Minerals Local Plan Issues and Options consultation

Response from SAGE to the Issues and Options Consultation

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

The overview refers to the impact that quarrying has had on the creation of wetlands. It should be emphasised that the creation of so many lakes has already had an adverse impact by changing the whole nature of the traditionally farmed Trent Valley landscape. In terms of biodiversity many of the lakes have simply become large lakes of deep water, many of which are sterile, support a limited range of wildlife, attract a limited number of water-birds, and no longer contribute substantially to the County's biodiversity. On the contrary, farmland birds are amongst the most endangered species and note needs to be taken of the negative impacts of removing agricultural land from Nottinghamshire's
landscape.
Perhaps we should protect and improve the biodiversity we have rather than looking for marginal increments.

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

We agree with the draft vision.

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

We believe the strategic issues are appropriate. However, whilst the preamble recognises that aggregates are generally located adjacent to rivers, under the heading "Minimise impacts on communities" no mention is made of flood risk and its potential effects on quality of life.
At the very least the vision should include a statement to the effect that it will be policy that existing flood risk will not be allowed to increase by quarrying.

Q4 Do you think the average 10 year sales figure is the most suitable methodology for forecasting future aggregate demand in Nottinghamshire. If not please identify any alternatives you feel are realistic and deliverable and the evidence to support this approach.

The average 10 year sales figure is probably the most appropriate and available measure to use although we have a number of concerns about the fact that this is a supply side figure and is only a proxy representation of demand. It does not show the spread or size of demand throughout the county nor reflect the export (from the county) of one third to one half of supply to South Yorkshire, largely from the northern quarries.

Q5 Do you think the same methodology (most recent average 10 year sales) should be used for each aggregate or is there merit in using different methodologies for different aggregates?

Please see our answer to question 4. There is no science that would indicate any greater accuracy for measuring the demand for different aggregates.

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

Yes - we believe that the expansion of existing quarries has resolved most of the strategic and practical issues facing the aggregates industry over the time they have been operated and their extension is the best way forward to protect the environment.

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

We see no particular merit in this approach.

Q8 How important is it to maintain a geographical spread of sand and gravel quarries across the County (i.e. Idle Valley, near Newark and near Nottingham) to minimise the distance minerals are transported to markets?

We recognise the importance of closeness to market and the high bulk low value equation of transport costs as well as the social and traffic implications.
It is important to determine the approximate size of the market from
the requirements of infrastructure and house and commercial building, and to produce a scientific approach to the selection of quarry sites which optimally meet requirements.

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

We believe that those sites which have the least impact on communities should be prioritised.

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

Clearly movement of sand and gravel by barge is more desirable than by road.
Whilst there appears, to our knowledge, to have been no published and objective cost-benefit analysis of transporting aggregates by barge we simply have the rationale provided by individuals and the industry itself.
For example the industry has moved away from barging as an economical means of transport because of the double handling and processing costs. One operator provided a cost estimate of £13 to £15 per tonne for moving sand and gravel by barge which makes this a very uncompetitive solution.
Also the publication "Gravel Extraction: History of Aggregate Extraction in the Trent Valley" states "Since the mid 1950's, haulage economics have dictated that the vast majority of sand and gravel aggregates are transported by road".


Q.14 Are you aware of any issues relating to alternative aggregates that should be considered through the Minerals Local Plan?

We believe that greater emphasis should be given to the search and support for alternative aggregates and their recycling so as to reduce the pressure on mineral reserves within the County.