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?

Showing comments and forms 1 to 11 of 11

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30215

Received: 07/01/2018

Respondent: Mr Steve Horne

Representation Summary:

Any exploitation of resources near Holbeck could impact on the internationally significant Creswell Crags heritage site both visually and environmentally. The importance of this site should not be underestimated.

Full text:

Any exploitation of resources near Holbeck could impact on the internationally significant Creswell Crags heritage site both visually and environmentally. The importance of this site should not be underestimated.

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30249

Received: 10/01/2018

Respondent: Mrs Diane Stokes

Representation Summary:

The Industrial Dolomite works are very close to the Creswell Crags heritage site; a decision on any expansion of activity in that area should prioritise the integrity of the heritage site.

Full text:

The Industrial Dolomite works are very close to the Creswell Crags heritage site; a decision on any expansion of activity in that area should prioritise the integrity of the heritage site.

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30303

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: 30408

Received: 14/01/2018

Respondent: Mrs Jackie Armstrong

Representation Summary:

I believe that the Creswell Crags heritage site and its landscape setting is of international cultural significance, and its protection is imperative. I support its nomination as a World Heritage Site.

Full text:

I believe that the Creswell Crags heritage site and its landscape setting is of international cultural significance, and its protection is imperative. I support its nomination as a World Heritage Site.

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30433

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: 30484

Received: 12/01/2018

Respondent: Bolsover District Council

Representation Summary:

Bolsover Council supports the final paragraph of this section of the consultation which acknowledges the importance of Creswell Crags; and also the associated Plan 5 which clearly shows the extent of the Scheduled Ancient Monument designation.

Full text:

Nottinghamshire Minerals Local Plan - Issues and Options Consultation
Dear Sir
Thank you for the opportunity to comment on the Issues and Options Consultation on the
Nottinghamshire Minerals Local Plan. The following comments are made at officer level in
consultation with the Chair of Planning Committee, and are limited to considering where the
proposed strategy may have cross border implications. It is anticipated that the Derbyshire
Minerals authority (i.e. Derbyshire County Council) will comment on other issues raised by
the consultation.
At this stage of the Nottinghamshire Minerals Local Plan, the key concern of Bolsover
Council is the protection of Creswell Crags, and its wider setting. Creswell Crags is one of the
most important archaeological and geological sites in Britain. This is reflected in its status as:
part of a Conservation Area; a Site of Special Scientific Interest; a Scheduled Ancient
Monument; and part of a grade 2 designation on the National Register of Parks and Gardens
of Special Historic Interest. In addition Creswell Crags is on the UK tentative list of potential
Word Heritage Sites;
Whilst is acknowledged that industrial dolomite is a scarce resource, Creswell Crags is clearly
a site of international importance. In addition, unlike many other forms of minerals
workings any disturbance to this important site or its setting could not be remedied by the
imposition of aftercare conditions.
Turning to our comments on specific questions in the consultation:
Overview of the Plan Area
Question 1 Do you think that any further information should be included in the
overview of the area?
Paragraph 3 of the overview of the Plan area refers to the network of important sites
for nature conservation in the county. It would be useful if this could be balanced by a
reference to the historic environment in the form of the many historic buildings;
Scheduled Ancient Monuments; and historic landscape areas in the county, many of
which (including Creswell Crags) are in the countryside.
Draft Vision
Question 2 Do you agree with the draft vision? Are there other things we should
include?
Paragraph 3 of the draft vision states 'Within geological constraints, mineral
development... It is suggested the sentence is widened to read 'Within geological and
other significant constraints, mineral development... to highlight that geological
constraints are not the only constraints on sites being developed for mineral workings.
Key Strategic Issues
Question 3 Are the above strategic issues appropriate? Are there others we should
consider?
The third strategic issue is to minimise impacts on communities. It is suggested that this
be expanded to include a reference to minimise impacts on key historic sites in the
county.
Industrial Dolomite Provision
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?
Bolsover Council supports the final paragraph of this section of the consultation which
acknowledges the importance of Creswell Crags; and also the associated Plan 5 which
clearly shows the extent of the Scheduled Ancient Monument designation.
Development Management Policies
Question 25 Do you agree with the proposed development management policy areas?
Are there any others that should be covered?
Bolsover Council supports the proposals to have development management policies on
landscape character, and the historic environment, and look forward to commenting on
these in greater detail at later stages of the Plan's development.
We hope that the above observations are helpful in preparing the next stage of your Local
Plan, but please do not hesitate to get in touch if you would like to discuss them in further
detail.
Yours faithfully
Helen Fairfax
Joint Planning Policy Manager

