Question 1: What do you think of the draft vision and strategic objectives?

Living locally for over 55 years, I feel very strongly that you are letting people down if this plan goes ahead.
"National policy states that minerals extraction is not inappropriate in the green belt provided the openness of the green belt is preserved and where it would not conflict with the purposes of including land in the green belt."
It will greatly conflict with the current usage of the area. For over 50 years the area has been of great family use, both as farming and for everyday families to enjoy fresh air and get exercise. In this day of growing diabetes you are considering culling a prime area. Horse riders will be forced to again go into conflict with road users and vehicular traffic appertaining to site.

NSDC is supportive.

Coddington Parish Council welcomes the new approach which has taken in views of local councils and communities, particularly on the improved spatial pattern for development, prioritisation of extensions, and the revised local aggregate assessment:
* SO1 - Support spatial pattern of mineral development
* SO1 - Support prioritising of improved use of sites (including mothballed sites) and extensions of existing sites
* SO2 - Support Local Aggregates Assessment as providing an adequate and sustainable supply of minerals. Balance of supply and demand should be reviewed regularly through monitoring reports to keep the plan up to date.

true sustainability should reflect the need to continuously increase the proportion of mineral provided through re-use, recycling etc. Incorporating a requirement to promote or contribute to minerals obtained by methods that avoid irreversible consumption of resources could achieve this. The price of primary mineral is a key factor in the viability of recycling efforts. Releasing sites only when a certain proportion of supply is recycled and subject to condition that require the output to be matched by a certain proportion of recycled mineral are ways of achieving this ways and clearly prioritises recycled mineral over new extraction.

Support

Notts Footpaths Preservation Society broadly support the vision and objectives.

CEMEX concur with the vision and strategic objectives and welcome the recognition that the County will seek to meets its share of national and local need. In this context CEMEX in particular supports Objective SO2 (Supporting an adequate supply of minerals).

We agree that the emerging plan acknowledges that "mineral development will be concentrated in locations that offer the greatest level of accessibility to the major markets and growth areas.."
We support the Strategic Objectives of the plan

Rotherham Council support the vision and strategic objectives.

SO1 Far more should be done to develop the use of recycled materials, thus reducing the need for extraction.
Prioritising the use of existing sites is an excellent objective.

SO3 Sites should NEVER be located in areas of high flood risk,given the increasing threat from Climate Change.
SO5/6/7/8
Protecting communities from the negative impacts of mineral extraction on health, flood threats, agricultural land, transport difficulties and landscape .
"Ensure that environmental harm and impacts of climate change are minimised."
"Locate sites where there are accessible,sustainable transport modes."
Protect the declining rural areas from industrial exploitation.
These are all laudable objectives.

The Vision and Strategy Objectives provide clear direction.

The mention of shale gas is highly concerning. Any and all attempts to access shale gas should be immediately blocked. Also concerning is the statement pointing out that national policy is that minerals can be extracted from green belt land. This indicates that there are plans to do this. This would be absolutely unacceptable.

I like this part of the plan.
SO5 about community engagement must be adhered to and people's concerns must not be ignored. The previously stated position of presumption in favour of sustainable development should not be allowed to override local communities' expressed needs. If a development has no local support it fails to be "sustainable".

When selecting areas for extraction of any products from the land there needs to be a careful review of the area, which in my opinion in relation to the Barton in Fabis site has now been done with due respect.

The Coal Authority supports the objectives set out in the plan.

In general, Coddington Against Gravel Extraction (CAGE) feels that the revised Draft Minerals Plan is better drafted and more honest than its predecessor. CAGE welcomes the new approach which has taken more account of the views of local communities and their Parish and District Councils. We support the lower, more rational basis for the assessment of need based on the most recent data and agree that the balance of supply and demand should be monitored to keep the plan up to date.

