Draft Nottinghamshire Minerals Local Plan

Question 11 - what do you think of the draft site specific sand and gravel allocations?
Remaining Permitted Reserves
Sites MP2a (Misson West) and MP2b (Newington South), noted in Policy MP2 1 (a), are sites operated by Hanson.
Permitted reserves at Misson West (MP2a) will soon be exhausted and permitted reserves at Newington South (MP2b) were exhausted in February 2018. Therefore neither of these sites, stated as to provide a combined 420,000 tonnes, will contribute existing permitted reserves towards the new MLP.
However, Policy MP2 1 (a) does not include Hanson's Newington West site as an existing permitted reserve, which was permitted in December 2015 under application reference number 1/15/01020/CDM. The site is currently operational and, as of July 2018, had remaining reserves of approximately 130,000 tonnes. At the current rate of production reserves are anticipated to be exhausted in 2019, again likely to be before the new MLP is formally adopted. A drawing identifying the site is enclosed.
Supply, Site Distribution and Proposed Allocations
Paragraph 4.18 of the draft MLP states the County estimates a shortfall of some 14.8 million tonnes of sand and gravel over the forthcoming plan period. As a result of which Policy MP2 seeks to allocate 6 extensions to existing quarries and 2 new quarries, which total some 15.46 million tonnes of reserve.
On the face of it, these proposed allocations appear to provide sufficient reserves in order to bridge the estimated total shortfall in Nottinghamshire. However, Table 3, Contributions to the sand and gravel shortfall over the plan period, indicates that only 3 of the extension sites and only 1 proposed new site are located within the Idle Valley.
It follows that of the total 15.46 million tonnes of additional reserve proposed for allocation, only 3.41 million tonnes is located at sites within the Idle Valley; an area suitable for viably, and sustainably, supplying sand and gravel to the north of the County as well as the Rotherham and Doncaster areas. The remaining 12.05 million tonnes is split across sites that are better suited to serve the south of the County.
This creates a clear imbalance between the north and the south of the County and their abilities to maintain an adequate supply of reserves in order to supply markets in their localities over the life of the plan, which Hanson believes should be reconsidered in detail.
Indeed, the issues of resource depletion in the Idle Valley and the north of the County, along with the associated impact on the ability to supply the Rotherham and Doncaster markets, are matters discussed at length in the County's most recent Local Aggregates Assessment (LAA), published October 2017.
The County should also recognise impacts further afield, with North Yorkshire County Councils most recent LAA (Third Review, 2017) stating, 'Pressure on NY sand and gravel resources to supply into West and South Yorkshire could also arise through any increasing constraints on supply of sand and gravel from other established supply areas such as the Idle Valley area in northern Nottinghamshire, as identified by Nottinghamshire County Council in their Local Aggregate Assessment, which concludes that resource depletion in the Idle Valley is likely to be the biggest factor potentially influencing exports to South Yorkshire. The Doncaster Local Aggregate Assessment states that South Yorkshire has an adequate supply of sand and gravel in the short term, but further reserves will need to be made available from alternative sources to ensure a steady and adequate supply. It also notes that production of sand and gravel in Nottinghamshire is moving southward away from the Idle Valley, which could impact on supply later on in the plan period. A joint position statement relating to aggregates supply into Doncaster and Rotherham from Nottinghamshire and Derbyshire has been completed by the relevant authorities to help safeguard the aggregates supply position.'
Duty to Co-Operate
As mentioned above, in November 2016 a joint minerals position statement was agreed between Nottinghamshire County Council, Rotherham MBC and Doncaster MBC. Amongst other things, Issue 2 of the Statement, which concerns the continued provision of sand and gravel to Rotherham MBC and Doncaster MBC, states 'Historically, a significant amount of sand and gravel has been exported to Rotherham Metropolitan Borough Council and Doncaster Metropolitan Borough Council from the Idle Valley in the north of Nottinghamshire. This demand is expected to continue as the Rotherham and Doncaster joint LAA identifies a current lack of permitted sand and gravel quarries in the area along with a significant shortfall expected over the plan period'.
