that developments must ensure that there are no unacceptable adverse impacts on, and ideally improvements to natural resources, including water, air and soil, the character and quality of the landscape and townscape, historical and cultural assets and residential amenity. DM15 – Amenity This policy states that ‘development will be permitted only where is can be demonstrated that the scale, siting and design of a proposal is appropriate and that unacceptable impact to local amenity will not arise from the construction and/or operation of the facility’.

DM15 – Cumulative impact This policy requires the potential cumulative impacts, from a number of mineral extraction and/or waste management facilities in close proximity, to be assessed and any adverse cumulative impacts to be adequately mitigated. CS15 – Transport This policy states that proposals will be satisfactory, in terms of access, where anticipated vehicular movements do not contribute to unacceptable risks to the safety of road users and unacceptable impact on air quality and residential and rural amenity. DM10 – Transport This policy requires applications for planning permission to be accompanied by a Transport Statement that demonstrates consideration of other road users (including pedestrians, cyclists and horse riders). DM13 – Air quality This policy states that planning applications must demonstrate that proposals effectively minimise harmful emissions to air and would not impact negatively on existing Air Quality Management Areas, nor lead to the declaration of a new AQMA.

Conclusion These policies should mitigate the potential adverse impacts on health and amenity. Provided these policies are applied robustly, it is highly unlikely that equality groups will be disproportionately discriminated against by virtue of the location of the silica sand extraction sites and areas of search. 6.1 Improvement planning and recommendations It is concluded that given the mitigation of impacts stated in stage 6, and the low level of relevance to equality groups, there are no outstanding equality issues.

Glossary Lower super-output areas This is one of two layers of Super Output Areas (see below). The lower layer consists of a minimum population of 1000 and mean population of 1500. Lower super output areas consist of a number of Output Areas.

Super Output Areas A Super output Area (SOA) is a geographical area used for statistical analysis (such as information gathered through the 2011 census). They are based on population sizes to enable comparisons of statistics from similar sized populations. There are two layers of Super Output Areas (lower layer and middle layer)

Sustainability Appraisal An evaluation process for assessing the environmental, social, economic and other sustainability effects of plans and programmes. This is a statutory requirement.

Air Quality Management Areas Under the Environment Act 1995 Local Authorities must review and assess the air quality in their area against National Air Quality Standards. In areas where UK air quality objectives will not be met, an Air Quality Management Area must be declared. For this area, a Local Air Quality Action Plan must be produced to show how concentrations of certain pollutants can be reduced.

Appendix Equality Legislation The Equality Act 2010 provides nine protected characteristics which cannot be used as a reason to treat people unfairly. These characteristics are: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, sexual orientation.

Most provisions of the Act came into force on 1 October 2010 including the basic framework of protection against direct and indirect discrimination, harassment and victimisation in services and public functions; premises; work; education; associations, and transport.

The public sector Equality Duty commenced in April 2011, which required public bodies to consider all individuals in shaping policy, delivering services and in relation to their own employees. It requires public bodies to have regard to the need to eliminate discrimination, advance equality of opportunity, and foster good relations between different people.