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

Barton in Fabis Parish Council response

Question 1 Do you think any other information should be included in the overview of the area?

Yes. Please see points below for inclusion.
Page 8
"Around two thirds of the population live in, or around, Nottingham which is a major centre for employment and retailing. The remainder live in, or close to, the other main towns of Mansfield, Kirkby in Ashfield, Sutton in Ashfield, Hucknall, Worksop, Newark and Retford. Outside these urban areas, the rest of the County is largelyrural with scattered small villages, farmland, woodland and commercial forestry.

The point should be added that as a result of the concentration of population access open space adjacent to the larger conurbation plays an important role in the health and wellbeing of local people and mineral extraction in those areas should be avoided wherever possible.
Page 8
"Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, near Edwinstowe. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status."
Attenborough Nature Reserve in the south of the county should be added to the list of sites for nature conservation as this attracts 600,000 visitors per year (RSPB 'Bigger and Better'). It is recognised as being of national ecological importance. Reference should be made to the importance of preserving / enhancing SSSIs across the county. We propose that a map of SSSIs is included in the MLP.

Page 8
"However, the overall quality of our natural environment has suffered in the past from industry and other development pressures and there has been a decline in biodiversity, with losses of ancient woodland, heathland, species-rich grassland, hedgerow and wetland habitats, as well as the species that these habitats support."

We agree. However, it should be stated that there should be no further loss or impact on designated sites including SSSIs, SINCs and Local Wildlife Sites in view of the County's decline in biodiversity. Reference should therefore be added to the need to preserve remaining examples of the habitats referred to, especially in considering sites for mineral extraction. Reference to conserving and strengthening ecological networks and corridors should also be added.

Page 8
"Road and rail links to the rest of the UK are generally good especially via the main north-south routes of the M1, A1 and direct rail links to London from Newark and Nottingham."

Reference should be added to the River Trent as a potential navigable route for aggregates along part of its length

Page 9
"Mansfield, Worksop and Newark are important centres for warehousing and
distribution whilst service, technology and research based industries tend to cluster around Nottingham. The energy industry also has a major role with four power stations along the River Trent. Elsewhere, agriculture and forestry are no longer major employers but still make up much of the Countyʼs rural landscape, particularly to the south and east."

Reference should be added to the fact that rural landscape in the south of the county has already diminished as a result of new road links and expansion of Nottingham. It should be noted that while agriculture may not be a major employer the importance of retaining the best agricultural land remains a priority.

Page 11
"As the County is quite poor in biodiversity, sand and gravel reclamation schemes have had a very significant role in redressing the balance."

Reference should be added for the need for areas which are already rich in biodiversity to be preserved, and where these would be negatively impacted by sand and gravel restoration schemes. It should be noted that restoration is beneficial in those areas already degraded ecologically. In those areas that are currently significant for biodiversity, conservation of existing biodiversity resources rather than restoration following mineral extraction is the preferred option


Question 2 Do you agree with the draft vision? Are there other things we should include?

No. Please see below for specific points that should be included

Page 12
"There are three dimensions to sustainable development which the planning system needs to take into account.......
The NPPF and the Planning Practice Guidance (PPG) also sets out specific guidance for the sustainable use of minerals"

It is simply not sufficient merely to quote the overall "dimensions" quoted in the NPPF.
Instead the specific elements of the NPPF / NPPG which are relevant to mineral extraction and its potential impact on the wider environment should be specifically identified. Moreover while there are three dimensions they should not be traded off against each other - sustainable development implied all three need to be considered in a balanced way. The MLP should confirm that these will be at the centre of the criteria used to assess the sustainability of proposed sites:

We would wish to see highlighted in particular:
-Section 11 on 'Conserving and enhancing the natural environment'
Para 109
"The planning system should contribute to and enhance the natural and local environment by:
● protecting and enhancing valued landscapes, geological conservation interests and soils;
● recognising the wider benefits of ecosystem services;
● minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;
● preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and
● remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate."
Para 118
"When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles:
● if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;
● proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest;
● development proposals where the primary objective is to conserve or enhance biodiversity should be permitted;
● opportunities to incorporate biodiversity in and around developments should be encouraged;
● planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss; and
● the following wildlife sites should be given the same protection as European sites: - potential Special Protection Areas and possible Special Areas of Conservation; - listed or proposed Ramsar sites;26 and - sites identified, or required, as compensatory measures for adverse effects on European sites, potential Special Protection Areas, possible Special Areas of Conservation, and listed or proposed Ramsar sites."
Para 123
"Planning policies and decisions should aim to:
● avoid noise from giving rise to significant adverse impacts
● mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions;
● recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established; and
● identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason."

-Section 13 on 'Facilitating the sustainable use of minerals'
Especially para 143:
"set out environmental criteria, in line with the policies in this Framework, against which planning applications will be assessed so as to ensure that permitted operations do not have unacceptable adverse impacts on the natural and historic environment or human health, including from noise, dust, visual intrusion, traffic, tip- and quarry-slope stability, differential settlement of quarry backfill, mining subsidence, increased flood risk, impacts on the flow and quantity of surface and groundwater and migration of contamination from the site; and take into account the cumulative effects of multiple impacts from individual sites and/or a number of sites in a locality;"

And para 144
"ensure, in granting planning permission for mineral development, that there are no unacceptable adverse impacts on the natural and historic environment, human health or aviation safety, and take into account the cumulative effect of multiple impacts from individual sites and/or from a number of sites in a locality;
● ensure that any unavoidable noise, dust and particle emissions and any blasting vibrations are controlled, mitigated or removed at source,31 and establish appropriate noise limits for extraction in proximity to noise sensitive properties;"

-Section 9 'Protecting Green Belt land'
The vision should set out how mineral planning relates to the Green Belt and the importance given to its preservation in the NPPF:
The NPPF and Government (para 79) "attaches great importance to Green Belts" and states (para 87) very clearly that inappropriate development should not be approved except in very special circumstances:
"inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances"

Para 88 states:
"When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm is clearly outweighed by other considerations"
Para 89 states:
"A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. "
Buildings associated with the processing of minerals are not listed amongst the exceptions and should therefore be considered inappropriate in the Green Belt
Para 90 states that mineral extraction is "not inappropriate" in the Green Belt provided it preserves the openness of the Green Belt and does not conflict with the purposes of including land in Green Belt. Even if the extraction of gravel is considered "not inappropriate" by the NPPF that does not mean that it is automatically permissible, "Very special circumstances" (para 88) must still be justified.
-PPG Minerals
Identifies a series of criteria against which proposed sites for mineral extraction should be evaluated:
*noise associated with the operation
*dust;
*air quality;
*lighting;
*visual impact on the local and wider landscape;
*landscape character;
*archaeological and heritage features (further guidance can be found under the Minerals and Historic Environment Forum's Practice Guide on mineral extrac-tion and archaeology;
*traffic;
*risk of contamination to land;
*soil resources;
*geological structure;
*impact on best and most versatile agricultural land;
*blast vibration;
*flood risk;
*land stability/subsidence;
*internationally, nationally or locally designated wildlife sites, protected habitats and species, and ecological networks;
*impacts on nationally protected landscapes (nationally protected geological and geo-morphological sites and features;)
*site restoration and aftercare;
*surface and, in some cases, ground water issues;
*water abstraction.

Page 13
"ensuring future minerals development does not have unacceptable adverse impacts on the natural and historic environment or human health. This is will be achieved through the identification of site specific allocations and a range of planning policies against which planning applications can be assessed."

This statement should be specific with regard to the "range of planning policies" that will be applied and should take account of a) the number of people and b) the relative quality of the existing natural and historic environments in identifying site specific allocations.

Page 13
"Local policy includes the Council Plan - 'Your Nottinghamshire, Your Future', the Nottinghamshire Local Transport Plan and the District Councils' Local Plans"

We believe that other policies such as Greater Nottingham Landscape Character Assessment (GNLCA) should also be taken in to consideration. Similarly policies for biodiversity and human health and well-being should be considered.

Page 14
"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."

In line with vision statements in the Council's strategic ambition 'Your Nottinghamshire, Your future' it should be added that the location of mineral development should be prioritised in locations which promote the interests of local people and the visions of 'a great place to bring up your family' and 'a great place to enjoy your later life' rather than those in the interests of the aggregate industry requiring the greatest level of accessibility to the major markets and growth areas. This will mean prioritising locations away from major centres of population, whilst also prioritising sustainable transport nodes to encourage sustainable modes of transport. It will also mean prioritising areas which are valuable in cultural and heritage terms and valuable ecologically.

Page 14
"All mineral workings will contribute towards a greener Nottinghamshire by ensuring that the County's diverse environmental and historic assets are protected, maintained and enhanced through appropriate working, restoration and after-use. This will result in improvements to the built and natural environment, and contribute to landscape-scale biodiversity delivery; and the re-connection of ecological networks.
The quality of life and health of those living, working in, or visiting Nottinghamshire will be protected."

It is unrealistic to suggest that mineral workings will improve the built and natural environment where the potential site is already rich in biodiversity for example including SSSIs and SINCs.
We would propose that the vision should state that:
"Sites for mineral workings will be allocated in areas which cause the least damage to the built and natural environment and which may improve the existing environments.
Sites will also be selected which minimise the impact on the quality of life and health on the minimum number of people living, working in or visiting Nottinghamshire. Sites which currently enhance the quality of life for nearby urban populations should be avoided."

Question 3 Are the above strategic issues appropriate? Are there others we should consider?

Yes, but the emphasis should be on reducing the number of people impacted by sand and gravel excavation - see comments below.

Page 15
1."Improving the sustainability of minerals development
Ensuring that primary minerals are worked in the most sustainable manner and the use of secondary and recycled aggregates is encouraged. Securing a spatial pattern of mineral development that efficiently delivers resources to markets within and outside Nottinghamshire".

We would add the statement "and which impacts the minimum number of people and uses the most sustainable modes of transport and which minimises the impact on local communities and the environment"

Page 15
"3. Minimise impacts on communities
Minimise the adverse impacts on Nottinghamshire's communities by protecting their quality of life and health from impacts such as traffic, visual impacts, noise and dust."

This should be placed as the first strategic issue and should be reworded and titled Title: "Prioritise the minimisation of impact on communities".... "Prioritise the minimisation of adverse impacts...etc"
The paragraph should also include reference to preserving the amenity value of areas such as rights of Way and their contribution to the quality of life and health of communities.

Question 4 Do you think the average 10 year sales figure is 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. The analysis of future aggregate demand should include a wider analysis of demand within and outside Nottinghamshire as well as a wider analysis of the total feasible supply of aggregates taking in to account supply from neighbouring counties - see points below.

Page 16
"Recycled and secondary aggregates are also produced, however reliable data for
this sector is limited"

The use of recycled and secondary aggregates is likely to be significant in offsetting the need for new supplies. Further work must be undertaken to obtain more reliable data and / or a reasonable estimate.

Page 18
"This factor is likely to be combined with the minerals industry focusing on existing quarries outside the County and the lack of investment in new greenfield quarries in Nottinghamshire, even though adequate sand and gravel resources remain."

The Issues and Options document should not be based on such unsubstantiated speculation. The document focuses purely on past sales within Nottinghamshire as a predictor of future demand. A more robust assessment should be based on an analysis of a) the likely demand from outside Nottinghamshire of material exported to counties to the north and west and b) the available supply from adjacent counties(particularly in the south of the county) to supply the Nottinghamshire market. The supply and demand for sand and gravel does NOT stop at the County border!

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

Yes - see comments below.

Page 19
"However, extensions to existing quarries can result in potential social and/or
environmental cumulative impacts in the area. National guidance states that potential sites should be based on their individual merits taking into account the need for the mineral, economic considerations, the potential positive and negative environmental impacts and the cumulative impacts of proposals in the area.

The Minerals Local Plan will need to identify site specific allocations. Depending on the availability of extensions to existing permitted quarries going forward, the suggested approach for the Minerals Local Plan will be to give priority to extensions to existing permitted quarries before new greenfield quarries are considered."

The required infrastructure is likely to be already available in the case of existing quarries and it therefore makes sense to prioritise the extension of these ahead of new greenfield sites. The environmental impact of a new greenfield site is likely in most cases to have a greater adverse impact.
There is the advantage of continuity of production as existing sites have infrastructure already in place. They can also help retain the existing workforce and provide a mechanism for the full recovery of the resource thus avoiding the unnecessary sterilisation of the mineral. It also means that restoration efforts can be coordinated and focussed on successful delivery of environmental outcomes.
It should be added that in considering new greenfield sites, account should be taken of the cumulative impact of such schemes in terms of other developments, especially where important sites such as SSSIs exist. Policy M3.27 refers.

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?

A geographical; spread of quarries is just ONE factor. Other more important factors need to be evaluated alongside this in determining where quarries should be located. See comments below.

Page 20
"Maintaining this geographical spread in the future would minimise the social and
environmental impacts of quarrying on individual areas and provide minerals close to the main markets, reducing the distances sand and gravel will have to be transported by road."

The social and environmental impact of transporting sand and gravel by road is only ONE factor in social and environmental impact and we do not understand why this factor has been singled out and it should not solely determine where quarrying should be located.
Other social and environmental impacts include:
-Landscape and visual impact including impact on the Green Belt
-Impact on the historical environment
-Noise and air quality impact on vulnerable communities, particularly in areas which impact the most people e.g. near to large settlements
-Loss of agricultural land
-Flood risk and hydrology impact
-Ecological impact
-The recreation ad amenity value of the area given the proximity of centres of population.
See also factors identified in PPG Minerals and response to Question 2 above. It would be entirely wrong to select a site merely because it is close to a particular market if it were also to have a greater social and environmental impact in other respects.
With respect to sites in the Green Belt NPPF para 88 states that "When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt" and that "very special circumstances" need to be demonstrated if the harm is to be outweighed by other considerations. The distance which aggregates have to travel by road cannot by itself be considered to outweigh the harm caused by quarry sites in the Green Belt.

Page 20
"Demand for sand and gravel from the wider Nottingham conurbation has historically seen quarries located close to the conurbation. This historic pattern started to break down as no new quarries have been opened to replace worked out quarries in this area. However, sand and gravel resources still exist, it is possible that over the next plan period new quarries could be opened around the Nottingham conurbation. A planning application for a quarry at Mill Hill, near Barton in Fabis, has been submitted to the County Council for determination. No decision has yet been taken, however, if approved the quarry would provide around 3.4 million tonnes which could serve the South Nottinghamshire area and the wider Nottingham conurbation."

We note that the report to the Communities and Place Committee from the Corporate Director for Place states that "It is important to note that the document does not consider site specific allocations." We therefore consider it completely inappropriate and prejudicial to other sites that might come forward for specific reference to be made to a planning application for a quarry at Mill Hill, near Barton in Fabis. No reference is to other sites which could serve the South Nottinghamshire area and the wider Nottingham conurbation such as the extension to the East Leake quarry for which planning permission has already been granted subject to S106 agreement and other sites pit forward in the withdrawn MLP such as that at Shelford.


Question 9 Would it be more appropriate to prioritise specific areas above others?

No. The prioritisation of areas can only be made once a full analysis of supply and demand has been undertaken including the projected demand from outside Nottinghamshire of material exported to counties to the North and West and the available supply from adjacent counties (particularly in the south of the county).

Question 10 Is it economical to transport mineral by river barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?

