Object

Representation ID: 92

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 MP3d Bestwood 2 North. We believe that this allocation renders this area of the Plan unsound because it is fundamentally flawed, for the following reasons:

The proposed allocation is entirely located within a LWS which would be destroyed as a result of extraction. The proposed site also lies with the ppSPA buffer zone and between two parts of the Sherwood Forest Important Bird Area, upon which any future Special Protection Area (SPA) designation may be based. Allocating a designated LWS is 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 poorly in the SA (-9 and -2) compared to several other sites that were assessed, and has been allocated whilst other sites that did not score as badly have not (eg. Coddington at -7, -2). 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 be short term “very negative” impacts on biodiversity and also on landscape when considered with Greenbelt impacts (as well as other factors outside the remit of NWT) . Indeed there could be a net loss of biodiversity if this site were to proceed, as it is unlikely that new habitats created through restoration would be of a higher biodiversity value than those that currently exist, and there would be further indirect impacts on the habitats and species of the remainder of the LWS as a result of extraction operations.