The improved spatial pattern for minerals development recognises that minerals should be sourced close to their point of use and not concentrated in the Newark area. Sites will continue to be needed in the South West of the County to service the large housing development planned near to Nottingham on land that was previously allocated as green belt. For supplies to South Yorkshire, Humber coastal extraction may be more sustainable than those in the Newark area, making use of river transport to reduce environmental impacts from HGV traffic.

CAGE supports prioritising mothballed sites and extensions because of the environmental and efficiency benefits, providing they do not encroach unacceptably close to settlements and that cumulative effects are properly evaluated.

In the Vision statement (2.29 Paragraph 3), where the phrase 'designed, located and operated to ensure' this should be replaced with 'designed, located, operated and the sites restored to ensure'.

CAGE wishes that government policy would give more powers and safeguards to help assure communities that proposed restoration scheme gains will actually be delivered.

CAGE would like more emphasis in the Vision on the protection of the quality of life and health of people. In the statement about a 'Greener Nottinghamshire' we should list the interests of people ahead of a narrow focus on biodiversity-led restoration. We suggest the replacement paragraph:

'This will result in improvements to the environment, in people's health and well-being and in landscape-scale biodiversity gains. Biodiversity gains will include improvements to existing habitats, creation of new priority habitat and the reconnection of ecological networks with sensitivity to surrounding land uses.'

In the Vision statement, CAGE supports including appropriate tools for reducing the impact of minerals extraction on environmental assets but would like an equivalent statement on the protection of the quality of life and health of people. (If not here, this text should be placed in DM1 Protecting Local Amenity.):

'The quality of life and health of those living, working in, or visiting Nottinghamshire will be protected by all appropriate means, including site establishment, sensitive siting of plant, plant operating conditions and hours, HGV routing, early and staged restoration and appropriate afteruse'.

SO5/SO7 - Nottinghamshire County Council should recognise here that the County has many different historic environments and the importance of sense of place to communities eg: 'Protect and where appropriate enhance Nottinghamshire's distinct historic environments and the distinctiveness of its regions.'

SO8 - CAGE believes strongly that this should refer to protecting Agricultural land and not just to soils, which require appropriate land-surface to support crop growth, forestry or animal grazing. They belong to the neighbourhood and should not be exported or asset stripped on this scale. To do so is an insult to the local community and to the generations of farmers who toiled to improve the land and pass it on to future generations.

In paragraph 2.14, the list of important heritage and cultural assets should include the agricultural management system at Laxton, the only remaining working "open field" farming village in Europe still operating this ancient system.

Page 20 Plan 2. This should also show mineral resources within the boundary of Nottingham City and those up to 20 miles beyond the Nottinghamshire County border to provide a true overview of the geographical distribution of sites and provide evidence of the duty to cooperate between minerals planning authorities. CAGE feels that making that unless this is made more transparent a proper concern cannot be demonstrated for communities living near the administrative boundaries.

I am writing to confirm that I wish to OBJECT to the above site.

The County Council's own 'Sustainability Assessment' shows that this site (MP2s Mill Hill nr Barton in Fabis) is the most damaging of all sites in the operational phase and the 3rd most damaging in the long term. Why would the County Council pick a site that by it's own investigations is one of the least attractive options? Why carry out the Sustainability assessment if you are only going to ignore its findings?

The Draft Minerals Local Plan is 'unsound' in that the Council has sought to justify the inclusion of the site on the basis of "maintaining a geographical spread" and therefore over-riding the adverse impact on sustainability. However, the Council has stated, "there is no published data related to geographical spread". Again the justification for the inclusion of this site seems to be at odds to the Councils own findings. Why is the Council repeatedly ignoring its own advice? It's seems that there are factions within the Council that are 'at war' with each other? Surely the function of the Council is for the betterment of the electorate and the county at large, not a cauldron of in-fighting?

There have been no projections for sand and gravel demand in the different submarket areas. The County Council's statement that the Shelford or Coddington sites are too big therefore cannot be justified. This seems completely non-nonsensical to me. It is like saying that a whole cake is too big to eat! You can just take a slice of the cake, you do not need to eat it all at once. The sites at Shelford or Coddington could be started small and then expanded, if necessary. Surely there is no such thing as too big if the sites have not yet begun?

