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

We have been invited to participate in the Mineral Local Plan in regard to the previous MLP being withdrawn in May 2017.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

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

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

Answer: I have nothing to add to this question

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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

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

Sustainability Appraisal Scoping Report

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

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

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

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

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

Answer: I have nothing to add to this question

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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

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

Response from Shelford Parish Council to the Issues and Options Consultation

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

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

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

We agree with the draft vision.

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

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

Q4 Do you think the average 10 year sales figure is the most suitable methodology for forecasting future aggregate demand in Nottinghamshire. If not please identify any alternatives you feel are realistic and deliverable and the evidence to support this approach.

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

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

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

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

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

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

We see no particular merit in this approach.

Q8 How important is it to maintain a geographical spread of sand and gravel quarries across the County (i.e. Idle Valley, near Newark and near Nottingham) to minimise the distance minerals are transported to markets?

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

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

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

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

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


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

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

Response from SAGE to the Issues and Options Consultation

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

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

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

We agree with the draft vision.

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

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

Q4 Do you think the average 10 year sales figure is the most suitable methodology for forecasting future aggregate demand in Nottinghamshire. If not please identify any alternatives you feel are realistic and deliverable and the evidence to support this approach.

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

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

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

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

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

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

We see no particular merit in this approach.

Q8 How important is it to maintain a geographical spread of sand and gravel quarries across the County (i.e. Idle Valley, near Newark and near Nottingham) to minimise the distance minerals are transported to markets?

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

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

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

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

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


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

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

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

Q4: Do you think the average 10 year sales figure the most suitable methodology for forecasting future aggregate demand in Nottinghamshire. If not please identify any alternatives you feel are realistic and deliverable and the evidence to support this approach.
In theory it seems sensible, but it allows no room for considering the impact from potential for using more recycled products in the future. Any forecasts of the volume of minerals required are based on the present heavy reliance on extracted aggregates, whereas with more vigorous development of recycling, those needs would diminish.
Q5: Do you think the same methodology (most recent average 10 years sales) should be used for each aggregate or is there merit in using different methodologies for different aggregates?
Q6: Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries? In theory, yes, If they are still viable and will cause minimum negative impacts on nearby communities. Why destroy more countryside unnecessarily? The term "greenfield sites" seems a sadly ironic misnomer.
Q7: Should different approaches (new sites/extensions to existing permitted quarries) be adopted for individual mineral types?
Every decision must take into account the potential long term impact on the environment and existing communities.
Q8: How important is it to maintain a geographical spread of sand and gravel quarries across the County (i.e. Idle Valley, near Newark and near Nottingham) to minimise the distance minerals are transported to markets?
There is a contradiction here in that you state that minerals extracted in the county are transported to Rotherham and Doncaster which can hardly minimise the transportation distances.
Q9: Would it be more appropriate to prioritise specific areas above others?
Those areas which will have the least negative impacts on communities and the environment.
Q10: Is it economical to transport mineral by river barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?
50 years ago, the River Trent was a busy highway with barges transporting goods and causing no negative impacts on communities or the environment. Sadly, over the years, this has dwindled to nothing. Any means of transport which reduces the number of heavy vehicles on the roads is an environmental priority ,even if it is more costly, and should be thoroughly investigated. However, developers, who want to maximise their profits, are likely to find arguments to evade this, even if at the outset they seem to support it!
Q11: Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?
------------------
Q12: Is there evidence to suggest that additional crushed rock reserves are required to meet demand n Nottinghamshire over the Plan period? If so please provide this evidence.
Q13: Are you aware of any other issues relating to crushed rock provision that should be considered through the Minerals Local Plan review?
You state that alternative aggregates provide for 29% of consumption and the new minerals plan should anticipate an expansion of their use.
Q14: Are you aware of any issues relating to alternative aggregates that should be considered through the Minerals Local Plan review?
As already stated elsewhere, a much greater emphasis and commitment should be demonstrated.
Q15: Should the Plan identify a specific replacement quarry (remote extension/ new site) to Dorket Head clay pit or should a criteria based policy be developed to ensure that an adequate supply of clay can be maintained over the Plan period?
------------------------
Q16: Is a criteria based policy the most suitable approach to cover the potential for new brick works and associated clay pits?
-----------------------
Q17: Should the plan seek to identify specific site allocations for Gypsum provision or should a criteria based policy be developed to ensure an adequate supply of Gypsum can be maintained over the Plan period?
------------------------
Q18: Are you aware of any issues regarding the provision of Gypsum that should be considered as part of the Minerals Local Plan review?
--------------------------------
Q19: Are you aware of any issues regarding the provision of silica sand that should be considered as part of the Minerals Local Plan review?
----------------------------------
Q20: Are you aware of any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan Review?
----------------------------------
Q21: Is there evidence to suggest that additional building stone reserves are required to meet demand in Nottinghamshire over the Plan period? If so please provide this evidence
-----------------------------------
Q22: Are you aware of any other issues relating to building stone provision that should be considered through the Minerals Local Plan review?
--------------------------------------
Q23: Are you aware of any issues relating to coal extraction that should be considered through the Minerals Local Plan review?
Fossil fuels should be a thing of the past and we should put all our energies into sustainable and renewable sources of energy.
Q24: Are you aware of any issues relating to hydrocarbon extraction that should be considered through the Minerals Local Plan review?
Hydrocarbon extraction of existing mine gas would be acceptable as it would have a positive environmental impact and involve no further land destruction, but shale gas and coal bed extraction would both have destructive impacts.
Q25: Do you agree with the proposed development management policy areas? Are there any others that should be covered?
--------------------------
Q26: Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?

