Draft Nottinghamshire Minerals Local Plan

I am writing on behalf of the Nottinghamshire Branch of The Campaign to Protect Rural England (CPRE) in response to the County Council's consultation on its draft plan.

I want to say, at the outset, that CPRE recognises the need for mineral extraction in Nottinghamshire. However, it also needs to be recognised both by local authorities, the industry and others that the impact of extracting millions of tonnes of aggregates (sand, gravel, and rock) every year on the countryside and local communities can be enormous, both during the operation and afterwards. There is a need to reduce the level of extraction in future by making better use of mineral resources and developing alternatives.

While having some small quarries to meet local needs may be appropriate (such as to provide stone to maintain locally characteristic housing) the size of modern quarries, combined with their location in often sensitive rural environments, makes aggregates quarrying one of the most controversial rural industries. Despite planning controls over quarrying and improved methods of operation, quarrying can still have a devastating impact on the countryside. Noise, dust and heavy lorry traffic are characteristic during mining operations and too often landscapes are left scarred by extraction. Even when restoration is mandatory and then undertaken, it is seldom - if ever - able to recreate the character of the countryside which was developed over centuries.


In our opinion, it is inappropriate that plans for mineral extraction should be built on society's demand for minerals and driven by driven by statistical forecasts for demand. The environment is too often taken into account only when considering where to quarry, not whether we really need to. The extent of land with plans for quarrying means that in some areas, there are enough sites already secured (the 'land bank') to ensure that quarrying continues for decades. These unused reserves hold billions of tonnes of aggregates - enough to build over hundreds of motorways - and hinder efforts to influence the rate of quarrying and to move towards a more sustainable basis for exploiting natural resources.

CPRE would like to reduce the damage to the countryside from quarrying by encouraging the more efficient use of aggregates and managing demand. We believe this can be achieved through recycling, making greater use of alternatives and reducing waste in construction. We dislike the notion of a narrow 'predict and provide' approach to quarrying. CPRE believes a fundamental overhaul of policies on quarrying is urgently required, so that in future the policies:

* value the whole countryside, its landscape, character and tranquillity by giving clear priority to reducing demand for aggregates, and including targets to steadily reduce the primary extraction of minerals;
* replace the old 'predict and provide' approach to minerals planning with more positive planning policies which use the principles of 'plan, monitor and manage' and environmental capacity assessments to govern where quarrying may be required. Such a change should also promote more sustainable construction techniques which reduce reliance on mineral extraction;
* ensure appropriate economic signals are sent to quarry operators and consumers which reflect the environmental costs of extraction on the countryside and help to break the link between economic prosperity and the consumption of natural resources; and
* achieve the more prudent use of natural resources through reuse, recovery and recycling, use of alternative (including non-aggregate) materials and techniques, and closer integration with land use planning.

Whilst I appreciate that some of but not all these considerations have been taken up by the County Council in the draft Plan and the actions of the Council are constrained by national policy, it is the considerations outlined above that drive some of the points that we do wish to make about the proposed changes to the future sand and gravel provision for Nottinghamshire.

The Plan states at paragraph 3.8 that "within Nottinghamshire the priority is therefore to extend existing sites, in preference to developing new sites, and to encourage the use of secondary and recycled aggregates far as possible". This priority has not counted for a great deal, when it has already been cast aside. There are new sites at both Barton-in-Fabis, near Nottingham; and Botany Bay

We wish to comment on each of these sites.

 
Barton-in -Fabis
1. Quarrying on this site would significantly impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit which are close -by and on five Sites of Important Nature Conservation one of which would be destroyed altogether.

2. We have concerns about three rights of way passing through countryside between Barton in Fabis and Clifton. It is difficult to see how this access could be protected or suitably managed or how the proposal is in line with Policy DM7: Public Access.

3. There would be a major impact on the quality of life and visual amenity of local people, as well as the loss of peace and tranquillity in an area used extensively by a wider community for walking, fishing, horse riding, bird watching and other leisure pursuits. The loss of a significant area of countryside on the edge of a large city such as Nottingham damages the recreational opportunities that are increasingly important for the health and well-being of city dwellers. We trust that mineral sites selection is not driven by party political consideration, but we cannot help but observe that the County Council's assessment of the sustainability and environmental impact of this site, under a previous administration, resulted in its rejection and exclusion from a previous draft Minerals Local Plan.

