Draft Nottinghamshire Minerals Local Plan

Draft Nottinghamshire Minerals Local Plan
Response from Thrumpton Parish Meeting - September 2018
Summary
1. Thrumpton Parish Meeting objects to the Draft Nottinghamshire Minerals Local Plan published in July 2018, and, in particular, to the inclusion of the site MP2s at Mill Hill nr Barton in Fabis.
2. In summary our objection is based on:
a) The identification of flaws in the analysis of issues and options that underpin the Draft Plan, and in particular the identification of geographical spread as a key factor determining site allocation.
b) The application of a rationale for the allocation of sites which is inconsistent with the strategic objectives that have been used to shape the Draft Plan.
c) The allocation of the site at Mill Hill, Barton in Fabis even though the NCCs own analysis shows it to be one of the most damaging developments for sand and gravel of those considered. Such an allocation is inconsistent with the strategic objectives set out in the plan and the strategic policy for sustainable development and planning requirements set out in the National Planning Policy Framework that should underpin it.
d) The process by which the draft plan has been formulated is flawed, and the recommendations in relation to Mill Hill nr Barton in Fabis are therefore unsound. The analysis of the site listed variously as Barton in Fabis or Barton in Fabis (west) is also inaccurate, seriously under-rating its potential impact on local residents. The revised Draft Minerals Plan does not therefore meet the standard of evidence-based planning that is to be expected in the minerals planning process.
The detailed reasoning for these objections is set out in the response from Barton in Fabis Parish Council which we would ask you to make reference to. We will summarise our position and our objections in this response.
Response to Consultation Questions
Question 1: What do you think to the draft vision and strategic objectives set out in the plan?
Question 2: What do you think of the draft strategic policy for sustainable development?
Question 3: What do you think to the draft strategic policy for minerals provision?
We object to the way in which the plan fails to adhere to the strategic objectives set out in 2.30 rather than to the objectives themselves. In particular, SO6 'Protecting and enhancing natural assets' states that an objective is to 'Conserve and enhance Nottinghamshire's natural environment, including its distinctive landscapes, habitats, geology, wildlife species and ecological health of water bodies by avoiding, minimising and mitigating potential

negative impacts.' The Plan has then allocated sites with the greatest environmental impact simply on grounds of size and location - even though nether size nor location appear as strategic objectives. The site allocation process is therefore flawed.
We therefore object to the plan on grounds that the site allocation methodology developed and applied is inconsistent with the strategic objectives of the strategic policy for minerals provision.
Question 4 What do you think of the draft strategic policy for biodiversity led restoration?
We object to the plan on grounds that the policy for biodiversity-led restoration is inadequate. Its application as a criteria for site allocation is flawed because it does not meaningfully discriminate between proposals in terms of the likely success of biodiversity-led restoration.
Question 6: What do you think of the draft strategic policy for sustainable transport?
We object to the Plan and the policy related to sustainable transport because we feel that It is not the function of the planning system to manipulate the geography of the market and associated commercial risk, but rather to ensure that development is appropriate and sustainable, given wider societal needs and requirements. The policy on sustainable transport needs to reflect this. One such requirement, for example, is the use of modes of transport other than road. Another is that the most vulnerable and valuable sites are protected notwithstanding their proximity to market.
Question 7: What do you think of the draft strategic policy for the built, historic and natural environment?
We object to the formulation of Policy SP6 because of the lack of transparency in the way it is applied in the site allocation process. The emphasis on restoration should be reduced and the importance of protection and maintenance of assets should be stressed.
Question 8: What do you think of the draft strategic policy for the Nottinghamshire Green Belt?
Policy SP7 is not transparent in that it fails to state how, in the context of minerals planning, the two tests of 'appropriateness' and 'special circumstances' will be applied. It should be noted that 'special circumstances' in relation to the Green Belt do not include supposed proximity to market or goals of developing a 'spatially sustainable distribution' of minerals sites.
We therefore object to the policy statement on green belt because it lacks any clear indication of how it is to be applied in the minerals planning process.

Question 11: What do you think of the draft site specific sand and gravel allocations?
We object to the application of the site Draft Selection Methodology and its conclusions on grounds of the inconsistency of its outcomes with the stated policy objectives that are stated as underpinning the Draft Plan.
The Draft Plan is therefore flawed and should be revised accordingly to meet the County's own sustainability objectives. In order to do so:
* sites should be considered on their own merits to minimise the likely overall environmental impacts of the Draft Plan;
* geographical spread should only be used to make decisions between sites when all other things are considered equal in order that it does not over-ride consideration of the scale of environmental damage likely to arise by the inappropriate selection of sites due to location. Proximity to market is not an 'exceptional circumstance' as envisaged by the NPPF.
Site at Mill Hill nr Barton in Fabis
We believe the scale of the impacts for the Mill Hill site have been under-estimated, making the decision insecure. We therefore object to the assessment made for the Mill Hill site.
The allocation of the site is not consistent with the objectives of SO6 or SP6. The landscape impacts are amongst the highest attributed to any site in the appraisal matrix, the allocation of this site in the Draft Plan is clearly inconsistent with Policy SP6.
The impact of the proposed development on the greenbelt also conflicts with the stated policy in SP6, because the processing plant will be located on a prominent ridgeline on Mill Hill. This will have an adverse impact on the openness and visual amenity of the Green Belt in this area. It will therefore conflict with the purposes of the Green Belt and should consequently be considered inappropriate development.
The bridleway passing through and near the site is part of the Trent Valley Way and is an important strategic route between Barton and Thrumpton in the county and Clifton and Wilford in the city which is extremely well-used by walkers, cyclists, and horseriders. The path will be close to quarry workings and will have to cross the site access road and gravel conveyor - this will have a major negative impact on users.
Just a river's width away from the site, those who walk Attenborough's riverside paths will continually view the adverse effects of the site over the lengthy operational period and will no longer be able to enjoy the peace and tranquillity of Attenborough Nature Reserve - a site of special scientific interest (SSSI) and one of the most important sites for conservation in the East Midlands. The noise and dust will have a negative impact on wildlife in the reserve.
The impacts are very negative in both the operational phase and the long-term operation and clearly inconsistent with most of the key sustainability objectives and strategic policies that frame the minerals plan. There is a lack of transparency in the assessment in terms of how the site is allocated on the grounds of viability and location when the impact assessment clearly indicates that there are other sites where impacts are far less serious.
The process by which the recommendation arose is flawed, and neither transparent or credible given even the partial evidence-base identified in the Draft Plan.

We therefore object to the allocation of the Mill Hill site.
Our main concerns with the allocation of the site are as follows:
* The Council's own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the third most damaging in the long-term.
* The Council has stated that "there is no published data related to geographical spread". Therefore, the Plan is 'unsound' as the Council has sought to justify the inclusion of the site based on "maintaining a geographical spread" and therefore overriding the adverse impact on sustainability.
* There have been no projections for sand and gravel demand in the different submarket areas. The Council's statement that the Shelford or Coddington sites are too big cannot be justified
* The Council has failed to follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" by not allocating any sites which use this mode of transport.
* The site would impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five Local Wildlife Sites one of which will be destroyed altogether.
* Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site - providing significant evidence of the negative impact on wildlife and the environment.
* The site is in the Green Belt, and 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 Council has failed to justify any "wholly exceptional reasons" required by the NPPF.
* The site is close to heavily populated areas - including the new Fairham Pastures development of 3,000 homes - which would be impacted by noise and dust from the site itself and from the extensive lorry movements.
* This plan generates 114 lorry movements a day on the section of Green Street adjoining Mill Hill. This was approved in the A453 dualling plans as being part of a route for non-motorised users, but this number of lorry movements is not compatible with safe cycling, walking or horse riding. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down. This number of lorry movements would make this junction even more hazardous.
* 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, cycling, 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 residents.

Site described as Barton in Fabis or Barton in Fabis (west)
We are also concerned about inaccuracies in the analysis of the site included in the 'Draft site selection methodology and assessment July 2018' and listed as Barton in Fabis or Barton in Fabis (west). Although this site has not been selected, this site assessment may be further used following the outcomes of this consultation and possibly as evidence for future mineral plans or planning applications, we therefore believe it is crucial that the information is reassessed and corrected.
Our main concerns are as follows:
Site location
This site is actually in the parish of Thrumpton and, as a consequence, was not immediately evident to residents of Thrumpton as being in such close proximity to the village. The site should be renamed to include Thrumpton to make its location clear.
Sustainability assessment
The assessment of visual sensitivity states:
The main visual impact would be on residents to the southern edge of Barton in Fabis and on users of the Trent Valley Way to the north of the site. There would be more distant views from residential properties on the northern edge of Thrumpton.
In reality, around 50% of Thrumpton properties would have a clear view of the site - these would not be 'distant views' as the site would be within 400-800 metres. The site would also be highly visible from the A453. Crucially, three properties (Fields Farm, The Orchard and Canterbury House) directly adjoin the site yet criteria 14 'Protect and improve human health and quality of life' makes no reference to the close-proximity of these properties and the assessment gives no consideration to the drastic impact (including noise, dust, traffic movement, visual amenity, property value) on these properties and their residents. Lack of reference to such an important factor indicates an inadequate assessment process.
Transport/highway implications
The Transport Evidence Base states that the Annual Average Daily Flow of HGVs on Green Street/Barton Lane is 15 and would be increased by 90 additional lorry movements per day - an increase of 600%. It dismisses this by stating that "Percentage changes in traffic on Green Street would be high, but this is mainly a result of this route being bypassed by the A453 leaving only low residual traffic flows." It also states that "once onto Green Street the route to the A453 is short."
In reality it is 1.8 miles on a road clearly approved and designated as part of the A453 dualling scheme as a route for non-motorised users linking Mill Hill to Long Lane. This number of lorry movements is simply not compatible with safe cycling, walking or horse riding on a road where there is no traffic separation. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down and this number of lorry movements would make this junction even more hazardous. The report's conclusion that No road safety issues identified is therefore flawed, inaccurate and highly misleading.

Conclusion
We object to a number of aspects of the Draft Plan as set out above.
The evidence for the Mill Hill nr Barton in Fabis site - one of the most environmentally sensitive sites in the assessment (and rejected on these grounds previously by the Council) - does not support its selection.
We believe the criteria and the process used were flawed. The inaccuracies in the assessment of Barton in Fabis (west) raise further questions about the robustness of the assessment process.