We see no reason for a different approach. We see a real need to consider the transport of these bulky and heavy materials as a whole , so that a series of local developments do not add up to an impossible load on a deficient and defective road system.

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 Mineral Planning Authority should adopt a policy relevant to the varying mineral types in the County.
For brick manufacturing, significant initial and on going investment is required to ensure that the brick factory performs efficiently. For Dorket Head, development of the site hundreds of years ago would have relied on the ample resources in the area to ensure a long term stock of permitted reserves closest to the point of manufacture. So far as resource is commercially and environmentally appropriate a presumption in favour of extensions to the existing quarry should be adopted to reflect the high initial and ongoing investment of the brick manufacturing facility.
As resources diminish or becomes unavailable proximal to the brick factory, resources further a field will be required.

This is unlikely to be necessary as the various impacts from different types of mineral extraction are similar.

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.

No, there should be a consistent, standard approach.

No, different approaches for new sites or extensions should not be adopted for individual mineral types. Given the congestion issues around Newark, new sites should not be considered until the new road network is in place. Overall, extensions are usually more sustainable and have more predictable impacts, particularly where routeing agreements remain.

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

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

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

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

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

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

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

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

Q4 and Q5 - both regarding forecasting methodology

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Q12 relating to additional crushed rock reserve requirements

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Dear Sir/Madam

Nottinghamshire Minerals Local Plan Issues and Options

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

Minerals Local Plan

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

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

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

Rushcliffe Borough Council broadly supports the overarching vision.

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

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

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

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

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

Rushcliffe Borough Council supports the key strategic issues.

Q4 Do you think the average 10 years sales figure is the most suitable methodology for forecasting future aggregate demand in Nottinghamshire? If not please identify any alternatives you feel are realistic and deliverable and the evidence to support this approach.

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

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

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

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

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

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

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

Q8 How important is it to maintain a geographical spread of sand and gravel quarries across the County (i.e. Idle Valley, near Newark and near Nottingham) to minimise the distance minerals are transported to markets?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Sustainability Appraisal Scoping Report

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

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

This concludes Rushcliffe Borough Council's representation.

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

John King MRTPI Planning Policy Officer
Rushcliffe Borough Council.

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

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.