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

Setting the overall context for the Plan

- An explanation of why the plan covers 19 years, compared to the current plan which covered 9 years and the previous draft which covered 15 years? This exaggerates the need for new sites to be included in the plan.


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

- Nottinghamshire's Spatial Portrait (Plan 1, Page 10) is out of date. For example, the extent of the greenbelt needs updating to include new developments, such as those South of West Bridgford either side of Melton Road up to the Ring Road.


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

- Plan 2 (page 12) incorrectly shows an active mineral development East of Newark on Trent - there is no active mineral site at Coddington.
- Less sand and gravel will be required in the future as the construction industry continues to develop modular buildings replacing traditional bricks and mortar. The UK Government supports the use of modern modular construction methods in the White Paper "Fixing our broken housing market" (Department for Communities and Local Government, February 2017).
- The CPC supports the environmental principles of the vision, but with grave concerns about sustainable transport due to inadequate road infrastructure in the Newark area, particularly in the vicinity of the A1 / A46 / A17 junctions which already suffers from significant congestion, leading to accidents and increased transport costs for businesses.


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

- CPC strongly supports points 3 and 4, to minimise the adverse impacts on Nottinghamshire's communities and to ensure that all worked out quarries are restored to the highest standard.

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.

- There is an arithmetical error in the figures shown in table 2 (page 17). The predicted shortfall of sand and gravel should be 14.8 million tonnes, not 17.8.
- CPC does not accept that this is the most suitable methodology, bearing in mind the fluctuations in sand and gravel production over the last 10 years, indicating a continuing demand of around 1.5 million tonnes - Figure 1, Page 16.
- The use of recycled and secondary aggregates is likely to increase in the future, given the trend shown in Figure 1, Page 16.


Q5 Do you think the same methodology (most recent average 10 year sales) should be used for each aggregate or is there merit in using different methodologies for different aggregates?

- The methodology should vary between mineral types where changes in future demand patterns can be forecast, for example due to changes in technology or methods of construction that are specific to different aggregates.


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

- Yes, existing quarries should be extended first, with restoration work a condition of planning.
- Extensions to existing quarries are supported where practicable and there is no adverse environmental impact.


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

- No. CPC agrees with a criteria-based policy as a standard reference tool.



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?

- Plan 3 (page 22) of the geographical spread of sand and gravel quarries needs clarification as the grey cross-hatch shaded areas have not been included in the key.
- It is more important to consider (on a criteria basis) the impact on infrastructure and congestion.

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

- No, this should be based on the sustainability assessment of proposed sites.



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?
- The priority is for adequate infrastructure and sustainable transport. Distance from markets is less important than the local impact on traffic congestion.


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.
- Less gypsum will be available on the closure of coal-fired power stations and will also contribute to further falls in the demand for crushed limestone - Page 25..


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

- Development of the process of recycling plastic to tarmac may reduce future demand for crushed rock. (For example: https://www.curbed.com/2017/4/26/15428382/road-potholes- repair-plastic-recycled-macrebur).


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

- CPC would welcome a policy on the use of alternative aggregates and a plan for monitoring their success.

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

- CPC agrees with a criteria-based policy as a standard reference tool. However, site specific considerations should also be identified.
Q16 Is a criteria based policy the most suitable approach to cover the potential for new brick works and associated clay pits?
- CPC agrees with a criteria-based policy as a standard reference tool. However, site specific considerations should also be identified.


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?
- CPC agrees with a criteria-based policy as a standard reference tool. However, site specific considerations should also be identified.


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

- Site specific factors should be considered to ensure sustainability objectives are met.



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?

- No



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?
- No


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.

- No

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

- No



Q23 Are you aware of any issues relating to coal extraction that should be considered through the Minerals Local Plan review?
- No



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

- No



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

- Must include consideration of the adequacy of immediate and wider infrastructure to cope with existing and future traffic levels. Newark area already has major congestion issues, the slightest increase in traffic will have a major impact.
- Development in the use of recycled construction materials should be encouraged through appropriate policies.


