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

We have been invited to participate in the Mineral Local Plan in regard to the previous MLP being withdrawn in May 2017.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

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

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

Answer: I have nothing to add to this question

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

Answer: I have nothing to add to this question

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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.

CONSULTATION ON THE NOTTINGHAMSHIRE MINERALS LOCAL PLAN ISSUES AND OPTIONS DOCUMENT
Highways England welcomes the opportunity to comment on the Nottinghamshire Minerals Local Plan (MLP) Issues and Options consultation document. We note that the new MLP will cover the period 2016 to 2036 and will replace the current, out of date MLP which was adopted in 2005.
Highways England has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). It is our role to maintain the safe and efficient operation of the SRN whilst acting as a delivery partner to national economic growth. In relation to the Nottinghamshire area, our principle interest is safeguarding the operation of the M1, A1, A52, A46, and A453, which all route through the Local Plan area.
We acknowledge the fact that minerals are a finite resource and can only be worked where they are found. However, we welcome the Council's vision for mineral development to 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". We consider that this will help to reduce the amount of freight traffic on the SRN across Nottinghamshire.
At this stage of the Local Plan process, we have limited further comments to provide other than to highlight the fact that the transportation of minerals can have the potential to generate significant volumes of HGV traffic which could negatively impact upon the operation of the SRN. This should be considered as part of the site allocation process along with the potential need for identified sites to be accompanied with a Transport Assessment.
We trust that the above is useful in the progression of the Minerals Local Plan for Nottinghamshire County Council.

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?
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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?
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Q16: Is a criteria based policy the most suitable approach to cover the potential for new brick works and associated clay pits?
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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?
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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?
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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?
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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
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Q22: Are you aware of any other issues relating to building stone provision that should be considered through the Minerals Local Plan review?
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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?
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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.

You should be sure to protect vulnerable sites and those of an historical importance.
Mineral extraction should not take place near towns or countryside where damage to the attractiveness of the area is jeopardised, as we need to protect our landscape for future generations.
Open countryside and woodlands make a huge contribution to the mental and physical health of the population, and people in towns also need to be able to enjoy spending time in unspoilt country areas.
Avoid extending mineral extraction where it will impact badly on small hamlets and villages.

Yes

The vision is laudable, but would be strengthened and therefore more achievable if it was a shared vision with other Councils in the East Midlands region

Protect the green belt by refusing to contemplate mineral extraction there unless there are very exceptional circumstances.

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

The Vision seems all encompassing and is acceptable, making reference to the main minerals in the County.

The vision is supported.

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.

Response to issues and options consultation

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

Impact on the environment and biodiversity is very important. There should also be a discussion regarding the use of recycled materials and aggregates in building, and the impact that will have on the amounts of new minerals required. Also, the future of the sites should be addressed. Where farmland is used, will it be returned to farmland?

It should be noted that there is an inherent tension between sustainable development and the irreversible extraction of finite resources, hence the increasing need to focus on recycled and secondary aggregates.

More emphasis is needed on the protection of those living close to the sites, rewording as follows: We recognise that the lifecycle of a quarry may be long in relation to the lifetimes of local residents and workers and that impacts on the local community are likely to be negative and extended. The quality of life and health of those living, working in, or visiting Nottinghamshire will be protected by all appropriate means, including site establishment, sensitive siting of plant, operating conditions and hours, HGV routing, early and staged restoration and appropriate after use.

Yes, however as with all such 'visions' there are difficult balances to be struck throughout. We would like to see Neighbourhood Plans incorporated in your Local Policy.

The MLP Vision statement about protecting quality of life and health should also cover well being, i.e. mood and mental health. Support of healthy lifestyle choices by protection and provision of tranquil open spaces for healthy recreation is consistent with 'a great place to bring up your family, fulfil your ambition, enjoy your later life'. The text should read, 'The quality of life, well being and health of those living, working in, or visiting Nottinghamshire will be protected and opportunities for supporting healthy lifestyle choices will be promoted.'

