Setting the overall context for the plan

We have been invited to participate in the Mineral Local Plan in regard to the previous MLP being withdrawn in May 2017. The new draft vision of the Issues and Options Consultation is based primary around the economic and environmental need in general for aggregates, however the attention given to the social aspects, is directed primary on the benefits gained from the use of aggregates rather than giving some thought to the detriment this creates by the mining of these aggregates, and how these detrimental impacts can directly affect the communities where sites are proposed.

To balance this we hope our input into this area will resonance into to a change of policy into how sites are assessed for their suitability and in validating our viewpoint we have given examples of how the present policy has affected those communities.

Q1 Do you think any further information should be included in the overview of the area?

Answer: I have nothing to add to this question

Q2 Do you agree with the draft vision? Are there other things we should include?
Q3 Are the above strategic issues appropriate? Are there others we should consider?

In regard to the above questions we would like the draft vision to review its policy on site selection and its responsibilities to safeguarding our communities from poor site choices causing detrimental impact.

As we have gone through all the stages of the consultation process in the previous MLP, we are in an enviable position recognising that the need for minerals should be balanced fairly. It is important that no community feels it is forced to have an unfavourable site allocated to them just to meet this need and in this context we would like to see a more pro-active policy to ensure that unsuitable sites submitted by the mineral operator/ owners will not automatically be considered for selection.

We believe this process should start at the 'call for site' stage, in as those submitting sites should have to meet a criteria to prevent unsuitable sites being allocated, we feel this would eliminate problems further along in the consultation process. I believe at the moment there appears to be no restrictions to where a site can be placed, and the call for sites has no guidelines at all. The responsibility is then left to the mineral operators to make crucial amendments, (due to a conflict of interest) inevitably some people will be considered less important than others and those who are not protected by guidelines will still be the ones expected to adversely take the brunt of it.

As an example of this, the site at Barnby Moor (SA score -15) was submitted for selection without initially any constraints at all, sited on a large area of agricultural land between two sections of the community, the proposed site butted up to a small modern development of new homes, which then continued down the A638 totally engulfing two bungalows on all three sides and open countryside (designated to be Grade 3 best and versatile agriculture soil) it then continued to the boundary of our property (if approved it will not only take away our open aspect and our long distance views, but also affect the quality of air we breathe, and eventually take away our peace and quiet).

In regard to the decision made by the mineral operators to protect the residents from these undesirable affects, the decision was made to alleviate the distress of those living in the new homes on this modern development, whilst the decision to those elderly residents in the bungalows and ourselves was that the quarry would still border our properties and we would still be subjected to the noise, pollution and dust which is inevitable due to the nature of the industry.

Due to amendments made by the mineral operators, they were then entitled to acquire more land next to our neighbour on the north side sprawling northwards up to the new business venture, 'Torworth Grange' which as a farm shop, a lovely restaurant, fishing lakes and is leisure based, at the moment it is a quiet place to relax!

The need for minerals cannot justify allocating quarries into the heart of communities, disrupting and destroying the vibrancy of village life, in to one where peace and tranquility is lost, polluting the village from fumes and dust from commercial plant machinery, increasing levels of toxic compounds from the HGV fumes which travel in and out of site, (76 per day to the proposed PA01 site) green fields and open countryside eliminated, destroyed and then shrouded from view.

This is not the vision as quoted by the draft vision that "the quality of life and health of those living, working or visiting Nottinghamshire will be protected". However what it does tell us, unfortunately is that these are just words on paper and the hypocrisy of it all is that communities are not protected, there are no guidelines that prevent the worse sites being allocated into the MLP.

If the site with the worse SA score in the County can be allocated, not as an error, but with intent then clearly we are not protected.

In conclusion we believe it is crucial that the Notts County Council should take the lead in ensuring that no undesirable sites are allowed to be submitted for consideration into the MLP. A criteria should apply when sites are being called for, any site that intrudes into the residential community should be viewed as being undesirable. If those sites submitted demonstrate an undesirable and detrimental SA score, it should not be then submitted into the MLP especially if there is a spurious attempt given to dismiss the detrimental consequences these site will have.

In your draft vision you have invited us to have our say, I hope in the same spirit our input will resonance into policy in safeguarding our communities.

Q (4) (5)
I am not informed enough to comment on these questions.

Q 6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield sites?

If this question relates to an existing permitted quarry not allocated within a residential community or sited in a place of beauty, then I would agree with the draft vision that extending an existing quarry would be the best option, as long as it is supported by a favourable SA score. However if the existing permitted site was sited detrimentally within the community I believe it should not be allowed further extensions. In regard to new greenfield sites, It would be more diligent to site these proposed quarries outside residential communities to achieve a more productive lifespan.

Q7 Should different approaches (new sites/extensions to existing permitted quarries) be adopted for individual minerals types?

There are huge differentials in the problems experienced when adopting different mineral types to existing quarries. These may cause unacceptable impacts if these sites are based close to residential communities, however even sites that are outside the residential community can have a detrimental affect on the area.

Q8. How important is it to maintain a geographical spread of sand and gravel across the county (Idle Valley near Newark and Notts) to minimise distance transported to market?

I feel setting the agenda for sites to be closer to the major markets would hinder the process of finding the most suitable and sustainable sites. In attempting to raise the bar too high to achieve both good sites, transport links and also close to the major markets would not be achievable without compromising integrity by allowing the most undesirable sites to be submitted into the mineral local plan just in a effort to support this policy.

The sites in the Idle Valley have the worse scores in the county yet was allocated into the MLP, purely to support the policy of sites being chosen close to the major markets despite the sites unsuitability. Those sites in the Idle Valley have been affected by this policy as the following example shows:-

On the A638 Great North Road, classified as being in the Idle Valley are the villages of Barnby Moor and Scrooby, there are 4 miles between these two villages, yet each of these villages have been selected for two allocations each, two New Greenfield sites. PA01, PA06 to the north and south of Barnby Moor, and in the village of Scrooby (existing permitted quarries) to the north and south, both have been allocated extensions PA31/PA32, four sites in total. As there is also a working quarry set between these two villages, accumulatively if approved, there will be five quarry sites, within a four miles radius.