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

- No

Issues and Options Paper

Section 2 - Setting the overall Context for the Plan

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

Yes. It is considered that the cross boundary relationship with neighbouring authorities should be identified taking into account:

1. cross boundary mineral supply from Nottinghamshire - eg to South Yorkshire, and Leicestershire in light of their identified lack of available sand and gravel resources and production capacity to meet demand over the Plan period

2. The lack of available crushed rock/limestone resource within the County and therefore the heavy reliance on import from adjoining Authority areas
3. The availability of infrastructure links - particularly good road network and therefore links to market in assisting to secure mineral supply
4. The overlap of housing, business, infrastructure and employment links with Derbyshire and Leicestershire are identified but there is currently no reference to an overlap of mineral supply issues
5. The relationship with other mineral authorities and duty to cooperate in Plan preparation should be referenced
6. The anticipated development needs for housing, employment and infrastructure provision (including HS2)

Q2 Do you agree with the Draft Vision? Are there other things that we should include?

In general terms we would support the Draft Vision. However, it is considered there are two important issues missing. Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF which states, 'Mineral Planning Authorities should plan for a steady and adequate supply of aggregates by making provision for the maintenance of landbank.... whilst ensuring that the capacity of operations to supply a wide range of materials is not compromised'. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources. Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.

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

Key Strategic Issue 1 and a locational strategy to securing mineral supply is supported. This approach maintains the spread of operations across the County and maintains a security in supply to the specific markets that these serve.

The principle of Key Strategic Issue 2 is supported. However, as referred above, the Plan should identify the anticipated demand from adjoining Authority areas.

We do not agree with Strategic Issue 4 and a 'Biodiversity led restoration' approach to all mineral operations. This is not always appropriate when balancing the needs of

the landowner and long term economic value of land post restoration. Biodiversity improvements should be sought 'where possible'. The Council's vision should adopt a more balanced stance in respect of the restoration of mineral sites taking account of the three elements of sustainability set out in the NPPF (e.g. economic, social and environmental). Tarmac do however support the vision for creating landscape-scale biodiversity resources as part of stakeholder co-ordinated initiatives (ie The RSPB Bigger Better Vision for the Trent Valley area north of Newark). This should be referred to in the strategy.

Strategic Issue 4 should also consider the opportunities which mineral extraction creates for the deposit of inert infill as part of delivering agricultural restoration in helping to meet the need for inert waste disposal in Nottinghamshire.

Minerals Provision

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.

No it is not considered that the 10 years average sales figures are the most suitable methodology for forecasting aggregate demand. National Policy states, forecasts of demand should be based on a rolling average of 10 years sales data, other relevant information and through assessment of all other supply options. The 10 years average sales are heavily influenced by the impact of the recession. In addition, the movement of production at Finningley outside the County boundary has effectively skewed the perceived sales/demand. This is particularly apparent given the picture across the East Midlands which in all other cases have seen increases in sales figures. Whilst, recycled and secondary aggregate has a role to play in meeting demand in some circumstances it cannot be relied upon for ensuring continuity in supply. In addition given the location of the County it is unlikely that demand can be met from other sources (for example marine). In light of this, the other relevant local information is particularly important in forecasting future demand in the County. We support the MPA in their previous approach which reviewed sales data pre and post- recession to give a greater appreciation of likely anticipated demand in recession and a period of economic growth.

As we have referred to above, the operational capacity of permitted operations within the County needs consideration to ensure that anticipated demand is met. A

decline in sales is not necessarily an indication of a decline in demand. Production moving outside of the County will impact upon perceived sales figures as well as sites/resource not being replaced when exhausted.

A Delivery schedule (as per previous MLP drafts) would be helpful in ensuring that sites are allocated to cover the whole Plan period. Although the landbank is sufficient at the start of the Plan period, sites will become exhausted during the Plan period and provision should be made for replacements. Tarmac have produced their own delivery schedule (enclosed with this submission) to illustrate the timescales for known reserves becoming available during the Plan period.

The Issues and Options paper states, the decline in Nottinghamshire sales of sand and gravel is a result of 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'. This statement is not substantiated or evidenced. The 9 years of public consultation (between 2008 and 2017) eventually leading to the withdrawn Nottinghamshire Draft Plan has not created a positive or stable platform for industry investment. There are numerous existing operations with logical and feasible extensions, a number of which have previously been promoted to the previous Mineral Local Plan process as well as new greenfield reserves which have been subject to Scoping Requests with the Mineral Planning Authority. Notwithstanding this, significant investment (both financial and time) is required in pre-planning processes in obtaining baseline environmental assessment work to support a planning application. The Mineral industry is only recently seeing increases in sales post-recession which provides the security/assurance in making significant financial investment to existing and new operations. In addition, it is the market factors that dictate where operations would be best placed to serve the local needs.