Finding new and sustainable sources of inert fill for site restoration is critical to reducing permanent loss of land surface, landscape change, and tension between the interests of biodiversity and the conservation of high quality agricultural land. It is also key to achieving significant gains in non-wetland habitat. Inert fill is necessary to supplement overburden and reject material to achieve significant proportions of restored land on sites with a high water-table.

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

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.

1 January 2018
Dear Sir/Madam
New Minerals Local Plan
I write in response to your consultation on the new Nottinghamshire Minerals Local Plan.
It is noted that it is the intention that the new Minerals Local Plan will cover a period of 19 year
from 2016 to 2036. This is the Issues & Options consultation stage and it does not consider
or identify and new sites or extensions to existing minerals extraction sites. .
The consultation asks a series of questions. I have responded below to those that are most
relevant to Nottingham City Council.
Q2 Do you agree with the draft vision? Are there other things we should include?
The vision appears to be appropriate for a Minerals Local Plan and in accordance with the
NPPF.
Q3 Are the above strategic issues appropriate? Are there others we should consider?
The strategic issues identified appear to be appropriate. However it is considered that
adverse impacts on the natural and historic environment should also form the basis of a
strategic issue.
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.
Using a rolling average of 10 years sales data accords with the NPPF although other relevant
local information, and an assessment of all supply options should also be taken into account
as part of the assessment.
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?
Planning Policy & Research
Planning Services
Loxley House
Nottingham City Council
Loxley House
Station St
Nottingham NG2 3NG
Tel: 0115 876 2561
www.nottinghamcity.gov.uk
Planning Policy Team
Place Department
Nottinghamshire County Council
County Hall
West Bridgford
Nottingham
NG2 7QP
My Ref: Notts Mineral Local Plan
Your
Ref:
N/A
Contact: Matthew Grant
Email: matthew.grant@nottinghamcity.gov.uk
Generally the same methodology should be used unless there is clear evidence to deviate
from this.
Q6 Do you think extensions to existing permitted quarries should be prioritised over new
greenfield quarries?
There should not be a presumption for either new quarries or extensions to existing where
increased capacity is required. Instead the most sustainable options should be pursued.
Q7 Should different approaches (new sites/extensions to existing permitted quarries) be
adopted for individual mineral types?
Each site/mineral type is individual and the impacts and benefits will need to be considered
on their own merits
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 logic in having a geographical spread of sand and gravel quarries across the County
as this is likely to be more sustainable, reducing transport and help meet market demand.
Q9 Would it be more appropriate to prioritise specific areas above others?
Areas with good links to the strategic transport network should be prioritised as this is likely to
be more sustainable.
Q24 Are you aware of any issues relating to hydrocarbon extraction that should be
considered through the Minerals Local Plan review?
A criteria based policy approach to be in line with the NPPF is supported. The City Council
has an adopted position on renewable energy, which is attached for your information.
If you have any queries regarding the issues raised above please do not hesitate to contact
me.
Yours sincerely
Matthew Grant
Senior Planner (Policy)
Direct line : 0115 876 2561

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

RE: NOTTINGHAMSHIRE MINERALS LOCAL PLAN ISSUES AND OPTIONS CONSULTATION

These representations to the Nottinghamshire Minerals Local Plan (NMLP) are made on behalf of our clients, Earl of Listowel & Mrs. Margaret Campbell, landowners in Nottinghamshire. Submissions to previous draft documents in respect of the NMLP have been made in respect of these landowners who retain an interest in promoting their interests at North Road Quarry for sand and gravel extraction.

Our clients wish to make representation in respect of the general issues covered in the Issues and Options Paper and also to support Tarmac's promotion of North Road Quarry as part of the Call for Sites process.

The following are offered in respect of the Issues & Options Consultation:

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

We do not agree with the draft vision. The "Vision" set out in the Consultation paper is essentially a policy review and offers little in the way of a vision. It sets out a defensive approach to the extraction of minerals, rather than an aspiration of promoting a sustainable industry in Nottinghamshire over the next 20 years.

The provision of minerals should be used not just to support the economy, as set out in the Vision, but as a driver to realise economic, social and environmental benefits and sustainable growth.

