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?

Barton in Fabis Parish Council response

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

Page 14
"Within geological constraints, mineral development will be concentrated in locations that offer the greatest level of accessibility to the major markets and growth areas and to sustainable transport nodes to encourage sustainable patterns and modes of movement."

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

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

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

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

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

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

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

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

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

Question 4 Do you think the average 10 year sales figure is the most suitable methodology for forecasting future aggregate demand in Nottinghamshire. If not please identify any alternatives you feel are realistic and deliverable and the evidence to support this approach.

No. The analysis of future aggregate demand should include a wider analysis of demand within and outside Nottinghamshire as well as a wider analysis of the total feasible supply of aggregates taking in to account supply from neighbouring counties - see points below.

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

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

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

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

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

Yes - see comments below.

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

Response from Shelford Parish Council to the Issues and Options Consultation

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

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

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

We agree with the draft vision.

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

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

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

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

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

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

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

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

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

We see no particular merit in this approach.

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

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

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

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

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

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


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

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

Response from SAGE to the Issues and Options Consultation

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

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

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

We agree with the draft vision.

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

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

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

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

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

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

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

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

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

We see no particular merit in this approach.

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

Q4: Do you think the average 10 year sales figure the most suitable methodology for forecasting future aggregate demand in Nottinghamshire. If not please identify any alternatives you feel are realistic and deliverable and the evidence to support this approach.
Prolonged period of austerity not best for forecasting, would average of last 20 years be more appropriate.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Barge transport is superficially attractive but it is only viable if the quarry and the customer have access to a suitable wharf or dock. The low value of this aggregate precludes any significant investment in such facilities, so the opportunities for barge transport are not likely to be great unless there is a very large contract involved. River dredging material has been delivered to Cromwell quarry for processing in the past.

Very concerned about extra traffic on the A6097 if this site is still going ahead near Gunthorpe Bridge. This road is already overloaded with traffic. We live at Lowdham & struggle to get out of our village as it is with the traffic going to the A46. Another set of traffic lights & more trucks on a road that should have a weight limit on it as it is, would block us in our village even more. Please think about this before going ahead with it.

We are very much in favour of this

This proposal is unlikely to make economic sense in comparison with road transport as the trans-shipment costs would be high and road transport would still be required at the destination end. However, if there is a belief that barge transportation would make sense for non financial reasons it would need to be built into planning permissions. Note how this has been done in Yorkshire Dales with quarry extensions only authorised so long as rock was taken out by rail

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.

No comments.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Transportation
It is a major concern that heavy goods vehicles would inadvertently use the Caythorpe and Hoveringham Roads when transporting materials from the A6097 to pre-cast concrete product companies situated within the Hoveringham industrial area . We would also point out that the A6097 is already an extremely busy road and question it's capacity to accommodate increased traffic volumes caused by quarrying activities .
Given the above , we would insist that a vehicle weight restriction is placed upon the Caythorpe and Hoveringham roads . Further , we strongly support the notion of transporting all materials by river barge , a form of transport which is sadly under utilised.
Flooding
Caythorpe is situated within flood zones 1 , 2 and 3 and any activity which would increase flood risk would be vigorously opposed.
Environmental
Caythorpe is effectively downwind of the A6097 and therefore likely to be affected by quarrying activities , in particular dust and noise .
We trust that you will take our concerns into account when considering the next stage of the New Minerals Local Plan .

Response to issues and options consultation

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

Yes, when economically and ecologically viable.

This is usually more expensive as it requires a receiving wharf and interchange to lorries for the last few miles. If wharves are unavailable or sites that cannot use river transport are equally available, then river barges will often be uncompetitive.

Environmental and social sustainability is as important as 'policy-off' economic viability. Therefore, sites with river barge access must be prioritised if heavy lorry route distance is to be minimised.

Barge transport should be considered if this can be achieved with minimum damge to other environmental considerations.

Yes. The current concerns over the environmental impact of HGV transport make this a priority.

Barging seems to be the most feasible sustainable transport method and more data about the network should be incorporated in the Minerals Local Plan evidence base, especially for distant markets. Barging requires regular maintenance of waterways and of waterway/road/rail interchange infrastructure along the extended mineral export route. This requires good regional authority co-operation and forethought. Alternative infrastructure has been allowed to fall into a neglected and disconnected state.

ANSWERS TO QUESTIONS FROM BILSTHORPE PARISH COUNCIL 8th JANUARY 2018

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

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


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

Question 2: no comment

Question 3: MGL agrees with the key strategic issues.