The Plan should not focus or specify a definitive/maximum amount of mineral provision. The sales data is an indication of demand and should not be perceived as a maximum requirement. The Plan needs to provide flexibility to support additional sites/resources coming forward during the Plan period to meet demand/operational requirements to serve existing/future markets.

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?

As above, the use of 10 years average does not accurately represent the 'local circumstance'. A decline in sales is not necessarily an indication of decline in demand. Whilst it is one consideration, the fact that the sales/supply picture within Nottinghamshire is so different from the rest of the East Midlands and the national picture indicates that the sales data alone is not a true reflection of current circumstances.

Strategic Approach to New Mineral Development

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

There needs to be allowance in the Plan for both extensions and new greenfield sites. The NPPF removed previous planning policy preference for extensions to existing operations. As a result, emerging policy should not give preference to extensions in order to be compliant with national policy. However, as we have previously stated, the Plan should provide flexibility and policy should be supportive in securing extensions to existing operations, this ensures a continuation in supply without sterilising mineral reserves. However, operational capacity constraints still apply (imposed by plant capacity or planning conditions which limit tonnages/production) which can limit the amount of resource available to meet demand and therefore there may be a requirement for green field sites in addition to extensions. It is considered that a more sustainable strategy would be a locational strategy which shows allocations and preferred areas of working for new sites in each of the three main areas for sand and gravel working (Trent Valley, north of Newark and the Idle Valley) to ensure there are sufficient operations in place to meet demand, particularly relevant where there is evidence of sand and gravel resource, reserve and production capacity decline in adjoining authority areas.

Sand and gravel provision

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 market.

It is considered that a geographical spread of sand and gravel operations is a sustainable strategy and Tarmac support this approach. These areas have historical supply markets/area demand which has not changed - i.e major growth areas which will still be providing housing, employment, infrastructure etc remain. In addition, a

number of operations spread within a locality will also ensure the continuity/maintenance of supply in the event of operational constraint or in the event of a site having to shut down/cease operating.

It is not clear why specific reference is made to the Planning Application at Barton in Fabis and the contribution this could make to future mineral supply? Current undetermined Applications at Langford and Bestwood are not referred to in the same context. It is considered that the Plan should provide factual information only at this stage, and the reference to Barton in Fabis specifically appears to give it a favourable status which is not appropriate in this context.

Plan 3 isn't very informative. It would benefit from major trunk roads being identified, major towns/growth areas labelling, and the Idle Valley showing.

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

The Locational strategy should be heavily influenced/focussed on known markets and by access to market and ease of access to the local highway network to transport mineral within and where necessary outside of the County.

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.

The difference between long distance barging to market and short distance/shuttle barging to processing plant requires a distinction.

Long Distance Barging to Market

It has not in recent years been economical to transport mineral by barge. The costs of loading / unloading and transportation are often significantly greater than conventional distribution to market by road, and is significantly less flexible to meet market demand. It is unlikely that sand and gravel operations will be developed based on barge transportation alone.

River barge transportation of sand and gravel from Besthorpe Quarry ceased in August 2013 as supply to the West Yorkshire market from North Yorkshire (including rail fed crushed rock) became more economic. The position may change in the medium to long term as supply scenarios change over time. Tarmac have therefore

retained the over wharf facility at Besthorpe in a mothballed state rather than removing the wharf facility altogether.

Short distance shuttle barging (to processing plant)

The costs of loading and unloading and provision of handling/ processing facilities significantly add to operating costs and shuttle barging over short distances are unlikely to be economic against traditional land based operations.

There may be opportunities for a shuttle barge transportation system to be adopted for working some sand and gravel resources where inadequate road access exists. Such a system may enable otherwise constrained mineral resources to be worked, but the viability does depend heavily on suitable mineral handling and processing facilities being available at the receiving end (particularly facilities for mineral processing , washing and silt disposal).

