Minerals Local Plan Issues and Options consultation
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Minerals Local Plan Issues and Options consultation
Q1 Do you think any further information should be included in the overview of the area?
Representation ID: 30650
Received: 10/01/2018
Respondent: Tarmac Ltd
Agent: Heaton Planning Ltd
Yes. Cross-boundary relationship with neighbouring authorities should be identified considering:
-cross-boundary mineral supply from Nottinghamshire
-Lack of available crushed rock/limestone within County
-Availability of infrastructure link
-Overlap housing/business/infrastructure/employment links with Derbyshire/Leicestershire
-Duty to co-operate in plan preparation should be referenced
-Anticipated development needs for housing/employment/infrastructure
NOTTINGHAMSHIRE MINERALS LOCAL PLAN - ISSUES AND OPTIONS CONSULTATION INCLUDING CALL FOR MINERAL SITES
Thank you for allowing us opportunity to comment on the above consultation document. We are making representations on behalf of our client Tarmac Trading Ltd (Tarmac). Tarmac have a number of existing mineral operations, handling and processing infrastructure within the County. Operations include sand and gravel operations, hard rock operations, as well as a cement depot (Barnstone). Tarmac also operate an industrial limestone operation across the County border within Derbyshire. However, there is a wider landholding containing industrial limestone resource to sustain operations longer term contained within Nottinghamshire.
Current Operations include:
* Langford Quarry - Sand and Gravel
* Besthorpe Quarry - Sand and Gravel
* Bestwood Quarry - Sherwood Sandstone
* Girton Quarry - Sand and Gravel (currently inactive)
* Sturton Quarry - Sand and Gravel (implemented but inactive)
* Nether Langwith - Limestone
* Carlton Forest - Sherwood Sandstone (currently inactive)
* Calverton/Burntstump - Sherwood Sandstone
* Cromwell Quarry - River wharf receiving river dredgings
In addition to responding to the Issues and Options document prepared by the Council, Tarmac have prepared a number of submissions in response the Mineral Planning Authorities 'Call for Sites' exercise. Enclosed with this submission are a series of site submissions/promotions based on the Mineral Planning Authority's 'Call for Sites Information' sheet attached to their consultation letter dated 3rd November 2017. A number of these sites have been previously submitted to Local Plan consultations and included within Draft documents as allocations. Sites promoted to this emerging Nottinghamshire Minerals Local Plan include:
Extensions to existing operations:
* Langford Quarry - South & West Extension (currently subject to a planning Application ref no 3/16/01689/CMA under consideration by the Mineral planning Authority)
* Langford Quarry - North Extension
* Besthorpe Quarry - East Extension (east of Northcroft Lane)
* Bestwood Quarry - North & East Extension (East extension currently subject to a planning Application ref no 7/2017/1491NCC under consideration by the Mineral planning Authority)
Greenfield Operations
* Great North Road - North
* Great North road - South
* Botany Bay
* Newark/Burridge Farm
In addition to the above, Tarmac are seeking their river wharf and mineral processing facilities at Cromwell safeguarded during the plan period to facilitate the unloading and processing of sand and gravel delivered by river barge, in addition to land at Holbeck which contains industrial limestone to serve the nearby Whitwell operations located across the County border within Derbyshire.
Background Evidence - Local Aggregate Assessment
The latest evidence base document concerning mineral demand is contained within the Local Aggregate Assessment published in 2017 (containing 2016 data).
Tarmac are members of the East Midlands Aggregate Working Party, to which they have made previous comments regarding the demand for mineral within Nottinghamshire in response to the draft Local Aggregate Assessment (LAA) published earlier in 2017. Whilst some of the specific comments have been incorporated, Tarmac maintain that the LAA does not give an accurate portrayal of the sand and gravel demand forecast for the Plan period. The LAA would benefit from further explanation/clarification on why Nottinghamshire is showing an overall decline in sales (contrary to the majority of the East Midlands where there has been a general increase in sales). It is Tarmac's view that this decline is a combination of many factors, including:
* the exhaustion of permitted reserves and closure of production capacity without new sites/permissions directly replacing them (particularly in the Idle Valley);
* the transfer of production into neighbouring authority areas (through working at Finningley Quarry moving across the boundary to Doncaster); and
* the continued constrained production from a number of mothballed/inactive reserves due to continuing impacts from the 2008 recession.
The above factors have skewed the available, and importantly, the operational landbank. Table 2 within the LAA shows permitted reserves at sand and gravel quarries in Nottinghamshire. However, the status of some of these sites (i.e they aren't currently in production due to the timescales required for investment) effects the current operational capacity available within the County. Some of those sites (ie Girton Quarry , mothballed since 2009 and Sturton Quarry implemented in 2017) are likely to come into production in the Plan period, but because of geographical position and changed economics of operation it may be in a different context. The predicted operational contribution of those sites is shown in the delivery schedule for those sites operated / promoted by Tarmac. In this regard, it is important to distinguish between operating capacity and demand. Sales data indicates that there is lower level of production but not necessarily that there is a lower demand. This is evidenced by the varying supply picture within Nottinghamshire and how it differs to that of neighbouring Authorities who are experiencing significant increases in sales.
In addition to sales figures indicating a decline in production (influenced by the recession and the above factors), the Mineral Planning Authority should give further consideration to anticipated future demand. It is incorrect to assume that export levels will continue at current/historic rates. The Mineral Planning Authority should review the growth projections and likely demand this will place on Nottinghamshire resources. As we have previously indicated, it is likely that there will be a greater demand during the Plan period from adjoining authorities. Leicestershire has identified a significant shortfall of some 9.53mt of resources to meet current demand over their Plan period (to 2031) as well as significant loss of long established production capacity. The Doncaster and South Rotherham Local Aggregate Assessment 2016 is showing very low sand and gravel average sales over the past 10 years. However, there is a sharp increase in 2015 (presumably linked to production at Finningley moving into Doncaster). However, Finningley is due to close later this year. Whilst the LAA is indicating that they have a sufficient landbank as a result of low average sales, it is identified that the sand and gravel resource available is currently 99% soft sand. The sand and gravel landbank may not therefore be sustained beyond the proposed 17 year plan period for Doncaster or 15 year plan period for Rotherham.
The Mineral Planning Authority should be setting out clear evidence of its' co- operation with adjoining authorities regarding demand and supply scenarios for sand and gravel which are likely to have an impact on supply and demand of sand and gravel from within Nottinghamshire during the Plan period to 2036.
Issues and Options Paper
Section 2 - Setting the overall Context for the Plan
Q1 - Do you think any further information should be included in the overview of the area?
Yes. Cross-boundary relationship with neighbouring authorities should be identified considering:
1. cross-boundary mineral supply from Nottinghamshire - South Yorkshire/Leicestershire in light of their identified lack of available sand and gravel resources to meet demand over Plan period
2. Lack of available crushed rock/limestone resource within County therefore heavy reliance on import from adjoining Authorities
3. Availability of infrastructure links - good road network therefore links to market assisting to secure mineral supply
4. Overlap housing/business/infrastructure/employment links with Derbyshire/Leicestershire. No reference to an overlap of mineral supply issues
5. Duty to cooperate in Plan preparation should be referenced
6. Anticipated development needs for housing/employment/infrastructure
Q2 Do you agree with the Draft Vision? Are there other things that we should include?
Generally support Draft Vision. However, 2 main issues. Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources. Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.
Q3 Are the above strategic issues appropriate? Are there others we should consider?
SI1 and a locational strategy to securing mineral supply is supported. Maintains spread of operations across the County. Maintains security in supply to markets that these serve.
SI2 is supported. However, Plan should identify anticipated demand from adjoining Authorities.
Disagree with SI4 Not always appropriate when balancing needs of
landowner and value of land post restoration. Biodiversity improvements should be sought 'where possible'. Council should adopt more balanced stance regarding restoration of sites considering the three elements of sustainability.
Tarmac support vision for creating landscape-scale biodiversity resources.
SI4- consider opportunities mineral extraction creates for the deposit of inert infill.
Minerals Provision
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.
No. National Policy states, forecasts of demand should be based on a rolling average of 10 years sales data, other relevant information and through assessment of all other supply options. We support the MPA in their previous approach which reviewed sales data pre and post- recession to give a greater appreciation of likely anticipated demand in recession and a period of economic growth.
The operational capacity of permitted operations within the County needs consideration to ensure that anticipated demand is met.
A Delivery schedule (as per previous MLP drafts) would be helpful.
The Issues and Options paper states, the decline in Nottinghamshire sales of sand and gravel is a result of the, 'minerals industry focusing on existing quarries outside the County and the lack of investment in new greenfield quarries in Nottinghamshire even though adequate sand and gravel resources remain'. This statement is not substantiated or evidenced.
The Plan should not focus or specify a definitive/maximum amount of mineral provision. The Plan needs to provide flexibility to support additional sites/resources coming forward during the Plan period to meet demand/operational requirements to serve existing/future markets.
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?
As above, the use of 10 years average does not accurately represent the 'local circumstance'. A decline in sales is not necessarily an indication of decline in demand. Whilst it is one consideration, the fact that the sales/supply picture within Nottinghamshire is so different from the rest of the East Midlands and the national picture indicates that the sales data alone is not a true reflection of current circumstances.
Strategic Approach to New Mineral Development
Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
There needs to be allowance in the Plan for both extensions and new greenfield sites. The NPPF removed previous planning policy preference for extensions to existing operations. As a result, emerging policy should not give preference to extensions in order to be compliant with national policy. However, as we have previously stated, the Plan should provide flexibility and policy should be supportive in securing extensions to existing operations, this ensures a continuation in supply without sterilising mineral reserves. However, operational capacity constraints still apply (imposed by plant capacity or planning conditions which limit tonnages/production) which can limit the amount of resource available to meet demand and therefore there may be a requirement for green field sites in addition to extensions. It is considered that a more sustainable strategy would be a locational strategy which shows allocations and preferred areas of working for new sites in each of the three main areas for sand and gravel working (Trent Valley, north of Newark and the Idle Valley) to ensure there are sufficient operations in place to meet demand, particularly relevant where there is evidence of sand and gravel resource, reserve and production capacity decline in adjoining authority areas.
Sand and gravel provision
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 market.
It is considered that a geographical spread of sand and gravel operations is a sustainable strategy and Tarmac support this approach. These areas have historical supply markets/area demand which has not changed - i.e major growth areas which will still be providing housing, employment, infrastructure etc remain. In addition, a
number of operations spread within a locality will also ensure the continuity/maintenance of supply in the event of operational constraint or in the event of a site having to shut down/cease operating.
It is not clear why specific reference is made to the Planning Application at Barton in Fabis and the contribution this could make to future mineral supply? Current undetermined Applications at Langford and Bestwood are not referred to in the same context. It is considered that the Plan should provide factual information only at this stage, and the reference to Barton in Fabis specifically appears to give it a favourable status which is not appropriate in this context.
Plan 3 isn't very informative. It would benefit from major trunk roads being identified, major towns/growth areas labelling, and the Idle Valley showing.
Q9. Would it be more appropriate to prioritise specific areas above others?
The Locational strategy should be heavily influenced/focussed on known markets and by access to market and ease of access to the local highway network to transport mineral within and where necessary outside of the County.
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.
The difference between long distance barging to market and short distance/shuttle barging to processing plant requires a distinction.
Long Distance Barging to Market
It has not in recent years been economical to transport mineral by barge. The costs of loading / unloading and transportation are often significantly greater than conventional distribution to market by road, and is significantly less flexible to meet market demand. It is unlikely that sand and gravel operations will be developed based on barge transportation alone.
River barge transportation of sand and gravel from Besthorpe Quarry ceased in August 2013 as supply to the West Yorkshire market from North Yorkshire (including rail fed crushed rock) became more economic. The position may change in the medium to long term as supply scenarios change over time. Tarmac have therefore
retained the over wharf facility at Besthorpe in a mothballed state rather than removing the wharf facility altogether.
Short distance shuttle barging (to processing plant)
The costs of loading and unloading and provision of handling/ processing facilities significantly add to operating costs and shuttle barging over short distances are unlikely to be economic against traditional land based operations.
There may be opportunities for a shuttle barge transportation system to be adopted for working some sand and gravel resources where inadequate road access exists. Such a system may enable otherwise constrained mineral resources to be worked, but the viability does depend heavily on suitable mineral handling and processing facilities being available at the receiving end (particularly facilities for mineral processing , washing and silt disposal).
Sherwood Sandstone
Q11. Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?
The LAA recognises the high level of export to markets outside the County due to limited resources elsewhere. As per comments on sand and gravel, there is a need where resource exists to maintain production and operating capacity to meet demand. The Plan should identify appropriate extensions to existing operations or new sites to meet this demand. Identified demand based on sales is a minimum requirement of the Plan and it is considered there needs to be flexibility built into the Plan to allow sites to come forward. The plan should address anticipated demand from outside of the County.
The Plan should recognise the unique properties of the sand as well as markets. Colour variances as well as properties of the sand are also important factors and therefore additional reserves (as allocations or new sites) should not solely be based upon estimated demand based on sales figures.
Crushed Rock
The Plan should update the current position on Nether Langwith as Tarmac has obtained planning permission to extend the timescales for working and restoration.
It is likely that there is a wider demand for crushed rock within the County than that met by Nether Langwith. Crushed rock requirements are likely to be met from imports to meet the demand within the south of the County to minimise the distance crushed rock will need to travel.
Alternative Aggregates
Q14. Are you aware of any issues relating to alternative aggregates that should be considered through the minerals Local Plan review?
Support for the MPA in seeking the use of alternative aggregates and the appreciation that there are limits on how far alternatives can substitute primary aggregate. It is considered whilst support for alternative aggregate should be encouraged in the Plan, the contribution should be viewed as a 'bonus' over and above the required amount of primary aggregate. This is reflective of the NPPF (para
143) which states that local Plans should take account of the, 'contribution that substitute or secondary and recycled materials and minerals waste can make'. The reference made by the MPA to the reduction in ash materials from coal fired power stations is also likely to increase the demand for primary aggregate over the Plan period to address this specific resource shortfall. The approach to recycled aggregates reflects the Mineral Products Association Long Tern Aggregates Demand and Supply Scenarios Paper which indicates that the potential for recycling has reached an optimum level (approximately 28-30% volume).
Industrial Dolomite Provision
Q20. Are you aware if any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?
Reserves of industrial dolomite are of international importance. Whilst additional resource areas do not need to be identified as an allocation, the resource within Nottinghamshire should be identified within the Plan and recognised as a proven resource to be safeguarded.
Development Management Policies
Q25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
Yes agree that it covers all areas.
Minerals Safeguarding and Consultation Areas
Q26 Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?
It is considered that the Minerals Plan should define more specific Mineral Consultation Areas. The proposed approach to define consultation areas on the same scale as safeguarding areas could mean that large amounts of development will be caught within an MSA/MCA which would be onerous on developers having to potentially submit minerals assessments and the MPA in assessing the potential for impact of development on mineral resource/mineral associated infrastructure. This is contrary to the objectives of the NPPF paragraph 143. A criteria based approach to MCA's would be a more appropriate strategy. In addition Plan 7 would benefit from clearer distinction between areas of safeguarding. It is not clear where the alluvial sand and gravel is located.
As well as safeguarding mineral associated infrastructure, rail heads should be expanded to include rail heads at coal fired power stations. A wharf facility at Colwick is specifically referenced for safeguarding. Tarmac have existing wharf facilities which should also be referenced if this is the approach to be adopted by the MPA.
The importance of Local Plan's (District and Borough Council) in understanding and appreciating the role of safeguarding and defining areas/sites within Local Development Plan Documents should be explained within the Mineral Plan. The Planning system is a tiered system with the policies contained within the Mineral Plan and Local plan pertinent to the consideration of Planning Applications at County and District level. The MPA has an important role in ensuring mineral safeguarding is not perceived as just a County function but guiding and supporting Local Authorities to appreciate they also have a role to play in accordance with the Planning Practice Guidance.
Sustainability Appraisal Scoping Report
Proposed SA Objectives
As per comments on the Issues and Options Paper, Objective 2 should reflect the NPPF and seek to protect and enhance biodiversity 'where possible' as opposed to at all levels. The NPPF recognises that biodiversity should be protected, enhanced and where necessary any impact mitigated against as opposed to being categorical that all development needs to provide ecological enhancement.
General Comments
As we have stated as part of previous consultation responses on other MLP Drafts, the weighting of each of the Sustainability Appraisal objectives should be explained and how these will be used to assess the Plan policies and any sites promoted for allocation. Currently the SA Objectives are heavily weighted to potential environmental effect. However, economic and social facets of sustainability are critical elements relating to minerals development - i.e maintaining supply, access and proximity to market, beneficial restoration objectives etc. Attention is drawn to the NPPF and that 'minerals are essential to support sustainable economic growth' (paragraph 142). As well as providing an 'adequate' amount, the SA has failed to take account of the need to plan for a 'steady and adequate' supply of aggregate (paragraph 145). There is a requirement for the MPA to recognise that as well as ensuring they have a sufficient land bank of resource that the Plan maintains aggregate provision across the whole Plan period - comments above on operational capacity are particularly pertinent to this.
Table 2 - Sustainability issues
Table 2 identifies the economy and employment as only having a low/moderate significance to the Plan. It is considered this is understated and refer to paragraph 142 of the NPPF, 'minerals are essential to support sustainable economic growth and our quality of life'. This significance should be amended.
Table 4
Objective 1 should include operational capacity as a proposed indicator in assessing whether adequate provision is being made to meet local and national mineral demand.
I trust that the above comments are helpful. Should you have any queries or wish to discuss any of the points raised in more detail, please do not hesitate to contact us.
Yours sincerely,
Jenna Conway
Heaton Planning Limited
Attachments:
Comment
Minerals Local Plan Issues and Options consultation
Q2 Do you agree with the draft vision? Are there other things we should include?