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

Question 5: no comment

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

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

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

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

Question 11: No comment

Question 12: No comment

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

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

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

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

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

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

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

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







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

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

Q8. How important is it to maintain a geographical spread of sand and gravel quarries across the County (i.e. Idle Valley, near Newark and near Nottingham) to minimise the distance minerals are transported to markets?
Minimising the distance that minerals are transported is an important consideration, not least because this will help to reduce the emission of greenhouse gases, as well as reducing impacts such as noise and pollution.
Q9. Would it be more appropriate to prioritise specific areas above others?
Whilst we support the principle of maintaining a geographical spread of sand and gravel quarries in order to minimise the distance minerals are transported to markets, as outlined in response to Q8, we believe that there may be circumstances in which it would be more appropriate to prioritise specific areas above others. In particular, as indicated in response to Q1, consideration should be given to locating mineral development where it has the greatest potential to deliver strategic restoration benefits. The relative merits of minimising transportation distances and delivering strategic restoration benefits should be assessed in the Sustainability Appraisal.
Q10. Is it economical to transport mineral by river barge and, if so, should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?
Although we are not in a position to comment on the economics of transporting mineral by river barge, we support this approach, in principle, on the basis that it should help to reduce greenhouse gas emissions and minimise other adverse impacts such as noise and pollution. However, consideration should be given to the potential adverse effects of this approach. For example, the installation of barge infrastructure during the operational phase of a mineral development could potentially limit longer-term, post-restoration objectives, such as flood alleviation and re-connecting the river with its floodplain.
Q24. Are you aware of any issues relating to hydrocarbon extraction that should be considered through the Minerals Local Plan review?
Yes. Among other issues, hydrocarbon extraction (especially unconventional shale-gas extraction, or "fracking") poses risks for climate change, water quality and supplies, and nature. The impacts of fracking on the UK environment are poorly understood given the novelty of the industry here, but potentially significant, and yet the Government is determined to put its weight and support behind it. We are concerned that developing unconventional gas resources including shale gas is incompatible with the UK's legal commitments on climate change. Furthermore, we are concerned that the current environmental regulatory framework does not provide adequate protection for the environment, especially as regulators are under pressure to speed up permitting processes and shale-gas extraction is a very new and largely untried process in a UK context.
We recognise the limited power that Nottinghamshire County Council has to resist further hydrocarbon developments (including shale-gas extraction) in the face of strong Government support for an expanded industry. However, a criteria-based policy governing proposals for new hydrocarbon development should specifically address:
* Protection of nature conservation assets (statutory and non-statutory sites, habitats of principal importance, and protected species) at the surface, including from potential indirect effects of pollution, noise, dust, light and water use (surface and sub-surface water resources);
* Minimising greenhouse gas emissions at site, in construction and operation including stray methane emissions from the borehole and from associated construction and operational traffic;
* Maximising sustainable water use, to minimise the need for further abstraction, or importing of new water resources from outside the area. The MLP should note in particular that the Sherwood Sandstone aquifer is closed to new abstractions at present, and large parts of Nottinghamshire are classed as being in "serious" or "moderate" water stress already. If technically feasible and subject to other environmental safeguards the MLP policy should push applicants to develop closed-loop water supply systems at site level.

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

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 methodology used in the consultation document and the supporting Local Aggregates Assessment (LAA) appears to be an objective approach that satisfies the requirements of the NPPF. Concerns expressed by the District Council about the methodology used in the withdrawn Minerals Local Plan (MLP) appear to have been addressed. The District Council is therefore supportive at this stage.

Q6 - Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
The District Council considers that extensions to existing permitted quarries should be prioritised over new greenfield quarries. It is the long held view of the District Council that an approach based around the extension of existing sites remains the most sustainable and the one which is likely to have least impact on the District's residents, highway network and local environment.

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?

The District Council believes that it is very important to maintain a geographical spread of sand and gravel quarries across the County. This is the more sustainable approach, as it means that the large quantities of heavy material extracted do not need to be transported long distances by road, contributing to congestion and generating unnecessary pollution. It is also the more equitable approach, as it avoids the negative consequences of sand and gravel extraction such as noise, dust and extra traffic being concentrated in one area.

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

As set out above, the District Council view is that prioritising specific areas is less sustainable and equitable than maintaining a geographical spread. The District Council would strongly oppose the concentration of sand and gravel quarrying around Newark, especially because most development in the County will occur around Nottingham. Traffic congestion is a problem in the Newark area already and it is important that this is not exacerbated.