This is particularly evident given the major infrastructure projects planned for the region in the short-term over the Plan period, identified in the National Infrastructure Delivery Plan 2016-2021, and those that are likely to come forward in the longer term. The NMLP should provide sufficient flexibility and a Vision to ensure that Nottinghamshire can play a fundamental role in providing appropriate materials for these projects. Such an apporach will assist national, regional and County objectives of econimic growth through infrastructure improvement.





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Question 4: Do you think that the average 10 years 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 - the approach to forecasting proposed is fundamentally flawed. The methodology of using 10 year sales figures focuses on historic demand and not on what is likely or possible to come forward during the Plan period.

There is sufficient doubt about the basis of the information used in the Local Aggregate Assessment, and the relationships between extraction from Nottinghamshire and adjoining Authorities, to suggest that the approach should be re-considered. . Of particular concern is the apparent recent anomaly of a downturn in sales as the general economy of Nottinghamshire has recovered from the recession. This suggests that there has been a structural change in the way in which production rates are measured/considered: the implication of this is that a declining rate such as that seen is a self-serving prophecy and will result in a long-term supply that will not ensure a steady and adequate supply of aggregates.

The heavy influence on the forecast of the recession and immediate post-recession during which sales were slow to recover results in a misleading approach. A more rounded assessment is required that considers, in accordance with relevant national policy, other relevant information as well as historic sales figures. With regards to Nottinghamshire, this other information is likely to include the changing production patterns within and immediately adjacent to the County that have taken place over the last few years, and the general increase in sales figures that other counties in the region have experienced.

It is likely that the void in strategic planning and the resulting uncertainty in investment decisions has also played a role in the low sales figures attributed to the County.

In essence the approach does not adequately demonstrate that the proposed plan provision meets the NPPF (para. 145) requirement to "plan for a steady and adequate supply of aggregates". Instead, it proposes that the plan is to maintain current low levels of production. This does not provide the flexibility and vision required to encourage this important industry in the County.

Question 6: Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries.
No - the approach should be based on the sustainability merits of each proposal in accordance with the policy advocated in the NPPF. This will ensure that appropriate flexibility can be maintained to bring forward the appropriate sites in the right locations to serve the required markets. As part of this approach, the application of a locational strategy which recognises the advantages and disadvantages of new or continued operations in each of the three areas historically associated with sand and gravel extraction (the Trent


Valley near Nottingham, to the north of Newark and in the Idle Valley) would appear to be an appropriate basis for decision making.

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?
As stated above, the historic area of sand and gravel production within Nottinghamshire appears to present an appropriate basis upon which to develop a coherent minerals planning policy that will ensure that Nottinghamshire can meet and (if necessary) exceed its requirements for the next twenty years.
Question 25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
The proposed development management policy areas focus solely on environmental issues. The proposed Vision for the Plan identifies the "economic, social and environmental benefits of sustainable growth" that the identification of sites can promote. However, the development management policy areas ignore the potential social and economic factors that should be taken into account in order to secure a comprehensive decision making process. The next stage of Plan preparation should remedy this to ensure that a true and accurate consideration of sustainability can be applied through the planning process to secure the most appropriate outcome to decision making.

Call for Sites

Our clients, Earl of Listowel & Mrs. Margaret Campbell, wish to promote land at North Road Quarry (NRQ) for consideration for allocation within the emerging Nottinghamshire Minerals Local Plan. The land extends to some 74 hectares north of the A617, east of the village Kelham. The greenfield site has the potential to realise approximately 4 million tonnes of good quality Trent Valley sand and gravel suitable for production of concreting aggregate.

Our clients have granted Tarmac a formal option to take a lease of the surface and the minerals, and Tarmac have made more detailed representations in respect of the Call for Sites as part of this consultation exercise. Our clients support this submission and draw on its content in support. You will be aware that this site has previously been promoted by Tarmac (and its various precursors) as "Home Farm" at various stages of the Nottinghamshire Minerals Local Plan review process, and the landowners have been aware of and are familiar with those previous submissions.