4. The site is close to populated areas which would be inevitably impacted by noise and dust.

5. The restoration suggested is not to restore the land to its current state, but to marshland and standing water. Even this is likely to take 10 years to establish, meaning that the area will be unusable for up to 25 years.

6. The issue of "geographical spread" of mineral extraction across the county is not a persuasive reason to establish a new site unless there are overwhelmingly other positive reasons to do so. The fact that a planning application has already been made is not such a reason and it is hard to detect any other reason that justifies giving priority to opening a new site here. The draft plan does not follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" and I do not believe this site is suitable on such a basis in any event.

7. Policy SP7 does state that minerals developments will be supported where the openness of the green belt is preserved, but Brandshill and Clifton Woods, adjacent to the site, have been designated as Ancient Woodland which have special protection under the National Planning Policy Framework (NPPF). The fact that minerals can be extracted in the green belt hardly seems to be a reason that they should be in this case.






Botany Bay

1. Properties on the southern edge of the village of Barnby Moor will particularly be adversely affected by the quarry, especially if a processing plant is established on site.

2. A feature of the agricultural land here is mature hedgerows and tree belts. These cannot be replaced quickly once any restoration is contemplated.

3. Where the A638 where it crosses the main east coast rail line there are elevated views of a great proportion of the site which cannot be screened.

4. The Chesterfield Canal is, at present, set in a tranquil setting. The quarry will badly affect canal boat users and those walking along the canal path. Whatever screening is proposed is hardly likely to ameliorate these effects to a satisfactory degree.

5. Dewatering of the workings could have an adverse impact upon the stability of the A638 (the Great North Road) and on the East Coast Rail Line (which is, of course, a vital transport link between London and the North of England and Scotland). There is also the possibility that creating more water spots will encourage birds that might endanger the local air traffic.


Finally, we want to make some comments about hydrocarbons and shale gas.


Hydrocarbons and Shale Gas

Paragraph 4.109 of the draft plan states:

"It is considered that there is no justifiable reason in planning policy terms to separate shale gas from other hydrocarbon development."

The facts are that extraction of gas or oil out of shale rock is very different to getting 'conventional' hydrocarbons out of permeable rock formations which allow gas or oil to flow to a well head from some distance. Shale must be fractured underground using horizontal drilling and high-volume hydraulic fracturing. This can be done only up to a mile or so from the wellhead, requiring well pads every couple of miles (and repeated fracturing every year or so) - potentially leading to a widespread industrialisation of the landscape. Frankly. It is extremely disappointing that the draft plan does not recognise these plain facts.

Nottinghamshire has large areas which could be fracked for shale gas in the north and south west. The east of the county could be drilled for coal bed methane.

Large parts of the county rest on Sherwood sandstone with aquifers important for drinking water for agriculture. And large areas of Nottinghamshire have been subject to coalmining - with associated instability and subsidence.
As you are aware, IGas has been granted permission to drill at exploratory sites at Misson and Barnby Moor. And Ineos has licences covering around 1,000 square kilometres around the Sherwood Forest area (including almost all the area between Chesterfield and Ollerton and between Mansfield and Sheffield. Ineos have even taken the National Trust to court to force seismic testing across Clumber Park.

We shall be open about our view on shale gas which is that fracking should be halted unless it can be clearly demonstrated that the following criteria are met.
* Help secure the radical reductions in carbon emissions required to comply with planning policy and meet legally binding climate change targets;
* Not lead to unacceptable cumulative harm, whether for landscapes or on the English countryside as a whole, and
* Be carefully controlled by effective systems of regulation and democratic planning, which are adequately resourced at both local and national levels.
However, we accept and appreciate that the County Council must proceed in line with government guidelines. That said, there does not appear to be any good reason why the County Council should not set some criteria for its planning approach to shale gas extraction. Would the Council really want to see fracking beneath Clumber Park? Why should the Council not have an established approach to matters such as and including:

* heavy goods vehicle movements and suitable transport links; increased accident risks, and occupational hazards;
* the arrangements for disposal of toxic flowback water;
* measures to protect groundwater - particularly the Sherwood Sandstone Aquifer;
* toxic air emissions; and
* seismic activity, particularly in former coalfield areas; and
* particular landscapes.


