Object

Representation ID: 90

Received: 11/10/2019

Respondent: Nottinghamshire Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Yes

NWT recognise the need to allocate sufficient land for future mineral needs, subject to accurate data and a regular review of actual sales and needs against predictions. NWT object strongly, however, to the allocation of a new site at Mill Hill nr Barton in Fabis. We believe that this allocation renders this area of the Plan unsound because it is fundamentally flawed, for the following reasons:

The proposed allocation would destroy all or part of 5 LWS, would indirectly damage a further 4 LWS which are in very close proximity and cause indirect damaging effects on 2 adjacent SSSI , a designated Ancient Woodland and a large area of BAP/Sn 41 priority habitat. This site is also known to host a significant number of protected species whose populations would be reduced or lost as a result of the scheme, as would several BAP/Sn 41 species. Allocating a site of such high existing biodiversity is therefore not compliant with Policies SO1 and SP5 and so is unsound. It is possible that such an allocation also breaches the MPA’s Biodiversity Duty under the NERC Act and so may not be legally compliant.

This proposed site scored worse in the SA (-13 and -3) than nearly all other sites that were assessed, and has been allocated whilst other sites that did not score as badly have not. This fundamentally undermines the aims of SA as an independent tool for choosing between sites, and so also undermines the soundness of this Plan, particularly the stated intent to achieve sustainable development. The descriptive text for the environmental impacts predicted for this proposed site in the SA is clear in stating that there would both short and long term negative impacts on biodiversity and landscape (as well as other factors outside the remit of NWT) . Indeed it makes clear that there would be a net loss of biodiversity if this site were to proceed.

It is also notable that in the Assessment of Multiple Environmental Sensitivities report, this proposed allocation has been assessed as being red – ie. a scheme would adversely impact several environmental assets.

The text is also inaccurate in stating that the quarry is predicted to start in 2019, this is not the case, as the applicant (having submitted a presumptive application in the absence of an allocation) has so far failed to produce adequate information to inform a proper determination by the MPA.