Q17 Should the plan seek to identify specific site allocations for gypsum provision or should a criteria based policy be developed?

We support the identification of specific site allocations

No comments.

As stated earlier Gotham has links with Gypsum mining. We believe the plan should not identify specific sites at this stage but await future criteria. British Gypsum (Saint Gobain) is a local employer and has a good relationship with the community.

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

Dear Mr Osborne-James


Re: Nottinghamshire Minerals Local Plan - Issues and Options Consultation

In relation to the Issues and Options Minerals Local Plan consultation document, we would like to make the following comments:

1) 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?

The Plan should seek to identify both a site specific allocation for gypsum and a criteria based policy.

a) The extension of Bantycock Quarry (Bantycock South, put forward as part of the call for sites running parallel to this consultation) is required for a continued supply of high purity / brightness (optical grade) gypsum for high value speciality products made by Formula. This extension should be identified as a preferred area for the ongoing supply of this grade of raw material to the important Jericho Factory located at Balderton, just south of Newark.

b) In addition, it is important not to overlook gypsum used in construction products, and it should be noted that Nottinghamshire and the East Midlands are an important centre for the manufacture of gypsum plaster and plasterboard products for use in construction products. Given the importance of the Industry, it is considered that a broad area of search for gypsum for use in construction products should also be adopted, covering the area shown on Plan 2.

The options for identifying gypsum deposits in the UK are limited and Nottinghamshire is one of the counties in which it may be possible to identify and develop gypsum mining / quarrying operations that could supply the UK construction product market.





British Gypsum
Head Office * East Leake * Loughborough * Leicestershire * LE12 6HX * Tel +44 (0) 115 945 1000 * Fax +44 (0) 115 945 1901 * www.british-gypsum.com Proprietor: BPB United Kingdom Limited registered in England 734396, registered office Saint-Gobain House, Binley Business Park, Coventry, CV3 2TT, UK A Saint-Gobain Company

2) Page 28 - gypsum provision

The third paragraph states that permitted reserves at Marblaegis Mine should be sufficient until at least 2026. Please note that planning permission has been granted to extend the life of the mine until February 2042 (see application no.
8/16/01430/CMA).


Yours sincerely,


Senior Estates and Minerals Planner

Dear Mr Osborne-James


Re: Nottinghamshire Minerals Local Plan - Issues and Options Consultation

In relation to the Issues and Options Minerals Local Plan consultation document, we would like to make the following comments:

1) 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?

The Plan should seek to identify both a site specific allocation for gypsum and a criteria based policy.

a) The extension of Bantycock Quarry (Bantycock South, put forward as part of the call for sites running parallel to this consultation) is required for a continued supply of high purity / brightness (optical grade) gypsum for high value speciality products made by Formula. This extension should be identified as a preferred area for the ongoing supply of this grade of raw material to the important Jericho Factory located at Balderton, just south of Newark.

b) In addition, it is important not to overlook gypsum used in construction products, and it should be noted that Nottinghamshire and the East Midlands are an important centre for the manufacture of gypsum plaster and plasterboard products for use in construction products. Given the importance of the Industry, it is considered that a broad area of search for gypsum for use in construction products should also be adopted, covering the area shown on Plan 2.

The options for identifying gypsum deposits in the UK are limited and Nottinghamshire is one of the counties in which it may be possible to identify and develop gypsum mining / quarrying operations that could supply the UK construction product market.





British Gypsum
Head Office * East Leake * Loughborough * Leicestershire * LE12 6HX * Tel +44 (0) 115 945 1000 * Fax +44 (0) 115 945 1901 * www.british-gypsum.com Proprietor: BPB United Kingdom Limited registered in England 734396, registered office Saint-Gobain House, Binley Business Park, Coventry, CV3 2TT, UK A Saint-Gobain Company

2) Page 28 - gypsum provision

The third paragraph states that permitted reserves at Marblaegis Mine should be sufficient until at least 2026. Please note that planning permission has been granted to extend the life of the mine until February 2042 (see application no.
8/16/01430/CMA).


Yours sincerely,


Senior Estates and Minerals Planner

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.

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

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

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

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

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

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

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

Q10 -Is it economical to transport mineral by river barge and if so should proposed quarries with the potential for moving sand and gravel by river barge be prioritised over other proposals?
While any proposal should be considered on its own merits, the potential benefits of transporting minerals by river should be explored. Clearly the use of river barges could significantly reduce reliance on road transport which could increase the sustainability of a mineral development. It is important to avoid placing greater pressure on the local road network.

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

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

Q17 -Should the plan seek to identify specific site allocations for gypsum provision or should a criteria based policy be developed to ensure an adequate supply of gypsum can be maintained over the Plan period?
As the District Council considers the extension of existing sites a more sustainable option than the development of new sites, the allocation of land to the south of Bantycock Quarry may be preferable to exploiting previously undeveloped sites elsewhere in the District. This approach would be likely to minimise impacts on District residents.

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

Dear Sir/Madam

Nottinghamshire Minerals Local Plan Issues and Options

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

Minerals Local Plan

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

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

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

Rushcliffe Borough Council broadly supports the overarching vision.

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

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

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

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

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

Rushcliffe Borough Council supports the key strategic issues.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Sustainability Appraisal Scoping Report

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

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

This concludes Rushcliffe Borough Council's representation.

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

John King MRTPI Planning Policy Officer
Rushcliffe Borough Council.

Setting the overall context for the Plan

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


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

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


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

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


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

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

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

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


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

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


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

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


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

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



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

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

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

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



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


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



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


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

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


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

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

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

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


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


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

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



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

- No



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


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

- No

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

- No



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



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

- No



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

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


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

- No