The Council has failed to follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" by not allocating any sites which use this mode of transport. From the work done by the Council on the previous Draft Minerals Plan, the only site highlighted as a potential for resource removal by barge was Shelford. If there is a desire, on the very sensible grounds of sustainable transport, to have the resources removed by barge, surely Shelford must be included in the proposal. Yet again we see the Council ignoring its own advice!

The site would impact on two SSSls (Sites of Special Scientific Interest) - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five LWSs (Local Wildlife Sites) one of which will be destroyed altogether. With an objective of the council to be sustainable and ecologically responsible it seems reckless that they are planning on carving up the countryside and destroying these nationally designated important and beautiful sites.

Public Health England RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site. Surely it is also a responsibility of the Council to take note of the advice of these important national bodies. Choosing to ignore the advice of these organisations makes the Council look like it does not care about the advice of others.

The site is in the Green Belt, and Brandshill and Clifton Woods, adjacent to the site, have been designated as Ancient Woodland, which have special protection under the National Planning Policy Framework (NPPF). The Council has failed to justify any "wholly exceptional reasons" required by the NPPF. Once again, the Council seems to be ignoring not only its own advice but the various national frameworks under which it is bound. It would appear that the Council has made a unilateral, unsound decision and is ignoring its legal obligations.

There would be a major impact on the quality of life and visual amenity of local people. There will be high levels of dust and noise adjacent to a highly populated area, including a local retirement village full of residents with possible respiratory problems, as well as the loss of peace and tranquillity in an area used extensively by a wider community for walking, fishing, horse riding, bird watching and other leisure pursuits, including an adverse impact on grazing land and especially to the respiratory health of horses and other wildlife. The loss of a significant area of countryside on the edge of a large city such as Nottingham damages the recreational opportunities that are increasingly important for the health and well-being of city dwellers.

The statement in S07;

'Ensure heritage assets (archaeological, historic buildings, settlements, landscapes, parks and gardens) and their settings are adequately protected and where appropriate enhanced.'

Should be amended to acknowledge that in relation to archaeological, the destructive nature of extraction means they aren't preotected or enhanced but that details of archaeologicsal interest are accurately recorded for historical purposes.

Barton on fabis should not be considered for sand/gravel extraction due to proximity to attenborough nature reserve (site of scientific interest) and the river trent. Attenborough is a major visitor attraction and should not be put at risk. Land is a sacrificial flood plane during high river levels, with the uk's biggest flood protection barrier on the opposite bank.
Shale gas extraction should not be considered in a long term strategic plan, banned in Scotland and likley to be banned in the uk if the opposition government elected, renewable energy sources will inevitably superceed fossil fuels due to global regulation.

Preface
This Council made submissions at the previous stage, "Issues and Options," in this process of producing the final Plan. We find that some issues we addressed at that stage have been included in the Draft Plan in a way we agree with, and some not. This Submission will refer to such points of agreement or disagreement again as they arise.

None of the sites proposed in this Draft is sufficiently close to Burton Joyce for this Council to have any direct comment on the suitability of them so we address only the general principles. However, identification of sites should not be done in isolation from the expected effects of anticipated infrastructure, commercial and housing developments in the areas concerned. The issues raised in the section concerning sand and gravel, since that mineral resource is the one relevant to the whole of this part of the Trent Vale, and we wish to see such principles applied to each site to be considered. Questions from number 12 onward are not addressed in this submission.

Where we refer to the NPPF, we refer to the draft version, on the assumption that, so far as it is relevant to the point we are considering, the final version will reflect the current draft.