Numerous studies (Canal and River Trust / Commercial Boat Operators Association) show barges provide an economically viable solution and provide environmental benefits e.g. 25% less fuel per tome/mile and 25% less CO2 per mile. Barges have been used on parts of the River Trent over many decades and proposed quarries with the potential for their use should certainly be prioritised.
The quarry site at Sturton Le Steeple has been quoted in the LAA as providing "150,000 tonnes per annum potential barge transportation" and the Shelford site in the previous draft MLP proposed some 40% output being transported by barge transport.
Barge transport is significantly more sustainable and provides a real opportunity to remove / reduce HGV transport journeys and deliver materials to the heart of cities such as Nottingham.

Question 25 Do you agree with the proposed development management policy areas? Are there any others that should be covered?

No. The current list contains some areas which are vague:
-What does 'Protecting local amenity' include?
-What is meant by 'Incidental mineral extraction'
-Historic environment should include reference to designated and undesignated heritage assets
In addition, the list of development management opportunities should include all those listed in PPG Minerals (see response to Question 2) to include areas such as noise, air quality. The full list is as follows:
*noise associated with the operation
*dust;
*air quality;
*lighting;
*visual impact on the local and wider landscape;
*landscape character;
*archaeological and heritage features (further guidance can be found under the Minerals and Historic Environment Forum's Practice Guide on mineral extrac-tion and archaeology);
*traffic;
*risk of contamination to land;
*soil resources;
*geological structure;
*impact on best and most versatile agricultural land;
*blast vibration;
*flood risk;
*land stability/subsidence;
*internationally, nationally or locally designated wildlife sites, protected habitats and species, and ecological networks;
*impacts on nationally protected landscapes (nationally protected geological and geo-morphological sites and features;)
*site restoration and aftercare;
*surface and, in some cases, ground water issues;
*water abstraction.
Proposed Development Management policies should also include and take account of the recently updated published National Character Profile for the Trent Valley Washlands, which proposed the following set of objectives in relation to the op-portunities to maintain, enhance and strengthen the landscape character of the Washlands,
SEO 1: 'Carefully plan and manage new development within the NCA to ensure that landscape character and ecosystem services are strengthened, that heritage features, wildlife habitats, woodland and the hedgerow network are enhanced, and that opportunities for creation of multifunctional green infrastructure are realised so that this landscape is resilient to the forces of change that it is experiencing'. As the Guidelines for Landscape and Visual Impact Assessment, 3rd Edition notes many valued landscape features perform a wide range of functions that in turn have the potential to deliver a wide range of different services of value to people. The guidelines suggest that consideration of ecosystem service concepts is espe-cially valuable in promoting cross-cutting and integrative approaches. We suggest they would be especially relevant in assessing the strategic dimension of this pro-posal.
SEO 2: 'Manage and enhance the Trent Valley Washlands' river and flood plain landscape to combine its essential provision and regulation of water role with landscape enhancement, nature conservation, climate regulation, farming, recrea-tion and a resource for understanding geodiversity.'
SEO 3: 'Protect, manage and enhance the pastoral landscape of the Trent Valley Washlands, seeking to join up and expand areas of pasture and associated attributes and habitats, to preserve heritage features, enhance biodiversity and geodiversity, protect farmland and provide additional recreational opportunities.'
SEO 4: 'Protect and enhance the historic environment of the Trent Valley Washlands and their characteristic historic landscape. Increase awareness of the richness of this resource, protect it from neglect and physical damage, and ensure that future development complements and enhances the sense of history of the NCA.'

Response from Shelford Parish Council to the Issues and Options Consultation

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

The overview refers to the impact that quarrying has had on the creation of wetlands. It should be emphasised that the creation of so many lakes has already had an adverse impact by changing the whole nature of the traditionally farmed Trent Valley landscape. In terms of biodiversity many of the lakes have simply become large lakes of deep water, many of which are sterile, support a limited range of wildlife, attract a limited number of water-birds, and no longer contribute substantially to the County's biodiversity. On the contrary, farmland birds are amongst the most endangered species and note needs to be taken of the negative impacts of removing agricultural land from Nottinghamshire's
landscape.
Perhaps we should protect and improve the biodiversity we have rather than looking for marginal increments.

Q2 Do you agree with the draft vision? Are there other things we should include?

We agree with the draft vision.

Q3 Are the above strategic issues appropriate? Are there others we should consider?

We believe the strategic issues are appropriate. However, whilst the preamble recognises that aggregates are generally located adjacent to rivers, under the heading "Minimise impacts on communities" no mention is made of flood risk and its potential effects on quality of life.
At the very least the vision should include a statement to the effect that it will be policy that existing flood risk will not be allowed to increase by quarrying.

Q4 Do you think the average 10 year sales figure is 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.

The average 10 year sales figure is probably the most appropriate and available measure to use although we have a number of concerns about the fact that this is a supply side figure and is only a proxy representation of demand. It does not show the spread or size of demand throughout the county nor reflect the export (from the county) of one third to one half of supply to South Yorkshire, largely from the northern quarries.

Q5 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?

Please see our answer to question 4. There is no science that would indicate any greater accuracy for measuring the demand for different aggregates.

Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?

Yes - we believe that the expansion of existing quarries has resolved most of the strategic and practical issues facing the aggregates industry over the time they have been operated and their extension is the best way forward to protect the environment.

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

We see no particular merit in this approach.

Q8 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?

We recognise the importance of closeness to market and the high bulk low value equation of transport costs as well as the social and traffic implications.
It is important to determine the approximate size of the market from
the requirements of infrastructure and house and commercial building, and to produce a scientific approach to the selection of quarry sites which optimally meet requirements.

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

We believe that those sites which have the least impact on communities should be prioritised.

Q10 Is it economical to transport mineral by river barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?

Clearly movement of sand and gravel by barge is more desirable than by road.
Whilst there appears, to our knowledge, to have been no published and objective cost-benefit analysis of transporting aggregates by barge we simply have the rationale provided by individuals and the industry itself.
For example the industry has moved away from barging as an economical means of transport because of the double handling and processing costs. One operator provided a cost estimate of £13 to £15 per tonne for moving sand and gravel by barge which makes this a very uncompetitive solution.
Also the publication "Gravel Extraction: History of Aggregate Extraction in the Trent Valley" states "Since the mid 1950's, haulage economics have dictated that the vast majority of sand and gravel aggregates are transported by road".


Q.14 Are you aware of any issues relating to alternative aggregates that should be considered through the Minerals Local Plan?

We believe that greater emphasis should be given to the search and support for alternative aggregates and their recycling so as to reduce the pressure on mineral reserves within the County.

Response from SAGE to the Issues and Options Consultation

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

The overview refers to the impact that quarrying has had on the creation of wetlands. It should be emphasised that the creation of so many lakes has already had an adverse impact by changing the whole nature of the traditionally farmed Trent Valley landscape. In terms of biodiversity many of the lakes have simply become large lakes of deep water, many of which are sterile, support a limited range of wildlife, attract a limited number of water-birds, and no longer contribute substantially to the County's biodiversity. On the contrary, farmland birds are amongst the most endangered species and note needs to be taken of the negative impacts of removing agricultural land from Nottinghamshire's
landscape.
Perhaps we should protect and improve the biodiversity we have rather than looking for marginal increments.

Q2 Do you agree with the draft vision? Are there other things we should include?

We agree with the draft vision.

Q3 Are the above strategic issues appropriate? Are there others we should consider?

We believe the strategic issues are appropriate. However, whilst the preamble recognises that aggregates are generally located adjacent to rivers, under the heading "Minimise impacts on communities" no mention is made of flood risk and its potential effects on quality of life.
At the very least the vision should include a statement to the effect that it will be policy that existing flood risk will not be allowed to increase by quarrying.

Q4 Do you think the average 10 year sales figure is 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.

The average 10 year sales figure is probably the most appropriate and available measure to use although we have a number of concerns about the fact that this is a supply side figure and is only a proxy representation of demand. It does not show the spread or size of demand throughout the county nor reflect the export (from the county) of one third to one half of supply to South Yorkshire, largely from the northern quarries.

Q5 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?

Please see our answer to question 4. There is no science that would indicate any greater accuracy for measuring the demand for different aggregates.

Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?

Yes - we believe that the expansion of existing quarries has resolved most of the strategic and practical issues facing the aggregates industry over the time they have been operated and their extension is the best way forward to protect the environment.

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

We see no particular merit in this approach.

Q8 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?

We recognise the importance of closeness to market and the high bulk low value equation of transport costs as well as the social and traffic implications.
It is important to determine the approximate size of the market from
the requirements of infrastructure and house and commercial building, and to produce a scientific approach to the selection of quarry sites which optimally meet requirements.

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

We believe that those sites which have the least impact on communities should be prioritised.

Q10 Is it economical to transport mineral by river barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?

Clearly movement of sand and gravel by barge is more desirable than by road.
Whilst there appears, to our knowledge, to have been no published and objective cost-benefit analysis of transporting aggregates by barge we simply have the rationale provided by individuals and the industry itself.
For example the industry has moved away from barging as an economical means of transport because of the double handling and processing costs. One operator provided a cost estimate of £13 to £15 per tonne for moving sand and gravel by barge which makes this a very uncompetitive solution.
Also the publication "Gravel Extraction: History of Aggregate Extraction in the Trent Valley" states "Since the mid 1950's, haulage economics have dictated that the vast majority of sand and gravel aggregates are transported by road".


Q.14 Are you aware of any issues relating to alternative aggregates that should be considered through the Minerals Local Plan?

We believe that greater emphasis should be given to the search and support for alternative aggregates and their recycling so as to reduce the pressure on mineral reserves within the County.

Q1: Do you think any further information should be included in the overview of the area?
More reference is needed to areas already threatened by flooding, the danger of which may be exacerbated by minerals extraction.
More consideration should be made to the need to conserve agricultural land and not allow it to be destroyed by mineral extraction. Our excessive dependency on imported food and the massive destruction of agricultural land which has taken place in recent years will leave our country in a very vulnerable situation in the future.
You should most certainly hold very firmly to your avowed intentions to "uphold strong environmental principles and enhance the environment" and avoid "unacceptable adverse impacts on the natural and historic environment or human health."
Massive industrial-scale extraction in environmentally sensitive areas such as that which was proposed at Shelford would be totally unacceptablein the light of your own statements.
Q2: Do you agree with the draft vision? Are there other things we should include?
Throughout the report there are only brief passing references to recycling and development of alternatives to extraction of minerals which I think shows a sad lack of vision. Your state that there is a lack of reliable data concerning recycling within the county. Should that not be an area for your department to investigate more thoroughly and promote ?
A much stronger will and initiative to a commitment to developing alternatives to sand and gravel extraction needs to be demonstrated. The web is full of documents from other areas and countries which show a much greater commitment to reducing the reliance on extracted materials. We HAVE to take all steps NOW to conserve our planet before it is too late.
Q3: Are the strategic issues appropriate? Are there others we should consider?
The strategic issues are appropriate as long as they are strictly adhered to.

Q4: 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.
In theory it seems sensible, but it allows no room for considering the impact from potential for using more recycled products in the future. Any forecasts of the volume of minerals required are based on the present heavy reliance on extracted aggregates, whereas with more vigorous development of recycling, those needs would diminish.
Q5: Do you think the same methodology (most recent average 10 years sales) should be used for each aggregate or is there merit in using different methodologies for different aggregates?
Q6: Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries? In theory, yes, If they are still viable and will cause minimum negative impacts on nearby communities. Why destroy more countryside unnecessarily? The term "greenfield sites" seems a sadly ironic misnomer.
Q7: Should different approaches (new sites/extensions to existing permitted quarries) be adopted for individual mineral types?
Every decision must take into account the potential long term impact on the environment and existing communities.
Q8: 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?
There is a contradiction here in that you state that minerals extracted in the county are transported to Rotherham and Doncaster which can hardly minimise the transportation distances.
Q9: Would it be more appropriate to prioritise specific areas above others?
Those areas which will have the least negative impacts on communities and the environment.
Q10: Is it economical to transport mineral by river barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?
50 years ago, the River Trent was a busy highway with barges transporting goods and causing no negative impacts on communities or the environment. Sadly, over the years, this has dwindled to nothing. Any means of transport which reduces the number of heavy vehicles on the roads is an environmental priority ,even if it is more costly, and should be thoroughly investigated. However, developers, who want to maximise their profits, are likely to find arguments to evade this, even if at the outset they seem to support it!
Q11: Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?
------------------
Q12: Is there evidence to suggest that additional crushed rock reserves are required to meet demand n Nottinghamshire over the Plan period? If so please provide this evidence.
Q13: Are you aware of any other issues relating to crushed rock provision that should be considered through the Minerals Local Plan review?
You state that alternative aggregates provide for 29% of consumption and the new minerals plan should anticipate an expansion of their use.
Q14: Are you aware of any issues relating to alternative aggregates that should be considered through the Minerals Local Plan review?
As already stated elsewhere, a much greater emphasis and commitment should be demonstrated.
Q15: Should the Plan identify a specific replacement quarry (remote extension/ new site) to Dorket Head clay pit or should a criteria based policy be developed to ensure that an adequate supply of clay can be maintained over the Plan period?
------------------------
Q16: Is a criteria based policy the most suitable approach to cover the potential for new brick works and associated clay pits?
-----------------------
Q17: Should the plan seek to identify specific site allocations for Gypsum provision or should a criteria based policy be developed to ensure an adequate supply of Gypsum can be maintained over the Plan period?
------------------------
Q18: Are you aware of any issues regarding the provision of Gypsum that should be considered as part of the Minerals Local Plan review?
--------------------------------
Q19: Are you aware of any issues regarding the provision of silica sand that should be considered as part of the Minerals Local Plan review?
----------------------------------
Q20: Are you aware of any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan Review?
----------------------------------
Q21: Is there evidence to suggest that additional building stone reserves are required to meet demand in Nottinghamshire over the Plan period? If so please provide this evidence
-----------------------------------
Q22: Are you aware of any other issues relating to building stone provision that should be considered through the Minerals Local Plan review?
--------------------------------------
Q23: Are you aware of any issues relating to coal extraction that should be considered through the Minerals Local Plan review?
Fossil fuels should be a thing of the past and we should put all our energies into sustainable and renewable sources of energy.
Q24: Are you aware of any issues relating to hydrocarbon extraction that should be considered through the Minerals Local Plan review?
Hydrocarbon extraction of existing mine gas would be acceptable as it would have a positive environmental impact and involve no further land destruction, but shale gas and coal bed extraction would both have destructive impacts.
Q25: Do you agree with the proposed development management policy areas? Are there any others that should be covered?
--------------------------
Q26: Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?

Q1: Do you think any further information should be included in the overview of the area?
Villages and hamlets which are along major road routes

Q2: Do you agree with the draft vision? Are there other things we should include? Agree with draft vision.
Please confirm the geological constraints in Nottinghamshire that will impact the "vision"

Q3: Are the strategic issues appropriate? Are there others we should consider? No, it does not address hydrocarbons

Q4: 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.
Prolonged period of austerity not best for forecasting, would average of last 20 years be more appropriate.

Q5: Do you think the same methodology (most recent average 10 years sales) should be used for each aggregate or is there merit in using different methodologies for different aggregates?
Only use 20 years for sand and gravel.

Q6: Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
Yes, infrastructure in place.

Q7: Should different approaches (new sites/extensions to existing permitted quarries) be adopted for individual mineral types?
Yes, depending on impact on local communities and life of existing permitted quarries.

Q8: How important is it to maintain a geographical spread of sand and gravel quarries across the County (ie Idle Valley, near Newark and near Nottingham) to minimise the distance minerals are transported to markets?
Important for environmental impact, reducing road miles. Special provisions (landscaping, routing etc.) should be made at planning stage with enforcement methods to reduce impact on local communities. All landscaping to be carried out as soon as possible after permission given to reduce impact.