Yours faithfully

I am writing on behalf of the Nottinghamshire Branch of The Campaign to Protect Rural England (CPRE) in response to the County Council's consultation on its draft plan.

I want to say, at the outset, that CPRE recognises the need for mineral extraction in Nottinghamshire. However, it also needs to be recognised both by local authorities, the industry and others that the impact of extracting millions of tonnes of aggregates (sand, gravel, and rock) every year on the countryside and local communities can be enormous, both during the operation and afterwards. There is a need to reduce the level of extraction in future by making better use of mineral resources and developing alternatives.

While having some small quarries to meet local needs may be appropriate (such as to provide stone to maintain locally characteristic housing) the size of modern quarries, combined with their location in often sensitive rural environments, makes aggregates quarrying one of the most controversial rural industries. Despite planning controls over quarrying and improved methods of operation, quarrying can still have a devastating impact on the countryside. Noise, dust and heavy lorry traffic are characteristic during mining operations and too often landscapes are left scarred by extraction. Even when restoration is mandatory and then undertaken, it is seldom - if ever - able to recreate the character of the countryside which was developed over centuries.


In our opinion, it is inappropriate that plans for mineral extraction should be built on society's demand for minerals and driven by driven by statistical forecasts for demand. The environment is too often taken into account only when considering where to quarry, not whether we really need to. The extent of land with plans for quarrying means that in some areas, there are enough sites already secured (the 'land bank') to ensure that quarrying continues for decades. These unused reserves hold billions of tonnes of aggregates - enough to build over hundreds of motorways - and hinder efforts to influence the rate of quarrying and to move towards a more sustainable basis for exploiting natural resources.

CPRE would like to reduce the damage to the countryside from quarrying by encouraging the more efficient use of aggregates and managing demand. We believe this can be achieved through recycling, making greater use of alternatives and reducing waste in construction. We dislike the notion of a narrow 'predict and provide' approach to quarrying. CPRE believes a fundamental overhaul of policies on quarrying is urgently required, so that in future the policies:

* value the whole countryside, its landscape, character and tranquillity by giving clear priority to reducing demand for aggregates, and including targets to steadily reduce the primary extraction of minerals;
* replace the old 'predict and provide' approach to minerals planning with more positive planning policies which use the principles of 'plan, monitor and manage' and environmental capacity assessments to govern where quarrying may be required. Such a change should also promote more sustainable construction techniques which reduce reliance on mineral extraction;
* ensure appropriate economic signals are sent to quarry operators and consumers which reflect the environmental costs of extraction on the countryside and help to break the link between economic prosperity and the consumption of natural resources; and
* achieve the more prudent use of natural resources through reuse, recovery and recycling, use of alternative (including non-aggregate) materials and techniques, and closer integration with land use planning.

Whilst I appreciate that some of but not all these considerations have been taken up by the County Council in the draft Plan and the actions of the Council are constrained by national policy, it is the considerations outlined above that drive some of the points that we do wish to make about the proposed changes to the future sand and gravel provision for Nottinghamshire.

The Plan states at paragraph 3.8 that "within Nottinghamshire the priority is therefore to extend existing sites, in preference to developing new sites, and to encourage the use of secondary and recycled aggregates far as possible". This priority has not counted for a great deal, when it has already been cast aside. There are new sites at both Barton-in-Fabis, near Nottingham; and Botany Bay

We wish to comment on each of these sites.

 
Barton-in -Fabis
1. Quarrying on this site would significantly impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit which are close -by and on five Sites of Important Nature Conservation one of which would be destroyed altogether.

2. We have concerns about three rights of way passing through countryside between Barton in Fabis and Clifton. It is difficult to see how this access could be protected or suitably managed or how the proposal is in line with Policy DM7: Public Access.

3. There would be a major impact on the quality of life and visual amenity of local people, as well as the loss of peace and tranquillity in an area used extensively by a wider community for walking, fishing, horse riding, bird watching and other leisure pursuits. The loss of a significant area of countryside on the edge of a large city such as Nottingham damages the recreational opportunities that are increasingly important for the health and well-being of city dwellers. We trust that mineral sites selection is not driven by party political consideration, but we cannot help but observe that the County Council's assessment of the sustainability and environmental impact of this site, under a previous administration, resulted in its rejection and exclusion from a previous draft Minerals Local Plan.