Q.1 the draft vision and strategic objectives
The listed policy points on p.13 are generally acceptable, with the significant exception of the 8th point. Nearness of mineral quarrying sites to end-use sites is of value to the commercial producers since transport costs are a significant element, but the Planning process must take account of those costs to the resident population and to local authorities which are not entered into commercial accounts. There is an inherent conflict within the NPPF between the need for a reliable supply of minerals and the need to take account of flood risks, particularly in light of anticipated climate change, predictions for which are more serious now than they were even in the initial stages of the drafting of this Plan. We also point out that closeness of an extraction site to the market is not the only measure of reducing transport costs, since the better-developed transport network on the Western side of the County may still make a longer journey a faster and cheaper one than adding vehicles to an already inadequate and congested road system. New building areas are most likely to be in logical places for population growth, which will already be places of relatively high density population. Such places will therefore suffer the worst damage from air pollution, noise, traffic congestion and dangers, loss of environment and amenity, and additional flood risk. More remote extraction sites result superficially in some extra cost only because the workings themselves do not take into account the very real cost to the residents and authorities. We happily accept the emphasis laid on biodiversity. However we strongly reject any suggestion that the destruction of farmland to be replaced by even more areas of stagnant open water is anything but harmful to biodiversity in the Trent Vale region.

Q2 sustainable development
We accept the principles in this section of the draft, and would lay particular emphasis on paragraph 3(a) in SP1. In the Trent Vale region there will be very many cases where the costs of development would significantly and demonstrably outweigh the benefit; not necessarily from the development itself, in the form of new buildings and infrastructure, but in terms highly relevant to this Draft Minerals local Plan, the cost to communities of extraction works. We also point out that one aspect of a low-carbon economy, referred to in paragraph 3.6 of the Justification to this section, should imply a low-concrete economy, as set out more fully in answer to Question 5.

Q3 Strategic Policy for Minerals Provision
We agree with the principles set out in SP2. In particular we approve of the priority being given to extension of existing sites over the development of new sites, and wish to emphasise the second paragraph in SP2, the need for avoidance of the damage of development of new sites.



Q4 Bio-diversity-led Restoration
While the general principles as set out in SP3 appear benevolent, they may be, and have previously been, used to present a false picture of the effects of minerals extraction as some sort of "gain." Specifically, it is wrong to suggest that there is any gain in the destruction of a diverse farming landscape of mixed pasture and arable land, with trees and hedges, turning it into an open area of stagnant water. The National Character Area description, NCA48, concerning the Trent and Belvoir Vales (NE429) makes it clear that "wetland" is already more than adequately provided in this part of Nottinghamshire. "Wildlife Corridors" referred to in the draft Strategic policy do not require a continuous ribbon of static holes full of water, but stopping and nesting sites that migratory wildfowl can fly between. Such places are, if anything, already over-supplied in this area by past gravel workings. If turned into high-quality nature reserves, such as at Attenborough, this is the work of decades and at great expense by charities and local councils. If left to minimum-cost "restoration," as suggested in 13.4, this creates a large wasted space of lifeless lagoons, as at Hoveringham. Such bodies of water may, if close to residential areas, present health risks to those with breathing problems, or, near road routes, create dangerous foggy conditions from time to time.

Q5 Climate Change
There are two important ways that climate change should affect the Minerals Plan, and both are referred to in Policy SP4. Paragraph 1(a) refers to the desirability of moving to a low carbon economy, but one aspect of such a move not mentioned is the desirability of using less concrete (and consequently less aggregate.) Creation of concrete not only uses large amounts of fossil fuel, but the process of creating cement specifically consists of breaking down the chemical composition of limestone by driving off large volumes of carbon dioxide into the atmosphere. Modern construction methods tend to use less concrete than was formerly used. As referred to in paragraphs 1(b) and 1(c), the second point on climate change is that it is producing greater extremes of weather, including longer periods of very high rainfall. This means areas at risk of flooding are in future at risk of more frequent and more severe potential flooding. Exacerbation of such risk, especially when close to existing human settlement, by extraction of gravel from river banks, is therefore to be all the more strenuously avoided.

