Draft Nottinghamshire Minerals Local Plan

Preface
This Council made submissions at the previous stage, "Issues and Options," in this process of producing the final Plan. We find that some issues we addressed at that stage have been included in the Draft Plan in a way we agree with, and some not. This Submission will refer to such points of agreement or disagreement again as they arise.

None of the sites proposed in this Draft is sufficiently close to Burton Joyce for this Council to have any direct comment on the suitability of them so we address only the general principles. However, identification of sites should not be done in isolation from the expected effects of anticipated infrastructure, commercial and housing developments in the areas concerned. The issues raised in the section concerning sand and gravel, since that mineral resource is the one relevant to the whole of this part of the Trent Vale, and we wish to see such principles applied to each site to be considered. Questions from number 12 onward are not addressed in this submission.

Where we refer to the NPPF, we refer to the draft version, on the assumption that, so far as it is relevant to the point we are considering, the final version will reflect the current draft.

Q.1 the draft vision and strategic objectives
The listed policy points on p.13 are generally acceptable, with the significant exception of the 8th point. Nearness of mineral quarrying sites to end-use sites is of value to the commercial producers since transport costs are a significant element, but the Planning process must take account of those costs to the resident population and to local authorities which are not entered into commercial accounts. There is an inherent conflict within the NPPF between the need for a reliable supply of minerals and the need to take account of flood risks, particularly in light of anticipated climate change, predictions for which are more serious now than they were even in the initial stages of the drafting of this Plan. We also point out that closeness of an extraction site to the market is not the only measure of reducing transport costs, since the better-developed transport network on the Western side of the County may still make a longer journey a faster and cheaper one than adding vehicles to an already inadequate and congested road system. New building areas are most likely to be in logical places for population growth, which will already be places of relatively high density population. Such places will therefore suffer the worst damage from air pollution, noise, traffic congestion and dangers, loss of environment and amenity, and additional flood risk. More remote extraction sites result superficially in some extra cost only because the workings themselves do not take into account the very real cost to the residents and authorities. We happily accept the emphasis laid on biodiversity. However we strongly reject any suggestion that the destruction of farmland to be replaced by even more areas of stagnant open water is anything but harmful to biodiversity in the Trent Vale region.

Q2 sustainable development
We accept the principles in this section of the draft, and would lay particular emphasis on paragraph 3(a) in SP1. In the Trent Vale region there will be very many cases where the costs of development would significantly and demonstrably outweigh the benefit; not necessarily from the development itself, in the form of new buildings and infrastructure, but in terms highly relevant to this Draft Minerals local Plan, the cost to communities of extraction works. We also point out that one aspect of a low-carbon economy, referred to in paragraph 3.6 of the Justification to this section, should imply a low-concrete economy, as set out more fully in answer to Question 5.

Q3 Strategic Policy for Minerals Provision
We agree with the principles set out in SP2. In particular we approve of the priority being given to extension of existing sites over the development of new sites, and wish to emphasise the second paragraph in SP2, the need for avoidance of the damage of development of new sites.



Q4 Bio-diversity-led Restoration
While the general principles as set out in SP3 appear benevolent, they may be, and have previously been, used to present a false picture of the effects of minerals extraction as some sort of "gain." Specifically, it is wrong to suggest that there is any gain in the destruction of a diverse farming landscape of mixed pasture and arable land, with trees and hedges, turning it into an open area of stagnant water. The National Character Area description, NCA48, concerning the Trent and Belvoir Vales (NE429) makes it clear that "wetland" is already more than adequately provided in this part of Nottinghamshire. "Wildlife Corridors" referred to in the draft Strategic policy do not require a continuous ribbon of static holes full of water, but stopping and nesting sites that migratory wildfowl can fly between. Such places are, if anything, already over-supplied in this area by past gravel workings. If turned into high-quality nature reserves, such as at Attenborough, this is the work of decades and at great expense by charities and local councils. If left to minimum-cost "restoration," as suggested in 13.4, this creates a large wasted space of lifeless lagoons, as at Hoveringham. Such bodies of water may, if close to residential areas, present health risks to those with breathing problems, or, near road routes, create dangerous foggy conditions from time to time.

Q5 Climate Change
There are two important ways that climate change should affect the Minerals Plan, and both are referred to in Policy SP4. Paragraph 1(a) refers to the desirability of moving to a low carbon economy, but one aspect of such a move not mentioned is the desirability of using less concrete (and consequently less aggregate.) Creation of concrete not only uses large amounts of fossil fuel, but the process of creating cement specifically consists of breaking down the chemical composition of limestone by driving off large volumes of carbon dioxide into the atmosphere. Modern construction methods tend to use less concrete than was formerly used. As referred to in paragraphs 1(b) and 1(c), the second point on climate change is that it is producing greater extremes of weather, including longer periods of very high rainfall. This means areas at risk of flooding are in future at risk of more frequent and more severe potential flooding. Exacerbation of such risk, especially when close to existing human settlement, by extraction of gravel from river banks, is therefore to be all the more strenuously avoided.