These site allocations have demonstrated the worse Sustainability Appraisal scores of all the sites submitted throughout the county, their scores are extremely negative, both of the quarries in Scrooby are -13. The site with the worse score submitted throughout the county is Barnby Moor which is -15. The only other site in the MLP demonstrating this score was withdrawn.

The question is why has this area in the Idle Valley been selected for multiple allocations when the evidence from the SA score clearly demonstrates that these sites will have an a detrimental affect on the community. The reason is that the transport mode objective is encouraging sites to be chosen closer to the major markets, despite the adverse impact they will have on those communities.

The draft vision, on page 14, fifth paragraph confirms this policy as written - "within geological constraints mineral development will be concentrated in locations that offer the greatest level of accessibility to the major markets and growth areas and to sustainable transport nodes to encourage sustainable patterns and modes of movement".

There are 14 objectives in the proposed SA scoping report, the above paragraph stating "mineral development will be concentrated in locations that offer greater accessibility to the major markets" is classified as 3) on the list, however at the bottom of the list at 14) is the objective to "protect human health and quality of life" these two objectives can conflict with each other when human health and quality of life becomes secondary, to choosing sites closer to the major markets.

The reason given to choose sites closer to the major market is for financial gain in transport cost and to a lesser degree reduce pollution, however siting a quarry in the wrong location creates pollution, so it is a very weak argument. The following paragraph demonstrates the consequence of allocating quarries to unsuitable sites.

The sites in question are within a community setting and are all close to residential properties. In siting a quarry close to residential properties the levels of pollution are greater when sited in a concentrated area than when it is fluent on the road. A poor site choice exposes the community to the pollution created just by the industry itself, with diggers, bulldozers, and plant hire continually depositing on a daily basis, pollution, dust, and noise. The increased number of (76) movements per day of HGV lorries will also make the situation worse for the community by the increasing levels of hazardous toxic gases to those communities and residential properties placed unjustly close to the site.

The only day this constant stream of pollution would cease would be on a Sunday, ( just one day where one can appreciate where one lives). That is why these proposed sites in the Idle Valley have the worse SA scores in the County, and predictively by its negative score will have a detrimental impact on their quality of life.

If a site is to be chosen for allocation into the MLP it has to be shown, that the site was not allocated purely because of its location, but due to the consultation process confirming its suitability by the evidence gathered throughout all the different stages of the process. Deciding to allocate a site simply on location, does not require a consultation process, if a decision is made irrespective of the consultation, then it has breached the rules of the consultation process.
.
This trust in the consultation process of it being democratic by having our say can also be tested when we discovered that in the previous MLP that the 'site selection background paper' May 2014 had published its conclusions to why the PA01 site was to be allocated into the MLP even though the consultation process was still ongoing until July 2014.

It is important if we are to participate in the consultation process, that decisions are taken because of the due processes of the consultation process than being made by partiality to a particular policy.


Q9. Would it be more appropriate to prioritise specific areas above others?

In my view of the above question, I would prioritise all areas that are consistent in demonstrating positive SA scores, either from evidence of previous allocations, or in regard to new allocations, I would ensure that in all areas and site allocations landowners/mineral operators would have to meet a criteria in as that a site would not be intrusive to the communities way of life. All sites chosen should be respectful of the community, this should be a priority before taking other considerations into account.

Q. 10 - 26. I am not informed enough to comment on these questions.

Sustainability Appraisal Scoping Report

My only comments regarding this report, is that the primary factor in making decisions should revolve around the SA score, in all the questions posed one can only reply by knowing this information. I believe in question 8, there has been an attempt to diminish the importance of the SA score by supporting preferential policies without incorporating this important tool.

This is our input on the Issues and Options Consultation and our comments regarding the Sustainability Appraisal Scoping Report.

We have been invited to participate in the Mineral Local Plan in regard to the previous MLP being withdrawn in May 2017. The new draft vision of the Issues and Options Consultation is based primary around the economic and environmental need in general for aggregates, however the attention given to the social aspects, is directed primary on the benefits gained from the use of aggregates rather than giving some thought to the detriment this creates by the mining of these aggregates, and how these detrimental impacts can directly affect the communities where sites are proposed.

To balance this we hope our input into this area will resonance into to a change of policy into how sites are assessed for their suitability and in validating our viewpoint we have given examples of how the present policy has affected those communities.

Q1 Do you think any further information should be included in the overview of the area?

Answer: I have nothing to add to this question

Q2 Do you agree with the draft vision? Are there other things we should include?
Q3 Are the above strategic issues appropriate? Are there others we should consider?

In regard to the above questions we would like the draft vision to review its policy on site selection and its responsibilities to safeguarding our communities from poor site choices causing detrimental impact.

As we have gone through all the stages of the consultation process in the previous MLP, we are in an enviable position recognising that the need for minerals should be balanced fairly. It is important that no community feels it is forced to have an unfavourable site allocated to them just to meet this need and in this context we would like to see a more pro-active policy to ensure that unsuitable sites submitted by the mineral operator/ owners will not automatically be considered for selection.

We believe this process should start at the 'call for site' stage, in as those submitting sites should have to meet a criteria to prevent unsuitable sites being allocated, we feel this would eliminate problems further along in the consultation process. I believe at the moment there appears to be no restrictions to where a site can be placed, and the call for sites has no guidelines at all. The responsibility is then left to the mineral operators to make crucial amendments, (due to a conflict of interest) inevitably some people will be considered less important than others and those who are not protected by guidelines will still be the ones expected to adversely take the brunt of it.

As an example of this, the site at Barnby Moor (SA score -15) was submitted for selection without initially any constraints at all, sited on a large area of agricultural land between two sections of the community, the proposed site butted up to a small modern development of new homes, which then continued down the A638 totally engulfing two bungalows on all three sides and open countryside (designated to be Grade 3 best and versatile agriculture soil) it then continued to the boundary of our property (if approved it will not only take away our open aspect and our long distance views, but also affect the quality of air we breathe, and eventually take away our peace and quiet).