Draft Nottinghamshire Minerals Local Plan
Response from Thrumpton Parish Meeting - September 2018
Summary
1. Thrumpton Parish Meeting objects to the Draft Nottinghamshire Minerals Local Plan published in July 2018, and, in particular, to the inclusion of the site MP2s at Mill Hill nr Barton in Fabis.
2. In summary our objection is based on:
a) The identification of flaws in the analysis of issues and options that underpin the Draft Plan, and in particular the identification of geographical spread as a key factor determining site allocation.
b) The application of a rationale for the allocation of sites which is inconsistent with the strategic objectives that have been used to shape the Draft Plan.
c) The allocation of the site at Mill Hill, Barton in Fabis even though the NCCs own analysis shows it to be one of the most damaging developments for sand and gravel of those considered. Such an allocation is inconsistent with the strategic objectives set out in the plan and the strategic policy for sustainable development and planning requirements set out in the National Planning Policy Framework that should underpin it.
d) The process by which the draft plan has been formulated is flawed, and the recommendations in relation to Mill Hill nr Barton in Fabis are therefore unsound. The analysis of the site listed variously as Barton in Fabis or Barton in Fabis (west) is also inaccurate, seriously under-rating its potential impact on local residents. The revised Draft Minerals Plan does not therefore meet the standard of evidence-based planning that is to be expected in the minerals planning process.
The detailed reasoning for these objections is set out in the response from Barton in Fabis Parish Council which we would ask you to make reference to. We will summarise our position and our objections in this response.
Response to Consultation Questions
Question 1: What do you think to the draft vision and strategic objectives set out in the plan?
Question 2: What do you think of the draft strategic policy for sustainable development?
Question 3: What do you think to the draft strategic policy for minerals provision?
We object to the way in which the plan fails to adhere to the strategic objectives set out in 2.30 rather than to the objectives themselves. In particular, SO6 'Protecting and enhancing natural assets' states that an objective is to 'Conserve and enhance Nottinghamshire's natural environment, including its distinctive landscapes, habitats, geology, wildlife species and ecological health of water bodies by avoiding, minimising and mitigating potential

negative impacts.' The Plan has then allocated sites with the greatest environmental impact simply on grounds of size and location - even though nether size nor location appear as strategic objectives. The site allocation process is therefore flawed.
We therefore object to the plan on grounds that the site allocation methodology developed and applied is inconsistent with the strategic objectives of the strategic policy for minerals provision.
Question 4 What do you think of the draft strategic policy for biodiversity led restoration?
We object to the plan on grounds that the policy for biodiversity-led restoration is inadequate. Its application as a criteria for site allocation is flawed because it does not meaningfully discriminate between proposals in terms of the likely success of biodiversity-led restoration.
Question 6: What do you think of the draft strategic policy for sustainable transport?
We object to the Plan and the policy related to sustainable transport because we feel that It is not the function of the planning system to manipulate the geography of the market and associated commercial risk, but rather to ensure that development is appropriate and sustainable, given wider societal needs and requirements. The policy on sustainable transport needs to reflect this. One such requirement, for example, is the use of modes of transport other than road. Another is that the most vulnerable and valuable sites are protected notwithstanding their proximity to market.
Question 7: What do you think of the draft strategic policy for the built, historic and natural environment?
We object to the formulation of Policy SP6 because of the lack of transparency in the way it is applied in the site allocation process. The emphasis on restoration should be reduced and the importance of protection and maintenance of assets should be stressed.
Question 8: What do you think of the draft strategic policy for the Nottinghamshire Green Belt?
Policy SP7 is not transparent in that it fails to state how, in the context of minerals planning, the two tests of 'appropriateness' and 'special circumstances' will be applied. It should be noted that 'special circumstances' in relation to the Green Belt do not include supposed proximity to market or goals of developing a 'spatially sustainable distribution' of minerals sites.
We therefore object to the policy statement on green belt because it lacks any clear indication of how it is to be applied in the minerals planning process.

Question 11: What do you think of the draft site specific sand and gravel allocations?
We object to the application of the site Draft Selection Methodology and its conclusions on grounds of the inconsistency of its outcomes with the stated policy objectives that are stated as underpinning the Draft Plan.
The Draft Plan is therefore flawed and should be revised accordingly to meet the County's own sustainability objectives. In order to do so:
* sites should be considered on their own merits to minimise the likely overall environmental impacts of the Draft Plan;
* geographical spread should only be used to make decisions between sites when all other things are considered equal in order that it does not over-ride consideration of the scale of environmental damage likely to arise by the inappropriate selection of sites due to location. Proximity to market is not an 'exceptional circumstance' as envisaged by the NPPF.
Site at Mill Hill nr Barton in Fabis
We believe the scale of the impacts for the Mill Hill site have been under-estimated, making the decision insecure. We therefore object to the assessment made for the Mill Hill site.
The allocation of the site is not consistent with the objectives of SO6 or SP6. The landscape impacts are amongst the highest attributed to any site in the appraisal matrix, the allocation of this site in the Draft Plan is clearly inconsistent with Policy SP6.
The impact of the proposed development on the greenbelt also conflicts with the stated policy in SP6, because the processing plant will be located on a prominent ridgeline on Mill Hill. This will have an adverse impact on the openness and visual amenity of the Green Belt in this area. It will therefore conflict with the purposes of the Green Belt and should consequently be considered inappropriate development.
The bridleway passing through and near the site is part of the Trent Valley Way and is an important strategic route between Barton and Thrumpton in the county and Clifton and Wilford in the city which is extremely well-used by walkers, cyclists, and horseriders. The path will be close to quarry workings and will have to cross the site access road and gravel conveyor - this will have a major negative impact on users.
Just a river's width away from the site, those who walk Attenborough's riverside paths will continually view the adverse effects of the site over the lengthy operational period and will no longer be able to enjoy the peace and tranquillity of Attenborough Nature Reserve - a site of special scientific interest (SSSI) and one of the most important sites for conservation in the East Midlands. The noise and dust will have a negative impact on wildlife in the reserve.
The impacts are very negative in both the operational phase and the long-term operation and clearly inconsistent with most of the key sustainability objectives and strategic policies that frame the minerals plan. There is a lack of transparency in the assessment in terms of how the site is allocated on the grounds of viability and location when the impact assessment clearly indicates that there are other sites where impacts are far less serious.
The process by which the recommendation arose is flawed, and neither transparent or credible given even the partial evidence-base identified in the Draft Plan.

We therefore object to the allocation of the Mill Hill site.
Our main concerns with the allocation of the site are as follows:
* The Council's own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the third most damaging in the long-term.
* The Council has stated that "there is no published data related to geographical spread". Therefore, the Plan is 'unsound' as the Council has sought to justify the inclusion of the site based on "maintaining a geographical spread" and therefore overriding the adverse impact on sustainability.
* There have been no projections for sand and gravel demand in the different submarket areas. The Council's statement that the Shelford or Coddington sites are too big cannot be justified
* The Council has failed to follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" by not allocating any sites which use this mode of transport.
* The site would impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five Local Wildlife Sites one of which will be destroyed altogether.
* Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site - providing significant evidence of the negative impact on wildlife and the environment.
* The site is in the Green Belt, and 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 Council has failed to justify any "wholly exceptional reasons" required by the NPPF.
* The site is close to heavily populated areas - including the new Fairham Pastures development of 3,000 homes - which would be impacted by noise and dust from the site itself and from the extensive lorry movements.
* This plan generates 114 lorry movements a day on the section of Green Street adjoining Mill Hill. This was approved in the A453 dualling plans as being part of a route for non-motorised users, but this number of lorry movements is not compatible with safe cycling, walking or horse riding. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down. This number of lorry movements would make this junction even more hazardous.
* 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, cycling, 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 residents.

Site described as Barton in Fabis or Barton in Fabis (west)
We are also concerned about inaccuracies in the analysis of the site included in the 'Draft site selection methodology and assessment July 2018' and listed as Barton in Fabis or Barton in Fabis (west). Although this site has not been selected, this site assessment may be further used following the outcomes of this consultation and possibly as evidence for future mineral plans or planning applications, we therefore believe it is crucial that the information is reassessed and corrected.
Our main concerns are as follows:
Site location
This site is actually in the parish of Thrumpton and, as a consequence, was not immediately evident to residents of Thrumpton as being in such close proximity to the village. The site should be renamed to include Thrumpton to make its location clear.
Sustainability assessment
The assessment of visual sensitivity states:
The main visual impact would be on residents to the southern edge of Barton in Fabis and on users of the Trent Valley Way to the north of the site. There would be more distant views from residential properties on the northern edge of Thrumpton.
In reality, around 50% of Thrumpton properties would have a clear view of the site - these would not be 'distant views' as the site would be within 400-800 metres. The site would also be highly visible from the A453. Crucially, three properties (Fields Farm, The Orchard and Canterbury House) directly adjoin the site yet criteria 14 'Protect and improve human health and quality of life' makes no reference to the close-proximity of these properties and the assessment gives no consideration to the drastic impact (including noise, dust, traffic movement, visual amenity, property value) on these properties and their residents. Lack of reference to such an important factor indicates an inadequate assessment process.
Transport/highway implications
The Transport Evidence Base states that the Annual Average Daily Flow of HGVs on Green Street/Barton Lane is 15 and would be increased by 90 additional lorry movements per day - an increase of 600%. It dismisses this by stating that "Percentage changes in traffic on Green Street would be high, but this is mainly a result of this route being bypassed by the A453 leaving only low residual traffic flows." It also states that "once onto Green Street the route to the A453 is short."
In reality it is 1.8 miles on a road clearly approved and designated as part of the A453 dualling scheme as a route for non-motorised users linking Mill Hill to Long Lane. This number of lorry movements is simply not compatible with safe cycling, walking or horse riding on a road where there is no traffic separation. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down and this number of lorry movements would make this junction even more hazardous. The report's conclusion that No road safety issues identified is therefore flawed, inaccurate and highly misleading.

Conclusion
We object to a number of aspects of the Draft Plan as set out above.
The evidence for the Mill Hill nr Barton in Fabis site - one of the most environmentally sensitive sites in the assessment (and rejected on these grounds previously by the Council) - does not support its selection.
We believe the criteria and the process used were flawed. The inaccuracies in the assessment of Barton in Fabis (west) raise further questions about the robustness of the assessment process.

Draft Nottinghamshire Minerals Local Plan
Response from Thrumpton Parish Meeting - September 2018
Summary
1. Thrumpton Parish Meeting objects to the Draft Nottinghamshire Minerals Local Plan published in July 2018, and, in particular, to the inclusion of the site MP2s at Mill Hill nr Barton in Fabis.
2. In summary our objection is based on:
a) The identification of flaws in the analysis of issues and options that underpin the Draft Plan, and in particular the identification of geographical spread as a key factor determining site allocation.
b) The application of a rationale for the allocation of sites which is inconsistent with the strategic objectives that have been used to shape the Draft Plan.
c) The allocation of the site at Mill Hill, Barton in Fabis even though the NCCs own analysis shows it to be one of the most damaging developments for sand and gravel of those considered. Such an allocation is inconsistent with the strategic objectives set out in the plan and the strategic policy for sustainable development and planning requirements set out in the National Planning Policy Framework that should underpin it.
d) The process by which the draft plan has been formulated is flawed, and the recommendations in relation to Mill Hill nr Barton in Fabis are therefore unsound. The analysis of the site listed variously as Barton in Fabis or Barton in Fabis (west) is also inaccurate, seriously under-rating its potential impact on local residents. The revised Draft Minerals Plan does not therefore meet the standard of evidence-based planning that is to be expected in the minerals planning process.
The detailed reasoning for these objections is set out in the response from Barton in Fabis Parish Council which we would ask you to make reference to. We will summarise our position and our objections in this response.
Response to Consultation Questions
Question 1: What do you think to the draft vision and strategic objectives set out in the plan?
Question 2: What do you think of the draft strategic policy for sustainable development?
Question 3: What do you think to the draft strategic policy for minerals provision?
We object to the way in which the plan fails to adhere to the strategic objectives set out in 2.30 rather than to the objectives themselves. In particular, SO6 'Protecting and enhancing natural assets' states that an objective is to 'Conserve and enhance Nottinghamshire's natural environment, including its distinctive landscapes, habitats, geology, wildlife species and ecological health of water bodies by avoiding, minimising and mitigating potential

negative impacts.' The Plan has then allocated sites with the greatest environmental impact simply on grounds of size and location - even though nether size nor location appear as strategic objectives. The site allocation process is therefore flawed.
We therefore object to the plan on grounds that the site allocation methodology developed and applied is inconsistent with the strategic objectives of the strategic policy for minerals provision.
Question 4 What do you think of the draft strategic policy for biodiversity led restoration?
We object to the plan on grounds that the policy for biodiversity-led restoration is inadequate. Its application as a criteria for site allocation is flawed because it does not meaningfully discriminate between proposals in terms of the likely success of biodiversity-led restoration.
Question 6: What do you think of the draft strategic policy for sustainable transport?
We object to the Plan and the policy related to sustainable transport because we feel that It is not the function of the planning system to manipulate the geography of the market and associated commercial risk, but rather to ensure that development is appropriate and sustainable, given wider societal needs and requirements. The policy on sustainable transport needs to reflect this. One such requirement, for example, is the use of modes of transport other than road. Another is that the most vulnerable and valuable sites are protected notwithstanding their proximity to market.
Question 7: What do you think of the draft strategic policy for the built, historic and natural environment?
We object to the formulation of Policy SP6 because of the lack of transparency in the way it is applied in the site allocation process. The emphasis on restoration should be reduced and the importance of protection and maintenance of assets should be stressed.
Question 8: What do you think of the draft strategic policy for the Nottinghamshire Green Belt?
Policy SP7 is not transparent in that it fails to state how, in the context of minerals planning, the two tests of 'appropriateness' and 'special circumstances' will be applied. It should be noted that 'special circumstances' in relation to the Green Belt do not include supposed proximity to market or goals of developing a 'spatially sustainable distribution' of minerals sites.
We therefore object to the policy statement on green belt because it lacks any clear indication of how it is to be applied in the minerals planning process.