Representation ID: 30651
Received: 10/01/2018
Respondent: Tarmac Ltd
Agent: Heaton Planning Ltd
Generally support Draft Vision. However, 2 main issues. Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources. Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.
NOTTINGHAMSHIRE MINERALS LOCAL PLAN - ISSUES AND OPTIONS CONSULTATION INCLUDING CALL FOR MINERAL SITES
Thank you for allowing us opportunity to comment on the above consultation document. We are making representations on behalf of our client Tarmac Trading Ltd (Tarmac). Tarmac have a number of existing mineral operations, handling and processing infrastructure within the County. Operations include sand and gravel operations, hard rock operations, as well as a cement depot (Barnstone). Tarmac also operate an industrial limestone operation across the County border within Derbyshire. However, there is a wider landholding containing industrial limestone resource to sustain operations longer term contained within Nottinghamshire.
Current Operations include:
* Langford Quarry - Sand and Gravel
* Besthorpe Quarry - Sand and Gravel
* Bestwood Quarry - Sherwood Sandstone
* Girton Quarry - Sand and Gravel (currently inactive)
* Sturton Quarry - Sand and Gravel (implemented but inactive)
* Nether Langwith - Limestone
* Carlton Forest - Sherwood Sandstone (currently inactive)
* Calverton/Burntstump - Sherwood Sandstone
* Cromwell Quarry - River wharf receiving river dredgings
In addition to responding to the Issues and Options document prepared by the Council, Tarmac have prepared a number of submissions in response the Mineral Planning Authorities 'Call for Sites' exercise. Enclosed with this submission are a series of site submissions/promotions based on the Mineral Planning Authority's 'Call for Sites Information' sheet attached to their consultation letter dated 3rd November 2017. A number of these sites have been previously submitted to Local Plan consultations and included within Draft documents as allocations. Sites promoted to this emerging Nottinghamshire Minerals Local Plan include:
Extensions to existing operations:
* Langford Quarry - South & West Extension (currently subject to a planning Application ref no 3/16/01689/CMA under consideration by the Mineral planning Authority)
* Langford Quarry - North Extension
* Besthorpe Quarry - East Extension (east of Northcroft Lane)
* Bestwood Quarry - North & East Extension (East extension currently subject to a planning Application ref no 7/2017/1491NCC under consideration by the Mineral planning Authority)
Greenfield Operations
* Great North Road - North
* Great North road - South
* Botany Bay
* Newark/Burridge Farm
In addition to the above, Tarmac are seeking their river wharf and mineral processing facilities at Cromwell safeguarded during the plan period to facilitate the unloading and processing of sand and gravel delivered by river barge, in addition to land at Holbeck which contains industrial limestone to serve the nearby Whitwell operations located across the County border within Derbyshire.
Background Evidence - Local Aggregate Assessment
The latest evidence base document concerning mineral demand is contained within the Local Aggregate Assessment published in 2017 (containing 2016 data).
Tarmac are members of the East Midlands Aggregate Working Party, to which they have made previous comments regarding the demand for mineral within Nottinghamshire in response to the draft Local Aggregate Assessment (LAA) published earlier in 2017. Whilst some of the specific comments have been incorporated, Tarmac maintain that the LAA does not give an accurate portrayal of the sand and gravel demand forecast for the Plan period. The LAA would benefit from further explanation/clarification on why Nottinghamshire is showing an overall decline in sales (contrary to the majority of the East Midlands where there has been a general increase in sales). It is Tarmac's view that this decline is a combination of many factors, including:
* the exhaustion of permitted reserves and closure of production capacity without new sites/permissions directly replacing them (particularly in the Idle Valley);
* the transfer of production into neighbouring authority areas (through working at Finningley Quarry moving across the boundary to Doncaster); and
* the continued constrained production from a number of mothballed/inactive reserves due to continuing impacts from the 2008 recession.
The above factors have skewed the available, and importantly, the operational landbank. Table 2 within the LAA shows permitted reserves at sand and gravel quarries in Nottinghamshire. However, the status of some of these sites (i.e they aren't currently in production due to the timescales required for investment) effects the current operational capacity available within the County. Some of those sites (ie Girton Quarry , mothballed since 2009 and Sturton Quarry implemented in 2017) are likely to come into production in the Plan period, but because of geographical position and changed economics of operation it may be in a different context. The predicted operational contribution of those sites is shown in the delivery schedule for those sites operated / promoted by Tarmac. In this regard, it is important to distinguish between operating capacity and demand. Sales data indicates that there is lower level of production but not necessarily that there is a lower demand. This is evidenced by the varying supply picture within Nottinghamshire and how it differs to that of neighbouring Authorities who are experiencing significant increases in sales.
In addition to sales figures indicating a decline in production (influenced by the recession and the above factors), the Mineral Planning Authority should give further consideration to anticipated future demand. It is incorrect to assume that export levels will continue at current/historic rates. The Mineral Planning Authority should review the growth projections and likely demand this will place on Nottinghamshire resources. As we have previously indicated, it is likely that there will be a greater demand during the Plan period from adjoining authorities. Leicestershire has identified a significant shortfall of some 9.53mt of resources to meet current demand over their Plan period (to 2031) as well as significant loss of long established production capacity. The Doncaster and South Rotherham Local Aggregate Assessment 2016 is showing very low sand and gravel average sales over the past 10 years. However, there is a sharp increase in 2015 (presumably linked to production at Finningley moving into Doncaster). However, Finningley is due to close later this year. Whilst the LAA is indicating that they have a sufficient landbank as a result of low average sales, it is identified that the sand and gravel resource available is currently 99% soft sand. The sand and gravel landbank may not therefore be sustained beyond the proposed 17 year plan period for Doncaster or 15 year plan period for Rotherham.
The Mineral Planning Authority should be setting out clear evidence of its' co- operation with adjoining authorities regarding demand and supply scenarios for sand and gravel which are likely to have an impact on supply and demand of sand and gravel from within Nottinghamshire during the Plan period to 2036.
Issues and Options Paper
Section 2 - Setting the overall Context for the Plan
Q1 - Do you think any further information should be included in the overview of the area?
Yes. Cross-boundary relationship with neighbouring authorities should be identified considering:
1. cross-boundary mineral supply from Nottinghamshire - South Yorkshire/Leicestershire in light of their identified lack of available sand and gravel resources to meet demand over Plan period
2. Lack of available crushed rock/limestone resource within County therefore heavy reliance on import from adjoining Authorities
3. Availability of infrastructure links - good road network therefore links to market assisting to secure mineral supply
4. Overlap housing/business/infrastructure/employment links with Derbyshire/Leicestershire. No reference to an overlap of mineral supply issues
5. Duty to cooperate in Plan preparation should be referenced
6. Anticipated development needs for housing/employment/infrastructure
Q2 Do you agree with the Draft Vision? Are there other things that we should include?
Generally support Draft Vision. However, 2 main issues. Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources. Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.
Q3 Are the above strategic issues appropriate? Are there others we should consider?
SI1 and a locational strategy to securing mineral supply is supported. Maintains spread of operations across the County. Maintains security in supply to markets that these serve.
SI2 is supported. However, Plan should identify anticipated demand from adjoining Authorities.
Disagree with SI4 Not always appropriate when balancing needs of
landowner and value of land post restoration. Biodiversity improvements should be sought 'where possible'. Council should adopt more balanced stance regarding restoration of sites considering the three elements of sustainability.
Tarmac support vision for creating landscape-scale biodiversity resources.
SI4- consider opportunities mineral extraction creates for the deposit of inert infill.
Minerals Provision
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.
No. National Policy states, forecasts of demand should be based on a rolling average of 10 years sales data, other relevant information and through assessment of all other supply options. We support the MPA in their previous approach which reviewed sales data pre and post- recession to give a greater appreciation of likely anticipated demand in recession and a period of economic growth.
The operational capacity of permitted operations within the County needs consideration to ensure that anticipated demand is met.
A Delivery schedule (as per previous MLP drafts) would be helpful.
The Issues and Options paper states, the decline in Nottinghamshire sales of sand and gravel is a result of the, 'minerals industry focusing on existing quarries outside the County and the lack of investment in new greenfield quarries in Nottinghamshire even though adequate sand and gravel resources remain'. This statement is not substantiated or evidenced.
The Plan should not focus or specify a definitive/maximum amount of mineral provision. The Plan needs to provide flexibility to support additional sites/resources coming forward during the Plan period to meet demand/operational requirements to serve existing/future markets.
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?
As above, the use of 10 years average does not accurately represent the 'local circumstance'. A decline in sales is not necessarily an indication of decline in demand. Whilst it is one consideration, the fact that the sales/supply picture within Nottinghamshire is so different from the rest of the East Midlands and the national picture indicates that the sales data alone is not a true reflection of current circumstances.
Strategic Approach to New Mineral Development
Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
There needs to be allowance in the Plan for both extensions and new greenfield sites. The NPPF removed previous planning policy preference for extensions to existing operations. As a result, emerging policy should not give preference to extensions in order to be compliant with national policy. However, as we have previously stated, the Plan should provide flexibility and policy should be supportive in securing extensions to existing operations, this ensures a continuation in supply without sterilising mineral reserves. However, operational capacity constraints still apply (imposed by plant capacity or planning conditions which limit tonnages/production) which can limit the amount of resource available to meet demand and therefore there may be a requirement for green field sites in addition to extensions. It is considered that a more sustainable strategy would be a locational strategy which shows allocations and preferred areas of working for new sites in each of the three main areas for sand and gravel working (Trent Valley, north of Newark and the Idle Valley) to ensure there are sufficient operations in place to meet demand, particularly relevant where there is evidence of sand and gravel resource, reserve and production capacity decline in adjoining authority areas.
Sand and gravel provision
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 market.
It is considered that a geographical spread of sand and gravel operations is a sustainable strategy and Tarmac support this approach. These areas have historical supply markets/area demand which has not changed - i.e major growth areas which will still be providing housing, employment, infrastructure etc remain. In addition, a
number of operations spread within a locality will also ensure the continuity/maintenance of supply in the event of operational constraint or in the event of a site having to shut down/cease operating.
It is not clear why specific reference is made to the Planning Application at Barton in Fabis and the contribution this could make to future mineral supply? Current undetermined Applications at Langford and Bestwood are not referred to in the same context. It is considered that the Plan should provide factual information only at this stage, and the reference to Barton in Fabis specifically appears to give it a favourable status which is not appropriate in this context.
Plan 3 isn't very informative. It would benefit from major trunk roads being identified, major towns/growth areas labelling, and the Idle Valley showing.
Q9. Would it be more appropriate to prioritise specific areas above others?
The Locational strategy should be heavily influenced/focussed on known markets and by access to market and ease of access to the local highway network to transport mineral within and where necessary outside of the County.
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.
The difference between long distance barging to market and short distance/shuttle barging to processing plant requires a distinction.
Long Distance Barging to Market
It has not in recent years been economical to transport mineral by barge. The costs of loading / unloading and transportation are often significantly greater than conventional distribution to market by road, and is significantly less flexible to meet market demand. It is unlikely that sand and gravel operations will be developed based on barge transportation alone.
River barge transportation of sand and gravel from Besthorpe Quarry ceased in August 2013 as supply to the West Yorkshire market from North Yorkshire (including rail fed crushed rock) became more economic. The position may change in the medium to long term as supply scenarios change over time. Tarmac have therefore
retained the over wharf facility at Besthorpe in a mothballed state rather than removing the wharf facility altogether.
Short distance shuttle barging (to processing plant)
The costs of loading and unloading and provision of handling/ processing facilities significantly add to operating costs and shuttle barging over short distances are unlikely to be economic against traditional land based operations.
There may be opportunities for a shuttle barge transportation system to be adopted for working some sand and gravel resources where inadequate road access exists. Such a system may enable otherwise constrained mineral resources to be worked, but the viability does depend heavily on suitable mineral handling and processing facilities being available at the receiving end (particularly facilities for mineral processing , washing and silt disposal).
Sherwood Sandstone
Q11. Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?
The LAA recognises the high level of export to markets outside the County due to limited resources elsewhere. As per comments on sand and gravel, there is a need where resource exists to maintain production and operating capacity to meet demand. The Plan should identify appropriate extensions to existing operations or new sites to meet this demand. Identified demand based on sales is a minimum requirement of the Plan and it is considered there needs to be flexibility built into the Plan to allow sites to come forward. The plan should address anticipated demand from outside of the County.
The Plan should recognise the unique properties of the sand as well as markets. Colour variances as well as properties of the sand are also important factors and therefore additional reserves (as allocations or new sites) should not solely be based upon estimated demand based on sales figures.
Crushed Rock
The Plan should update the current position on Nether Langwith as Tarmac has obtained planning permission to extend the timescales for working and restoration.
It is likely that there is a wider demand for crushed rock within the County than that met by Nether Langwith. Crushed rock requirements are likely to be met from imports to meet the demand within the south of the County to minimise the distance crushed rock will need to travel.
Alternative Aggregates
Q14. Are you aware of any issues relating to alternative aggregates that should be considered through the minerals Local Plan review?
Support for the MPA in seeking the use of alternative aggregates and the appreciation that there are limits on how far alternatives can substitute primary aggregate. It is considered whilst support for alternative aggregate should be encouraged in the Plan, the contribution should be viewed as a 'bonus' over and above the required amount of primary aggregate. This is reflective of the NPPF (para
143) which states that local Plans should take account of the, 'contribution that substitute or secondary and recycled materials and minerals waste can make'. The reference made by the MPA to the reduction in ash materials from coal fired power stations is also likely to increase the demand for primary aggregate over the Plan period to address this specific resource shortfall. The approach to recycled aggregates reflects the Mineral Products Association Long Tern Aggregates Demand and Supply Scenarios Paper which indicates that the potential for recycling has reached an optimum level (approximately 28-30% volume).
Industrial Dolomite Provision
Q20. Are you aware if any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?
Reserves of industrial dolomite are of international importance. Whilst additional resource areas do not need to be identified as an allocation, the resource within Nottinghamshire should be identified within the Plan and recognised as a proven resource to be safeguarded.
Development Management Policies
Q25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
Yes agree that it covers all areas.
Minerals Safeguarding and Consultation Areas
Q26 Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?
It is considered that the Minerals Plan should define more specific Mineral Consultation Areas. The proposed approach to define consultation areas on the same scale as safeguarding areas could mean that large amounts of development will be caught within an MSA/MCA which would be onerous on developers having to potentially submit minerals assessments and the MPA in assessing the potential for impact of development on mineral resource/mineral associated infrastructure. This is contrary to the objectives of the NPPF paragraph 143. A criteria based approach to MCA's would be a more appropriate strategy. In addition Plan 7 would benefit from clearer distinction between areas of safeguarding. It is not clear where the alluvial sand and gravel is located.
As well as safeguarding mineral associated infrastructure, rail heads should be expanded to include rail heads at coal fired power stations. A wharf facility at Colwick is specifically referenced for safeguarding. Tarmac have existing wharf facilities which should also be referenced if this is the approach to be adopted by the MPA.
The importance of Local Plan's (District and Borough Council) in understanding and appreciating the role of safeguarding and defining areas/sites within Local Development Plan Documents should be explained within the Mineral Plan. The Planning system is a tiered system with the policies contained within the Mineral Plan and Local plan pertinent to the consideration of Planning Applications at County and District level. The MPA has an important role in ensuring mineral safeguarding is not perceived as just a County function but guiding and supporting Local Authorities to appreciate they also have a role to play in accordance with the Planning Practice Guidance.
Sustainability Appraisal Scoping Report
Proposed SA Objectives
As per comments on the Issues and Options Paper, Objective 2 should reflect the NPPF and seek to protect and enhance biodiversity 'where possible' as opposed to at all levels. The NPPF recognises that biodiversity should be protected, enhanced and where necessary any impact mitigated against as opposed to being categorical that all development needs to provide ecological enhancement.
General Comments
As we have stated as part of previous consultation responses on other MLP Drafts, the weighting of each of the Sustainability Appraisal objectives should be explained and how these will be used to assess the Plan policies and any sites promoted for allocation. Currently the SA Objectives are heavily weighted to potential environmental effect. However, economic and social facets of sustainability are critical elements relating to minerals development - i.e maintaining supply, access and proximity to market, beneficial restoration objectives etc. Attention is drawn to the NPPF and that 'minerals are essential to support sustainable economic growth' (paragraph 142). As well as providing an 'adequate' amount, the SA has failed to take account of the need to plan for a 'steady and adequate' supply of aggregate (paragraph 145). There is a requirement for the MPA to recognise that as well as ensuring they have a sufficient land bank of resource that the Plan maintains aggregate provision across the whole Plan period - comments above on operational capacity are particularly pertinent to this.
Table 2 - Sustainability issues
Table 2 identifies the economy and employment as only having a low/moderate significance to the Plan. It is considered this is understated and refer to paragraph 142 of the NPPF, 'minerals are essential to support sustainable economic growth and our quality of life'. This significance should be amended.
Table 4
Objective 1 should include operational capacity as a proposed indicator in assessing whether adequate provision is being made to meet local and national mineral demand.
I trust that the above comments are helpful. Should you have any queries or wish to discuss any of the points raised in more detail, please do not hesitate to contact us.
Yours sincerely,
Jenna Conway
Heaton Planning Limited
Attachments:
Comment
Minerals Local Plan Issues and Options consultation
Q3 Are the above strategic issues appropriate? Are there others we should consider?
Representation ID: 30652
Received: 10/01/2018
Respondent: Tarmac Ltd
Agent: Heaton Planning Ltd
SI1 and a locational strategy to securing mineral supply is supported. Maintains spread of operations across the County. Maintains security in supply to markets that these serve.
SI2 is supported. However, Plan should identify anticipated demand from adjoining Authorities.
Disagree with SI4 Not always appropriate when balancing needs of
landowner and value of land post restoration. Biodiversity improvements should be sought 'where possible'. Council should adopt more balanced stance regarding restoration of sites considering the three elements of sustainability.
Tarmac support vision for creating landscape-scale biodiversity resources.
