Nottinghamshire Minerals Local Plan Publication Version

MP1
Lincolnshire County Council's Minerals and Waste Planning Policy Team objects to policy MP1 on the
basis that the policy is not sound in its current form, because it does not make sufficient
provision for sand and gravel extraction within Nottinghamshire over the plan period.

Policy MP1 has not been positively prepared: The provision is based on a Local Aggregate Assessment
which has failed to objectively assess the needs of the County. This is because the proposed provision rate of 1.7mt per annum for sand and gravel is based on depressed average sales figures which do not take into account Nottinghamshire's increased reliance on imports of sand and gravel from Lincolnshire to meet demand. Our concerns in this regard have been well documented in our representations to earlier drafts of the emerging Nottinghamshire Minerals Local Plan and on-going
correspondence with Nottinghamshire County Council.

Policy MP1 is not justified: There is no reasonable justification in the publication draft or the supporting Local Aggregate Assessment as to why Nottinghamshire County Council need to continue to rely on significant imports of sand and gravel from Lincolnshire, rather than making appropriate provision for a steady and adequate supply of aggregates from its own substantial indigenous
resources. In this respect is should be pointed out that historically Nottinghamshire was the most important producer of sand and gravel in the East Midlands, and was only overtaken by Lincolnshire due to the aftermath of the recession when some mineral operators temporarily rationalised their operations close to the county boundary. The extent of the available sand and gravel resource in Nottinghamshire was demonstrated by the significantly greater number of sites originally proposed for allocation in the withdrawn submission draft Nottinghamshire Minerals Plan (Feb/March 2016).

Policy MP1 is not effective: In not addressing the above cross-boundary issues, the proposed sand and gravel provision is insufficient to meet demand in the County without substantial imports from Lincolnshire. This is masked by the current practice adopted in the Local Aggregate Assessment of basing the landbank on the "10-year average sales" approach which inflates the landbank calculations This is deceptive in that it gives the impression that there are no supply issues in Nottinghamshire.

Policy MP1 is not consistent with national policy. In not addressing the above issues, the proposed sand and gravel provision rate is contrary to the NPPF as it fails to have due regard to this "other relevant local
information".

It is recommended that an appropriate uplift is applied to the proposed sand and gravel provision rate in order to account for the demand that is currently driving imports from Lincolnshire.

Furthermore, given Nottinghamshire's importance as a sand and gravel producer, the level of provision should be based on the assumption that sales in Nottinghamshire will return to a similar proportion of total sales in the East Midlands achieved prior to the recession.

Representatives of Lincolnshire County Council's Planning Policy Team would like the opportunity to participate in the hearing sessions in order to discuss our concerns.

MP2

In conjunction with our comments in relation to Policy MP1, Lincolnshire County Council's Minerals and Waste Planning Policy Team objects to Policy MP2 because it does not make sufficient provision for sand and gravel extraction in Nottinghamshire over the Plan Period.

The number of sites allocated is based on a deflated provision rate as argued in relation to Policy MP1. As a consequence, we consider that the productive capacity of the proposed allocations does not provide sufficient flexibility to respond to increases in demand. Furthermore, when referring to the delivery schedule in Appendix 1 of the publication draft, it appears the majority of the proposed allocations could be worked out prior to the end of the plan period, which would further constrain productive capacity.

Allocating additional sites for sand and gravel extraction based on an increased provision rate would ensure a greater productive capacity for the duration of the plan period and allow sufficient flexibility to accommodate changes in demand, whilst in turn reducing the reliance on imports from Lincolnshire, for which there is no apparent justification, and ensuring Nottinghamshire remains an important provider of Sand and Gravel in the East Midlands.

Representatives of Lincolnshire County Council's Planning Policy Team would like the opportunity to participate in the hearing sessions in order to discuss our concerns.

MP1
Lincolnshire County Council's Minerals and Waste Planning Policy Team objects to policy MP1 on the
basis that the policy is not sound in its current form, because it does not make sufficient
provision for sand and gravel extraction within Nottinghamshire over the plan period.

Policy MP1 has not been positively prepared: The provision is based on a Local Aggregate Assessment
which has failed to objectively assess the needs of the County. This is because the proposed provision rate of 1.7mt per annum for sand and gravel is based on depressed average sales figures which do not take into account Nottinghamshire's increased reliance on imports of sand and gravel from Lincolnshire to meet demand. Our concerns in this regard have been well documented in our representations to earlier drafts of the emerging Nottinghamshire Minerals Local Plan and on-going
correspondence with Nottinghamshire County Council.

Policy MP1 is not justified: There is no reasonable justification in the publication draft or the supporting Local Aggregate Assessment as to why Nottinghamshire County Council need to continue to rely on significant imports of sand and gravel from Lincolnshire, rather than making appropriate provision for a steady and adequate supply of aggregates from its own substantial indigenous
resources. In this respect is should be pointed out that historically Nottinghamshire was the most important producer of sand and gravel in the East Midlands, and was only overtaken by Lincolnshire due to the aftermath of the recession when some mineral operators temporarily rationalised their operations close to the county boundary. The extent of the available sand and gravel resource in Nottinghamshire was demonstrated by the significantly greater number of sites originally proposed for allocation in the withdrawn submission draft Nottinghamshire Minerals Plan (Feb/March 2016).

Policy MP1 is not effective: In not addressing the above cross-boundary issues, the proposed sand and gravel provision is insufficient to meet demand in the County without substantial imports from Lincolnshire. This is masked by the current practice adopted in the Local Aggregate Assessment of basing the landbank on the "10-year average sales" approach which inflates the landbank calculations This is deceptive in that it gives the impression that there are no supply issues in Nottinghamshire.

