Minerals Local Plan Issues and Options consultation

Would it be helpful to make reference to expected population growth Nottinghamshire and the reliance on minerals in supporting all housing and other infrastructure developments during the plan period.

It might also be appropriate to refer to relationship of mineral extraction and links to surrounding Counties as part of co operation in the import and export of minerals across county boundaries.

The Vision seems all encompassing and is acceptable, making reference to the main minerals in the County.

In relation to Strategic issue 3 it should be clear that minimisation of impacts from traffic, visual, noise etc will be in conformity with relevant assessment of impacts as directed in National Planning Policy and Practice Guides.

Safeguarding Policy in issue 5 is most important, especially where pressure from the built environment could otherwise result in the loss of finite resource. We would look to work in detail on this matter as the plan develops.

For sound operational and environmental reasons, extensions to existing sites can provide a good opportunity to increase the stock of permitted reserves at an operational site. It should be clear that 'Extension' of a quarry may not mean an area entirely contiguous to the existing quarry but could include the traversing of the local road network or other boundary features to extend the site.
Ibstock Brick own and operate the Dorket Head Brick factory in Arnold and over hundreds of years, clay has been extracted locally to the factory, minimising transport by road and using a conveyor to move clay into the factory. Further extensions beyond the confines of the existing quarry boundary will be necessary in the plan period to maintain a stock of permitted reserve in accordance with National Planning Policy. As the site operator, preference will be given to the closest proximity 'extensions' which are both environmental acceptable and commercially available. If these key components cannot however be met, any presumption in favour of 'extending' the existing site may need to give way to other new remote greenfield site locations. At the plan making stage and given the relative timescales for new / extended sites coming 'on line' it is not possible to have complete certainty as to the commercial availability and environmental acceptability of the land, hence flexibility should be maintained in the policy.

The Mineral Planning Authority should adopt a policy relevant to the varying mineral types in the County.
For brick manufacturing, significant initial and on going investment is required to ensure that the brick factory performs efficiently. For Dorket Head, development of the site hundreds of years ago would have relied on the ample resources in the area to ensure a long term stock of permitted reserves closest to the point of manufacture. So far as resource is commercially and environmentally appropriate a presumption in favour of extensions to the existing quarry should be adopted to reflect the high initial and ongoing investment of the brick manufacturing facility.
As resources diminish or becomes unavailable proximal to the brick factory, resources further a field will be required.

Ibstock Brick is the owner and operator of the Dorket Head Brick factory and the associated quarry land. Over hundreds of years Ibstock and its predecessors have ensured the continuity of clay supply through extension of the existing quarry, initially west of Calverton Road, before commencement of working on the east side of Calverton Road in the early 1960's. Clay extraction has progressively worked easterly to date. A combination of the Eastern Extension approved in 2013 and the remainder of the existing consented areas leaves only circa 14 years clay. The small southerly extension could lift this to 17 years.

The National Planning Policy Framework para 146 identifies the need for Planning Authorities to 'plan for a steady and adequate supply of industrial minerals......at least 25 years for brick clay....'. Dorket Head will fall well short of the 25 years during the plan period to 2036 as current reserves will be exhausted two years prior to the end of the plan period. The plan for an adequate supply of minerals should commence with identification, where possible' of a future replacement quarry.

Ibstock Brick have proactively identified future quarry opportunities for both 'extension' sites and also remote quarries. It will be the intention of this company to promote the most appropriate of these sites in this current 'call for sites' exercise. The relative longevity between the call for sites and working timescales of proposed future quarry allocations does however mean that circumstances may change and flexibility should be built into the plan using criteria based selection for other alternative future sites.

Ibstock Brick Dorket Head is only one of two brick factories in Nottinghamshire. Bricks are vitally important to ensure adequate supply of building materials to meet the UK demand for house building. Bricks provide an aesthetically pleasing, durable and safe building product.
The existing Dorket Head factory will undoubtedly remain the mainstay of brick production and representations to ensure security of future supply are made elsewhere in this plan through the extension of the existing site and potentially remote quarries.
The Mineral Plan should however also make provision for a criteria based policy taking account the potential for further additional, alternative or relocated sites to come forward during the plan period which are not allocated or envisaged at the plan making stage.

We agree that the scope of the DM policies seems appropriate.

Ibstock Brick have provided responses on various consultations since 2007 pertaining to Mineral Safeguarding and the identification of the brick clay resource, specifically that of the Gunthorpe Formation which forms a smaller part of the overall brick clay resource shown on map 7. The available resource is reduced yet further due to the presence of physical features and natural topography together with the proximial presence of towns / villages.
The Mineral Safeguarding Area and the MCA provide a good overall position as to the clay resource which should be protected, however incidents have occurred whereby Borough and District plans do not have regard to the MSA and MCA in their initial plan preparation and Sustainability Appraisals. Failure of District / Borough Councils to take full account of these areas leads to potential loss of minerals or at least, unnecessary protracted examination discussions and the risk of Local Plans being unsound due to an omission of consistency with National Policy and the Mineral Plan. The MSA and MCA should therefore be raised high on the agenda of the District and Borough Councils plus Neighbourhood plans as appropriate.
In addition, Ibstock have identified within the overall MSA and MCA areas of land which are not restricted by other surface development and which, at the appropriate time, will be prime future sites for clay extraction. These sites should be identified in the Safeguarding Policy as areas of particular interest so to avoid the risk of inappropriate development on or in proximity to them.