In regard to the decision made by the mineral operators to protect the residents from these undesirable affects, the decision was made to alleviate the distress of those living in the new homes on this modern development, whilst the decision to those elderly residents in the bungalows and ourselves was that the quarry would still border our properties and we would still be subjected to the noise, pollution and dust which is inevitable due to the nature of the industry.

Due to amendments made by the mineral operators, they were then entitled to acquire more land next to our neighbour on the north side sprawling northwards up to the new business venture, 'Torworth Grange' which as a farm shop, a lovely restaurant, fishing lakes and is leisure based, at the moment it is a quiet place to relax!

The need for minerals cannot justify allocating quarries into the heart of communities, disrupting and destroying the vibrancy of village life, in to one where peace and tranquility is lost, polluting the village from fumes and dust from commercial plant machinery, increasing levels of toxic compounds from the HGV fumes which travel in and out of site, (76 per day to the proposed PA01 site) green fields and open countryside eliminated, destroyed and then shrouded from view.

This is not the vision as quoted by the draft vision that "the quality of life and health of those living, working or visiting Nottinghamshire will be protected". However what it does tell us, unfortunately is that these are just words on paper and the hypocrisy of it all is that communities are not protected, there are no guidelines that prevent the worse sites being allocated into the MLP.

If the site with the worse SA score in the County can be allocated, not as an error, but with intent then clearly we are not protected.

In conclusion we believe it is crucial that the Notts County Council should take the lead in ensuring that no undesirable sites are allowed to be submitted for consideration into the MLP. A criteria should apply when sites are being called for, any site that intrudes into the residential community should be viewed as being undesirable. If those sites submitted demonstrate an undesirable and detrimental SA score, it should not be then submitted into the MLP especially if there is a spurious attempt given to dismiss the detrimental consequences these site will have.

In your draft vision you have invited us to have our say, I hope in the same spirit our input will resonance into policy in safeguarding our communities.

Q (4) (5)
I am not informed enough to comment on these questions.

Q 6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield sites?

If this question relates to an existing permitted quarry not allocated within a residential community or sited in a place of beauty, then I would agree with the draft vision that extending an existing quarry would be the best option, as long as it is supported by a favourable SA score. However if the existing permitted site was sited detrimentally within the community I believe it should not be allowed further extensions. In regard to new greenfield sites, It would be more diligent to site these proposed quarries outside residential communities to achieve a more productive lifespan.

Q7 Should different approaches (new sites/extensions to existing permitted quarries) be adopted for individual minerals types?

There are huge differentials in the problems experienced when adopting different mineral types to existing quarries. These may cause unacceptable impacts if these sites are based close to residential communities, however even sites that are outside the residential community can have a detrimental affect on the area.

Q8. How important is it to maintain a geographical spread of sand and gravel across the county (Idle Valley near Newark and Notts) to minimise distance transported to market?

I feel setting the agenda for sites to be closer to the major markets would hinder the process of finding the most suitable and sustainable sites. In attempting to raise the bar too high to achieve both good sites, transport links and also close to the major markets would not be achievable without compromising integrity by allowing the most undesirable sites to be submitted into the mineral local plan just in a effort to support this policy.

The sites in the Idle Valley have the worse scores in the county yet was allocated into the MLP, purely to support the policy of sites being chosen close to the major markets despite the sites unsuitability. Those sites in the Idle Valley have been affected by this policy as the following example shows:-

On the A638 Great North Road, classified as being in the Idle Valley are the villages of Barnby Moor and Scrooby, there are 4 miles between these two villages, yet each of these villages have been selected for two allocations each, two New Greenfield sites. PA01, PA06 to the north and south of Barnby Moor, and in the village of Scrooby (existing permitted quarries) to the north and south, both have been allocated extensions PA31/PA32, four sites in total. As there is also a working quarry set between these two villages, accumulatively if approved, there will be five quarry sites, within a four miles radius.

These site allocations have demonstrated the worse Sustainability Appraisal scores of all the sites submitted throughout the county, their scores are extremely negative, both of the quarries in Scrooby are -13. The site with the worse score submitted throughout the county is Barnby Moor which is -15. The only other site in the MLP demonstrating this score was withdrawn.

The question is why has this area in the Idle Valley been selected for multiple allocations when the evidence from the SA score clearly demonstrates that these sites will have an a detrimental affect on the community. The reason is that the transport mode objective is encouraging sites to be chosen closer to the major markets, despite the adverse impact they will have on those communities.

The draft vision, on page 14, fifth paragraph confirms this policy as written - "within geological constraints mineral development will be concentrated in locations that offer the greatest level of accessibility to the major markets and growth areas and to sustainable transport nodes to encourage sustainable patterns and modes of movement".

There are 14 objectives in the proposed SA scoping report, the above paragraph stating "mineral development will be concentrated in locations that offer greater accessibility to the major markets" is classified as 3) on the list, however at the bottom of the list at 14) is the objective to "protect human health and quality of life" these two objectives can conflict with each other when human health and quality of life becomes secondary, to choosing sites closer to the major markets.

The reason given to choose sites closer to the major market is for financial gain in transport cost and to a lesser degree reduce pollution, however siting a quarry in the wrong location creates pollution, so it is a very weak argument. The following paragraph demonstrates the consequence of allocating quarries to unsuitable sites.

The sites in question are within a community setting and are all close to residential properties. In siting a quarry close to residential properties the levels of pollution are greater when sited in a concentrated area than when it is fluent on the road. A poor site choice exposes the community to the pollution created just by the industry itself, with diggers, bulldozers, and plant hire continually depositing on a daily basis, pollution, dust, and noise. The increased number of (76) movements per day of HGV lorries will also make the situation worse for the community by the increasing levels of hazardous toxic gases to those communities and residential properties placed unjustly close to the site.