Q6 Sustainable Transport
We would emphasise the point SO5 in the Objectives list in this section, "minimising impact on communities." This is not necessarily best achieved in all cases by barging or by having extraction sites close to end markets. Heavy lorries on single-carriageway roads necessarily cause extra congestion, danger, pollution and dust. Longer journeys by clearer roads - or better still by rail - may have less damaging impact. To cite an example no longer under consideration but studied locally in the now-discontinued previous Draft Minerals Local Plan, barging from a proposed new-built site in Shelford would have caused great problems to residents in Burton Joyce, a few metres from that site, from the noise and air pollution, from both its construction and operation, and added to the already unacceptable flood risk, while cutting out only about four miles of road travel before the entire loads were put back onto the same overcrowded A612 route.

Q7. The built, historic and natural environment
We agree with the Policy SP6 standards, and place particular emphasis on landscape character; flood risk; community amenity. As stated above, mainly in answer to Question 4, we have strong reservations about any claim, such as that at 3.49, that "restoration to wetland" has any meaningful contribution to make to local biodiversity. We strongly support the point made in paragraph 3.58 that the landscape in the Trent Washlands is particularly under pressure. We reiterate our concerns expressed earlier on issues mentioned under Flooding, paragraphs 3.61-3.64, but would add that increase in flood risk to areas of human settlement should not be contemplated at all, since the damage, both in financial terms and its destructive effect on people's lives, can far outweigh the value of material extracted. We therefore reject the assumption of paragraph 3.65 that it is sufficient "in some cases" merely "to reduce flood risks" from new mineral extraction plans. In our view there must always be an EIA before consideration of any such proposed quarrying. We state again our opposition to plans that would add significant amounts of heavy traffic to already-overloaded road systems. None of the sites in the present Draft is in the immediate vicinity of our Parish. However, under the previous Minerals Local Plan and the now-withdrawn first version of the current Draft Plan, proposals were made for gravel extraction on our immediate river bank, and then on the neighbouring Shelford bank, which would have brought quarrying to about 200 metres from the nearest houses in Burton Joyce. Therefore we are very conscious of the great value placed on the beautiful local landscape; and we would wish to avoid any such potential destructive impact at any site.

Q8 The Nottinghamshire Green Belt
The Green Belt is not itself designed to provide adequate protection against destructive mineral extraction operations. However, "beneficial use of the Green Belt" must include its landscape character, which is bound to be damaged by mineral working; and especially sand and gravel digging.

Q9 Mineral Safeguarding Consultation areas and associated minerals infrastructure
The greater part of this section is beyond our specific concerns or expertise. However, we view with alarm the reference to the wharf at Colwick, 3.90 and 3.91. The proposal for quarrying at Shelford, part of a revised version of the draft Minerals plan in the consultation and draft plan abandoned in 2017, would have had devastating consequences for Burton Joyce. This is not the place to raise those specific points again, but to say that the Shelford proposal has been excluded from this Draft for no doubt strong reasons. There is no reason to mention that wharf in this Draft Plan if there is not the expectation of adding the Shelford proposal at a later stage. The Fact that the wharf is out of use and part of an existing industrial estate is a positive reason to put that land to more productive use by removing the wharf, and removing also a spurious case for reviving that very threatening proposal.

Q10 Aggregate provision
We are clearly among those who, at the Issues and Options stage, referred to in the first box under MP1 on p.55, advocated a significant allowance for recycled materials as a replacement for newly-extracted aggregates. Given the very high proportion of aggregates in the minerals usage nationally, as quoted in paragraph 4.6, and the very high proportion that these materials represent in Nottinghamshire's minerals output, even a fairly small percentage contribution from recycled and secondary aggregates would make a very significant reduction to total extraction requirements. We must recognise that this is not in the financial interests of extraction businesses, nor perhaps does it help with imposed targets to be hit, but protection of the wider interests of the area and its inhabitants is the essence of planning controls. We therefore are also advocates for Option B in the forecast figures in the second box on that page, "a lower figure than Option A." But of course in the second set of Options we prefer that proposed, A, "Prioritise extensions to existing permitted quarries." We thus consider the figure for sand and gravel, 32.30 million tonnes, in Policy MP1, to be an overestimate that can lead to serious but avoidable harm to the area, and we object to the subsequent figures in the tables at 4.10.

Q11. The draft specific sand and gravel site allocations
Clearly this Council is among those described in the second paragraph of the first box under MP2: we consider that the impacts on local residents, the availability of capacity on the highway network and the availability of recycled materials in the main urban areas should override the attractions of an even geographical spread, and therefore we disagree with the Appraisal Findings under that heading. While in general terms we see benefits to river barging from some sites, this is subject to our severe concerns set out in the answer to Question 9. Since none of the specific proposed extraction sites in the remainder of this section is close to Burton Joyce or its road and transport routes, we make no comment on their individual merits but would simply wish to see that the same standards we would apply to our own area should apply to other places: the reduction in estimates of overall new-dug aggregate demand, and the protection of more densely inhabited parts of the County from the dangers, loss of quality of life, and environmental destruction that nearby quarrying operations would cause.