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

Showing comments and forms 1 to 16 of 16

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30151

Received: 29/12/2017

Respondent: Shelford & Newton Parish Council

Representation Summary:

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.

Full text:

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.

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30162

Received: 29/12/2017

Respondent: Shelford Against Gravel Extraction (SAGE)

Representation Summary:

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.

Full text:

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.

Attachments:

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30176

Received: 03/01/2018

Respondent: Roberta Prime

Representation Summary:

As already stated elsewhere, a much greater emphasis and commitment should be demonstrated.

Full text:

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

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

Attachments:

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30194

Received: 03/01/2018

Respondent: Collingham Parish Council

Representation Summary:

No

Full text:

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.

Attachments:

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30233

Received: 10/01/2018

Respondent: AKS Community Action Group

Representation Summary:

This significant sector of the aggregates supply is little understood and quantified in Nottinghamshire. Every effort should be made to improve quantification, as has been done in Dorset. With the decline of coal powered electrical generation there willl be a further decline in available secondary minerals. It would surely make sense for a full survey to identify and quantify fly ash etc that has been used as land fill etc in the past and which could be made available in the future. Available material in slag heaps also needs to be quantified and assessed.

Full text:

This significant sector of the aggregates supply is little understood and quantified in Nottinghamshire. Every effort should be made to improve quantification, as has been done in Dorset. With the decline of coal powered electrical generation there willl be a further decline in available secondary minerals. It would surely make sense for a full survey to identify and quantify fly ash etc that has been used as land fill etc in the past and which could be made available in the future. Available material in slag heaps also needs to be quantified and assessed.

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30281

Received: 05/01/2018

Respondent: Burton Joyce Parish Council

Representation Summary:

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.

Full text:

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.

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30297

Received: 11/01/2018

Respondent: Gedling Borough Council

Representation Summary:

No comments.

Full text:

No comments.

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30327

Received: 11/01/2018

Respondent: Burton Joyce Village Society

Representation Summary:

1.Potential for much of the waste or sub-standard material from working of 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. The potential to use material from colliery spoil heaps as aggregate should be investigated to potentially reduce future primary aggregates demand.

Full text:

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.

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30353

Received: 12/01/2018

Respondent: Averham, Kelham & Staythorpe Parish Council

Representation Summary:

Recycled aggregates volume should be taken into account in calculation of demand over the plan period.

Full text:

Recycled aggregates volume should be taken into account in calculation of demand over the plan period.

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30361

Received: 12/01/2018

Respondent: Newark PAGE

Agent: SSA Planning

Representation Summary:

There is potential to link extraction rates to consumption of alternative minerals in order to maintain or increase rates of recycling.

Full text:

There is potential to link extraction rates to consumption of alternative minerals in order to maintain or increase rates of recycling.

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30427

Received: 11/01/2018

Respondent: Bilsthorpe Parish Council

Representation Summary:

No

Full text:

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

Attachments:

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30449

Received: 08/02/2018

Respondent: Mick George Ltd

Representation Summary:

Recycled aggregates have probably reached their peak. They provide about 28% of the market for aggregates. Over 90% of C&D arisings are recycled, meaning further gains will be marginal.

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.

Full text:

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.

Attachments:

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30507

Received: 13/01/2018

Respondent: Historic England (East Midlands)

Representation Summary:

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

Full text:

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

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

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

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

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

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

Q4 and Q5 - both regarding forecasting methodology

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Q12 relating to additional crushed rock reserve requirements

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Attachments:

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30613

Received: 12/01/2018

Respondent: Coddington Parish Council

Representation Summary:

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

Full text:

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

Attachments:

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30667

Received: 10/01/2018

Respondent: Tarmac Ltd

Representation Summary:

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. 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.

Full text:


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.

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30684

Received: 12/01/2018

Respondent: Minerals Products Association

Representation Summary:

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."

Full text:

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.