Appendix 2: Site Allocation Development Briefs

Gedling Borough welcomes and supports the Site Allocation Brief for Bestwood 2 Northern Extension. In particualar there is support for ensuring that the restoration scheme should demonstrate that the loss of the LWS would be outweighed by the need for the mineral and compensated for through the creation of high quality habitat.

Whilst the site proposed to be allocated by this policy (Policy MP2p – ‘Mill Hill near Barton In
Fabis’) is not located within the local authority area of Broxtowe Borough Council, it is situated
immediately adjacent to the Borough’s boundary.
The Borough Council is of the view that the policy and supporting site development brief should
be slightly amended to enhance the level of protection for the various natural and recreational
assets along this part of the Borough’s boundary.
A number of environmental and recreational assets within the Borough Council’s boundary may
potentially be adversely affected by this allocation. These include not only the Attenborough
Gravel Pits SSSI, which is referred to within the site development brief, but also the
Attenborough Nature Reserve (open space) and Trent Valley Green Infrastructure (GI) Corridor.
The Borough Council notes that the ‘policy’ does not refer to the ‘Trent Valley Green
Infrastructure (GI) Corridor’, which runs along the River Trent. There is also no reference to this
GI Corridor within the site development brief. This important GI Corridor is not only of
environmental and biodiversity value, but is also an important recreational route within the
Borough. The development of a minerals extraction facility close to this location has the potential
to impact upon the environmental assets of the local area, as well as the potential of the area as
a recreational resource to the local community.

The Borough Council recommends that mitigation measures should be proposed within the
policy and site development brief to protect the various nearby environmental and recreational
assets within the Borough’s boundary, including the Attenborough Gravel Pits SSSI,
Attenborough Nature Reserve (open space) and the Trent Valley Green Infrastructure Corridor,
in order to both protect wildlife and biodiversity and also to minimise any disturbance to the
recreational use of these areas. Examples of such mitigation measures could include additional
buffers between the mineral extraction site and the banks of the River Trent.
The Borough Council also recommends that the Trent Valley Green Infrastructure Corridor is
referenced within the site development brief.

Parts 1 (a) and 2 (a) of Policy MP12 refer to ‘protected areas’, although the policy does not
currently define which types of ‘protection’ this term refers to. The Borough Council is of the view
that it would be helpful for the policy and supporting text to clearly define the extent of these
‘areas’. In particular, it would be useful to clarify whether these areas include land designated as
‘Green Belt’ or land protected by other designations (for example, Local Wildlife Sites, SSSIs,
Local Nature Reserves etc.).
The Borough Council recommends that the term ‘protected areas’, as referred to within parts
1(a) and 2(a) of Policy MP12, should be clearly defined within the policy and supporting text. The
Borough Council considers that the inclusion of mapping illustrating the extent of these
‘protected areas’ would also be very useful