Sherwood Sandstone

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

The LAA recognises the high level of export to markets outside the County due to limited resources elsewhere. As per comments on sand and gravel, there is a need where resource exists to maintain production and operating capacity to meet demand. The Plan should identify appropriate extensions to existing operations or new sites to meet this demand. Identified demand based on sales is a minimum requirement of the Plan and it is considered there needs to be flexibility built into the Plan to allow sites to come forward. The plan should address anticipated demand from outside of the County.

The Plan should recognise the unique properties of the sand as well as markets. Colour variances as well as properties of the sand are also important factors and therefore additional reserves (as allocations or new sites) should not solely be based upon estimated demand based on sales figures.

Crushed Rock

The Plan should update the current position on Nether Langwith as Tarmac has obtained planning permission to extend the timescales for working and restoration.


It is likely that there is a wider demand for crushed rock within the County than that met by Nether Langwith. Crushed rock requirements are likely to be met from imports to meet the demand within the south of the County to minimise the distance crushed rock will need to travel.

Alternative Aggregates

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

Support for the MPA in seeking the use of alternative aggregates and the appreciation that there are limits on how far alternatives can substitute primary aggregate. It is considered whilst support for alternative aggregate should be encouraged in the Plan, the contribution should be viewed as a 'bonus' over and above the required amount of primary aggregate. This is reflective of the NPPF (para
143) which states that local Plans should take account of the, 'contribution that substitute or secondary and recycled materials and minerals waste can make'. The reference made by the MPA to the reduction in ash materials from coal fired power stations is also likely to increase the demand for primary aggregate over the Plan period to address this specific resource shortfall. The approach to recycled aggregates reflects the Mineral Products Association Long Tern Aggregates Demand and Supply Scenarios Paper which indicates that the potential for recycling has reached an optimum level (approximately 28-30% volume).

Industrial Dolomite Provision

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

Reserves of industrial dolomite are of international importance. Whilst additional resource areas do not need to be identified as an allocation, the resource within Nottinghamshire should be identified within the Plan and recognised as a proven resource to be safeguarded.

Development Management Policies

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


Yes agree that it covers all areas.


Minerals Safeguarding and Consultation Areas

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

It is considered that the Minerals Plan should define more specific Mineral Consultation Areas. The proposed approach to define consultation areas on the same scale as safeguarding areas could mean that large amounts of development will be caught within an MSA/MCA which would be onerous on developers having to potentially submit minerals assessments and the MPA in assessing the potential for impact of development on mineral resource/mineral associated infrastructure. This is contrary to the objectives of the NPPF paragraph 143. A criteria based approach to MCA's would be a more appropriate strategy. In addition Plan 7 would benefit from clearer distinction between areas of safeguarding. It is not clear where the alluvial sand and gravel is located.

As well as safeguarding mineral associated infrastructure, rail heads should be expanded to include rail heads at coal fired power stations. A wharf facility at Colwick is specifically referenced for safeguarding. Tarmac have existing wharf facilities which should also be referenced if this is the approach to be adopted by the MPA.

The importance of Local Plan's (District and Borough Council) in understanding and appreciating the role of safeguarding and defining areas/sites within Local Development Plan Documents should be explained within the Mineral Plan. The Planning system is a tiered system with the policies contained within the Mineral Plan and Local plan pertinent to the consideration of Planning Applications at County and District level. The MPA has an important role in ensuring mineral safeguarding is not perceived as just a County function but guiding and supporting Local Authorities to appreciate they also have a role to play in accordance with the Planning Practice Guidance.

Question 1: Do you think any further information should be included in the overview of the area?
1. We believe this is a succinct and useful introduction to the county. However, we would like you to say more about planned and expected development that might have implications for the future demand and supply of minerals, such as planned rates of housing growth, employment growth and the implications of HS2. For example, we know that HS2a (western corridor) will require the supply of 3 Million tonnes of concrete along its length. We do not at present know the demand for the planned eastern branch (HS2b) but we think you should mention the huge potential for increases in demand even if not all of this comes from Nottinghamshire, since it is likely to distort supply patterns for many miles around when under construction.


