Object

Representation ID: 301

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

The Nottinghamshire Minerals Local Plan Publication Version (MLPPV) does not meet the criteria for ‘justification’ as set out in para 35 of the National Planning Policy Framework, because in relation to the site at Mill Hill, Barton in Fabis, it does not apply an appropriate site selection strategy that takes account the reasonable alternatives. The justification for the selection of the site at Barton and the omission of other sites considered at the draft stage (e.g. Shelford) is not based on a proportionate and consistent evaluation of the available evidence Contrary to the objectives of the NPPF as a whole, the allocation of Mill Hill does not constitute sustainable development. Specifically:
a) Unsoundness of site selection methodology: The methodology in site selection is unsound and unjustified because it is not aligned with the results of the public consultation at the Issues and Options stage.
b) Application of site selection methodology: The application of the existing site selection methodology is unsound because of the weight given to geographical spread. The plan lacks justification because there is a significant absence of evidence to support the application of geographical spread. We show that contrary to the position of the County Council, the allocation of Shelford would not affect the geographical spread of sites and not selecting Shelford misses a highly significant opportunity to embrace sustainable transport principles.
c) Site Assessment for Mill Hill, Barton in Fabis: The site at Mill Hill, Barton in Fabis, has the greatest score for negative impacts of all the sites selected for allocation in the Plan. Page 61 of the Site Selection Methodology and Assessment (SSMA) May 2019 states “In assessment against sustainability appraisal objectives, the site scores very negatively during the operational phase (our emphasis) and slightly negatively in the long term.” We consider, however, that the site should score more negatively than is conveyed in the Sustainability Appraisal: there are highly negative impacts in relation to heritage, ecology, landscape, flood risk, air quality and impact on human health and quality of life. The allocation of Mill Hill Barton in Fabis has significantly greater adverse effects than Shelford, which we consider should be allocated instead. The selection of Mill Hill, Barton in Fabis is therefore unjustified.
It should be noted also that as a result of a planning application for gravel extraction for part of the proposed site at Barton in Fabis a number of other adverse issues can be identified that makes the allocation the Minerals Plan unjustified. The planning application at Barton on Fabis (reference ES/3712) is for a site larger than the proposed allocation and includes land within Nottingham City. The Parish Council has objected to this application and has followed its progress closely. We recognise that the application will need to be determined on its own merits but it is clear from correspondence from the County Council that there is clear fundamental harm derived from the application proposals and we append the County Council’s letter to the Applicant dated 30 August 2019 (Our Appendix 4) .
In regard to Heritage, the County Council state:
“Following consultation, officers disagree with a number of the conclusions of the assessment and are of the view the development would result in the following impacts:
- There would be substantial harm to the setting of Clifton Hall (Grade I listed) and its Registered Park and Garden (grade II listed) during extraction;
- There would be less than substantial harm to Clifton Hall and its Registered Park and Garden following restoration.”
Substantial harm to a Grade I listed building should be wholly exceptional and to a Registered Park and Garden, exceptional, as defined by paragraph 194 of the NPPF. It is highly pertinent to note that the officers of the County Council do not consider this harm would be likely to be reduced through amendments. While they advise that substantial public benefits could be forthcoming “through the improvements to the understanding of Clifton Hall Registered Park and Garden and the preparation and implementation of a Conservation Management Plan to improve the condition and management of the heritage asset”. We do not consider that this would be either feasible or sufficient to mitigate the harm created to Clifton Hall and the Registered Park and Gardens and alone is sufficient justification to de-select the site as a proposed allocation.
Further supporting detail is contained in the full representation.