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Thank you for consulting Lincolnshire County Council on the above document.
Having reviewed the Draft Minerals Local Plan, we wish to reiterate our concerns as set out in our previous response to your options consultation in January 2018, and our comments prior to this in relation to the Local Aggregate Assessment (October 2017).
The County Council is concerned that the continued reliance on 10-year average sales as a basis for future provision of Sand and Gravel over the plan period is not appropriate because it does not acknowledge the significant imbalance in imports/exports of sand and gravel that has developed between Nottinghamshire and Lincolnshire in recent years. This is relevant local information that should be taken into account in determining future demand for sand and gravel, in accordance with National Planning Practice Guidance.
As set out in our previous consultation response in January 2018, Nottinghamshire has become a significant net-importer of sand and gravel from Lincolnshire. It is considered that this has occurred in part as operators in the Trent Valley have rationalised their operations during and following the recession, focussing production in Lincolnshire and reducing operations temporarily in Nottinghamshire. To therefore base future provision in Nottinghamshire solely on its resultant deflated sales figures is fundamentally flawed as it fails to account for the underlying demand within Nottinghamshire which has been temporarily met by imports from Lincolnshire, and in turn puts undue pressure on mineral resources within Lincolnshire. Indeed, as set out in our previous response, a continued reliance on imports from Lincolnshire could lead to supply issues during the plan period if quarries in Lincolnshire are unable to meet any increased demand from shortfalls in Nottinghamshire.
As acknowledged within your Draft Plan (Para 4.7 and Para 4.15) Nottinghamshire has a substantial Sand and Gravel Resource, and traditionally has been one of the primary contributors within the East Midlands. Although now outdated, the last published national Guidelines in 2009, and their subsequent apportionment at regional level illustrated the importance of Nottinghamshire's contribution, with a Sand and Gravel apportionment of 3.25 million tonnes per annum (2005-2020) - excluding the Sherwood Sandstone. There is therefore no clear justification for why Nottinghamshire cannot allocate sufficient Sand and Gravel resources to meet its future requirements, rather than relying on sales data which infers a continued reliance on imports from Lincolnshire. It is considered that this approach is at odds with the vision in the Draft Plan which states "Nottinghamshire will continue to provide minerals to meet its share of local and national needs". Furthermore, paragraph 204 of the NPPF states, amongst other things, that policies in mineral local plans should aim to source mineral supplies indigenously.
Furthermore it is considered that there are no clear supply-based barriers to the provision of additional sand and gravel sites within Nottinghamshire. The Feb/March 2016 submission draft of the previous (subsequently withdrawn) Minerals Local Plan proposed to allocate a significantly larger number of sand and gravel sites over the plan period to meet a higher provision rate (10 Extensions and 5 New Sites, compared to 6 Extensions and 2 New sites in the current Draft Plan). It is therefore considered that there are a substantial number of additional sites available that the Authority has previously considered deliverable and suitable for allocation.
Para 4.13 of your Draft Plan states "The average production figures set out in the LAA will be compared against the permitted reserves of aggregates to monitor the level of the landbanks". We have two concerns with this approach. Firstly, the local Plan is effectively prejudging the basis on which future LAAs will forecast future demand. Secondly, the use of a deflated 10 year average sales figure does not reflect local demand and would serve to artificially inflate land bank calculations, limiting the ability of the Plan to respond quickly to increased demand. Whilst it is acknowledged that some of the proposed allocations in the Draft Minerals Local Plan include reserves that extend beyond the plan period, it is not considered that this presents a suitable buffer to accommodate any increases in sales to address local demand. This is because the productive capacity of allocated sites is likely to be insufficient given that allocated provision is proposed to be based on deflated annual outputs. Allocating additional sites based on increased provision would allow greater productive capacity and allow sales to increase to meet local demand, in turn reducing the reliance on imports from Lincolnshire for which there is no apparent justification.
Accordingly, the County Council maintains its objection to the proposed provision and suggests additional provision should be made to ensure Nottinghamshire meets local demand and provides its share of overall provision within the East Midlands.