Question 11: What do you think of the draft site specific sand and gravel allocations?
We object to the application of the site Draft Selection Methodology and its conclusions on grounds of the inconsistency of its outcomes with the stated policy objectives that are stated as underpinning the Draft Plan.
The Draft Plan is therefore flawed and should be revised accordingly to meet the County's own sustainability objectives. In order to do so:
* sites should be considered on their own merits to minimise the likely overall environmental impacts of the Draft Plan;
* geographical spread should only be used to make decisions between sites when all other things are considered equal in order that it does not over-ride consideration of the scale of environmental damage likely to arise by the inappropriate selection of sites due to location. Proximity to market is not an 'exceptional circumstance' as envisaged by the NPPF.
Site at Mill Hill nr Barton in Fabis
We believe the scale of the impacts for the Mill Hill site have been under-estimated, making the decision insecure. We therefore object to the assessment made for the Mill Hill site.
The allocation of the site is not consistent with the objectives of SO6 or SP6. The landscape impacts are amongst the highest attributed to any site in the appraisal matrix, the allocation of this site in the Draft Plan is clearly inconsistent with Policy SP6.
The impact of the proposed development on the greenbelt also conflicts with the stated policy in SP6, because the processing plant will be located on a prominent ridgeline on Mill Hill. This will have an adverse impact on the openness and visual amenity of the Green Belt in this area. It will therefore conflict with the purposes of the Green Belt and should consequently be considered inappropriate development.
The bridleway passing through and near the site is part of the Trent Valley Way and is an important strategic route between Barton and Thrumpton in the county and Clifton and Wilford in the city which is extremely well-used by walkers, cyclists, and horseriders. The path will be close to quarry workings and will have to cross the site access road and gravel conveyor - this will have a major negative impact on users.
Just a river's width away from the site, those who walk Attenborough's riverside paths will continually view the adverse effects of the site over the lengthy operational period and will no longer be able to enjoy the peace and tranquillity of Attenborough Nature Reserve - a site of special scientific interest (SSSI) and one of the most important sites for conservation in the East Midlands. The noise and dust will have a negative impact on wildlife in the reserve.
The impacts are very negative in both the operational phase and the long-term operation and clearly inconsistent with most of the key sustainability objectives and strategic policies that frame the minerals plan. There is a lack of transparency in the assessment in terms of how the site is allocated on the grounds of viability and location when the impact assessment clearly indicates that there are other sites where impacts are far less serious.
The process by which the recommendation arose is flawed, and neither transparent or credible given even the partial evidence-base identified in the Draft Plan.

We therefore object to the allocation of the Mill Hill site.
Our main concerns with the allocation of the site are as follows:
* The Council's own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the third most damaging in the long-term.
* The Council has stated that "there is no published data related to geographical spread". Therefore, the Plan is 'unsound' as the Council has sought to justify the inclusion of the site based on "maintaining a geographical spread" and therefore overriding the adverse impact on sustainability.
* There have been no projections for sand and gravel demand in the different submarket areas. The Council's statement that the Shelford or Coddington sites are too big cannot be justified
* The Council has failed to follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" by not allocating any sites which use this mode of transport.
* The site would impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five Local Wildlife Sites one of which will be destroyed altogether.
* Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site - providing significant evidence of the negative impact on wildlife and the environment.
* The site is in the Green Belt, and 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 Council has failed to justify any "wholly exceptional reasons" required by the NPPF.
* The site is close to heavily populated areas - including the new Fairham Pastures development of 3,000 homes - which would be impacted by noise and dust from the site itself and from the extensive lorry movements.
* This plan generates 114 lorry movements a day on the section of Green Street adjoining Mill Hill. This was approved in the A453 dualling plans as being part of a route for non-motorised users, but this number of lorry movements is not compatible with safe cycling, walking or horse riding. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down. This number of lorry movements would make this junction even more hazardous.
* 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, cycling, 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 residents.

Site described as Barton in Fabis or Barton in Fabis (west)
We are also concerned about inaccuracies in the analysis of the site included in the 'Draft site selection methodology and assessment July 2018' and listed as Barton in Fabis or Barton in Fabis (west). Although this site has not been selected, this site assessment may be further used following the outcomes of this consultation and possibly as evidence for future mineral plans or planning applications, we therefore believe it is crucial that the information is reassessed and corrected.
Our main concerns are as follows:
Site location
This site is actually in the parish of Thrumpton and, as a consequence, was not immediately evident to residents of Thrumpton as being in such close proximity to the village. The site should be renamed to include Thrumpton to make its location clear.
Sustainability assessment
The assessment of visual sensitivity states:
The main visual impact would be on residents to the southern edge of Barton in Fabis and on users of the Trent Valley Way to the north of the site. There would be more distant views from residential properties on the northern edge of Thrumpton.
In reality, around 50% of Thrumpton properties would have a clear view of the site - these would not be 'distant views' as the site would be within 400-800 metres. The site would also be highly visible from the A453. Crucially, three properties (Fields Farm, The Orchard and Canterbury House) directly adjoin the site yet criteria 14 'Protect and improve human health and quality of life' makes no reference to the close-proximity of these properties and the assessment gives no consideration to the drastic impact (including noise, dust, traffic movement, visual amenity, property value) on these properties and their residents. Lack of reference to such an important factor indicates an inadequate assessment process.
Transport/highway implications
The Transport Evidence Base states that the Annual Average Daily Flow of HGVs on Green Street/Barton Lane is 15 and would be increased by 90 additional lorry movements per day - an increase of 600%. It dismisses this by stating that "Percentage changes in traffic on Green Street would be high, but this is mainly a result of this route being bypassed by the A453 leaving only low residual traffic flows." It also states that "once onto Green Street the route to the A453 is short."
In reality it is 1.8 miles on a road clearly approved and designated as part of the A453 dualling scheme as a route for non-motorised users linking Mill Hill to Long Lane. This number of lorry movements is simply not compatible with safe cycling, walking or horse riding on a road where there is no traffic separation. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down and this number of lorry movements would make this junction even more hazardous. The report's conclusion that No road safety issues identified is therefore flawed, inaccurate and highly misleading.

Conclusion
We object to a number of aspects of the Draft Plan as set out above.
The evidence for the Mill Hill nr Barton in Fabis site - one of the most environmentally sensitive sites in the assessment (and rejected on these grounds previously by the Council) - does not support its selection.
We believe the criteria and the process used were flawed. The inaccuracies in the assessment of Barton in Fabis (west) raise further questions about the robustness of the assessment process.

Draft Nottinghamshire Minerals Local Plan
Response from Thrumpton Parish Meeting - September 2018
Summary
1. Thrumpton Parish Meeting objects to the Draft Nottinghamshire Minerals Local Plan published in July 2018, and, in particular, to the inclusion of the site MP2s at Mill Hill nr Barton in Fabis.
2. In summary our objection is based on:
a) The identification of flaws in the analysis of issues and options that underpin the Draft Plan, and in particular the identification of geographical spread as a key factor determining site allocation.
b) The application of a rationale for the allocation of sites which is inconsistent with the strategic objectives that have been used to shape the Draft Plan.
c) The allocation of the site at Mill Hill, Barton in Fabis even though the NCCs own analysis shows it to be one of the most damaging developments for sand and gravel of those considered. Such an allocation is inconsistent with the strategic objectives set out in the plan and the strategic policy for sustainable development and planning requirements set out in the National Planning Policy Framework that should underpin it.
d) The process by which the draft plan has been formulated is flawed, and the recommendations in relation to Mill Hill nr Barton in Fabis are therefore unsound. The analysis of the site listed variously as Barton in Fabis or Barton in Fabis (west) is also inaccurate, seriously under-rating its potential impact on local residents. The revised Draft Minerals Plan does not therefore meet the standard of evidence-based planning that is to be expected in the minerals planning process.
The detailed reasoning for these objections is set out in the response from Barton in Fabis Parish Council which we would ask you to make reference to. We will summarise our position and our objections in this response.
Response to Consultation Questions
Question 1: What do you think to the draft vision and strategic objectives set out in the plan?
Question 2: What do you think of the draft strategic policy for sustainable development?
Question 3: What do you think to the draft strategic policy for minerals provision?
We object to the way in which the plan fails to adhere to the strategic objectives set out in 2.30 rather than to the objectives themselves. In particular, SO6 'Protecting and enhancing natural assets' states that an objective is to 'Conserve and enhance Nottinghamshire's natural environment, including its distinctive landscapes, habitats, geology, wildlife species and ecological health of water bodies by avoiding, minimising and mitigating potential

negative impacts.' The Plan has then allocated sites with the greatest environmental impact simply on grounds of size and location - even though nether size nor location appear as strategic objectives. The site allocation process is therefore flawed.
We therefore object to the plan on grounds that the site allocation methodology developed and applied is inconsistent with the strategic objectives of the strategic policy for minerals provision.
Question 4 What do you think of the draft strategic policy for biodiversity led restoration?
We object to the plan on grounds that the policy for biodiversity-led restoration is inadequate. Its application as a criteria for site allocation is flawed because it does not meaningfully discriminate between proposals in terms of the likely success of biodiversity-led restoration.
Question 6: What do you think of the draft strategic policy for sustainable transport?
We object to the Plan and the policy related to sustainable transport because we feel that It is not the function of the planning system to manipulate the geography of the market and associated commercial risk, but rather to ensure that development is appropriate and sustainable, given wider societal needs and requirements. The policy on sustainable transport needs to reflect this. One such requirement, for example, is the use of modes of transport other than road. Another is that the most vulnerable and valuable sites are protected notwithstanding their proximity to market.
Question 7: What do you think of the draft strategic policy for the built, historic and natural environment?
We object to the formulation of Policy SP6 because of the lack of transparency in the way it is applied in the site allocation process. The emphasis on restoration should be reduced and the importance of protection and maintenance of assets should be stressed.
Question 8: What do you think of the draft strategic policy for the Nottinghamshire Green Belt?
Policy SP7 is not transparent in that it fails to state how, in the context of minerals planning, the two tests of 'appropriateness' and 'special circumstances' will be applied. It should be noted that 'special circumstances' in relation to the Green Belt do not include supposed proximity to market or goals of developing a 'spatially sustainable distribution' of minerals sites.
We therefore object to the policy statement on green belt because it lacks any clear indication of how it is to be applied in the minerals planning process.

