Object

Representation ID: 296

Received: 11/10/2019

Respondent: Barton PC, Thrumpton PM, Lark Hill RA, Clifton Village RA, SAVE

Number of people: 5

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 1: Improving the sustainability of minerals development
This strategic objective is unsound because it is poorly drafted and is therefore ineffective (para 35 NPPF). It includes the aim of “more efficient exploitation” without specifying what the comparator is. More than what? Is it more compared to the operation of the last plan? If so, how is efficiency judged? Is it more than the current national average? Again, if so, what is the base-line measure?
A further aspect of the unsoundness is that the objective to “Secure a spatial pattern of mineral development that efficiently delivers resources to markets within and outside Nottinghamshire” is too narrowly drawn. The objective relates to “Improving the sustainability of minerals development” which includes but does not solely relate to market delivery. The objective is therefore not effective in delivering sustainable minerals development.
The Vision for the Minerals Local Plan Publication Version (MLPPV) states that “mineral development will be concentrated in locations that offer the greatest level of accessibility to the major markets and growth areas and to sustainable transport nodes to encourage sustainable patterns and modes of movement.” However, the complete absence of numerical or other analysis in the MLPPV or indeed the County Council’s Local Aggregate Assessments in recent years of: a) what are the major markets and growth areas; and b) the failure to specify sites which utilise the most sustainable modes of movement such as barging means that the MLPPV is fundamentally flawed. The Vision fails the ‘justified’ test of Paragraph 35 of the NPPF in that it is not based on proportionate evidence and accordingly is unsound.