4. The site is close to populated areas which would be inevitably impacted by noise and dust.

5. The restoration suggested is not to restore the land to its current state, but to marshland and standing water. Even this is likely to take 10 years to establish, meaning that the area will be unusable for up to 25 years.

6. The issue of "geographical spread" of mineral extraction across the county is not a persuasive reason to establish a new site unless there are overwhelmingly other positive reasons to do so. The fact that a planning application has already been made is not such a reason and it is hard to detect any other reason that justifies giving priority to opening a new site here. The draft plan does not follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" and I do not believe this site is suitable on such a basis in any event.

7. Policy SP7 does state that minerals developments will be supported where the openness of the green belt is preserved, but Brandshill and Clifton Woods, adjacent to the site, have been designated as Ancient Woodland which have special protection under the National Planning Policy Framework (NPPF). The fact that minerals can be extracted in the green belt hardly seems to be a reason that they should be in this case.






Botany Bay

1. Properties on the southern edge of the village of Barnby Moor will particularly be adversely affected by the quarry, especially if a processing plant is established on site.

2. A feature of the agricultural land here is mature hedgerows and tree belts. These cannot be replaced quickly once any restoration is contemplated.

3. Where the A638 where it crosses the main east coast rail line there are elevated views of a great proportion of the site which cannot be screened.

4. The Chesterfield Canal is, at present, set in a tranquil setting. The quarry will badly affect canal boat users and those walking along the canal path. Whatever screening is proposed is hardly likely to ameliorate these effects to a satisfactory degree.

5. Dewatering of the workings could have an adverse impact upon the stability of the A638 (the Great North Road) and on the East Coast Rail Line (which is, of course, a vital transport link between London and the North of England and Scotland). There is also the possibility that creating more water spots will encourage birds that might endanger the local air traffic.


Finally, we want to make some comments about hydrocarbons and shale gas.


Hydrocarbons and Shale Gas

Paragraph 4.109 of the draft plan states:

"It is considered that there is no justifiable reason in planning policy terms to separate shale gas from other hydrocarbon development."

The facts are that extraction of gas or oil out of shale rock is very different to getting 'conventional' hydrocarbons out of permeable rock formations which allow gas or oil to flow to a well head from some distance. Shale must be fractured underground using horizontal drilling and high-volume hydraulic fracturing. This can be done only up to a mile or so from the wellhead, requiring well pads every couple of miles (and repeated fracturing every year or so) - potentially leading to a widespread industrialisation of the landscape. Frankly. It is extremely disappointing that the draft plan does not recognise these plain facts.

Nottinghamshire has large areas which could be fracked for shale gas in the north and south west. The east of the county could be drilled for coal bed methane.

Large parts of the county rest on Sherwood sandstone with aquifers important for drinking water for agriculture. And large areas of Nottinghamshire have been subject to coalmining - with associated instability and subsidence.
As you are aware, IGas has been granted permission to drill at exploratory sites at Misson and Barnby Moor. And Ineos has licences covering around 1,000 square kilometres around the Sherwood Forest area (including almost all the area between Chesterfield and Ollerton and between Mansfield and Sheffield. Ineos have even taken the National Trust to court to force seismic testing across Clumber Park.

We shall be open about our view on shale gas which is that fracking should be halted unless it can be clearly demonstrated that the following criteria are met.
* Help secure the radical reductions in carbon emissions required to comply with planning policy and meet legally binding climate change targets;
* Not lead to unacceptable cumulative harm, whether for landscapes or on the English countryside as a whole, and
* Be carefully controlled by effective systems of regulation and democratic planning, which are adequately resourced at both local and national levels.
However, we accept and appreciate that the County Council must proceed in line with government guidelines. That said, there does not appear to be any good reason why the County Council should not set some criteria for its planning approach to shale gas extraction. Would the Council really want to see fracking beneath Clumber Park? Why should the Council not have an established approach to matters such as and including:

* heavy goods vehicle movements and suitable transport links; increased accident risks, and occupational hazards;
* the arrangements for disposal of toxic flowback water;
* measures to protect groundwater - particularly the Sherwood Sandstone Aquifer;
* toxic air emissions; and
* seismic activity, particularly in former coalfield areas; and
* particular landscapes.