SI4- consider opportunities mineral extraction creates for the deposit of inert infill.
NOTTINGHAMSHIRE MINERALS LOCAL PLAN - ISSUES AND OPTIONS CONSULTATION INCLUDING CALL FOR MINERAL SITES
Thank you for allowing us opportunity to comment on the above consultation document. We are making representations on behalf of our client Tarmac Trading Ltd (Tarmac). Tarmac have a number of existing mineral operations, handling and processing infrastructure within the County. Operations include sand and gravel operations, hard rock operations, as well as a cement depot (Barnstone). Tarmac also operate an industrial limestone operation across the County border within Derbyshire. However, there is a wider landholding containing industrial limestone resource to sustain operations longer term contained within Nottinghamshire.
Current Operations include:
* Langford Quarry - Sand and Gravel
* Besthorpe Quarry - Sand and Gravel
* Bestwood Quarry - Sherwood Sandstone
* Girton Quarry - Sand and Gravel (currently inactive)
* Sturton Quarry - Sand and Gravel (implemented but inactive)
* Nether Langwith - Limestone
* Carlton Forest - Sherwood Sandstone (currently inactive)
* Calverton/Burntstump - Sherwood Sandstone
* Cromwell Quarry - River wharf receiving river dredgings
In addition to responding to the Issues and Options document prepared by the Council, Tarmac have prepared a number of submissions in response the Mineral Planning Authorities 'Call for Sites' exercise. Enclosed with this submission are a series of site submissions/promotions based on the Mineral Planning Authority's 'Call for Sites Information' sheet attached to their consultation letter dated 3rd November 2017. A number of these sites have been previously submitted to Local Plan consultations and included within Draft documents as allocations. Sites promoted to this emerging Nottinghamshire Minerals Local Plan include:
Extensions to existing operations:
* Langford Quarry - South & West Extension (currently subject to a planning Application ref no 3/16/01689/CMA under consideration by the Mineral planning Authority)
* Langford Quarry - North Extension
* Besthorpe Quarry - East Extension (east of Northcroft Lane)
* Bestwood Quarry - North & East Extension (East extension currently subject to a planning Application ref no 7/2017/1491NCC under consideration by the Mineral planning Authority)
Greenfield Operations
* Great North Road - North
* Great North road - South
* Botany Bay
* Newark/Burridge Farm
In addition to the above, Tarmac are seeking their river wharf and mineral processing facilities at Cromwell safeguarded during the plan period to facilitate the unloading and processing of sand and gravel delivered by river barge, in addition to land at Holbeck which contains industrial limestone to serve the nearby Whitwell operations located across the County border within Derbyshire.
Background Evidence - Local Aggregate Assessment
The latest evidence base document concerning mineral demand is contained within the Local Aggregate Assessment published in 2017 (containing 2016 data).
Tarmac are members of the East Midlands Aggregate Working Party, to which they have made previous comments regarding the demand for mineral within Nottinghamshire in response to the draft Local Aggregate Assessment (LAA) published earlier in 2017. Whilst some of the specific comments have been incorporated, Tarmac maintain that the LAA does not give an accurate portrayal of the sand and gravel demand forecast for the Plan period. The LAA would benefit from further explanation/clarification on why Nottinghamshire is showing an overall decline in sales (contrary to the majority of the East Midlands where there has been a general increase in sales). It is Tarmac's view that this decline is a combination of many factors, including:
* the exhaustion of permitted reserves and closure of production capacity without new sites/permissions directly replacing them (particularly in the Idle Valley);
* the transfer of production into neighbouring authority areas (through working at Finningley Quarry moving across the boundary to Doncaster); and
* the continued constrained production from a number of mothballed/inactive reserves due to continuing impacts from the 2008 recession.
The above factors have skewed the available, and importantly, the operational landbank. Table 2 within the LAA shows permitted reserves at sand and gravel quarries in Nottinghamshire. However, the status of some of these sites (i.e they aren't currently in production due to the timescales required for investment) effects the current operational capacity available within the County. Some of those sites (ie Girton Quarry , mothballed since 2009 and Sturton Quarry implemented in 2017) are likely to come into production in the Plan period, but because of geographical position and changed economics of operation it may be in a different context. The predicted operational contribution of those sites is shown in the delivery schedule for those sites operated / promoted by Tarmac. In this regard, it is important to distinguish between operating capacity and demand. Sales data indicates that there is lower level of production but not necessarily that there is a lower demand. This is evidenced by the varying supply picture within Nottinghamshire and how it differs to that of neighbouring Authorities who are experiencing significant increases in sales.
In addition to sales figures indicating a decline in production (influenced by the recession and the above factors), the Mineral Planning Authority should give further consideration to anticipated future demand. It is incorrect to assume that export levels will continue at current/historic rates. The Mineral Planning Authority should review the growth projections and likely demand this will place on Nottinghamshire resources. As we have previously indicated, it is likely that there will be a greater demand during the Plan period from adjoining authorities. Leicestershire has identified a significant shortfall of some 9.53mt of resources to meet current demand over their Plan period (to 2031) as well as significant loss of long established production capacity. The Doncaster and South Rotherham Local Aggregate Assessment 2016 is showing very low sand and gravel average sales over the past 10 years. However, there is a sharp increase in 2015 (presumably linked to production at Finningley moving into Doncaster). However, Finningley is due to close later this year. Whilst the LAA is indicating that they have a sufficient landbank as a result of low average sales, it is identified that the sand and gravel resource available is currently 99% soft sand. The sand and gravel landbank may not therefore be sustained beyond the proposed 17 year plan period for Doncaster or 15 year plan period for Rotherham.
The Mineral Planning Authority should be setting out clear evidence of its' co- operation with adjoining authorities regarding demand and supply scenarios for sand and gravel which are likely to have an impact on supply and demand of sand and gravel from within Nottinghamshire during the Plan period to 2036.
Issues and Options Paper
Section 2 - Setting the overall Context for the Plan
Q1 - Do you think any further information should be included in the overview of the area?
Yes. Cross-boundary relationship with neighbouring authorities should be identified considering:
1. cross-boundary mineral supply from Nottinghamshire - South Yorkshire/Leicestershire in light of their identified lack of available sand and gravel resources to meet demand over Plan period
2. Lack of available crushed rock/limestone resource within County therefore heavy reliance on import from adjoining Authorities
3. Availability of infrastructure links - good road network therefore links to market assisting to secure mineral supply
4. Overlap housing/business/infrastructure/employment links with Derbyshire/Leicestershire. No reference to an overlap of mineral supply issues
5. Duty to cooperate in Plan preparation should be referenced
6. Anticipated development needs for housing/employment/infrastructure
Q2 Do you agree with the Draft Vision? Are there other things that we should include?
Generally support Draft Vision. However, 2 main issues. Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources. Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.
Q3 Are the above strategic issues appropriate? Are there others we should consider?
SI1 and a locational strategy to securing mineral supply is supported. Maintains spread of operations across the County. Maintains security in supply to markets that these serve.
SI2 is supported. However, Plan should identify anticipated demand from adjoining Authorities.
Disagree with SI4 Not always appropriate when balancing needs of
landowner and value of land post restoration. Biodiversity improvements should be sought 'where possible'. Council should adopt more balanced stance regarding restoration of sites considering the three elements of sustainability.
Tarmac support vision for creating landscape-scale biodiversity resources.
SI4- consider opportunities mineral extraction creates for the deposit of inert infill.
Minerals Provision
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.
No. National Policy states, forecasts of demand should be based on a rolling average of 10 years sales data, other relevant information and through assessment of all other supply options. We support the MPA in their previous approach which reviewed sales data pre and post- recession to give a greater appreciation of likely anticipated demand in recession and a period of economic growth.
The operational capacity of permitted operations within the County needs consideration to ensure that anticipated demand is met.
A Delivery schedule (as per previous MLP drafts) would be helpful.
The Issues and Options paper states, the decline in Nottinghamshire sales of sand and gravel is a result of the, 'minerals industry focusing on existing quarries outside the County and the lack of investment in new greenfield quarries in Nottinghamshire even though adequate sand and gravel resources remain'. This statement is not substantiated or evidenced.
The Plan should not focus or specify a definitive/maximum amount of mineral provision. The Plan needs to provide flexibility to support additional sites/resources coming forward during the Plan period to meet demand/operational requirements to serve existing/future markets.
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?
As above, the use of 10 years average does not accurately represent the 'local circumstance'. A decline in sales is not necessarily an indication of decline in demand. Whilst it is one consideration, the fact that the sales/supply picture within Nottinghamshire is so different from the rest of the East Midlands and the national picture indicates that the sales data alone is not a true reflection of current circumstances.
Strategic Approach to New Mineral Development
Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
There needs to be allowance in the Plan for both extensions and new greenfield sites. The NPPF removed previous planning policy preference for extensions to existing operations. As a result, emerging policy should not give preference to extensions in order to be compliant with national policy. However, as we have previously stated, the Plan should provide flexibility and policy should be supportive in securing extensions to existing operations, this ensures a continuation in supply without sterilising mineral reserves. However, operational capacity constraints still apply (imposed by plant capacity or planning conditions which limit tonnages/production) which can limit the amount of resource available to meet demand and therefore there may be a requirement for green field sites in addition to extensions. It is considered that a more sustainable strategy would be a locational strategy which shows allocations and preferred areas of working for new sites in each of the three main areas for sand and gravel working (Trent Valley, north of Newark and the Idle Valley) to ensure there are sufficient operations in place to meet demand, particularly relevant where there is evidence of sand and gravel resource, reserve and production capacity decline in adjoining authority areas.
Sand and gravel provision
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 market.
It is considered that a geographical spread of sand and gravel operations is a sustainable strategy and Tarmac support this approach. These areas have historical supply markets/area demand which has not changed - i.e major growth areas which will still be providing housing, employment, infrastructure etc remain. In addition, a
number of operations spread within a locality will also ensure the continuity/maintenance of supply in the event of operational constraint or in the event of a site having to shut down/cease operating.
It is not clear why specific reference is made to the Planning Application at Barton in Fabis and the contribution this could make to future mineral supply? Current undetermined Applications at Langford and Bestwood are not referred to in the same context. It is considered that the Plan should provide factual information only at this stage, and the reference to Barton in Fabis specifically appears to give it a favourable status which is not appropriate in this context.
Plan 3 isn't very informative. It would benefit from major trunk roads being identified, major towns/growth areas labelling, and the Idle Valley showing.
Q9. Would it be more appropriate to prioritise specific areas above others?
The Locational strategy should be heavily influenced/focussed on known markets and by access to market and ease of access to the local highway network to transport mineral within and where necessary outside of the County.
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.
The difference between long distance barging to market and short distance/shuttle barging to processing plant requires a distinction.
Long Distance Barging to Market
It has not in recent years been economical to transport mineral by barge. The costs of loading / unloading and transportation are often significantly greater than conventional distribution to market by road, and is significantly less flexible to meet market demand. It is unlikely that sand and gravel operations will be developed based on barge transportation alone.
River barge transportation of sand and gravel from Besthorpe Quarry ceased in August 2013 as supply to the West Yorkshire market from North Yorkshire (including rail fed crushed rock) became more economic. The position may change in the medium to long term as supply scenarios change over time. Tarmac have therefore
retained the over wharf facility at Besthorpe in a mothballed state rather than removing the wharf facility altogether.
Short distance shuttle barging (to processing plant)
The costs of loading and unloading and provision of handling/ processing facilities significantly add to operating costs and shuttle barging over short distances are unlikely to be economic against traditional land based operations.
There may be opportunities for a shuttle barge transportation system to be adopted for working some sand and gravel resources where inadequate road access exists. Such a system may enable otherwise constrained mineral resources to be worked, but the viability does depend heavily on suitable mineral handling and processing facilities being available at the receiving end (particularly facilities for mineral processing , washing and silt disposal).
Sherwood Sandstone
Q11. Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?
The LAA recognises the high level of export to markets outside the County due to limited resources elsewhere. As per comments on sand and gravel, there is a need where resource exists to maintain production and operating capacity to meet demand. The Plan should identify appropriate extensions to existing operations or new sites to meet this demand. Identified demand based on sales is a minimum requirement of the Plan and it is considered there needs to be flexibility built into the Plan to allow sites to come forward. The plan should address anticipated demand from outside of the County.
The Plan should recognise the unique properties of the sand as well as markets. Colour variances as well as properties of the sand are also important factors and therefore additional reserves (as allocations or new sites) should not solely be based upon estimated demand based on sales figures.
Crushed Rock
The Plan should update the current position on Nether Langwith as Tarmac has obtained planning permission to extend the timescales for working and restoration.
It is likely that there is a wider demand for crushed rock within the County than that met by Nether Langwith. Crushed rock requirements are likely to be met from imports to meet the demand within the south of the County to minimise the distance crushed rock will need to travel.
Alternative Aggregates
Q14. Are you aware of any issues relating to alternative aggregates that should be considered through the minerals Local Plan review?
Support for the MPA in seeking the use of alternative aggregates and the appreciation that there are limits on how far alternatives can substitute primary aggregate. It is considered whilst support for alternative aggregate should be encouraged in the Plan, the contribution should be viewed as a 'bonus' over and above the required amount of primary aggregate. This is reflective of the NPPF (para
143) which states that local Plans should take account of the, 'contribution that substitute or secondary and recycled materials and minerals waste can make'. The reference made by the MPA to the reduction in ash materials from coal fired power stations is also likely to increase the demand for primary aggregate over the Plan period to address this specific resource shortfall. The approach to recycled aggregates reflects the Mineral Products Association Long Tern Aggregates Demand and Supply Scenarios Paper which indicates that the potential for recycling has reached an optimum level (approximately 28-30% volume).
Industrial Dolomite Provision
Q20. Are you aware if any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?
Reserves of industrial dolomite are of international importance. Whilst additional resource areas do not need to be identified as an allocation, the resource within Nottinghamshire should be identified within the Plan and recognised as a proven resource to be safeguarded.
Development Management Policies
Q25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
Yes agree that it covers all areas.
Minerals Safeguarding and Consultation Areas
Q26 Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?
It is considered that the Minerals Plan should define more specific Mineral Consultation Areas. The proposed approach to define consultation areas on the same scale as safeguarding areas could mean that large amounts of development will be caught within an MSA/MCA which would be onerous on developers having to potentially submit minerals assessments and the MPA in assessing the potential for impact of development on mineral resource/mineral associated infrastructure. This is contrary to the objectives of the NPPF paragraph 143. A criteria based approach to MCA's would be a more appropriate strategy. In addition Plan 7 would benefit from clearer distinction between areas of safeguarding. It is not clear where the alluvial sand and gravel is located.
As well as safeguarding mineral associated infrastructure, rail heads should be expanded to include rail heads at coal fired power stations. A wharf facility at Colwick is specifically referenced for safeguarding. Tarmac have existing wharf facilities which should also be referenced if this is the approach to be adopted by the MPA.
The importance of Local Plan's (District and Borough Council) in understanding and appreciating the role of safeguarding and defining areas/sites within Local Development Plan Documents should be explained within the Mineral Plan. The Planning system is a tiered system with the policies contained within the Mineral Plan and Local plan pertinent to the consideration of Planning Applications at County and District level. The MPA has an important role in ensuring mineral safeguarding is not perceived as just a County function but guiding and supporting Local Authorities to appreciate they also have a role to play in accordance with the Planning Practice Guidance.
Sustainability Appraisal Scoping Report
Proposed SA Objectives
As per comments on the Issues and Options Paper, Objective 2 should reflect the NPPF and seek to protect and enhance biodiversity 'where possible' as opposed to at all levels. The NPPF recognises that biodiversity should be protected, enhanced and where necessary any impact mitigated against as opposed to being categorical that all development needs to provide ecological enhancement.
General Comments
As we have stated as part of previous consultation responses on other MLP Drafts, the weighting of each of the Sustainability Appraisal objectives should be explained and how these will be used to assess the Plan policies and any sites promoted for allocation. Currently the SA Objectives are heavily weighted to potential environmental effect. However, economic and social facets of sustainability are critical elements relating to minerals development - i.e maintaining supply, access and proximity to market, beneficial restoration objectives etc. Attention is drawn to the NPPF and that 'minerals are essential to support sustainable economic growth' (paragraph 142). As well as providing an 'adequate' amount, the SA has failed to take account of the need to plan for a 'steady and adequate' supply of aggregate (paragraph 145). There is a requirement for the MPA to recognise that as well as ensuring they have a sufficient land bank of resource that the Plan maintains aggregate provision across the whole Plan period - comments above on operational capacity are particularly pertinent to this.
Table 2 - Sustainability issues
Table 2 identifies the economy and employment as only having a low/moderate significance to the Plan. It is considered this is understated and refer to paragraph 142 of the NPPF, 'minerals are essential to support sustainable economic growth and our quality of life'. This significance should be amended.
Table 4
Objective 1 should include operational capacity as a proposed indicator in assessing whether adequate provision is being made to meet local and national mineral demand.
I trust that the above comments are helpful. Should you have any queries or wish to discuss any of the points raised in more detail, please do not hesitate to contact us.
Yours sincerely,
Jenna Conway
Heaton Planning Limited
Attachments:
Comment
Minerals Local Plan Issues and Options consultation
Q1 Do you think any further information should be included in the overview of the area?
Representation ID: 30658
Received: 10/01/2018
Respondent: Tarmac Ltd
Yes. It is considered that the cross boundary relationship with neighbouring authorities should be identified taking into account:
-Cross-boundary mineral supply
-Lack of crushed rock/limestone within County
-Availability of infrastructure links
-Overlap of housing,business,infrastructure,employment links
-Relationship with other minerals authorities&Duty to Cooperate
-Anticipated development needs for housing,employment,infrastructure provision
Issues and Options Paper
Section 2 - Setting the overall Context for the Plan
Q1 - Do you think any further information should be included in the overview of the area?