The statement continues by noting, 'As part of the wider discussions between the three authorities a joint aggregate minerals position statement has been prepared. This sets out an agreed approach thatNottinghamshire would continue to contribute to expected demand from the Rotherham and Doncaster areas in the short term'.
The County will no doubt be aware that Doncaster MBC is currently preparing a new Local Plan for the period up to 2032 and that consultation is underway on its various visions, objectives, policies and proposals, which will include policies in respect of minerals. The County is referred to Doncaster MBC's document titled Local Plan Evidence Base, Assessing Mineral Sites Representations, Version: Consultation Draft May 2018, which states: 'Evidence within previous LAAs indicates that it may be difficult for the council to maintain a supply of sand and gravel to meet our apportionment up to the end of the plan period....... Previous monitoring reports and aggregate assessments identify that sharp sand and gravel essential for concreting products is a declining resource in our area and will become increasingly difficult to find in the future. The Local Aggregates Assessment (LAA) identifies minerals flow between authorities and counties and quarries in North Nottinghamshire will in the short term provide sand and gravel to support development in Doncaster. 30% of the sand and gravel extracted in Nottinghamshire is exported to the Yorkshire and Humber region, there is however no additional detail as to how much is consumed in the Doncaster area. The Aggregate Minerals Survey collects monitoring figures as part of a four yearly survey; this survey confirms that in 2009 84% of the sand and gravel landbank was made up of soft sand, which has a small but on-going demand. Paragraph 3.9 of the 2014 Annual Monitoring Report also confirms that that the reserves of sand and gravel in South Yorkshire are almost exclusively made up of soft sand deposits. This has resulted in fewer larger mineral companies coming forward with site representations or extensions to existing quarries.'
This further emphasises the importance of Nottinghamshire's sand and gravel reserves to neighbouring authorities and the need for the County to re-consider the geographical distribution of site allocations in the new MLP; to ensure that the ability to viably supply sand and gravel to the north of the county and neighbouring areas is maintained over the life of the plan.
Barnby Moor
It is clear that the County has sought to favour the allocation of a fewer number of larger potential sites and site extensions in order to maintain supply over the plan period. Whilst the merits of this approach are recognised in the longer term, Hanson considers there is still a need to maintain the immediate supply of reserves during the early years of plan.
The County's October 2017 LAA indicates that Hanson's Newington Quarry currently contributes the equivalent of 16% of the total sand and gravel sales produced by Nottinghamshire sand and gravel quarries. Importantly, the site predominantly serves markets in the north of the County as well as Rotherham and Doncaster.
As previously mentioned, Newington South and Misson West will not contribute to the County's existing permitted reserves during the plan period. Newington West, which is not identified as an existing site in policy MP2, is anticipated to be exhausted prior to adoption of the new plan, so will not contribute either.
As such the contribution Newington currently makes, particularly in providing a much needed supply for the north of the County and neighbouring areas, will be lost if a replacement site does not come online in the early stages of the new plan.
Hanson maintains its view that Barnby Moor represents a viable and deliverable site within the Idle Valley resource block, which can help to maintain the supply of much needed concreting aggregates to the Nottinghamshire and South Yorkshire and Doncaster markets. As described, the latter areas depend heavily on imports to meet their construction needs. Given the positive contribution that Barnby Moor would make as a replacement for Newington, Hanson considers this should be reflected by an allocation of the site.
Following Hanson's January 2018 Call for Sites submission, the Council expressed concern over the status of the landownership at Barnby Moor, which is referenced in the Analysis within Table 9, Summary of Key Issues, of the County's Draft site selection methodology and assessment July 2018. The landownership has since been resolved and, as a result, Hanson subsequently wishes to submit a revised proposal for the County to reconsider allocating the site. Full details and plans are enclosed.