Yours faithfully

I am writing on behalf of the Nottinghamshire Branch of The Campaign to Protect Rural England (CPRE) in response to the County Council's consultation on its draft plan.

I want to say, at the outset, that CPRE recognises the need for mineral extraction in Nottinghamshire. However, it also needs to be recognised both by local authorities, the industry and others that the impact of extracting millions of tonnes of aggregates (sand, gravel, and rock) every year on the countryside and local communities can be enormous, both during the operation and afterwards. There is a need to reduce the level of extraction in future by making better use of mineral resources and developing alternatives.

While having some small quarries to meet local needs may be appropriate (such as to provide stone to maintain locally characteristic housing) the size of modern quarries, combined with their location in often sensitive rural environments, makes aggregates quarrying one of the most controversial rural industries. Despite planning controls over quarrying and improved methods of operation, quarrying can still have a devastating impact on the countryside. Noise, dust and heavy lorry traffic are characteristic during mining operations and too often landscapes are left scarred by extraction. Even when restoration is mandatory and then undertaken, it is seldom - if ever - able to recreate the character of the countryside which was developed over centuries.


In our opinion, it is inappropriate that plans for mineral extraction should be built on society's demand for minerals and driven by driven by statistical forecasts for demand. The environment is too often taken into account only when considering where to quarry, not whether we really need to. The extent of land with plans for quarrying means that in some areas, there are enough sites already secured (the 'land bank') to ensure that quarrying continues for decades. These unused reserves hold billions of tonnes of aggregates - enough to build over hundreds of motorways - and hinder efforts to influence the rate of quarrying and to move towards a more sustainable basis for exploiting natural resources.

CPRE would like to reduce the damage to the countryside from quarrying by encouraging the more efficient use of aggregates and managing demand. We believe this can be achieved through recycling, making greater use of alternatives and reducing waste in construction. We dislike the notion of a narrow 'predict and provide' approach to quarrying. CPRE believes a fundamental overhaul of policies on quarrying is urgently required, so that in future the policies:

* value the whole countryside, its landscape, character and tranquillity by giving clear priority to reducing demand for aggregates, and including targets to steadily reduce the primary extraction of minerals;
* replace the old 'predict and provide' approach to minerals planning with more positive planning policies which use the principles of 'plan, monitor and manage' and environmental capacity assessments to govern where quarrying may be required. Such a change should also promote more sustainable construction techniques which reduce reliance on mineral extraction;
* ensure appropriate economic signals are sent to quarry operators and consumers which reflect the environmental costs of extraction on the countryside and help to break the link between economic prosperity and the consumption of natural resources; and
* achieve the more prudent use of natural resources through reuse, recovery and recycling, use of alternative (including non-aggregate) materials and techniques, and closer integration with land use planning.

Whilst I appreciate that some of but not all these considerations have been taken up by the County Council in the draft Plan and the actions of the Council are constrained by national policy, it is the considerations outlined above that drive some of the points that we do wish to make about the proposed changes to the future sand and gravel provision for Nottinghamshire.

The Plan states at paragraph 3.8 that "within Nottinghamshire the priority is therefore to extend existing sites, in preference to developing new sites, and to encourage the use of secondary and recycled aggregates far as possible". This priority has not counted for a great deal, when it has already been cast aside. There are new sites at both Barton-in-Fabis, near Nottingham; and Botany Bay

We wish to comment on each of these sites.

 
Barton-in -Fabis
1. Quarrying on this site would significantly impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit which are close -by and on five Sites of Important Nature Conservation one of which would be destroyed altogether.

2. We have concerns about three rights of way passing through countryside between Barton in Fabis and Clifton. It is difficult to see how this access could be protected or suitably managed or how the proposal is in line with Policy DM7: Public Access.

3. There would be a major impact on the quality of life and visual amenity of local people, as well as the loss of peace and tranquillity in an area used extensively by a wider community for walking, fishing, horse riding, bird watching and other leisure pursuits. The loss of a significant area of countryside on the edge of a large city such as Nottingham damages the recreational opportunities that are increasingly important for the health and well-being of city dwellers. We trust that mineral sites selection is not driven by party political consideration, but we cannot help but observe that the County Council's assessment of the sustainability and environmental impact of this site, under a previous administration, resulted in its rejection and exclusion from a previous draft Minerals Local Plan.

