Object

Representation ID: 238

Received: 11/10/2019

Respondent: Historic England (East Midlands)

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Historic England (formerly English Heritage) has maintained concerns about the dolomite allocation at Holbeck since 2012 and throughout this emerging Plan process. It is noted that Policy MP9 relates to industrial dolomite extraction generally. Historic England submits that this approach is not sound since known sources of dolomite within the UK are limited and in respect of the draft Nottinghamshire Minerals Local Plan the main extraction location is found in the Holbeck area and this is set out in the paragraphs accompanying MP9. As such Policy MP9 in its current form would provide a de facto site allocation. In addition, Policy MP9 sets out that extraction would be supported if need is demonstrated which ignores environmental and other social and economic factors which would have to be considered in the balance. Paragraph 4.84 sets out that a criteria based policy is being proposed but this consists of one criteria – ‘where a need can be demonstrated’.

These issues are explored in more detail within the attachment and full submission.