Minerals Local Plan Sustainability Appraisal Scoping Report

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Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

1. Introduction - What is Sustainability Appraisal?

Representation ID: 30528

Received: 12/01/2018

Respondent: Barton PC, Thrumpton PM, Lark Hill RA, Clifton Village RA, SAVE

Representation Summary:

The rationale for the objectives (page 4) aren't explained, there is no indication of weighting. It isn't sufficient to assume that they are all of equal importance.

The NPPF makes specific reference the need to "protect and enhance the physical and natural environment", this isn't included in the list of objectives.

Specific elements of the NPPF / NPPG and PPG which are relevant to mineral extraction and its potential impacts should be identified. The MLP should confirm that these will be at the centre of criteria used to assess the sustainability of proposed sites and impact on green belt.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

2. Methodology

Representation ID: 30529

Received: 12/01/2018

Respondent: Barton PC, Thrumpton PM, Lark Hill RA, Clifton Village RA, SAVE

Representation Summary:

Question 2 - "Has the methodology been adequately described and is it considered to be
appropriate?"

No. Other assessments taken into consideration should include assessments of (1) landscape character (2) local and national biodiversity, (3) impact on human well-being.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

Introduction

Representation ID: 30530

Received: 12/01/2018

Respondent: Barton PC, Thrumpton PM, Lark Hill RA, Clifton Village RA, SAVE

Representation Summary:

Add Historic England's document 'The Setting of Heritage Assets'

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

Table 1: Key messages from the document review

Representation ID: 30531

Received: 12/01/2018

Respondent: Barton PC, Thrumpton PM, Lark Hill RA, Clifton Village RA, SAVE

Representation Summary:

Landscape and Countryside

"listed parks and gardens" amend to "listed parks and gardens and their settings"
Landscape Character Areas. These are too widely drawn and generalised. A finer level of detail is required including provision for taking account of local knowledge.

"landscape quality and character" amend to "landscape quality and character and associated amenity value and tranquility"

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

Introduction

Representation ID: 30532

Received: 12/01/2018

Respondent: Barton PC, Thrumpton PM, Lark Hill RA, Clifton Village RA, SAVE

Representation Summary:

There is no reference to ecosystem services under 'Natural Environment and Biodiversity' See UK National Ecosystem Assessment and the NPPF in relation to this topic.

This chapter should be an objective statement about base-line conditions/trends but is actually too often an interpretation of the situation (see full representation for detail).

Landscape character should be protected when the existing landscape is important for biodiversity and is locally significant for its contribution to the overall history of an area and is valued for its tranquillity.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

Table 2: Sustainability issues

Representation ID: 30533

Received: 12/01/2018

Respondent: Barton PC, Thrumpton PM, Lark Hill RA, Clifton Village RA, SAVE

Representation Summary:

Question 11 - "Have the ways in which the Minerals Local Plan can influence the
sustainability issues been adequately addressed in Table 2? If not, what
amendments are required?"

No - regarding Natural Environment and Biodiversity, Air Quality, Water, Soil, Sustainable Communities, Population, Health, Flooding, Climate Change, Minerals, Landscape and countryside/townscape. See full representation for detail.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

6. Developing our sustainability objectives (the SA Framework)

Representation ID: 30534

Received: 12/01/2018

Respondent: Barton PC, Thrumpton PM, Lark Hill RA, Clifton Village RA, SAVE

Representation Summary:

We have commented on the objectives and decision making criteria. However, it appears that these are mainly focused on assessing the sustainability of the overall Minerals Local Plan - it is not clear what criteria will be utilised to assess individual sites and provide a comparative score for each.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

Consultation Questions

Representation ID: 30535

Received: 12/01/2018

Respondent: Barton PC, Thrumpton PM, Lark Hill RA, Clifton Village RA, SAVE

Representation Summary:

The basis on which individual sites are scored is not clear. Are they assessed relative to each other according to their impact on the overall indicator?
There also ought to be criteria that exclude sites on the basis that the threshold of impact is too great.

Comment

Minerals Local Plan Sustainability Appraisal Scoping Report

Table 4: Proposed SA Objectives, decision making criteria and proposed indicators

Representation ID: 30536

Received: 12/01/2018

Respondent: Barton PC, Thrumpton PM, Lark Hill RA, Clifton Village RA, SAVE

Representation Summary:

Suggested amendments to Table 4 Points 2, 3, 4, 5, 8, 9, 11, 13, and 14 (see full representation).

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