The only day this constant stream of pollution would cease would be on a Sunday, ( just one day where one can appreciate where one lives). That is why these proposed sites in the Idle Valley have the worse SA scores in the County, and predictively by its negative score will have a detrimental impact on their quality of life.

If a site is to be chosen for allocation into the MLP it has to be shown, that the site was not allocated purely because of its location, but due to the consultation process confirming its suitability by the evidence gathered throughout all the different stages of the process. Deciding to allocate a site simply on location, does not require a consultation process, if a decision is made irrespective of the consultation, then it has breached the rules of the consultation process.
.
This trust in the consultation process of it being democratic by having our say can also be tested when we discovered that in the previous MLP that the 'site selection background paper' May 2014 had published its conclusions to why the PA01 site was to be allocated into the MLP even though the consultation process was still ongoing until July 2014.

It is important if we are to participate in the consultation process, that decisions are taken because of the due processes of the consultation process than being made by partiality to a particular policy.


Q9. Would it be more appropriate to prioritise specific areas above others?

In my view of the above question, I would prioritise all areas that are consistent in demonstrating positive SA scores, either from evidence of previous allocations, or in regard to new allocations, I would ensure that in all areas and site allocations landowners/mineral operators would have to meet a criteria in as that a site would not be intrusive to the communities way of life. All sites chosen should be respectful of the community, this should be a priority before taking other considerations into account.

Q. 10 - 26. I am not informed enough to comment on these questions.

MMO Marine Planning response to The Nottinghamshire Minerals Local Plan Issues & Options consultation

Thank you for giving us the opportunity to comment on the Nottinghamshire Minerals Local Plan. The comments provided within this letter refer to the document entitled The Nottinghamshire Minerals Local Plan Issues & Options Consultation.

As the marine planning authority for England, the MMO is responsible for preparing marine plans for English inshore and offshore waters. At its landward extent the Marine Plan boundaries extend up to the level of the mean high water spring tides mark (which includes the tidal extent of any rivers), there will be an overlap with terrestrial plans which generally extend to the mean low water springs mark.

Marine plans will inform and guide decision makers on development in marine and coastal area. Planning documents for areas with a coastal influence may wish to make reference to the MMO's licensing requirements and any relevant marine plans to ensure the necessary considerations are included. For marine and coastal areas where a Marine Plan is not currently in place, we advise local authorities to refer to the Marine Policy Statement for guidance on any planning activity that includes a section of coastline or tidal river.

All public authorities taking authorisation or enforcement decisions that affect or might affect the UK marine area must do so in accordance with the Marine and Coastal Access Act 2009 and any relevant adopted Marine Plan or the UK Marine Policy Statement (MPS) unless relevant considerations indicate otherwise. Local authorities may also wish to refer to our online guidance and the Planning Advisory Service soundness self-assessment checklist.
I am led to believe that the River Trent, which as stated on page 8 (of the document highlighted above) is situated towards the east of the plan area, has a tidal extent up to Cromwell Lock. I would recommend the East Inshore and East Offshore Marine Plans are a relevant consideration in the Nottinghamshire Minerals Local Plan (East Marine Plan, chapter 1 section 19). Additionally the use of transportation by river barge, as referred to on page 20 (of the document highlighted above), should be considered and the applicable policies could be referenced from the marine plan.
Policy Recommendations
Please see below suggested policies from the East Marine Plan to be considered when developing your policy. These suggested policies included below have been identified based on the activities and categories within the document entitled above. They are provided only as recommendation and we would suggest your own interpretation of the East marine plan is completed:

*CC1: Proposals should demonstrate that they have taken account of how they may:
o Be impacted upon by, and respond to, climate change over their lifetime
o Impact upon any climate change adaptation measures elsewhere during their lifetime
Where detrimental impacts on climate change adaptation measures are identified, evidence should be provided as to how the proposal will reduce such impacts.
*CC2: Proposals for development should minimise emissions of greenhouse gases as far as is appropriate. Mitigation measures will also be encouraged where emissions remain following minimising steps. Consideration should also be given to emissions from other activities or users affected by the proposal.
*EC1: Proposals that provide economic productivity benefits which are additional to Gross Value Added (GVA) currently generated by existing activities should be supported.
*EC2: Proposals that provide additional employment benefits should be supported, particularly where these benefits have the potential to meet employment needs in localities close to the marine plan areas.
*BIO1: Appropriate weight should be attached to biodiversity, reflecting the need to protect biodiversity as a whole, taking account of the best available evidence including habitats and species that are protected or conservation concern in the East Marine Plan and adjacent areas (marine, terrestrial).
*BIO2: Where appropriate, proposals for development should incorporate features that enhance biodiversity and geological interests.
*ECO1: Cumulative impacts affecting the ecosystem of the East Marine Plans and adjacent areas (marine, terrestrial) should be addressed in decision-making and plan implementation.
*ECO2: The risk of release of hazardous substances as a secondary effect due to any increased collision risk should be taken account of in proposals that require an authorisation.
*FISH2: Proposals should demonstrate, in order of preference:
a. that they will not have an adverse impact upon spawning and nursery areas and any associated habitat
b. how, if there are adverse impacts upon the spawning and nursery areas and any associated habitat, they will minimise them
c. how, if the adverse impacts cannot be minimised they will be mitigated
d. the case for proceeding with their proposals if it is not possible to minimise or mitigate the adverse impacts.
* GOV1: Appropriate provision should be made for infrastructure on land which supports activities in the marine area and vice versa.
* GOV2: Opportunities for co-existence should be maximised wherever possible.
* GOV3: Proposals should demonstrate in order of preference:
a. that they will avoid displacement of other existing or authorised (but yet to be implemented) activities
b. how, if there are impacts resulting in displacement by the proposal activity, they will minimise them
c. how, if the impacts resulting in displacement by the proposal activity, cannot be minimised, they will be mitigated against
d. the case for proceeding with the proposal if it is not possible to minimise or mitigate the impacts of displacement.
* SOC2: Proposals that may affect heritage assets should demonstrate, in order of preference:
a. that they will not compromise or harm elements which contribute to the significance of the heritage asset
b. how, if there is compromise or harm to a heritage asset, this will be minimised
c. how, where compromise or harm to a heritage asset cannot be minimised it will be mitigated against
d. the public benefits for proceeding with the proposal if it is not possible to minimise or mitigate harm to the heritage asset.
* SOC3: Proposals that may affect the terrestrial and marine character of an area should demonstrate, in order of preference:
a. that they will not adversely impact the terrestrial and marine character of an area
b. how, if there are adverse impacts on the terrestrial and marine character of an area, they will minimise them
c. how, where these adverse impacts on the terrestrial and marine character of an area cannot be minimised they will be mitigated against
d. the case for proceeding with the proposal if it is not possible to minimise or mitigate the adverse impacts.
* TR1: Proposals for development should demonstrate in order of preference, that during construction and operation:
a. they will not adversely impact tourism and recreation activities
b. how, if there are adverse impacts on tourism and recreation activities, they will minimise them
c. how, if the adverse impacts cannot be minimised, they will be mitigated
d. the case for proceeding with the proposal if it is not possible to minimise or mitigate the adverse impacts.
As previously stated, we would also recommend you consult the following references for further information:
East inshore and East Offshore Marine Plans and Marine Information System