Question 11: What do you think of the draft site specific sand and gravel allocations?
We object to the application of the site Draft Selection Methodology and its conclusions on grounds of the inconsistency of its outcomes with the stated policy objectives that are stated as underpinning the Draft Plan.
The Draft Plan is therefore flawed and should be revised accordingly to meet the County's own sustainability objectives. In order to do so:
* sites should be considered on their own merits to minimise the likely overall environmental impacts of the Draft Plan;
* geographical spread should only be used to make decisions between sites when all other things are considered equal in order that it does not over-ride consideration of the scale of environmental damage likely to arise by the inappropriate selection of sites due to location. Proximity to market is not an 'exceptional circumstance' as envisaged by the NPPF.
Site at Mill Hill nr Barton in Fabis
We believe the scale of the impacts for the Mill Hill site have been under-estimated, making the decision insecure. We therefore object to the assessment made for the Mill Hill site.
The allocation of the site is not consistent with the objectives of SO6 or SP6. The landscape impacts are amongst the highest attributed to any site in the appraisal matrix, the allocation of this site in the Draft Plan is clearly inconsistent with Policy SP6.
The impact of the proposed development on the greenbelt also conflicts with the stated policy in SP6, because the processing plant will be located on a prominent ridgeline on Mill Hill. This will have an adverse impact on the openness and visual amenity of the Green Belt in this area. It will therefore conflict with the purposes of the Green Belt and should consequently be considered inappropriate development.
The bridleway passing through and near the site is part of the Trent Valley Way and is an important strategic route between Barton and Thrumpton in the county and Clifton and Wilford in the city which is extremely well-used by walkers, cyclists, and horseriders. The path will be close to quarry workings and will have to cross the site access road and gravel conveyor - this will have a major negative impact on users.
Just a river's width away from the site, those who walk Attenborough's riverside paths will continually view the adverse effects of the site over the lengthy operational period and will no longer be able to enjoy the peace and tranquillity of Attenborough Nature Reserve - a site of special scientific interest (SSSI) and one of the most important sites for conservation in the East Midlands. The noise and dust will have a negative impact on wildlife in the reserve.
The impacts are very negative in both the operational phase and the long-term operation and clearly inconsistent with most of the key sustainability objectives and strategic policies that frame the minerals plan. There is a lack of transparency in the assessment in terms of how the site is allocated on the grounds of viability and location when the impact assessment clearly indicates that there are other sites where impacts are far less serious.
The process by which the recommendation arose is flawed, and neither transparent or credible given even the partial evidence-base identified in the Draft Plan.

We therefore object to the allocation of the Mill Hill site.
Our main concerns with the allocation of the site are as follows:
* The Council's own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the third most damaging in the long-term.
* The Council has stated that "there is no published data related to geographical spread". Therefore, the Plan is 'unsound' as the Council has sought to justify the inclusion of the site based on "maintaining a geographical spread" and therefore overriding the adverse impact on sustainability.
* There have been no projections for sand and gravel demand in the different submarket areas. The Council's statement that the Shelford or Coddington sites are too big cannot be justified
* The Council has failed to follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" by not allocating any sites which use this mode of transport.
* The site would impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five Local Wildlife Sites one of which will be destroyed altogether.
* Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site - providing significant evidence of the negative impact on wildlife and the environment.
* The site is in the Green Belt, and 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 Council has failed to justify any "wholly exceptional reasons" required by the NPPF.
* The site is close to heavily populated areas - including the new Fairham Pastures development of 3,000 homes - which would be impacted by noise and dust from the site itself and from the extensive lorry movements.
* This plan generates 114 lorry movements a day on the section of Green Street adjoining Mill Hill. This was approved in the A453 dualling plans as being part of a route for non-motorised users, but this number of lorry movements is not compatible with safe cycling, walking or horse riding. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down. This number of lorry movements would make this junction even more hazardous.
* 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, cycling, 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 residents.

Site described as Barton in Fabis or Barton in Fabis (west)
We are also concerned about inaccuracies in the analysis of the site included in the 'Draft site selection methodology and assessment July 2018' and listed as Barton in Fabis or Barton in Fabis (west). Although this site has not been selected, this site assessment may be further used following the outcomes of this consultation and possibly as evidence for future mineral plans or planning applications, we therefore believe it is crucial that the information is reassessed and corrected.
Our main concerns are as follows:
Site location
This site is actually in the parish of Thrumpton and, as a consequence, was not immediately evident to residents of Thrumpton as being in such close proximity to the village. The site should be renamed to include Thrumpton to make its location clear.
Sustainability assessment
The assessment of visual sensitivity states:
The main visual impact would be on residents to the southern edge of Barton in Fabis and on users of the Trent Valley Way to the north of the site. There would be more distant views from residential properties on the northern edge of Thrumpton.
In reality, around 50% of Thrumpton properties would have a clear view of the site - these would not be 'distant views' as the site would be within 400-800 metres. The site would also be highly visible from the A453. Crucially, three properties (Fields Farm, The Orchard and Canterbury House) directly adjoin the site yet criteria 14 'Protect and improve human health and quality of life' makes no reference to the close-proximity of these properties and the assessment gives no consideration to the drastic impact (including noise, dust, traffic movement, visual amenity, property value) on these properties and their residents. Lack of reference to such an important factor indicates an inadequate assessment process.
Transport/highway implications
The Transport Evidence Base states that the Annual Average Daily Flow of HGVs on Green Street/Barton Lane is 15 and would be increased by 90 additional lorry movements per day - an increase of 600%. It dismisses this by stating that "Percentage changes in traffic on Green Street would be high, but this is mainly a result of this route being bypassed by the A453 leaving only low residual traffic flows." It also states that "once onto Green Street the route to the A453 is short."
In reality it is 1.8 miles on a road clearly approved and designated as part of the A453 dualling scheme as a route for non-motorised users linking Mill Hill to Long Lane. This number of lorry movements is simply not compatible with safe cycling, walking or horse riding on a road where there is no traffic separation. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down and this number of lorry movements would make this junction even more hazardous. The report's conclusion that No road safety issues identified is therefore flawed, inaccurate and highly misleading.

Conclusion
We object to a number of aspects of the Draft Plan as set out above.
The evidence for the Mill Hill nr Barton in Fabis site - one of the most environmentally sensitive sites in the assessment (and rejected on these grounds previously by the Council) - does not support its selection.
We believe the criteria and the process used were flawed. The inaccuracies in the assessment of Barton in Fabis (west) raise further questions about the robustness of the assessment process.

Draft Nottinghamshire Minerals Local Plan
Response from Thrumpton Parish Meeting - September 2018
Summary
1. Thrumpton Parish Meeting objects to the Draft Nottinghamshire Minerals Local Plan published in July 2018, and, in particular, to the inclusion of the site MP2s at Mill Hill nr Barton in Fabis.
2. In summary our objection is based on:
a) The identification of flaws in the analysis of issues and options that underpin the Draft Plan, and in particular the identification of geographical spread as a key factor determining site allocation.
b) The application of a rationale for the allocation of sites which is inconsistent with the strategic objectives that have been used to shape the Draft Plan.
c) The allocation of the site at Mill Hill, Barton in Fabis even though the NCCs own analysis shows it to be one of the most damaging developments for sand and gravel of those considered. Such an allocation is inconsistent with the strategic objectives set out in the plan and the strategic policy for sustainable development and planning requirements set out in the National Planning Policy Framework that should underpin it.
d) The process by which the draft plan has been formulated is flawed, and the recommendations in relation to Mill Hill nr Barton in Fabis are therefore unsound. The analysis of the site listed variously as Barton in Fabis or Barton in Fabis (west) is also inaccurate, seriously under-rating its potential impact on local residents. The revised Draft Minerals Plan does not therefore meet the standard of evidence-based planning that is to be expected in the minerals planning process.
The detailed reasoning for these objections is set out in the response from Barton in Fabis Parish Council which we would ask you to make reference to. We will summarise our position and our objections in this response.
Response to Consultation Questions
Question 1: What do you think to the draft vision and strategic objectives set out in the plan?
Question 2: What do you think of the draft strategic policy for sustainable development?
Question 3: What do you think to the draft strategic policy for minerals provision?
We object to the way in which the plan fails to adhere to the strategic objectives set out in 2.30 rather than to the objectives themselves. In particular, SO6 'Protecting and enhancing natural assets' states that an objective is to 'Conserve and enhance Nottinghamshire's natural environment, including its distinctive landscapes, habitats, geology, wildlife species and ecological health of water bodies by avoiding, minimising and mitigating potential

negative impacts.' The Plan has then allocated sites with the greatest environmental impact simply on grounds of size and location - even though nether size nor location appear as strategic objectives. The site allocation process is therefore flawed.
We therefore object to the plan on grounds that the site allocation methodology developed and applied is inconsistent with the strategic objectives of the strategic policy for minerals provision.
Question 4 What do you think of the draft strategic policy for biodiversity led restoration?
We object to the plan on grounds that the policy for biodiversity-led restoration is inadequate. Its application as a criteria for site allocation is flawed because it does not meaningfully discriminate between proposals in terms of the likely success of biodiversity-led restoration.
Question 6: What do you think of the draft strategic policy for sustainable transport?
We object to the Plan and the policy related to sustainable transport because we feel that It is not the function of the planning system to manipulate the geography of the market and associated commercial risk, but rather to ensure that development is appropriate and sustainable, given wider societal needs and requirements. The policy on sustainable transport needs to reflect this. One such requirement, for example, is the use of modes of transport other than road. Another is that the most vulnerable and valuable sites are protected notwithstanding their proximity to market.
Question 7: What do you think of the draft strategic policy for the built, historic and natural environment?
We object to the formulation of Policy SP6 because of the lack of transparency in the way it is applied in the site allocation process. The emphasis on restoration should be reduced and the importance of protection and maintenance of assets should be stressed.
Question 8: What do you think of the draft strategic policy for the Nottinghamshire Green Belt?
Policy SP7 is not transparent in that it fails to state how, in the context of minerals planning, the two tests of 'appropriateness' and 'special circumstances' will be applied. It should be noted that 'special circumstances' in relation to the Green Belt do not include supposed proximity to market or goals of developing a 'spatially sustainable distribution' of minerals sites.
We therefore object to the policy statement on green belt because it lacks any clear indication of how it is to be applied in the minerals planning process.

Question 11: What do you think of the draft site specific sand and gravel allocations?
We object to the application of the site Draft Selection Methodology and its conclusions on grounds of the inconsistency of its outcomes with the stated policy objectives that are stated as underpinning the Draft Plan.
The Draft Plan is therefore flawed and should be revised accordingly to meet the County's own sustainability objectives. In order to do so:
* sites should be considered on their own merits to minimise the likely overall environmental impacts of the Draft Plan;
* geographical spread should only be used to make decisions between sites when all other things are considered equal in order that it does not over-ride consideration of the scale of environmental damage likely to arise by the inappropriate selection of sites due to location. Proximity to market is not an 'exceptional circumstance' as envisaged by the NPPF.
Site at Mill Hill nr Barton in Fabis
We believe the scale of the impacts for the Mill Hill site have been under-estimated, making the decision insecure. We therefore object to the assessment made for the Mill Hill site.
The allocation of the site is not consistent with the objectives of SO6 or SP6. The landscape impacts are amongst the highest attributed to any site in the appraisal matrix, the allocation of this site in the Draft Plan is clearly inconsistent with Policy SP6.
The impact of the proposed development on the greenbelt also conflicts with the stated policy in SP6, because the processing plant will be located on a prominent ridgeline on Mill Hill. This will have an adverse impact on the openness and visual amenity of the Green Belt in this area. It will therefore conflict with the purposes of the Green Belt and should consequently be considered inappropriate development.
The bridleway passing through and near the site is part of the Trent Valley Way and is an important strategic route between Barton and Thrumpton in the county and Clifton and Wilford in the city which is extremely well-used by walkers, cyclists, and horseriders. The path will be close to quarry workings and will have to cross the site access road and gravel conveyor - this will have a major negative impact on users.
Just a river's width away from the site, those who walk Attenborough's riverside paths will continually view the adverse effects of the site over the lengthy operational period and will no longer be able to enjoy the peace and tranquillity of Attenborough Nature Reserve - a site of special scientific interest (SSSI) and one of the most important sites for conservation in the East Midlands. The noise and dust will have a negative impact on wildlife in the reserve.
The impacts are very negative in both the operational phase and the long-term operation and clearly inconsistent with most of the key sustainability objectives and strategic policies that frame the minerals plan. There is a lack of transparency in the assessment in terms of how the site is allocated on the grounds of viability and location when the impact assessment clearly indicates that there are other sites where impacts are far less serious.
The process by which the recommendation arose is flawed, and neither transparent or credible given even the partial evidence-base identified in the Draft Plan.