Question 2: Do you agree with the draft vision? Are there other things we should include?
1. You should change the term 'mineral reserves' in the paragraph on safeguarding to 'mineral resources' in line with BGS guidance and national policy.

2. You should also include mineral infrastructure in the safeguarding regime in accordance with national policy.

3. We believe the vision should be stronger about meeting the growth needs of the community;
i.e. providing a steady and adequate supply of minerals to meet objectively assessed development needs, and then say you will also make an appropriate contribution to wider local and national needs.

Question 3: Are the above strategic issues appropriate? Are there others we should consider?
1. We broadly agree with the key strategic issues as proposed.



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.
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?

1. National policy says that forecasts of demand should be based on a rolling average of 10 years sales data and other relevant local information, and an assessment of all supply options. National practice guidance says that forecasts must not be based solely on the 10 year rolling average. It is essential, especially now that we have come out of the recession, for the County Council to use this other relevant information. We are aware that the Council's change of approach is politically motivated, but it is not sound, and it is not best practice.

2. A number of things have distorted the traditional relationship between development in Nottinghamshire and sand and gravel supplies. You allude to the effects of the recession and to short term commercial decisions made by producers, which has resulted in large export volumes to Doncaster and large import volumes from Lincolnshire, and to quarries being mothballed as producers adapted to vastly difficult market conditions. This does not represent a long term sustainable supply pattern and should not be used as a straightjacket for future supply from the county, which still is the most important source of high quality sand and gravel in the region.

3. Companies have only recently had the capacity to recapitalise mothballed sites, and to look for replacements for others which had become exhausted, which takes a long time to come to fruition, and is not yet reflected in the sales figures. There is already strong evidence of industry interest in the county returning to the county, indicated by the numbers of new sites proposed for the last Local Plan process. It would be a profound mistake for the County Council to fossilise the current abnormal conditions which if not corrected will undoubtedly

lead to future underprovision of mineral contrary to the declared intentions of your draft vision and objectives, not to say national policy.

4. We commented on the failure to consider other relevant information as required by NPPF in our comment to the draft LAA in August 2017, which does not seem to have been heeded in this consultation document.


5. The LAA is indicating an annual housing completion rate of 4,574. As a reality check, we can compare the forecast with the last time 4,574 dwellings were completed which was in 2005 when 4,842 dwellings were completed. The extraction rate of sand and gravel in that year was 3.08 Mt. This would seem to suggest that the LAA 10 year rolling average of only
1.7 Mtpa is inadequate. This does not consider any of the infrastructure projects indicated in our response to question 1.
6. On this basis, the MPA considers that the County Council should plan for future sand and gravel demand of 3.0Mtpa for the plan period. By reference to your Table 2 this means that over the plan period (19 years) the requirement for sand and gravel will be 57 Mt. Deducting existing permitted reserves results in a shortfall to be proved by the Local Plan of 39.5 Mt. This means finding an additional 21.7 Mt than you have assumed.




Question 6: Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
Question 7: Should different approaches (new sites/extensions to existing permitted quarries) be adopted for individual mineral types?

1. National policy makes no reference to a preference of extensions over new sites. National practice guidance recognises the advantages and disadvantages of extensions over new sites, but stresses that each case must be decided on its merits. For these reasons we do not consider that there should be a policy preference of one type of proposal over the other, and whilst a majority of proposals will be extensions, our members are confident that they can successfully argue the merits of their sites whatever category they fall into. So we consider that the Local Plan should be neutral over the issue as the best reflection of national policy and guidance.

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

1. We consider that if resources allow, it is important to maintain a spread of workings in the areas mentioned. However, we are aware that future working in the Idle valley will be limited as resources decline. Clearly, the nearer one can get to market the more sustainable the aggregate resource is, so locating nearer to Nottingham also has SD advantages. The Newark area possesses the best resources for the future as they are more abundant and suffer from fewer strategic constraints. However, there are accessibility issues that may need to be overcome and it would greatly assist the industry in its future planning and investment decisions, to know what the views of the mpa are on this.

2. On this basis, we do not consider that one area should be prioritised over another.

3. We leave any economics of barge transport for our members to comment on individually. These facilities are very expensive to install and run, only apply to sites with easy access to the riverside, and require substantial investment at the receiving end as for rail depots. Our view is that whilst there are clear advantages to this form of transport, it should not from the basis of any judgment on the acceptability of proposals in isolation. Road transport of mineral will continue to predominate for the foreseeable future.