4. The site is close to populated areas which would be inevitably impacted by noise and dust.

5. The restoration suggested is not to restore the land to its current state, but to marshland and standing water. Even this is likely to take 10 years to establish, meaning that the area will be unusable for up to 25 years.

6. The issue of "geographical spread" of mineral extraction across the county is not a persuasive reason to establish a new site unless there are overwhelmingly other positive reasons to do so. The fact that a planning application has already been made is not such a reason and it is hard to detect any other reason that justifies giving priority to opening a new site here. The draft plan does not follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" and I do not believe this site is suitable on such a basis in any event.

7. Policy SP7 does state that minerals developments will be supported where the openness of the green belt is preserved, but Brandshill and Clifton Woods, adjacent to the site, have been designated as Ancient Woodland which have special protection under the National Planning Policy Framework (NPPF). The fact that minerals can be extracted in the green belt hardly seems to be a reason that they should be in this case.






Botany Bay

1. Properties on the southern edge of the village of Barnby Moor will particularly be adversely affected by the quarry, especially if a processing plant is established on site.

2. A feature of the agricultural land here is mature hedgerows and tree belts. These cannot be replaced quickly once any restoration is contemplated.

3. Where the A638 where it crosses the main east coast rail line there are elevated views of a great proportion of the site which cannot be screened.

4. The Chesterfield Canal is, at present, set in a tranquil setting. The quarry will badly affect canal boat users and those walking along the canal path. Whatever screening is proposed is hardly likely to ameliorate these effects to a satisfactory degree.

5. Dewatering of the workings could have an adverse impact upon the stability of the A638 (the Great North Road) and on the East Coast Rail Line (which is, of course, a vital transport link between London and the North of England and Scotland). There is also the possibility that creating more water spots will encourage birds that might endanger the local air traffic.


Finally, we want to make some comments about hydrocarbons and shale gas.


Hydrocarbons and Shale Gas

Paragraph 4.109 of the draft plan states:

"It is considered that there is no justifiable reason in planning policy terms to separate shale gas from other hydrocarbon development."

The facts are that extraction of gas or oil out of shale rock is very different to getting 'conventional' hydrocarbons out of permeable rock formations which allow gas or oil to flow to a well head from some distance. Shale must be fractured underground using horizontal drilling and high-volume hydraulic fracturing. This can be done only up to a mile or so from the wellhead, requiring well pads every couple of miles (and repeated fracturing every year or so) - potentially leading to a widespread industrialisation of the landscape. Frankly. It is extremely disappointing that the draft plan does not recognise these plain facts.

Nottinghamshire has large areas which could be fracked for shale gas in the north and south west. The east of the county could be drilled for coal bed methane.

Large parts of the county rest on Sherwood sandstone with aquifers important for drinking water for agriculture. And large areas of Nottinghamshire have been subject to coalmining - with associated instability and subsidence.
As you are aware, IGas has been granted permission to drill at exploratory sites at Misson and Barnby Moor. And Ineos has licences covering around 1,000 square kilometres around the Sherwood Forest area (including almost all the area between Chesterfield and Ollerton and between Mansfield and Sheffield. Ineos have even taken the National Trust to court to force seismic testing across Clumber Park.

We shall be open about our view on shale gas which is that fracking should be halted unless it can be clearly demonstrated that the following criteria are met.
* Help secure the radical reductions in carbon emissions required to comply with planning policy and meet legally binding climate change targets;
* Not lead to unacceptable cumulative harm, whether for landscapes or on the English countryside as a whole, and
* Be carefully controlled by effective systems of regulation and democratic planning, which are adequately resourced at both local and national levels.
However, we accept and appreciate that the County Council must proceed in line with government guidelines. That said, there does not appear to be any good reason why the County Council should not set some criteria for its planning approach to shale gas extraction. Would the Council really want to see fracking beneath Clumber Park? Why should the Council not have an established approach to matters such as and including:

* heavy goods vehicle movements and suitable transport links; increased accident risks, and occupational hazards;
* the arrangements for disposal of toxic flowback water;
* measures to protect groundwater - particularly the Sherwood Sandstone Aquifer;
* toxic air emissions; and
* seismic activity, particularly in former coalfield areas; and
* particular landscapes.