We therefore object to the allocation of the Mill Hill site.
Our main concerns with the allocation of the site are as follows:
* The Council's own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the third most damaging in the long-term.
* The Council has stated that "there is no published data related to geographical spread". Therefore, the Plan is 'unsound' as the Council has sought to justify the inclusion of the site based on "maintaining a geographical spread" and therefore overriding the adverse impact on sustainability.
* There have been no projections for sand and gravel demand in the different submarket areas. The Council's statement that the Shelford or Coddington sites are too big cannot be justified
* The Council has failed to follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" by not allocating any sites which use this mode of transport.
* The site would impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five Local Wildlife Sites one of which will be destroyed altogether.
* Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site - providing significant evidence of the negative impact on wildlife and the environment.
* The site is in the Green Belt, and 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 Council has failed to justify any "wholly exceptional reasons" required by the NPPF.
* The site is close to heavily populated areas - including the new Fairham Pastures development of 3,000 homes - which would be impacted by noise and dust from the site itself and from the extensive lorry movements.
* This plan generates 114 lorry movements a day on the section of Green Street adjoining Mill Hill. This was approved in the A453 dualling plans as being part of a route for non-motorised users, but this number of lorry movements is not compatible with safe cycling, walking or horse riding. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down. This number of lorry movements would make this junction even more hazardous.
* 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, cycling, 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 residents.

Site described as Barton in Fabis or Barton in Fabis (west)
We are also concerned about inaccuracies in the analysis of the site included in the 'Draft site selection methodology and assessment July 2018' and listed as Barton in Fabis or Barton in Fabis (west). Although this site has not been selected, this site assessment may be further used following the outcomes of this consultation and possibly as evidence for future mineral plans or planning applications, we therefore believe it is crucial that the information is reassessed and corrected.
Our main concerns are as follows:
Site location
This site is actually in the parish of Thrumpton and, as a consequence, was not immediately evident to residents of Thrumpton as being in such close proximity to the village. The site should be renamed to include Thrumpton to make its location clear.
Sustainability assessment
The assessment of visual sensitivity states:
The main visual impact would be on residents to the southern edge of Barton in Fabis and on users of the Trent Valley Way to the north of the site. There would be more distant views from residential properties on the northern edge of Thrumpton.
In reality, around 50% of Thrumpton properties would have a clear view of the site - these would not be 'distant views' as the site would be within 400-800 metres. The site would also be highly visible from the A453. Crucially, three properties (Fields Farm, The Orchard and Canterbury House) directly adjoin the site yet criteria 14 'Protect and improve human health and quality of life' makes no reference to the close-proximity of these properties and the assessment gives no consideration to the drastic impact (including noise, dust, traffic movement, visual amenity, property value) on these properties and their residents. Lack of reference to such an important factor indicates an inadequate assessment process.
Transport/highway implications
The Transport Evidence Base states that the Annual Average Daily Flow of HGVs on Green Street/Barton Lane is 15 and would be increased by 90 additional lorry movements per day - an increase of 600%. It dismisses this by stating that "Percentage changes in traffic on Green Street would be high, but this is mainly a result of this route being bypassed by the A453 leaving only low residual traffic flows." It also states that "once onto Green Street the route to the A453 is short."
In reality it is 1.8 miles on a road clearly approved and designated as part of the A453 dualling scheme as a route for non-motorised users linking Mill Hill to Long Lane. This number of lorry movements is simply not compatible with safe cycling, walking or horse riding on a road where there is no traffic separation. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down and this number of lorry movements would make this junction even more hazardous. The report's conclusion that No road safety issues identified is therefore flawed, inaccurate and highly misleading.

Conclusion
We object to a number of aspects of the Draft Plan as set out above.
The evidence for the Mill Hill nr Barton in Fabis site - one of the most environmentally sensitive sites in the assessment (and rejected on these grounds previously by the Council) - does not support its selection.
We believe the criteria and the process used were flawed. The inaccuracies in the assessment of Barton in Fabis (west) raise further questions about the robustness of the assessment process.

Draft Nottinghamshire Minerals Local Plan
Response from Thrumpton Parish Meeting - September 2018
Summary
1. Thrumpton Parish Meeting objects to the Draft Nottinghamshire Minerals Local Plan published in July 2018, and, in particular, to the inclusion of the site MP2s at Mill Hill nr Barton in Fabis.
2. In summary our objection is based on:
a) The identification of flaws in the analysis of issues and options that underpin the Draft Plan, and in particular the identification of geographical spread as a key factor determining site allocation.
b) The application of a rationale for the allocation of sites which is inconsistent with the strategic objectives that have been used to shape the Draft Plan.
c) The allocation of the site at Mill Hill, Barton in Fabis even though the NCCs own analysis shows it to be one of the most damaging developments for sand and gravel of those considered. Such an allocation is inconsistent with the strategic objectives set out in the plan and the strategic policy for sustainable development and planning requirements set out in the National Planning Policy Framework that should underpin it.
d) The process by which the draft plan has been formulated is flawed, and the recommendations in relation to Mill Hill nr Barton in Fabis are therefore unsound. The analysis of the site listed variously as Barton in Fabis or Barton in Fabis (west) is also inaccurate, seriously under-rating its potential impact on local residents. The revised Draft Minerals Plan does not therefore meet the standard of evidence-based planning that is to be expected in the minerals planning process.
The detailed reasoning for these objections is set out in the response from Barton in Fabis Parish Council which we would ask you to make reference to. We will summarise our position and our objections in this response.
Response to Consultation Questions
Question 1: What do you think to the draft vision and strategic objectives set out in the plan?
Question 2: What do you think of the draft strategic policy for sustainable development?
Question 3: What do you think to the draft strategic policy for minerals provision?
We object to the way in which the plan fails to adhere to the strategic objectives set out in 2.30 rather than to the objectives themselves. In particular, SO6 'Protecting and enhancing natural assets' states that an objective is to 'Conserve and enhance Nottinghamshire's natural environment, including its distinctive landscapes, habitats, geology, wildlife species and ecological health of water bodies by avoiding, minimising and mitigating potential

negative impacts.' The Plan has then allocated sites with the greatest environmental impact simply on grounds of size and location - even though nether size nor location appear as strategic objectives. The site allocation process is therefore flawed.
We therefore object to the plan on grounds that the site allocation methodology developed and applied is inconsistent with the strategic objectives of the strategic policy for minerals provision.
Question 4 What do you think of the draft strategic policy for biodiversity led restoration?
We object to the plan on grounds that the policy for biodiversity-led restoration is inadequate. Its application as a criteria for site allocation is flawed because it does not meaningfully discriminate between proposals in terms of the likely success of biodiversity-led restoration.
Question 6: What do you think of the draft strategic policy for sustainable transport?
We object to the Plan and the policy related to sustainable transport because we feel that It is not the function of the planning system to manipulate the geography of the market and associated commercial risk, but rather to ensure that development is appropriate and sustainable, given wider societal needs and requirements. The policy on sustainable transport needs to reflect this. One such requirement, for example, is the use of modes of transport other than road. Another is that the most vulnerable and valuable sites are protected notwithstanding their proximity to market.
Question 7: What do you think of the draft strategic policy for the built, historic and natural environment?
We object to the formulation of Policy SP6 because of the lack of transparency in the way it is applied in the site allocation process. The emphasis on restoration should be reduced and the importance of protection and maintenance of assets should be stressed.
Question 8: What do you think of the draft strategic policy for the Nottinghamshire Green Belt?
Policy SP7 is not transparent in that it fails to state how, in the context of minerals planning, the two tests of 'appropriateness' and 'special circumstances' will be applied. It should be noted that 'special circumstances' in relation to the Green Belt do not include supposed proximity to market or goals of developing a 'spatially sustainable distribution' of minerals sites.
We therefore object to the policy statement on green belt because it lacks any clear indication of how it is to be applied in the minerals planning process.

Question 11: What do you think of the draft site specific sand and gravel allocations?
We object to the application of the site Draft Selection Methodology and its conclusions on grounds of the inconsistency of its outcomes with the stated policy objectives that are stated as underpinning the Draft Plan.
The Draft Plan is therefore flawed and should be revised accordingly to meet the County's own sustainability objectives. In order to do so:
* sites should be considered on their own merits to minimise the likely overall environmental impacts of the Draft Plan;
* geographical spread should only be used to make decisions between sites when all other things are considered equal in order that it does not over-ride consideration of the scale of environmental damage likely to arise by the inappropriate selection of sites due to location. Proximity to market is not an 'exceptional circumstance' as envisaged by the NPPF.
Site at Mill Hill nr Barton in Fabis
We believe the scale of the impacts for the Mill Hill site have been under-estimated, making the decision insecure. We therefore object to the assessment made for the Mill Hill site.
The allocation of the site is not consistent with the objectives of SO6 or SP6. The landscape impacts are amongst the highest attributed to any site in the appraisal matrix, the allocation of this site in the Draft Plan is clearly inconsistent with Policy SP6.
The impact of the proposed development on the greenbelt also conflicts with the stated policy in SP6, because the processing plant will be located on a prominent ridgeline on Mill Hill. This will have an adverse impact on the openness and visual amenity of the Green Belt in this area. It will therefore conflict with the purposes of the Green Belt and should consequently be considered inappropriate development.
The bridleway passing through and near the site is part of the Trent Valley Way and is an important strategic route between Barton and Thrumpton in the county and Clifton and Wilford in the city which is extremely well-used by walkers, cyclists, and horseriders. The path will be close to quarry workings and will have to cross the site access road and gravel conveyor - this will have a major negative impact on users.
Just a river's width away from the site, those who walk Attenborough's riverside paths will continually view the adverse effects of the site over the lengthy operational period and will no longer be able to enjoy the peace and tranquillity of Attenborough Nature Reserve - a site of special scientific interest (SSSI) and one of the most important sites for conservation in the East Midlands. The noise and dust will have a negative impact on wildlife in the reserve.
The impacts are very negative in both the operational phase and the long-term operation and clearly inconsistent with most of the key sustainability objectives and strategic policies that frame the minerals plan. There is a lack of transparency in the assessment in terms of how the site is allocated on the grounds of viability and location when the impact assessment clearly indicates that there are other sites where impacts are far less serious.
The process by which the recommendation arose is flawed, and neither transparent or credible given even the partial evidence-base identified in the Draft Plan.