Yes. It is considered that the cross boundary relationship with neighbouring authorities should be identified taking into account:
1. cross boundary mineral supply from Nottinghamshire - eg to South Yorkshire, and Leicestershire in light of their identified lack of available sand and gravel resources and production capacity to meet demand over the Plan period
2. The lack of available crushed rock/limestone resource within the County and therefore the heavy reliance on import from adjoining Authority areas
3. The availability of infrastructure links - particularly good road network and therefore links to market in assisting to secure mineral supply
4. The overlap of housing, business, infrastructure and employment links with Derbyshire and Leicestershire are identified but there is currently no reference to an overlap of mineral supply issues
5. The relationship with other mineral authorities and duty to cooperate in Plan preparation should be referenced
6. The anticipated development needs for housing, employment and infrastructure provision (including HS2)
Q2 Do you agree with the Draft Vision? Are there other things that we should include?
In general terms we would support the Draft Vision. However, it is considered there are two important issues missing. Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF which states, 'Mineral Planning Authorities should plan for a steady and adequate supply of aggregates by making provision for the maintenance of landbank.... whilst ensuring that the capacity of operations to supply a wide range of materials is not compromised'. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources. Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.
Q3 Are the above strategic issues appropriate? Are there others we should consider?
Key Strategic Issue 1 and a locational strategy to securing mineral supply is supported. This approach maintains the spread of operations across the County and maintains a security in supply to the specific markets that these serve.
The principle of Key Strategic Issue 2 is supported. However, as referred above, the Plan should identify the anticipated demand from adjoining Authority areas.
We do not agree with Strategic Issue 4 and a 'Biodiversity led restoration' approach to all mineral operations. This is not always appropriate when balancing the needs of
the landowner and long term economic value of land post restoration. Biodiversity improvements should be sought 'where possible'. The Council's vision should adopt a more balanced stance in respect of the restoration of mineral sites taking account of the three elements of sustainability set out in the NPPF (e.g. economic, social and environmental). Tarmac do however support the vision for creating landscape-scale biodiversity resources as part of stakeholder co-ordinated initiatives (ie The RSPB Bigger Better Vision for the Trent Valley area north of Newark). This should be referred to in the strategy.
Strategic Issue 4 should also consider the opportunities which mineral extraction creates for the deposit of inert infill as part of delivering agricultural restoration in helping to meet the need for inert waste disposal in Nottinghamshire.
Minerals Provision
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.
No it is not considered that the 10 years average sales figures are the most suitable methodology for forecasting aggregate demand. National Policy states, forecasts of demand should be based on a rolling average of 10 years sales data, other relevant information and through assessment of all other supply options. The 10 years average sales are heavily influenced by the impact of the recession. In addition, the movement of production at Finningley outside the County boundary has effectively skewed the perceived sales/demand. This is particularly apparent given the picture across the East Midlands which in all other cases have seen increases in sales figures. Whilst, recycled and secondary aggregate has a role to play in meeting demand in some circumstances it cannot be relied upon for ensuring continuity in supply. In addition given the location of the County it is unlikely that demand can be met from other sources (for example marine). In light of this, the other relevant local information is particularly important in forecasting future demand in the County. We support the MPA in their previous approach which reviewed sales data pre and post- recession to give a greater appreciation of likely anticipated demand in recession and a period of economic growth.
As we have referred to above, the operational capacity of permitted operations within the County needs consideration to ensure that anticipated demand is met. A
decline in sales is not necessarily an indication of a decline in demand. Production moving outside of the County will impact upon perceived sales figures as well as sites/resource not being replaced when exhausted.
A Delivery schedule (as per previous MLP drafts) would be helpful in ensuring that sites are allocated to cover the whole Plan period. Although the landbank is sufficient at the start of the Plan period, sites will become exhausted during the Plan period and provision should be made for replacements. Tarmac have produced their own delivery schedule (enclosed with this submission) to illustrate the timescales for known reserves becoming available during the Plan period.
The Issues and Options paper states, the decline in Nottinghamshire sales of sand and gravel is a result of the, 'minerals industry focusing on existing quarries outside the County and the lack of investment in new greenfield quarries in Nottinghamshire even though adequate sand and gravel resources remain'. This statement is not substantiated or evidenced. The 9 years of public consultation (between 2008 and 2017) eventually leading to the withdrawn Nottinghamshire Draft Plan has not created a positive or stable platform for industry investment. There are numerous existing operations with logical and feasible extensions, a number of which have previously been promoted to the previous Mineral Local Plan process as well as new greenfield reserves which have been subject to Scoping Requests with the Mineral Planning Authority. Notwithstanding this, significant investment (both financial and time) is required in pre-planning processes in obtaining baseline environmental assessment work to support a planning application. The Mineral industry is only recently seeing increases in sales post-recession which provides the security/assurance in making significant financial investment to existing and new operations. In addition, it is the market factors that dictate where operations would be best placed to serve the local needs.
The Plan should not focus or specify a definitive/maximum amount of mineral provision. The sales data is an indication of demand and should not be perceived as a maximum requirement. The Plan needs to provide flexibility to support additional sites/resources coming forward during the Plan period to meet demand/operational requirements to serve existing/future markets.
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?
As above, the use of 10 years average does not accurately represent the 'local circumstance'. A decline in sales is not necessarily an indication of decline in demand. Whilst it is one consideration, the fact that the sales/supply picture within Nottinghamshire is so different from the rest of the East Midlands and the national picture indicates that the sales data alone is not a true reflection of current circumstances.
Strategic Approach to New Mineral Development
Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
There needs to be allowance in the Plan for both extensions and new greenfield sites. The NPPF removed previous planning policy preference for extensions to existing operations. As a result, emerging policy should not give preference to extensions in order to be compliant with national policy. However, as we have previously stated, the Plan should provide flexibility and policy should be supportive in securing extensions to existing operations, this ensures a continuation in supply without sterilising mineral reserves. However, operational capacity constraints still apply (imposed by plant capacity or planning conditions which limit tonnages/production) which can limit the amount of resource available to meet demand and therefore there may be a requirement for green field sites in addition to extensions. It is considered that a more sustainable strategy would be a locational strategy which shows allocations and preferred areas of working for new sites in each of the three main areas for sand and gravel working (Trent Valley, north of Newark and the Idle Valley) to ensure there are sufficient operations in place to meet demand, particularly relevant where there is evidence of sand and gravel resource, reserve and production capacity decline in adjoining authority areas.
Sand and gravel provision
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 market.
It is considered that a geographical spread of sand and gravel operations is a sustainable strategy and Tarmac support this approach. These areas have historical supply markets/area demand which has not changed - i.e major growth areas which will still be providing housing, employment, infrastructure etc remain. In addition, a
number of operations spread within a locality will also ensure the continuity/maintenance of supply in the event of operational constraint or in the event of a site having to shut down/cease operating.
It is not clear why specific reference is made to the Planning Application at Barton in Fabis and the contribution this could make to future mineral supply? Current undetermined Applications at Langford and Bestwood are not referred to in the same context. It is considered that the Plan should provide factual information only at this stage, and the reference to Barton in Fabis specifically appears to give it a favourable status which is not appropriate in this context.
Plan 3 isn't very informative. It would benefit from major trunk roads being identified, major towns/growth areas labelling, and the Idle Valley showing.
Q9. Would it be more appropriate to prioritise specific areas above others?
The Locational strategy should be heavily influenced/focussed on known markets and by access to market and ease of access to the local highway network to transport mineral within and where necessary outside of the County.
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.
The difference between long distance barging to market and short distance/shuttle barging to processing plant requires a distinction.
Long Distance Barging to Market
It has not in recent years been economical to transport mineral by barge. The costs of loading / unloading and transportation are often significantly greater than conventional distribution to market by road, and is significantly less flexible to meet market demand. It is unlikely that sand and gravel operations will be developed based on barge transportation alone.
River barge transportation of sand and gravel from Besthorpe Quarry ceased in August 2013 as supply to the West Yorkshire market from North Yorkshire (including rail fed crushed rock) became more economic. The position may change in the medium to long term as supply scenarios change over time. Tarmac have therefore
retained the over wharf facility at Besthorpe in a mothballed state rather than removing the wharf facility altogether.
Short distance shuttle barging (to processing plant)
The costs of loading and unloading and provision of handling/ processing facilities significantly add to operating costs and shuttle barging over short distances are unlikely to be economic against traditional land based operations.
There may be opportunities for a shuttle barge transportation system to be adopted for working some sand and gravel resources where inadequate road access exists. Such a system may enable otherwise constrained mineral resources to be worked, but the viability does depend heavily on suitable mineral handling and processing facilities being available at the receiving end (particularly facilities for mineral processing , washing and silt disposal).
Sherwood Sandstone
Q11. Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?
The LAA recognises the high level of export to markets outside the County due to limited resources elsewhere. As per comments on sand and gravel, there is a need where resource exists to maintain production and operating capacity to meet demand. The Plan should identify appropriate extensions to existing operations or new sites to meet this demand. Identified demand based on sales is a minimum requirement of the Plan and it is considered there needs to be flexibility built into the Plan to allow sites to come forward. The plan should address anticipated demand from outside of the County.
The Plan should recognise the unique properties of the sand as well as markets. Colour variances as well as properties of the sand are also important factors and therefore additional reserves (as allocations or new sites) should not solely be based upon estimated demand based on sales figures.
Crushed Rock
The Plan should update the current position on Nether Langwith as Tarmac has obtained planning permission to extend the timescales for working and restoration.
It is likely that there is a wider demand for crushed rock within the County than that met by Nether Langwith. Crushed rock requirements are likely to be met from imports to meet the demand within the south of the County to minimise the distance crushed rock will need to travel.
Alternative Aggregates
Q14. Are you aware of any issues relating to alternative aggregates that should be considered through the minerals Local Plan review?
Support for the MPA in seeking the use of alternative aggregates and the appreciation that there are limits on how far alternatives can substitute primary aggregate. It is considered whilst support for alternative aggregate should be encouraged in the Plan, the contribution should be viewed as a 'bonus' over and above the required amount of primary aggregate. This is reflective of the NPPF (para
143) which states that local Plans should take account of the, 'contribution that substitute or secondary and recycled materials and minerals waste can make'. The reference made by the MPA to the reduction in ash materials from coal fired power stations is also likely to increase the demand for primary aggregate over the Plan period to address this specific resource shortfall. The approach to recycled aggregates reflects the Mineral Products Association Long Tern Aggregates Demand and Supply Scenarios Paper which indicates that the potential for recycling has reached an optimum level (approximately 28-30% volume).
Industrial Dolomite Provision
Q20. Are you aware if any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?
Reserves of industrial dolomite are of international importance. Whilst additional resource areas do not need to be identified as an allocation, the resource within Nottinghamshire should be identified within the Plan and recognised as a proven resource to be safeguarded.
Development Management Policies
Q25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
Yes agree that it covers all areas.
Minerals Safeguarding and Consultation Areas
Q26 Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?
It is considered that the Minerals Plan should define more specific Mineral Consultation Areas. The proposed approach to define consultation areas on the same scale as safeguarding areas could mean that large amounts of development will be caught within an MSA/MCA which would be onerous on developers having to potentially submit minerals assessments and the MPA in assessing the potential for impact of development on mineral resource/mineral associated infrastructure. This is contrary to the objectives of the NPPF paragraph 143. A criteria based approach to MCA's would be a more appropriate strategy. In addition Plan 7 would benefit from clearer distinction between areas of safeguarding. It is not clear where the alluvial sand and gravel is located.
As well as safeguarding mineral associated infrastructure, rail heads should be expanded to include rail heads at coal fired power stations. A wharf facility at Colwick is specifically referenced for safeguarding. Tarmac have existing wharf facilities which should also be referenced if this is the approach to be adopted by the MPA.
The importance of Local Plan's (District and Borough Council) in understanding and appreciating the role of safeguarding and defining areas/sites within Local Development Plan Documents should be explained within the Mineral Plan. The Planning system is a tiered system with the policies contained within the Mineral Plan and Local plan pertinent to the consideration of Planning Applications at County and District level. The MPA has an important role in ensuring mineral safeguarding is not perceived as just a County function but guiding and supporting Local Authorities to appreciate they also have a role to play in accordance with the Planning Practice Guidance.
Comment
Minerals Local Plan Issues and Options consultation
Q2 Do you agree with the draft vision? Are there other things we should include?
Representation ID: 30659
Received: 10/01/2018
Respondent: Tarmac Ltd
Generally support.
Two important issues missing:
Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources.
Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.
Issues and Options Paper
Section 2 - Setting the overall Context for the Plan
Q1 - Do you think any further information should be included in the overview of the area?
Yes. It is considered that the cross boundary relationship with neighbouring authorities should be identified taking into account:
1. cross boundary mineral supply from Nottinghamshire - eg to South Yorkshire, and Leicestershire in light of their identified lack of available sand and gravel resources and production capacity to meet demand over the Plan period
2. The lack of available crushed rock/limestone resource within the County and therefore the heavy reliance on import from adjoining Authority areas
3. The availability of infrastructure links - particularly good road network and therefore links to market in assisting to secure mineral supply
4. The overlap of housing, business, infrastructure and employment links with Derbyshire and Leicestershire are identified but there is currently no reference to an overlap of mineral supply issues
5. The relationship with other mineral authorities and duty to cooperate in Plan preparation should be referenced
6. The anticipated development needs for housing, employment and infrastructure provision (including HS2)
Q2 Do you agree with the Draft Vision? Are there other things that we should include?
In general terms we would support the Draft Vision. However, it is considered there are two important issues missing. Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF which states, 'Mineral Planning Authorities should plan for a steady and adequate supply of aggregates by making provision for the maintenance of landbank.... whilst ensuring that the capacity of operations to supply a wide range of materials is not compromised'. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources. Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.
Q3 Are the above strategic issues appropriate? Are there others we should consider?
Key Strategic Issue 1 and a locational strategy to securing mineral supply is supported. This approach maintains the spread of operations across the County and maintains a security in supply to the specific markets that these serve.
The principle of Key Strategic Issue 2 is supported. However, as referred above, the Plan should identify the anticipated demand from adjoining Authority areas.
We do not agree with Strategic Issue 4 and a 'Biodiversity led restoration' approach to all mineral operations. This is not always appropriate when balancing the needs of
the landowner and long term economic value of land post restoration. Biodiversity improvements should be sought 'where possible'. The Council's vision should adopt a more balanced stance in respect of the restoration of mineral sites taking account of the three elements of sustainability set out in the NPPF (e.g. economic, social and environmental). Tarmac do however support the vision for creating landscape-scale biodiversity resources as part of stakeholder co-ordinated initiatives (ie The RSPB Bigger Better Vision for the Trent Valley area north of Newark). This should be referred to in the strategy.
Strategic Issue 4 should also consider the opportunities which mineral extraction creates for the deposit of inert infill as part of delivering agricultural restoration in helping to meet the need for inert waste disposal in Nottinghamshire.
Minerals Provision
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.
No it is not considered that the 10 years average sales figures are the most suitable methodology for forecasting aggregate demand. National Policy states, forecasts of demand should be based on a rolling average of 10 years sales data, other relevant information and through assessment of all other supply options. The 10 years average sales are heavily influenced by the impact of the recession. In addition, the movement of production at Finningley outside the County boundary has effectively skewed the perceived sales/demand. This is particularly apparent given the picture across the East Midlands which in all other cases have seen increases in sales figures. Whilst, recycled and secondary aggregate has a role to play in meeting demand in some circumstances it cannot be relied upon for ensuring continuity in supply. In addition given the location of the County it is unlikely that demand can be met from other sources (for example marine). In light of this, the other relevant local information is particularly important in forecasting future demand in the County. We support the MPA in their previous approach which reviewed sales data pre and post- recession to give a greater appreciation of likely anticipated demand in recession and a period of economic growth.
As we have referred to above, the operational capacity of permitted operations within the County needs consideration to ensure that anticipated demand is met. A
decline in sales is not necessarily an indication of a decline in demand. Production moving outside of the County will impact upon perceived sales figures as well as sites/resource not being replaced when exhausted.
A Delivery schedule (as per previous MLP drafts) would be helpful in ensuring that sites are allocated to cover the whole Plan period. Although the landbank is sufficient at the start of the Plan period, sites will become exhausted during the Plan period and provision should be made for replacements. Tarmac have produced their own delivery schedule (enclosed with this submission) to illustrate the timescales for known reserves becoming available during the Plan period.
The Issues and Options paper states, the decline in Nottinghamshire sales of sand and gravel is a result of the, 'minerals industry focusing on existing quarries outside the County and the lack of investment in new greenfield quarries in Nottinghamshire even though adequate sand and gravel resources remain'. This statement is not substantiated or evidenced. The 9 years of public consultation (between 2008 and 2017) eventually leading to the withdrawn Nottinghamshire Draft Plan has not created a positive or stable platform for industry investment. There are numerous existing operations with logical and feasible extensions, a number of which have previously been promoted to the previous Mineral Local Plan process as well as new greenfield reserves which have been subject to Scoping Requests with the Mineral Planning Authority. Notwithstanding this, significant investment (both financial and time) is required in pre-planning processes in obtaining baseline environmental assessment work to support a planning application. The Mineral industry is only recently seeing increases in sales post-recession which provides the security/assurance in making significant financial investment to existing and new operations. In addition, it is the market factors that dictate where operations would be best placed to serve the local needs.
The Plan should not focus or specify a definitive/maximum amount of mineral provision. The sales data is an indication of demand and should not be perceived as a maximum requirement. The Plan needs to provide flexibility to support additional sites/resources coming forward during the Plan period to meet demand/operational requirements to serve existing/future markets.
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?
As above, the use of 10 years average does not accurately represent the 'local circumstance'. A decline in sales is not necessarily an indication of decline in demand. Whilst it is one consideration, the fact that the sales/supply picture within Nottinghamshire is so different from the rest of the East Midlands and the national picture indicates that the sales data alone is not a true reflection of current circumstances.