This new plan covers 19 years and runs until 2036. The previous submitted plan covered 15 years and ran until 2030. The current minerals local plan, which is due for replacement, covered a period of 9 years.

Explanation for the more than doubling in duration of the new plan compared to the current plan is required in the issues and options document as the increase in duration and the reasoning behind it is not mentioned.

The document states: "This consultation paper provides a summary of the issues and options. This may be sufficient for your purposes, but for a fuller picture we have prepared a range of background papers which set out in detail the particular issues faced by each mineral and some other key topic areas. There are also a number of technical reports."

These were requested, but the response was "As you correctly identified page 7 of the Issues and Options document states that background papers would be available however this is an error with the version of the document published"

Page 8/9 - Deprivation is not confined to former mining areas, but is particularly high in Nottingham City and its hinterlands, and in areas of towns such as Newark on Trent (English indices of deprivation 2015, Ministry of Housing, Communities and Local Government).

This representation is made on behalf of the Nottinghamshire Branch of the Campaign to Protect Rural England.
CPRE recognises the need for mineral extraction. It also needs to be recognised that the impact of extraction of millions of tonnes of aggregates every year on the countryside and local communities can be enormous. There is a need to reduce the level of extraction in future by making better use of mineral resources and developing alternatives. The environment is too often taken into account only when considering where to quarry, not whether we really need to.

The document states: 'This consultation paper provides a summary of the issues and options. This may be sufficient for your purposes, but for a fuller picture we have prepared a range of background papers which set out in detail the particular issues faced by each mineral and some other key topic areas. There are also a number of technical reports.'

These were requested, but the response was 'As you correctly identified page 7 of the Issues and Options document states that background papers would be available however this is an error with the version of the document published'

