Draft Nottinghamshire Minerals Local Plan

These representations are made on behalf of FCC Environment Limited ("FCC") in response to the consultation exercise undertaken by Nottinghamshire County Council (NCC) in relation to the Draft Minerals Local Plan. These representations specifically make reference to the Carlton Forest site (site ref: MP3c) located in Worksop, which is owned freehold by FCC.
The table below sets out each part of the Draft Minerals Local Plan we wish to comment on and our response (either to support, object or comment), in the order each part appears within the Draft Minerals Local Plan.
Strategic Objective 4 (SO4) seeks to protect the County's potential mineral resources of economic importance from development.
FCC supports the protection of important mineral resources, and therefore supports this objective. However, mineral extraction will not be taking place at Carlton Forest during the plan period as all reserves have been exhausted, and
therefore the site should not be considered a potential mineral resource requiring safeguarding.
This plan illustrates that the Carlton Forest site is a permitted Sherwood Sandstone site. Condition 2 of planning permission 1/16/01785/CDM relating to sand extraction at Carlton Forest states: "All sand extraction, processing and
export of mineral from the site shall cease on or before 25th August 2018". The decision notice is attached to these representations for ease of reference.
It should also be noted that all economically important mineral resources would have already been extracted prior to the adoption of the plan. The quarry operator lease expires this year and they will be vacating site.
Mineral extraction will not be permitted at Carlton Forest during the plan period, and therefore the site should not be shown within the Key Diagram as a permitted site.
Policy SP8 safeguards economically important mineral resources. For the reason set out in the response to SO4, FCC supports this policy. However, mineral extraction will not be permitted at Carlton Forest during the plan period,
and therefore the site should not be considered a potential mineral resource requiring safeguarding.
Para 3.47 This policy identifies that the County contains over 1,400 Local Wildlife Sites (LWS) which are protected by its designation. The majority of the Carlton Forest site forms part of the Carlton Forest Sandpit LWS, which is designated for its botanical interest.
Following a Phase 2 Botanical Survey (to support a recent planning application on the site - ref: 18/01093/OUT) it was considered that none of the on-site area met the criteria to be designated as an LWS and the majority of the off-site
area of the LWS was not considered to meet the criteria with the exception of a small, linear strip approximately 220m west of the site boundary due to a lack of indicator species.
It is therefore considered that the extent of the LWS should be reduced to cover only the small, linear strip approximately 220m west of the site boundary.
Para 3.81 This paragraph states that only the most meaningful and
best current estimate of viable resources have been
safeguarded for future assessment and possible use. This is incorrect.
The Carlton Forest site (ref: MP3c) has been safeguarded within the draft plan for its Sherwood Sandstone resource, despite not having any important resources remaining with the plan period or an extant planning consent for mineral
extraction. Carlton Forest should be removed from the safeguarded sites.
Plan 4 illustrates that the Carlton Forest site is safeguarded for its Sherwood Sandstone resource. As stated within the response to 'Plan 3 Key Diagram', all economically important mineral resources on the site would have already
been extracted prior to the adoption of the plan. Therefore, the site should not be safeguarded and should be removed from Plan 4.
Policy MP1 This policy states that 7.03 million tonnes of Sherwood Sandstone will be provided over the plan period. This policy includes 0.07 million tonnes reserve at Carlton Forest (ref:MP3c), which will not be available when the plan is adopted.
The policy is relying on a site that will not deliver the resource that is stated. Therefore, the Carlton Forest site should be removed from the anticipated Sherwood Sandstone provision.
In reality, just 6.96 million tonnes of Sherwood Sandstone will be provided over the plan period. This policy therefore needs to be updated.
Policy MP3 states that remaining reserves at Carlton Forest (ref: MP3c) are at 0.07 million tonnes. As noted above, this is incorrect.
There will be no economically important reserves left on the site when the plan is adopted, thus any reference to the site in this policy should be removed.
Para 4.45 This text reiterates the points made in Policy MP3. For the reason set out within the response to Policies MP1 and MP3, references to 7.03 million tonnes of Sherwood Sandstone reserves in Nottinghamshire should be amended to state
6.96 million tonnes.
Para 4.46This text states that as of December 2016, there were 4 permitted Sherwood Sandstone sites with estimated reserves of 3.85 million tonnes. This information is now out of date.
As noted within the response to 'Plan 3 Key Diagram', mineral extraction at Carlton Forest will not be permitted during the plan period. Additionally, all economically important mineral resources would have already been
extracted prior to the adoption of the plan. Therefore, the site would have 0 reserves.
