Draft Nottinghamshire Minerals Local Plan

1 Introduction

1.1 Calverton Parish Council objects to the location of the proposed clay extraction
extension at Woodborough Lane. It is viewed as inaccurate to regard the proposed
extraction site as a simple extension of the current Dorket Head clay pit. The proposed
'extension' not only 'jumps the road' but also 'jumps' the ridgeline into a neighbouring
valley. This leap in location results in a change in the surrounding landscape character
from predominantly urban-fringe to rural greenbelt.
1.2 It is concerning that no other potential clay extraction locations have been
included in the site-selection process, even though brick clay reserves are widespread
across Nottinghamshire. Given the extremely sensitive nature of the Woodborough
Lane site, as outlined in comments below, it is felt that this proposal should only be
considered once there is a reasonable certainty that no other more suitable sites could
be available, either within the locality or within the wider Nottinghamshire area.

2 Unacceptable impact on a sensitive landscape location
2.1 The extraction of clay from this area would result in the loss of high-grade
agricultural land that falls within the 'best and most versatile' category - this grade
would normally be afforded significant protection from development. As noted in the
Sustainability Appraisal, the "proposed restoration scheme does not include a return
to agricultural land." (Draft Minerals Local Plan Sustainability Appraisal Interim Report
July 2018, p.297)
2.2 The proposed site is located within a particularly open, visually prominent area
of greenbelt. As acknowledged in the Sustainability Appraisal, the proposed clay
extraction site would have an "adverse impact on its openness and visual amenity
during the operational phase." (Draft Minerals Local Plan Sustainability Appraisal Interim Report July 2018, p.296). As the operational phase could extend to 25 years, this represents a significant period for residents to suffer a loss of amenity.
2.3 The proposed site would have a significant negative impact in terms of loss of
visual/recreational amenity. The Landscape Character Assessment made no appraisal
of the site as viewed from the north, despite the fact that it is noted that there is a
significant change in gradient within the northern sector of the site:
"Field rises very slightly to ridge line before dropping down out of view...The elevated
plateau drops steeply down beyond to the northern edge and is not visible from the
road" (Landscape Character Assessment Appendix 2, Part 2)

Thus, the landscape assessment appears to have been conducted only from the
perspective of the impact on views of the site from the south. No consideration is given
within the assessment to the fact that the area of the site that is noted to be out of
sight - when viewed from the road to the south - is very much within view when viewed
from the north. This omission is compounded by the fact that the area to the north,
the Woodborough Valley, has a network of well-used PRoW; the site is highly visible
from the prominent ridgeline bridleway of Spindle Lane.
Development of the extraction site would also degrade the valley when viewed from
the approach to Calverton - Dorket Head, Calverton Road to Georges Lane; no
consideration has been given to the proposed development's impact on views from
the west.
2.4 In addition, the Scheduled Ancient Monument of the Fox Wood Iron-Age
Hillfort lies on the ridgeline to the north, within direct view of the proposed site. The
potential impact on its setting does not appear to have been appraised as part of the
site selection process.
2.5 There are proposed mitigation measures for a landscape buffer of advanced
planting to screen the site from the ridgeline footpath to the north. (Draft Minerals
Local Plan Sustainability Appraisal Interim Report July 2018, p.295). These proposals
are clearly not based on any reasonable assessment of the location through actual site
visits. Below is a photograph of the proposed area of clay extraction (viewed from the
Spindle Lane bridleway to the north). It is apparent that the gradient of the slope,
combined with the higher elevation of sensitive viewpoints, would render the
suggested planting screening methods completely ineffectual.

3 Emerging MLP's inadequate site-selection process - request for this matter to
be rectified
3.1 A single 'call for sites' took place, between December 2017 and January 2018.
It may be that this relatively short time-period, combined with the fact that it included
a busy festive period over Christmas and New Year, limited the response- level. The
ramifications of a sub-optimal response to the 'call for sites' was less serious for the
non-clay minerals included in the draft MLP, with a choice of sites being achieved for
both 'Sand & Gravel' and 'Sherwood Sandstone'. However, in the cases of clay and
gypsum, there were no choices in the potential sites. For gypsum, the single proposed
site was the inevitable result of the fact that the Bantycock Quarry is the only location
for this high-grade gypsum within the UK. In the case of clay, there were no such
constraints, with widespread brick clay reserves extant across Nottinghamshire
3.2 The lack of proposed alternative sites makes the process of carrying out a
meaningful Sustainability Appraisal difficult. The Sustainability Appraisal is intended to
incorporate the requirements of the European Strategic Environmental Directive. It is
notable that this directive requires that "...reasonable alternatives taking into account
the objectives and the geographical scope of the plan or programme, are identified,
described and evaluated" (Article 5.1). Environmental Report information should
include "an outline of the reasons for selecting the alternatives dealt with" (Annex I
(h)).
3.3 It is the position of Calverton Parish Council that, given the scale of negative
impact that would result from the development of this location as a clay extraction
site, it was unreasonable for Nottinghamshire County Council not to have made any
additional effort to encourage other clay extraction sites to come forward. There are
many examples of other authorities conducting more than one 'call for sites' exercise.
It is also commonplace for those calls to extend over a longer period of time. For
example, the Wiltshire and Swindon Aggregate Minerals Site Allocations Local Plan had
two 'call for site' exercises. In addition, all potentially suitable landowners were
contacted directly by Wiltshire and Swindon Councils. It was only as a result of this
final exercise, speculatively contacting the maximum number of landowners, that
sufficient interest, resulting in a reasonable number of potential sites, was generated
http://www.wiltshire.gov.uk/minerals-adopted-sites-local-plan-may-13.pdf
As the low response to the original 'call for sites' principally relates to the lack of
proposed locations for clay extraction, it would, obviously, be acceptable for a request
for more sites to be confined to clay - limiting any negative impact on the integrity of
the Draft MLP process as a whole.

4 Concluding comments
4.1 Given the fact that the Landscape Character Assessment did not explicitly
assess the impact of the proposed extraction site when viewed from all relevant
directions, Calverton Parish Council requests that the plan is now modified. The plan
must include a formal consideration of the sensitivity of the site, as viewed from all
relevant directions - in terms of its potential effect on the visual and historic amenity
of the area. It is requested that this assessment is subsequently documented within the Sustainability Appraisal and forms the basis of a comprehensive reassessment of
the proposed site, in line with the statutory requirements of the European Strategic
Environmental Assessment (SEA) Directive.
4.2 In accordance with the Stage B requirements of the SEA Directive, to consider
reasonable alternatives, it is requested that the plan process is also modified to include
a further 'call for sites' with respect to the clay mineral requirement. Consideration
should be given to targeting the landowners of all potentially suitable sites.
4.3 Should a sound planning process eventually conclude that there are indeed no
reasonable alternatives to the Woodborough Lane location for the period up until
2036, then it is the position of Calverton Parish Council that its extent must be reduced
so that it is topographically limited to the plateau area of the site, where screening
mitigation measures are more feasible. The "landscape buffer" should be based on
advanced planting that is comprehensive enough to screen this reduced site, when
viewed from Spindle Lane, the Fox Wood Scheduled Ancient Monument, public
footpaths and roads to the west, before any site activity commences.