We therefore object to the allocation of the Mill Hill site.
Our main concerns with the allocation of the site are as follows:
* The Council's own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the third most damaging in the long-term.
* The Council has stated that "there is no published data related to geographical spread". Therefore, the Plan is 'unsound' as the Council has sought to justify the inclusion of the site based on "maintaining a geographical spread" and therefore overriding the adverse impact on sustainability.
* There have been no projections for sand and gravel demand in the different submarket areas. The Council's statement that the Shelford or Coddington sites are too big cannot be justified
* The Council has failed to follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" by not allocating any sites which use this mode of transport.
* The site would impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five Local Wildlife Sites one of which will be destroyed altogether.
* Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site - providing significant evidence of the negative impact on wildlife and the environment.
* The site is in the Green Belt, and 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 Council has failed to justify any "wholly exceptional reasons" required by the NPPF.
* The site is close to heavily populated areas - including the new Fairham Pastures development of 3,000 homes - which would be impacted by noise and dust from the site itself and from the extensive lorry movements.
* This plan generates 114 lorry movements a day on the section of Green Street adjoining Mill Hill. This was approved in the A453 dualling plans as being part of a route for non-motorised users, but this number of lorry movements is not compatible with safe cycling, walking or horse riding. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down. This number of lorry movements would make this junction even more hazardous.
* 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, cycling, 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 residents.

Site described as Barton in Fabis or Barton in Fabis (west)
We are also concerned about inaccuracies in the analysis of the site included in the 'Draft site selection methodology and assessment July 2018' and listed as Barton in Fabis or Barton in Fabis (west). Although this site has not been selected, this site assessment may be further used following the outcomes of this consultation and possibly as evidence for future mineral plans or planning applications, we therefore believe it is crucial that the information is reassessed and corrected.
Our main concerns are as follows:
Site location
This site is actually in the parish of Thrumpton and, as a consequence, was not immediately evident to residents of Thrumpton as being in such close proximity to the village. The site should be renamed to include Thrumpton to make its location clear.
Sustainability assessment
The assessment of visual sensitivity states:
The main visual impact would be on residents to the southern edge of Barton in Fabis and on users of the Trent Valley Way to the north of the site. There would be more distant views from residential properties on the northern edge of Thrumpton.
In reality, around 50% of Thrumpton properties would have a clear view of the site - these would not be 'distant views' as the site would be within 400-800 metres. The site would also be highly visible from the A453. Crucially, three properties (Fields Farm, The Orchard and Canterbury House) directly adjoin the site yet criteria 14 'Protect and improve human health and quality of life' makes no reference to the close-proximity of these properties and the assessment gives no consideration to the drastic impact (including noise, dust, traffic movement, visual amenity, property value) on these properties and their residents. Lack of reference to such an important factor indicates an inadequate assessment process.
Transport/highway implications
The Transport Evidence Base states that the Annual Average Daily Flow of HGVs on Green Street/Barton Lane is 15 and would be increased by 90 additional lorry movements per day - an increase of 600%. It dismisses this by stating that "Percentage changes in traffic on Green Street would be high, but this is mainly a result of this route being bypassed by the A453 leaving only low residual traffic flows." It also states that "once onto Green Street the route to the A453 is short."
In reality it is 1.8 miles on a road clearly approved and designated as part of the A453 dualling scheme as a route for non-motorised users linking Mill Hill to Long Lane. This number of lorry movements is simply not compatible with safe cycling, walking or horse riding on a road where there is no traffic separation. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down and this number of lorry movements would make this junction even more hazardous. The report's conclusion that No road safety issues identified is therefore flawed, inaccurate and highly misleading.

Conclusion
We object to a number of aspects of the Draft Plan as set out above.
The evidence for the Mill Hill nr Barton in Fabis site - one of the most environmentally sensitive sites in the assessment (and rejected on these grounds previously by the Council) - does not support its selection.
We believe the criteria and the process used were flawed. The inaccuracies in the assessment of Barton in Fabis (west) raise further questions about the robustness of the assessment process.

Draft Nottinghamshire Minerals Local Plan
Response from Thrumpton Parish Meeting - September 2018
Summary
1. Thrumpton Parish Meeting objects to the Draft Nottinghamshire Minerals Local Plan published in July 2018, and, in particular, to the inclusion of the site MP2s at Mill Hill nr Barton in Fabis.
2. In summary our objection is based on:
a) The identification of flaws in the analysis of issues and options that underpin the Draft Plan, and in particular the identification of geographical spread as a key factor determining site allocation.
b) The application of a rationale for the allocation of sites which is inconsistent with the strategic objectives that have been used to shape the Draft Plan.
c) The allocation of the site at Mill Hill, Barton in Fabis even though the NCCs own analysis shows it to be one of the most damaging developments for sand and gravel of those considered. Such an allocation is inconsistent with the strategic objectives set out in the plan and the strategic policy for sustainable development and planning requirements set out in the National Planning Policy Framework that should underpin it.
d) The process by which the draft plan has been formulated is flawed, and the recommendations in relation to Mill Hill nr Barton in Fabis are therefore unsound. The analysis of the site listed variously as Barton in Fabis or Barton in Fabis (west) is also inaccurate, seriously under-rating its potential impact on local residents. The revised Draft Minerals Plan does not therefore meet the standard of evidence-based planning that is to be expected in the minerals planning process.
The detailed reasoning for these objections is set out in the response from Barton in Fabis Parish Council which we would ask you to make reference to. We will summarise our position and our objections in this response.
Response to Consultation Questions
Question 1: What do you think to the draft vision and strategic objectives set out in the plan?
Question 2: What do you think of the draft strategic policy for sustainable development?
Question 3: What do you think to the draft strategic policy for minerals provision?
We object to the way in which the plan fails to adhere to the strategic objectives set out in 2.30 rather than to the objectives themselves. In particular, SO6 'Protecting and enhancing natural assets' states that an objective is to 'Conserve and enhance Nottinghamshire's natural environment, including its distinctive landscapes, habitats, geology, wildlife species and ecological health of water bodies by avoiding, minimising and mitigating potential

negative impacts.' The Plan has then allocated sites with the greatest environmental impact simply on grounds of size and location - even though nether size nor location appear as strategic objectives. The site allocation process is therefore flawed.
We therefore object to the plan on grounds that the site allocation methodology developed and applied is inconsistent with the strategic objectives of the strategic policy for minerals provision.
Question 4 What do you think of the draft strategic policy for biodiversity led restoration?
We object to the plan on grounds that the policy for biodiversity-led restoration is inadequate. Its application as a criteria for site allocation is flawed because it does not meaningfully discriminate between proposals in terms of the likely success of biodiversity-led restoration.
Question 6: What do you think of the draft strategic policy for sustainable transport?
We object to the Plan and the policy related to sustainable transport because we feel that It is not the function of the planning system to manipulate the geography of the market and associated commercial risk, but rather to ensure that development is appropriate and sustainable, given wider societal needs and requirements. The policy on sustainable transport needs to reflect this. One such requirement, for example, is the use of modes of transport other than road. Another is that the most vulnerable and valuable sites are protected notwithstanding their proximity to market.
Question 7: What do you think of the draft strategic policy for the built, historic and natural environment?
We object to the formulation of Policy SP6 because of the lack of transparency in the way it is applied in the site allocation process. The emphasis on restoration should be reduced and the importance of protection and maintenance of assets should be stressed.
Question 8: What do you think of the draft strategic policy for the Nottinghamshire Green Belt?
Policy SP7 is not transparent in that it fails to state how, in the context of minerals planning, the two tests of 'appropriateness' and 'special circumstances' will be applied. It should be noted that 'special circumstances' in relation to the Green Belt do not include supposed proximity to market or goals of developing a 'spatially sustainable distribution' of minerals sites.
We therefore object to the policy statement on green belt because it lacks any clear indication of how it is to be applied in the minerals planning process.

Question 11: What do you think of the draft site specific sand and gravel allocations?
We object to the application of the site Draft Selection Methodology and its conclusions on grounds of the inconsistency of its outcomes with the stated policy objectives that are stated as underpinning the Draft Plan.
The Draft Plan is therefore flawed and should be revised accordingly to meet the County's own sustainability objectives. In order to do so:
* sites should be considered on their own merits to minimise the likely overall environmental impacts of the Draft Plan;
* geographical spread should only be used to make decisions between sites when all other things are considered equal in order that it does not over-ride consideration of the scale of environmental damage likely to arise by the inappropriate selection of sites due to location. Proximity to market is not an 'exceptional circumstance' as envisaged by the NPPF.
Site at Mill Hill nr Barton in Fabis
We believe the scale of the impacts for the Mill Hill site have been under-estimated, making the decision insecure. We therefore object to the assessment made for the Mill Hill site.
The allocation of the site is not consistent with the objectives of SO6 or SP6. The landscape impacts are amongst the highest attributed to any site in the appraisal matrix, the allocation of this site in the Draft Plan is clearly inconsistent with Policy SP6.
The impact of the proposed development on the greenbelt also conflicts with the stated policy in SP6, because the processing plant will be located on a prominent ridgeline on Mill Hill. This will have an adverse impact on the openness and visual amenity of the Green Belt in this area. It will therefore conflict with the purposes of the Green Belt and should consequently be considered inappropriate development.
The bridleway passing through and near the site is part of the Trent Valley Way and is an important strategic route between Barton and Thrumpton in the county and Clifton and Wilford in the city which is extremely well-used by walkers, cyclists, and horseriders. The path will be close to quarry workings and will have to cross the site access road and gravel conveyor - this will have a major negative impact on users.
Just a river's width away from the site, those who walk Attenborough's riverside paths will continually view the adverse effects of the site over the lengthy operational period and will no longer be able to enjoy the peace and tranquillity of Attenborough Nature Reserve - a site of special scientific interest (SSSI) and one of the most important sites for conservation in the East Midlands. The noise and dust will have a negative impact on wildlife in the reserve.
The impacts are very negative in both the operational phase and the long-term operation and clearly inconsistent with most of the key sustainability objectives and strategic policies that frame the minerals plan. There is a lack of transparency in the assessment in terms of how the site is allocated on the grounds of viability and location when the impact assessment clearly indicates that there are other sites where impacts are far less serious.
The process by which the recommendation arose is flawed, and neither transparent or credible given even the partial evidence-base identified in the Draft Plan.

We therefore object to the allocation of the Mill Hill site.
Our main concerns with the allocation of the site are as follows:
* The Council's own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the third most damaging in the long-term.
* The Council has stated that "there is no published data related to geographical spread". Therefore, the Plan is 'unsound' as the Council has sought to justify the inclusion of the site based on "maintaining a geographical spread" and therefore overriding the adverse impact on sustainability.
* There have been no projections for sand and gravel demand in the different submarket areas. The Council's statement that the Shelford or Coddington sites are too big cannot be justified
* The Council has failed to follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" by not allocating any sites which use this mode of transport.
* The site would impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five Local Wildlife Sites one of which will be destroyed altogether.
* Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site - providing significant evidence of the negative impact on wildlife and the environment.
* The site is in the Green Belt, and 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 Council has failed to justify any "wholly exceptional reasons" required by the NPPF.
* The site is close to heavily populated areas - including the new Fairham Pastures development of 3,000 homes - which would be impacted by noise and dust from the site itself and from the extensive lorry movements.
* This plan generates 114 lorry movements a day on the section of Green Street adjoining Mill Hill. This was approved in the A453 dualling plans as being part of a route for non-motorised users, but this number of lorry movements is not compatible with safe cycling, walking or horse riding. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down. This number of lorry movements would make this junction even more hazardous.
* 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, cycling, 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 residents.

