Q.1.
No comment
Q.2.
No comment
Q.3.
No comment
Q.4.
Using the 10-year average is not considered the most suitable approach. The 10-year approach is
based on the PRODUCTION of aggregates which is different to the DEMAND for aggregates.
Therefore to maintain an adequate and steady supply the levels of DEMAND should take into
consideration other factors which include the increased pressure for house building as a good
example. The Plan acknowledges that sales at national and East Midlands level have steadily
increased (possibly / probably partly due to the reduced availability / PRODUCTION from
Nottinghamshire) and there is no evidence in the Plan to demonstrate that this level of growth
should not and does not apply to Nottinghamshire. In short, the use of the 10-year average
assumes that the economic downturn continues to apply to Nottinghamshire, which is contrary to
the evidence of the East Midlands Region.
This is other relevant local information which the NPPF says must be taken into consideration.
Q.5.
See answer to Q.4. which applies to all types of construction aggregates.
Q.6.
NPPF does not favour extensions over greenfield sites but does recognise there can be benefits
through making use of the existing infrastructure. Each site should be assessed on its own
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Issues & Options Consultation
D.K. Symes Associates 2
individual merits so, in short, there should be no preference given to extensions. (It is also
relevant to note that if preference is given to extensions, this could lead to stifling competition).
Q.7.
No comment
Q.8.
The commentary supports the comments at Q.4. that production has fallen due to reserves running
out rather than demand for aggregates reducing. A geographical spread is supported as it will
reduce lorry road miles in the delivery of aggregates.
Q.9.
If an 'area of search' approach is supported then this would prioritise areas. However, as the
industry is expected to bring forward sites for consideration, it may be better not to prioritise areas
as this could reduce the flexibility.
Q.10.
Moving aggregates by barge is clearly very sustainable and supported by National Policy and
should be strongly supported. However, the 'PRODUCTION' will most likely be delivered to a
distant market as short distance movement by barge is not economic. Therefore the
PRODUCTION will not contribute to meeting the local demand and this needs to be recognised in
the annual apportionment assessment.
Potential deposits that can use river transport should be given priority and be considered outside
the annual apportionment figure. Ideally, for such sites there should be no requirement to
demonstrate need.
Q.11.
No comment
Q.12.
The comment that as there have been no sales (whereas it should say no production) the landbank
is rapidly increasing demonstrates the point made at Q.4. that PRODUCTION does not reflect
demand. As a large proportion of the demand for aggregates can be met by sand and gravel
(gravel) OR crushed rock, the opportunity to increase crushed rock production should be
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Issues & Options Consultation
D.K. Symes Associates 3
encouraged as the yields per hectare are noticeably greater than sand and gravel, and it would
provide a greater choice to the market.
Q.13.
No comment
Q.14.
No comment
Q.15 - 24.
No comment
Q.25.
It is suggested that 'Health' may need to be covered.
Q.26.
No comment