Strategic Approach to New Mineral Development
Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
There needs to be allowance in the Plan for both extensions and new greenfield sites. The NPPF removed previous planning policy preference for extensions to existing operations. As a result, emerging policy should not give preference to extensions in order to be compliant with national policy. However, as we have previously stated, the Plan should provide flexibility and policy should be supportive in securing extensions to existing operations, this ensures a continuation in supply without sterilising mineral reserves. However, operational capacity constraints still apply (imposed by plant capacity or planning conditions which limit tonnages/production) which can limit the amount of resource available to meet demand and therefore there may be a requirement for green field sites in addition to extensions. It is considered that a more sustainable strategy would be a locational strategy which shows allocations and preferred areas of working for new sites in each of the three main areas for sand and gravel working (Trent Valley, north of Newark and the Idle Valley) to ensure there are sufficient operations in place to meet demand, particularly relevant where there is evidence of sand and gravel resource, reserve and production capacity decline in adjoining authority areas.
Sand and gravel provision
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 market.
It is considered that a geographical spread of sand and gravel operations is a sustainable strategy and Tarmac support this approach. These areas have historical supply markets/area demand which has not changed - i.e major growth areas which will still be providing housing, employment, infrastructure etc remain. In addition, a
number of operations spread within a locality will also ensure the continuity/maintenance of supply in the event of operational constraint or in the event of a site having to shut down/cease operating.
It is not clear why specific reference is made to the Planning Application at Barton in Fabis and the contribution this could make to future mineral supply? Current undetermined Applications at Langford and Bestwood are not referred to in the same context. It is considered that the Plan should provide factual information only at this stage, and the reference to Barton in Fabis specifically appears to give it a favourable status which is not appropriate in this context.
Plan 3 isn't very informative. It would benefit from major trunk roads being identified, major towns/growth areas labelling, and the Idle Valley showing.
Q9. Would it be more appropriate to prioritise specific areas above others?
The Locational strategy should be heavily influenced/focussed on known markets and by access to market and ease of access to the local highway network to transport mineral within and where necessary outside of the County.
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.
The difference between long distance barging to market and short distance/shuttle barging to processing plant requires a distinction.
Long Distance Barging to Market
It has not in recent years been economical to transport mineral by barge. The costs of loading / unloading and transportation are often significantly greater than conventional distribution to market by road, and is significantly less flexible to meet market demand. It is unlikely that sand and gravel operations will be developed based on barge transportation alone.
River barge transportation of sand and gravel from Besthorpe Quarry ceased in August 2013 as supply to the West Yorkshire market from North Yorkshire (including rail fed crushed rock) became more economic. The position may change in the medium to long term as supply scenarios change over time. Tarmac have therefore
retained the over wharf facility at Besthorpe in a mothballed state rather than removing the wharf facility altogether.
Short distance shuttle barging (to processing plant)
The costs of loading and unloading and provision of handling/ processing facilities significantly add to operating costs and shuttle barging over short distances are unlikely to be economic against traditional land based operations.
There may be opportunities for a shuttle barge transportation system to be adopted for working some sand and gravel resources where inadequate road access exists. Such a system may enable otherwise constrained mineral resources to be worked, but the viability does depend heavily on suitable mineral handling and processing facilities being available at the receiving end (particularly facilities for mineral processing , washing and silt disposal).
Sherwood Sandstone
Q11. Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?
The LAA recognises the high level of export to markets outside the County due to limited resources elsewhere. As per comments on sand and gravel, there is a need where resource exists to maintain production and operating capacity to meet demand. The Plan should identify appropriate extensions to existing operations or new sites to meet this demand. Identified demand based on sales is a minimum requirement of the Plan and it is considered there needs to be flexibility built into the Plan to allow sites to come forward. The plan should address anticipated demand from outside of the County.
The Plan should recognise the unique properties of the sand as well as markets. Colour variances as well as properties of the sand are also important factors and therefore additional reserves (as allocations or new sites) should not solely be based upon estimated demand based on sales figures.
Crushed Rock
The Plan should update the current position on Nether Langwith as Tarmac has obtained planning permission to extend the timescales for working and restoration.
It is likely that there is a wider demand for crushed rock within the County than that met by Nether Langwith. Crushed rock requirements are likely to be met from imports to meet the demand within the south of the County to minimise the distance crushed rock will need to travel.
Alternative Aggregates
Q14. Are you aware of any issues relating to alternative aggregates that should be considered through the minerals Local Plan review?
Support for the MPA in seeking the use of alternative aggregates and the appreciation that there are limits on how far alternatives can substitute primary aggregate. It is considered whilst support for alternative aggregate should be encouraged in the Plan, the contribution should be viewed as a 'bonus' over and above the required amount of primary aggregate. This is reflective of the NPPF (para
143) which states that local Plans should take account of the, 'contribution that substitute or secondary and recycled materials and minerals waste can make'. The reference made by the MPA to the reduction in ash materials from coal fired power stations is also likely to increase the demand for primary aggregate over the Plan period to address this specific resource shortfall. The approach to recycled aggregates reflects the Mineral Products Association Long Tern Aggregates Demand and Supply Scenarios Paper which indicates that the potential for recycling has reached an optimum level (approximately 28-30% volume).
Industrial Dolomite Provision
Q20. Are you aware if any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?
Reserves of industrial dolomite are of international importance. Whilst additional resource areas do not need to be identified as an allocation, the resource within Nottinghamshire should be identified within the Plan and recognised as a proven resource to be safeguarded.
Development Management Policies
Q25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
Yes agree that it covers all areas.
Minerals Safeguarding and Consultation Areas
Q26 Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?
It is considered that the Minerals Plan should define more specific Mineral Consultation Areas. The proposed approach to define consultation areas on the same scale as safeguarding areas could mean that large amounts of development will be caught within an MSA/MCA which would be onerous on developers having to potentially submit minerals assessments and the MPA in assessing the potential for impact of development on mineral resource/mineral associated infrastructure. This is contrary to the objectives of the NPPF paragraph 143. A criteria based approach to MCA's would be a more appropriate strategy. In addition Plan 7 would benefit from clearer distinction between areas of safeguarding. It is not clear where the alluvial sand and gravel is located.
As well as safeguarding mineral associated infrastructure, rail heads should be expanded to include rail heads at coal fired power stations. A wharf facility at Colwick is specifically referenced for safeguarding. Tarmac have existing wharf facilities which should also be referenced if this is the approach to be adopted by the MPA.
The importance of Local Plan's (District and Borough Council) in understanding and appreciating the role of safeguarding and defining areas/sites within Local Development Plan Documents should be explained within the Mineral Plan. The Planning system is a tiered system with the policies contained within the Mineral Plan and Local plan pertinent to the consideration of Planning Applications at County and District level. The MPA has an important role in ensuring mineral safeguarding is not perceived as just a County function but guiding and supporting Local Authorities to appreciate they also have a role to play in accordance with the Planning Practice Guidance.
Comment
Minerals Local Plan Issues and Options consultation
Q3 Are the above strategic issues appropriate? Are there others we should consider?
Representation ID: 30660
Received: 10/01/2018
Respondent: Tarmac Ltd
KSI1&locational strategy to securing mineral supply is supported. This approach maintains the spread of operations across the County and maintains a security in supply to the specific markets that these serve.
The principle of Key Strategic Issue 2 is supported. The Plan should identify anticipated demand from adjoining Authority areas.
Don't with SI4 and a 'Biodiversity led restoration' approach to all mineral operations.
SI4 should consider opportunities which mineral extraction creates for the deposit of inert infill.
Issues and Options Paper
Section 2 - Setting the overall Context for the Plan
Q1 - Do you think any further information should be included in the overview of the area?
Yes. It is considered that the cross boundary relationship with neighbouring authorities should be identified taking into account:
1. cross boundary mineral supply from Nottinghamshire - eg to South Yorkshire, and Leicestershire in light of their identified lack of available sand and gravel resources and production capacity to meet demand over the Plan period
2. The lack of available crushed rock/limestone resource within the County and therefore the heavy reliance on import from adjoining Authority areas
3. The availability of infrastructure links - particularly good road network and therefore links to market in assisting to secure mineral supply
4. The overlap of housing, business, infrastructure and employment links with Derbyshire and Leicestershire are identified but there is currently no reference to an overlap of mineral supply issues
5. The relationship with other mineral authorities and duty to cooperate in Plan preparation should be referenced
6. The anticipated development needs for housing, employment and infrastructure provision (including HS2)
Q2 Do you agree with the Draft Vision? Are there other things that we should include?
In general terms we would support the Draft Vision. However, it is considered there are two important issues missing. Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF which states, 'Mineral Planning Authorities should plan for a steady and adequate supply of aggregates by making provision for the maintenance of landbank.... whilst ensuring that the capacity of operations to supply a wide range of materials is not compromised'. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources. Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.
Q3 Are the above strategic issues appropriate? Are there others we should consider?
Key Strategic Issue 1 and a locational strategy to securing mineral supply is supported. This approach maintains the spread of operations across the County and maintains a security in supply to the specific markets that these serve.
The principle of Key Strategic Issue 2 is supported. However, as referred above, the Plan should identify the anticipated demand from adjoining Authority areas.
We do not agree with Strategic Issue 4 and a 'Biodiversity led restoration' approach to all mineral operations. This is not always appropriate when balancing the needs of
the landowner and long term economic value of land post restoration. Biodiversity improvements should be sought 'where possible'. The Council's vision should adopt a more balanced stance in respect of the restoration of mineral sites taking account of the three elements of sustainability set out in the NPPF (e.g. economic, social and environmental). Tarmac do however support the vision for creating landscape-scale biodiversity resources as part of stakeholder co-ordinated initiatives (ie The RSPB Bigger Better Vision for the Trent Valley area north of Newark). This should be referred to in the strategy.
Strategic Issue 4 should also consider the opportunities which mineral extraction creates for the deposit of inert infill as part of delivering agricultural restoration in helping to meet the need for inert waste disposal in Nottinghamshire.
Minerals Provision
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.
No it is not considered that the 10 years average sales figures are the most suitable methodology for forecasting aggregate demand. National Policy states, forecasts of demand should be based on a rolling average of 10 years sales data, other relevant information and through assessment of all other supply options. The 10 years average sales are heavily influenced by the impact of the recession. In addition, the movement of production at Finningley outside the County boundary has effectively skewed the perceived sales/demand. This is particularly apparent given the picture across the East Midlands which in all other cases have seen increases in sales figures. Whilst, recycled and secondary aggregate has a role to play in meeting demand in some circumstances it cannot be relied upon for ensuring continuity in supply. In addition given the location of the County it is unlikely that demand can be met from other sources (for example marine). In light of this, the other relevant local information is particularly important in forecasting future demand in the County. We support the MPA in their previous approach which reviewed sales data pre and post- recession to give a greater appreciation of likely anticipated demand in recession and a period of economic growth.
As we have referred to above, the operational capacity of permitted operations within the County needs consideration to ensure that anticipated demand is met. A
decline in sales is not necessarily an indication of a decline in demand. Production moving outside of the County will impact upon perceived sales figures as well as sites/resource not being replaced when exhausted.
A Delivery schedule (as per previous MLP drafts) would be helpful in ensuring that sites are allocated to cover the whole Plan period. Although the landbank is sufficient at the start of the Plan period, sites will become exhausted during the Plan period and provision should be made for replacements. Tarmac have produced their own delivery schedule (enclosed with this submission) to illustrate the timescales for known reserves becoming available during the Plan period.
The Issues and Options paper states, the decline in Nottinghamshire sales of sand and gravel is a result of the, 'minerals industry focusing on existing quarries outside the County and the lack of investment in new greenfield quarries in Nottinghamshire even though adequate sand and gravel resources remain'. This statement is not substantiated or evidenced. The 9 years of public consultation (between 2008 and 2017) eventually leading to the withdrawn Nottinghamshire Draft Plan has not created a positive or stable platform for industry investment. There are numerous existing operations with logical and feasible extensions, a number of which have previously been promoted to the previous Mineral Local Plan process as well as new greenfield reserves which have been subject to Scoping Requests with the Mineral Planning Authority. Notwithstanding this, significant investment (both financial and time) is required in pre-planning processes in obtaining baseline environmental assessment work to support a planning application. The Mineral industry is only recently seeing increases in sales post-recession which provides the security/assurance in making significant financial investment to existing and new operations. In addition, it is the market factors that dictate where operations would be best placed to serve the local needs.
The Plan should not focus or specify a definitive/maximum amount of mineral provision. The sales data is an indication of demand and should not be perceived as a maximum requirement. The Plan needs to provide flexibility to support additional sites/resources coming forward during the Plan period to meet demand/operational requirements to serve existing/future markets.
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?
As above, the use of 10 years average does not accurately represent the 'local circumstance'. A decline in sales is not necessarily an indication of decline in demand. Whilst it is one consideration, the fact that the sales/supply picture within Nottinghamshire is so different from the rest of the East Midlands and the national picture indicates that the sales data alone is not a true reflection of current circumstances.
Strategic Approach to New Mineral Development
Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
There needs to be allowance in the Plan for both extensions and new greenfield sites. The NPPF removed previous planning policy preference for extensions to existing operations. As a result, emerging policy should not give preference to extensions in order to be compliant with national policy. However, as we have previously stated, the Plan should provide flexibility and policy should be supportive in securing extensions to existing operations, this ensures a continuation in supply without sterilising mineral reserves. However, operational capacity constraints still apply (imposed by plant capacity or planning conditions which limit tonnages/production) which can limit the amount of resource available to meet demand and therefore there may be a requirement for green field sites in addition to extensions. It is considered that a more sustainable strategy would be a locational strategy which shows allocations and preferred areas of working for new sites in each of the three main areas for sand and gravel working (Trent Valley, north of Newark and the Idle Valley) to ensure there are sufficient operations in place to meet demand, particularly relevant where there is evidence of sand and gravel resource, reserve and production capacity decline in adjoining authority areas.
Sand and gravel provision
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 market.
It is considered that a geographical spread of sand and gravel operations is a sustainable strategy and Tarmac support this approach. These areas have historical supply markets/area demand which has not changed - i.e major growth areas which will still be providing housing, employment, infrastructure etc remain. In addition, a
number of operations spread within a locality will also ensure the continuity/maintenance of supply in the event of operational constraint or in the event of a site having to shut down/cease operating.
It is not clear why specific reference is made to the Planning Application at Barton in Fabis and the contribution this could make to future mineral supply? Current undetermined Applications at Langford and Bestwood are not referred to in the same context. It is considered that the Plan should provide factual information only at this stage, and the reference to Barton in Fabis specifically appears to give it a favourable status which is not appropriate in this context.
Plan 3 isn't very informative. It would benefit from major trunk roads being identified, major towns/growth areas labelling, and the Idle Valley showing.
Q9. Would it be more appropriate to prioritise specific areas above others?
The Locational strategy should be heavily influenced/focussed on known markets and by access to market and ease of access to the local highway network to transport mineral within and where necessary outside of the County.
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.
The difference between long distance barging to market and short distance/shuttle barging to processing plant requires a distinction.
Long Distance Barging to Market
It has not in recent years been economical to transport mineral by barge. The costs of loading / unloading and transportation are often significantly greater than conventional distribution to market by road, and is significantly less flexible to meet market demand. It is unlikely that sand and gravel operations will be developed based on barge transportation alone.
River barge transportation of sand and gravel from Besthorpe Quarry ceased in August 2013 as supply to the West Yorkshire market from North Yorkshire (including rail fed crushed rock) became more economic. The position may change in the medium to long term as supply scenarios change over time. Tarmac have therefore
retained the over wharf facility at Besthorpe in a mothballed state rather than removing the wharf facility altogether.
Short distance shuttle barging (to processing plant)
The costs of loading and unloading and provision of handling/ processing facilities significantly add to operating costs and shuttle barging over short distances are unlikely to be economic against traditional land based operations.
There may be opportunities for a shuttle barge transportation system to be adopted for working some sand and gravel resources where inadequate road access exists. Such a system may enable otherwise constrained mineral resources to be worked, but the viability does depend heavily on suitable mineral handling and processing facilities being available at the receiving end (particularly facilities for mineral processing , washing and silt disposal).
Sherwood Sandstone
Q11. Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?
The LAA recognises the high level of export to markets outside the County due to limited resources elsewhere. As per comments on sand and gravel, there is a need where resource exists to maintain production and operating capacity to meet demand. The Plan should identify appropriate extensions to existing operations or new sites to meet this demand. Identified demand based on sales is a minimum requirement of the Plan and it is considered there needs to be flexibility built into the Plan to allow sites to come forward. The plan should address anticipated demand from outside of the County.
The Plan should recognise the unique properties of the sand as well as markets. Colour variances as well as properties of the sand are also important factors and therefore additional reserves (as allocations or new sites) should not solely be based upon estimated demand based on sales figures.
Crushed Rock
The Plan should update the current position on Nether Langwith as Tarmac has obtained planning permission to extend the timescales for working and restoration.
It is likely that there is a wider demand for crushed rock within the County than that met by Nether Langwith. Crushed rock requirements are likely to be met from imports to meet the demand within the south of the County to minimise the distance crushed rock will need to travel.
Alternative Aggregates
Q14. Are you aware of any issues relating to alternative aggregates that should be considered through the minerals Local Plan review?
Support for the MPA in seeking the use of alternative aggregates and the appreciation that there are limits on how far alternatives can substitute primary aggregate. It is considered whilst support for alternative aggregate should be encouraged in the Plan, the contribution should be viewed as a 'bonus' over and above the required amount of primary aggregate. This is reflective of the NPPF (para
143) which states that local Plans should take account of the, 'contribution that substitute or secondary and recycled materials and minerals waste can make'. The reference made by the MPA to the reduction in ash materials from coal fired power stations is also likely to increase the demand for primary aggregate over the Plan period to address this specific resource shortfall. The approach to recycled aggregates reflects the Mineral Products Association Long Tern Aggregates Demand and Supply Scenarios Paper which indicates that the potential for recycling has reached an optimum level (approximately 28-30% volume).
Industrial Dolomite Provision
Q20. Are you aware if any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?