Q9: Would it be more appropriate to prioritise specific areas above others?
Yes. Were provisions already existing, landscaping and routing established to reduce impact on local communities. Good relationships often already exist between local communities and quarry companies to reduce problems.

Q10: Is it economical to transport mineral by river barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals? Barge transport has been used on the River Trent in the recent past and should be prioritised.

Q11: Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review? No.

Q12: Is there evidence to suggest that additional crushed rock reserves are required to meet demand in Nottinghamshire over the Plan period? If so please provide this evidence. Unable to reply due to insufficient information.

Q13: Are you aware of any other issues relating to crushed rock provision that should be considered through the Minerals Local Plan review? Unable to reply due to insufficient information.

Q14: Are you aware of any issues relating to alternative aggregates that should be considered through the Minerals Local Plan review? No.

Q15: Should the Plan identify a specific replacement quarry (remote extension/ new site) to Dorket Head clay pit or should a criteria based policy be developed to ensure that an adequate supply of clay can be maintained over the Plan period? Unable to reply due to insufficient information

Q16: Is a criteria based policy the most suitable approach to cover the potential for new brick works and associated clay pits? Unable to reply due to insufficient information

Q17: Should the plan seek to identify specific site allocations for Gypsum provision or should a criteria based policy be developed to ensure an adequate supply of Gypsum can be maintained over the Plan period? Unable to reply due to insufficient information

Q18: Are you aware of any issues regarding the provision of Gypsum that should be considered as part of the Minerals Local Plan review? Unable to reply due to insufficient information

Q19: Are you aware of any issues regarding the provision of silica sand that should be considered as part of the Minerals Local Plan review? Unable to reply due to insufficient information

Q20: Are you aware of any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan Review? Unable to reply due to insufficient information

Q21: Is there evidence to suggest that additional building stone reserves are required to meet demand in Nottinghamshire over the Plan period? If so please provide this evidence. Unable to reply due to insufficient information

Q22: Are you aware of any other issues relating to building stone provision that should be considered through the Minerals Local Plan review? Unable to reply due to insufficient information

Q23: Are you aware of any issues relating to coal extraction that should be considered through the Minerals Local Plan review? Yes; Carbon Capture. We suggest that consideration is given to "softening" planning for coal extraction for power plants that use carbon capture storage.

Q24: Are you aware of any issues relating to hydrocarbon extraction that should be considered through the Minerals Local Plan review? Yes; Carbon Capture. We suggest that consideration is given to "softening" planning for coal extraction for power plants that use carbon capture storage.

Q25: Do you agree with the proposed development management policy areas? Are there any others that should be covered? Routes for vehicles from quarries to avoid villages and hamlets along major roads.

Q26: Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review? Railheads should be built where quarries are adjacent to current currently used railways lines.

It would be more relevant to show the overview for the East Midlands region mineral resources and industry as a whole , including showing exact figures for input and export of materials and to show how the individual county councils work together to serve needs of the whole region.A positive example is Dorset LAA which includes import and export figures.


We are concerned about the emphasis on the value of wetlands in bio-diversity since the Trent Valley is already dominated by former sand and gravel extraction areas that are now areas of still water

Plan 2 Nottinghamshire's minerals resources incorrectly shows there to be an active mineral site East of Newark on Trent, North of the A17 in the Parish of Coddington.

There is no active mineral site at Coddington - it is a greenfield agricultural site with a high proportion of best and most versatile farmland, with adjacent woodlands. The incorrect active site should be deleted from Plan 2.

The word "rich" should be deleted from "rich rolling farmlands to the south". The Best and Most Versatile agricultural land is present in most areas of the County, and is not restricted to the south.

There is no mention of areas of tranquillity within the county. Mineral extraction has an inevitable impact on tranquillity - a feature of the countryside that is valued by so many people. Recommended reading:
http://www.cpre.org.uk/resources/countryside/tranquil-places/item/3963-give-peace-a-chance.

The word 'rich' should be deleted from 'rich rolling farmlands to the south'. The Best and Most Versatile agricultural land is present in most areas of the County, and is not restricted to the south.

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.

Would it be helpful to make reference to expected population growth Nottinghamshire and the reliance on minerals in supporting all housing and other infrastructure developments during the plan period.

It might also be appropriate to refer to relationship of mineral extraction and links to surrounding Counties as part of co operation in the import and export of minerals across county boundaries.

No comments.

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.

Any future site should be the subject of a rigorous traffic impact assessment. There should also be research into the impact on surrounding villages and infrastructures, as to drainage/flooding,damage to bridges, etc. Nineteen years is a long time and situations change, therefore the forecast should be reviewed at least every five years.

It would be useful to add some broad indication of where the main demand arises within the county and the scale and direction of in- and out-flows.

Yes. Plan 2 Mineral resources: 'The Plan must also consider mineral and other plans produced by adjacent authorities to ensure compatibility across administrative boundaries.' Plans in this consultation document only show features inside the county boundaries. Plan 2 should map resources and sites in all neighbouring counties for a zone of at least 20 miles beyond the Notts border. This will help show cumulative impacts and spatial relationships between markets and resources.

Yes. Plan 1 should be extended to cover areas beyond Nottinghamshire. Landscape, wildlife and development do not stop at the county border, but the spatial portrait map only shows features inside the county boundaries. The detail given should extend at least 20 miles into neighbouring counties to properly represent the environs on which the plan for minerals supply and demand is based, and the current status of the landscape.

'Wetlands' implies shallow marshy borderlands between water and solid land. Sand and gravel excavation often permanently destroys most land surface, creating artificial deep-water lagoons - not wetlands.

A more honest description: 'This activity has transformed large areas of the Trent and Idle Valleys into wetlands and deep lagoons and in doing so has changed the landscape character of the area. A small proportion of these former workings are now used for sports and recreation whilst others have become important wildlife habitats, however many unmodified lagoons still mark the permanent loss of former productive land surface.'

Yes. Reference is made to the extraction of gypsum. Gotham was a gypsum mining village and while it holds no strategic importance for gypsum mining now, some works remain here and in nearby East Leake and British Gypsum are still a local employer, though not of course at the levels of when the village mines were active. It is important however to learn from the legacy. Several of the old works sites have been allowed to return to a wild state and have been classified as green field rather than brown field. Furthermore with the presence of gypsum spoil the soil quality is poor which has encouraged the growth of local flora that is not choked by the invasive species that would flourish in rich soil. This has led to some of these old works sites as being registered as SSSI, and others recognised by agencies such as the Nottinghamshire Grassland and the Nottinghamshire Wildlife Trust for preservation. This is a double edged sword in that while it preserves interesting and valuable flora it has removed what are ugly and well situated housing development sites from consideration by the planning authority. This puts further pressure on less well situated and otherwise valuable green field sites to be developed instead.

I am not sure that the economic summary is properly representative of the employment situation of the County or an adequate baseline. Employment figures by the minerals industry (site and HGV drivers) need to be given. As 70 percent of land is being farmed I would expect to see agricultural employment figures as well as some data on the largest sectors as context. Important regional differences within Nottinghamshire should be mentioned. Employment levels should include some reference to youth employment levels. The baseline in the scoping report should be more in depth.

ANSWERS TO QUESTIONS FROM BILSTHORPE PARISH COUNCIL 8th JANUARY 2018

1 No
2 Yes & no
3 Yes & no
4 Yes
5 Yes
6 No, We think they should be judged on merit in line with the councils stated criteria
7 No
8 Very important
9 Not sure
10 A cost analysis is required to determine this
11 No
12 No
13 No
14 No
15 It should be a criteria based policy
16 Yes
17 Criteria based policy
18 No
19 No
20 No
21 No
22 No
23 No
24 Yes, what or who dictates what is an unacceptable impact on the environment and public?
There should be a long term impact assessment carried out and published before proceeding
25 A future impact assessment required
26 No

Nottinghamshire Minerals Local Plan - Issues & Options Consultation Jan 2018
Comments of Mick George Ltd (MGL)


Question 1: The Plan should include planned development that might affect the future
demand for minerals, such as housing, employment and the implications of HS2. For example,
MGL currently has the contract to supply concrete and fill material to the A14 construction
project in Cambridgeshire. This is severely straining existing supplies and sucking in
replacement material from many miles around. Other large infrastructure projects will have the
potential to affect areas outside of the immediate area where they are being constructed
especially if supplies of material in places like Notts are under-replenished by years of low
growth and low provision in Local Plans.

Question 2: no comment

Question 3: MGL agrees with the key strategic issues.

Question 4: In MGL's view the consultation document has not given any consideration to the
improved market conditions experienced by the industry over the last three years. PPG says
that averages of past production should not be used to project future demand since they are
backward looking. Specifically, PPG says to include planned levels of housebuilding in their
forecasts, "Local Aggregate Assessments must also consider other relevant local information in
addition to the 10 year rolling supply, which seeks to look ahead at possible future demand,
rather than rely solely on past sales. Such information may include, for example, levels of
planned construction and housebuilding in their area and throughout the country." (para 27-
064). The use of the 10 year average on its own is therefore fundamentally flawed, and should
be discontinued.
This is especially required since the averages of the last 10 years' production are heavily
skewed towards recessionary conditions which no longer apply. By basing future provision on
such a figure the Council risks building in a permanent loss of capacity at a time of increased
market demand, and expectations by communities for new houses and more jobs. If
Nottinghamshire underprovides for its own needs, it will put strain on other areas to make up
the shortfall.
2
Therefore, the most glaring omission from the analysis is any consideration of future growth,
and the distortions in supply that have occurred because of the recession. MGL does not know
why the big companies have not increased their production from Notts sites during the recovery
rather than keeping large reserves mothballed, and importing material from Lincolnshire, but
there are companies like MGL who see opportunities to meet increased demand from
Nottinghamshire and cannot do so if the County Council does not provide alternative sites.
In the company's view, the Plan must ignore the distortions of the recession and plan on the
basis of pre-recessionary conditions, or must use a statistical approach which has the benefit of
being robust, up-to-date, open and transparent, free of assumption, and easy to understand.
In this latter case the company suggests the statistical link between sand and gravel production
and housing completions is used, which can be derived from figures used in the LAA. Using
sand and gravel sales and housing completions between 2006 and 2015 gives a Pearson
Correlation Coefficient (PCC) of +0.825146 which is a very strong positive linear relationship,
and which has an equally strong basis as a causative effect. Applying the expected annual
average planned housing completion rate for the county over the plan period of 4,574 dwellings
to that PCC using the forecast function in Excel gives a return sand and gravel forecast of 2.9
Mt pa, which MGL suggests is a robust alternative to the 10 year average. MGL therefore
suggests that this figure is used to plan for future sand and gravel provision.

Question 5: no comment

Question 6: MGL strongly objects to a policy preference of extensions over new sites. NPPF
contains no such provision, whilst PPG advises that there are cons as well as pros when
considering extensions and new sites, and that therefore all proposals should be treated on
their merits. Each operator should be allowed to make their case for new working without being
hamstrung by a policy bias. The company was extremely critical of the last MLP SA exercise in
selecting sites, which produced biased results because new sites were consistently scored lower
in SD terms without proper scrutiny or consideration. For example, new accesses were scored
lower than the use of an existing access on an a priori basis, irrespective of whether there was
any empirical evidence that an existing access was substandard and caused traffic problems, or
whether a new access could be constructed to satisfy national policy. This is both inequitable
and unjustifiable.
3
The consultation proposals also raise competition issues. The company has previously remarked
in consultations on the last MLP that 75% of the county's sand and gravel reserves are
controlled by one company. NPPF advises against large reserves being tied up in few sites, and
it is considered that the principle also extends to a large overall reserve being held by one
company even if this is spread over a number of sites since the effect on supply is the same. A
policy of preferring extensions over new sites is an artificial barrier to market entry and is
undesirable as it allows incumbent companies to avoid competition with the possibility of abuse
of market power. It is also unnecessary if the declared reason for the policy is the protection of
the environment and this can be achieved by treating sites equally without affecting
competition. Let the merits of competing sites be considered on equal terms and the issue of
competition goes away. MGL may have more to say on this issue later in the Local Plan process
after taking legal advice. A bias towards extensions should therefore be dropped from policy.

Question 8: It is clearly beneficial to have a spread of sites across the county since it is SD to
supply as locally to the market as possible. All areas should therefore be considered where
mineral is present and can be accessed in an environmentally acceptable way.

Question 9: For the same reason no one area should be prioritised over another.

Question 10: Barge transport is very expensive to set up and is only used to the company's
knowledge at present in Worcestershire where it may be coming to an end shortly as reserves
at the site in question run out. If it is proposed to be used to justify a site allocation then it is
considered that the operator should be required by condition or legal agreement to use this
form of transport.

Question 11: No comment

Question 12: No comment

Question 14: Recycled aggregates have probably reached their peak in terms of contribution
to national and local markets. They provide about 28% of the market for aggregates; all
companies are involved in producing and selling them, and data from Defra shows that over
90% of C&D arisings are recycled, which means that further gains will be marginal. It is
certainly MGL's experience that material taken to its inert landfill sites is either already treated
4
to remove recyclable material, or will be treated at the landfill site. Only loads containing very
small quantities of recyclable material are tipped where it is uneconomic to carry out further
recycling. Therefore, it may be expected that the level of recycled aggregates in the market will
rise and fall with economic conditions, and the proportion used will not grow significantly.

Question 25: The list of management policy areas appears to cover everything. Please do not
repeat national policy in the Local Plan; keep it short and simple.
Comments on Sustainability Appraisal Scoping Report
As a general comment on the scoping report, it is considered that there is not sufficient
emphasis on the economic importance of minerals which would be in accordance with national
policy that minerals are essential to support sustainable economic growth and our quality of
life, and that when determining planning applications, local planning authorities should give
great weight to the benefits of the mineral extraction, including to the economy. There is also
not sufficient reference to specific implications of mineral extraction for the community's growth
aspirations.