Thank you for the opportunity to comment on your consultation. Severn Trent are generally supportive of Polices to protect the environment and water resources, and agree with the principles outlined within the minerals plan to protect ground and surface water from the impacts of mineral extraction, to help to deliver Water Framework Directives, to mitigate the impacts of climate change and flooding, where possible.
There are a number of sites that are indicated to be located in close proximity or intersect with Severn Trent assets:
Potential Mineral Allocation Sites:
 MP2k (Bawtry Road West) – This site falls within a groundwater Source Protection Zone (SPZ) 3 therefore it may pose a risk to groundwater assets. This site is located within the Idle and Torne EA CAMS (Environment Agency Catchment Abstraction Management Strategies) area and is also situated within a sub-area designated as ‘Water Not Available for Licensing” (See Note1 below).
 MP2l (Scrooby Thompson Land) - The site falls within a groundwater SPZ 3 therefore it may pose a risk to groundwater assets. This site is located within the Idle and Torne EA CAMS area and is also situated within a sub-area designated as ‘Water Not Available for Licensing” (See Note1 below).
 MP2m (Scrooby North) - The site falls within a groundwater SPZ 3 therefore it may pose a risk to groundwater assets. This site is located within the Idle and Torne EA CAMS area and is also situated within a sub-area designated as ‘Water Not Available for Licensing” (See Note1 below).
 MP3 (Scrooby Top North) - The site falls within a groundwater SPZ 3 therefore it may pose a risk to groundwater assets. This site is located within the Idle and Torne EA CAMS area and is also situated within a sub-area designated as ‘Water Not Available for Licensing” (See Note1 below).
 MP2n (Langford Lowfield North) – The site does not fall in a groundwater asset Source Protection Zone therefore it is unlikely to pose a risk to groundwater assets. No CAMS data is available from the EA for this site.
 MP2o (Besthorpe East) - The site does not fall in a groundwater asset Source Protection Zone therefore it is unlikely to pose a risk to groundwater assets. No CAMS data is available from the EA for this site.
2
 MP7c (Bantycock Quarry South) - the site is indicated to be in close proximity to Severn
Trent surface water assets therefore it may be necessary to have discussions concerning
extraction, to ensure that Severn Trent assets are not adversely effected by operations. The
site does not fall in a groundwater asset Source Protection Zone therefore it is unlikely to
pose a risk to groundwater assets. No CAMS data is available from the EA for this site.
 MP3d (Bestwood 2 North) - The site falls within a groundwater SPZ 3 therefore it may pose
a risk to groundwater assets. This site falls within the Lower Trent & Erewash EA CAMS
area and is also situated within a sub-area designated as ‘Water Not Available for Licensing”
(See Note1 below).
 MP2p Mill Hill (near Barton in Fabis) – This minerals extraction site is indicated to be
intersected by Severn Trent surface water assets, therefore discussions with Severn Trent
should be held to ensure that impacts on Severn Trent are appropriately mitigated. The site
does not fall in a groundwater asset Source Protection Zone therefore it is unlikely to pose a
risk to groundwater assets. CAMS data are not available from the EA for this site.
All Permitted Sites April 2019:
 MP2g (Girton) – The site does not fall in a groundwater asset Source Protection Zone
therefore it is unlikely to pose a risk to groundwater assets. CAMS data are not available
from the EA for this site.
 MP2h (Langford Lowfields) – Indicated to be in close proximity to Severn Trent Surface
Water assets. The site does not fall in a groundwater asset Source Protection Zone
therefore it is unlikely to pose a risk to groundwater assets. CAMS data are not available
from the EA for this site.
 MP2f (Besthorpe) - Indicated to be in close proximity to Severn Trent Surface Water assets.
The site does not fall in a groundwater asset Source Protection Zone therefore it is unlikely
to pose a risk to groundwater assets. CAMS data are not available from the EA for this site.
 MP2c (Sturton Le Steeple) - The site does not fall in a groundwater asset Source
Protection Zone therefore it is unlikely to pose a risk to groundwater assets. CAMS data are
not available from the EA for this site.
 MP2a (Newington South) - The site falls within a groundwater SPZ 3 therefore it may pose
a risk to groundwater assets. This site is located within the Idle and Torne EA CAMS area
and is also situated within a sub-area designated as ‘Water Not Available for Licensing” (See
Note1 below).
 MP4a (Nether Langwith) - The site does not fall in a groundwater asset Source Protection
Zone therefore it is unlikely to pose a risk to groundwater assets. This site falls within the Idle
& Torne EA CAMS area and is also situated within a sub-area designated as ‘Water Not
Available for Licensing” (See Note1 below).
