Draft Nottinghamshire Minerals Local Plan

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Comment

Draft Nottinghamshire Minerals Local Plan

Question 1: What do you think of the draft vision and strategic objectives?

Representation ID: 30870

Received: 20/09/2018

Respondent: Cemex UK operations

Representation Summary:

CEMEX concur with the vision and strategic objectives and welcome the recognition that the County will seek to meets its share of national and local need. In this context CEMEX in particular supports Objective SO2 (Supporting an adequate supply of minerals).

Full text:

CEMEX concur with the vision and strategic objectives and welcome the recognition that the County will seek to meets its share of national and local need. In this context CEMEX in particular supports Objective SO2 (Supporting an adequate supply of minerals).

Comment

Draft Nottinghamshire Minerals Local Plan

Question 2: What do you think of the draft strategic policy for sustainable development?

Representation ID: 30871

Received: 20/09/2018

Respondent: Cemex UK operations

Representation Summary:

No comment

Full text:

No comment

Comment

Draft Nottinghamshire Minerals Local Plan

Question 3: What do you think of the draft strategic policy for minerals provision?

Representation ID: 30875

Received: 20/09/2018

Respondent: Cemex UK operations

Representation Summary:

CEMEX support the County Councils recognition that the strategy should in particular seek to identify land to maintain a steady and adequate supply of minerals (bullet point a). However, it is concerned that this relates just to the plan period and not a miniumum of seven years beyond this in accordance with paragraph 207 of the NPPF. In addition the words 'or as identified through the annual Local Aggregates Assessment' should be added to the end of bullet-point (a).

Full text:

CEMEX support the County Councils recognition that the strategy should in particular seek to identify land to maintain a steady and adequate supply of minerals (bullet point a). However, it is concerned that this relates just to the plan period and not a miniumum of seven years beyond this in accordance with paragraph 207 of the NPPF. In addition the words 'or as identified through the annual Local Aggregates Assessment' should be added to the end of bullet-point (a).

Comment

Draft Nottinghamshire Minerals Local Plan

Question 4: What do you think of the draft strategic policy for biodiversity led restoration?

Representation ID: 30877

Received: 20/09/2018

Respondent: Cemex UK operations

Representation Summary:

CEMEX strongly support restoration led proposals which provide enhanced opportunities for biodiversity but recognise also the positive benefits of enhanced public access where possible and compatible

Full text:

CEMEX strongly support restoration led proposals which provide enhanced opportunities for biodiversity but recognise also the positive benefits of enhanced public access where possible and compatible

Comment

Draft Nottinghamshire Minerals Local Plan

Question 5: What do you think of the draft strategic policy for climate change?

Representation ID: 30879

Received: 20/09/2018

Respondent: Cemex UK operations

Representation Summary:

No comment

Full text:

No comment

Comment

Draft Nottinghamshire Minerals Local Plan

Question 6: What do you think of the draft strategic policy for sustainable transport?

Representation ID: 30880

Received: 20/09/2018

Respondent: Cemex UK operations

Representation Summary:

No comment

Full text:

No comment

Comment

Draft Nottinghamshire Minerals Local Plan

Question 7: What do you think of the draft strategic policy for the built, historic and natural environment?

Representation ID: 30886

Received: 20/09/2018

Respondent: Cemex UK operations

Representation Summary:

The policy appears to afford the same weight to international, national, regional and local nature conservation sites and priority habitats and species yet paragraph 171 of the NPPF states that plans should actually distinguish between their hierarchy. Suggest these are separated out in the policy in recognition of the NPPF.

CEMEX also query the status of the comment about comprising 'planned future infrastructure' (paragraph 3.66) as this is vague and can potentially result in the sterilisation of mineral reserves.

Full text:

The policy appears to afford the same weight to international, national, regional and local nature conservation sites and priority habitats and species yet paragraph 171 of the NPPF states that plans should actually distinguish between their hierarchy. Suggest these are separated out in the policy in recognition of the NPPF.

CEMEX also query the status of the comment about comprising 'planned future infrastructure' (paragraph 3.66) as this is vague and can potentially result in the sterilisation of mineral reserves.

Comment

Draft Nottinghamshire Minerals Local Plan

Question 8: What do you think of the draft strategic policy for the Nottinghamshire Green Belt?

Representation ID: 30887

Received: 20/09/2018

Respondent: Cemex UK operations

Representation Summary:

No comment

Full text:

No comment

Comment

Draft Nottinghamshire Minerals Local Plan

Question 9: What do you think of the draft strategic policy for minerals safeguarding, consultation areas and associated minerals infrastructure?

Representation ID: 30889

Received: 20/09/2018

Respondent: Cemex UK operations

Representation Summary:

The NPPF (Paragraph c) states that planning policies should safeguard mineral resource areas without qualification as to whether they are economically important or not. Therefore reference to 'economically important' should be removed from the policy.

Full text:

The NPPF (Paragraph c) states that planning policies should safeguard mineral resource areas without qualification as to whether they are economically important or not. Therefore reference to 'economically important' should be removed from the policy.

Comment

Draft Nottinghamshire Minerals Local Plan

Question 10: What do you think of the draft policy approach regarding future aggregate provision?

Representation ID: 30892

Received: 20/09/2018

Respondent: Cemex UK operations

Representation Summary:

CEMEX strongly object to the provision of aggregate set out in Policy MP1 as the figure of 32 million tonnes arrived at by taking a 10 average of sales does take account of future demand going forward. It appears to CEMEX therefore that the plan seriously underprovides for needs of the economy which will as a consequence result into potentially unsustainable imports into the county.

In addition, it is noted that the policy makes provision for the maintenance of a landbank of 7 years yet the provision is just for the plan period.

Full text:

CEMEX strongly object to the provision of aggregate set out in Policy MP1 as the figure of 32 million tonnes arrived at by taking a 10 average of sales does take account of future demand going forward. It appears to CEMEX therefore that the plan seriously underprovides for needs of the economy which will as a consequence result into potentially unsustainable imports into the county.

In addition, it is noted that the policy makes provision for the maintenance of a landbank of 7 years yet the provision is just for the plan period.

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