It is proposed that the Tarmac has secured the mineral working rights and promoted the NRQ site as a direct replacement for the Company's long standing operations in the Trent Valley which have served markets to the East of Nottingham.

The suggested details of production, rates of extraction, access, method of working, restoration and all other matters of interest are as set out in the submission made by Heaton Planning on behalf of Tarmac dated 10th January 2018.


Closure

Our clients have welcomed the opportunity to make submissions in respect of the Consultation paper and look forward to further input into the preparation of the Nottinghamshire Minerals Local Plan.
Yours sincerely

W. Ryan

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

Q2. Do you agree with the draft vision? Are there other things we should include?
In response to the first part of Q2 overall, we do agree with the draft Vision. In particular, we support paragraph 4 of the draft Vision ('All mineral workings will contribute towards a greener Nottinghamshire...') and its emphasis on landscape-scale biodiversity delivery and the re-connection of ecological networks.
Landscape-scale biodiversity delivery and the re-connection of ecological networks are essential components in the fight to halt and reverse the significant and ongoing declines in biodiversity in Nottinghamshire, the UK and globally. The importance of this issue is recognised and promoted in key government publications such as the Natural Environment White Paper, the Biodiversity 2020 strategy, the National Planning Policy Framework and the new 25 Year Plan for the Environment. Mineral development has a vital role to play in delivering these aspirations, as mineral site restoration provides a unique opportunity to create large areas of priority habitat in what would otherwise, in many cases, be intensively farmed landscapes.
For more evidence and justification to underpin this approach please refer to the two "Bigger and Better" documents, published by an RSPB-led partnership in June 2015 and March 20161. The first considers the whole Trent and Tame Valley from Warwickshire to the Humber; the second specifically addresses the Newark to South Clifton area of the Nottinghamshire Trent, including the Langford Lowfields and Besthorpe Nature Reserves. Together they highlight the benefits of restoration of mineral sites for biodiversity and communities, and give examples and more detail on the rationale.
In response to the second part of Q2, we recommend that the draft Vision should explicitly address climate change, including the need to mitigate and adapt to climate change. Climate change is the most important challenge that we face in the world today and the need to mitigate and adapt to its impacts is recognised in the global 'Paris Agreement'. Furthermore, just as the UK is legally obliged to reduce greenhouse gas emissions, we also have no choice but to be prepared to adapt to the unavoidable consequences of climate change already 'locked in' over the next several decades, from past and current emissions levels. We recommend that, to address this issue, an additional sentence should be added to paragraph four of the draft Vision:
* Measures will be taken to mitigate and adapt to climate change, for example, by minimising the emission of greenhouse gas emissions in the extraction and transportation of minerals.
In addition, in the context of the location of mineral development, consideration should be given to locations that have the greatest potential to deliver strategic restoration benefits, such as flood alleviation, landscape-scale biodiversity delivery and the re-connection of ecological networks. For example, in the Grensmaas project, in the Netherlands, the extraction of 54 million tonnes of sand and gravel along a 43km stretch of the Meus / Maas River, is being strategically planned to deliver a major flood alleviation scheme, which will reduce the risk of flooding to thousands of homes, as well as creating a 1,000ha nature reserve. The same approach could potentially be applied, albeit at a smaller scale, to minerals development along the River Trent and its tributaries. To address this issue, we recommend that the following sentence is added at the end of paragraph two of the draft Vision ('Within geological constraints...'):
* Consideration will also be given to locations that have the greatest potential to deliver strategic restoration benefits.