Q6 Sustainable Transport
We would emphasise the point SO5 in the Objectives list in this section, "minimising impact on communities." This is not necessarily best achieved in all cases by barging or by having extraction sites close to end markets. Heavy lorries on single-carriageway roads necessarily cause extra congestion, danger, pollution and dust. Longer journeys by clearer roads - or better still by rail - may have less damaging impact. To cite an example no longer under consideration but studied locally in the now-discontinued previous Draft Minerals Local Plan, barging from a proposed new-built site in Shelford would have caused great problems to residents in Burton Joyce, a few metres from that site, from the noise and air pollution, from both its construction and operation, and added to the already unacceptable flood risk, while cutting out only about four miles of road travel before the entire loads were put back onto the same overcrowded A612 route.

Q7. The built, historic and natural environment
We agree with the Policy SP6 standards, and place particular emphasis on landscape character; flood risk; community amenity. As stated above, mainly in answer to Question 4, we have strong reservations about any claim, such as that at 3.49, that "restoration to wetland" has any meaningful contribution to make to local biodiversity. We strongly support the point made in paragraph 3.58 that the landscape in the Trent Washlands is particularly under pressure. We reiterate our concerns expressed earlier on issues mentioned under Flooding, paragraphs 3.61-3.64, but would add that increase in flood risk to areas of human settlement should not be contemplated at all, since the damage, both in financial terms and its destructive effect on people's lives, can far outweigh the value of material extracted. We therefore reject the assumption of paragraph 3.65 that it is sufficient "in some cases" merely "to reduce flood risks" from new mineral extraction plans. In our view there must always be an EIA before consideration of any such proposed quarrying. We state again our opposition to plans that would add significant amounts of heavy traffic to already-overloaded road systems. None of the sites in the present Draft is in the immediate vicinity of our Parish. However, under the previous Minerals Local Plan and the now-withdrawn first version of the current Draft Plan, proposals were made for gravel extraction on our immediate river bank, and then on the neighbouring Shelford bank, which would have brought quarrying to about 200 metres from the nearest houses in Burton Joyce. Therefore we are very conscious of the great value placed on the beautiful local landscape; and we would wish to avoid any such potential destructive impact at any site.

Q8 The Nottinghamshire Green Belt
The Green Belt is not itself designed to provide adequate protection against destructive mineral extraction operations. However, "beneficial use of the Green Belt" must include its landscape character, which is bound to be damaged by mineral working; and especially sand and gravel digging.

Q9 Mineral Safeguarding Consultation areas and associated minerals infrastructure
The greater part of this section is beyond our specific concerns or expertise. However, we view with alarm the reference to the wharf at Colwick, 3.90 and 3.91. The proposal for quarrying at Shelford, part of a revised version of the draft Minerals plan in the consultation and draft plan abandoned in 2017, would have had devastating consequences for Burton Joyce. This is not the place to raise those specific points again, but to say that the Shelford proposal has been excluded from this Draft for no doubt strong reasons. There is no reason to mention that wharf in this Draft Plan if there is not the expectation of adding the Shelford proposal at a later stage. The Fact that the wharf is out of use and part of an existing industrial estate is a positive reason to put that land to more productive use by removing the wharf, and removing also a spurious case for reviving that very threatening proposal.

Q10 Aggregate provision
We are clearly among those who, at the Issues and Options stage, referred to in the first box under MP1 on p.55, advocated a significant allowance for recycled materials as a replacement for newly-extracted aggregates. Given the very high proportion of aggregates in the minerals usage nationally, as quoted in paragraph 4.6, and the very high proportion that these materials represent in Nottinghamshire's minerals output, even a fairly small percentage contribution from recycled and secondary aggregates would make a very significant reduction to total extraction requirements. We must recognise that this is not in the financial interests of extraction businesses, nor perhaps does it help with imposed targets to be hit, but protection of the wider interests of the area and its inhabitants is the essence of planning controls. We therefore are also advocates for Option B in the forecast figures in the second box on that page, "a lower figure than Option A." But of course in the second set of Options we prefer that proposed, A, "Prioritise extensions to existing permitted quarries." We thus consider the figure for sand and gravel, 32.30 million tonnes, in Policy MP1, to be an overestimate that can lead to serious but avoidable harm to the area, and we object to the subsequent figures in the tables at 4.10.