Site described as Barton in Fabis or Barton in Fabis (west)
We are also concerned about inaccuracies in the analysis of the site included in the 'Draft site selection methodology and assessment July 2018' and listed as Barton in Fabis or Barton in Fabis (west). Although this site has not been selected, this site assessment may be further used following the outcomes of this consultation and possibly as evidence for future mineral plans or planning applications, we therefore believe it is crucial that the information is reassessed and corrected.
Our main concerns are as follows:
Site location
This site is actually in the parish of Thrumpton and, as a consequence, was not immediately evident to residents of Thrumpton as being in such close proximity to the village. The site should be renamed to include Thrumpton to make its location clear.
Sustainability assessment
The assessment of visual sensitivity states:
The main visual impact would be on residents to the southern edge of Barton in Fabis and on users of the Trent Valley Way to the north of the site. There would be more distant views from residential properties on the northern edge of Thrumpton.
In reality, around 50% of Thrumpton properties would have a clear view of the site - these would not be 'distant views' as the site would be within 400-800 metres. The site would also be highly visible from the A453. Crucially, three properties (Fields Farm, The Orchard and Canterbury House) directly adjoin the site yet criteria 14 'Protect and improve human health and quality of life' makes no reference to the close-proximity of these properties and the assessment gives no consideration to the drastic impact (including noise, dust, traffic movement, visual amenity, property value) on these properties and their residents. Lack of reference to such an important factor indicates an inadequate assessment process.
Transport/highway implications
The Transport Evidence Base states that the Annual Average Daily Flow of HGVs on Green Street/Barton Lane is 15 and would be increased by 90 additional lorry movements per day - an increase of 600%. It dismisses this by stating that "Percentage changes in traffic on Green Street would be high, but this is mainly a result of this route being bypassed by the A453 leaving only low residual traffic flows." It also states that "once onto Green Street the route to the A453 is short."
In reality it is 1.8 miles on a road clearly approved and designated as part of the A453 dualling scheme as a route for non-motorised users linking Mill Hill to Long Lane. This number of lorry movements is simply not compatible with safe cycling, walking or horse riding on a road where there is no traffic separation. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down and this number of lorry movements would make this junction even more hazardous. The report's conclusion that No road safety issues identified is therefore flawed, inaccurate and highly misleading.

Conclusion
We object to a number of aspects of the Draft Plan as set out above.
The evidence for the Mill Hill nr Barton in Fabis site - one of the most environmentally sensitive sites in the assessment (and rejected on these grounds previously by the Council) - does not support its selection.
We believe the criteria and the process used were flawed. The inaccuracies in the assessment of Barton in Fabis (west) raise further questions about the robustness of the assessment process.

Draft Nottinghamshire Minerals Local Plan
Response from Thrumpton Parish Meeting - September 2018
Summary
1. Thrumpton Parish Meeting objects to the Draft Nottinghamshire Minerals Local Plan published in July 2018, and, in particular, to the inclusion of the site MP2s at Mill Hill nr Barton in Fabis.
2. In summary our objection is based on:
a) The identification of flaws in the analysis of issues and options that underpin the Draft Plan, and in particular the identification of geographical spread as a key factor determining site allocation.
b) The application of a rationale for the allocation of sites which is inconsistent with the strategic objectives that have been used to shape the Draft Plan.
c) The allocation of the site at Mill Hill, Barton in Fabis even though the NCCs own analysis shows it to be one of the most damaging developments for sand and gravel of those considered. Such an allocation is inconsistent with the strategic objectives set out in the plan and the strategic policy for sustainable development and planning requirements set out in the National Planning Policy Framework that should underpin it.
d) The process by which the draft plan has been formulated is flawed, and the recommendations in relation to Mill Hill nr Barton in Fabis are therefore unsound. The analysis of the site listed variously as Barton in Fabis or Barton in Fabis (west) is also inaccurate, seriously under-rating its potential impact on local residents. The revised Draft Minerals Plan does not therefore meet the standard of evidence-based planning that is to be expected in the minerals planning process.
The detailed reasoning for these objections is set out in the response from Barton in Fabis Parish Council which we would ask you to make reference to. We will summarise our position and our objections in this response.
Response to Consultation Questions
Question 1: What do you think to the draft vision and strategic objectives set out in the plan?
Question 2: What do you think of the draft strategic policy for sustainable development?
Question 3: What do you think to the draft strategic policy for minerals provision?
We object to the way in which the plan fails to adhere to the strategic objectives set out in 2.30 rather than to the objectives themselves. In particular, SO6 'Protecting and enhancing natural assets' states that an objective is to 'Conserve and enhance Nottinghamshire's natural environment, including its distinctive landscapes, habitats, geology, wildlife species and ecological health of water bodies by avoiding, minimising and mitigating potential

negative impacts.' The Plan has then allocated sites with the greatest environmental impact simply on grounds of size and location - even though nether size nor location appear as strategic objectives. The site allocation process is therefore flawed.
We therefore object to the plan on grounds that the site allocation methodology developed and applied is inconsistent with the strategic objectives of the strategic policy for minerals provision.
Question 4 What do you think of the draft strategic policy for biodiversity led restoration?
We object to the plan on grounds that the policy for biodiversity-led restoration is inadequate. Its application as a criteria for site allocation is flawed because it does not meaningfully discriminate between proposals in terms of the likely success of biodiversity-led restoration.
Question 6: What do you think of the draft strategic policy for sustainable transport?
We object to the Plan and the policy related to sustainable transport because we feel that It is not the function of the planning system to manipulate the geography of the market and associated commercial risk, but rather to ensure that development is appropriate and sustainable, given wider societal needs and requirements. The policy on sustainable transport needs to reflect this. One such requirement, for example, is the use of modes of transport other than road. Another is that the most vulnerable and valuable sites are protected notwithstanding their proximity to market.
Question 7: What do you think of the draft strategic policy for the built, historic and natural environment?
We object to the formulation of Policy SP6 because of the lack of transparency in the way it is applied in the site allocation process. The emphasis on restoration should be reduced and the importance of protection and maintenance of assets should be stressed.
Question 8: What do you think of the draft strategic policy for the Nottinghamshire Green Belt?
Policy SP7 is not transparent in that it fails to state how, in the context of minerals planning, the two tests of 'appropriateness' and 'special circumstances' will be applied. It should be noted that 'special circumstances' in relation to the Green Belt do not include supposed proximity to market or goals of developing a 'spatially sustainable distribution' of minerals sites.
We therefore object to the policy statement on green belt because it lacks any clear indication of how it is to be applied in the minerals planning process.

Question 11: What do you think of the draft site specific sand and gravel allocations?
We object to the application of the site Draft Selection Methodology and its conclusions on grounds of the inconsistency of its outcomes with the stated policy objectives that are stated as underpinning the Draft Plan.
The Draft Plan is therefore flawed and should be revised accordingly to meet the County's own sustainability objectives. In order to do so:
* sites should be considered on their own merits to minimise the likely overall environmental impacts of the Draft Plan;
* geographical spread should only be used to make decisions between sites when all other things are considered equal in order that it does not over-ride consideration of the scale of environmental damage likely to arise by the inappropriate selection of sites due to location. Proximity to market is not an 'exceptional circumstance' as envisaged by the NPPF.
Site at Mill Hill nr Barton in Fabis
We believe the scale of the impacts for the Mill Hill site have been under-estimated, making the decision insecure. We therefore object to the assessment made for the Mill Hill site.
The allocation of the site is not consistent with the objectives of SO6 or SP6. The landscape impacts are amongst the highest attributed to any site in the appraisal matrix, the allocation of this site in the Draft Plan is clearly inconsistent with Policy SP6.
The impact of the proposed development on the greenbelt also conflicts with the stated policy in SP6, because the processing plant will be located on a prominent ridgeline on Mill Hill. This will have an adverse impact on the openness and visual amenity of the Green Belt in this area. It will therefore conflict with the purposes of the Green Belt and should consequently be considered inappropriate development.
The bridleway passing through and near the site is part of the Trent Valley Way and is an important strategic route between Barton and Thrumpton in the county and Clifton and Wilford in the city which is extremely well-used by walkers, cyclists, and horseriders. The path will be close to quarry workings and will have to cross the site access road and gravel conveyor - this will have a major negative impact on users.
Just a river's width away from the site, those who walk Attenborough's riverside paths will continually view the adverse effects of the site over the lengthy operational period and will no longer be able to enjoy the peace and tranquillity of Attenborough Nature Reserve - a site of special scientific interest (SSSI) and one of the most important sites for conservation in the East Midlands. The noise and dust will have a negative impact on wildlife in the reserve.
The impacts are very negative in both the operational phase and the long-term operation and clearly inconsistent with most of the key sustainability objectives and strategic policies that frame the minerals plan. There is a lack of transparency in the assessment in terms of how the site is allocated on the grounds of viability and location when the impact assessment clearly indicates that there are other sites where impacts are far less serious.
The process by which the recommendation arose is flawed, and neither transparent or credible given even the partial evidence-base identified in the Draft Plan.

We therefore object to the allocation of the Mill Hill site.
Our main concerns with the allocation of the site are as follows:
* The Council's own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the third most damaging in the long-term.
* The Council has stated that "there is no published data related to geographical spread". Therefore, the Plan is 'unsound' as the Council has sought to justify the inclusion of the site based on "maintaining a geographical spread" and therefore overriding the adverse impact on sustainability.
* There have been no projections for sand and gravel demand in the different submarket areas. The Council's statement that the Shelford or Coddington sites are too big cannot be justified
* The Council has failed to follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" by not allocating any sites which use this mode of transport.
* The site would impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five Local Wildlife Sites one of which will be destroyed altogether.
* Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site - providing significant evidence of the negative impact on wildlife and the environment.
* The site is in the Green Belt, and 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 Council has failed to justify any "wholly exceptional reasons" required by the NPPF.
* The site is close to heavily populated areas - including the new Fairham Pastures development of 3,000 homes - which would be impacted by noise and dust from the site itself and from the extensive lorry movements.
* This plan generates 114 lorry movements a day on the section of Green Street adjoining Mill Hill. This was approved in the A453 dualling plans as being part of a route for non-motorised users, but this number of lorry movements is not compatible with safe cycling, walking or horse riding. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down. This number of lorry movements would make this junction even more hazardous.
* 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, cycling, 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 residents.

Site described as Barton in Fabis or Barton in Fabis (west)
We are also concerned about inaccuracies in the analysis of the site included in the 'Draft site selection methodology and assessment July 2018' and listed as Barton in Fabis or Barton in Fabis (west). Although this site has not been selected, this site assessment may be further used following the outcomes of this consultation and possibly as evidence for future mineral plans or planning applications, we therefore believe it is crucial that the information is reassessed and corrected.
Our main concerns are as follows:
Site location
This site is actually in the parish of Thrumpton and, as a consequence, was not immediately evident to residents of Thrumpton as being in such close proximity to the village. The site should be renamed to include Thrumpton to make its location clear.
Sustainability assessment
The assessment of visual sensitivity states:
The main visual impact would be on residents to the southern edge of Barton in Fabis and on users of the Trent Valley Way to the north of the site. There would be more distant views from residential properties on the northern edge of Thrumpton.
In reality, around 50% of Thrumpton properties would have a clear view of the site - these would not be 'distant views' as the site would be within 400-800 metres. The site would also be highly visible from the A453. Crucially, three properties (Fields Farm, The Orchard and Canterbury House) directly adjoin the site yet criteria 14 'Protect and improve human health and quality of life' makes no reference to the close-proximity of these properties and the assessment gives no consideration to the drastic impact (including noise, dust, traffic movement, visual amenity, property value) on these properties and their residents. Lack of reference to such an important factor indicates an inadequate assessment process.
Transport/highway implications
The Transport Evidence Base states that the Annual Average Daily Flow of HGVs on Green Street/Barton Lane is 15 and would be increased by 90 additional lorry movements per day - an increase of 600%. It dismisses this by stating that "Percentage changes in traffic on Green Street would be high, but this is mainly a result of this route being bypassed by the A453 leaving only low residual traffic flows." It also states that "once onto Green Street the route to the A453 is short."
In reality it is 1.8 miles on a road clearly approved and designated as part of the A453 dualling scheme as a route for non-motorised users linking Mill Hill to Long Lane. This number of lorry movements is simply not compatible with safe cycling, walking or horse riding on a road where there is no traffic separation. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down and this number of lorry movements would make this junction even more hazardous. The report's conclusion that No road safety issues identified is therefore flawed, inaccurate and highly misleading.