Question: 11 Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?

1. We have already answered this in relation to questions 4 & 5 above.


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.

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

1. Demand for crushed rock is increasing and has returned to pre-recession levels across the country. We cannot comment on the reason why the site mentioned is not operational, neither do we have any evidence that more rock is required. However, no doubt following your call for sites, evidence may come to light of further need, and it would be up to any promoters of other sites to justify that.

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

1. The role of recycling has in the industry's view reached a level where supplies will rise and fall with the level of construction activity. In its paper on Long-Term Aggregates Demand & Supply Scenarios 2016-30, the Mineral Products Association (MPA) said "All supply scenarios described in this paper assume that recycled and secondary aggregates supplies grow in line with construction trends, not faster. The view is that the potential for recycling has already reached a high level, and that if further improvements are possible, these are expected to remain incremental in volume terms."

Question: 19 Are you aware of any issues regarding the provision of Silica Sand that should be considered as part of the Minerals Local Plan review?

1. We agree that a criteria based approach to policy is the best solution for this important industrial mineral given it is national policy that a stock of permitted reserves of at least 10 years is required to support the level of actual and proposed investment. However, if further sites are promoted in the call for sites we would expect the County Council to take a sympathetic approach to need assuming environmental impact was acceptable.


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?

1. Clearly, the importance of this industrial mineral is recognised by the County Council and we have nothing further to add to the approach we have advocated for silica sand, except to say that since dolomite is a refractory product, it makes sense to treat it in similar terms to

cement and allow for a minimum stock of permitted reserves of at least 15 years to reflect the higher levels of investment involved.

Question 21: 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.
Question 22: Are you aware of any other issues relating to building stone provision that should be considered through the Minerals Local Plan review?

1. We agree that a criteria based approach to this mineral is justified because of its special qualities. In general, production of dimension stone is rising in the UK, not only for the repair of historic buildings and structures, but also for new-build projects. Although the industry has traditionally been small scale there are an increasing number of larger producers (most of whom are now MPA members) and we consider that restricting sites to being small, or for a local market or for only repair work, is not justified. NPPF policy does not restrict the development of dimension stone production; the description of the industry as small scale is meant to reflect its historic role and impact, but not its future development, for which the MPA considers there should be no policy restriction. The industry believes individual proposal should be treated on their merits in accordance with national policy and guidance.

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

1. We agree that the list of management policy areas is comprehensive, and we would ask that in formulating local policies, you do not merely repeat national policy, and that if you cannot improve upon the national approach then the Local Plan should defer to the wording of NPPF.

Question 26: Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?

1. The summary of issues for mineral and infrastructure safeguarding is comprehensive and we would encourage you to closely follow the advice of the BGS in this matter, not only in respect of prior extraction, but also in respect of the equally important and often ignored, issue of sterilisation by proximity.

Nottinghamshire Minerals Local Plan, Issues and Options Consultation East Leake Parish Council Response, January 2018

The East Leake Parish Council wish to express concerns in respect to the council's new Minerals Local Plan and make comments in respect of some aspects of mineral extraction that are already in the public domain.

1) Extension of East Leake Quarry towards Rempstone.

The extraction of Sand and Gravel from East Leake Quarry has been going on for a number of years and as the local Parish Council we have had an effective communication arrangement with the local management. The quarry is now going to move the extraction area towards Rempstone which makes sense in that it extends the life of the quarry and makes use of the existing plant on the site. However there are local concerns that do not seem to be taken into account. These are:

1a) The existing quarry working has identified several Saxon Burials in the area that has been quarried - these at the time were something of a surprise, but perhaps it should not have been as the Saxon Wipentake based on Court Hill on the edge of East Leake Golf Course was responsible for the name "Rushcliffe" which is that of our local Borough Council.

1b) The very old maps show a Roman track from the Fosse Way to the River Soar. This Roman Route passes through the proposed extension of the Quarry and the existing quarry in the form of a footpath, and can be traced to the Soar in the Kingston area. Evidence of the Roman use of this was verified when some Roman artefacts were found during excavation of the minerals in the existing quarry.