Q11. The draft specific sand and gravel site allocations
Clearly this Council is among those described in the second paragraph of the first box under MP2: we consider that the impacts on local residents, the availability of capacity on the highway network and the availability of recycled materials in the main urban areas should override the attractions of an even geographical spread, and therefore we disagree with the Appraisal Findings under that heading. While in general terms we see benefits to river barging from some sites, this is subject to our severe concerns set out in the answer to Question 9. Since none of the specific proposed extraction sites in the remainder of this section is close to Burton Joyce or its road and transport routes, we make no comment on their individual merits but would simply wish to see that the same standards we would apply to our own area should apply to other places: the reduction in estimates of overall new-dug aggregate demand, and the protection of more densely inhabited parts of the County from the dangers, loss of quality of life, and environmental destruction that nearby quarrying operations would cause.

Draft Nottinghamshire Minerals Local Plan
Response from Thrumpton Parish Meeting - September 2018
Summary
1. Thrumpton Parish Meeting objects to the Draft Nottinghamshire Minerals Local Plan published in July 2018, and, in particular, to the inclusion of the site MP2s at Mill Hill nr Barton in Fabis.
2. In summary our objection is based on:
a) The identification of flaws in the analysis of issues and options that underpin the Draft Plan, and in particular the identification of geographical spread as a key factor determining site allocation.
b) The application of a rationale for the allocation of sites which is inconsistent with the strategic objectives that have been used to shape the Draft Plan.
c) The allocation of the site at Mill Hill, Barton in Fabis even though the NCCs own analysis shows it to be one of the most damaging developments for sand and gravel of those considered. Such an allocation is inconsistent with the strategic objectives set out in the plan and the strategic policy for sustainable development and planning requirements set out in the National Planning Policy Framework that should underpin it.
d) The process by which the draft plan has been formulated is flawed, and the recommendations in relation to Mill Hill nr Barton in Fabis are therefore unsound. The analysis of the site listed variously as Barton in Fabis or Barton in Fabis (west) is also inaccurate, seriously under-rating its potential impact on local residents. The revised Draft Minerals Plan does not therefore meet the standard of evidence-based planning that is to be expected in the minerals planning process.
The detailed reasoning for these objections is set out in the response from Barton in Fabis Parish Council which we would ask you to make reference to. We will summarise our position and our objections in this response.
Response to Consultation Questions
Question 1: What do you think to the draft vision and strategic objectives set out in the plan?
Question 2: What do you think of the draft strategic policy for sustainable development?
Question 3: What do you think to the draft strategic policy for minerals provision?
We object to the way in which the plan fails to adhere to the strategic objectives set out in 2.30 rather than to the objectives themselves. In particular, SO6 'Protecting and enhancing natural assets' states that an objective is to 'Conserve and enhance Nottinghamshire's natural environment, including its distinctive landscapes, habitats, geology, wildlife species and ecological health of water bodies by avoiding, minimising and mitigating potential

