Question 3: What do you think of the draft strategic policy for minerals provision?

Charnwood Borough Council welcomes the reference to encouraging the use of secondary and recycled aggregates. which is more sustainable and is in accordance with the new NPPF.

NSDC is supportive, particularly of 1.b.

Coddington Parish Council supports priority being given to the extension of existing sites as part of the conservation of minerals resources providing there is no adverse effect on local communities. Need to add making best use of existing resources by also giving priority to mothballed sites. Also need to add that planned sites are based on a spatial pattern to locate sites of supply closer to areas of demand, thus reducing the environmental and safety impacts of HGV transport.

We welcome the commitments to give priority to the extensions to existing sites.
We are concerned however that the policy does not specify how need for non-allocated sited will be assessed.
Culmulative local impact , particularly upon transport, should receive some priority

Support

CEMEX support the County Councils recognition that the strategy should in particular seek to identify land to maintain a steady and adequate supply of minerals (bullet point a). However, it is concerned that this relates just to the plan period and not a miniumum of seven years beyond this in accordance with paragraph 207 of the NPPF. In addition the words 'or as identified through the annual Local Aggregates Assessment' should be added to the end of bullet-point (a).

I writing to confirm that I wish to object to the above site.
The County Councils own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the 3rd most damaging in the long term.
The site would impact on two SSSIs (Sites of Special Scientific Interest) - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five LWS's (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.
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 which would be impacted by noise and dust.
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, horse riding, bird watching and other leisure pursuits, including an adverse impact on grazing land and especially to the respiratory health of horses. 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 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 of sustainability. However, the council has stated that 'there is no published data related to a geographical spread'.
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 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 policy should also secure adequate facilities to process mineral to ensure a steady supply of material throughout the plan period this will also prevent large landbanks of reserves in few sites.

It is important when thinking about this that the term "adequate" is properly used. What seems adequate today should, if low carbon objectives are met as we expect in the years ahead, soon appear to be oversupply.

The County Councils own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the 3rd most damaging in the long term.
The site would impact on two SSSIs (Sites of Special Scientific Interest) - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five LWS's (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.
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 which would be impacted by noise and dust.
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, horse riding, bird watching and other leisure pursuits, including an adverse impact on grazing land and especially to the respiratory health of horses. 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 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 of sustainability. However, the council has stated that 'there is no published data related to a geographical spread'.
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 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.

Proposed sand and gravel quarry site MP2s
I writing to confirm that I wish to object to the above site.
The County Councils own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the 3rd most damaging in the long term.
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 of sustainability. However, the council has stated that 'there is no published data related to a geographical spread'.
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 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 SSSIs (Sites of Special Scientific Interest) - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five LWS's (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.
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.
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, horse riding, bird watching and other leisure pursuits, including an adverse impact on grazing land and especially to the respiratory health of horses. 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.

Proposed sand and gravel quarry site MP2s
I writing to confirm that I wish to object to the above site.
The County Councils own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the 3rd most damaging in the long term.
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 of sustainability. However, the council has stated that 'there is no published data related to a geographical spread'.
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 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 SSSIs (Sites of Special Scientific Interest) - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five LWS's (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.
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 which would be impacted by noise and dust.
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, horse riding, bird watching and other leisure pursuits, including an adverse impact on grazing land and especially to the respiratory health of horses. 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.

Proposed sand and gravel quarry site MP2s
I writing to confirm that I wish to object to the above site.
The County Councils own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the 3rd most damaging in the long term.
The site would impact on two SSSIs (Sites of Special Scientific Interest) - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five LWS's (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.
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 which would be impacted by noise and dust.
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, horse riding, bird watching and other leisure pursuits, including an adverse impact on grazing land and especially to the respiratory health of horses. 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 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 of sustainability. However, the council has stated that 'there is no published data related to a geographical spread'.
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 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.

Proposed sand and gravel quarry site MP2s
I writing to confirm that I wish to object to the above site.
The County Councils own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the 3rd most damaging in the long term.
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 of sustainability. However, the council has stated that 'there is no published data related to a geographical spread'.
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 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 SSSIs (Sites of Special Scientific Interest) - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five LWS's (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.
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 which would be impacted by noise and dust.
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, horse riding, bird watching and other leisure pursuits, including an adverse impact on grazing land and especially to the respiratory health of horses. 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 wording of the policy makes sense however clearly this is not being followed!! There is a major issue with making a policy and then not following it! I live in Attenborough and walk along the river every morning and the thought of the effect of a gravel works on the opposite bank is horrifying! Where is the opinion sought of local people???

The Coal Authority supports the inclusion of this policy which sets out the strategy for minerals provision.

CAGE support the lower, more rational basis for the assessment of need based on the most recent data which conserves resources for the future and minimises the opening of new green field sites. CAGE supports priority being given mothballed sites and to extensions, providing they do not impact adversely on local communities and are located close to markets.

Cumulative effects should be examined rigorously, locally (both within and extending up to 20 miles beyond the County border) and regionally to protect communities and the environment from over-exploitation. Maps in the draft plan, such as Plan 2 should also show relevant features in neighbouring Counties. The revision of Plan 3 to correct an error in the earlier draft is welcomed.

CAGE supports the requirement for developers to provide adequate mitigation and compensation measures. It wishes that government policy would give more powers and safeguards to assure communities that proposed restoration scheme gains will actually be realised.

