Draft Nottinghamshire Minerals Local Plan
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Draft Nottinghamshire Minerals Local Plan
Question 1: What do you think of the draft vision and strategic objectives?
Representation ID: 30953
Received: 22/09/2018
Respondent: Greenfield Associates
Agent: Greenfield Associates
We agree that the emerging plan acknowledges that "mineral development will be concentrated in locations that offer the greatest level of accessibility to the major markets and growth areas.."
We support the Strategic Objectives of the plan
We agree that the emerging plan acknowledges that "mineral development will be concentrated in locations that offer the greatest level of accessibility to the major markets and growth areas.."
We support the Strategic Objectives of the plan
Comment
Draft Nottinghamshire Minerals Local Plan
Question 2: What do you think of the draft strategic policy for sustainable development?
Representation ID: 30954
Received: 22/09/2018
Respondent: Greenfield Associates
Agent: Greenfield Associates
We fully support Policy SP1
We fully support Policy SP1
Comment
Draft Nottinghamshire Minerals Local Plan
Question 6: What do you think of the draft strategic policy for sustainable transport?
Representation ID: 30955
Received: 22/09/2018
Respondent: Greenfield Associates
Agent: Greenfield Associates
Policy SP5 makes no link between river barge/ rail transport and need for a wharf or rail siding that will be required to off-load and process material. The wharf/ siding then becomes a "shadow quarry" operation where HGV's will then transport the minerals to the point of use. Within Nottingham (the main market) there are no available river wharves or rail sidings suitable for these operations.
The principle of locating sites as close to market is the most sustainable transport solution at the present time for the period of the plan.
Policy SP5 makes no link between river barge/ rail transport and need for a wharf or rail siding that will be required to off-load and process material. The wharf/ siding then becomes a "shadow quarry" operation where HGV's will then transport the minerals to the point of use. Within Nottingham (the main market) there are no available river wharves or rail sidings suitable for these operations.
The principle of locating sites as close to market is the most sustainable transport solution at the present time for the period of the plan.
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: 30956
Received: 22/09/2018
Respondent: Greenfield Associates
Agent: Greenfield Associates
There is no clear definition of "no unacceptable adverse impacts". Is there any impact that can be acceptable?
The demonstration of "an overriding need for a development" is very difficult to prove. If a site is allocated in the plan, does this constitute an overriding need. What is meant by overriding
Who decides what is "adequate mitigation". A reference to the restoration plan may be useful in this policy as mineral development is temporary use of the land.
There is no clear definition of "no unacceptable adverse impacts". Is there any impact that can be acceptable?
The demonstration of "an overriding need for a development" is very difficult to prove. If a site is allocated in the plan, does this constitute an overriding need. What is meant by overriding
Who decides what is "adequate mitigation". A reference to the restoration plan may be useful in this policy as mineral development is temporary use of the land.
Comment
Draft Nottinghamshire Minerals Local Plan
Question 8: What do you think of the draft strategic policy for the Nottinghamshire Green Belt?
Representation ID: 30957
Received: 22/09/2018
Respondent: Greenfield Associates
Agent: Greenfield Associates
We support the statement that "minerals developments will be supported" in the Green Belt. However, the definition of development needs to be clear. Does this relate to extraction areas only or can this include extraction area and the associated processing plant and screening/ landscaping required for any new quarry.
What is "openness". Does this have a time element as the opennes may be impacted for the duration of the operations but not as part of the restoration.
What are " very special circumstances". Is allocation in plan very special circumstances.
We support the statement that "minerals developments will be supported" in the Green Belt. However, the definition of development needs to be clear. Does this relate to extraction areas only or can this include extraction area and the associated processing plant and screening/ landscaping required for any new quarry.
What is "openness". Does this have a time element as the opennes may be impacted for the duration of the operations but not as part of the restoration.
What are " very special circumstances". Is allocation in plan very special circumstances.