negative impacts.' The Plan has then allocated sites with the greatest environmental impact simply on grounds of size and location - even though nether size nor location appear as strategic objectives. The site allocation process is therefore flawed.
We therefore object to the plan on grounds that the site allocation methodology developed and applied is inconsistent with the strategic objectives of the strategic policy for minerals provision.
Question 4 What do you think of the draft strategic policy for biodiversity led restoration?
We object to the plan on grounds that the policy for biodiversity-led restoration is inadequate. Its application as a criteria for site allocation is flawed because it does not meaningfully discriminate between proposals in terms of the likely success of biodiversity-led restoration.
Question 6: What do you think of the draft strategic policy for sustainable transport?
We object to the Plan and the policy related to sustainable transport because we feel that It is not the function of the planning system to manipulate the geography of the market and associated commercial risk, but rather to ensure that development is appropriate and sustainable, given wider societal needs and requirements. The policy on sustainable transport needs to reflect this. One such requirement, for example, is the use of modes of transport other than road. Another is that the most vulnerable and valuable sites are protected notwithstanding their proximity to market.
Question 7: What do you think of the draft strategic policy for the built, historic and natural environment?
We object to the formulation of Policy SP6 because of the lack of transparency in the way it is applied in the site allocation process. The emphasis on restoration should be reduced and the importance of protection and maintenance of assets should be stressed.
Question 8: What do you think of the draft strategic policy for the Nottinghamshire Green Belt?
Policy SP7 is not transparent in that it fails to state how, in the context of minerals planning, the two tests of 'appropriateness' and 'special circumstances' will be applied. It should be noted that 'special circumstances' in relation to the Green Belt do not include supposed proximity to market or goals of developing a 'spatially sustainable distribution' of minerals sites.
We therefore object to the policy statement on green belt because it lacks any clear indication of how it is to be applied in the minerals planning process.

Question 11: What do you think of the draft site specific sand and gravel allocations?
We object to the application of the site Draft Selection Methodology and its conclusions on grounds of the inconsistency of its outcomes with the stated policy objectives that are stated as underpinning the Draft Plan.
The Draft Plan is therefore flawed and should be revised accordingly to meet the County's own sustainability objectives. In order to do so:
* sites should be considered on their own merits to minimise the likely overall environmental impacts of the Draft Plan;
* geographical spread should only be used to make decisions between sites when all other things are considered equal in order that it does not over-ride consideration of the scale of environmental damage likely to arise by the inappropriate selection of sites due to location. Proximity to market is not an 'exceptional circumstance' as envisaged by the NPPF.
Site at Mill Hill nr Barton in Fabis
We believe the scale of the impacts for the Mill Hill site have been under-estimated, making the decision insecure. We therefore object to the assessment made for the Mill Hill site.
The allocation of the site is not consistent with the objectives of SO6 or SP6. The landscape impacts are amongst the highest attributed to any site in the appraisal matrix, the allocation of this site in the Draft Plan is clearly inconsistent with Policy SP6.
The impact of the proposed development on the greenbelt also conflicts with the stated policy in SP6, because the processing plant will be located on a prominent ridgeline on Mill Hill. This will have an adverse impact on the openness and visual amenity of the Green Belt in this area. It will therefore conflict with the purposes of the Green Belt and should consequently be considered inappropriate development.
The bridleway passing through and near the site is part of the Trent Valley Way and is an important strategic route between Barton and Thrumpton in the county and Clifton and Wilford in the city which is extremely well-used by walkers, cyclists, and horseriders. The path will be close to quarry workings and will have to cross the site access road and gravel conveyor - this will have a major negative impact on users.
Just a river's width away from the site, those who walk Attenborough's riverside paths will continually view the adverse effects of the site over the lengthy operational period and will no longer be able to enjoy the peace and tranquillity of Attenborough Nature Reserve - a site of special scientific interest (SSSI) and one of the most important sites for conservation in the East Midlands. The noise and dust will have a negative impact on wildlife in the reserve.
The impacts are very negative in both the operational phase and the long-term operation and clearly inconsistent with most of the key sustainability objectives and strategic policies that frame the minerals plan. There is a lack of transparency in the assessment in terms of how the site is allocated on the grounds of viability and location when the impact assessment clearly indicates that there are other sites where impacts are far less serious.
The process by which the recommendation arose is flawed, and neither transparent or credible given even the partial evidence-base identified in the Draft Plan.