Policy MP1 is not consistent with national policy. In not addressing the above issues, the proposed sand and gravel provision rate is contrary to the NPPF as it fails to have due regard to this "other relevant local
information".

It is recommended that an appropriate uplift is applied to the proposed sand and gravel provision rate in order to account for the demand that is currently driving imports from Lincolnshire.

Furthermore, given Nottinghamshire's importance as a sand and gravel producer, the level of provision should be based on the assumption that sales in Nottinghamshire will return to a similar proportion of total sales in the East Midlands achieved prior to the recession.

Representatives of Lincolnshire County Council's Planning Policy Team would like the opportunity to participate in the hearing sessions in order to discuss our concerns.

MP2

In conjunction with our comments in relation to Policy MP1, Lincolnshire County Council's Minerals and Waste Planning Policy Team objects to Policy MP2 because it does not make sufficient provision for sand and gravel extraction in Nottinghamshire over the Plan Period.

The number of sites allocated is based on a deflated provision rate as argued in relation to Policy MP1. As a consequence, we consider that the productive capacity of the proposed allocations does not provide sufficient flexibility to respond to increases in demand. Furthermore, when referring to the delivery schedule in Appendix 1 of the publication draft, it appears the majority of the proposed allocations could be worked out prior to the end of the plan period, which would further constrain productive capacity.

Allocating additional sites for sand and gravel extraction based on an increased provision rate would ensure a greater productive capacity for the duration of the plan period and allow sufficient flexibility to accommodate changes in demand, whilst in turn reducing the reliance on imports from Lincolnshire, for which there is no apparent justification, and ensuring Nottinghamshire remains an important provider of Sand and Gravel in the East Midlands.

Representatives of Lincolnshire County Council's Planning Policy Team would like the opportunity to participate in the hearing sessions in order to discuss our concerns.

MP1
Lincolnshire County Council's Minerals and Waste Planning Policy Team objects to policy MP1 on the
basis that the policy is not sound in its current form, because it does not make sufficient
provision for sand and gravel extraction within Nottinghamshire over the plan period.

Policy MP1 has not been positively prepared: The provision is based on a Local Aggregate Assessment
which has failed to objectively assess the needs of the County. This is because the proposed provision rate of 1.7mt per annum for sand and gravel is based on depressed average sales figures which do not take into account Nottinghamshire's increased reliance on imports of sand and gravel from Lincolnshire to meet demand. Our concerns in this regard have been well documented in our representations to earlier drafts of the emerging Nottinghamshire Minerals Local Plan and on-going
correspondence with Nottinghamshire County Council.

Policy MP1 is not justified: There is no reasonable justification in the publication draft or the supporting Local Aggregate Assessment as to why Nottinghamshire County Council need to continue to rely on significant imports of sand and gravel from Lincolnshire, rather than making appropriate provision for a steady and adequate supply of aggregates from its own substantial indigenous
resources. In this respect is should be pointed out that historically Nottinghamshire was the most important producer of sand and gravel in the East Midlands, and was only overtaken by Lincolnshire due to the aftermath of the recession when some mineral operators temporarily rationalised their operations close to the county boundary. The extent of the available sand and gravel resource in Nottinghamshire was demonstrated by the significantly greater number of sites originally proposed for allocation in the withdrawn submission draft Nottinghamshire Minerals Plan (Feb/March 2016).

Policy MP1 is not effective: In not addressing the above cross-boundary issues, the proposed sand and gravel provision is insufficient to meet demand in the County without substantial imports from Lincolnshire. This is masked by the current practice adopted in the Local Aggregate Assessment of basing the landbank on the "10-year average sales" approach which inflates the landbank calculations This is deceptive in that it gives the impression that there are no supply issues in Nottinghamshire.

Policy MP1 is not consistent with national policy. In not addressing the above issues, the proposed sand and gravel provision rate is contrary to the NPPF as it fails to have due regard to this "other relevant local
information".

It is recommended that an appropriate uplift is applied to the proposed sand and gravel provision rate in order to account for the demand that is currently driving imports from Lincolnshire.

Furthermore, given Nottinghamshire's importance as a sand and gravel producer, the level of provision should be based on the assumption that sales in Nottinghamshire will return to a similar proportion of total sales in the East Midlands achieved prior to the recession.

Representatives of Lincolnshire County Council's Planning Policy Team would like the opportunity to participate in the hearing sessions in order to discuss our concerns.

MP2

In conjunction with our comments in relation to Policy MP1, Lincolnshire County Council's Minerals and Waste Planning Policy Team objects to Policy MP2 because it does not make sufficient provision for sand and gravel extraction in Nottinghamshire over the Plan Period.

The number of sites allocated is based on a deflated provision rate as argued in relation to Policy MP1. As a consequence, we consider that the productive capacity of the proposed allocations does not provide sufficient flexibility to respond to increases in demand. Furthermore, when referring to the delivery schedule in Appendix 1 of the publication draft, it appears the majority of the proposed allocations could be worked out prior to the end of the plan period, which would further constrain productive capacity.

Allocating additional sites for sand and gravel extraction based on an increased provision rate would ensure a greater productive capacity for the duration of the plan period and allow sufficient flexibility to accommodate changes in demand, whilst in turn reducing the reliance on imports from Lincolnshire, for which there is no apparent justification, and ensuring Nottinghamshire remains an important provider of Sand and Gravel in the East Midlands.

Representatives of Lincolnshire County Council's Planning Policy Team would like the opportunity to participate in the hearing sessions in order to discuss our concerns.