It is therefore suggested that this paragraph is updated to include up to date reserves information.
Para 4.47 This paragraph states that an additional 3.3 million tonnes of Sherwood Sandstone would need to be provided up to 2036 to meet demand on top of remaining reserves at permitted sites.
However, considering that the permitted reserves data includes a site (Carlton Forest - ref: MP3c) which will have no remaining reserves within the plan period, this paragraph needs to be updated to state that atleast an additional 4
million tonnes of Sherwood Sandstone would be required to meet demand.
Para 4.53 This paragraph relates to the Carlton Forest site (ref: MP3c), and states that there are still 54,000 tonnes of permitted reserves remaining. For the reasons set out previously within this table, this paragraph should be removed.
Policy DM12 This policy relates to restoration, after use and aftercare of minerals sites. Paragraph 7 of this policy states that the after-use of a site will be required to have regard to the wider context of the site and its surroundings. Paragraph 8 states that where opportunities arise, after use proposals should provide benefits to the local and wider community, which may include employment.
Policy DM12 promotes the after-use of mineral sites for appropriate and beneficial uses including employment. FCC recently submitted a planning application (which is currently under determination) for the erection of circa 3,125m2 of B1
(Business), B2 (General Industry) and/or B8 (Storage and Distribution) floorspace at Carlton Forest Quarry (ref:18/01093/OUT), which is located adjacent to a number of other existing commercial / industrial units. FCC therefore
supports Policy DM12.
Policy DM13 supports the recovery of minerals as an incidental element of another development proposal.
This policy promotes sustainable development by helping to conserve mineral resources that might otherwise be lost, therefore FCC supports Policy DM13.
Appendix 2 Sherwood Sandstone delivery schedule: The Sherwood Sandstone Delivery Schedule contained within Appendix 2 of the Draft Minerals Plan references the Carlton Forest site (ref: MP3c). For the reasons set out
previously within this table, reference to Carlton Forest should be removed from this schedule.
Appendix 4- policies map: The Policies Map contained within Appendix 4 identifies the Carlton Forest site (ref: MP3c) as a permitted and safeguarded Sherwood Sandstone site. For the reasons set out previously within this table, Carlton Forest should not be identified within the Policies Map.

These representations are made on behalf of FCC Environment Limited ("FCC") in response to the consultation exercise undertaken by Nottinghamshire County Council (NCC) in relation to the Draft Minerals Local Plan. These representations specifically make reference to the Carlton Forest site (site ref: MP3c) located in Worksop, which is owned freehold by FCC.
The table below sets out each part of the Draft Minerals Local Plan we wish to comment on and our response (either to support, object or comment), in the order each part appears within the Draft Minerals Local Plan.
Strategic Objective 4 (SO4) seeks to protect the County's potential mineral resources of economic importance from development.
FCC supports the protection of important mineral resources, and therefore supports this objective. However, mineral extraction will not be taking place at Carlton Forest during the plan period as all reserves have been exhausted, and
therefore the site should not be considered a potential mineral resource requiring safeguarding.
This plan illustrates that the Carlton Forest site is a permitted Sherwood Sandstone site. Condition 2 of planning permission 1/16/01785/CDM relating to sand extraction at Carlton Forest states: "All sand extraction, processing and
export of mineral from the site shall cease on or before 25th August 2018". The decision notice is attached to these representations for ease of reference.
It should also be noted that all economically important mineral resources would have already been extracted prior to the adoption of the plan. The quarry operator lease expires this year and they will be vacating site.
Mineral extraction will not be permitted at Carlton Forest during the plan period, and therefore the site should not be shown within the Key Diagram as a permitted site.
Policy SP8 safeguards economically important mineral resources. For the reason set out in the response to SO4, FCC supports this policy. However, mineral extraction will not be permitted at Carlton Forest during the plan period,
and therefore the site should not be considered a potential mineral resource requiring safeguarding.
Para 3.47 This policy identifies that the County contains over 1,400 Local Wildlife Sites (LWS) which are protected by its designation. The majority of the Carlton Forest site forms part of the Carlton Forest Sandpit LWS, which is designated for its botanical interest.
Following a Phase 2 Botanical Survey (to support a recent planning application on the site - ref: 18/01093/OUT) it was considered that none of the on-site area met the criteria to be designated as an LWS and the majority of the off-site
area of the LWS was not considered to meet the criteria with the exception of a small, linear strip approximately 220m west of the site boundary due to a lack of indicator species.