3. Have all the relevant documents been listed in Appendix 1? If not, what others
should be included?
Under the heading of Economy and Employment Sources of information, these should be
expanded to include
* The Mineral Products Industry at a Glance 2015 & 2016 Editions
* The Foundations for a Strong Economy - Initial assessment of the contribution of the
mineral products industry to the UK economy - October 2012 Capital Economics
* Derby & Derbyshire Nottingham & Nottinghamshire LEP (D2N2) Economic Strategy

4. Have the key messages from the documents review been correctly identified in
Table 1? If not, what should be added, amended or deleted?
Under the heading Minerals Key Messages the order and emphasis should be changed as
follows,
* Secure adequate and steady supplies of minerals by and maintenance of appropriate
land banks and by incorporating planned future growth across the County;
5
* Reduce the reliance on primary minerals, by encouraging the increased use of recycled
and secondary materials;
* Safeguarding mineral resources from sterilisation;
* Maximise the benefits and minimise the impacts of minerals operations over their full life
cycle;
* Minimise environmental impacts from mineral working and promote best practice at all
sites.
Under the heading of Economy and Employment Key messages the order and emphasis should
be changed as follows,
* Mineral products are part of the unseen and unloved part of the economy, but which
employs the bulk of the workforce and generates much of the country's prosperity. It
isn't high profile or glamorous but nevertheless, without it, much of what is high profile
would simply not be possible.
* The Mineral products industry generates £6.4 Billion of Gross Value Added (GVA) and
employs 78,000 people directly. A similar number is supported indirectly.
* Using GVA per worker as a measure the sector's productivity employees are 1.6 times
more productive than the average for the UK generating over £82,000 of GVA per
worker each year.
* The industry contributes similar levels of GVA to the economy as creative, arts and
entertainment, the manufacture of electrical equipment, information service activities,
and air and spacecraft.
* The industry is also a major tax payer contributing over £1 Billion of taxes to the
exchequer each year (2012 figure).
* The industry spends over £5 Billion on suppliers each year which benefits many other
sectors by increasing economic activity in every region of the UK (2012 figure).
* The biggest customer of the industry is the construction sector, which is crucial to
providing the infrastructure that the country will depend on to supply the economic
growth that it needs to renew the economy. In total the contribution to this sector was
£144 Bn.
* In total the construction sector spends over £6 Billion pa on mineral products (over 5%
of construction turnover) which are vital to almost every type of building project (2014
figures).
* Every £1 invested in construction delivers £3 of benefit to the total economy (2012
figures).
6
* The total value of mineral products in construction is £6.4 Billion pa. Of this over £2
Billion is product flow into infrastructure products. Repair and maintenance and private
commercial property construction accounts for another £2.2 Billion and noninfrastructure
public work accounts for £800 Million.
* The total turnover of the industries which are dependent on mineral products for their
raw materials is £495 Billion pa, and support jobs for 3.4 Million people.
* About 225 Million tonnes of mineral products are extracted in the UK each year or
900,000 tonnes every working day. This represents the largest materials movements in
the economy although much of it is unseen by the public.
* The LEP target is to increase the potential growth in the number of private sector
employee jobs from 30,000 (if current trends were to continue) to 55,000 in the ten
year period to 2023, and accelerate the delivery 77,000 new homes. This investment
will play a critical role in tackling barriers to the effective operation of the economy and
enable the rapid delivery of suitable employment and housing sites that meet local
planning objectives. Evidence indicates that, without a step-change in infrastructure
investment across D2N2 the area will face serious constraints in unlocking these
ambitions.
* Planned future growth across the County will increase overall demand for minerals;
* Ensure a steady and adequate supply of minerals to support sustainable economic
growth;
* Support the rural economy and encourage rural diversification;
* Help to promote diverse range of employment opportunities and skills development;
* Encourage new and innovative technologies;
* Provide an appropriate framework for investment to enable the timely delivery of key
infrastructure (i.e. clear planning policies showing where development is likely to be
acceptable).
5. Have the implications for the SA framework been accurately assessed in Table 1.
If not, what should be added, amended or deleted?
Please see above.
6. Has all the relevant baseline data been included in Appendix 2? If not, what else
should be included?
7
Under the heading Economy and Employment - delete the last sentence and replace with
"Although the minerals sector is not a major employer this reflects its greater productivity, not
its lack of importance to the local economy, which can be judged by its support for its major
customer, the construction industry, which is in turn recognised by D2N2 economic Strategy as
one of the six priority growth sectors. It literally underpins everything else in the economy
providing essential raw materials for new infrastructure, the 55,000 jobs intended to be created
by 2023, the 77,000 homes to be constructed by 2023, and for the local economy's growth
sectors in manufacturing and services."

9. Have all the relevant sustainability issues been correctly identified in Table 2? If
not, what amendments are required?

Under Population Sustainability Issue Identified add the fact that it is intended to provide over
90,000 houses in Nottinghamshire during the plan. Under Significance to Plan add according to
BGS estimates this will require the use of about 36 Mt of aggregates (400 tonnes per house),
not including additional needs of non-housing related infrastructure, commercial, retail and
industrial development, etc.
Under Economy and Employment restate MGL's comments under question 6 and change
assessment to High Significance. How can the Plan influence this issue? - add steady and
adequate supply of minerals.
Under Climate Change Sustainability Issue Identified - add "Sustainability for minerals requires
that as far as possible, supply should be locally based. This in turn requires that mineral miles
are minimised. Current road delivery distance for aggregates (2015) is 34.9 miles and is
growing as a result of localised shortages. It is therefore essential to reduce unnecessary
imports of mineral from adjoining areas which have no advantages of greater resources or
fewer environmental constraints."
Under Significance to Plan - it is unlikely that mineral development would take place in the
worst affected greenhouse gas areas, since these are urban based. However, it is still essential
to reduce distances over which minerals are transported by making local supplies available.
Change significance to high.
8
Under How can the Plan influence this issue? - mention the need to reduce unnecessary
imports.
Under Transport - all columns repeat analysis as for climate change.
12. Do the SA objectives adequately cover the sustainability issues which are
relevant to the Minerals Local Plan? If not, what amendments are required?
Under SA Objectives -
1. Change to "Ensure that steady and adequate provision is made including for
community growth aspirations to meet local and national mineral demand."
3. Change to "Promote sustainable patterns of movement including the elimination
of unnecessary imports of minerals, and encourage the use of more sustainable
forms of transport".
7. Change to "Minimise any possible impacts on, and maximise contribution to,
climate change adaption through provision of flood relief."
8. Change to "Protect the potential of high quality agricultural land and soil
consistent with efforts to enhance biodiversity and the constraints of
restoration."
13. Change to "Support wider economic development, contribution to community
growth aspirations, local plan provision for development and local job
opportunities".
13. Are the decision-making criteria and proposed indicators appropriate? If not,
what amendments are required?
1. Change objective to "Ensure that steady and adequate provision is made including for
community growth aspirations to meet local and national mineral demand." Add "Will the
plan identify steady and adequate resources to meet local and national requirements
9
including community growth aspirations, over the plan period?" to decision making
criteria. Add "forecasts of aggregates" and "Local Plan provision figures for housing and
employment" to proposed indictors.
3. Change objective to "Promote sustainable patterns of movement including the elimination
of unnecessary imports of minerals, and encourage the use of more sustainable forms of
transport". Add "Will plan/proposals reduce levels of unnecessary imports of mineral?" to
decision making criteria. Add "levels of imports of aggregates" to proposed indictors.
7. Change objective to "Minimise any possible impacts on, and maximise contribution to,
climate change adaption through provision of flood relief." Add "Will it lead to flood relief
or provide flood storage capacity?" to decision making criteria. Add "Number of permitted
sites that provide flood relief or additional flood capacity" to proposed indictors.
8. Change objective to "Protect the potential of high quality agricultural land and soil
consistent with efforts to enhance biodiversity and the constraints of restoration." Add"
Will any loss of soil potential be offset by biodiversity gains?" and "Is loss of soil potential
unavoidable?" to decision making criteria. Add "Amount of land offset by biodiversity
gains" and "amount of land restored to original quality by use of inert fill" to proposed
indicators.
13. Change objective to "Support wider economic development, contribution to community
growth aspirations, local plan provision for development and local job opportunities".
Add" Will it contribute to Local Plan objectives for development provision?" and "Does it
fulfil forecast levels of demand?" to decision making criteria.

Contents




1. Introduction

2. Policy Response

3. Sustainability Appraisal

4. Appendices:
i. Table 2 & supporting evidence (Nottinghamshire annual dwelling completions by district).
ii. Table 3 (East Midlands and South Yorkshire, annual aggregate production by County).
iii. Table 4 (Nottinghamshire permitted reserves by area).
iv. RPS report (Sand & Gravel Provision Emissions Footprint)




Introduction

1. Context
1.1. Brett Aggregates Ltd (BAL) is the wholly owned subsidiary of Robert and Sons Limited (Brett Group), the aggregates, building materials and civil engineering business, which was established over a century ago. It is the largest independent producer of sand and gravel in the UK. BAL manages all Brett's quarry, marine dredged and recycled aggregates together with coated roadstone operations.

1.2. Following withdrawal of the Submission Draft of the Minerals Local Plan in 2017, Nottinghamshire County Council (the County) have recently published an Issues an Options document in respect of a revised MLP which is intended to be published in 2018. The County are seeking responses to a number of questions raised in the document by the 14th.January 2018.

1.3. BAL's interest in Nottinghamshire is in respect of aggregate bearing land adjacent to the River Trent at Shelford. This land represents a significant sand and gravel resource, the future development of which will ensure that Nottinghamshire, in particular the south of the County including the City of Nottingham, will be able to meet a steady and adequate supply of aggregates throughout the plan period whilst minimizing the amount of mineral miles travelled on the Count's road network by HGVs delivering aggregate. It will also provide for the delivery of aggregate using the River Trent to bring aggregate into the established industrial area of the City for use in the production of concrete. This approach accords with National Planning Policy Guidance (NPPF) in respect of providing a steady and adequate supply of mineral and sustainable development objectives.

1.4. The comments made in this submission relate only to those questions raised by the County in the Issues and Options document and do not alter BAL's submissions in respect of the withdrawn MLP. The format of this response is to address those questions which relate to BAL's area of interest. As the MLP preparation proceeds and further information becomes available other matters may arise on which BAL may wish to comment.

1.5. Subsequent to the Policy Response, Brett also include representation in regard to the sustainability appraisal (in section 8 of this document).

1.6. Primary contact with the Brett Group/ BAL in regard to this consultation is: Chris Hemmingsley, Area Planning Manager: Tel: 07484088794 or e-mail chris.hemmingsley@brett.co.uk.




Policy Response

2. Question 1. Do you think any further information should be included in the overview of the area?

2.1. Nottinghamshire has a varied population distribution and it would be helpful to show on Plan 1 the relative sizes of the principal towns and Nottingham City in terms of population size. This would be helpful in understanding where demand for aggregate is likely to arise.

2.2. It would also be useful to show where the boundaries of adjoining Mineral Planning Authorities intersect with the boundary for Nottinghamshire. This information would be helpful in understanding the spatial inter-relationship with the neighboring counties as there is significant interaction between them in respect of mineral production and demand, see later comments.


3. QUESTION 2. Do you agree with the draft vision? Are there other things we should include?

3.1. Generally BAL agrees that the draft vision is appropriate. In particular the need to ensure that mineral development is concentrated in locations that offer the greatest level of accessibility to major markets and growth areas.


4. QUESTION 3. Are the above strategic issues appropriate? Are there others we should consider?

4.1. Generally BAL agrees with the strategic issues, in particular securing a spatial pattern of mineral development that efficiently delivers resources to markets within and outside Nottinghamshire.


5. QUESTION 4. Do you think the average 10 year sales figure is 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 base to support this approach.

5.1. National Policy in relation to planning for future aggregate demand is to be found in NPPF. For an MLP to be found sound1 it is necessary for it to be
* Positively prepared
* Justified
* Effective
* Consistent with national policy


1 NPPF para 182.


5.2. The assessment of need on which the County are currently embarking is an essential component of this process as follows. For the plan to be positively prepared it must look forward on the basis that proposed development as set out in other plans and proposals will come forward and that need must be met through adequate allocation of resources in the MLP. This requirement must also be met for the MLP to be justified and effective.

5.3. The requirement for the MLP to be consistent with national policy in relation to assessing need and in particular the calculation of an adequate landbank requirement for an MLP can be found in the NPPF as follows2

* Preparing an annual Local Aggregates Assessment (LAA) based on a rolling average of 10 years sales data and other relevant local information.
* Ensuring that large landbanks bound up in a very few sites do not stifle competition.

5.4. It is clear from the NPPF that the 10 year rolling average should be a starting point and that other local factors should be taken into account. The NPPF does not detail what local factors should be taken into account but National Planning Practice Guidance gives further advice. The guidance is that relevant local information used should be that which seeks to look ahead rather than just relying on past sales. The guidance goes onto advise that such information may include levels of planned construction and house building in the local area but also " throughout the country" 3

5.5. The Planning Officers Society in conjunction with the Mineral Products Association have also produced useful practical guidance in assessing need and in particular what sort of local information should be used in considering the adequacy of the 10 year rolling average. These include4:-

* Geological resources being exhausted
* Trends and forecasts of population change including information in Local Plans on housebuilding.
* Validated data on aggregate use in construction provided by the MPA.
* Planned major infrastructure projects including those within the County and 30 miles beyond as detailed in the National Infrastructure Plan 2016- 2020. Also those projects included in Local Economic Partnerships Growth Deals and Strategic Economic Plans together with construction projects identified in District and Unitary Authority's infrastructure Development Plans. Planned highway improvement and maintenance works should also be considered.
* Local Regional and national economic forecasts from various sources.
* Information from the minerals industry on the availability of marine materials.
* Major new sources of recycled or secondary material becoming available.

2 NPPF para 145
3 Planning Practice Guidance Para 064
4 Practice Guidance on The Production and Use of LAAs May 2017 (POS/MPA Guidance)para 3.8


* New environmental constraints being identified in aggregate producing areas or in proximity to them.

5.6. In looking at the appropriateness of the rolling 10 year average as the basis for calculating future demand it is essential that the veracity of the information is examined forensically. In particular are there any factors which have influenced the data such that it does not truly reflect the production of aggregate in the County to the extent that it cannot be relied upon to predict future need. In terms of the basis of a future MLP will it result in a plan which is not justified or effective in terms of whether the plan is sound.

5.7. Geological resources being exhausted and the issue of Finningly Quarry. Finningley Quarry is situated on the northern border of Nottinghamshire where is abuts Doncaster. It should be noted that the latest Nottinghamshire LAA (Oct 2017) advises that the annual production figures for the County have been affected by production at Finningley moving across the border into some of the years covered by the latest 10 years of production5. If this situation were to continue to operate in the future, that is production moving in and out of the County then its inclusion in the 10 year rolling average would be a sound basis for predicting future need. However, the Notts LAA advises6 that the reserves in both Doncaster and Rotherham (also referred to as South Yorkshire) are extremely limited and future supplies will be coming from Nottinghamshire, in particular the quarry at Sturton le Steeple which has permitted reserves.

5.8. This being the case it is necessary to look at the impact Finningley Quarry moving across the border has had on the last 10 years production in Nottinghamshire. This can be done by looking at the Doncaster and Rotherham LAA. Whilst individual quarry production is confidential the explanation below Table 1 makes it clear that production decreased in 2010 from 0.5MT to 0.16MT probably due to production at Finningley moving across the border into Nottinghamshire. Looking at Table 1 production from 2006 to 2015 was either 0.4/5MT or 0.14/5/6MT which indicates that at the higher levels production at Finningley was in Doncaster and at the lower levels it was in Nottinghamshire. Consequently from Table 1 we can deduce which years there would have been a shortfall in the Finningley contribution to the Nottinghamshire landbank and we can calculate the annual difference this will make by averaging the higher and lower figures and subtracting the lower from the higher. The difference is calculated as 0.3MT (0.45MT less 0.15MT).


5.9. The Nottinghamshire 10 year rolling average for sand and gravel is based on the years 2007 to 2016 whilst the Rotherham and Doncaster LAA is based on 2006 to 2015. However the Notts LAA does advise that in 2016 production in Finningley was across the border in Doncaster. This means it is possible to estimate the amount of the shortfall in the Nottinghamshire 2007 to 2016 production figures attributable to production at Finningley being in Doncaster. The calculation is based on table 1:




5 Notts LAA Oct 2017 para 3.1.
6 Notts LAA Oct 2017 para 5.11



Table 1

Year 2007 2008 2009 2015 2016 TOTAL
MT 0.3 0.3 0.3 0.3 0.3 1.5

5.10. The 10 year rolling average if being used to predict future requirement in Nottinghamshire should now be calculated using a 10 year which includes the Finningley missing years as detailed above. That requires an addition 1.5MT to be added to the 17.04MT and results in an average annual sales of 1.85MT compared with the County's calculation of 17.04MT. The contribution of Finningley Quarry to the landbank is clearly a significant local factor which should be taken into account in using the 10 year rolling average as the basis for predicting future need.