The draft policy would seem wholly appropriate in identifying a preference for site allocation but embracing the flexibility for site selection.

Reference: Sand and Gravel Provision Site 'MP2s Mill Hill nr Barton in Fabis'

Dear Sir/ Madam,

I am writing to confirm I wish to OBJECT to the above site because I live at Lark Hill Retirement Village, which lies directly in line of the prevailing wind from the proposed site. All residents here are over 65 years, most over 75. The dust and noise would be a dangerous health hazard for all the residents. Please consider these facts. There are other sites that do not impinge so heavily on so many senior citizens, all in one relatively small location.
Additionally I would stress:
The dust hazard would seriously affect my husband, who has already had an operation on his lungs. I am also personally concerned about the potential negative effect this site would have on the surrounding nature reserve and, consequently, on the abundant animal and bird life.

Proposed sand and gravel quarry site MP2s
I writing to confirm that I wish to object to the above site.
The County Councils own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the 3rd most damaging in the long term.
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 of sustainability. However, the council has stated that 'there is no published data related to a geographical spread'.
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 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 SSSIs (Sites of Special Scientific Interest) - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five LWS's (Local Wildlife Sites) one of which will be destroyed altogether.
Public Health England, Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site.
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.
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, horse riding, bird watching and other leisure pursuits, including an adverse impact on grazing land and especially to the respiratory health of horses. 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.

To whom it may concern,
My name is Robert Surgey and want to formally object to the sand and gravel provision MP2S Mill Hill Nr Barton in Fabis.
My objection is that If it goes ahead next year, the quarry will destroy 200 acres of wildlife habitat and feeding grounds for Attenborough Nature Reserve, ancient woodlands and spoil local natural landscape enjoyed by walkers, fishermen, cyclists and horseriders alike (i count myself as one of these). If that's not enough, it will create heavy noise and dust across Clifton, Barton in Fabis areas and has the potential for local flooding. It will most certainly spoil walks along Attenborough Nature Reserve, with planned work continuing for approx 15-25 years.

I hope this plan is cancelled.

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.

Proposed sand and gravel quarry site MP2s
I writing to confirm that I wish to object to the above site.
The County Councils own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the 3rd most damaging in the long term.
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 of sustainability. However, the council has stated that 'there is no published data related to a geographical spread'.
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 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 SSSIs (Sites of Special Scientific Interest) - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five LWS's (Local Wildlife Sites) one of which will be destroyed altogether.
Public Health England, Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site.
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.
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, horse riding, bird watching and other leisure pursuits, including an adverse impact on grazing land and especially to the respiratory health of horses. 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.

Proposed sand and gravel quarry site MP2s
I writing to confirm that I wish to object to the above site.
The County Councils own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the 3rd most damaging in the long term.
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 of sustainability. However, the council has stated that 'there is no published data related to a geographical spread'.
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 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 SSSIs (Sites of Special Scientific Interest) - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five LWS's (Local Wildlife Sites) one of which will be destroyed altogether.
Public Health England, Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site.
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 which would be impacted by noise and dust.
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, horse riding, bird watching and other leisure pursuits, including an adverse impact on grazing land and especially to the respiratory health of horses. 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.

Ref: Sand and Gravel Provision Site 'MP2s Mill Hill near Barton in Fabis'
To whom it may concern,
I am writing to object to the above site.
On a recent visit to my daughter's family in Barton in Fabis, I attended the presentation in the village hall. On their behalf I was concerned about the proposals.
* I learned from your representative that the original plans for gravel extraction were scrapped by the County Council because the site was 'too large' for current demands. Could you not just extract less? If the demand increases, then there would be capacity without opening another site.
* I heard that the previous site contained a highly commendable, environmentally friendly plan to use barges for removal of 40% of the materials instead of lorries, thus cutting down on pollution and noise. Why was this scrapped?
* I also heard that a member of the County Council lives in the previously affected village. Could this have played a part in the council's decision to relocate the site?
* The representative said that the gravel extraction sites were spread across the county to lesson the impact, but there were no maps or plans available for the public to judge for themselves whether or not this was so.
* I am concerned about the environmental impact as the noise of machinery and traffic relating to the extraction will disturb the wildlife in a Site of Special Scientific Interest and cause the destruction of one of five Local Wildlife sites.
* The proposed site is very close to populated areas which will be affected by both noise, dust and air pollution from the increase in heavy traffic.

I feel that the decision making process for these plans may not be fair and unbiased. For this reason I am objecting to the proposals.
Yours faithfully,

Susan Dick

I am writing to confirm that my husband and I wish to object to the above site

Hi there,
I would like to object to MP2S Mill Hill Nr Barton in Fabis sand and gravel provision.
If it goes ahead next year, the quarry will destroy 200 acres of wildlife habitat and feeding grounds for Attenborough Nature Reserve, ancient woodlands and spoil local natural landscape enjoyed by walkers, fishermen, cyclists and horseriders alike. If that's not enough, it will create heavy noise and dust across Clifton, Barton in Fabis areas and has the potential for local flooding. It will most certainly spoil walks along Attenborough Nature Reserve, with planned work continuing for approx 15-25 years. We regularly enjoy visiting the area to visit a local resident. We are concerned about the high levels of dust and noise and local residents health may be impacted by this. Please consider my objection.

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.