Reserves of industrial dolomite are of international importance. Whilst additional resource areas do not need to be identified as an allocation, the resource within Nottinghamshire should be identified within the Plan and recognised as a proven resource to be safeguarded.
Development Management Policies
Q25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
Yes agree that it covers all areas.
Minerals Safeguarding and Consultation Areas
Q26 Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?
It is considered that the Minerals Plan should define more specific Mineral Consultation Areas. The proposed approach to define consultation areas on the same scale as safeguarding areas could mean that large amounts of development will be caught within an MSA/MCA which would be onerous on developers having to potentially submit minerals assessments and the MPA in assessing the potential for impact of development on mineral resource/mineral associated infrastructure. This is contrary to the objectives of the NPPF paragraph 143. A criteria based approach to MCA's would be a more appropriate strategy. In addition Plan 7 would benefit from clearer distinction between areas of safeguarding. It is not clear where the alluvial sand and gravel is located.
As well as safeguarding mineral associated infrastructure, rail heads should be expanded to include rail heads at coal fired power stations. A wharf facility at Colwick is specifically referenced for safeguarding. Tarmac have existing wharf facilities which should also be referenced if this is the approach to be adopted by the MPA.
The importance of Local Plan's (District and Borough Council) in understanding and appreciating the role of safeguarding and defining areas/sites within Local Development Plan Documents should be explained within the Mineral Plan. The Planning system is a tiered system with the policies contained within the Mineral Plan and Local plan pertinent to the consideration of Planning Applications at County and District level. The MPA has an important role in ensuring mineral safeguarding is not perceived as just a County function but guiding and supporting Local Authorities to appreciate they also have a role to play in accordance with the Planning Practice Guidance.
Comment
Minerals Local Plan Issues and Options consultation
Q4 Do you think the average 10 year sales figure is the most suitable methodology for forecasting future demand in Nottinghamshire? If not please identify any alternatives
Representation ID: 30661
Received: 10/01/2018
Respondent: Tarmac Ltd
10 year average figure is not considered suitable as the figures are heavily influenced by the recession and movement of production at Finningley.
This is particularly apparent given increasing sales across the East Midlands. Worth noting that a decline in sales is not necessarily an indication of a decline in demand.
The 9 years of public consultation resulting in the withdrawal of the MLP has not created a positive or stable platform for industry investment.
Recycled and secondary aggregate has a role to play in meeting demand in some circumstances it cannot be relied upon for ensuring continuity in supply.
Issues and Options Paper
Section 2 - Setting the overall Context for the Plan
Q1 - Do you think any further information should be included in the overview of the area?
Yes. It is considered that the cross boundary relationship with neighbouring authorities should be identified taking into account:
1. cross boundary mineral supply from Nottinghamshire - eg to South Yorkshire, and Leicestershire in light of their identified lack of available sand and gravel resources and production capacity to meet demand over the Plan period
2. The lack of available crushed rock/limestone resource within the County and therefore the heavy reliance on import from adjoining Authority areas
3. The availability of infrastructure links - particularly good road network and therefore links to market in assisting to secure mineral supply
4. The overlap of housing, business, infrastructure and employment links with Derbyshire and Leicestershire are identified but there is currently no reference to an overlap of mineral supply issues
5. The relationship with other mineral authorities and duty to cooperate in Plan preparation should be referenced
6. The anticipated development needs for housing, employment and infrastructure provision (including HS2)
Q2 Do you agree with the Draft Vision? Are there other things that we should include?
In general terms we would support the Draft Vision. However, it is considered there are two important issues missing. Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF which states, 'Mineral Planning Authorities should plan for a steady and adequate supply of aggregates by making provision for the maintenance of landbank.... whilst ensuring that the capacity of operations to supply a wide range of materials is not compromised'. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources. Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.
Q3 Are the above strategic issues appropriate? Are there others we should consider?
Key Strategic Issue 1 and a locational strategy to securing mineral supply is supported. This approach maintains the spread of operations across the County and maintains a security in supply to the specific markets that these serve.
The principle of Key Strategic Issue 2 is supported. However, as referred above, the Plan should identify the anticipated demand from adjoining Authority areas.
We do not agree with Strategic Issue 4 and a 'Biodiversity led restoration' approach to all mineral operations. This is not always appropriate when balancing the needs of
the landowner and long term economic value of land post restoration. Biodiversity improvements should be sought 'where possible'. The Council's vision should adopt a more balanced stance in respect of the restoration of mineral sites taking account of the three elements of sustainability set out in the NPPF (e.g. economic, social and environmental). Tarmac do however support the vision for creating landscape-scale biodiversity resources as part of stakeholder co-ordinated initiatives (ie The RSPB Bigger Better Vision for the Trent Valley area north of Newark). This should be referred to in the strategy.
Strategic Issue 4 should also consider the opportunities which mineral extraction creates for the deposit of inert infill as part of delivering agricultural restoration in helping to meet the need for inert waste disposal in Nottinghamshire.
Minerals Provision
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.
No it is not considered that the 10 years average sales figures are the most suitable methodology for forecasting aggregate demand. National Policy states, forecasts of demand should be based on a rolling average of 10 years sales data, other relevant information and through assessment of all other supply options. The 10 years average sales are heavily influenced by the impact of the recession. In addition, the movement of production at Finningley outside the County boundary has effectively skewed the perceived sales/demand. This is particularly apparent given the picture across the East Midlands which in all other cases have seen increases in sales figures. Whilst, recycled and secondary aggregate has a role to play in meeting demand in some circumstances it cannot be relied upon for ensuring continuity in supply. In addition given the location of the County it is unlikely that demand can be met from other sources (for example marine). In light of this, the other relevant local information is particularly important in forecasting future demand in the County. We support the MPA in their previous approach which reviewed sales data pre and post- recession to give a greater appreciation of likely anticipated demand in recession and a period of economic growth.
As we have referred to above, the operational capacity of permitted operations within the County needs consideration to ensure that anticipated demand is met. A
decline in sales is not necessarily an indication of a decline in demand. Production moving outside of the County will impact upon perceived sales figures as well as sites/resource not being replaced when exhausted.
A Delivery schedule (as per previous MLP drafts) would be helpful in ensuring that sites are allocated to cover the whole Plan period. Although the landbank is sufficient at the start of the Plan period, sites will become exhausted during the Plan period and provision should be made for replacements. Tarmac have produced their own delivery schedule (enclosed with this submission) to illustrate the timescales for known reserves becoming available during the Plan period.
The Issues and Options paper states, the decline in Nottinghamshire sales of sand and gravel is a result of the, 'minerals industry focusing on existing quarries outside the County and the lack of investment in new greenfield quarries in Nottinghamshire even though adequate sand and gravel resources remain'. This statement is not substantiated or evidenced. The 9 years of public consultation (between 2008 and 2017) eventually leading to the withdrawn Nottinghamshire Draft Plan has not created a positive or stable platform for industry investment. There are numerous existing operations with logical and feasible extensions, a number of which have previously been promoted to the previous Mineral Local Plan process as well as new greenfield reserves which have been subject to Scoping Requests with the Mineral Planning Authority. Notwithstanding this, significant investment (both financial and time) is required in pre-planning processes in obtaining baseline environmental assessment work to support a planning application. The Mineral industry is only recently seeing increases in sales post-recession which provides the security/assurance in making significant financial investment to existing and new operations. In addition, it is the market factors that dictate where operations would be best placed to serve the local needs.
The Plan should not focus or specify a definitive/maximum amount of mineral provision. The sales data is an indication of demand and should not be perceived as a maximum requirement. The Plan needs to provide flexibility to support additional sites/resources coming forward during the Plan period to meet demand/operational requirements to serve existing/future markets.
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?
As above, the use of 10 years average does not accurately represent the 'local circumstance'. A decline in sales is not necessarily an indication of decline in demand. Whilst it is one consideration, the fact that the sales/supply picture within Nottinghamshire is so different from the rest of the East Midlands and the national picture indicates that the sales data alone is not a true reflection of current circumstances.
Strategic Approach to New Mineral Development
Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
There needs to be allowance in the Plan for both extensions and new greenfield sites. The NPPF removed previous planning policy preference for extensions to existing operations. As a result, emerging policy should not give preference to extensions in order to be compliant with national policy. However, as we have previously stated, the Plan should provide flexibility and policy should be supportive in securing extensions to existing operations, this ensures a continuation in supply without sterilising mineral reserves. However, operational capacity constraints still apply (imposed by plant capacity or planning conditions which limit tonnages/production) which can limit the amount of resource available to meet demand and therefore there may be a requirement for green field sites in addition to extensions. It is considered that a more sustainable strategy would be a locational strategy which shows allocations and preferred areas of working for new sites in each of the three main areas for sand and gravel working (Trent Valley, north of Newark and the Idle Valley) to ensure there are sufficient operations in place to meet demand, particularly relevant where there is evidence of sand and gravel resource, reserve and production capacity decline in adjoining authority areas.
Sand and gravel provision
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 market.
It is considered that a geographical spread of sand and gravel operations is a sustainable strategy and Tarmac support this approach. These areas have historical supply markets/area demand which has not changed - i.e major growth areas which will still be providing housing, employment, infrastructure etc remain. In addition, a
number of operations spread within a locality will also ensure the continuity/maintenance of supply in the event of operational constraint or in the event of a site having to shut down/cease operating.
It is not clear why specific reference is made to the Planning Application at Barton in Fabis and the contribution this could make to future mineral supply? Current undetermined Applications at Langford and Bestwood are not referred to in the same context. It is considered that the Plan should provide factual information only at this stage, and the reference to Barton in Fabis specifically appears to give it a favourable status which is not appropriate in this context.
Plan 3 isn't very informative. It would benefit from major trunk roads being identified, major towns/growth areas labelling, and the Idle Valley showing.
Q9. Would it be more appropriate to prioritise specific areas above others?
The Locational strategy should be heavily influenced/focussed on known markets and by access to market and ease of access to the local highway network to transport mineral within and where necessary outside of the County.
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.
The difference between long distance barging to market and short distance/shuttle barging to processing plant requires a distinction.
Long Distance Barging to Market
It has not in recent years been economical to transport mineral by barge. The costs of loading / unloading and transportation are often significantly greater than conventional distribution to market by road, and is significantly less flexible to meet market demand. It is unlikely that sand and gravel operations will be developed based on barge transportation alone.
River barge transportation of sand and gravel from Besthorpe Quarry ceased in August 2013 as supply to the West Yorkshire market from North Yorkshire (including rail fed crushed rock) became more economic. The position may change in the medium to long term as supply scenarios change over time. Tarmac have therefore
retained the over wharf facility at Besthorpe in a mothballed state rather than removing the wharf facility altogether.
Short distance shuttle barging (to processing plant)
The costs of loading and unloading and provision of handling/ processing facilities significantly add to operating costs and shuttle barging over short distances are unlikely to be economic against traditional land based operations.
There may be opportunities for a shuttle barge transportation system to be adopted for working some sand and gravel resources where inadequate road access exists. Such a system may enable otherwise constrained mineral resources to be worked, but the viability does depend heavily on suitable mineral handling and processing facilities being available at the receiving end (particularly facilities for mineral processing , washing and silt disposal).
Sherwood Sandstone
Q11. Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?
The LAA recognises the high level of export to markets outside the County due to limited resources elsewhere. As per comments on sand and gravel, there is a need where resource exists to maintain production and operating capacity to meet demand. The Plan should identify appropriate extensions to existing operations or new sites to meet this demand. Identified demand based on sales is a minimum requirement of the Plan and it is considered there needs to be flexibility built into the Plan to allow sites to come forward. The plan should address anticipated demand from outside of the County.
The Plan should recognise the unique properties of the sand as well as markets. Colour variances as well as properties of the sand are also important factors and therefore additional reserves (as allocations or new sites) should not solely be based upon estimated demand based on sales figures.
Crushed Rock
The Plan should update the current position on Nether Langwith as Tarmac has obtained planning permission to extend the timescales for working and restoration.
It is likely that there is a wider demand for crushed rock within the County than that met by Nether Langwith. Crushed rock requirements are likely to be met from imports to meet the demand within the south of the County to minimise the distance crushed rock will need to travel.
Alternative Aggregates
Q14. Are you aware of any issues relating to alternative aggregates that should be considered through the minerals Local Plan review?
Support for the MPA in seeking the use of alternative aggregates and the appreciation that there are limits on how far alternatives can substitute primary aggregate. It is considered whilst support for alternative aggregate should be encouraged in the Plan, the contribution should be viewed as a 'bonus' over and above the required amount of primary aggregate. This is reflective of the NPPF (para
143) which states that local Plans should take account of the, 'contribution that substitute or secondary and recycled materials and minerals waste can make'. The reference made by the MPA to the reduction in ash materials from coal fired power stations is also likely to increase the demand for primary aggregate over the Plan period to address this specific resource shortfall. The approach to recycled aggregates reflects the Mineral Products Association Long Tern Aggregates Demand and Supply Scenarios Paper which indicates that the potential for recycling has reached an optimum level (approximately 28-30% volume).
Industrial Dolomite Provision
Q20. Are you aware if any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?
Reserves of industrial dolomite are of international importance. Whilst additional resource areas do not need to be identified as an allocation, the resource within Nottinghamshire should be identified within the Plan and recognised as a proven resource to be safeguarded.
Development Management Policies
Q25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
Yes agree that it covers all areas.
Minerals Safeguarding and Consultation Areas
Q26 Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?
It is considered that the Minerals Plan should define more specific Mineral Consultation Areas. The proposed approach to define consultation areas on the same scale as safeguarding areas could mean that large amounts of development will be caught within an MSA/MCA which would be onerous on developers having to potentially submit minerals assessments and the MPA in assessing the potential for impact of development on mineral resource/mineral associated infrastructure. This is contrary to the objectives of the NPPF paragraph 143. A criteria based approach to MCA's would be a more appropriate strategy. In addition Plan 7 would benefit from clearer distinction between areas of safeguarding. It is not clear where the alluvial sand and gravel is located.
As well as safeguarding mineral associated infrastructure, rail heads should be expanded to include rail heads at coal fired power stations. A wharf facility at Colwick is specifically referenced for safeguarding. Tarmac have existing wharf facilities which should also be referenced if this is the approach to be adopted by the MPA.
The importance of Local Plan's (District and Borough Council) in understanding and appreciating the role of safeguarding and defining areas/sites within Local Development Plan Documents should be explained within the Mineral Plan. The Planning system is a tiered system with the policies contained within the Mineral Plan and Local plan pertinent to the consideration of Planning Applications at County and District level. The MPA has an important role in ensuring mineral safeguarding is not perceived as just a County function but guiding and supporting Local Authorities to appreciate they also have a role to play in accordance with the Planning Practice Guidance.
Comment
Minerals Local Plan Issues and Options consultation
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?
Representation ID: 30662
Received: 10/01/2018
Respondent: Tarmac Ltd
The use of 10 years average does not accurately represent the 'local circumstance'. A decline in sales is not necessarily an indication of decline in demand. Whilst it is one consideration, the fact that the sales/supply picture within Nottinghamshire is so different from the rest of the East Midlands and the national picture indicates that the sales data alone is not a true reflection of current circumstances.
Issues and Options Paper
Section 2 - Setting the overall Context for the Plan
Q1 - Do you think any further information should be included in the overview of the area?
Yes. It is considered that the cross boundary relationship with neighbouring authorities should be identified taking into account:
1. cross boundary mineral supply from Nottinghamshire - eg to South Yorkshire, and Leicestershire in light of their identified lack of available sand and gravel resources and production capacity to meet demand over the Plan period
2. The lack of available crushed rock/limestone resource within the County and therefore the heavy reliance on import from adjoining Authority areas
3. The availability of infrastructure links - particularly good road network and therefore links to market in assisting to secure mineral supply
4. The overlap of housing, business, infrastructure and employment links with Derbyshire and Leicestershire are identified but there is currently no reference to an overlap of mineral supply issues
5. The relationship with other mineral authorities and duty to cooperate in Plan preparation should be referenced
6. The anticipated development needs for housing, employment and infrastructure provision (including HS2)
Q2 Do you agree with the Draft Vision? Are there other things that we should include?
In general terms we would support the Draft Vision. However, it is considered there are two important issues missing. Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF which states, 'Mineral Planning Authorities should plan for a steady and adequate supply of aggregates by making provision for the maintenance of landbank.... whilst ensuring that the capacity of operations to supply a wide range of materials is not compromised'. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources. Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.
Q3 Are the above strategic issues appropriate? Are there others we should consider?
Key Strategic Issue 1 and a locational strategy to securing mineral supply is supported. This approach maintains the spread of operations across the County and maintains a security in supply to the specific markets that these serve.
The principle of Key Strategic Issue 2 is supported. However, as referred above, the Plan should identify the anticipated demand from adjoining Authority areas.
We do not agree with Strategic Issue 4 and a 'Biodiversity led restoration' approach to all mineral operations. This is not always appropriate when balancing the needs of
the landowner and long term economic value of land post restoration. Biodiversity improvements should be sought 'where possible'. The Council's vision should adopt a more balanced stance in respect of the restoration of mineral sites taking account of the three elements of sustainability set out in the NPPF (e.g. economic, social and environmental). Tarmac do however support the vision for creating landscape-scale biodiversity resources as part of stakeholder co-ordinated initiatives (ie The RSPB Bigger Better Vision for the Trent Valley area north of Newark). This should be referred to in the strategy.
Strategic Issue 4 should also consider the opportunities which mineral extraction creates for the deposit of inert infill as part of delivering agricultural restoration in helping to meet the need for inert waste disposal in Nottinghamshire.
Minerals Provision
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.