5.11. Population Change and house building. The second local factor which needs to be taken into account in reviewing the 10 year rolling average is house building rates in the County and what is now planned. Whilst the County's latest LAA (October 2017) sets out the planned house building rates for the individual planning authorities in the County. It is imported to note that these are not maximum rates but are those which have been rigorously tested through the Local Plan processes including Strategic Housing Market Assessments and in some cases full Independent Examination procedures. It is also important to note that the Local Plans on which these house building rates are based were using pre 2014 Office of National Statistic (ONS) data. The 2014 when applied to the districts in Nottinghamshire will invariably lead to an increase in requirement. Consequently the house building rates in the LAA should be considered as a minimum on which aggregate requirement should be based.

5.12. At Appendix 1 is Table 2 which shows the house building rates for the local planning authority areas in Nottinghamshire over the 10 year period covering that being used by the County for the 10 year rolling average. The information contained within Table 2 has been taken from the Annual Monitoring Reports and other documents produced by the LPAs. The extracts from these documents can also be found at Appendix 1.

5.13. From Table 2 it can be seen that the average annual house building rate per LPA area over the past 10 years has been 351 units per annum. This figure is directly comparable with the average annual sand and gravel production rates calculated from the past 10 years production. Table 2 uses the future house building rates deduced by the County in October 2017 LAA7 to show that the average future rate will be 571 dwellings per annum. This is an increase of 220 dwellings per annum and represents a 63% increase. It is essential that this increase is taken as the minimum as it is based on solid evidence, it is not stated as a maximum so may be exceeded and is likely to be an underestimate based on the 2014 ONS data and the latest government advice that house building must increase. The population of Nottinghamshire including the County is expected to grow from 1.13 million in 2016 to 1.25 million in 2036. This growth will require at least the planned housebuilding detailed on Table 2 which is based on the lower pre ONS 2014 estimates and it

7 Para 5.9 Table 8


should be noted that as house building picks up following the recession the annual average rate per authority has already reached 468 dwellings per annum (2015/6) which is 81% of the planned annual requirement..

5.14. Validated data on aggregate use in construction provided by the MPA. The October 2017 LAA references the use of aggregates in house buildings as being 20% of total production. Although it should be noted that at the recent examination into the Oxfordshire MLP 35% was used. It should be noted that house building requires significant support construction such as local roads, schools, village halls etc.

5.15. Planned major infrastructure projects. The October 2017 LAA notes that no further major infrastructure projects have been identified since the production of the previous LAA (January 2017). However that LAA was based on significantly higher rolling 10 year average taking into account partly pre recession construction levels and, therefore, capturing higher level of construction. With the move to the most recent 10 year rolling average this is no longer the case and the LAA needs to recognize that planned infrastructure for the future is significantly higher than accounted for by the 10 year rolling average which now almost solely covering a recession period. An adjustment needs to be made.

5.16. Infrastructure identified in the National Infrastructure Delivery Plan 2016 to 2021 for the Nottinghamshire area are:-

* Midland Main Line. Further electrification to Nottingham.
* East Coast Mainline. Station, signaling and track works to facilitate longer new Super Express Trains.
* HS2.

It should be noted that the time period for this infrastructure plan is just 5 years and represents only 16% of the MLP plan period. Also included in the plan is reference to the Midlands Engine and the proposal for carrying out feasibility studies in respect of upgrades to the M1 and Smart motorway improvements together with improvements to the A46 Newark bypass and its intersection with the A1.

5.17. The Local Enterprise Partnership D2N2 (covering Nottingham and Derby and parts of both counties) has produced a programme which includes a target to create 50,000 jobs and to build 77,000 dwellings. The dwellings are included in Local Plan but D2N2 are intending to ensure that infrastructure delivery does not frustrate the building of the dwellings.

5.18. East Midlands airport which lies alongside the HS2 route is planning to increase from 4.3 to 10 million passengers and 300,000 to 700,000t of freight by 2040. The majority of this development will occur in the MLP plan period. A major freight terminal is also planned for the M1 J23a/24. Whilst this is in Leicestershire it lies within the 30 mile zone beyond the County boundary which the POS/MPA advice considers should be included in any future assessment for aggregate provision.



5.19. Local regional and national economic forecast. The latest MPA forecasts (February 2019) suggest that aggregate demand will have increased by 19% by 2019 compared to 2015. Infrastructure growth is expected to be 56% from 2015 to 2019. In the longer term replenishment rates for sand and gravel show that for every 100 tonnes of material used planning permissions for replacement accounts for only 56 tonnes indicating that in the future shortages of supply may become apparent.

5.20. Availability of marine materials. Nottinghamshire is a landlocked county and some distance from any marine sourced aggregate landing facility. Consequently the material is not normally used in the County.

5.21. Major new sources of recycled or secondary material. For Nottinghamshire inert waste processing (considered suitable for recycled aggregate production) has now recovered to pre recession rates. However, whilst power station ash is capable of being substituted for primary aggregates the coal fired power stations are all planned to be closed by 2025. There are 3 coal fired power stations in the County. It would, therefore, be unwise to rely on any further increase in recycled output.

5.22. New environmental constraints. No new environmental constraints which could restrict aggregate extraction in the County have been identified. Locally the ban on extraction in the Peak District National Park has been accounted for by Derbyshire planning to increase production in the rest of the County by an amount equivalent to that to be lost through lack of production in the National Park.

5.23. It is apparent from the above information that there are a number of factors pointing to the need to modify the rolling 10 year average if a robust prediction of future need is to be made. The evidence is that the figure will need to be increased on the basis that during the MLP period more aggregate will have to be exported to South Yorkshire, a greater number of dwellings will be built, more jobe created and more infrastructure built. Of these elements it has been possible to quantify numerically only the impact of the increase in future exports to South Yorkshire and house building rates. House building is considered to represent the use of only 20 to 35% of the total supply of aggregate however house building is a key component in providing dwellings for new employees who will occupy newly constructed factories and commercial premises. House building also drives infrastructure provision including roads, such as those around Newark, schools, hospitals etc. lt is, therefore proposed that the house building rates of the past 10 years be compared with aggregate use of the same period and then used to predict future aggregate requirement.

5.24. Taking the 1.85MTPA 10 year rolling average modified to take account of the Finningley Quarry production changes is comparable with an 10 year rolling average house building rate of per local authority (including Nottingham City) of 351 dwellings per annum. The future house building rate is 572 dwellings per annum. This is an increase of 63% and requires a similar increase in aggregate production going forward. This requires that the 10 year rolling average be modified to 3.02MT.


5.25. In order to understand the veracity of this calculation it is useful to look at the 10 year production rates of the counties making up the East Midlands AWP area. Table 3 at Appendix 2 shows figures taken from the LAAs for these counties. The East Midlands in 2016 had reached 70% of its pre recession production rate. Three counties were at around pre recession levels with two counties actually producing more. Lincolnshire is now producing 64 % of its pre recession level but Nottinghamshire is only at 40%. It is clear that lack of production in Nottinghamshire is holding back the East Midlands is reaching pre recession production levels. This assessment supports the need to increase the proposed landbank above that which would result from using the rolling 10 year landbank as the basis for future need prediction.


6. Question 6. Do you think extensions to existing permitted quarries should be prioritized over new greenfield quarries?

Question 8. How important is it to maintain a geographical spread of sand and gravel quarries across the Count (i.e.Idle Valley, near Newark and near Nottingham) to minimize the distance minerals are transported to market?

Question 9 Would it be more appropriate to prioritise specific areas above others?

6.1. These questions are inter related and the assessment below sets out gives the response which relates to all three questions.

6.2. It is necessary to maintain a geographical spread of quarries and permitted reserves across the County for two reasons. Firstly is the cost of transporting bulky materials relative to value that in respect of aggregates is low. This means that an appropriate geographic spread is important to ensure that the economy works effectively and additional costs are not unnecessarily incurred. It is also the case that for this reason proposed aggregate reserves should be matched geographically to where those reserves will be used. Secondly is the issue of environmental damage caused by HGV movements associated with aggregate transport.

6.3. Table 5 shows the current distribution of permitted reserves compared with spatial requirement for future house building. This is based on the information contained within the October 2017 LAA in respect of permitted reserves and Table 4 at Appendix 3 of this document.


Table 5, Comparison of permitted reserves with future house building requirement.
District S and G
(See Above) Housing requirement per
annum (see Table 2)
Newark area Newark and Sherwood 40% 16%
South Notts Nottingham City Gedling
Broxtowe Rushcliffe 0/12%* 56%
North Notts Bassetlaw Mansfield
Ashfield 28% 18%
* Currently no reserves but East Leake planning application now with a resolution to grant subject to a S.106 Agreement to be completed.

The current distribution is not sustainable in terms of transportation of aggregate and the consequences for air quality and climate change, . If extensions to quarries were to be preferred compared to opening up new sites this unsustainable distribution will continue. This is not in accordance with the NPPF guidance in respect of sustainable development.

6.4. The air quality and climate consequences have been assessed with respect to HGV movements associated with the proposed Shelford Quarry and those at Newark in the attached (Appendix 4) RPS document. This gives an indication of the problems associated with having a poor geographical distribution of mineral resources in the County.


7. Question 10. Is it economical to transport mineral by river barge and if so should proposed quarries with potential for moving sand and gravel by river barge be prioritized over others?

7.1. The River Trent has the potential to reduce transport emissions and have a positive effect on climate change. At Appendix 4 is a report which looked at the potential for air quality benefits of using the river to transport aggregate from the proposed quarry at Shelford to Colwick wharf. Air quality benefits and positive impacts on climate change are set out in the document. This clearly illustrates whilst all opportunities should be taken to allow transport of minerals on the river.

7.2. In respect of the economic consideration these will vary according to local conditions on the Trent and also economic opportunities as they arise. When considering the length of time covered by the plan period the location of a reserve which has access to the river and where proposals demonstrate that barge transport is physically capable of being undertaken without undue environmental disturbance then these sites should be given priority.

7.3. In respect of the proposals at Shelford BAL are proposing to produce concrete at the Colwick Industrial Estate and that aggregate will be transported there by barge. There is a significant positive difference in the transport rates in favour of barges. The actual details are commercially sensitive however, BAL have experience of


barging aggregate on the river Thames and are confident in the commercial opportunities in respect of Shelford and operations at Colwick..

7.4. It should be note as well as transport savings there will be added value from producing concrete at Colwick and the access to the valuable Nottingham city market from the industrial estate.


Sustainability Appraisal

8. Considerations
8.1 It is considered that overall there is a significant amount of work and information which could be scoped out of the Sustainability Appraisal. Further, there are also a number of modifications that Brett would welcome. A summary of views, suggestions and recommended improvements is outlined below:

8.2 Non Technical Summary: The issue of the uncertainty of economic viability of rail and water transport is not referenced in the main document so should not be included in the none technical summary.

8.3 Chapter 5, Questions 9, 10 and 11,
* Page 37. Under 'How can the Plan influence this issue'? In respect of Soil the conflict between biodiversity improvements and loss of productive land needs to be recognised.

* Page 38. Under "How can the Plan influence this issue? In respect of Economy and Employment there needs to be a reference to "planned" in order to tie in with existing Local Plans and other plans and policies.

8.4 Chapter 6, Questions 12, 13 and 14.
* Page 43. Para. 61 should recognize the economic implications of having insufficient mineral allocated for house building and other construction projects in terms of increased costs associated with bringing mineral from outside the County boundary and time delays.

* Page 46. Table 4, Objective 1. Needs to recognise that there are other local factors influencing annual production which may need to be taken into account in accordance with NPPF.

* Page 47. Table 4, Objective 5. Area of Green Belt lost should not be an indication of townscape and landscape. The latter is dealt with elsewhere and because mineral extraction is not considered inappropriate development in the Green Belt (NPPF) it should not be a factor for consideration here.

* Page 48. Table 4, Objective 7. Comparison of mineral reserves, existing and proposed, per area of Nottinghamshire (north, Newark area and South) with proposed house building numbers for these areas should be added as an additional indicator.

* Page 49. Table 4, Objective 8. The indicators need some consideration in whether the land can in the future be returned to agriculture by retaining soils on site.

* Page 51. Table 4, Objective 11. Reference to distances travelled by HGVs to deliver mineral needs to be added as an indicator.


* Pages 52, 53 and 54. Tables 5, 6 and 7 do not accurately reflect the situation that all of the objectives effect the three NPPF themes and internal compatibility is largely unknown for all of them. Similarly the relationship between SEA topics and SA objectives is more complicated than any table can usefully demonstrate. Therfore we suggest that the tables should be removed.


8.5 Appendices.
* Page 89. With specific reference to the comment on production levels the closure of quarries in the County and concentration of reserves in just a few quarries with one operator controlling over 60% are also likely to be factors in depressing annual production.

NOTTINGHAMSHIRE MINERALS LOCAL PLAN
ISSUES & OPTIONS CONSULTATION
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
Nottinghamshire Minerals Local Plan
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
Nottinghamshire Minerals Local Plan
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

Nottinghamshire Minerals Local Plan - Issues and Options Consultation
Dear Sir
Thank you for the opportunity to comment on the Issues and Options Consultation on the
Nottinghamshire Minerals Local Plan. The following comments are made at officer level in
consultation with the Chair of Planning Committee, and are limited to considering where the
proposed strategy may have cross border implications. It is anticipated that the Derbyshire
Minerals authority (i.e. Derbyshire County Council) will comment on other issues raised by
the consultation.
At this stage of the Nottinghamshire Minerals Local Plan, the key concern of Bolsover
Council is the protection of Creswell Crags, and its wider setting. Creswell Crags is one of the
most important archaeological and geological sites in Britain. This is reflected in its status as:
part of a Conservation Area; a Site of Special Scientific Interest; a Scheduled Ancient
Monument; and part of a grade 2 designation on the National Register of Parks and Gardens
of Special Historic Interest. In addition Creswell Crags is on the UK tentative list of potential
Word Heritage Sites;
Whilst is acknowledged that industrial dolomite is a scarce resource, Creswell Crags is clearly
a site of international importance. In addition, unlike many other forms of minerals
workings any disturbance to this important site or its setting could not be remedied by the
imposition of aftercare conditions.
Turning to our comments on specific questions in the consultation:
Overview of the Plan Area
Question 1 Do you think that any further information should be included in the
overview of the area?
Paragraph 3 of the overview of the Plan area refers to the network of important sites
for nature conservation in the county. It would be useful if this could be balanced by a
reference to the historic environment in the form of the many historic buildings;
Scheduled Ancient Monuments; and historic landscape areas in the county, many of
which (including Creswell Crags) are in the countryside.
Draft Vision
Question 2 Do you agree with the draft vision? Are there other things we should
include?
Paragraph 3 of the draft vision states 'Within geological constraints, mineral
development... It is suggested the sentence is widened to read 'Within geological and
other significant constraints, mineral development... to highlight that geological
constraints are not the only constraints on sites being developed for mineral workings.
Key Strategic Issues
Question 3 Are the above strategic issues appropriate? Are there others we should
consider?
The third strategic issue is to minimise impacts on communities. It is suggested that this
be expanded to include a reference to minimise impacts on key historic sites in the
county.
Industrial Dolomite Provision
Question 20 Are you aware of any issues regarding the provision of industrial dolomite
that should be considered as part of the Minerals Local Plan review?
Bolsover Council supports the final paragraph of this section of the consultation which
acknowledges the importance of Creswell Crags; and also the associated Plan 5 which
clearly shows the extent of the Scheduled Ancient Monument designation.
Development Management Policies
Question 25 Do you agree with the proposed development management policy areas?
Are there any others that should be covered?
Bolsover Council supports the proposals to have development management policies on
landscape character, and the historic environment, and look forward to commenting on
these in greater detail at later stages of the Plan's development.
We hope that the above observations are helpful in preparing the next stage of your Local
Plan, but please do not hesitate to get in touch if you would like to discuss them in further
detail.
Yours faithfully
Helen Fairfax
Joint Planning Policy Manager

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

No, Historic England has nothing further to add to the overview.