Introduction, scope, Context etc. pp 3-9.
We accept the overall approach to the preparation of the Minerals Plan. We consider especially important the recognition that it requires balancing the economic benefits and need for minerals against the social and environmental disruption and harm that their extraction can cause. We note and would emphasise the importance given to flood risk, to which our Parish is exceptionally vulnerable - a danger which, as stated, is higher now than ever when the impact of future climate change could result in higher winter rainfall and more extreme flood events.
Q.1. Do you think any further information should be included in the overview of the area?
The overview covers all major points except the importance of landscape. Much of the area being considered for extraction lies within the Green Belt, as does this Parish. While this is no legal obstacle to mineral working, it is a recognition, by statutory definition, that landscape in such places is highly valued, and therefore deserves consideration in its own right.
We entirely reject the assertion that "As the County is quite poor in biodiversity, sand and gravel reclamation schemes have a very significant role in redressing the balance," for which no supporting evidence is referenced; at least as far as the Trent Valley is concerned. From the Derbyshire border downstream as far as Hoveringham the Trent is virtually lined with disused gravel and sand workings, and from Newark downstream with working ones. There is if anything an oversupply of such sites in this region of the County, and any addition to them will only exacerbate the local imbalance and do nothing for areas, such as the West of Nottinghamshire, poor in wetlands. A local study in our Parish early in this decade has found that the arable and pasture land along the Trent provides a rich habitat for a varied wildlife. Topography in the Trent Valley East of Nottingham provides exceptionally wide views of great value to local people. Research for this Council's ongoing consultation in preparation of a Neighbourhood Plan shows clearly that the local landscape is held in high regard. Moreover, abandoned extraction sites do not easily become flourishing "wetland" areas. Attenborough Nature reserve only became what it is after great investments by Nottinghamshire Wildlife Trust and the local Council, whereas the land at Hoveringham has been left as a collection of virtually lifeless lagoons.
Q.2. Do you agree with the draft vision? Are there other things we should include?
We accept the draft vision, and the preceding paragraphs concerning national and local policy, on the basis that the restraints on extraction required by giving due attention to quality of life and health for people in the county, and protection and maintenance of the environmental and historic assets should mean that no exploitation of minerals happens that would contravene those principles whenever alternative supplies are available. The NPPF guidelines setting out the Social role and the Environmental role of the Planning Process should be maintained throughout.
Regarding biodiversity and the natural environment, especially relating to restoration of exhausted sites, see answer to Question 1 above. Regarding selection of sites and closeness to markets of sites, see answer to Question 8 below. Regarding Alternative Aggregates see answer to Questions 4 and 14 below. Regarding use of barges see answer to Question 10 below.
Q.3. Are the Strategic issues appropriate? Are there others we should consider?
The strategic issues are appropriate provided that site allocations (at a later stage) are made in a way that avoids so far as possible conflicts between the various 5 issues. Most importantly, we consider the need to minimise impact on communities , which is a complex but clear requirement, should override mathematically simplistic measures such as transport distances, or special pattern.
Q.4. Do you think the average 10 year sales figure the most suitable methodology for forecasting future aggregate demand in Nottinghamshire? If not, please identify any alternatives you feel are realistic and deliverable and the evidence to support this approach.
No we do not. A more pro-active independent investigation into demand questions is likely to produce a lower figure. It is apparent from the paragraphs on Estimating Future Demand that figures given by the industry have contributed to the estimate; for normal business reasons it is probable that such figures would be as high as can be justified. Further, past demand is not likely to be repeated for several reasons. The information given makes it clear that there is a lag of a few years between an economic downturn and the reduction in building activity, which is quite natural. This will mean that the economic downturn resulting from Brexit has not yet affected numbers, but will. Further, modern architectural developments suggest that there will be less demand for concrete in newer building than previously, even in times of economic revival. Practicing members of the profession tell us that they and their colleagues are consciously seeking a reduction in concrete manufacture and use for environmental reasons, and new design systems such as suspended or metal-braced roofs reduce concrete use. At the same time we note the reference to sources outside the county and to growing use of Recycled and Secondary aggregates: the combination of these factors could combine their effects, in that the successful use of stone quarrying waste from Derbyshire, where there is more of such activity and which is closest to the City of Nottingham and the proposed HS2 hub, and from Yorkshire, closer to the Yorkshire market obviously, could displace demand for materials sourced in this County.
Q.5. Do you think the same methodology (most recent average 10 year sales) should be used for each aggregate or is there merit in using different methodologies for different aggregates?
It is appropriate to consider the overall picture for normal aggregates for concrete manufacture together, i.e. gravel, recycled material and secondary sources, but for other aggregates different approaches and calculations may work better.
Q.6. Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
Yes, as a rule. The overriding consideration in comparing different sites should be to prevent, entirely if possible, destruction of the environments of existing communities, with the health problems, traffic congestion, flood threats and damage to the physical surroundings and quality of life of those communities. In most cases, but not necessarily all, that will mean prioritising existing permitted quarries, but the prevention of damage to communities should always be the decisive question.
Q.7. Should different approaches (new sites/extensions to existing permitted quarries) be adopted for individual mineral types?
Yes. Extraction sites in river valleys are likely to result in the long term of almost total loss of the land concerned (since we are unimpressed by the "wetland" solution as "restoration") whereas sites on higher ground may have a future for other forms of use. Coal, oil and other hydrocarbon extraction processes may also result in long-term loss of land. Overall, the standards stated in answer to Q.6 should apply to this question.
Q.8. How important is it to maintain a geographical spread of sand and gravel quarries across the County (i.e. Idle Valley, near Newark and near Nottingham) to minimise the distance minerals are transported to markets?
Not important. Important markets for aggregates in Nottinghamshire are the city of Nottingham and the HS2 hub planned for Toton. These are for natural and obvious reasons in a part of the county where population densities are higher, and therefore the damage to be done from extraction sites to resident communities is greater. There would be a greater cost to local Councils and public services as well as residents from demands for road space, problems of health and pollution, as well as severe damage to the quality of life. All these are part of the real cost of putting extraction sites in such areas, so the lower cost of transport is delusory: these real costs are not a charge on the end price at the site of use, but must be included in consideration by the Planning process. Air Quality index in the Nottingham area is only "moderate," (aqcin.org./map/united kingdom) while in potential sites for aggregate extraction further from the city, it is still "good." Additionally, both those developments would be an exceptionally rich source of recycled material as an alternative aggregate since much demolition would be involved, and are both also close to sources outside the County and with good transport links to bring in aggregates, whether freshly extracted or secondary, from those sources.
Q.9. Would it be more appropriate to prioritise specific areas above others?
Yes. Priority should be given to sites of low amenity value away from densely inhabited areas, though each site should be considered on its own merits. Explicitly, road systems already over-strained by commuter traffic, particularly the A612 and A6097, should not have further congestion , with its associated air and noise pollution, cost and danger, added by the large-scale transport of aggregates.
Q.10. Is it economical to transport minerals by barge, and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?
Such use of barges should not automatically carry any prioritising of sites using barges. If using barges reduces to overall impact of quarrying on local communities, from road congestion and all other causes combined, if the barging is for long distances (so making a real difference to road congestion,) if infrastructure i.e. docking and wharf facilities is already in place and if the barges would not themselves cause problems to other river traffic or the stability of the bank, then such cases may be considered on their own merits. None of these requirements would be met for any sites in this area of the Trent Valley, i.e. above Newark.
Q.11 - 13. These minerals would all be extracted from areas outside our competence for comments
Q.14. Are you aware of any issues relating to alternative aggregates that should be considered through the Minerals Local Plan Review?
From the statistics supplied as well as from the application of sound ecological principles, there should be much more use of recycled and secondary materials expected, including demolition products which would otherwise go to landfill and which should be readily available on most sites likely to be used for foreseeable new development. Other waste material from various forms of stone quarrying, inside and outside Nottinghamshire, should make an important contribution.
Q. 15-24 Again, this Parish Council has no mandate to address these questions.
Q. 25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
Yes. This Parish Council represents an area highly vulnerable to severe damage to the quality of life of its inhabitants. The Development Management policies address the proper issues which need to be considered in preserving the rights and interests of the community, so justifying the direction by democratic forces representing the public interest.
Q.26. Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?
In this part of the Trent Valley the most severe threat is that of flooding. While any mineral extraction would increase that threat to an unacceptable level, the same danger means that no other form of development is appropriate; therefore mineral safeguarding does not become an issue.

The Society and its predecessors, the Burton Joyce Preservation Society and the Burton Joyce Residents' Association, have always resisted mineral extraction plans proposed in this century which would have seriously damaged this area. These include the Application to dig up the Trent bank in our area and further downstream on this side ("The Gunthorpe Allocation") under the 2005 Minerals Plan; and on the immediately adjacent riverbank, in Shelford Parish, we have explicitly opposed proposals to include that territory in the now-abandoned draft for the new Plan. This submission is concerned only with aspects of the new Minerals Plan (2016-36) that will affect Burton Joyce.

All references are to page, paragraph and question numbers in the Consultation Document.

