Object

Representation ID: 261

Received: 11/10/2019

Respondent: Tarmac

Agent: Heaton Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

It is considered that Policy SP7 is not positively prepared, an effective strategy or consistent
with the NPPF and is therefore unsound. Policy SP7 should refer to ‘known’ locations of
specific mineral resource as opposed to ‘economically important’ in accordance with
paragraph 204 of the NPPF. This would recognise that mineral resource is a finite resource.
Extraction of resource may not be economically viable at one stage but may become so as
reserves deplete.
It is considered that the Minerals Plan would be more effective if it was to define more
specific Mineral Consultation Areas. The proposed approach to define consultation areas on the same scale as safeguarding areas could mean that large amounts of development will be
caught within an MSA/MCA which would be onerous on developers having to potentially
submit minerals assessments and the MPA in assessing the potential for impact of
development on mineral resource/mineral associated infrastructure.
As well as safeguarding mineral associated infrastructure, rail heads should be expanded to
include rail heads at coal fired power stations. A wharf facility at Colwick is specifically
referenced for safeguarding. Tarmac has existing river wharf facilities at Besthorpe Quarry
(loading) and Cromwell Quarry (receiving) which are referenced on the Policies Maps and
Tarmac supports this.
The importance of Local Plans (District and Borough Council) in understanding and
appreciating the role of safeguarding and defining areas/sites within Local Development Plan
Documents should be explained within the Mineral Plan. The planning system is a tiered
system with the policies contained within the Mineral Plan and Local Plan pertinent to the
consideration of Planning Applications at County and District level. The MPA has an
important role in ensuring mineral safeguarding is not perceived as just a County function
but guiding and supporting Local Authorities to appreciate they also have a role to play in
accordance with the Planning Practice Guidance.
In light of the above and the identification of safeguarding areas on the policies maps Plan 4
should not be required.
Paragraph 3.90 is contrary to the NPPF paragraph 204 (e) and should be deleted. Policies
should safeguard all ancillary infrastructure and the NPPF does not distinguish that only
strategic facilities should be safeguarded. Whilst it may be unnecessary to identify all
facilities on policies maps, the policy wording itself ensures that these facilities will be
safeguarded.
Policies regarding safeguarding should make reference to the ‘agent of change’ identified at
paragraph 182 of the NPPF. This seeks to ensure that the onus is on Applicants for new
development to put in place adequate mitigation to ensure that the development would not place unreasonable restrictions on existing businesses/operations.