 MP7b (Bantycock Quarry) - the site is indicated to be in close proximity to Severn Trent
assets it may be necessary to have discussions around the extraction, to ensure that Severn
Trent assets are not adversely effected by operations. The site does not fall in a
groundwater asset Source Protection Zone therefore it is unlikely to pose a risk to
groundwater assets. CAMS data are not available from the EA for this site.
 MP6b (Dorket Head – part a) - the site is bounded by Severn Trent assets; we strongly
advise that Severn Trent Water is consulted during permitting to ensure that Severn Trent
assets are not adversely effected by operations. The site does not fall in a groundwater
3
asset Source Protection Zone therefore it is unlikely to pose a risk to groundwater assets.
CAMS data are not available from the EA for this site.
 MP3a (Burnstump) - the site is indicated to be intersected by Severn Trent assets, it is vital
that discussions are held with Severn Trent to ensure that any impacts on Severn Trent
assets are managed appropriately. The site falls within a groundwater SPZ 3 and is
approximately 60 m from an SPZ 2 therefore there is a moderate chance it may pose a risk
to groundwater assets. This site falls within the Lower Trent & Erewash EA CAMS area and
is also situated within a sub-area designated as ‘Water Not Available for Licensing” (See
Note1 below).
 MP6b (Dorket Head – part b) - the site is indicated to be intersected by Severn Trent
assets, it is vital that discussions are held with Severn Trent to ensure that any impacts on
Severn Trent assets are managed appropriately. The site does not fall in a groundwater
asset Source Protection Zone therefore it is unlikely to pose a risk to groundwater assets.
CAMS data are not available from the EA for this site.
 MP7a (Marlaegis Mine) – the site is located in close proximity to Severn Trent assets it may
be necessary to discuss these assets to prevent any detrimental impacts to the Severn Trent
network. The site does not fall in a groundwater asset SPZ therefore it is unlikely to pose a
risk to groundwater assets. CAMS data are not available from the EA for this site.
 MP8a (Two Oaks Farm) - the site is indicated to be bounded by Severn Trent assets, it may
be necessary to discuss the site with Severn Trent to ensure that the development of the site
does not have an adverse impact on Severn Trent assets. The site falls within a groundwater
SPZ 3 therefore it may pose a risk to groundwater assets. This site is also located within the
Idle & Torne EA CAMS area and is designated as ‘Water Not Available for Licensing” (See
Note1 below).
 MP10a (Yellowstone Quarry) - The site does not fall in a groundwater asset Source
Protection Zone therefore it is unlikely to pose a risk to groundwater assets. This site falls
within Lower Trent & Erewash EA CAMS area and is also situated within a sub-area
designated as ‘Restricted Water Available for Licensing” (See Note1 below).
 MP3b (Bestwood 2) - The site is indicated to be bounded by Severn Trent Assets,
discussion We strongly recommend that you contact Severn Trent to ensure that Severn
Trent assets are not adversely effected. The site falls within a groundwater SPZ 3 therefore
it may pose a risk to groundwater assets. This site falls within Lower Trent & Erewash EA
CAMS area and is also situated within a sub-area designated as ‘Water Not Available for
Licensing” (See Note1 below).
 MP2i (East Leake) - the site is located in close proximity to Severn Trent assets it may be
necessary to discuss these assets to prevent any detrimental impacts to the Severn Trent
network. The site does not fall in a groundwater asset Source Protection Zone therefore it is
unlikely to pose a risk to groundwater assets. CAMS data are not available from the EA for
this site.
 MP2e (Cromwell) – This site is indicated to be in close proximity to Severn Trent surface
water assets. The site does not fall in a groundwater asset Source Protection Zone therefore
it is unlikely to pose a risk to groundwater assets. CAMS data are not available from the EA
for this site.
 MP3c (Scrooby Top) - The site falls within a groundwater SPZ 3 therefore it may pose a
risk to groundwater assets. This site falls within the Idle & Torne EA CAMS area and is also
situated within a sub-area designated as ‘Water Not Available for Licensing” (See Note1
below).
4
 MP2j (Scrooby) - The site falls within a groundwater SPZ 3 therefore it may pose a risk to
groundwater assets. This site falls within the Idle & Torne EA CAMS area and is also
situated within a sub-area designated as ‘Water Not Available for Licensing” (See Note1
below).
 MP2b (Finningley) - The site is located within a groundwater SPZ 3 therefore it may pose a
risk to groundwater assets. This site falls within the Idle & Torne EA CAMS area and is also
situated within a sub-area designated as ‘Water Not Available for Licensing” (See Note1
below).
 MP2d (Bawtry Road) - The site falls within a groundwater SPZ 3 therefore it may pose a
risk to groundwater assets. This site falls within the Idle & Torne EA CAMS area and is also