Yours faithfully

I am writing on behalf of the Nottinghamshire Branch of The Campaign to Protect Rural England (CPRE) in response to the County Council's consultation on its draft plan.

I want to say, at the outset, that CPRE recognises the need for mineral extraction in Nottinghamshire. However, it also needs to be recognised both by local authorities, the industry and others that the impact of extracting millions of tonnes of aggregates (sand, gravel, and rock) every year on the countryside and local communities can be enormous, both during the operation and afterwards. There is a need to reduce the level of extraction in future by making better use of mineral resources and developing alternatives.

While having some small quarries to meet local needs may be appropriate (such as to provide stone to maintain locally characteristic housing) the size of modern quarries, combined with their location in often sensitive rural environments, makes aggregates quarrying one of the most controversial rural industries. Despite planning controls over quarrying and improved methods of operation, quarrying can still have a devastating impact on the countryside. Noise, dust and heavy lorry traffic are characteristic during mining operations and too often landscapes are left scarred by extraction. Even when restoration is mandatory and then undertaken, it is seldom - if ever - able to recreate the character of the countryside which was developed over centuries.


In our opinion, it is inappropriate that plans for mineral extraction should be built on society's demand for minerals and driven by driven by statistical forecasts for demand. The environment is too often taken into account only when considering where to quarry, not whether we really need to. The extent of land with plans for quarrying means that in some areas, there are enough sites already secured (the 'land bank') to ensure that quarrying continues for decades. These unused reserves hold billions of tonnes of aggregates - enough to build over hundreds of motorways - and hinder efforts to influence the rate of quarrying and to move towards a more sustainable basis for exploiting natural resources.

CPRE would like to reduce the damage to the countryside from quarrying by encouraging the more efficient use of aggregates and managing demand. We believe this can be achieved through recycling, making greater use of alternatives and reducing waste in construction. We dislike the notion of a narrow 'predict and provide' approach to quarrying. CPRE believes a fundamental overhaul of policies on quarrying is urgently required, so that in future the policies:

* value the whole countryside, its landscape, character and tranquillity by giving clear priority to reducing demand for aggregates, and including targets to steadily reduce the primary extraction of minerals;
* replace the old 'predict and provide' approach to minerals planning with more positive planning policies which use the principles of 'plan, monitor and manage' and environmental capacity assessments to govern where quarrying may be required. Such a change should also promote more sustainable construction techniques which reduce reliance on mineral extraction;
* ensure appropriate economic signals are sent to quarry operators and consumers which reflect the environmental costs of extraction on the countryside and help to break the link between economic prosperity and the consumption of natural resources; and
* achieve the more prudent use of natural resources through reuse, recovery and recycling, use of alternative (including non-aggregate) materials and techniques, and closer integration with land use planning.

Whilst I appreciate that some of but not all these considerations have been taken up by the County Council in the draft Plan and the actions of the Council are constrained by national policy, it is the considerations outlined above that drive some of the points that we do wish to make about the proposed changes to the future sand and gravel provision for Nottinghamshire.

The Plan states at paragraph 3.8 that "within Nottinghamshire the priority is therefore to extend existing sites, in preference to developing new sites, and to encourage the use of secondary and recycled aggregates far as possible". This priority has not counted for a great deal, when it has already been cast aside. There are new sites at both Barton-in-Fabis, near Nottingham; and Botany Bay

We wish to comment on each of these sites.

 
Barton-in -Fabis
1. Quarrying on this site would significantly impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit which are close -by and on five Sites of Important Nature Conservation one of which would be destroyed altogether.

2. We have concerns about three rights of way passing through countryside between Barton in Fabis and Clifton. It is difficult to see how this access could be protected or suitably managed or how the proposal is in line with Policy DM7: Public Access.

3. There would be a major impact on the quality of life and visual amenity of local people, as well as the loss of peace and tranquillity in an area used extensively by a wider community for walking, fishing, horse riding, bird watching and other leisure pursuits. The loss of a significant area of countryside on the edge of a large city such as Nottingham damages the recreational opportunities that are increasingly important for the health and well-being of city dwellers. We trust that mineral sites selection is not driven by party political consideration, but we cannot help but observe that the County Council's assessment of the sustainability and environmental impact of this site, under a previous administration, resulted in its rejection and exclusion from a previous draft Minerals Local Plan.