We therefore object to the allocation of the Mill Hill site.
Our main concerns with the allocation of the site are as follows:
* The Council's own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the third most damaging in the long-term.
* The Council has stated that "there is no published data related to geographical spread". Therefore, the Plan is 'unsound' as the Council has sought to justify the inclusion of the site based on "maintaining a geographical spread" and therefore overriding the adverse impact on sustainability.
* There have been no projections for sand and gravel demand in the different submarket areas. The Council's statement that the Shelford or Coddington sites are too big cannot be justified
* The Council has failed to follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" by not allocating any sites which use this mode of transport.
* The site would impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five Local Wildlife Sites one of which will be destroyed altogether.
* Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site - providing significant evidence of the negative impact on wildlife and the environment.
* The site is in the Green Belt, and Brandshill and Clifton Woods, adjacent to the site, have been designated as Ancient Woodland which have special protection under the National Planning Policy Framework (NPPF). The Council has failed to justify any "wholly exceptional reasons" required by the NPPF.
* The site is close to heavily populated areas - including the new Fairham Pastures development of 3,000 homes - which would be impacted by noise and dust from the site itself and from the extensive lorry movements.
* This plan generates 114 lorry movements a day on the section of Green Street adjoining Mill Hill. This was approved in the A453 dualling plans as being part of a route for non-motorised users, but this number of lorry movements is not compatible with safe cycling, walking or horse riding. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down. This number of lorry movements would make this junction even more hazardous.
* There would be a major impact on the quality of life and visual amenity of local people, as well as the loss of peace and tranquillity in an area used extensively by a wider community for walking, fishing, cycling, horse riding, bird watching and other leisure pursuits. The loss of a significant area of countryside on the edge of a large city such as Nottingham damages the recreational opportunities that are increasingly important for the health and well-being of residents.

Site described as Barton in Fabis or Barton in Fabis (west)
We are also concerned about inaccuracies in the analysis of the site included in the 'Draft site selection methodology and assessment July 2018' and listed as Barton in Fabis or Barton in Fabis (west). Although this site has not been selected, this site assessment may be further used following the outcomes of this consultation and possibly as evidence for future mineral plans or planning applications, we therefore believe it is crucial that the information is reassessed and corrected.
Our main concerns are as follows:
Site location
This site is actually in the parish of Thrumpton and, as a consequence, was not immediately evident to residents of Thrumpton as being in such close proximity to the village. The site should be renamed to include Thrumpton to make its location clear.
Sustainability assessment
The assessment of visual sensitivity states:
The main visual impact would be on residents to the southern edge of Barton in Fabis and on users of the Trent Valley Way to the north of the site. There would be more distant views from residential properties on the northern edge of Thrumpton.
In reality, around 50% of Thrumpton properties would have a clear view of the site - these would not be 'distant views' as the site would be within 400-800 metres. The site would also be highly visible from the A453. Crucially, three properties (Fields Farm, The Orchard and Canterbury House) directly adjoin the site yet criteria 14 'Protect and improve human health and quality of life' makes no reference to the close-proximity of these properties and the assessment gives no consideration to the drastic impact (including noise, dust, traffic movement, visual amenity, property value) on these properties and their residents. Lack of reference to such an important factor indicates an inadequate assessment process.
Transport/highway implications
The Transport Evidence Base states that the Annual Average Daily Flow of HGVs on Green Street/Barton Lane is 15 and would be increased by 90 additional lorry movements per day - an increase of 600%. It dismisses this by stating that "Percentage changes in traffic on Green Street would be high, but this is mainly a result of this route being bypassed by the A453 leaving only low residual traffic flows." It also states that "once onto Green Street the route to the A453 is short."
In reality it is 1.8 miles on a road clearly approved and designated as part of the A453 dualling scheme as a route for non-motorised users linking Mill Hill to Long Lane. This number of lorry movements is simply not compatible with safe cycling, walking or horse riding on a road where there is no traffic separation. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down and this number of lorry movements would make this junction even more hazardous. The report's conclusion that No road safety issues identified is therefore flawed, inaccurate and highly misleading.

Conclusion
We object to a number of aspects of the Draft Plan as set out above.
The evidence for the Mill Hill nr Barton in Fabis site - one of the most environmentally sensitive sites in the assessment (and rejected on these grounds previously by the Council) - does not support its selection.
We believe the criteria and the process used were flawed. The inaccuracies in the assessment of Barton in Fabis (west) raise further questions about the robustness of the assessment process.