situated within a sub-area designated as ‘Water Not Available for Licensing” (See Note1
below).
 MP6a (Kirton) - The site falls within a groundwater SPZ 3 therefore it may pose a risk to
groundwater assets. This site falls within the Idle & Torne EA CAMS area and is also
situated within a sub-area designated as ‘Water Not Available for Licensing” (See Note1
below).
South Muskham Archaeological Centre:
 DM6 – The allocation around South Muskham is indicated to be in close proximity to Severn
Trent surface water assets. The site does not fall in a groundwater asset Source Protection
Zone therefore it is unlikely to pose a risk to groundwater assets. CAMS data are not
available from the EA for this site.
Note1 – The specific quarry sites designated above fall within an Environment Agency CAMS subareas
which are marked as either “(Ground) Water Not Available for Licensing” or “Restricted
(Ground) Water Available”. In such areas the EA is unlikely to grant new consumptive abstraction
licences. Even in “(Ground) Water Available for Licensing” areas the EA would request that the
WFD ‘No-Deterioration” principles are followed.
Please keep us informed when your plans are further developed when we will be able to offer more
detailed comments and advice.
For your information we have set out some general guidelines that may be useful to you.
Position Statement
As a water company we have an obligation to provide water supplies and sewage treatment
capacity for domestic flows from future development. It is important for us to work collaboratively
with Local Planning Authorities to provide relevant assessments of the impacts of future
developments. For outline proposals we are able to provide general comments. Once detailed
developments and site specific locations are confirmed by local councils, we are able to provide
more specific comments and modelling of the network if required. For most developments we do not
foresee any particular issues that would prevent the supply of water or sewerage. Where we
consider there may be an issue we would discuss in further detail with the Local Planning Authority.
Where quarries are proposed to be developed or extended, we do not anticipate there will be any
significant need to supply water or sewerage due to the nature of development. If however you
anticipate that there will be a requirement for Severn Trent to provide these services it is strongly
advised that you contact us to ensure that capacity can be made available at the appropriate time.
5
Sewage Strategy
Once detailed plans are available and we have modelled the additional capacity, in areas where sufficient capacity is not currently available and we have sufficient confidence that developments will be built, we will complete necessary improvements to provide the capacity. We will ensure that our assets have no adverse effect on the environment and that we provide appropriate levels of treatment at each of our sewage treatment works.
Surface Water and Sewer Flooding
Whilst we do not anticipate a significant increase in impermeable area, it may be necessary to pump water out of the minerals working area. Severn Trent would anticipate that this will be managed appropriately onsite and discharged through sustainable outfall, without the need to utilise public sewerage network. It is however anticipated that sewerage connections may be required for site offices and welfare facilities.
Groundwater
While most of the proposed locations do not appear to constitute a significant risk to water quality of our assets, there are a few that may constitute risks to groundwater assets. Severn Trent strongly recommends that all appropriate EA guidance is followed with reference to site management and any future abstraction of water to ensure the WFD ‘No-Deterioration’ Principles are followed.
Water Quality
Good quality river water and groundwater is vital for provision of good quality drinking water. We work closely with the Environment Agency and local farmers to ensure that water quality of supplies are not impacted by our or others operations. The Environment Agency’s Source Protection Zone (SPZ) and Safe Guarding Zone policy should provide guidance on development. Any proposals should take into account the principles of the Water Framework Directive and River Basin Management Plan for the Severn River basin unit as prepared by the Environment Agency.
Water Supply
Whilst it is not anticipated that water supply will be required for quarrying operations, we do anticipate some water supply needs for domestic activities associated with site offices and welfare facilities.
We would not anticipate capacity problems within the urban areas of our network, any issues can be addressed through reinforcing our network. However, the ability to support significant development in the rural areas is likely to have a greater impact and require greater reinforcement to accommodate greater demands.
We hope this information has been useful to you and we look forward in hearing from you in the near future.