Conclusion
We object to a number of aspects of the Draft Plan as set out above.
The evidence for the Mill Hill nr Barton in Fabis site - one of the most environmentally sensitive sites in the assessment (and rejected on these grounds previously by the Council) - does not support its selection.
We believe the criteria and the process used were flawed. The inaccuracies in the assessment of Barton in Fabis (west) raise further questions about the robustness of the assessment process.

Draft Nottinghamshire Minerals Local Plan
Response from Thrumpton Parish Meeting - September 2018
Summary
1. Thrumpton Parish Meeting objects to the Draft Nottinghamshire Minerals Local Plan published in July 2018, and, in particular, to the inclusion of the site MP2s at Mill Hill nr Barton in Fabis.
2. In summary our objection is based on:
a) The identification of flaws in the analysis of issues and options that underpin the Draft Plan, and in particular the identification of geographical spread as a key factor determining site allocation.
b) The application of a rationale for the allocation of sites which is inconsistent with the strategic objectives that have been used to shape the Draft Plan.
c) The allocation of the site at Mill Hill, Barton in Fabis even though the NCCs own analysis shows it to be one of the most damaging developments for sand and gravel of those considered. Such an allocation is inconsistent with the strategic objectives set out in the plan and the strategic policy for sustainable development and planning requirements set out in the National Planning Policy Framework that should underpin it.
d) The process by which the draft plan has been formulated is flawed, and the recommendations in relation to Mill Hill nr Barton in Fabis are therefore unsound. The analysis of the site listed variously as Barton in Fabis or Barton in Fabis (west) is also inaccurate, seriously under-rating its potential impact on local residents. The revised Draft Minerals Plan does not therefore meet the standard of evidence-based planning that is to be expected in the minerals planning process.
The detailed reasoning for these objections is set out in the response from Barton in Fabis Parish Council which we would ask you to make reference to. We will summarise our position and our objections in this response.
Response to Consultation Questions
Question 1: What do you think to the draft vision and strategic objectives set out in the plan?
Question 2: What do you think of the draft strategic policy for sustainable development?
Question 3: What do you think to the draft strategic policy for minerals provision?
We object to the way in which the plan fails to adhere to the strategic objectives set out in 2.30 rather than to the objectives themselves. In particular, SO6 'Protecting and enhancing natural assets' states that an objective is to 'Conserve and enhance Nottinghamshire's natural environment, including its distinctive landscapes, habitats, geology, wildlife species and ecological health of water bodies by avoiding, minimising and mitigating potential

negative impacts.' The Plan has then allocated sites with the greatest environmental impact simply on grounds of size and location - even though nether size nor location appear as strategic objectives. The site allocation process is therefore flawed.
We therefore object to the plan on grounds that the site allocation methodology developed and applied is inconsistent with the strategic objectives of the strategic policy for minerals provision.
Question 4 What do you think of the draft strategic policy for biodiversity led restoration?
We object to the plan on grounds that the policy for biodiversity-led restoration is inadequate. Its application as a criteria for site allocation is flawed because it does not meaningfully discriminate between proposals in terms of the likely success of biodiversity-led restoration.
Question 6: What do you think of the draft strategic policy for sustainable transport?
We object to the Plan and the policy related to sustainable transport because we feel that It is not the function of the planning system to manipulate the geography of the market and associated commercial risk, but rather to ensure that development is appropriate and sustainable, given wider societal needs and requirements. The policy on sustainable transport needs to reflect this. One such requirement, for example, is the use of modes of transport other than road. Another is that the most vulnerable and valuable sites are protected notwithstanding their proximity to market.
Question 7: What do you think of the draft strategic policy for the built, historic and natural environment?
We object to the formulation of Policy SP6 because of the lack of transparency in the way it is applied in the site allocation process. The emphasis on restoration should be reduced and the importance of protection and maintenance of assets should be stressed.
Question 8: What do you think of the draft strategic policy for the Nottinghamshire Green Belt?
Policy SP7 is not transparent in that it fails to state how, in the context of minerals planning, the two tests of 'appropriateness' and 'special circumstances' will be applied. It should be noted that 'special circumstances' in relation to the Green Belt do not include supposed proximity to market or goals of developing a 'spatially sustainable distribution' of minerals sites.
We therefore object to the policy statement on green belt because it lacks any clear indication of how it is to be applied in the minerals planning process.

Question 11: What do you think of the draft site specific sand and gravel allocations?
We object to the application of the site Draft Selection Methodology and its conclusions on grounds of the inconsistency of its outcomes with the stated policy objectives that are stated as underpinning the Draft Plan.
The Draft Plan is therefore flawed and should be revised accordingly to meet the County's own sustainability objectives. In order to do so:
* sites should be considered on their own merits to minimise the likely overall environmental impacts of the Draft Plan;
* geographical spread should only be used to make decisions between sites when all other things are considered equal in order that it does not over-ride consideration of the scale of environmental damage likely to arise by the inappropriate selection of sites due to location. Proximity to market is not an 'exceptional circumstance' as envisaged by the NPPF.
Site at Mill Hill nr Barton in Fabis
We believe the scale of the impacts for the Mill Hill site have been under-estimated, making the decision insecure. We therefore object to the assessment made for the Mill Hill site.
The allocation of the site is not consistent with the objectives of SO6 or SP6. The landscape impacts are amongst the highest attributed to any site in the appraisal matrix, the allocation of this site in the Draft Plan is clearly inconsistent with Policy SP6.
The impact of the proposed development on the greenbelt also conflicts with the stated policy in SP6, because the processing plant will be located on a prominent ridgeline on Mill Hill. This will have an adverse impact on the openness and visual amenity of the Green Belt in this area. It will therefore conflict with the purposes of the Green Belt and should consequently be considered inappropriate development.
The bridleway passing through and near the site is part of the Trent Valley Way and is an important strategic route between Barton and Thrumpton in the county and Clifton and Wilford in the city which is extremely well-used by walkers, cyclists, and horseriders. The path will be close to quarry workings and will have to cross the site access road and gravel conveyor - this will have a major negative impact on users.
Just a river's width away from the site, those who walk Attenborough's riverside paths will continually view the adverse effects of the site over the lengthy operational period and will no longer be able to enjoy the peace and tranquillity of Attenborough Nature Reserve - a site of special scientific interest (SSSI) and one of the most important sites for conservation in the East Midlands. The noise and dust will have a negative impact on wildlife in the reserve.
The impacts are very negative in both the operational phase and the long-term operation and clearly inconsistent with most of the key sustainability objectives and strategic policies that frame the minerals plan. There is a lack of transparency in the assessment in terms of how the site is allocated on the grounds of viability and location when the impact assessment clearly indicates that there are other sites where impacts are far less serious.
The process by which the recommendation arose is flawed, and neither transparent or credible given even the partial evidence-base identified in the Draft Plan.

We therefore object to the allocation of the Mill Hill site.
Our main concerns with the allocation of the site are as follows:
* The Council's own 'Sustainability Assessment' shows that this site is the most damaging of all sites in the operational phase and the third most damaging in the long-term.
* The Council has stated that "there is no published data related to geographical spread". Therefore, the Plan is 'unsound' as the Council has sought to justify the inclusion of the site based on "maintaining a geographical spread" and therefore overriding the adverse impact on sustainability.
* There have been no projections for sand and gravel demand in the different submarket areas. The Council's statement that the Shelford or Coddington sites are too big cannot be justified
* The Council has failed to follow its policy aim to "Prioritise sites with potential for transporting sand and gravel by river barge" by not allocating any sites which use this mode of transport.
* The site would impact on two Sites of Special Scientific Interest - Attenborough Nature Reserve and Holme Pit - which are close to the site, and on five Local Wildlife Sites one of which will be destroyed altogether.
* Natural England, RSPB, CPRE, Ramblers Association and Nottinghamshire Wildlife Trust have already objected to a planning application for this site - providing significant evidence of the negative impact on wildlife and the environment.
* The site is in the Green Belt, and 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 Council has failed to justify any "wholly exceptional reasons" required by the NPPF.
* The site is close to heavily populated areas - including the new Fairham Pastures development of 3,000 homes - which would be impacted by noise and dust from the site itself and from the extensive lorry movements.
* This plan generates 114 lorry movements a day on the section of Green Street adjoining Mill Hill. This was approved in the A453 dualling plans as being part of a route for non-motorised users, but this number of lorry movements is not compatible with safe cycling, walking or horse riding. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down. This number of lorry movements would make this junction even more hazardous.
* 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, cycling, 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 residents.

Site described as Barton in Fabis or Barton in Fabis (west)
We are also concerned about inaccuracies in the analysis of the site included in the 'Draft site selection methodology and assessment July 2018' and listed as Barton in Fabis or Barton in Fabis (west). Although this site has not been selected, this site assessment may be further used following the outcomes of this consultation and possibly as evidence for future mineral plans or planning applications, we therefore believe it is crucial that the information is reassessed and corrected.
Our main concerns are as follows:
Site location
This site is actually in the parish of Thrumpton and, as a consequence, was not immediately evident to residents of Thrumpton as being in such close proximity to the village. The site should be renamed to include Thrumpton to make its location clear.
Sustainability assessment
The assessment of visual sensitivity states:
The main visual impact would be on residents to the southern edge of Barton in Fabis and on users of the Trent Valley Way to the north of the site. There would be more distant views from residential properties on the northern edge of Thrumpton.
In reality, around 50% of Thrumpton properties would have a clear view of the site - these would not be 'distant views' as the site would be within 400-800 metres. The site would also be highly visible from the A453. Crucially, three properties (Fields Farm, The Orchard and Canterbury House) directly adjoin the site yet criteria 14 'Protect and improve human health and quality of life' makes no reference to the close-proximity of these properties and the assessment gives no consideration to the drastic impact (including noise, dust, traffic movement, visual amenity, property value) on these properties and their residents. Lack of reference to such an important factor indicates an inadequate assessment process.
Transport/highway implications
The Transport Evidence Base states that the Annual Average Daily Flow of HGVs on Green Street/Barton Lane is 15 and would be increased by 90 additional lorry movements per day - an increase of 600%. It dismisses this by stating that "Percentage changes in traffic on Green Street would be high, but this is mainly a result of this route being bypassed by the A453 leaving only low residual traffic flows." It also states that "once onto Green Street the route to the A453 is short."
In reality it is 1.8 miles on a road clearly approved and designated as part of the A453 dualling scheme as a route for non-motorised users linking Mill Hill to Long Lane. This number of lorry movements is simply not compatible with safe cycling, walking or horse riding on a road where there is no traffic separation. Also, entering and leaving the roundabout at Mill Hill is already hazardous for all road users due to traffic from the A453 not slowing down and this number of lorry movements would make this junction even more hazardous. The report's conclusion that No road safety issues identified is therefore flawed, inaccurate and highly misleading.

Conclusion
We object to a number of aspects of the Draft Plan as set out above.
The evidence for the Mill Hill nr Barton in Fabis site - one of the most environmentally sensitive sites in the assessment (and rejected on these grounds previously by the Council) - does not support its selection.
We believe the criteria and the process used were flawed. The inaccuracies in the assessment of Barton in Fabis (west) raise further questions about the robustness of the assessment process.