1c) Whilst the company operating the quarry are well briefed with respect to the likelihood of similar findings as they move eastwards towards Rempstone, there does not appear to be any recognition of the importance of this site as a likely source of ancient artefacts being found and perhaps damaged by the extraction process, neither does there appear to be any concern for the line of the public footpath that historically followed the Roman track but has not been required to be re-instated to the original line as part of the site restoration.

1d) The existing quarry site has, this last year, been getting a lot of publicity due to the migrating "Bee-Eater'' which was widely reported in the local and national press. Whilst this was very exciting for Bird Watchers, there was local concern that, whilst a local famer provided a field for parking, this involved the public visiting the area to cross over the busy A6006 as there is no public parking area in or near the existing quarry site to enable the public with their binoculars to have reasonable access to view the wild-life that has taken up residence as the quarry workings are restored to become a wild-life 'haven' in the area. It seems as though the restoration plan for the site is not maximizing for the public the full benefit of the "after life" of the quarry, which is an opportunity missed to encourage people to have long-term benefit from the mineral extraction.

2) Mineral extraction by mining:

2a) The largest employer in East Leake is British Gypsum (Saint Gobain) which is famous for it's Plasterboard and 'Bag Plaster' that is vital to the building industry.

2b) For a number of years the Plasterboard has made use of De-Sulpher Gypsum which is a by-product of using Limestone filtration on chimney gases at Coal fired Power Stations. The nearest local supply is from Ratcliffe Power Station, with additional material being brought by rail from other Coal fired Power stations and other British Gypsum factories outside Nottinghamshire making use of De-Sulpher Gypsum from other power stations. However, the government has said that the Coal Fired power stations need to be closed down as part of the 'Global Warming' initiative, and H.M.G. have said all U.K. coal fired stations will be closed by 2025 giving a maximum seven year life to the facilities generating De-Sulpher Gypsum.

2c) This decision has a major impact on the Plasterboard manufacturing industry. The response of the Plasterboard manufacturers is to make more use of mined Gypsum. British Gypsum has already had permission to extend the East Leake Gypsum mine to meet the needs of the building industry, but the demand is bound to increase as 2025 approaches unless a suitable alternative to De-Sulpher Gypsum can be found.

2d) The Parish Council has serious concerns as to the approach of Nottinghamshire C.C. to address the situation and the knock-on effect in the East Leake Area in terms of both Employment and Business Rates. It has recently been announced that our County Council has not been selected as one of the 10 pilot areas to take part in the government scheme to change the way Business rates are retained by the local area with them saying by 2021 (i.e. 4 years before the 2025 deadline for coal fired power stations to shut down) 75% of business rates will be retained locally to replace government grants. This may have a significant impact on the local Council Tax for East Leake residents as

Ratcliffe Power Station and British Gypsum are the top two companies in the amount of Business Rates they pay in the Borough of Rushcliffe, and with the power station closing in its present form and British Gypsum having to accommodate a large reduction in the De-Sulpher raw material the tax income would seem to be totally unpredictable. The County Council does not seem to have a contingency plan as to how we are to overcome the potential loss of jobs in the area and an uncertainty as to how much government funding will be available in the post 20-21 arrangement to support the local community and the impact on Council tax.

2e) The Parish Council is concerned about the impact of potential Gypsum mining on the area which has suffered major housing development in recent years, and especially in the recent Rushcliffe allocation of land for housing. The policy for Gypsum mining is that houses should not be built above a mined area as the Gypsum can become unstable as has been demonstrated locally by, for example, the collapse of an old mine below the west Leake hills that collapsed leaving a pond that is said to be 20ft deep. The Parish Council would like to have the plans for both existing and potential new mining in the area put in the public domain so that the danger of housing being built over a potentially unstable mine can be identified early in the housing land application. A useful 20 year projection of potential mining area would back up the concern that we are getting excessive amounts of housing and increasing the risk that our local employer (British Gypsum) do not have the access to enough raw material to give long term protection to the business and the employment it generates. The present arrangement is likely to lead to increasing mileage to work for East Leake residents and in supplying the raw materials for our largest local business, impacting on the road network in the area and potentially creating an impact that could match the community issues when a major coal-field closes.