Comment
Draft Nottinghamshire Minerals Local Plan
Question 10: What do you think of the draft policy approach regarding future aggregate provision?
Representation ID: 30958
Received: 22/09/2018
Respondent: Greenfield Associates
Agent: Greenfield Associates
Calculation of need and aggregate provision using 10year LAA average is flawed. This makes no allowance for future demand or the closure of sites. The policy will encourage the increased importation of minerals from adjacent counties - is this the desired policy of Nottinghamshire?
The 32.30mt provision for sand and gravel is considered a gross under-estimate due to future predicted major infrastructure (eg HS2) and the growing number of house building projects within the county.
Calculation of need and aggregate provision using 10year LAA average is flawed. This makes no allowance for future demand or the closure of sites. The policy will encourage the increased importation of minerals from adjacent counties - is this the desired policy of Nottinghamshire?
The 32.30mt provision for sand and gravel is considered a gross under-estimate due to future predicted major infrastructure (eg HS2) and the growing number of house building projects within the county.
Comment
Draft Nottinghamshire Minerals Local Plan
Question 11: What do you think of the draft site specific sand and gravel allocations?
Representation ID: 30959
Received: 22/09/2018
Respondent: Greenfield Associates
Agent: Greenfield Associates
We agree with the Policy MP2 and that site allocation site MP2s is the most suitable site to supply the Nottingham market in the most sustainable manner, given the size of the mineral deposit and the location of the site.
We agree with the Policy MP2 and that site allocation site MP2s is the most suitable site to supply the Nottingham market in the most sustainable manner, given the size of the mineral deposit and the location of the site.
Comment
Draft Nottinghamshire Minerals Local Plan
Question 12: What do you think of the draft site specific Sherwood Sandstone allocations?
Representation ID: 30960
Received: 22/09/2018
Respondent: Greenfield Associates
Agent: Greenfield Associates
We do not agree with Policy MP3 as there is no potential for an alternative/ additional sand sites to be developed over the plan period, where there is a clear need. Sand is becoming a much more scarcer resource across the UK and its uses as an industrial mineral, a mortar product and also as use in "fracking" will lead to even greater demand. Sand resources are spread across the north and east of Nottinghamshire thus there is great resource potential. Sand is becoming a regional product that is now transported over large distances.
We do not agree with Policy MP3 as there is no potential for an alternative/ additional sand sites to be developed over the plan period, where there is a clear need. Sand is becoming a much more scarcer resource across the UK and its uses as an industrial mineral, a mortar product and also as use in "fracking" will lead to even greater demand. Sand resources are spread across the north and east of Nottinghamshire thus there is great resource potential. Sand is becoming a regional product that is now transported over large distances.
Comment
Draft Nottinghamshire Minerals Local Plan
Question 25: What do you think of the draft policy wording for DM4: Protection and enhancement of biodiversity and geodiversity
Representation ID: 30961
Received: 22/09/2018
Respondent: Greenfield Associates
Agent: Greenfield Associates
For minerals development that have a direct impact on Local Wildlife Sites, a "need for and benefits of the development in that location outweigh the impacts". However for higher level sites (eg SSSI) the benefits need to be shown rather than a need.
Does an allocation within the Mineral Plan give a presumed need for a minerals development.?
For minerals development that have a direct impact on Local Wildlife Sites, a "need for and benefits of the development in that location outweigh the impacts". However for higher level sites (eg SSSI) the benefits need to be shown rather than a need.
Does an allocation within the Mineral Plan give a presumed need for a minerals development.?
Comment
Draft Nottinghamshire Minerals Local Plan
Question 26: What do you think of the draft policy wording for DM5: Landscape character
Representation ID: 30962
Received: 22/09/2018
Respondent: Greenfield Associates
Agent: Greenfield Associates
This Policy does not make a reference to Green Belt and openness when considering planting and landscape proposals for the operational phase of development or the final restoration.
This Policy does not make a reference to Green Belt and openness when considering planting and landscape proposals for the operational phase of development or the final restoration.
