Nottinghamshire Minerals Local Plan Publication Version

Policy MP1
This policy has been based on evidence from the 2017 LAA, which relied on data to the end of 2016. It is not considered that teh LAA, and this policy, make enough provision for sand and gravel going forward. The LAA notes that the 10 year average sales figure for sand and gravel continues to fall as a greater period of recession data is taken into account and that sales have remained flat. Planning Practice is clear that LAAs should forecast the demand for aggregates based on the 10-year rolling sales data and other relevant local information. While the LAA discusses future growth, this is not reflected in the future provision. The planned house building rates are similar to the completions seen in 2005 and the extraction rate in that year was over 3mt, which is almost double the 10-year rolling avergae of 1.7mt, and this does not take into account other infrastructure projects. The LAA also notes that the replacement of worked out quarries has remained low, but it takes time for the industry to find new sites and put forward for inclusion in the plan have not been taken forward. This is a significant under provision therefore and it is considered that the requirement for sand and gravel should be significantly higher. 3mt per annum, would equate to a requirement for 57mt over the plan period of 19 years, and not 32.3mt.
Policy MP2
Previous responses have been made by CEMEX to this policy which have not been taken into account in this Publication Draft. A reserve assessment fro Cromwell has resulted in 0.76mt less at Cromwell and so the figures in Policy MP" are incorrect and there are not 17.5mt of permitted reserves, there are 0.76mt less than that. The policy does not allow for sufficient flexibility, as the reserve figures are estimates and further assessment work often means a reduction in volumes. There is not enough flexibility in the plan to allow for the uncertainties of geological investigation nor the mitigation consequences of Environmnetal Impact Assessment that can often mean that some reserves cannot be worked for other reasons. CEMEXs site at Cromwell North, for which an application has been submitted, should be included.
Changes
Increase forecast demand to 57 million tonnes
Amend reserves at Cromwell to 1.36mt
Add Cromwell North quarry 1.8mt

Policy MP1
This policy has been based on evidence from the 2017 LAA, which relied on data to the end of 2016. It is not considered that teh LAA, and this policy, make enough provision for sand and gravel going forward. The LAA notes that the 10 year average sales figure for sand and gravel continues to fall as a greater period of recession data is taken into account and that sales have remained flat. Planning Practice is clear that LAAs should forecast the demand for aggregates based on the 10-year rolling sales data and other relevant local information. While the LAA discusses future growth, this is not reflected in the future provision. The planned house building rates are similar to the completions seen in 2005 and the extraction rate in that year was over 3mt, which is almost double the 10-year rolling avergae of 1.7mt, and this does not take into account other infrastructure projects. The LAA also notes that the replacement of worked out quarries has remained low, but it takes time for the industry to find new sites and put forward for inclusion in the plan have not been taken forward. This is a significant under provision therefore and it is considered that the requirement for sand and gravel should be significantly higher. 3mt per annum, would equate to a requirement for 57mt over the plan period of 19 years, and not 32.3mt.
Policy MP2
Previous responses have been made by CEMEX to this policy which have not been taken into account in this Publication Draft. A reserve assessment fro Cromwell has resulted in 0.76mt less at Cromwell and so the figures in Policy MP" are incorrect and there are not 17.5mt of permitted reserves, there are 0.76mt less than that. The policy does not allow for sufficient flexibility, as the reserve figures are estimates and further assessment work often means a reduction in volumes. There is not enough flexibility in the plan to allow for the uncertainties of geological investigation nor the mitigation consequences of Environmnetal Impact Assessment that can often mean that some reserves cannot be worked for other reasons. CEMEXs site at Cromwell North, for which an application has been submitted, should be included.
Changes
Increase forecast demand to 57 million tonnes
Amend reserves at Cromwell to 1.36mt
Add Cromwell North quarry 1.8mt