No it is not considered that the 10 years average sales figures are the most suitable methodology for forecasting aggregate demand. National Policy states, forecasts of demand should be based on a rolling average of 10 years sales data, other relevant information and through assessment of all other supply options. The 10 years average sales are heavily influenced by the impact of the recession. In addition, the movement of production at Finningley outside the County boundary has effectively skewed the perceived sales/demand. This is particularly apparent given the picture across the East Midlands which in all other cases have seen increases in sales figures. Whilst, recycled and secondary aggregate has a role to play in meeting demand in some circumstances it cannot be relied upon for ensuring continuity in supply. In addition given the location of the County it is unlikely that demand can be met from other sources (for example marine). In light of this, the other relevant local information is particularly important in forecasting future demand in the County. We support the MPA in their previous approach which reviewed sales data pre and post- recession to give a greater appreciation of likely anticipated demand in recession and a period of economic growth.
As we have referred to above, the operational capacity of permitted operations within the County needs consideration to ensure that anticipated demand is met. A
decline in sales is not necessarily an indication of a decline in demand. Production moving outside of the County will impact upon perceived sales figures as well as sites/resource not being replaced when exhausted.
A Delivery schedule (as per previous MLP drafts) would be helpful in ensuring that sites are allocated to cover the whole Plan period. Although the landbank is sufficient at the start of the Plan period, sites will become exhausted during the Plan period and provision should be made for replacements. Tarmac have produced their own delivery schedule (enclosed with this submission) to illustrate the timescales for known reserves becoming available during the Plan period.
The Issues and Options paper states, the decline in Nottinghamshire sales of sand and gravel is a result of the, 'minerals industry focusing on existing quarries outside the County and the lack of investment in new greenfield quarries in Nottinghamshire even though adequate sand and gravel resources remain'. This statement is not substantiated or evidenced. The 9 years of public consultation (between 2008 and 2017) eventually leading to the withdrawn Nottinghamshire Draft Plan has not created a positive or stable platform for industry investment. There are numerous existing operations with logical and feasible extensions, a number of which have previously been promoted to the previous Mineral Local Plan process as well as new greenfield reserves which have been subject to Scoping Requests with the Mineral Planning Authority. Notwithstanding this, significant investment (both financial and time) is required in pre-planning processes in obtaining baseline environmental assessment work to support a planning application. The Mineral industry is only recently seeing increases in sales post-recession which provides the security/assurance in making significant financial investment to existing and new operations. In addition, it is the market factors that dictate where operations would be best placed to serve the local needs.
The Plan should not focus or specify a definitive/maximum amount of mineral provision. The sales data is an indication of demand and should not be perceived as a maximum requirement. The Plan needs to provide flexibility to support additional sites/resources coming forward during the Plan period to meet demand/operational requirements to serve existing/future markets.
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?
As above, the use of 10 years average does not accurately represent the 'local circumstance'. A decline in sales is not necessarily an indication of decline in demand. Whilst it is one consideration, the fact that the sales/supply picture within Nottinghamshire is so different from the rest of the East Midlands and the national picture indicates that the sales data alone is not a true reflection of current circumstances.
Strategic Approach to New Mineral Development
Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
There needs to be allowance in the Plan for both extensions and new greenfield sites. The NPPF removed previous planning policy preference for extensions to existing operations. As a result, emerging policy should not give preference to extensions in order to be compliant with national policy. However, as we have previously stated, the Plan should provide flexibility and policy should be supportive in securing extensions to existing operations, this ensures a continuation in supply without sterilising mineral reserves. However, operational capacity constraints still apply (imposed by plant capacity or planning conditions which limit tonnages/production) which can limit the amount of resource available to meet demand and therefore there may be a requirement for green field sites in addition to extensions. It is considered that a more sustainable strategy would be a locational strategy which shows allocations and preferred areas of working for new sites in each of the three main areas for sand and gravel working (Trent Valley, north of Newark and the Idle Valley) to ensure there are sufficient operations in place to meet demand, particularly relevant where there is evidence of sand and gravel resource, reserve and production capacity decline in adjoining authority areas.
Sand and gravel provision
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 market.
It is considered that a geographical spread of sand and gravel operations is a sustainable strategy and Tarmac support this approach. These areas have historical supply markets/area demand which has not changed - i.e major growth areas which will still be providing housing, employment, infrastructure etc remain. In addition, a
number of operations spread within a locality will also ensure the continuity/maintenance of supply in the event of operational constraint or in the event of a site having to shut down/cease operating.
It is not clear why specific reference is made to the Planning Application at Barton in Fabis and the contribution this could make to future mineral supply? Current undetermined Applications at Langford and Bestwood are not referred to in the same context. It is considered that the Plan should provide factual information only at this stage, and the reference to Barton in Fabis specifically appears to give it a favourable status which is not appropriate in this context.
Plan 3 isn't very informative. It would benefit from major trunk roads being identified, major towns/growth areas labelling, and the Idle Valley showing.
Q9. Would it be more appropriate to prioritise specific areas above others?
The Locational strategy should be heavily influenced/focussed on known markets and by access to market and ease of access to the local highway network to transport mineral within and where necessary outside of the County.
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.
The difference between long distance barging to market and short distance/shuttle barging to processing plant requires a distinction.
Long Distance Barging to Market
It has not in recent years been economical to transport mineral by barge. The costs of loading / unloading and transportation are often significantly greater than conventional distribution to market by road, and is significantly less flexible to meet market demand. It is unlikely that sand and gravel operations will be developed based on barge transportation alone.
River barge transportation of sand and gravel from Besthorpe Quarry ceased in August 2013 as supply to the West Yorkshire market from North Yorkshire (including rail fed crushed rock) became more economic. The position may change in the medium to long term as supply scenarios change over time. Tarmac have therefore
retained the over wharf facility at Besthorpe in a mothballed state rather than removing the wharf facility altogether.
Short distance shuttle barging (to processing plant)
The costs of loading and unloading and provision of handling/ processing facilities significantly add to operating costs and shuttle barging over short distances are unlikely to be economic against traditional land based operations.
There may be opportunities for a shuttle barge transportation system to be adopted for working some sand and gravel resources where inadequate road access exists. Such a system may enable otherwise constrained mineral resources to be worked, but the viability does depend heavily on suitable mineral handling and processing facilities being available at the receiving end (particularly facilities for mineral processing , washing and silt disposal).
Sherwood Sandstone
Q11. Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?
The LAA recognises the high level of export to markets outside the County due to limited resources elsewhere. As per comments on sand and gravel, there is a need where resource exists to maintain production and operating capacity to meet demand. The Plan should identify appropriate extensions to existing operations or new sites to meet this demand. Identified demand based on sales is a minimum requirement of the Plan and it is considered there needs to be flexibility built into the Plan to allow sites to come forward. The plan should address anticipated demand from outside of the County.
The Plan should recognise the unique properties of the sand as well as markets. Colour variances as well as properties of the sand are also important factors and therefore additional reserves (as allocations or new sites) should not solely be based upon estimated demand based on sales figures.
Crushed Rock
The Plan should update the current position on Nether Langwith as Tarmac has obtained planning permission to extend the timescales for working and restoration.
It is likely that there is a wider demand for crushed rock within the County than that met by Nether Langwith. Crushed rock requirements are likely to be met from imports to meet the demand within the south of the County to minimise the distance crushed rock will need to travel.
Alternative Aggregates
Q14. Are you aware of any issues relating to alternative aggregates that should be considered through the minerals Local Plan review?
Support for the MPA in seeking the use of alternative aggregates and the appreciation that there are limits on how far alternatives can substitute primary aggregate. It is considered whilst support for alternative aggregate should be encouraged in the Plan, the contribution should be viewed as a 'bonus' over and above the required amount of primary aggregate. This is reflective of the NPPF (para
143) which states that local Plans should take account of the, 'contribution that substitute or secondary and recycled materials and minerals waste can make'. The reference made by the MPA to the reduction in ash materials from coal fired power stations is also likely to increase the demand for primary aggregate over the Plan period to address this specific resource shortfall. The approach to recycled aggregates reflects the Mineral Products Association Long Tern Aggregates Demand and Supply Scenarios Paper which indicates that the potential for recycling has reached an optimum level (approximately 28-30% volume).
Industrial Dolomite Provision
Q20. Are you aware if any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?
Reserves of industrial dolomite are of international importance. Whilst additional resource areas do not need to be identified as an allocation, the resource within Nottinghamshire should be identified within the Plan and recognised as a proven resource to be safeguarded.
Development Management Policies
Q25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
Yes agree that it covers all areas.
Minerals Safeguarding and Consultation Areas
Q26 Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?
It is considered that the Minerals Plan should define more specific Mineral Consultation Areas. The proposed approach to define consultation areas on the same scale as safeguarding areas could mean that large amounts of development will be caught within an MSA/MCA which would be onerous on developers having to potentially submit minerals assessments and the MPA in assessing the potential for impact of development on mineral resource/mineral associated infrastructure. This is contrary to the objectives of the NPPF paragraph 143. A criteria based approach to MCA's would be a more appropriate strategy. In addition Plan 7 would benefit from clearer distinction between areas of safeguarding. It is not clear where the alluvial sand and gravel is located.
As well as safeguarding mineral associated infrastructure, rail heads should be expanded to include rail heads at coal fired power stations. A wharf facility at Colwick is specifically referenced for safeguarding. Tarmac have existing wharf facilities which should also be referenced if this is the approach to be adopted by the MPA.
The importance of Local Plan's (District and Borough Council) in understanding and appreciating the role of safeguarding and defining areas/sites within Local Development Plan Documents should be explained within the Mineral Plan. The Planning system is a tiered system with the policies contained within the Mineral Plan and Local plan pertinent to the consideration of Planning Applications at County and District level. The MPA has an important role in ensuring mineral safeguarding is not perceived as just a County function but guiding and supporting Local Authorities to appreciate they also have a role to play in accordance with the Planning Practice Guidance.
Comment
Minerals Local Plan Issues and Options consultation
Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries
Representation ID: 30663
Received: 10/01/2018
Respondent: Tarmac Ltd
There needs to be allowance in the Plan for both extensions and new greenfield sites. However, as we have previously stated, the Plan should provide flexibility and policy should be supportive in securing extensions to existing operations, this ensures a continuation in supply without sterilising mineral reserves. However, operational capacity constraints still apply which can limit the amount of resource available to meet demand. A more sustainable strategy would be a locational strategy which shows allocations and preferred areas of working for new sites in each of the three main areas for sand and gravel working to ensure there are sufficient operations in place to meet demand.
Issues and Options Paper
Section 2 - Setting the overall Context for the Plan
Q1 - Do you think any further information should be included in the overview of the area?
Yes. It is considered that the cross boundary relationship with neighbouring authorities should be identified taking into account:
1. cross boundary mineral supply from Nottinghamshire - eg to South Yorkshire, and Leicestershire in light of their identified lack of available sand and gravel resources and production capacity to meet demand over the Plan period
2. The lack of available crushed rock/limestone resource within the County and therefore the heavy reliance on import from adjoining Authority areas
3. The availability of infrastructure links - particularly good road network and therefore links to market in assisting to secure mineral supply
4. The overlap of housing, business, infrastructure and employment links with Derbyshire and Leicestershire are identified but there is currently no reference to an overlap of mineral supply issues
5. The relationship with other mineral authorities and duty to cooperate in Plan preparation should be referenced
6. The anticipated development needs for housing, employment and infrastructure provision (including HS2)
Q2 Do you agree with the Draft Vision? Are there other things that we should include?
In general terms we would support the Draft Vision. However, it is considered there are two important issues missing. Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF which states, 'Mineral Planning Authorities should plan for a steady and adequate supply of aggregates by making provision for the maintenance of landbank.... whilst ensuring that the capacity of operations to supply a wide range of materials is not compromised'. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources. Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.
Q3 Are the above strategic issues appropriate? Are there others we should consider?
Key Strategic Issue 1 and a locational strategy to securing mineral supply is supported. This approach maintains the spread of operations across the County and maintains a security in supply to the specific markets that these serve.
The principle of Key Strategic Issue 2 is supported. However, as referred above, the Plan should identify the anticipated demand from adjoining Authority areas.
We do not agree with Strategic Issue 4 and a 'Biodiversity led restoration' approach to all mineral operations. This is not always appropriate when balancing the needs of
the landowner and long term economic value of land post restoration. Biodiversity improvements should be sought 'where possible'. The Council's vision should adopt a more balanced stance in respect of the restoration of mineral sites taking account of the three elements of sustainability set out in the NPPF (e.g. economic, social and environmental). Tarmac do however support the vision for creating landscape-scale biodiversity resources as part of stakeholder co-ordinated initiatives (ie The RSPB Bigger Better Vision for the Trent Valley area north of Newark). This should be referred to in the strategy.
Strategic Issue 4 should also consider the opportunities which mineral extraction creates for the deposit of inert infill as part of delivering agricultural restoration in helping to meet the need for inert waste disposal in Nottinghamshire.
Minerals Provision
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.
No it is not considered that the 10 years average sales figures are the most suitable methodology for forecasting aggregate demand. National Policy states, forecasts of demand should be based on a rolling average of 10 years sales data, other relevant information and through assessment of all other supply options. The 10 years average sales are heavily influenced by the impact of the recession. In addition, the movement of production at Finningley outside the County boundary has effectively skewed the perceived sales/demand. This is particularly apparent given the picture across the East Midlands which in all other cases have seen increases in sales figures. Whilst, recycled and secondary aggregate has a role to play in meeting demand in some circumstances it cannot be relied upon for ensuring continuity in supply. In addition given the location of the County it is unlikely that demand can be met from other sources (for example marine). In light of this, the other relevant local information is particularly important in forecasting future demand in the County. We support the MPA in their previous approach which reviewed sales data pre and post- recession to give a greater appreciation of likely anticipated demand in recession and a period of economic growth.
As we have referred to above, the operational capacity of permitted operations within the County needs consideration to ensure that anticipated demand is met. A
decline in sales is not necessarily an indication of a decline in demand. Production moving outside of the County will impact upon perceived sales figures as well as sites/resource not being replaced when exhausted.
A Delivery schedule (as per previous MLP drafts) would be helpful in ensuring that sites are allocated to cover the whole Plan period. Although the landbank is sufficient at the start of the Plan period, sites will become exhausted during the Plan period and provision should be made for replacements. Tarmac have produced their own delivery schedule (enclosed with this submission) to illustrate the timescales for known reserves becoming available during the Plan period.
The Issues and Options paper states, the decline in Nottinghamshire sales of sand and gravel is a result of the, 'minerals industry focusing on existing quarries outside the County and the lack of investment in new greenfield quarries in Nottinghamshire even though adequate sand and gravel resources remain'. This statement is not substantiated or evidenced. The 9 years of public consultation (between 2008 and 2017) eventually leading to the withdrawn Nottinghamshire Draft Plan has not created a positive or stable platform for industry investment. There are numerous existing operations with logical and feasible extensions, a number of which have previously been promoted to the previous Mineral Local Plan process as well as new greenfield reserves which have been subject to Scoping Requests with the Mineral Planning Authority. Notwithstanding this, significant investment (both financial and time) is required in pre-planning processes in obtaining baseline environmental assessment work to support a planning application. The Mineral industry is only recently seeing increases in sales post-recession which provides the security/assurance in making significant financial investment to existing and new operations. In addition, it is the market factors that dictate where operations would be best placed to serve the local needs.
The Plan should not focus or specify a definitive/maximum amount of mineral provision. The sales data is an indication of demand and should not be perceived as a maximum requirement. The Plan needs to provide flexibility to support additional sites/resources coming forward during the Plan period to meet demand/operational requirements to serve existing/future markets.
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?
As above, the use of 10 years average does not accurately represent the 'local circumstance'. A decline in sales is not necessarily an indication of decline in demand. Whilst it is one consideration, the fact that the sales/supply picture within Nottinghamshire is so different from the rest of the East Midlands and the national picture indicates that the sales data alone is not a true reflection of current circumstances.
Strategic Approach to New Mineral Development
Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
There needs to be allowance in the Plan for both extensions and new greenfield sites. The NPPF removed previous planning policy preference for extensions to existing operations. As a result, emerging policy should not give preference to extensions in order to be compliant with national policy. However, as we have previously stated, the Plan should provide flexibility and policy should be supportive in securing extensions to existing operations, this ensures a continuation in supply without sterilising mineral reserves. However, operational capacity constraints still apply (imposed by plant capacity or planning conditions which limit tonnages/production) which can limit the amount of resource available to meet demand and therefore there may be a requirement for green field sites in addition to extensions. It is considered that a more sustainable strategy would be a locational strategy which shows allocations and preferred areas of working for new sites in each of the three main areas for sand and gravel working (Trent Valley, north of Newark and the Idle Valley) to ensure there are sufficient operations in place to meet demand, particularly relevant where there is evidence of sand and gravel resource, reserve and production capacity decline in adjoining authority areas.
Sand and gravel provision
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 market.
It is considered that a geographical spread of sand and gravel operations is a sustainable strategy and Tarmac support this approach. These areas have historical supply markets/area demand which has not changed - i.e major growth areas which will still be providing housing, employment, infrastructure etc remain. In addition, a
number of operations spread within a locality will also ensure the continuity/maintenance of supply in the event of operational constraint or in the event of a site having to shut down/cease operating.
It is not clear why specific reference is made to the Planning Application at Barton in Fabis and the contribution this could make to future mineral supply? Current undetermined Applications at Langford and Bestwood are not referred to in the same context. It is considered that the Plan should provide factual information only at this stage, and the reference to Barton in Fabis specifically appears to give it a favourable status which is not appropriate in this context.
Plan 3 isn't very informative. It would benefit from major trunk roads being identified, major towns/growth areas labelling, and the Idle Valley showing.
Q9. Would it be more appropriate to prioritise specific areas above others?
The Locational strategy should be heavily influenced/focussed on known markets and by access to market and ease of access to the local highway network to transport mineral within and where necessary outside of the County.
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.
The difference between long distance barging to market and short distance/shuttle barging to processing plant requires a distinction.
Long Distance Barging to Market
It has not in recent years been economical to transport mineral by barge. The costs of loading / unloading and transportation are often significantly greater than conventional distribution to market by road, and is significantly less flexible to meet market demand. It is unlikely that sand and gravel operations will be developed based on barge transportation alone.