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30513

Received: 13/01/2018

Respondent: Historic England (East Midlands)

Representation Summary:

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

Due to the potential site area being limited to this area of the County a site allocation and specific site policy would be required within the Plan.

Heritage Impact Assessment needed

Any economic information would need to consider the outcome of DCC application CM5/0416/4 for further 3.23mt from new sites within existing Whitwell site.

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: 30559

Received: 12/01/2018

Respondent: Natural England

Representation Summary:

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

Full text:

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

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

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

1. Issues and Options

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

that restoration should achieve together with appropriate management plans.

Attachments:

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30668

Received: 10/01/2018

Respondent: Tarmac Ltd

Representation Summary:

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.

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: 30686

Received: 12/01/2018

Respondent: Minerals Products Association

Representation Summary:

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.

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.

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30704

Received: 15/01/2018

Respondent: Derby and Derbyshire Development Plans Joint Advisory Committee

Agent: Derbyshire County Council

Representation Summary:

Whitwell Quarry, operated by Tarmac, lies on the dolomitic limestone resource which straddles the County boundary with Nottinghamshire; the resource is of national importance. The Issues and Options Consultation matters in a Duty to Co-operate Report which was first published in 2015.

The County and City Council will be publishing the next stage of the preparation of the Derbyshire and Derby Minerals Local Plan by the end of January 2018. It will include an updated Duty to Co-operate Report.

Full text:

Consultation on Nottinghamshire County Council - Minerals Local Plan Issues and Options 2017


I write with regard to the above consultation, upon which Derbyshire County Council (DCC) and Derby City Council have the following comments to make.

Brick Clay Provision

Waingroves Quarry in Derbyshire supplies Kirton Brickworks in Nottinghamshire with approximately 24,000 tonnes of brick clay annually. It also supplies two brickworks in Leicestershire. The main purpose of the material is for blending; the NPPF requires this matter to be taken into account in planning for the supply of brick clay. Based on estimated future production, current permitted reserves at Waingroves Quarry should be sufficient to last for 35 years. Nevertheless the Plan should make reference to this cross border movement of material, including the need to monitor supply.

Industrial Dolomitic Limestone Provision

Whitwell Quarry, operated by Tarmac, lies on the dolomitic limestone resource which straddles the County boundary with Nottinghamshire; the resource is of national importance. The Issues and Options Consultation matters in a Duty to Co-operate Report which was first published in 2015.

The County and City Council will be publishing the next stage of the preparation of the Derbyshire and Derby Minerals Local Plan by the end of January 2018. It will include an updated Duty to Co-operate Report.

Mineral Safeguarding Areas

Development which is close to, but not actually within, a mineral resource may also lead to the sterilisation of part of the resource. For example, if a house was built in this zone close to a mineral resource, a quantity of the resource may not be able to be worked (it would be sterilised) as the property would lie within the area that could be affected by the effects of mineral working to an unacceptable degree. To take account of such risks, and to also account for the inexact nature of mapped geological boundaries , particularly for more scarce resources, consideration should be given to whether it will be necessary to extend the MSA beyond the actual resource boundary, using a buffer zone.


Please note that these are officer comments, and are subject to consideration by the Chair and Vice Chair of the Derby and Derbyshire Development Plans Joint Advisory Committee.