MP8: Silica Sand Provision

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Nottinghamshire Minerals Local Plan Publication Version

Representation ID: 99

Received: 11/10/2019

Respondent: Nottinghamshire Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

NWT do not consider this policy to be sound because of the inherent contradiction between the Plan-led approach whilst simultaneously making specific provision for potential development on non-allocated sites within Policy MP8. If the plan-making process has been robust and based on good data, then there should be no need for development on non-allocated sites. A robust plan review progress at fixed intervals may identify the need to bring new sites forward for further allocations in a proper manner, where the need has changed, in which case they can be compared to other potential sites in a rigorous way. It is not a rigorous process for a single operator’s proposal to be brought forward at a particular point in time, and therefore not be subject to a proper comparative test against others prospective sites, including an SA. Given the predicted life for Two Oaks Farm Quarry is 40 years, well beyond the recommende 10 year land bank for this resource, the inclusion of bullet point 2 is unnecessary and incongruous.

By undermining the plan-led approach, it is possible that this policy could inadvertently breach the requirements of the NPPF and so may not be legally compliant.

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