Introduction
We especially welcome and endorse the reference on p.3 to the important fact that "potential environmental impacts of extraction can limit where extraction is feasible" and that economic advantages must be measured "against the social and environmental disruption and harm that extraction can cause." We would add that while the economic benefits are necessarily of limited duration, as are some aspects of the damage to local communities, other sorts of damage would be permanent.

Question 1.Do you think any further information should be included in the overview of the area?
Might not the question of Biodiversity be enlarged? We note the assertion that "as the County is quite poor in biodiversity, sand and gravel reclamation schemes have had a very significant role in redressing the balance." Since this is in the past tense, the sentence appears to recognise that no further re-balancing is required; nor is it appropriate. The Trent Valley is a recognised wildlife corridor. This is not only for migrating waterfowl, for which feeding and breeding grounds in the form of old quarry workings are more than adequate, but other species that would be put at risk by any increase in wetland. The value of restoration schemes varies greatly, and while nature reserves such as Attenborough and parks as at Colwick are a public amenity, they have been achieved over a very long time, largely at the expense of the public, rather than of those who took the gains from the quarrying process, and basic so-called "restoration to wetland" amounts to little more than ever more extensive holes full of water. If greater areas of wetland were once desirable, that need has already been met more than adequately, at least in the areas likely to be subject to possible applications for further digging. Detailed research on the river bank has shown that in this area there is great variety of important species, flora and fauna, on both banks of the Trent, which would be irreplaceably lost if gravel extraction were allowed.

Question 2.Do you agree with the draft vision? Are there other things we should include?
We agree with the draft vision, in particular the second and third points from the National Planning Policy Framework: "A social role - to support strong, vibrant and healthy communities" and "An environmental role - contributing to protecting and enhancing our natural built and historic environment, including improving biodiversity, prudent use of natural resources and adapting to climate change."
Burton Joyce is already such a community, but the loss of amenity that would result from the destruction of either bank of the Trent would be a catastrophe: the pollution by noise and dust from gravel workings and the congestion, air pollution, and noise caused by heavy traffic carrying away gravel would render parts of the village virtually uninhabitable. Serious flooding is already a threat which could render much of the area literally uninhabitable, and gravel digging on either bank would greatly increase that threat, especially in the light of the recently published analysis of the likelihood of more frequent severe weather conditions (Met Office Report 24th July 2017).
In relation to biodiversity and site restoration issues, see answer to Q1 above.
In relation to Alternative Aggregates, see answer to Q4 and Q14 below.
Transport of sand and gravel after extraction is an issue because of the low value of the material relative to its weight, resulting in the cost of transport accounting for a high proportion of its price at the site of use. However, if for this reason extraction sites are closer to inhabited areas to minimise mileage, there is very much greater cost, in terms of destruction of quality of life, detriment to health, increased probability of destructive flooding, and overloading of the road network on already-overstressed routes. Although those costs would not fall on those profiting from the sale of the minerals, it is the task of the Planning process as a whole to give those factors due weight.
In relation to barging of materials, see answer to Q10.

Question 3. Are the above Strategic issues appropriate? Are there others we should consider?
The relevant issues for Burton Joyce are paragraphs 3 and 4 concerning impact on communities and restoration of sites. While all the issues are appropriate where extraction is carried out, the only appropriate safeguards for this area would be to prevent extraction altogether.

Question 4. Do you think he average 10 year sales figure is the most suitable methodology for forecasting future aggregate demand in Nottinghamshire?
No. Firstly, the graph (figure 1) itself shows overall the amount of Recycled and Secondary materials effectively steady, even at a time of a fall, by over 50%, in the demand for newly-extracted fresh material. This would suggest that there is potential for the Recycled and Secondary aggregates to increase when there is need for overall increase in consumption of aggregates, and this would consequently reduce the eventual demand for fresh material. Logically the main source of this Recycled material would automatically grow with revived demand, since an increase in construction activity is necessarily accompanied by an increase in demolition and waste which can then become aggregate. This is especially so in the City of Nottingham, where there are very large areas of derelict land fit for redevelopment, and therefore this consideration is especially relevant to requirements for aggregates in or near the city. Similar considerations apply to the potential for new construction at the HS2 Hub at Toton, which now seems a certainty, but with the additional factor that this development will have, by definition, excellent rail connections, making transport of minerals from outside Nottinghamshire a more attractive proposition.
A ten-year base for estimates covers of course approximately half the period that this Minerals Plan will cover. Modern architectural practices place greater emphasis on ecological sensitivity; Nottingham University is a leading research and advocacy base for this. This involves reduced use of concrete, since the pollution and environmental degradation caused by its production are undesirable. Before 2036 it is likely that government regulations and local planning policies will reinforce that trend. We note with interest the finding (p.17) that the effect on demand of recession in 2008-9 shows up in the consumption figures only in 2012. It might be reasonable to suppose that the Brexit-induced economic downturn has not yet shown in such figures, but will. In the longer term which we are necessarily contemplating, it seems likely that improved technology will make Recycled and Secondary sources more plentiful. Tax incentives, as mentioned in the Consultation document (p.24) could further increase the proportion of aggregates available from these sources, and, while this is a matter of political will, it would be a move welcomed by the public and it may well be reasonable to include that probability in demand estimates.

Question 5. Do you think the same methodology (most recent average 10 year sales) should be used for each aggregate, or is there merit in using different methodologies for different aggregates?
Different methodologies appear more appropriate. The arguments in answer to Q4 apply almost entirely to gravel, and to a lesser degree to sand, but very much less to other materials.

Question 6. Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
In most cases yes, but the individual circumstances of each site will vary. The essential question is which choice will create the least risk of environmental destruction, flood risk, transport problems, destruction of natural habitat and damage to people's quiet enjoyment of their own homes. In most cases this is likely to be an extension of an existing site but there will be exceptions.