It is therefore considered that the extent of the LWS should be reduced to cover only the small, linear strip approximately 220m west of the site boundary.
Para 3.81 This paragraph states that only the most meaningful and
best current estimate of viable resources have been
safeguarded for future assessment and possible use. This is incorrect.
The Carlton Forest site (ref: MP3c) has been safeguarded within the draft plan for its Sherwood Sandstone resource, despite not having any important resources remaining with the plan period or an extant planning consent for mineral
extraction. Carlton Forest should be removed from the safeguarded sites.
Plan 4 illustrates that the Carlton Forest site is safeguarded for its Sherwood Sandstone resource. As stated within the response to 'Plan 3 Key Diagram', all economically important mineral resources on the site would have already
been extracted prior to the adoption of the plan. Therefore, the site should not be safeguarded and should be removed from Plan 4.
Policy MP1 This policy states that 7.03 million tonnes of Sherwood Sandstone will be provided over the plan period. This policy includes 0.07 million tonnes reserve at Carlton Forest (ref:MP3c), which will not be available when the plan is adopted.
The policy is relying on a site that will not deliver the resource that is stated. Therefore, the Carlton Forest site should be removed from the anticipated Sherwood Sandstone provision.
In reality, just 6.96 million tonnes of Sherwood Sandstone will be provided over the plan period. This policy therefore needs to be updated.
Policy MP3 states that remaining reserves at Carlton Forest (ref: MP3c) are at 0.07 million tonnes. As noted above, this is incorrect.
There will be no economically important reserves left on the site when the plan is adopted, thus any reference to the site in this policy should be removed.
Para 4.45 This text reiterates the points made in Policy MP3. For the reason set out within the response to Policies MP1 and MP3, references to 7.03 million tonnes of Sherwood Sandstone reserves in Nottinghamshire should be amended to state
6.96 million tonnes.
Para 4.46This text states that as of December 2016, there were 4 permitted Sherwood Sandstone sites with estimated reserves of 3.85 million tonnes. This information is now out of date.
As noted within the response to 'Plan 3 Key Diagram', mineral extraction at Carlton Forest will not be permitted during the plan period. Additionally, all economically important mineral resources would have already been
extracted prior to the adoption of the plan. Therefore, the site would have 0 reserves.
It is therefore suggested that this paragraph is updated to include up to date reserves information.
Para 4.47 This paragraph states that an additional 3.3 million tonnes of Sherwood Sandstone would need to be provided up to 2036 to meet demand on top of remaining reserves at permitted sites.
However, considering that the permitted reserves data includes a site (Carlton Forest - ref: MP3c) which will have no remaining reserves within the plan period, this paragraph needs to be updated to state that atleast an additional 4
million tonnes of Sherwood Sandstone would be required to meet demand.
Para 4.53 This paragraph relates to the Carlton Forest site (ref: MP3c), and states that there are still 54,000 tonnes of permitted reserves remaining. For the reasons set out previously within this table, this paragraph should be removed.
Policy DM12 This policy relates to restoration, after use and aftercare of minerals sites. Paragraph 7 of this policy states that the after-use of a site will be required to have regard to the wider context of the site and its surroundings. Paragraph 8 states that where opportunities arise, after use proposals should provide benefits to the local and wider community, which may include employment.
Policy DM12 promotes the after-use of mineral sites for appropriate and beneficial uses including employment. FCC recently submitted a planning application (which is currently under determination) for the erection of circa 3,125m2 of B1
(Business), B2 (General Industry) and/or B8 (Storage and Distribution) floorspace at Carlton Forest Quarry (ref:18/01093/OUT), which is located adjacent to a number of other existing commercial / industrial units. FCC therefore
supports Policy DM12.
Policy DM13 supports the recovery of minerals as an incidental element of another development proposal.
This policy promotes sustainable development by helping to conserve mineral resources that might otherwise be lost, therefore FCC supports Policy DM13.
Appendix 2 Sherwood Sandstone delivery schedule: The Sherwood Sandstone Delivery Schedule contained within Appendix 2 of the Draft Minerals Plan references the Carlton Forest site (ref: MP3c). For the reasons set out
previously within this table, reference to Carlton Forest should be removed from this schedule.
Appendix 4- policies map: The Policies Map contained within Appendix 4 identifies the Carlton Forest site (ref: MP3c) as a permitted and safeguarded Sherwood Sandstone site. For the reasons set out previously within this table, Carlton Forest should not be identified within the Policies Map.