River barge transportation of sand and gravel from Besthorpe Quarry ceased in August 2013 as supply to the West Yorkshire market from North Yorkshire (including rail fed crushed rock) became more economic. The position may change in the medium to long term as supply scenarios change over time. Tarmac have therefore
retained the over wharf facility at Besthorpe in a mothballed state rather than removing the wharf facility altogether.
Short distance shuttle barging (to processing plant)
The costs of loading and unloading and provision of handling/ processing facilities significantly add to operating costs and shuttle barging over short distances are unlikely to be economic against traditional land based operations.
There may be opportunities for a shuttle barge transportation system to be adopted for working some sand and gravel resources where inadequate road access exists. Such a system may enable otherwise constrained mineral resources to be worked, but the viability does depend heavily on suitable mineral handling and processing facilities being available at the receiving end (particularly facilities for mineral processing , washing and silt disposal).
Sherwood Sandstone
Q11. Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?
The LAA recognises the high level of export to markets outside the County due to limited resources elsewhere. As per comments on sand and gravel, there is a need where resource exists to maintain production and operating capacity to meet demand. The Plan should identify appropriate extensions to existing operations or new sites to meet this demand. Identified demand based on sales is a minimum requirement of the Plan and it is considered there needs to be flexibility built into the Plan to allow sites to come forward. The plan should address anticipated demand from outside of the County.
The Plan should recognise the unique properties of the sand as well as markets. Colour variances as well as properties of the sand are also important factors and therefore additional reserves (as allocations or new sites) should not solely be based upon estimated demand based on sales figures.
Crushed Rock
The Plan should update the current position on Nether Langwith as Tarmac has obtained planning permission to extend the timescales for working and restoration.
It is likely that there is a wider demand for crushed rock within the County than that met by Nether Langwith. Crushed rock requirements are likely to be met from imports to meet the demand within the south of the County to minimise the distance crushed rock will need to travel.
Alternative Aggregates
Q14. Are you aware of any issues relating to alternative aggregates that should be considered through the minerals Local Plan review?
Support for the MPA in seeking the use of alternative aggregates and the appreciation that there are limits on how far alternatives can substitute primary aggregate. It is considered whilst support for alternative aggregate should be encouraged in the Plan, the contribution should be viewed as a 'bonus' over and above the required amount of primary aggregate. This is reflective of the NPPF (para
143) which states that local Plans should take account of the, 'contribution that substitute or secondary and recycled materials and minerals waste can make'. The reference made by the MPA to the reduction in ash materials from coal fired power stations is also likely to increase the demand for primary aggregate over the Plan period to address this specific resource shortfall. The approach to recycled aggregates reflects the Mineral Products Association Long Tern Aggregates Demand and Supply Scenarios Paper which indicates that the potential for recycling has reached an optimum level (approximately 28-30% volume).
Industrial Dolomite Provision
Q20. Are you aware if any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?
Reserves of industrial dolomite are of international importance. Whilst additional resource areas do not need to be identified as an allocation, the resource within Nottinghamshire should be identified within the Plan and recognised as a proven resource to be safeguarded.
Development Management Policies
Q25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
Yes agree that it covers all areas.
Minerals Safeguarding and Consultation Areas
Q26 Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?
It is considered that the Minerals Plan should define more specific Mineral Consultation Areas. The proposed approach to define consultation areas on the same scale as safeguarding areas could mean that large amounts of development will be caught within an MSA/MCA which would be onerous on developers having to potentially submit minerals assessments and the MPA in assessing the potential for impact of development on mineral resource/mineral associated infrastructure. This is contrary to the objectives of the NPPF paragraph 143. A criteria based approach to MCA's would be a more appropriate strategy. In addition Plan 7 would benefit from clearer distinction between areas of safeguarding. It is not clear where the alluvial sand and gravel is located.
As well as safeguarding mineral associated infrastructure, rail heads should be expanded to include rail heads at coal fired power stations. A wharf facility at Colwick is specifically referenced for safeguarding. Tarmac have existing wharf facilities which should also be referenced if this is the approach to be adopted by the MPA.
The importance of Local Plan's (District and Borough Council) in understanding and appreciating the role of safeguarding and defining areas/sites within Local Development Plan Documents should be explained within the Mineral Plan. The Planning system is a tiered system with the policies contained within the Mineral Plan and Local plan pertinent to the consideration of Planning Applications at County and District level. The MPA has an important role in ensuring mineral safeguarding is not perceived as just a County function but guiding and supporting Local Authorities to appreciate they also have a role to play in accordance with the Planning Practice Guidance.
Comment
Minerals Local Plan Issues and Options consultation
Q9 Would it be more appropriate to prioritise specific areas above others?
Representation ID: 30664
Received: 10/01/2018
Respondent: Tarmac Ltd
The Locational strategy should be heavily influenced/focussed on known markets and by access to market and ease of access to the local highway network to transport mineral within and where necessary outside of the County.
Issues and Options Paper
Section 2 - Setting the overall Context for the Plan
Q1 - Do you think any further information should be included in the overview of the area?
Yes. It is considered that the cross boundary relationship with neighbouring authorities should be identified taking into account:
1. cross boundary mineral supply from Nottinghamshire - eg to South Yorkshire, and Leicestershire in light of their identified lack of available sand and gravel resources and production capacity to meet demand over the Plan period
2. The lack of available crushed rock/limestone resource within the County and therefore the heavy reliance on import from adjoining Authority areas
3. The availability of infrastructure links - particularly good road network and therefore links to market in assisting to secure mineral supply
4. The overlap of housing, business, infrastructure and employment links with Derbyshire and Leicestershire are identified but there is currently no reference to an overlap of mineral supply issues
5. The relationship with other mineral authorities and duty to cooperate in Plan preparation should be referenced
6. The anticipated development needs for housing, employment and infrastructure provision (including HS2)
Q2 Do you agree with the Draft Vision? Are there other things that we should include?
In general terms we would support the Draft Vision. However, it is considered there are two important issues missing. Firstly, as well as the identification of sites/resources to maintain landbanks and support the objectively assessed development needs/demand, the Plan should ensure that there is sufficient operational capacity to maintain the demand in accordance with paragraph 145 of the NPPF which states, 'Mineral Planning Authorities should plan for a steady and adequate supply of aggregates by making provision for the maintenance of landbank.... whilst ensuring that the capacity of operations to supply a wide range of materials is not compromised'. This should include the assessed needs of adjacent Authority areas which may place added pressure on Nottinghamshire resources. Secondly, as well as safeguarding mineral resource, in accordance with the NPPF the Plan should safeguard mineral associated infrastructure.
Q3 Are the above strategic issues appropriate? Are there others we should consider?
Key Strategic Issue 1 and a locational strategy to securing mineral supply is supported. This approach maintains the spread of operations across the County and maintains a security in supply to the specific markets that these serve.
The principle of Key Strategic Issue 2 is supported. However, as referred above, the Plan should identify the anticipated demand from adjoining Authority areas.
We do not agree with Strategic Issue 4 and a 'Biodiversity led restoration' approach to all mineral operations. This is not always appropriate when balancing the needs of
the landowner and long term economic value of land post restoration. Biodiversity improvements should be sought 'where possible'. The Council's vision should adopt a more balanced stance in respect of the restoration of mineral sites taking account of the three elements of sustainability set out in the NPPF (e.g. economic, social and environmental). Tarmac do however support the vision for creating landscape-scale biodiversity resources as part of stakeholder co-ordinated initiatives (ie The RSPB Bigger Better Vision for the Trent Valley area north of Newark). This should be referred to in the strategy.
Strategic Issue 4 should also consider the opportunities which mineral extraction creates for the deposit of inert infill as part of delivering agricultural restoration in helping to meet the need for inert waste disposal in Nottinghamshire.
Minerals Provision
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.
No it is not considered that the 10 years average sales figures are the most suitable methodology for forecasting aggregate demand. National Policy states, forecasts of demand should be based on a rolling average of 10 years sales data, other relevant information and through assessment of all other supply options. The 10 years average sales are heavily influenced by the impact of the recession. In addition, the movement of production at Finningley outside the County boundary has effectively skewed the perceived sales/demand. This is particularly apparent given the picture across the East Midlands which in all other cases have seen increases in sales figures. Whilst, recycled and secondary aggregate has a role to play in meeting demand in some circumstances it cannot be relied upon for ensuring continuity in supply. In addition given the location of the County it is unlikely that demand can be met from other sources (for example marine). In light of this, the other relevant local information is particularly important in forecasting future demand in the County. We support the MPA in their previous approach which reviewed sales data pre and post- recession to give a greater appreciation of likely anticipated demand in recession and a period of economic growth.
As we have referred to above, the operational capacity of permitted operations within the County needs consideration to ensure that anticipated demand is met. A
decline in sales is not necessarily an indication of a decline in demand. Production moving outside of the County will impact upon perceived sales figures as well as sites/resource not being replaced when exhausted.
A Delivery schedule (as per previous MLP drafts) would be helpful in ensuring that sites are allocated to cover the whole Plan period. Although the landbank is sufficient at the start of the Plan period, sites will become exhausted during the Plan period and provision should be made for replacements. Tarmac have produced their own delivery schedule (enclosed with this submission) to illustrate the timescales for known reserves becoming available during the Plan period.
The Issues and Options paper states, the decline in Nottinghamshire sales of sand and gravel is a result of the, 'minerals industry focusing on existing quarries outside the County and the lack of investment in new greenfield quarries in Nottinghamshire even though adequate sand and gravel resources remain'. This statement is not substantiated or evidenced. The 9 years of public consultation (between 2008 and 2017) eventually leading to the withdrawn Nottinghamshire Draft Plan has not created a positive or stable platform for industry investment. There are numerous existing operations with logical and feasible extensions, a number of which have previously been promoted to the previous Mineral Local Plan process as well as new greenfield reserves which have been subject to Scoping Requests with the Mineral Planning Authority. Notwithstanding this, significant investment (both financial and time) is required in pre-planning processes in obtaining baseline environmental assessment work to support a planning application. The Mineral industry is only recently seeing increases in sales post-recession which provides the security/assurance in making significant financial investment to existing and new operations. In addition, it is the market factors that dictate where operations would be best placed to serve the local needs.
The Plan should not focus or specify a definitive/maximum amount of mineral provision. The sales data is an indication of demand and should not be perceived as a maximum requirement. The Plan needs to provide flexibility to support additional sites/resources coming forward during the Plan period to meet demand/operational requirements to serve existing/future markets.
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?
As above, the use of 10 years average does not accurately represent the 'local circumstance'. A decline in sales is not necessarily an indication of decline in demand. Whilst it is one consideration, the fact that the sales/supply picture within Nottinghamshire is so different from the rest of the East Midlands and the national picture indicates that the sales data alone is not a true reflection of current circumstances.
Strategic Approach to New Mineral Development
Q6 Do you think extensions to existing permitted quarries should be prioritised over new greenfield quarries?
There needs to be allowance in the Plan for both extensions and new greenfield sites. The NPPF removed previous planning policy preference for extensions to existing operations. As a result, emerging policy should not give preference to extensions in order to be compliant with national policy. However, as we have previously stated, the Plan should provide flexibility and policy should be supportive in securing extensions to existing operations, this ensures a continuation in supply without sterilising mineral reserves. However, operational capacity constraints still apply (imposed by plant capacity or planning conditions which limit tonnages/production) which can limit the amount of resource available to meet demand and therefore there may be a requirement for green field sites in addition to extensions. It is considered that a more sustainable strategy would be a locational strategy which shows allocations and preferred areas of working for new sites in each of the three main areas for sand and gravel working (Trent Valley, north of Newark and the Idle Valley) to ensure there are sufficient operations in place to meet demand, particularly relevant where there is evidence of sand and gravel resource, reserve and production capacity decline in adjoining authority areas.
Sand and gravel provision
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 market.
It is considered that a geographical spread of sand and gravel operations is a sustainable strategy and Tarmac support this approach. These areas have historical supply markets/area demand which has not changed - i.e major growth areas which will still be providing housing, employment, infrastructure etc remain. In addition, a
number of operations spread within a locality will also ensure the continuity/maintenance of supply in the event of operational constraint or in the event of a site having to shut down/cease operating.
It is not clear why specific reference is made to the Planning Application at Barton in Fabis and the contribution this could make to future mineral supply? Current undetermined Applications at Langford and Bestwood are not referred to in the same context. It is considered that the Plan should provide factual information only at this stage, and the reference to Barton in Fabis specifically appears to give it a favourable status which is not appropriate in this context.
Plan 3 isn't very informative. It would benefit from major trunk roads being identified, major towns/growth areas labelling, and the Idle Valley showing.
Q9. Would it be more appropriate to prioritise specific areas above others?
The Locational strategy should be heavily influenced/focussed on known markets and by access to market and ease of access to the local highway network to transport mineral within and where necessary outside of the County.
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.
The difference between long distance barging to market and short distance/shuttle barging to processing plant requires a distinction.
Long Distance Barging to Market
It has not in recent years been economical to transport mineral by barge. The costs of loading / unloading and transportation are often significantly greater than conventional distribution to market by road, and is significantly less flexible to meet market demand. It is unlikely that sand and gravel operations will be developed based on barge transportation alone.
River barge transportation of sand and gravel from Besthorpe Quarry ceased in August 2013 as supply to the West Yorkshire market from North Yorkshire (including rail fed crushed rock) became more economic. The position may change in the medium to long term as supply scenarios change over time. Tarmac have therefore
retained the over wharf facility at Besthorpe in a mothballed state rather than removing the wharf facility altogether.
Short distance shuttle barging (to processing plant)
The costs of loading and unloading and provision of handling/ processing facilities significantly add to operating costs and shuttle barging over short distances are unlikely to be economic against traditional land based operations.
There may be opportunities for a shuttle barge transportation system to be adopted for working some sand and gravel resources where inadequate road access exists. Such a system may enable otherwise constrained mineral resources to be worked, but the viability does depend heavily on suitable mineral handling and processing facilities being available at the receiving end (particularly facilities for mineral processing , washing and silt disposal).
Sherwood Sandstone
Q11. Are you aware of any other issues relating to Sherwood Sandstone provision that should be considered through the Minerals Local Plan review?
The LAA recognises the high level of export to markets outside the County due to limited resources elsewhere. As per comments on sand and gravel, there is a need where resource exists to maintain production and operating capacity to meet demand. The Plan should identify appropriate extensions to existing operations or new sites to meet this demand. Identified demand based on sales is a minimum requirement of the Plan and it is considered there needs to be flexibility built into the Plan to allow sites to come forward. The plan should address anticipated demand from outside of the County.
The Plan should recognise the unique properties of the sand as well as markets. Colour variances as well as properties of the sand are also important factors and therefore additional reserves (as allocations or new sites) should not solely be based upon estimated demand based on sales figures.
Crushed Rock
The Plan should update the current position on Nether Langwith as Tarmac has obtained planning permission to extend the timescales for working and restoration.
It is likely that there is a wider demand for crushed rock within the County than that met by Nether Langwith. Crushed rock requirements are likely to be met from imports to meet the demand within the south of the County to minimise the distance crushed rock will need to travel.
Alternative Aggregates
Q14. Are you aware of any issues relating to alternative aggregates that should be considered through the minerals Local Plan review?
Support for the MPA in seeking the use of alternative aggregates and the appreciation that there are limits on how far alternatives can substitute primary aggregate. It is considered whilst support for alternative aggregate should be encouraged in the Plan, the contribution should be viewed as a 'bonus' over and above the required amount of primary aggregate. This is reflective of the NPPF (para
143) which states that local Plans should take account of the, 'contribution that substitute or secondary and recycled materials and minerals waste can make'. The reference made by the MPA to the reduction in ash materials from coal fired power stations is also likely to increase the demand for primary aggregate over the Plan period to address this specific resource shortfall. The approach to recycled aggregates reflects the Mineral Products Association Long Tern Aggregates Demand and Supply Scenarios Paper which indicates that the potential for recycling has reached an optimum level (approximately 28-30% volume).
Industrial Dolomite Provision
Q20. Are you aware if any issues regarding the provision of industrial dolomite that should be considered as part of the Minerals Local Plan review?
Reserves of industrial dolomite are of international importance. Whilst additional resource areas do not need to be identified as an allocation, the resource within Nottinghamshire should be identified within the Plan and recognised as a proven resource to be safeguarded.
Development Management Policies
Q25. Do you agree with the proposed development management policy areas? Are there any others that should be covered?
Yes agree that it covers all areas.
Minerals Safeguarding and Consultation Areas
Q26 Are you aware of any issues relating to minerals safeguarding that should be considered through the Minerals Local Plan review?
It is considered that the Minerals Plan should define more specific Mineral Consultation Areas. The proposed approach to define consultation areas on the same scale as safeguarding areas could mean that large amounts of development will be caught within an MSA/MCA which would be onerous on developers having to potentially submit minerals assessments and the MPA in assessing the potential for impact of development on mineral resource/mineral associated infrastructure. This is contrary to the objectives of the NPPF paragraph 143. A criteria based approach to MCA's would be a more appropriate strategy. In addition Plan 7 would benefit from clearer distinction between areas of safeguarding. It is not clear where the alluvial sand and gravel is located.
As well as safeguarding mineral associated infrastructure, rail heads should be expanded to include rail heads at coal fired power stations. A wharf facility at Colwick is specifically referenced for safeguarding. Tarmac have existing wharf facilities which should also be referenced if this is the approach to be adopted by the MPA.
The importance of Local Plan's (District and Borough Council) in understanding and appreciating the role of safeguarding and defining areas/sites within Local Development Plan Documents should be explained within the Mineral Plan. The Planning system is a tiered system with the policies contained within the Mineral Plan and Local plan pertinent to the consideration of Planning Applications at County and District level. The MPA has an important role in ensuring mineral safeguarding is not perceived as just a County function but guiding and supporting Local Authorities to appreciate they also have a role to play in accordance with the Planning Practice Guidance.