Question 7. Should different approaches (new sites/extensions to existing permitted quarries) be adopted for individual mineral types?
Probably yes, but always subject to the criteria set out in answer to Q6. Attention should be given also to the long-term post-extraction future of sites, which is very different for the different minerals. For example, disused quarries for limestone or building stone may become more useful than previously, and even used for housing. However, gravel and sand extraction, in river valleys, usually destroys good agricultural land, close to inhabited areas, which has important amenity value and/or potential for development; all this is permanently lost if the site becomes a big hole full of water.

Question 8. How important is it to maintain a geographical spread of sand and gravel quarries across the county (i.e. Idle Valley, near Newark and near Nottingham) to minimise the distance minerals are transported to markets?
Not important. As stated in the answer to Q2, extraction sites close to built-up areas only have lower costs because the extracting and construction companies do not pay the extra costs imposed on the inhabitants and on public authorities by that extraction. Such costs are automatically greater in a more densely populated area, particularly near the city of Nottingham. For many such sites the imposition of a quarry may effectively destroy a community.

Question 9. Would it be more appropriate to prioritise specific areas above others?
Yes. Priority should be given to areas of low population, unencumbered traffic routes and places where the existing land use is of low value.

Question 10. Is it economical to transport minerals by barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?
Not as a rule: only in appropriate specific cases. We note that references in the consultation document are to barge transport over long distance, to and/or from existing infrastructure, none of which applies to the area near Nottingham. The economic calculations are beyond our capacity to estimate. However, we note that in now-superseded attempts to add a local site to the earlier draft of this Minerals Plan included the suggestion that a small proportion of the output could be carried by barge a short distance from an as-yet non-existent wharf. Such a suggestion appears unrealistic, and a misleading attempt to suggest that the impact on road systems could be moderated. The work to construct and operate a wharf could alone threaten damage to the existing bank and raise flood risks on both sides of the Trent, and inevitable spillages would also obstruct water flow and further increase risk of flooding. Given the very short barge journey proposed, most of the traffic problems caused by transporting the gravel would only be literally pushed a few miles down the road, if the wharf were actually used. If used, it would be a source of noise, dust and air pollution to the neighbouring homes, and if (as seems probable) it added expense to the transport system, it would not be used, and therefore not reduce a large extra burden on the road system.

Questions 11-13. As the Burton Joyce Village Society, we do not claim to have any useful contribution to make relating to sandstone and crushed rock provision.

Question 14. Are you aware of any issues relating to alternative aggregates that should be considered in the Minerals Local Plan review.
As well as points raised in answer to Q4, two issues are relevant. 1: there is potential for much of the waste or sub-standard material from working for minerals other than gravel to substitute for gravel. This presumably comes under the heading of Secondary sources and will be taken into account in the next stage of the Plan. Such sources would be not large but have the advantages of being within an existing distribution system and located in areas where gravel is not available. 2. We are unaware whether or to what extent there has been investigation of the potential for material from colliery spoil heaps as aggregate. If the physical and chemical properties of such material are suitable, it has both those advantages, as well as of course being extremely plentiful in this County, and its removal would in most cases improve the value of the site.

Question 15-24. Again, the Society claims no right to speak on these issues. References to some of these materials as potential Secondary aggregates has been made already under Q.14.1

Question 25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
We enthusiastically endorse the policies here set out. Even those few with no direct relevance to Burton Joyce (e.g. airfield safeguarding) are clearly important considerations where they arise. The fundamental purpose of Planning procedures should be to maintain the priority of these principles where they may conflict with short-term commercial gains.

Question 26. Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals local Plan review?
The issue scarcely arises in this part of the Trent Valley since the continuing agricultural use of land appears to be the alternative. The area is all unsuitable for other uses because of the high and growing threat of flooding, which would be aggravated by either mineral extraction or by building.

Re this consultation, it is then dismaying a location specific planning reference at the document's page 20 paragraph 4.

Response to issues and options consultation

As the member for the Collingham Division I believe the primary issues to be as outlined below which I present in response to the questions posed in the consultation documentation provided:
1.The inclusion of issues relating to extraordinary traffic congestion in the area of the Collingham Division should be included because the A17 / A46 / A1, A1133 and A614 all converge in the Division. Of the quarries identified - Coddington sits on the A17 and Flash Farm on the A614; both these quarries if developed would generate significant, additional traffic congestion in an area which already suffers considerable congestion issues. Until these issues are resolved these two quarries should not be considered for development. Additionally, congestion in the area is already impacting the economy of Newark on Trent.
2.The 'Our Vision' section of the consultation document does not demonstrate sufficiently that you have considered use of minerals in house building, roads and infrastructure in the future. Much research and innovation investment is being directed towards the development of environmentally friendly materials and materials which enable the development of homes in shorter timeframes and are less likely to be traditional minerals. It does not appear that this has been considered in the vision or future forecasts.
3.In respect of the Strategic Issues identified I suggest that consideration be given to the priority of the issues as presented. I believe that the most important issue for consideration is how we minimise impact upon communities and the second most important issue is the biodiversity led restoration of worked out quarries. In my Division we already have significant flooding issues which impact upon the villages bordering the River Trent and River Fleet. Additionally, I recommend we consider involving Academic Institutions and their students in developing innovative ideas and options for the restoration of worked out quarries which does not involve water and provides much needed flood relief.
4.See comments above in response to Question 2.
5.See comments above in response to Question 2.
6.It makes sense to extend existing permitted quarries which should be prioritised over new greenfield quarries providing that consideration is given to communities surrounding the sites and any impacts that these extensions might have e.g. traffic related issues in areas of changing traffic/congestion circumstances.
7.See comment above in response to Question 6.
8.9. and 10. Where possible it makes sense to remove transportation of minerals from road placing them on river barges. However, a full evaluation in collaboration with Operators will be required.

Scope on Page 4: 'Long term environmental gains can be achieved, for example, by creating wildlife habitats out of worked out quarries.'

This is not balanced - it needs to continue to say, '... however, in most open cast quarrying activities a high proportion of the former land surface is permanently replaced by open water'.

Even in well restored quarries, gains in non-wetland habitat areas (significant and valuable though they may be) are generally tiny in area compared with the productive land surface area permanently lost.