Q2: Do you agree with the draft Vision? Are there other things we should include?

The wider Vision statement is supported. However, the fourth paragraph indicates that 'historic assets' will contribute towards a 'greener' Nottinghamshire but the relationship between the two is not clear since the paragraph essentially relates to green infrastructure matters. 'Historic assets' should be replaced with either 'cultural heritage', 'the historic environment', or 'heritage assets and their setting' for clarity within the sentence and paragraph. In addition, in terms of cultural heritage, only the built environment is subsequently referred to so archaeological remains are not included and would need to be. It may be prudent to replace 'built' with 'historic' to ensure all aspects are addressed in the Vision.

Q3: Are the above strategic issues appropriate? Are there others we should consider?

The identified strategic issues are appropriate but it is considered there is an omission and that conservation and enhancement of the historic environment should feature within the key strategic issues to ensure the Plan takes forward a positive approach to the historic environment as required in the NPPF.

Q4 and Q5 - both regarding forecasting methodology

Historic England has no alternative methodology to suggest at this time.

Q6: Do you think extensions to existing permitted quarries should be prioritised over new greenfield sites?

Not necessarily, either option would need to demonstrate it meets the environmental, social and economic threads of sustainability as required by the NPPF, and the Plan and SA would need to demonstrate that sites taken forward have been considered in relation to alternative options.

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

Possibly, but this would depend on the outcome of any Call for Sites and subsequent site assessment and this information is not available at this time.

Q8: How important is it to maintain a geographical spread of sand and gravel across the County... to minimise the distance minerals are transported to markets?

The Plan and SA should recognise synergy between mineral extraction related traffic and the historic environment in terms of impact on heritage assets, for example through traffic impacts on Conservation Areas and heavy vehicle noise and vibration impacts on Listed Buildings.

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

Historic England is of the view that sites put forward for consideration as being taken forward in the Plan should be done so by using a robust site selection methodology. We recommend that Historic England Advice Note 3: The Historic Environment and Site Allocations in Local Plans and Historic England Good Practice in Planning 3: The setting of heritage assets (2nd edition) be used as a basis for the site selection methodology in respect of the historic environment:

<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

Q10: Is it economical to transport mineral by river barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?

Historic England has no evidence to support or oppose the matter of whether transportation of minerals by barge is economical. Any proposed quarry would need to be identified through a robust site selection methodology in relation to the historic environment, amongst others.

Q11: Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?

Historic England is not aware at this stage of any further issues that should be considered.

Q12 relating to additional crushed rock reserve requirements

Historic England has no evidence to suggest that additional crushed rock reserves are required to meet demand in Nottinghamshire over the Plan period.

Q13: Are you aware of any other issues relating to crushed rock provision that should be considered through the Minerals Local Plan review?

Historic England is not aware at this stage of any further issues that should be considered.

Q14: Are you aware of any other issues relating to alternative aggregates that should be considered through the Minerals Local Plan review?

Historic England is not aware at this stage of any further issues that should be considered.

Q15: Should the Plan identify a specific replacement quarry (remote extension/new site) to Dorket Head clay pit or should a criteria based policy be developed to ensure an adequate supply of clay can be maintained over the plan period?

Historic England is of the view that a specific replacement quarry would be the preferred option in order for full consideration of impact on heritage assets and setting to be undertaken. Sites put forward for consideration as being taken forward in the Plan should be done so based on a robust site selection methodology for the historic environment. We recommend that Historic England Advice Note 3: The Historic Environment and Site Allocations in Local Plans and Historic England Good Practice in Planning 3: The setting of heritage assets (2nd edition) be used as a basis for the site selection methodology in respect of the historic environment.

Q16: Is a criteria based policy the most suitable approach to cover the potential for new brick works and associated clay pits?

No - Historic England is of the view that any new brick works and their associated clay pits should have a specific policy, or policies, to ensure that there is no confusion between clay pits for any new brick works and the use of the same clay pits for supplying clay to existing brick works i.e. potential viability issues in addition to potentially unnecessary harm to heritage assets and their setting through, possibly, unnecessary new brick work development.

Q17: Should the plan seek to identify specific site allocations for gypsum provision or should a criteria based policy be developed to ensure an adequate supply of gypsum can be maintained over the Plan period?

Historic England is of the view that specific site allocations would be the preferred option in order for full consideration of impact on heritage assets and setting to be undertaken, particularly since the Issues and Options document sets out that specific grades of gypsum are dictated by location. Sites put forward for consideration as being taken forward in the Plan should be done so based on a robust site selection methodology for the historic environment. We recommend that Historic England Advice Note 3: The Historic Environment and Site Allocations in Local Plans and Historic England Good Practice in Planning 3: The setting of heritage assets (2nd edition) be used as a basis for the site selection methodology in respect of the historic environment.

Q18: Are you aware of any issues regarding the provision of gypsum that should be considered as part of the Minerals Local Plan?

Historic England is not aware at this stage of any further issues that should be considered.

Q19: Are you aware of any issues regarding the provision of Silica Sand that should be considered as part of the Minerals Local Plan review?

Historic England is not aware of any issues relating to provision during the proposed Plan period that should be considered. However, we would recommend that justification text in the Plan sets out that the proposed criteria based approach is being taken due to current supply forecasts for the mineral, and that the situation be revisited at the next Mineral Local Plan review/trigger to establish whether a site allocation approach may be required at that time. This would ensure that a positive approach to the historic environment could be demonstrated in the Plan.

Q20: Are you aware of any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?

Historic England has serious concerns about the extraction of dolomite in the Holbeck area due to the potential harm to heritage assets and their setting. These include Creswell Crags (Scheduled Monument), the Conservation Area, and Welbeck Abbey Registered Park and Garden.

We are of the view that due to the potential site area being limited to this area of the County, due to geological formations, and the presence of high value heritage assets which would need to be considered fully in respect of the Plan, a site allocation and specific site policy would be required within the Plan.

Consideration of the site would need to be informed by a Heritage Impact Assessment which should include a rigorous analysis of the contribution made by the setting on the significance of heritage assets in line with Historic England Good Practice Advice 3: The setting of heritage assets (2nd edition). The Minerals Plan should take into account the potential for Creswell Crags to be inscribed on the World Heritage List, together with an associated buffer zone, and have full regard to NPPF paragraph 132 guidance that harm to significant heritage assets, and their settings, should be wholly exceptional.

Heritage impact information would also need to look at how both Neanderthal and human populations across the Paleolithic used the landscape to interact with resources. Documentation should engage with recent and current research on comparable Paleolithic sites such as Bradgate Park, Leicestershire and comparable Neanderthal sites such as Glaston, Rutland. Neither Neanderthal nor Late Upper Palaeolithic populations were simply huddled in gorges and caves enclosed from their environment, they were also up on the ridges above working flint and hides and looking out across extensive steppe grassland as demonstrated in recent and current excavations in Rutland and Leicestershire. The lives of hunter gather peoples were, we believe, intimately associated with the seasonal movements of large mammals and birds through the landscape in which they operated, as supported by the cave art at Creswell. The ability to experience this monument in its extant landscape context, as well as within the enclosed space of the gorge, is central to its significance.

Any heritage impact assessment would need to focus on heritage solely with separate documentation to present any economic and social elements in order for public benefits to be considered appropriately.

Any economic information would need to consider the outcome of Derbyshire County Council application CM5/0416/4 for a further 3.23mt from new sites within the existing Whitwell site in addition to the approval of the main site for extraction to continue until 2040. In addition, the most current situation with the Thrislington site would need to be considered since it is our understanding that the site was mothballed for industrial dolomite in 2015 due to the demise in the UK steel industry and, whilst the site has been granted permission for further mineral workings they are unlikely to be industrial dolomite due to lower grade resources now available there. Any impact this may have on the supply for the national market would need to be explored during the Plan process since the existing UK supplies may be retained for national use rather than export and it may be prudent to consider alternative sources. In addition, any economic information should consider the impact of a minerals site allocation on the local economy in respect of tourism related to Creswell Crags caves and the wider heritage site.

Q21: Is there evidence to suggest that additional building stone reserves are required to meet demand in Nottinghamshire over the plan period? If so please provide this evidence.

Historic England is not aware at this stage of any further evidence that should be considered.

Q22: Are you aware of any other issues relating to building stone provision that should be considered thought the Minerals Plan Review?

Historic England is not aware at this stage of any further issues that should be considered.

Q23: Are you aware of any issues relating to coal extraction that should be considered through the Minerals Local Plan review?

Historic England is not aware at this stage of any further issues that should be considered.

Q24: Are you aware of any issues relating to hydrocarbon extraction that should be considered through the Minerals Local Plan review?

Historic England is not aware at this stage of any further issues that should be considered. The proposed criteria based policy for hydrocarbons is noted.

Q25: Do you agree with the proposed development management policy areas? Are there any others that should be covered?

Historic England supports the inclusion of 'Landscape Character' and 'Historic Environment' policy topics.

Q26: Are you aware of any issues relating to minerals safeguarding that should be considered though the Minerals Plan review?

Historic England is not aware at this stage of any further issues that should be considered.

Planning consultation: Nottinghamshire Minerals Local Plan Issues and Options; Sustainability Appraisal Scoping Report

Thank you for your consultation on the above documents dated 01 November 2017 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

1. Issues and Options

Natural England generally welcomes the Plan and is particularly pleased to note the continuing approach to encourage biodiversity-led restoration which has been followed in previous versions of the Minerals Local Plan. We have addressed the questions, posed in the document, which are of particular relevance to our interests in the natural environment:

Q1. Overview of the Plan Area
We consider that this section provides a satisfactory overview of the plan area. We particularly welcome the recognition of the importance of the designations within Sherwood Forest area including the Special Area of Conservation and the possible potential Special Protection Area (ppSPA). We would however suggest that it should be clear that there are other nationally and locally important nature conservation sites throughout the County.

Q2. Vision
Natural England generally agrees with the Vision particularly paragraph 4 which aspires to improve the natural environment, contribute to landscape-scale biodiversity delivery and create ecological networks. We suggest however that the vision also includes climate change for example "New development will take positive action to mitigate and adapt to climate change"

Q3. Strategic Issues
We consider that the strategic issues are appropriate and we welcome the inclusion of the issue to encourage biodiversity-led restoration in worked out quarries. We also agree that the restoration proposals should be addressed at the earliest possible stages of an application. We suggest however that the following should also be included within this section as the plan progresses:
* After uses should be identified which best meet local circumstances and where appropriate should include the enhancement of existing and the creation of new priority habitats, resulting in a net gain for biodiversity.

* Opportunities should be encouraged to make landscape-scale gains to biodiversity and green infrastructure enhancing wider ecological networks.
* The protection of Nottinghamshire's high quality agricultural land (Grades 1, 2 and 3a) and soil.
* Consideration of natural flood management and flood plain restoration.
* Consideration of community benefits which should include the provision of a long term legacy for environmental and heritage assets including enhanced access and green infrastructure opportunities.

Q4&5. Minerals Provision
Natural England would not comment on the aggregate demand as such but advises that the agreed aggregate apportionment should be able to be delivered without unacceptable environmental impacts.

Q6&7. Strategic Approach to New Mineral Development sites
With respect to the question of whether extensions to existing quarries should be prioritised over new greenfield sites we would suggest that the decision should consider the merits of each individual situation. In all case there should be no damage to designated sites or protected landscapes. In addition opportunities for landscape scale biodiversity and green infrastructure gains/enhancements should be considered. Likewise for approaches for different minerals sites we suggest that each site should be considered on the individual situation.

Sand and gravel provision geographical spread
Q8. In all case there should be no damage to designated sites or protected landscapes. In addition opportunities for landscape scale biodiversity and green infrastructure gains/enhancements should be considered.
Q9. When determining which specific areas to prioritise over others we suggest that it is important to consider where there are opportunities to enhance ecological networks and green infrastructure. We would suggest that a landscape scale approach should be taken for maximum benefit for nature conservation. For example the "Bigger & Better" strategy for the Trent Valley offers an important example of strategic biodiversity enhancement from the restoration of sand & gravel sites.
Q10. We would encourage opportunities for the most sustainable form of transport. The plan should reflect the NPPF emphasis on supporting development that facilitates the use of sustainable modes of transport that reduce the need for new infrastructure.

Q11 Sherwood Sandstone provision
It is important to protect the sandstone aquifer and we note that this has been included in the Sustainable Appraisal scoping report. This area includes sites which fall in close proximity to areas important for nightjars and woodlarks and that have been identified for inclusion in the Sherwood Forest ppSPA we therefore suggest that this should be considered within the plan.

Q19. Silica Sand provision
We suggest that the continued working for silica sand at The Two Oaks site should consider the impact on the nightjar and woodlark populations and the Sherwood ppSPA which are in close proximity.

Q20 Provision of industrial dolomite
We would wish to ensure the protection of the Sites of Special Scientific Interest in the Whitwell area
i.e. Ginny Spring and Whitwell Wood SSSI and Cresswell Craggs SSSI.


Q24 Hydrocarbons
For proposals to extract hydrocarbons we emphasise the importance of protecting designated sites and protected species from the direct and indirect impact of the activity including air, water, soil and

noise pollution. In cases were relatively new technologies are employed we would advise that a precautionary approach is followed.

We have particular concerns with the air quality in the Sherwood Forest area which may impact on designated sites and sensitive habitats. We would therefore need reassurance that the extraction of Coal bed methane would not result in an adverse impact on air quality.

Q25 Development Management Policy Areas
Natural England acknowledges that the proposed development management policy areas which have been set out are appropriate and suggest that the future development policies should consider the following:
Water resources and flood risk
Development management policies would need to protect habitats from water related impacts resulting from mineral development and seek enhancement, especially for designated sites. Policies should also aim to positively contribute to reducing flood risk by working with natural processes, which could result in significant gains for biodiversity and green infrastructure.
Agricultural Land & Soil Quality
The plan should safeguard the long term capability of best and most versatile agricultural land. It should make it clear that areas of lower quality agricultural land should be used for development in preference to best and most versatile land and recognise that extraction can have an irreversible adverse (cumulative) impact on BMV land. Avoiding the use of high grade land is the priority as mitigation is rarely possible, even with the best restoration standards.
Where alternative afteruses (such as forestry or nature conservation) are proposed on BMV land the methods used in restoration and aftercare should enable the land to retain its longer- term capability, thus remaining a high quality resource for the future. (For further information on soils see annexe 1 attached).

Protection and enhancement of biodiversity and geodiversity
Development management policies need to set out that any proposal that adversely affects a European site, or causes significant harm to a SSSI will not normally be granted permission to reflect the advice in paragraph 113 of the NPPF. The policies should following appropriate guidance including the Nottinghamshire Biodiversity Action Plan (BAP), Nottinghamshire Biodiversity Opportunities Mapping, and relevant Green Infrastructure strategies.

