Mineral Local Plan Draft Consultation.

INTRODUCTION

In regard to the Issues and Options Consultation, we submitted our views into how sites are chosen due to the unfavourable site choices that had been submitted in the previous MLP.

However, the same sites choices which were in the previous MLP have been re-submitted again in the new MLP Draft Consultation,with the exception of Barnby Moor.

Although Barnby Moor has now been removed from the MLP Draft Consultation, a planning application regarding this site was submitted to the planning department and is still pending, to allow the mineral operators time to come to an agreement on how to work this site.

As Botany Bay and Barnby Moor are under consideration by different departments, if approved, this will result in having two new greenfield sites in the same village, contrary to the preference shown in the Issues and Options Consultation, of choosing extensions to permitted quarries rather than creating new greenfield sites.


In regard to the previous MLP Consultation, a stipulation was made by the Independent Inspector stating no more sites should be chosen from the idle valley.

This stipulation occurred when the Independent Inspector in the 2005 Mineral Local Plan gave approval to permit a quarry to be allocated at Sturton Le Steeple. The decision made by the Independent Inspector stipulated however, that no further sites would be required in the idle valley until the reserves in this site was worked out.

When the site at Sturton Le Steeple was allocated into the MLP, however an objection was made to why Botany Bay had not been allocated, however the inspector reply was, as there were sufficient reserves in the Sturton Le Steeple quarry that no further sites from the idle valley were needed until this quarry had been worked out to prevent an over provision from the area.

The Sturton Le Steeple quarry obtained planning approval in 2008, however in 2011 the mineral operator made a request to the NCC to shelve this quarry stating that the lack of demand for sand and gravel was the reason for their decision and that commercially they would proceed with the application in its entirety when the situation changed.

However, this was contrary to the findings in the LAA report which stated at the time of this request, that sand and gravel was showing an increase in demand, not a decrease, however the request was still approved by the NCC to delay working this quarry.

This was also duplicity on the part of the mineral operator, as at the call for site stage, the mineral operator, submitted the largest number of sites throughout the County into the MLP, including the idle valley, which went against the stipulation that no further sites should be submitted.


This mineral operator has now decided to mothball the Sturton Le Steeple quarry, however he also owns the mineral rights of Girton quarry and has also mothballed this quarry. This quarry's planning permission is up to 2036.


In mothballing sites, it allows the operators to submit more sites into the MLP, however in the previous Mineral Local Plan, it was not considered sound, as it exceeded the permitted reserves, as too many sites were being submitted by the mineral industry without sufficient justification, as there was not a need. However the more sites the mineral operator acquires, the more assets they have.


When mineral operators are allowed to stockpile quarries by mothballing or restricting output, the owness is then put on the less favourable sites, which are then chosen to make up the shortfall. This was cited in the LAA which states the decision to delay working the Sturton Le Steeple quarry was the reason for the shortfall.

In the Consultation Process, the rules are that all parties should accept without objection, the final decision of the Independent Inspector. However that did not happen, due to the mineral operator mothballing the Sturton Le Steeple quarry, he has now submitted his preferred choice of Botany Bay into the Mineral Local Plan Draft Consultation, against the Inspector's stipulation, so in essence it is the mineral operator who has made the final decision.

As the NCC ignored this stipulation, by allowing further sites from the idle valley into the MLP, then we believe justification needs to be demonstrated to why this was allowed.

However this request for information was declined, requesting us to submit our comments into the MLP Draft Consultation.

On these grounds we would like to challenge the decision in allocating further sites into the idle valley for the reasons we have stated. I believe we will be given the opportunity to address this matter to the Secretary of State in the next Consultation Process.

Have Your Say

The MLP Draft Consultation is a complex document which has taken 7 months to complete, and was submitted for us to view on 26th June 2018. However, I do not find this document user friendly, as the individual questions posed, covered policies too diverse to be able to respond with a single reply.

In Question 1, our comments was invited on the strategic objectives and the draft vision, as these objectives covered a range of issues in total, there were nine objectives, then equally it would require 9 responses, and this was just in Question 1.

This approach was applied to every question in the MLP, the reading matter also prior to the question was far too extensive, which added more information and different approaches and elements to the policy, that when you reached the question, it required reading the information again as there were too many issues to respond to.

Due to the reasons above, I believe the presentation of the MLP Draft Consultation does not lend itself in encouraging participation into the consultation process, it actually discourages it.

As these policies are very important, I would prefer to address them in context to the site allocations and to whether they are being applied, to safeguard our communities from adverse effects.

DM8 Cumulative Impact

In regard to the new site allocations selected in the MLP Draft Consultation, there are eight new sand and gravel allocations submitted, and five of those have been chosen from the idle valley. (This includes the sherwood sandstone allocation into the MLP)

However, as the mineral operator has also submitted to the Planning Department a proposal to quarry at Barnby moor, then as this is a foreseeable development and will add to the cumulative impact, then this should have been taken into account when further sites were submitted.