4. The site is close to populated areas which would be inevitably impacted by noise and dust.

5. The restoration suggested is not to restore the land to its current state, but to marshland and standing water. Even this is likely to take 10 years to establish, meaning that the area will be unusable for up to 25 years.

6. The issue of "geographical spread" of mineral extraction across the county is not a persuasive reason to establish a new site unless there are overwhelmingly other positive reasons to do so. The fact that a planning application has already been made is not such a reason and it is hard to detect any other reason that justifies giving priority to opening a new site here. The draft plan does not follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" and I do not believe this site is suitable on such a basis in any event.

7. Policy SP7 does state that minerals developments will be supported where the openness of the green belt is preserved, but Brandshill and Clifton Woods, adjacent to the site, have been designated as Ancient Woodland which have special protection under the National Planning Policy Framework (NPPF). The fact that minerals can be extracted in the green belt hardly seems to be a reason that they should be in this case.






Botany Bay

1. Properties on the southern edge of the village of Barnby Moor will particularly be adversely affected by the quarry, especially if a processing plant is established on site.

2. A feature of the agricultural land here is mature hedgerows and tree belts. These cannot be replaced quickly once any restoration is contemplated.

3. Where the A638 where it crosses the main east coast rail line there are elevated views of a great proportion of the site which cannot be screened.

4. The Chesterfield Canal is, at present, set in a tranquil setting. The quarry will badly affect canal boat users and those walking along the canal path. Whatever screening is proposed is hardly likely to ameliorate these effects to a satisfactory degree.

5. Dewatering of the workings could have an adverse impact upon the stability of the A638 (the Great North Road) and on the East Coast Rail Line (which is, of course, a vital transport link between London and the North of England and Scotland). There is also the possibility that creating more water spots will encourage birds that might endanger the local air traffic.


Finally, we want to make some comments about hydrocarbons and shale gas.


Hydrocarbons and Shale Gas

Paragraph 4.109 of the draft plan states:

"It is considered that there is no justifiable reason in planning policy terms to separate shale gas from other hydrocarbon development."

The facts are that extraction of gas or oil out of shale rock is very different to getting 'conventional' hydrocarbons out of permeable rock formations which allow gas or oil to flow to a well head from some distance. Shale must be fractured underground using horizontal drilling and high-volume hydraulic fracturing. This can be done only up to a mile or so from the wellhead, requiring well pads every couple of miles (and repeated fracturing every year or so) - potentially leading to a widespread industrialisation of the landscape. Frankly. It is extremely disappointing that the draft plan does not recognise these plain facts.

Nottinghamshire has large areas which could be fracked for shale gas in the north and south west. The east of the county could be drilled for coal bed methane.

Large parts of the county rest on Sherwood sandstone with aquifers important for drinking water for agriculture. And large areas of Nottinghamshire have been subject to coalmining - with associated instability and subsidence.
As you are aware, IGas has been granted permission to drill at exploratory sites at Misson and Barnby Moor. And Ineos has licences covering around 1,000 square kilometres around the Sherwood Forest area (including almost all the area between Chesterfield and Ollerton and between Mansfield and Sheffield. Ineos have even taken the National Trust to court to force seismic testing across Clumber Park.

We shall be open about our view on shale gas which is that fracking should be halted unless it can be clearly demonstrated that the following criteria are met.
* Help secure the radical reductions in carbon emissions required to comply with planning policy and meet legally binding climate change targets;
* Not lead to unacceptable cumulative harm, whether for landscapes or on the English countryside as a whole, and
* Be carefully controlled by effective systems of regulation and democratic planning, which are adequately resourced at both local and national levels.
However, we accept and appreciate that the County Council must proceed in line with government guidelines. That said, there does not appear to be any good reason why the County Council should not set some criteria for its planning approach to shale gas extraction. Would the Council really want to see fracking beneath Clumber Park? Why should the Council not have an established approach to matters such as and including:

* heavy goods vehicle movements and suitable transport links; increased accident risks, and occupational hazards;
* the arrangements for disposal of toxic flowback water;
* measures to protect groundwater - particularly the Sherwood Sandstone Aquifer;
* toxic air emissions; and
* seismic activity, particularly in former coalfield areas; and
* particular landscapes.


Yours faithfully