Landscape character
The policies should take account of the character of different areas and recognise the intrinsic character and beauty of the countryside. We suggest that reference is made to National Character Areas (NCAs) which provide valuable information on local landscapes (see below under comments on the Scoping Report)

Restoration and aftercare
The plan should ensure high quality restoration and aftercare of mineral sites, including for agriculture, geodiversity, biodiversity, native woodland, the historic environment and recreation.
The plan should set out the key principles for restoration including:
* Opportunities to enhance landscape character (NPPF156, 109),
* An assessment of existing and potential components of ecological networks (NPPF165),
* A strategic approach in for the creation, protection, enhancement and management of networks of biodiversity (linked to national and local targets) and green infrastructure (NPPF114),
* Rights of way and access to nature in general (NPPF 9 & 75),
* Maintaining soil quality (NPPF112)

Restoration should also include provision for appropriate aftercare of the site, especially where priority habitat has been created together with long term management agreements. We suggest that each minerals allocation is accompanied by a site brief which details the type of habitats

that restoration should achieve together with appropriate management plans.

Dear Sir/Madam

Nottinghamshire Minerals Local Plan Issues and Options

Thank you for consulting Rushcliffe Borough Council on the Minerals Local Plan Issues and Options and supporting Sustainability Appraisal Scoping Report.
Having read the document, please accept the following responses to selected questions which are pertinent to minerals developments in Rushcliffe.

Minerals Local Plan

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

Rushcliffe Borough Council considers the information within the overview sufficient as an introduction to the minerals local plan. Whilst not critical, Plan 1 (Spatial portrait of Nottinghamshire) should accurately identify the inner Green Belt around the edge of the main urban area within Rushcliffe. The removal of Green Belt land to accommodate the strategic urban extensions on land south of Clifton, at Edwalton and east of Gamston are not shown.

Q2 Do you agree with the draft vision? Are there other things we should include?

Rushcliffe Borough Council broadly supports the overarching vision.

However the vision should not prioritise proximity to major markets, growth areas and sustainable transport nodes. Whilst these are important considerations, the location of minerals development should also consider environmental constraints (including impacts on the natural environment and local communities).
Consequently the second paragraph should read:

"Within geological and wider environmental constraints, minerals development will be concentrated in locations that offer..."

Furthermore, in accordance with the mitigation hierarchy as set out in paragraph 118 of the NPPF (avoid, mitigate and last resort compensate), prioritise sites with less harmful impacts and avoids adverse impacts on the environment rather than mitigation or compensations measures such as appropriate working, restoration and after-use. The fourth paragraph should read:

"All minerals workings will contribute towards a greener Nottinghamshire by ensuring that the County's diverse environmental and historic assets are protected, maintained and enhanced through the sensitive selection of minerals sites, appropriate working, restoration and after use."

Q3 Are the above strategic issues appropriate? Are there others we should consider?

Rushcliffe Borough Council supports the key strategic issues.

Q4 Do you think the average 10 years sales figure is 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.

Rushcliffe Borough Council supports the use of the average 10 years sales figures as the basis for forecasting future aggregate demand in Nottinghamshire. This methodology is required by paragraph 145. However, other local information may be used to support this forecasting.

Q5 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?

The same methodology should be used for each aggregate, however as stated above local factors may have implications for different aggregates.

Q6 Do you think extensions to existing permitted quarries should be prioritised over new green field quarries?

Subject to any environmental constraints, Rushcliffe Borough Council support the prioritisation of extensions to existing permitted quarries rather than new green field quarries, as the infrastructure for extraction, processing and transportation is in place.

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

Yes, depending on remaining reserves, feasibility of extraction, impacts on the environment and human health which may constrain extensions to existing permitted quarries.

Q8 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?

Rushcliffe Borough Council considers the geographical spread of sand and gravel quarries across the County is important. As this will meet demand both within and outside the County, including Greater Nottingham, South Yorkshire and elsewhere in the East Midlands.

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

It would be appropriate to prioritise specific areas, depending on the socio-economic and environmental benefits these areas provide relative to each other. Whilst the proximity to markets is an important factor, it should not be the overriding consideration. Impacts on local populations and the natural environment must be equally weighted and assessed through the Sustainability Appraisal.

Q10 Is it economical to transport mineral by river barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?

Whilst Rushcliffe Borough Council has no position regarding the economics of transporting minerals by river barge, doing so clearly brings environmental benefits and reduces adverse impacts on the highway network and amenity of local residents.

If the potential for moving sand and gravel by river barge is identified as a positive factor when identifying quarries in the minerals plan, the ability to transport the mineral in this manner must be realised. Criteria based policies that support allocations and ensure they deliver sustainable development should therefore require this transportation method.

Q17 Should the plan seek to identify specific site allocations for gypsum provision or should a criteria based policy be developed to ensure an adequate supply of gypsum can be maintained over the plan period?

As permitted reserves exist at East Leake and Balderton (these should be sufficient to 2026 and 2027 respectively) and there is considerable uncertainty regarding future demand beyond this date (due to the closure of coal fired power stations which provide desulphogypsum and unknown future demand for specific grades of gypsum during the plan period), Rushcliffe Borough Council support the use of criteria based policy rather than the identification of specific site allocations.

Q18 are you aware of any issues regarding the provision of gypsum that should be considered as part of the Minerals Local Plan review?

Rushcliffe Borough Council notes that the Issues and Options consultation identifies the closure of coal fired power stations, including the Ratcliffe on Soar Power Station, by 2025 and the

subsequent reduction in supply of desulphogypsum. As recognised, this may have particular implications for the demand for Gypsum resources in Rushcliffe.

Q24 Are you aware of any issues relating to hydrocarbon extraction that should be considered through the Minerals Local Plan review?

Rushcliffe Borough Council supports the inclusion of criteria based policies which protect local communities and the natural environment from unacceptable direct and indirect environmental impacts of hydrocarbon extraction facilities during their construction and operation.

Q25 Do you agree with the proposed development management policy areas? Are there any others that should be covered?

Rushcliffe Borough Council welcomes and supports the development management policies proposed.

Sustainability Appraisal Scoping Report

Having read the SA Scoping Report, Rushcliffe Borough Council supports: the methodology proposed; the main sustainability issues identified; the documents that form the evidence base; and the SA objectives and decision making criteria. We have no detailed comments on the SA at this stage.

We look forward to reviewing the next iteration of the Minerals Local Plan and supporting SA in due course.

This concludes Rushcliffe Borough Council's representation.

If you would like to discuss our comments on the emerging plan, please feel free to contact me. Yours sincerely

John King MRTPI Planning Policy Officer
Rushcliffe Borough Council.

Re: Minerals Local Plan Consultation - Issues and Options

Thank you for consulting NWT on the above. NWT strongly welcome the MPA's continued approach in seeking to embed the large scale restoration and re-creation of biodiversity into the MLP. NWT supports the MLP's aim to create more habitat, larger areas of habitat, enhanced habitat and habitats that are linked, as this is in accordance with the aims of the Lawton Review and the Natural Environment White Paper. We have welcomed the opportunity to work with the MPA for several years on discussing the concepts behind this approach and also recognise that a great deal of good biodiversity restoration has been both approved and undertaken under the period of the current MLP. We look forward to working in a similar manner with the MPA in the future, underpinned by a shared vision for the substantive conservation and enhancement of biodiversity in the County.
In this response, I have followed the normal convention of showing the existing text from the consultation document in italics and recommended changes in bold italics.


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

NWT support the overview in general, but would like to see more explicit recognition given to the value of the range of ecologically designated sites in the County, we would suggest:


" Nottinghamshire also supports a wide network of important sites for nature conservation, the most important focused within Sherwood Forest, near Edwinstowe. This includes a Special Area of Conservation and possible future Special Protection Area, both of which hold international status. There is however a significant network of SSSIs and LWS across the County, representing the wide range of habitat types found on the diverse geology of the County and hosting diverse, and often scarce, species of flora and fauna. Some of these habitats have been created as a result of well-planned, biodiversity-led restoration of former mineral sites.


Q2 Do you agree with the draft vision? Are there other things we should include?

NWT agree strongly with the draft Vision in general, but would hope to see the addition of a specific reference to priority habitats, not least as this recognises the potential for mineral restoration to meet national and local targets for BAP/Sn41 Habitats of Principal Importance.

"All mineral workings will contribute towards a greener Nottinghamshire by ensuring that the County's diverse environmental and historic assets are protected, maintained and enhanced through appropriate working, restoration and after-use. This will result in improvements to the built and natural environment, and contribute to landscape-scale biodiversity delivery of priority habitats; and the re-connection of ecological networks. "

NWT would also like to see a reference to the need for mineral working to both reduce and mitigate for the effects of climate change.
Q3 Are the above strategic issues appropriate? Are there others we should consider?

NWT support the issues as stated, but would expect to see a stronger emphasis on environmental protection. This could fit into Issue 1 as follows:
"1. Improving the sustainability of minerals development

Ensuring that primary minerals are worked in the most sustainable manner, with strict safeguards to ensure the protection of the County's natural and historic heritage, and that the use of secondary and recycled aggregates is encouraged. Securing a spatial pattern of mineral development that efficiently delivers resources to markets within and outside Nottinghamshire."


NWT strongly welcome the MPA's approach in seeking to embed the large scale restoration and re-creation of biodiversity into the MLP. NWT supports the MLP's intention to follow the the aims of the Lawton Review and the Natural Environment White Paper. It is particularly important, however, that adequate and long term financial provision is made for the future management of the restored habitats, and also that both existing and restored habitats are protected. The biodiversity gains of a mineral scheme cannot be claimed if the habitats become lost or degraded once the statutory 5 year aftercare period has ended. Sadly, this has happened on occasions in Notts in the past. NWT would therefore suggest the following addition to the text:

"4. Biodiversity led restoration of worked out quarries

Ensuring that areas of existing high biodiversity value within proposed quarries are protected and enhanced through the scheme, and that all worked out quarries are restored to the highest standard and at the earliest opportunity through a biodiversity led approach and that the restoration proposals are addressed at an early stage of the application process. It is essential that adequate and long term provision is made for the protection and management of the restored habitats and that this is secured by legal obligations."


Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?

NWT consider that extensions are generally more sustainable from an ecological perspective than new greenfield quarries, but there may be areas of high ecological value in proximity to existing sites which should be a limiting factor as such areas of natural capital may not be replaceable. Where (chronological or spatial) extensions are proposed, they should also enable a review of the existing restoration scheme to ensure that it meets the current biodiversity-led approach and is making the best possible contribution to meeting targets for the re-creation of priority habitats. New greenfield quarries may provide opportunities for better designed, landscape-scale restoration schemes, but may also have higher impacts on existing habitat and species of value. Therefore NWT consider that each proposal must be considered on a site by site basis.

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


NWT consider that the issues described in the answer to Q6 can apply to all mineral types, particularly the presence of existing habitats and species of high ecological value and the potential for the restoration of priority habitats. Therefore the assessment should be done on a site by site basis for all mineral types.


Q8 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?

From a sustainability perspective NWT would hope to see transportation of large quantities of mineral reduced as far as possible, which might indicate that it would be better to seek to secure a spread of allocations which can serve the disparate markets, but local environmental constraints should be the principal and deciding factor.

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

Local environmental factors and impacts should be the principal consideration. Other factors such as the potential for the re-creation of landscape-scale habitats, for floodplain reconnection and natural flood management and the creation of important ecological stepping stones should all be accorded significant weight. It is essential that there is a stronger drive towards seeking to secure floodplain connection of restored sand and gravel

sites to the Trent and Idle, as part of mineral schemes, which would have significant biodiversity and flood storage benefits, as well as ensuring that mineral reserves are efficiently worked, where they lie below current floodbanks.


Q10 Is it economical to transport mineral by river barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?

NWT do not have a view on the economic viability of barge transportation, but would expect a robust assessment of the potential environmental effects to be undertaken, before such an approach could be supported. Barge transport may have benefits with regard to reductions in HGV transport and greenhouse gas emissions, but may result in local environmental impacts to biodiversity, or water quality and hydromorphology.
Q11 Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?


Extensions to existing sandstone quarries may have impacts on priority habitats and species, including heathland, woodland, and nightjar and woodlark in the ppSPA. These factors should be taken into account when considering proposals on where best to allocate extensions. It should be noted that extensions of time may also result in unacceptable extensions of impacts of noise, vibration and dust on sensitive species, so this should also be considered. . If new or extended sites were to be under consideration for allocation, their potential to contribute to larger areas of heathland and acid grassland habitats and to the strengthening of an ecological network should be a heavily weighted factor. The potential strengthening of ecological networks can be calculated through the BOM model


Q13 Are you aware of any other issues relating to crushed rock provision that should be considered through the Minerals Local Plan review?

A spatial extension to Nether Langwith Quarry within the Plan period would have substantial implications for priority magnesian limestone habitats and nearby SSSIs. The calcareous habitats of the magnesian limestone are some of the scarcest and most threatened in the County, so this should be part of the considerations for any new sites or extension. If new or extended sites are to be under consideration for allocation, their potential to contribute to larger areas of calcareous habitats and to the strengthening of an ecological network should be a heavily weighted factor. The potential strengthening of ecological networks can be calculated through the BOM model

Q15 Should the Plan identify a specific replacement quarry (remote extension / new site) to Dorket Head clay pit or should a criteria based policy be developed to ensure an adequate supply of clay can be maintained over the plan period?

NWT consider that the higher level of certainty of location and outcomes for an allocation over a criteria-based policy can be beneficial for all parties, including local communities. A

known location enables a more accurate assessment of both impacts and potential restoration benefits at an early stage. A comparison of the relative disbenefits and benefits of sites at a plan-making stage also enables a more robust sustainability appraisal If new or extended sites are to be under consideration for allocation, their potential to contribute to larger areas of priority habitats and to the strengthening of an ecological network should be a heavily weighted factor. The potential strengthening of ecological networks can be calculated through the BOM model. Habitats suitable for the brick-clay geology include native broadleaved woodland, species-rich neutral grassland, small ponds, marsh and reedbed. As with all new allocations and extensions, the potential for impacts on existing habitats and species should be a principal consideration.

Q16 Is a criteria based policy the most suitable approach to cover the potential for new brick works and associated clay pits?


For the reasons given in answer to Q16, NWT do not consider this to be the most suitable approach. If a criteria-based policy were to be developed, the ecological factors described in NWT's answer to Q15 should form part of those criteria.
Q17 Should the plan seek to identify specific site allocations for gypsum provision or should a criteria based policy be developed to ensure an adequate supply of gypsum can be maintained over the Plan period?

NWT consider that the higher level of certainty of location and outcomes for an allocation over a criteria-based policy can be beneficial for all parties, including local communities. A known location enables a more accurate assessment of both impacts and potential restoration benefits at an early stage. A comparison of the relative disbenefits and benefits of sites at a plan-making stage also enables a more robust sustainability appraisal. If new or extended sites are to be under consideration for allocation, their potential to contribute to larger areas of priority habitats and to the strengthening of an ecological network should be a heavily weighted factor. The potential strengthening of ecological networks can be calculated through the BOM model. Habitats suitable for the gypsum geology include species-rich calcareous grassland, native broadleaved woodland, small ponds and marsh. As with all new allocations and extensions, the potential for impacts on existing habitats and species should be a principal consideration.

Q18 Are you aware of any issues regarding the provision of gypsum that should be considered as part of the Minerals Local Plan review?

New or extended gypsum quarries can have an impact on existing calcareous habitats of value, and may also have the potential for the delivery of large scale calcareous and wetland habitats. An extension to underground Gypsum mining is likely to have relatively less impact on existing habitats, although impacts on water quality and quantity may be an issue. Such mines also offer little opportunity for habitat restoration, due to their relatively small footprint above ground.


Q19 Are you aware of any issues regarding the provision of Silica Sand

that should be considered as part of the Minerals Local Plan review?