1 https://www.rspb.org.uk/our-work/conservation/landscape-scale-conservation/sites/trent-and-tame-river-valleys

Q3. Are the above strategic issues appropriate? Are there others we should consider?
In response to the first part of Q3, overall, we agree that the strategic issues are appropriate. In particular, we support Strategic Issue 4 (Biodiversity led restoration of worked out quarries). This is because, as outlined in response to Q2, mineral development provides a unique opportunity to contribute to landscape-scale biodiversity delivery and the re-connection of ecological networks.
This opportunity will only be realised if biodiversity is a primary consideration in mineral site restoration. However, if the biodiversity value of these restored sites is to be maintained, or even further enhanced, into the future, then consideration also needs to be given to the long-term funding that will be required to support the long-term management of these sites. As such we recommend that the supporting text for Strategic Issue 4 is amended as follows:
* Ensuring 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 - and funding for long-term aftercare - are addressed at an early stage of the application process.
In response to the second part of Q3, we recommend that Strategic Issue 3, which currently focuses on minimising adverse impacts on communities, should be broadened such that it seeks to minimise all adverse impacts of mineral development. This should include adverse impacts on environmental and heritage features such as biodiversity, landscape and archaeology, in addition to adverse impacts on communities.
Minimising adverse environmental impacts is a crucial element of any planning strategy that is not currently addressed under any of the Strategic Issues in this Minerals Local Plan. Addressing this wider range of issues would provide a more direct link between the strategic objectives and the range of development management policy areas that are covered in relation to Q26. As such, we recommend that the heading for Strategic Issue 3 is changed to:
* 3. Minimise adverse impacts.
Whilst we agree that it is appropriate to use the word 'minimise' at this strategic level, when this strategic issue / objective is worked up in more detail, at a policy level, in future iterations of the Minerals Local Plan, it should promote the 'mitigation hierarchy' (as set out in paragraph 118 of the National Planning Policy Framework (NPPF)). Under the mitigation hierarchy, priority should be given to avoiding adverse effects. Mitigating (or minimising) these effects should only come into play when adverse effects cannot be avoided.
In addition, for the reasons outlined in response to Q1, mitigating - and adapting to - climate change should also be explicitly identified as a strategic issue, either as part of Strategic Issue 1 or as a stand- along strategic issue.
Q6. Do you think extensions to existing permitted quarries should be prioritised over new, greenfield quarries?
Yes. In principle, we agree with the principle of doing so as, overall, this is likely to minimise adverse effects on the wider environment and on communities. There should also be benefits to biodiversity because larger blocks of habitat can be delivered in this way, that hectare for hectare are easier and cheaper to manage and less susceptible to the impacts of climate change and other external influences.
However, if it is identified that an extension to an existing quarry is likely to have adverse effects on key features, particularly in relation to nature conservation designations and priority habitats, then consideration should be given to prioritising a new, greenfield quarry instead. It is also worth noting that the biodiversity-led restoration of new, greenfield sites has the potential to provide important 'stepping stones' for wildlife between existing areas of priority habitat, thereby helping to establish a more coherent ecological network.
Ideally, the allocation of extensions to existing quarries should provide an opportunity to review and, if appropriate, amend the overall restoration plan to ensure the best possible biodiversity-led restoration.