The number of sites under consideration in the idle valley, are six in total, and to which five of these sites, are located on the A638 within a 4mile radius.

As Barnby Moor is under consideration, I have included it in the calculations.

These relate to 2 new greenfield sites, PA01/MP2r one submitted into the MLP Draft Consultation and one submitted into the Planning Department and 4 extensions MP21/ MP2n/ MP2m/ MP3g/

Also in a 2 mile radius off the A638, a permitted development of shale gas extraction at Tinker lane, Torworth where drilling is expected to start October 2018. The proposed quarry at Barnby Moor and nearby residents are in the air quality sensitive receptor zone.

The situation in the idle valley is that we have been given unjustly the lions share of the sites allocations submitted into the Mineral Draft Consultation.

Cumulative Policy

5.95 'as the plan is to ensure that impacts of a mineral proposal are considered in conjunction with the impacts of other past, present or foreseeable developments, in that the cumulative impact on the environment of an area, or on the amenity of a local community are fully addressed'.

The cumulative Impact occurs when over development is allowed to intrude, into the local amenity of those who live and work in those communities.

DM1 Protecting Local Amenity

The actions of protecting local amenity, is not by designating multiple quarries and shale extraction in one location. I would not consider that to be line with the preferred option, of geographical spreading the sites throughout the County, not compacting them all in a four mile radius.

This decision of choosing them all in one location, will have a negative impact on our health and wellbeing and also is contrary to the climate change policy by increasing emissions of carbon monoxide and nitrate oxide into communities where people are living and bringing up their families.

This disregard for human health by allowing mineral operators to site their quarries so close to the community, as created a situation where residents who have previously been happy to live in the area have decided that it is not fair or healthy for their children to be living so close to a site that will omit on a daily basis, dust, noise, fumes from the plant machinery, dangerous gases from the heavy goods vehicles in and out all day.

I believe those that are affected think enough is enough, and If the County Council is failing us, then the decision falls onto to those living in the community to take the decision to leave, and unfortunately that is what is happening.

DM6 Historic Environment
Scrooby MP3g

5.70. National Policy states the most important heritage assets should be conserved and that balancing the need for development against potential harm to heritage assets needs to be fully justified. The Council has a duty to protect, conserve and enhance the significance and appearance of the area's historic environment when carrying out its statutory functions and through the planning system.

As the majority of these sites are located in Scrooby, I was surprised that another extension for Scrooby is to be allocated in 2023.

This site MP3g which is only 1.3km from Scrooby village has 4,831,000m/t of sherwood sandstone, which will be worked over a period of 40 years. This just adds to the burden of increasing pollution into the area, defacing its landscape and affecting biodiversity.

In the assessment of this site, it would have a negative impact on the historic assets as the quarrying operation is 1.3km from Scrooby village and its setting. it also stated that during the operational period there could be a negative effect on the quality of life,

As the National Policy states that the most important assets will be conserved, and the Council states it has a duty to protect, conserve and enhance the appearance of the area's historic environment. As Scrooby is the birth place of William Brewster, one of founders of the Pilgrim Fathers then why is it not being protected.

Sustainable Development
SP1 (NPPF) 'presumption of favour '

This is a policy that is put in place that allows a decision not to be made on evidence or justification, it can be made on presumption of favour, which basically stating it is predetermined in its favour. The meaning of presumption in the dictionary is, a behaviour perceived as arrogant, disrespectful, and transgressing the limits of what is permitted appropriate.

This policy is not appropriate, especially in public office, where you have to show transparency. The mineral industry is a lucrative business, so making decisions in presumption of favour is not appropriate.

If this policy was applied in a Court room and you was told that the judgment was to presume in favour of the Court, you would know instantly that would be an unjust decision, and equally it still applicable in the Consultation Process, when life changing decisions are being made, to adversely change the tranquility of where you live, the air that you breath, your outlook on the landscape and the peacefulness of the countryside. If the policy is presuming in its own favour, then it is predetermining the decision.

This policy uses the term, golden thread in the presumption of favour, however I would say its the golden egg, which benefits the County Council and the mineral industry.

Site Allocations

In the idle valley, we have been subjected to major quarry developments in close proximity of each other, 5 quarries, and a shale gas extraction site, all in a four mile radius.

In view that Barnby Moor is a foreseeable development, then there are six quarries.

This development will change our rural communities from fields of wheat and corn, to noisy dusty sites with increased transport, poor air quality, with an increase in fumes, loss of landscape and character, and will change these pretty hamlets with open fields to become large dust bowls.

This area was rightly assessed as being the worse sites submitted in the County because of the detrimental impact these developments will have on the area if these are approved.

Conclusion

In view that an Independent Inspector had chosen the appropriate site from the idle valley, but his decision was not executed, then we would like to challenge the allocations from the idle valley which have been substituted for this site not being implemented.