Publication Version of the Nottinghamshire Mineral Plan

Thank you for the opportunity to comment on the Publication version of the
Nottinghamshire Minerals Local Plan.

The Environment Agency supports the publication of this Local Plan.

The Environment Agency is satisfied that the Local Plan is legally complaint.

The Environment Agency is satisfied that the Local Plan is sound.

We welcome the comments made in the responses from the council to the draft mineral plan about the changes between minimised and mitigated. We accept the reason that minimised has been kept within the wording.

SP3 Climate Change
We welcome this policy inclusion within the Mineral Plan and the requirements for minimising the risks upon climate change. We had previously asked that all mineral development should reduce, or as a minimum, cause no increases in their impact on the causes of climate change in our response to the draft mineral plan and would reiterate this for inclusion.

We also asked that water resources and water quality are added into part c) of the policy as restoration could offer future opportunities to so support the adaptation to climate change.

SP5 – The Built, Historic and Natural Environment
We previously highlighted the change of date for the Water Framework Directive (WFD), to 2027. We note that this wording doesn’t appear to be mentioned now within the document.

Water Resources Information
We have previously highlighted the changes to water abstraction regulations (new authorisations) that now requires abstractions, such as dewatering, that were previously exempt from permitting, to be brought into the permitting process, and now require an abstraction licence.

We reiterate this point and highlight that a number of sites previously mentioned will have difficulties obtaining new abstraction licences for water due to these changes, which could impact upon the viability of the sites. We wish to reiterate this non planning matter to the Local Planning Authority (LPA) for their consideration. Recent mineral applicants within these closed catchemnts, where planning permission has been granted, have subsequently come to the Environment Agency to discuss the requirements for a permit application. The Environment Agency permitting team have started the process of advising on the environmental permit process highlighting than an abstraction licence would be unlikely to be granted, however the EA have advised that some options, including neutral water balance options such as water reinjection or trading the rights to abstract groundwater should be considered.

Policy MP6: Brick Clay Provision
We note that the site area previously identified in the draft has now been removed.

Policy DM2: Water Resources and Flood Risk
We previously made comments about the layout and the wording of this particular policy. For information we reiterated that consideration was needed to whether the policy should be split up into separate ones, one for water resources, and the other for flooding. We also mentioned that as water quality is mentioned within the policy, then water quality should be included in the title of this policy.

In section 5.31 we previously mentioned that we would query that mineral extraction can increase flood risk elsewhere. We would reiterate that no development, no matter how temporary should not increase flood risk elsewhere as per the requirements of the National Planning Policy Framework.

Policy DM3: Agricultural land and soil quality
We welcome the inclusion of this policy.

Policy DM4: Protection and Enhancement of Biodiversity and Geodiversity
We welcome point 3 of this policy stating that biodiversity will be enhanced. Biodiversity net gain is a key matter to consider for any future mineral developments.

Policy DM12: Restoration, aftercare and after-use
We did ask that detailed information for flood risk and possible reductions in flood risk are included where full restoration plans are not provided.

Site Allocations
We have previously highlighted our comments on the proposed sites within the Mineral Plan. As per our comments relating to water resources and the new authorisations we would reiterate that a number of these sites will find it unlikely that any application for an abstraction licence will be approved. This risk needs to be understood by the Mineral Planning Authority and quarry operators and the permit requirements for each site need to be understood at the same time as, or before planning is applied for. We would reiterate that at the very least parallel tracking of both the planning and permitting processes should be undertaken, or even the permitting process be undertaken beforehand. This requirement should be added into the site briefs.

Yours sincerely

Please see attachment