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?
Minimising the distance that minerals are transported is an important consideration, not least because this will help to reduce the emission of greenhouse gases, as well as reducing impacts such as noise and pollution.
Q9. Would it be more appropriate to prioritise specific areas above others?
Whilst we support the principle of maintaining a geographical spread of sand and gravel quarries in order to minimise the distance minerals are transported to markets, as outlined in response to Q8, we believe that there may be circumstances in which it would be more appropriate to prioritise specific areas above others. In particular, as indicated in response to Q1, consideration should be given to locating mineral development where it has the greatest potential to deliver strategic restoration benefits. The relative merits of minimising transportation distances and delivering strategic restoration benefits should be assessed in 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?
Although we are not in a position to comment on the economics of transporting mineral by river barge, we support this approach, in principle, on the basis that it should help to reduce greenhouse gas emissions and minimise other adverse impacts such as noise and pollution. However, consideration should be given to the potential adverse effects of this approach. For example, the installation of barge infrastructure during the operational phase of a mineral development could potentially limit longer-term, post-restoration objectives, such as flood alleviation and re-connecting the river with its floodplain.
Q24. Are you aware of any issues relating to hydrocarbon extraction that should be considered through the Minerals Local Plan review?
Yes. Among other issues, hydrocarbon extraction (especially unconventional shale-gas extraction, or "fracking") poses risks for climate change, water quality and supplies, and nature. The impacts of fracking on the UK environment are poorly understood given the novelty of the industry here, but potentially significant, and yet the Government is determined to put its weight and support behind it. We are concerned that developing unconventional gas resources including shale gas is incompatible with the UK's legal commitments on climate change. Furthermore, we are concerned that the current environmental regulatory framework does not provide adequate protection for the environment, especially as regulators are under pressure to speed up permitting processes and shale-gas extraction is a very new and largely untried process in a UK context.
We recognise the limited power that Nottinghamshire County Council has to resist further hydrocarbon developments (including shale-gas extraction) in the face of strong Government support for an expanded industry. However, a criteria-based policy governing proposals for new hydrocarbon development should specifically address:
* Protection of nature conservation assets (statutory and non-statutory sites, habitats of principal importance, and protected species) at the surface, including from potential indirect effects of pollution, noise, dust, light and water use (surface and sub-surface water resources);
* Minimising greenhouse gas emissions at site, in construction and operation including stray methane emissions from the borehole and from associated construction and operational traffic;
* Maximising sustainable water use, to minimise the need for further abstraction, or importing of new water resources from outside the area. The MLP should note in particular that the Sherwood Sandstone aquifer is closed to new abstractions at present, and large parts of Nottinghamshire are classed as being in "serious" or "moderate" water stress already. If technically feasible and subject to other environmental safeguards the MLP policy should push applicants to develop closed-loop water supply systems at site level.

Q25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
Yes, we agree with the proposed development management policy areas, in particular:
* Protecting local amenity
* Water resources and flood risk
* Agricultural land and soil quality
* Protection and enhancement of biodiversity and geodiversity
* Landscape character
* Public access
* Cumulative impact
* Airfield safeguarding
* Planning obligations
* Restoration, afteruse and aftercare
With regards to agricultural land and soil quality, the main focus should be on conserving soil quality rather than maintaining the agricultural use of the land, per se. This would facilitate the biodiversity-led restoration approach which is being promoted in the draft Plan. For example, it would allow the creation of priority wetland habitats rather than a presumption in favour of restoration to agriculture. The creation of wetland priority habitats, in particular, has the potential to conserve soil quality more effectively than an intensive agricultural after-use, particularly on peat-based soils, as there would be less risk of soil erosion. The climate mitigation benefits may also be more significant (i.e. through carbon sequestration).
With regards to airfield safeguarding, we recognise the need to minimise the area of open water and short grass adjacent to open water in these areas. However, biodiversity-led restoration should still be a priority in these areas, focussing on priority habitats that have a lower risk of bird strike compared to large areas of open water.
Any policy on the protection and enhancement of biodiversity and geodiversity should reflect the hierarchy of nature conservation designations and the mitigation hierarchy, as outlined in the National Planning Policy Framework. Any such policy should make it clear that the presumption in favour of (sustainable) development does not apply to proposed development in international and national nature conservation designations, as outlined in the NPPF, paragraph 14.
As indicated in response to Q2, any policy on restoration, afteruse and aftercare should address:
* biodiversity-led restoration;
* landscape-scale biodiversity deliver;
* re-connecting ecological networks;
* funding for the long-term aftercare and management of restored mineral sites.
In relation to mineral extraction in the Trent Valley, the policy on restoration, afteruse and aftercare should recognise the contribution that mineral restoration can make to enhancing the ecological network of the Trent Valley as a whole, not just limited to the Nottinghamshire section of the Trent Valley. It should also promote the coordinated development and restoration of clusters of mineral sites to ensure that they collectively deliver the best possible biodiversity outcomes, for example through the production of 'masterplans' for the restoration of these clusters. The policy should also take account of proposals and recommendations outlined in relevant documents and strategies such as the Trent Valley Biodiversity Opportunity Mapping, relevant National Character Areas, Living Landscapes and Futurescapes.
In response to the second part of Q25 (i.e. Are there any others that should be covered?), we believe that mitigating and adapting to climate change should be explicitly as a development management policy area, for the reasons outlined in response to Q2.