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?
While any proposal should be considered on its own merits, the potential benefits of transporting minerals by river should be explored. Clearly the use of river barges could significantly reduce reliance on road transport which could increase the sustainability of a mineral development. It is important to avoid placing greater pressure on the local road network.

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

If a criteria based policy is used, residential amenity should be a key consideration. It is also important to consider the impact on residents of any expansion of Kirton clay pit, especially towards the village.

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 the District Council considers the extension of existing sites a more sustainable option than the development of new sites, the allocation of land to the south of Bantycock Quarry may be preferable to exploiting previously undeveloped sites elsewhere in the District. This approach would be likely to minimise impacts on District residents.

Q26 -Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?
Plan 7 appears to indicate that Minerals Safeguarding Areas include urban areas within Newark, Nottingham City, Mansfield and Ashfield. National guidance advises that urban areas should be included in safeguarding areas where necessary - the District Council does not believe that it is necessary in this case. It seems very unlikely that these urban areas will be used for minerals development in preference to other areas of Nottinghamshire.

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

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

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

1. Issues and Options

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

that restoration should achieve together with appropriate management plans.

Dear Sir/Madam

Nottinghamshire Minerals Local Plan Issues and Options

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

Minerals Local Plan

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

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

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

Rushcliffe Borough Council broadly supports the overarching vision.

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

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

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

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

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

Rushcliffe Borough Council supports the key strategic issues.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Sustainability Appraisal Scoping Report

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

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

This concludes Rushcliffe Borough Council's representation.

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

John King MRTPI Planning Policy Officer
Rushcliffe Borough Council.

Setting the overall context for the Plan

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


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

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


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

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


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

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

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

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


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

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


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

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


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

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



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

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

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

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



Q10 Is it economical to transport mineral by river barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?
- The priority is for adequate infrastructure and sustainable transport. Distance from markets is less important than the local impact on traffic congestion.


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



Q12 Is there evidence to suggest that additional crushed rock reserves are required to meet demand in Nottinghamshire over the Plan period? If so please provide this evidence.
- Less gypsum will be available on the closure of coal-fired power stations and will also contribute to further falls in the demand for crushed limestone - Page 25..


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

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


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

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

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

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


Q17 Should the plan seek to identify specific site allocations for gypsum provision or should a criteria based policy be developed to ensure an adequate supply of gypsum can be maintained over the Plan period?
- CPC agrees with a criteria-based policy as a standard reference tool. However, site specific considerations should also be identified.


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

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



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

- No



Q20 Are you aware of any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?
- No


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

- No

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

- No



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



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

- No



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

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


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

- No

Issues and Options Paper

Section 2 - Setting the overall Context for the Plan

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

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

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

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

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

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

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

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

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

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

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

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

Minerals Provision

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

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

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

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

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

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

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

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

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

Strategic Approach to New Mineral Development

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

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

Sand and gravel provision

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

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

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

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

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

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

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

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

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

Long Distance Barging to Market

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

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

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

Short distance shuttle barging (to processing plant)

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

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

Sherwood Sandstone

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

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

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

Crushed Rock

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


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

Alternative Aggregates

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

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

Industrial Dolomite Provision

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

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

Development Management Policies

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


Yes agree that it covers all areas.


Minerals Safeguarding and Consultation Areas

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

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

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

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

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


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

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

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

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



Question 4: Do you think the average 10 year sales figure is the most suitable methodology for forecasting future aggregate demand in Nottinghamshire? If not please identify any alternatives you feel are realistic and deliverable and the evidence to support this approach.
Question 5: Do you think the same methodology (most recent average 10 year sales) should be used for each aggregate or is there merit in using different methodologies for different aggregates?

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

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

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

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

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


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




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

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

Question 8: How important is it to maintain a geographical spread of sand and gravel quarries across the County (i.e. Idle Valley, near Newark and near Nottingham) to minimise the distance minerals are transported to markets?
Question 9: Would it be more appropriate to prioritise specific areas above others? Question 10: Is it economical to transport mineral by river barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?

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

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

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




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

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


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

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

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

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

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

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

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


Question 20: Are you aware of any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?

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

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

Question 21: Is there evidence to suggest that additional building stone reserves are required to meet demand in Nottinghamshire over the plan period? If so please provide this evidence.
Question 22: Are you aware of any other issues relating to building stone provision that should be considered through the Minerals Local Plan review?

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

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

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

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

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