There is currently an adequate supply for the Plan period and so no new allocation is needed. An extension of Two Oaks Farm Quarry could have impacts on nightjar and woodlark within the Sherwood ppSPA. It is essential that the Plan identifies the need for the Two Oaks Farm Quarry restoration to maximise its contribution to the re-creation and restoration of priority habitats, particularly heathland and acid grassland, so that it fully conforms with the principles of biodiversity-led restoration and the long term provision for the protection and management of the restored habitats is secured. These principles should inform the ROMP for this site.
Q20 Are you aware of any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?

Given that there is no exact confirmed location for the extraction of this mineral in Notts, we do not know what scarce and valuable habitats may, or may not, be present on any future proposed site. Given that the location would be in the Holwell area, however, of particular concern would be the potential loss of calcareous habitats and impacts on calcareous LWS and SSSI in that area.
Q22 Are you aware of any other issues relating to building stone provision that should be considered through the Minerals Local Plan review?


There would be ecological impacts from an extension at Yellowstone Quarry, given its proximity to LWS and a SSSI. Based on the current site, there is the potential for indirect impacts on local water courses through changes to water quality, and also on protected species. Thus any extension to the Yellowstone Quarry would need to be subject to the most robust assessment of the potential impacts on these habitats and species, both direct and indirect.


Q23 Are you aware of any issues relating to coal extraction that should be considered through the Minerals Local Plan review?

NWT agree that reworking of lagoons and tips for marketable coal fines is still a possibility For potential sites, account should be taken of the existing wildlife value and also the potential for improved restoration over that which was undertaken previously, to achieve the re-creation of priority habitats, particularly heathland and acid grassland.


Q24 Are you aware of any issues relating to hydrocarbon extraction that should be considered through the Minerals Local Plan review?

NWT note that the focus in the text remains on reducing the impacts of the techniques of mineral extraction on climate change, whilst potentially supporting extraction of energy minerals which will fundamentally contribute to further greenhouse gas emissions. There should be greater emphasis on reducing hydrocarbon extraction per se, in order to meet national and global climate change reduction targets. With regard to the greenhouse gases

produced by different extraction methods, it is not clear how comparisons would be made as to the effectiveness of the different extraction methods for the energy produced versus the greenhouse gases released. This is particularly pertinent in relation to comparisons between coal, oil, CBM, CMM and shale gas. This requires explanation and clarification.
Oil - Specific consideration is needed for the requirement of new oil extraction schemes to result in enhanced priority habitats, as in some cases the relatively small scale of such scheme, but large number of sites, has lead to incremental impacts and degradation of habitats over several years, which has led to an overall loss of biodiversity when considered in the round. This should be recognised in any future provision through a robust assessment of likely cumulative effects on biodiversity.
CMM - given the location of most suitable seams/former mine sites, specific reference should be made to the potential for disturbance to nightjar and woodlark and need to assess the cumulative effects of nitrogen emissions from burning CMM on sensitive heathland habitats.
CBM and Shale Gas - The relatively unproven nature of these technologies when applied to the UK should predicate a highly precautionary approach, particularly given the unpredictable nature of the behaviour of the sandstone geology of the County which overlays much of the northern shale beds. This unpredictability is evidenced both by deep- mine accidents in Sherwood in recent history where unexpected pockets of methane have been encountered in fractured stone and also by the above-ground subsidence effects of planned mining activity, which do not always appear to happen as predicted by the industry. Both CBM, and Shale Gas extraction through hydraulic fracturing have the potential for far- reaching impacts on the quantity and quality of surface and groundwaters and through effects of noise and vibration, which may impact valuable habitats and sensitive species. Robust and very precautionary assessment is therefore required of any such schemes.

Q25 Do you agree with the proposed development management policy areas? Are there any others that should be covered?


NWT agree strongly that DM policies are required for all the areas listed and consider that the following details should be taken into account when developing the policies:

* Water resources and flood risk
All mineral schemes should meet the requirements of the Water Framework Directive. Particular regard should be given for the potential for mineral schemes to deliver reduced flood risk through incorporating Natural Flood Management and to improve the hydromorphology or rivers through floodplain re-connection, naturalisation of channels etc.

* Agricultural land and soil quality

NWT are mindful that mineral restoration decisions can create an apparent conflict between the need for restoration to biodiversity-rich habitats and a perceived need to retain

agricultural land. NWT recognise that agricultural land and B&MV soils are a finite resource, but it is a fact that land occupied by wildlife habitats is a far smaller resource and is subject to many pressures. Wildlife-rich land also provides a diverse landscape, contributes to many ecosystem services, and is often available for informal recreation, and so is highly valued by local people. Restoring mineral sites to wildlife-rich diverse landscapes, which they can access for informal recreation, can help to compensate local communities for the disruption and disturbance caused by a mining scheme.
Based on the proposed allocations in the previous version of the draft MLP, the total area that would be affected by schemes was approximately 800ha, thus if the new Plan contains a similar level of sites, and all were restored solely to priority habitats, this would amount to 0.5% of the 140,000+ha of farmland in the County, and thus would have no meaningful impact on food security at all, but would constitute a significant gain towards biodiversity targets, as the current area of biodiversity habitats is so small. It is also important to note that this not a permanent loss of land for food production (as it would be were it to be built on for example), as all the farmland was converted from habitats in the first place. Hence, in the unlikely event of a food security crisis, the land could be brought into food production again. It is also worth noting that land previously in food production is now also being used voluntarily for biomass energy production by farmers. Whilst NWT recognises that there may be issues relating to individual agricultural holdings and how they may be affected by restoration schemes on a small number of sites, this should be considered on a site by site basis and not as a means to undermine the overarching policy of biodiversity-led restoration.

There is also a distinction to be made between protecting agricultural land specifically and protecting B&MV soils. We consider that focussing more on the protection of B&MV soils as a finite resource is a more sustainable way forward than focussing on the need for land to be in agricultural product per se. The relationship between the conservation of soils and the potential to deliver habitats is an important consideration and should reflect that several of the priority habitats such as species-rich grasslands, floodplain grazing marshes and heathland can be managed through extensive grazing, which is a form of pastoral farming.

Government Policy for more than 20 years has been to reduce the amount of land in agricultural production and to increase the land managed for conservation, through agri- environment subsidies. Mineral extraction provides a means to achieve this aim, without recourse to public funds. NWT recognises that B&MV agricultural soils are important in terms of food security, but this should be viewed in context of the many millions of pounds that have been paid to farmers to take land out of agricultural production through Countryside Stewardship Schemes by DEFRA, with the specific aim of trying to protect, conserve and increase biodiversity and also to enhance the landscape. In Nottinghamshire this equates to 112,559ha in some form of Stewardship, out of a total farmed area of 140,797ha, which is 79.9% of the farmland (Defra 2010 data).

These publicly funded environmental land management schemes (ELMS) are part of the Government drive to deliver the challenging targets in "Biodiversity 2020: A strategy for England's wildlife and ecosystem services"1. Public bodies have a statutory duty under the NERC Act to contribute to the conservation of biodiversity and to help to achieve these

1 Biodiversity 2020: A strategy for England's wildlife and ecosystem services, Department for Environment, Food & Rural Affairs, 19 August 2011

targets. Mineral extraction and the subsequent land reclamation provides an almost unique opportunity (because of its scale and the transformative potential that results from the mass movement of soils and changes to hydrology) to restore and re-create our most important BAP/Section 41 habitats on a meaningful scale, and so is an opportunity that should not be squandered.

For some habitats, conventional agricultural profiles can be restored and the habitats established on top, so that were a real food security crisis to occur, the land could be returned to intensive agriculture. These habitats could include woodlands and certain types of grassland.

Other habitats, such as heathland, are more effectively restored on thinner soil profiles, with less topsoil,. In this case the topsoil could be used either by concentrating it within some areas of the site to create deeper profiles for other habitats, or preferably used elsewhere off-site to augment and improve existing farmland. In this latter case the soils are conserved and put to better use elsewhere to increase productivity. Hence it is the soils that are of value to food production, not the area of land per se.


* Protection and enhancement of biodiversity and geodiversity

NWT welcome the strong recognition for the need for both protection and enhancement of biodiversity and geodiversity. It is essential that the Plan emphasises the requirement to follow the Mitigation Hierarchy ie. the need to prioritise the avoidance of impacts, before mitigation and compensation are considered.
NWT expect to see the recognition of the importance of all ecologically important sites, including SSSIs, the SAC, NNR the ppSPA and Local Wildlife Sites, and the need to protect them. LWS constitute irreplaceable natural capital, particularly in Nottinghamshire where we have a low coverage of SSSIs (3,135ha out of 216,000 total area of the County, which is 1.45%) compared to other Counties, so the habitats within LWS represent a crucially important biodiversity resource and are irreplaceable natural capital. If we are to achieve landscape-scale conservation in Nottinghamshire, in line with the Lawton recommendations, it is essential to protect LWS as they contain the species that will be needed to colonise the new areas of restored habitats. In addition, because the SSSI suite is nationally representative, not comprehensive, there are LWS that may be nationally important, but have not been designated as SSSIs.


There is no specific reference to air pollution in the list of DM policy areas. It may be that this would be considered under Local Amenity, however it is important to note that this is also particularly relevant to habitats too. Nitrogen deposition is considered one of the greatest threats to habitats across Europe, with particularly severe effects on habitats such as heathland with require low nutrient levels. Increases in Nitrogen act as fertilisers in such habitats leading to a loss of species diversity. For the MLP, this is particularly pertinent to sandstone extraction in the Sherwood area and to emissions from hydrocarbon extraction. The impacts of ammonia and particulate emissions should also be a consideration in DM policies.

* Airfield safeguarding

Safeguarding is obviously important but should also be underpinned by robust science and a reasonable approach, in order to prevent interpretation that prevents restoration of a wide range of wetland habitats across large areas of the County.

* Planning obligations

Planning obligations are essential in ensuring the long term protection and management of restored habitats, and developers should be expected to bring forward proposals to meet these requirements at the earliest stage, before determination.

* Restoration, afteruse and aftercare

NWT welcomes NCC's commitment in this Plan to ensure that mineral schemes can help Nottinghamshire is to meet its local and national targets for protecting, conserving and enhancing biodiversity.
It is important, to recognise that all types of mineral extraction can lead to significant habitat gains through biodiversity-led restoration, and so use should be made of the outcomes of Biodiversity Opportunity Mapping by the Biodiversity Action Group across the County. Some of these areas, such as within Sherwood Forest, have the potential to deliver restoration of lowland heath, and limestone extraction in the west of the County may contribute to the creation of calcareous grasslands, both of which habitats are internationally scarce, hence it is important that the potential for the full range of habitats being delivered through mineral restoration be explicit in the DM policy. NWT have long identified Living Landscape areas in the County where the re-creation of ecological networks is of the highest priority, many of these coincide with areas of potential mineral extraction, and so are pertinent to this Plan. A map of the Living Landscape Areas is attached.
It is also essential that the biodiversity benefits required under restoration schemes can be maintained in the long term. There is no meaningful benefit to biodiversity, landscape quality or local communities if the habitats are ploughed up, or fall out of suitable management, as soon as the aftercare period has ended. In order to achieve this, it is important to ensure that long term financial provision (or some other mechanism) to maintain those habitats is agreed before the application is determined. There have been examples of where restored habitats have been lost as a result of cessation of appropriate management after the end of the statutory aftercare period. Excellent examples of long term provision have been agreed in Nottinghamshire for some sites, and can be used as an exemplar in the future. This would not only ensure that a meaningful and lasting contribution to biodiversity targets has been made, but also that local communities can have certainty of long term landscape quality as recompense for the loss of amenity experienced as a result of the scheme. This is essential to the delivery of the biodiversity-led approach and should be explicit in DM policy.
The use of site restoration briefs at an allocation stage in the previous version of the draft MLP was an exemplary and constructive approach and should be replicated in this Plan, and the creation of priority biodiversity habitats should be the primary restoration aim for all allocations and extensions.

It is also important to recognise that mineral extraction can present opportunities to re-create habitats that are hard to re-create on intensively farmed land, due to the years of soil modification for farming that have resulted in very high nutrient levels and high alkalinity (from the addition of lime) and also the existence of extensive under-drainage infrastructure. Heathland restoration on arable land, for example, requires intensive removal of nutrients through either top-soil stripping or the growing of sacrificial crops for at least 2 years, combined with the addition of large quantities of acidic material to lower the pH. Thus large scale habitat re-creation of heathland can be far more easily, and effectively, achieved through prioritising restoration of suitable mineral sites where the substrate is acidic, and has low nutrient status, such as on colliery tips and sand quarries. This is a far more effective way to recreate these national priority habitats for the public good, as a byproduct of the private sector minerals industry, than by publicly funded schemes on land that requires substantive, and unsustainable, amelioration.
Through the BOM project it will be possible set robust habitat targets for each NCA in the County and as a result, during the development period of this new Plan it will be possible to set scientifically robust minima habitat targets that could be achieved through mineral schemes.
Using the existing NE Natural Character Area approach the key habitats for each NCA in the County are shown below, those in italics are the most difficult to re-create and/or reliant on very specific geological or topographical conditions which can often be readily achieved through mineral extraction, as described above, this can be used to inform the restoration details of the MLP.:
Sherwood: lowland heath, acid grassland, small ponds (especially for amphibians), marsh, oak-birch woodland
Southern Magnesian Limestone: calcareous grassland, ash-dominated woodland, streams, ponds, hedgerows
Coal Measures: wet grassland/floodplain grazing marsh, species-rich neutral grassland (meadows), ponds, rivers and streams, oak-dominated woodland, acid grassland/lowland heath, hedgerows, ditches
Humberhead Levels: rivers and streams, fen, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland (where it abuts the northern outreach of the sandstone), including channel re-braiding and reconnection, hedgerows, ditches.
Trent Valley and Rises: : rivers and streams, swamp, marsh, floodplain grazing marsh/seasonally wet grassland, reedbed, wet woodland, acid grassland and heath (on blown sands), including channel re-braiding and reconnection, open water, hedgerows, ditches.
Within each NCA there are also many complexities, which should be taken into account in the design of restoration schemes eg, the coal measures and magnesian limestone can occur concurrently, such as in Ashfield, leading to complex mosaics of acidic and calcareous habitats. For this reason, even with good guidance for the restoration of biodiversity as described above, it is essential that the details of restoration plans are discussed with local ecological consultees at a pre-application stage, who have the local

knowledge to make informed judgements as to what is most suitable on a site by site basis, within the overarching guidance.

Mineral extraction can provide an opportunity to reconnect rivers to their floodplains and thus to both contribute to biodiversity targets and to sustainable flood management. Connections may take the form of new channels, the installation of pipe-connections, the re-creation of meanders, reduced bank height to encourage overtopping, removal of minor floodbanks through extraction, and re-braiding of smaller watercourses. Most of these measures will also contribute to meeting a variety of WFD objectives (and requirements under the Eel Regulations) and will bring other ecosystem services benefits. DM policies should recognise this potential.

* Incidental mineral extraction

Cases have arisen previously in the County where substantive mineral extraction has been proposed as incidental to other development such as commercial fish ponds, or creation of a marina etc. NWT welcome the recognition that this requires a robust DM policy to control this type of development.

* Mineral exploration
Mineral exploration can cover large areas and may have cumulative impacts, and should be subject to robust assessment for its likely effects on habitats and species.
Please do not hesitate to contact me if you have any queries about the above or if I can provide more information. I look forward to continuing to work closely with the MPA in the development of this important Plan.
Yours sincerely,



Janice Bradley C.Env, MCIEEM Head of Conservation

cc. Nick Crouch, NCC

enc. Living Landscapes Map