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

Showing comments and forms 1 to 6 of 6

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30177

Received: 03/01/2018

Respondent: Roberta Prime

Representation Summary:

Fossil fuels should be a thing of the past and we should put all our energies into sustainable and renewable sources of energy.

Full text:

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

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

Attachments:

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30197

Received: 03/01/2018

Respondent: Collingham Parish Council

Representation Summary:

Yes; Carbon Capture. We suggest that consideration is given to "softening" planning for coal extraction for power plants that use carbon capture storage.

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Attachments:

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30306

Received: 11/01/2018

Respondent: Gedling Borough Council

Representation Summary:

No

Full text:

No

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30436

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: 30516

Received: 13/01/2018

Respondent: Historic England (East Midlands)

Representation Summary:

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

Full text:

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

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

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

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

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

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

Q4 and Q5 - both regarding forecasting methodology

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Q12 relating to additional crushed rock reserve requirements

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Attachments:

Comment

Minerals Local Plan Issues and Options consultation

Representation ID: 30623

Received: 10/01/2018

Respondent: The Coal Authority

Representation Summary:

Agrees that a criteria based policy is appropriate.

Supports the approach to coal recovery from tip washing and colliery lagoons, which can provide a useful source of coal and can help to reduce the scale and impact of historic mineral waste. It can, at times, also be a useful method of removing mining legacy instability in some tips and/or allowing them to be re-engineered into less artificial landforms.

Hope policy will be flexible enough to cater for small scale prior extraction surface coal proposals, most of which are likely to occur in existing urban areas, as well as more major stand-alone surface coal extraction.

Full text:

Thank you for your notification received on the 1 November 2017 in respect of the above consultation.

The current Issues and Options Consultation is an early stage in the Local Plan process and asks a series of questions. The Coal Authority has the following comments to make on the current consultation and questions asked:

Q1. No specific comments to make.

Q2. The Coal Authority is pleased to see that the draft vision identifies the importance of mineral reserves and the need to safeguard them against inappropriate development.

Q3. The Coal Authority is pleased to see restoration and safeguarding of minerals identified as key strategic issues.

Q4/Q5. No specific comments to make. Q6/Q7. No specific comments to make. Q8/Q9/Q10. No specific comments to make. Q11. No specific comments to make.
Q12/Q13. No specific comments to make. Q14. No specific comments to make.

Q15/Q16. No specific comments to make. Q17/Q18. No specific comments to make. Q19. No specific comments to make.
Q20. No specific comments to make. Q21/Q22. No specific comments to make.
Q23. The Coal Authority agrees that the use of a criteria based policy to assess any proposals for energy minerals is appropriate.

The Coal Authority supports the approach to coal recovery from tip washing and colliery lagoons, which can provide a useful source of coal and can help to reduce the scale and impact of historic mineral waste. It can, at times, also be a useful method of removing mining legacy instability in some tips and/or allowing them to be re-engineered into less artificial landforms.

We would hope that this policy will be flexible enough to cater for small scale prior extraction surface coal proposals, most of which are likely to occur in existing urban areas, as well as more major stand-alone surface coal extraction. This type of prior extraction often takes place to address historic mining legacy as the removal of remaining surface coal deposits can be more economically viable than hard engineering solutions such as grout fill.

Q24. The Coal Authority supports the inclusion of a criteria based hydrocarbons policy within the Local Plan. We also support the inclusion of a plan which identifies the PEDL areas.

Q25. No specific comments to make.

Q26. The Coal Authority is pleased to see the identification of surface coal resource within the list of Nottinghamshire's eight distinct mineral resources.

It is not clear from Plan 7 - Minerals safeguarding in Nottinghamshire- if the whole of the county boundary is designated as the mineral safeguarding area or just the coloured areas, which appear to identify areas where minerals are present.

Please do not hesitate to contact me should you wish to discuss any of the above comments. Regards
Melanie Lindsley
Melanie Lindsley BA (Hons), DipEH, DipURP, MA, PGCertUD, PGCertSP, MRTPI
Team Leader - Planning Liaison

Attachments: