Nottinghamshire Minerals Local Plan

Representations - by respondent

Volume 1 of 11 Respondent numbers 759 – 1073

This document sets out in full all of the representations received to the Submission Draft. They are presented in respondent number order. An index has been provided that lists all respondents in alphabetical order for ease of reference. SD7b provides a summary of the representations in plan order.

Index of Respondents

Organisations

Organisation Respondent Respondent Number

AKS Community Action Group White, Linda Mrs 7742

Baker, Neil (Baker Barnett Alkane Energy UK Limited 7637 for 7638 Limited) Anglian Water Patience, Stewart 7379

Ashfield District Council Wiltshire, Stuart 7848

Auckley Parish Council Caygill, Marorie 4541

Averham, Kelham and Staythorpe Parish Burbidge, Mr J 781 Council

Barnby in the Willows Parish Council Wellard, Yvette 3548

Barton in Fabis Parish Council Angell, Bev 891

Brett Aggregates Limited Owen, Jenny 2953 for 69

Bulcote Parish Council Aston, RJ 880

Burton Joyce Parish Council Dawn, Jackie 896

Burton Joyce Village Society Wright, Stephen 6664 for 7122

CAGE (petition) Armstrong, David 7719

Caunton Parish Council Catherine Millward 2315

CBOA Horne, Richard 3319

Coddington Against Gravel Extraction Armstrong, David 7719

Coddington Against Gravel Extraction Campbell, Robert 7780

Coddington Parish Council Wellard, Yvette 7846

CPRE Cook, Fred 2833

Creswell Heritage Trust Shelley, Roger 2978

Cromwell Parish Meeting Swift, David 7619 Derby and Derbyshire Development Plans Spence, Michelle 7910 Joint Advisory Committee

Derbyshire County Council Murfin, Rob 1041 Earl of Listowel and Mrs Margaret Ryan, Will (Savills) 7852 for 7851 Campbell East Bridgford Parish Council Clarke, Philip 7653

Egdon Resources UK Ltd Bailey, Justine (Barton Wilmore) 7831 for 1777

Environment Agency Pitts, Andrew 2714

Fiskerton com Morton Parish Council Aston, RJ 759

Gedling Borough Council Foster, Greame 2120

Gunthorpe Parish Council Oldham, Gordon 1670

Hanson Quarry Products Europe Limited Ayres, Ben 1021

Harworth Estates Todd, Kate (Heaton Planning) 7622 for 1941

Highways England Murrain, Trevor 7614

Historic England Jordan, Rachel 7609

Hockerton Parish Meeting Hall, Andrew 883

Holme Parish Richards, Patricia 1835

Hucknall Branch Labour Party Cooper, Kath 7776 Warren, Spencer (Heaton Igas 2395 for 7911 Planning) Kelham Hall Limited Pass, Jonathan 7854

Kirklington Parish Council Cowlan, Helen 879

Kirton Parish Council Wildgust, Karen 7714 Oldridge, Mark (Mineral Latham Family 1760 for 7847 Surveying Services Limited) Rees, Simon (Greenfield London Rock Supplies Ltd 2976 for 7882 Associates) Lowland Derbyshire and Nottinghamshire Carter, Rosy 2670 Local Nature Partnership Mick George Gough, John 2752

MPA Ratcliff, Malcolm 1517

National Trust Miller, Kim 2987

Natural England Deeming, Roslyn 1750

Newark Air Museum Heeley, Howard 3485

Newark and Sherwood District Council Tubb, Matthew 2950

Newark PAGE Simms, Steve 2945 for 2485 Newark Town Council Mellor, Alan 1573

NFU Tame, Paul 1564

Norwell Parish Council Millwall, Catherine 810

Nottingham City Council Grant, Matthew 1036

Nottingham Friends of the Earth Lee, Nigel 1261

Nottinghamshire Wildlife Trust Bradley, Janice 1495

Public Health England Aldridge, Stuart 7747 Rolandon Water and Sea Fright Advisory Dodwell, John 2077 Service Standen, Jonathan (Nathaniel Rotherham Sand and Gravel 7607 for 496 Lichfield & Partners) RSPB Wilkinson, Colin 1006

Rushcliffe Borough Mapletoft, Richard 969

SAGE Whysall, Mr JR 2392

Shelford Parish Council Squires, Brian 1799 for 7840

Southwell Town Council Standish, Carol 784

Sport England Beard, Steve 1586

Tarmac Todd, Kate (Heaton Planning) 7622 for 580

The Coal Authority Northcote, Anthony 2032 for 2853

Upton Parish Council Johnson, Ian 7786 for 618

West Stockwith Parish Council Harford, Dave 2701

Individuals

Respondent Respondent Number Adams, Anne 3626 Adey, James 7693 Allan, John 3617 Allen, Joy 7867 Angelides, Dr Paul (represented by Bassett, Mark - Freeths) 7833 Arkely, Peter 3817 Armstrong, Amanda 7755 Armstrong, David 2806 Armstrong, Jackie 2881 Athey, Gary 7790 Austin, Tony 7877 Barbary, Tim 7670 Barker, John 3532 Barlow, Stephen 7660 Barron, Philip Dr 7749 Bassey, Michael 3323 Bassey, Michael and 23 others 3323 Batchford, Jane 3045 Bates, Michael 7706 Baxendale, Bryn 3993 Beecroft, Nina 7873 Bell, David and Susan 7705 Bell, Philip (represented by DeRenzy-Tomson, Fisher German) 7850 for 3585 Bell, Susan 7705 Bennett, Carolyn 7820 Bevan, Sharon 3452 Black, Craig 3612 Blinston, Phill 7792 Blount, Sarah 3460 Boot, Richard 7657 Bosworth, Susan 7795 Bousfield, Lorraine 7763 Bousfield, Paul 7762 Bowerman, Christopher 2997 Bradey, Ian 7824 Bradey, Rachel 3623 Brandon-Bravo, Martin 2993 Brettle, Eleanor and Richard 7890 Briggs- Price, Sally 7908 Brown, Heather 7414 Brown, Raymond 7410 Brown, Richard 7411 Bryan, Christina 7895 Burbidge, John 7826 Burch, Mr and Mrs 7896 Burgess, Gerry 7883 Burke, Norma 3766 Campbell, Robert 3140 Cassidy, Deborah 7818 Channon, Simon 7724 Chatterton, John 5448 Clarke MP, Kenneth 890 Clarke, Ian 7646 Coddington, John 7855 Coddington, Pamela 3872 Coles, Caroline 3895 Coles, Julian 2981 Collington, Di 7907 Collins, Paul (represented by Bassett, Mark - Freeths) 7837 Collins, Sharon (represented by Bassett, Mark - Freeths) 7838 Collyer, Graham 2879 Corner, Richard 7789 Cutts, Cllrs Mrs Kay 6747 Dankowski, Annette (represented by Bassett, Mark - Freeths) 7839 Davey, Brian 2763 Davies, Daniel 7699 Davies, PS 2480 Davies, Ralph and Anna 3075 Derbyshire, Celia 7709 Dobson, Maureen Councillor 3619 Douglass, Wg Cmd Mike 7668 Doyle, Cllr Kevin 7086 Doyle, Joyce 2736 Doyle, Peter 2788 Edis, Beryl 7860 Edwards, Ray 3531 Evans, John 7893 Fell, Roger 2474 Fereday, Andrew 7756 Fletcher, Robert 2990 Galley, Bob 7686 Garner, Jonathan 3291 Gell, John 7672 Gill, Madeline and Clifford 7897 Gillespie, John 7881 Gilroy, Nic 3767 Green, Penny 7904 Grummitt, Jui and Peter 7887 Grundy, Steve (represented by Bassett, Mark - Freeths) 7836 Hall, Chris 3582 Hambidge, Mr and Mrs 7902 Hardy, Lawrence 7683 Harris, Glen 3044 Harris, Heather 7865 Harris, Lee 7866 Harrison, Alison 4011 Harrison, Andrew 7843 Harrison, Charlotte 3322 Harrison, Clifford William 4251 Harrison, Diane 3321 Harrison, Edna 7859 Harrison, Jonathan 3068 Harrison, Marilyn 3490 Harrison, Tim 3311 Hatton, Adrian and P 2828 Hayes, Rose 7886 Hedge, David C 3097 Henson, Philip 3575 Hobbs, DJ 7888 Holmes, Yasmin 3063 Holt, Jane 7885 Howick, Arthur 7863 Howick, June Mary 7864 Humphries, Faith 7857 Humprhries, Faith 7857 Jeal, Paul 7704 John, Sally 7710 Johnson, Deborah 7690 Johnson, Greta and Leslie 2724 Jones, Rob 7680 Jones, Robert 7680 Kawecki, John 7876 Keel, Janine 3613 Khin-Htun, Swe 7884 Kilby, Kate 7708 Kitson, Derek 2489 Knight, Hazel 7687 Laine, Liz 3303 Lane, Mr KN (represented by Kitson, Derek) 2489 for 2754 Laughton, Cllr Bruce 1073 LeBlanc, Leon 7830 Lightbody, Jonathan 3071 Lyth, Dr Peter 7696 Mackin, M, C,C and C 7898 Mann MP, John 792 Marsh, Stephen 7750 Marshall, John William 3877 Mayfield, Jason 7743 Michaelides, Custas 7862 Mill, Judith 7829 Miller, David 1247 Miller, Margaret Anne 7880 Milne, Alan and Jenny 7761 Moodie, David 7892 Mossop, Liz 3038 Mulliss, Stephen 7849 Ng, Myra 7757 Overbury, Frances 3037 Overbury, Frances 3037 Overbury, Michael 3870 Parkes, Robert 3326 Parkinson, Tim 7694 Parrett, Christopher 3469 Patel, Prem 3754 Patel, Sharon 4506 Pearson, Dorothy 7871 Pearson, Nicholas 7700 Pennelegion, Simon 7717 Peterson, John 7673 Peterson, John 7673 Phillips, Alan 3342 Pierrepoint, Carol 3729 Plowright, Anegla and Kaczmarzuk, Paul and Harriet 3160 Pollock, Neil 7878 Potter, J 2108 Primett, Jamie 7832 Rayner, Philip Dr 7752 Redhead, Mr and Mrs 7858 Redhead, Mr and Mrs J 7858 Riddell, Eva 7872 Rigby, Amanda 7770 Roche, Patrick and Susan 7899 Rodgers, Mr and Mrs LW 7900 Ross, Mark 3459 Rowles, Gill 7692 Rushby, Helen 7730 Saddington, Cllr Sue 1195 Sawle, Geoff 2783 Seymour, Daniel 7679 Short, Stephen 7667 Sims, Kevin 7725 Sketchley, Beverley 3476 Smallwood, Celia 2893 Smith, Geoffrey 3533 Smith, J 3662 Smith, Jeanette 7661 Smith, Martin 7727 Snell, Frances 7759 Spit, Lysette 7731 Spit, Lysette 7731 Stables, Terry 907 Staff, Michael 3695 Stephens, Mark (represented by Bassett, Mark - Freeths) 7835 Stokes, Liz 7844 Taylor, Michael 7828 Thamburaja, Dr Sree (represented by Bassett, Mark - Freeths) 7834 Tilley, Sheila 4507 Toogood, Mr & Mrs 7901 Towers, Mr and Mrs 3001 Townsend, DF and M 7681 Tunaley, Paul 3014 Turner, Kate 7906 Twidale, Andrew 7744 Usaite, Inge 7677 Varma, Aarti 7823 Waddington, Alan M 7889 Wallace, AS 2596 Wallinder, Margaret and Stig 3814 Walton, David 7745 Warwick, Tony 3331 Watchman, John 7785 Waterfield, Brian 5656 Webb, Sarah 3553 Weightman, Gail 7869 Weightman, Steven 7868 Wesson, Doreen and Barrie 7676 Whitburn, Terence 3340 White, Kathy 7879 White, Linda 7642 White, Mr LE & Mrs KA 7879 Whitt, Daniel 7675 Willcocks, Dr Valerie 7774 Wilson, David 7905 Wilson, Jo 3674 Wilson, John Joseph 7894 Wilson, Lindy 3087 Wilson, Simon 7659 Wolfenden, John 7806 Woolridge, Ian 7726 Worsdall, G 7891 Wright, BG 3489 Wright, Neil 3026 Wright, Olwen 7870 Yesil, Alisan 2994 Yesil, Dileksu 7875 Yesil, Mehmet Erdem 7874 Yesil, Saniye 7811

Index of Volumes

Volume Respondent numbers

1 759 - 1073

2 1195 – 1799 for 7840

3 1835 - 2736

4 2752 - 2881

5 2893 - 2993

6 2994 - 3754

7 3766 - 7717

8 7719

9 7724 - 7824

10 7826 - 7872

11 7873 - 7910

Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29472

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29472 Document: Minerals Local Plan Submission Draft Section: Overview of the plan area Support/Object: Object

The Trent Valley is already recognised as having a raised level of respiratory disease in its population, of which a major contributory factor is particulates in the air, additional mineral extraction and associated increase in traffic can only exacerbate this problem. Therefore this needs to be considered as part of the environmental impact on health in the relative health assessment. Consideration must also be given to the additional water drainage issues extraction would cause, as this can only increase flood risk. In the Newark / Kelham area there are 18 sites / buildings of historic interest, these must be safeguarded.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

This email is acknowledgement of the receipt of your representation. It is NOT confirmation that the representation has yet been registered. You will not receive any further notification by email that your representation has been registered until the end of the participation period.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29474

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29474 Document: Minerals Local Plan Submission Draft Section: Plan 1: Overview of the Plan Area Support/Object: Object

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29475

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29475 Document: Minerals Local Plan Submission Draft Section: Strategic Objectives, SO2: Providing an adequate supply of minerals Support/Object: Object

NPPF and Planning Officers Society and Aggregate working party guidelines tstates tha MPAs should use available latest figures when looking at apportionment within emerging MLP calculations. In failing to take into account the most up to dates figures regarding aggregates demand and without giving evidence to support the assumed regional growth demand this plan does not present a credible evidence base. In the case of Notts emerging MLP, using latest 2015 LAA gives a 10 year rolling average sales figure of 2.24million Tonnes/annum (2004‐13) and permitted reserves figure of 17.81 million tonnes (as at Dec 2013) which results in a shortfall of some 20.27 million tonnes for the MLP period to 2030, which is some 9.44 fewer millions of tonnes or, a very significant 32% reduction when compared with current suggestions. The draft submission fails to take into consideration as a mineral resource the role of recycled and secondary waste.

SUMMARY

NPPF and Planning Officers Society and Aggregate working party guidelines states that MPAs should use available latest figures when looking at apportionment within emerging MLP calculations. In failing to take into account the most up to dates figures regarding aggregates demand and without giving evidence to support the assumed regional growth demand this plan does not present a credible evidence base.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29476

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29476 Document: Minerals Local Plan Submission Draft Section: Strategic Objectives, SO5: Minimising impacts on communities Support/Object: Object

Firstly the complicated method being used of raising concerns/objections is a barrier for the wider community involvement in the planning process. Unfortunately the effect of this is frustration on not getting valid points across and in creating apathy when public input is sought in the future. Secondly as local community will not be able to maintain their current level of quality of life, and health from impacts such as traffic, visual impact, dust, noise and water resources should Flash Farm quarry development proceed, it should be withdrawn from the Minerals Local Plan.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29477

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29477 Document: Minerals Local Plan Submission Draft Section: Strategic Objectives, SO7: Protecting and enhancing historic assets Support/Object: Object

Historic England lists eleven listed structures in Kelham, all no more than 200 metres from the A617, which will be used by HGVs carrying aggregate towards the A1/A4. These include several Grade II residences within 50 metres of the road and the Grade I listed Kelham Hall and St Wilfred's Church. The road passes over Grade II listed Kelham Bridge, originally designed as a toll bridge, deliberately narrow, with a 90‐ degree turn intended to slow traffic. The inclusion of Flash Farm will pose additional threats to these historic structures.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

This email is acknowledgement of the receipt of your representation. It is NOT confirmation that the representation has yet been registered. tYou will no receive any further notification by email that your representation has been registered until the end of the participation period.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29478

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29478 Document: Minerals Local Plan Submission Draft Section: Strategic Objectives, SO8: Protecting agriculturalsoils Support/Object: Object

Flash Farm is a green field site actively farmed for dairy grazing. Green field sites should not be considered as their agricultural value will not be reinstated to a quality that would support the previous level of food production.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29479

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29479 Document: Minerals Local Plan Submission Draft Section: SP2: Minerals Provision Support/Object: Object

NPPF and Planning Officers Society and Aggregate working party guidelines states that MPAs should use available latest figures when looking at apportionment within emerging MLP calculations. NCC have failed to use the most up to date data in calculation of sand and gravel requirement throughout the plan period. As a result the forecasted tonnage is unnecessarily high and is out of line with economic trends. The calculated tonnage forecast ignores the positive impact of recycled and secondary minerals and material differences in future construction methods.

In the case of Notts emerging MLP, using latest 2015 LAA gives a 10 year rolling average sales figure of 2.24million Tonnes/annum (2004‐13) and permitted reserves figure of 17.81 million tonnes (as at Dec 2013) which results in a shortfall of some 20.27 million tonnes for the MLP period to 2030, which is some 9.44 fewer millions of tonnes or, a very significant 32% reduction when compared with submission document figures.

SUMMARY

NPPF and Planning Officers Society and Aggregate working party guidelines states that MPAs should use available latest figures when looking at apportionment within emerging MLP calculations. NCC have failed to use the most up to date data in calculation of sand and gravel requirement throughout the plan period. As a result the forecasted tonnage is unnecessarily high and is out of line with economic trends. The calculated tonnage forecast ignores the positive impact of recycled and secondary minerals and material differences in future construction methods.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 This email is acknowledgement of the receipt of your representation. It is NOT confirmation that the representation has yet been registered. You will not receive any further notification by email that your representation has been registered until the end of the participation period.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29480

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29480 Document: Minerals Local Plan Submission Draft Section: SP3: Biodiversity‐Led Restoration Support/Object: Object

While we support the Plan's emphasis on bio‐diversity, the current use of Flash Farm is grazing and the likelihood is that it will be returned to the same, negating any opportunity to increase bio‐diversity in the area. The commercial nature of Flash Farm makes it an unsuitable site for development.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29481

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29481 Document: Minerals Local Plan Submission Draft Section: SP4: Climate Change Support/Object: Object

Averham and Kelham are in Environment Agency designated Flood Zones, which Clause B of the Policy advises should be avoided for development. Surplus water resulting from sand and gravel extraction at Flash Farm is likely to be pumped into Mission Dyke, which is unlikely to have sufficient capacity. The Dyke is the storm‐drain for nearby domestic residences and there is potential for any overflow to pass backwards through the storm drain into these residencies. Any restorations schemes are unlikely to improve bio‐diversity as the land is currently used for commercial farming.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29482

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29482 Document: Minerals Local Plan Submission Draft Section: SP6: The Built, Historic and Natural Environment Support/Object: Object

We believe that the development of Flash Farm will have a detrimental effect on the local heritage, which includes 18 listed structures in Averham and Kelham all of which contribute to the historic environment of the Villages. It will also affect the character of the landscape, in particular the vista towards Kelham Hills. It presents an additional flood risk and will bring additional traffic onto an already busy road which narrows significantly through Kelham and over Kelham Bridge. This additional traffic will also exacerbate problems of noise and air pollution which already exceed CRTN and WHO standards.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29484

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29484 Document: Minerals Local Plan Submission Draft Section: SP6 Justification Support/Object: Object

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29485

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29485 Document: Minerals Local Plan Submission Draft Section: SP4 Justification Support/Object: Object

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29486

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29486 Document: Minerals Local Plan Submission Draft Section: SP3 Justification Support/Object: Object

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29487

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29487 Document: Minerals Local Plan Submission Draft Section: SP2 Justification Support/Object: Object

NPPF and Planning Officers Society and Aggregate working party guidelines states that MPAs should use available latest figures when looking at apportionment within emerging MLP calculations. NCC have failed to use the most up to date data in calculation of sand and gravel requirement throughout the plan period. As a result the forecasted tonnage is unnecessarily high and is out of line with economic trends. The calculated tonnage forecast ignores the positive impact of recycled and secondary minerals and material differences in future construction methods.

SUMMARY

NPPF and Planning Officers Society and Aggregate working party guidelinest states tha MPAs should use available latest figures when looking at apportionment within emerging MLP calculations. NCC have failed to use the most up to date data in calculation of sand and gravel requirement throughout the plan period. As a result the forecasted tonnage is unnecessarily high and is out of line with economic trends. The calculated tonnage forecast ignores the positive impact of recycled and secondary minerals and material differences in future construction methods.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29488

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29488 Document: Minerals Local Plan Submission Draft Section: MP1: Aggregate Provision Support/Object: Object

NPPF and Planning Officers Society and Aggregate working party guidelines states that MPAs should use available latest figures when looking at apportionment within emerging MLP calculations. NCC have failed to use the most up to date data in calculation of sand and gravel requirement throughout the plan period. As a result the forecasted tonnage is unnecessarily high and is out of line with economic trends. The calculated tonnage forecast ignores the positive impact of recycled and secondary minerals and material differences in future construction methods.

SUMMARY

NPPF and Planning Officers Society and Aggregate working party guidelines states that MPAs should use available latest figures when looking at apportionment within emerging MLP calculations. NCC have failed to use the most up to date data in calculation of sand and gravel requirement throughout the plan period. As a result the forecasted tonnage is unnecessarily high and is out of line with economic trends. The calculated tonnage forecast ignores the positive impact of recycled and secondary minerals and material differences in future construction methods.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29489

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29489 Document: Minerals Local Plan Submission Draft Section: MP1 Justification Support/Object: Object

NPPF and Planning Officers Society and Aggregate working party guidelines states that MPAs should use available latest figures when looking at apportionment within emerging MLP calculations. NCC have failed to use the most up to date data in calculation of sand and gravel requirement throughout the plan period. As a result the forecasted tonnage is unnecessarily high and is out of line with economic trends. The calculated tonnage forecast ignores the positive impact of recycled and secondary minerals and material differences in future construction methods.

SUMMARY

NPPF and Planning Officers Society and Aggregate working party guidelinest states tha MPAs should use available latest figures when looking at apportionment within emerging MLP calculations. NCC have failed to use the most up to date data in calculation of sand and gravel requirement throughout the plan period. As a result the forecasted tonnage is unnecessarily high and is out of line with economic trends. The calculated tonnage forecast ignores the positive impact of recycled and secondary minerals and material differences in future construction methods.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29490

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29490 Document: Minerals Local Plan Submission Draft Section: Table 1 Annual aggregate production Support/Object: Object

NPPF and Planning Officers Society and Aggregate working party guidelines states that MPAs should use available latest figures when looking at apportionment within emerging MLP calculations. NCC have failed to use the most up to date data in calculation of sand and gravel requirement throughout the plan period. As a result the forecasted tonnage is unnecessarily high and is out of line with economic trends.e Th calculated tonnage forecast ignores the positive impact of recycled and secondary minerals and material differences in future construction methods.

SUMMARY

NPPF and Planning Officers Society and Aggregate working party guidelines states that MPAs should use available latest figures when looking at apportionment within emerging MLP calculations. NCC have failed to use the most up to date data in calculation of sand and gravel requirement throughout the plan period. As a result the forecasted tonnage is unnecessarily high and is out of line with economic trends. The calculated tonnage forecast ignores the positive impact of recycled and secondary minerals and material differences in future construction methods.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29491

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29491 Document: Minerals Local Plan Submission Draft Section: MP2: Sand and gravel provision Support/Object: Object

The proposed new site near Newark at Averham will result in a significant increase in traffic volumes in and around Newark, with the majority being Heavy Goods Vehicles, this would further exacerbate the problems with traffic congestion in the Newark area. This factor has not been properly taken into account within the Plan. The use of the sites will also create noise and air pollution in the surrounding villages as well as in the town of Newark and this factor has also not been properly considered within the Plan. Increased traffic through local villages Heavy traffic on the route to Newark ‐ a road that already suffers badly for traffic jams Heavy lorries over an awkward, old bridge not suitable for lorries Adverse impact on the local economy Adverse impact on the rural landscape Damage to human health Flooding and water management Historic environment at danger Cumulative impact of other developments in the area Loss of productive farmland Loss of local amenity and a failure to demonstrate a need to open this new greenfield site

SUMMARY

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29492

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29492 Document: Minerals Local Plan Submission Draft Section: MP2: Sand and gravel provision, MP2p Flash Farm Support/Object: Object

SUMMARY

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29493

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29493 Document: Minerals Local Plan Submission Draft Section: MP2 Justification Support/Object: Object

NCC state that their predicted demand use a 5 year recession and 5 year growth model. It is naïve to assume a 50:50 split. No evidence is given to show what economic growth predictions support the demand through the plan period. The current proposals for demand would require an unrealistically high growth in sales to be achieved. The MLP uses an annual allocation figure of 2.58 million tonnes, and this overestimates demand.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29494

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29494 Document: Minerals Local Plan Submission Draft Section: Table 3 Contributions to the sand and gravel shortfall over the plan period Support/Object: Object

The development of green field sites is not justified by the estimate of required supply based on most recent LAA figures and increase in use of recycled and secondary aggregates. There is no evidence to demonstrate a need for immediately deliverable sites.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29495

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29495 Document: Minerals Local Plan Submission Draft Section: MP5: Secondary and recycled aggregates Support/Object: Object

A major issue here is that the Nottinghamshire and Nottingham Replacement Waste Local Plan is not an integral part of the Minerals Local Plan, it is therefore impossible to make meaningful or indeed accurate forecasts of the quantity of secondary and recycled materials that may be available for re‐instatement after minerals extraction. Also as current data shows, quantities available annually from the whole of Nottinghamshire of inert backfill material is minuscule in relation to the quantity required. Finally processing on greenfield sites of material for recycling is a noisy and pollution creating operation, causing further nuisance to local residents.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29496

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29496 Document: Minerals Local Plan Submission Draft Section: MP5 Justification Support/Object: Object

A major issue here is that the Nottinghamshire and Nottingham Replacement Waste Local Plan is not an integral part of the Minerals Local Plan, it is therefore impossible to make meaningful or indeed accurate forecasts of the quantity of secondary and recycled materials that may be available for re‐instatement after minerals extraction. Also as current data shows, quantities available annually from the whole of Nottinghamshire of inertl backfil material is minuscule in relation to the quantity required. Finally processing on greenfield sites of material for recycling is a noisy and pollution creating operation, causing further nuisance to local residents.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29498

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29498 Document: Minerals Local Plan Submission Draft Section: DM2: Water resources and flood risk Support/Object: Object

Flash Farm is adjacent to areas that are classed as either Flood Zone 2 having a Medium Probability or Flood Zone 3, a High Probability of flooding (National Planning Policy Framework). Potentially this can increase flood risk elsewhere. It is unlikely that Mission Dyke has sufficient capacity to absorb surplus water from mineral extraction, and may become a source of flooding to nearby houses.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29499

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29499 Document: Minerals Local Plan Submission Draft Section: DM2 Justification Support/Object: Object

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29500

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29500 Document: Minerals Local Plan Submission Draft Section: DM3: Agricultural land and soil quality Support/Object: Object

Flash Farm forms part of a productive dairy farm unit and restoration of the land would not return it to current land quality sufficient to sustain current production levels. The developer's proposal included backfilling the site with inert waste streams, however evidence shows that the county's entire inert waste production would be insufficient for this site alone, therefore the plan is unsustainable.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29501

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29501 Document: Minerals Local Plan Submission Draft Section: DM3 Justification Support/Object: Object

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29502

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29502 Document: Minerals Local Plan Submission Draft Section: DM5: Landscape character Support/Object: Object

We broadly support the policy statement "that proposals for mineral development will be supported where it can be demonstrated that it will not adversely impact on the character and distinctiveness of the landscape" Notts County Council has seen fit to recently remove the only sight barrier, namely the woodland bordering the A617, that could have screened the Flash farm site. The area around Flash Farm is idyllically rural, not industrial, and sits well within the historic buildings and conservation areas within the local vernacular. Extraction, even with subsequent restoration (unlikely due to limited supply of inert infill), would disrupt or even destroy this landscape.

SUMMARY

Notts County Council has seen fit to recently remove the only sight barrier, namely the woodland bordering the A617, that could have screened the Flash farm site. The area around Flash Farm is idyllically rural, not industrial, and sits well within the historic buildings and conservation areas within the local vernacular. Extraction, even with subsequent restoration (unlikely due to limited supply of inert infill), would disrupt or even destroy this landscape.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29503

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29503 Document: Minerals Local Plan Submission Draft Section: DM5 Justification Support/Object: Object

SUMMARY

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29504

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29504 Document: Minerals Local Plan Submission Draft Section: DM6: Historic environment Support/Object: Object

Kelham and Averham contribute to the Historic Environment including one listed building, two listed churches and many other structures. The development of Flash Farm will adversely affect their cultural settings, as well as the ambiance of the wider landscape environment. Para 5.79 of the Justification states that the adverse effects of development can be mitigated by the use of 'careful design, buffer zones and considered restoration'. The location and current use of Flash Farm will make all these provisions difficult to implement.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29505

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29505 Document: Minerals Local Plan Submission Draft Section: DM6 Justification Support/Object: Object

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29506

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29506 Document: Minerals Local Plan Submission Draft Section: DM12: Restoration, after‐use and aftercare Support/Object: Object

The submission policy states "Mineral extraction proposals which rely on the importation of waste for restoration must: a. Include satisfactory evidence that the waste will be available over an appropriate timescale in the types and quantities assumed;" The developer's proposal included backfilling the site with inert waste streams, however evidence shows that the county's entire inert waste production would be insufficient for this site alone, therefore the submission MLP is unrealistic, unsustainable and flawed.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29507

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29507 Document: Minerals Local Plan Submission Draft Section: DM12 Justification Support/Object: Object

The submission draft MLP policy states "Mineral extraction proposals which rely on the importation of waste for restoration must: a. Include satisfactory evidence that the waste will be available over an appropriate timescale in the types and quantities assumed;" The developer's proposal included backfilling the site with inert waste streams, however evidence shows that the county's entire inert waste production would be insufficient for this site alone, therefore the submission MLP is unrealistic, unsustainable and flawed.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29508

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29508 Document: Minerals Local Plan Submission Draft Section: MP2p ‐ Flash Farm Support/Object: Object

All proposals for restoration schemes should be in line with the County Council's approach to Biodiversity‐Led Restoration contained within Policy SP3 and also with full consultation of local interested parties. A return to full agricultural use also needs consideration. Indirect impacts on Kelham Woods LWS must be considered, in particular to maintaining the current level of the local water table, High archaeological potential which needs to be managed through appropriate survey methods, these methods need to be beyond the control of any potential developer and fully available for public scrutiny. Potential impacts on heritage assets in Kelham and Averham in particular Kelham Hall and Bridge, and protection or suitable management of Averham footpath 6 also needs including. A Flood Risk Assessment should address: surface and ground water flooding, overland flow paths and mitigation of potential flooding as part of the site lies in Flood Zone 3

SUMMARY

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29517

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29517 Document: Minerals Local Plan Submission Draft Section: SP5: Sustainable Transport Support/Object: Object

The A617 currently handles on average 18000 vehicles a day and carries an increasing number of HGV's along this route as it is the main link from Mansfield to Newark and the A1. With the expansion of a number of haulage companies within the area this will further increase. The proposed site of Flash farm will introduce slow moving and contaminated vehicles onto this route creating further congestion and additional surface debris hazards as well as emerging vehicle hazards. As the A617 passes through Kelham and narrows over the bridge this has been the locations of a number of incidents involving HGV's and other vehicles resulting in the significant delays and inconvenience to residents. On regular occasion's traffic is tailing back from the Newark island into and beyond Kelham Village and once this road is blocked there is no direct route for emergency vehicles coming to the area from either direction. The addition of further HGV's to this road is not a sustainable solution and no proposal one th alternative transportation solutions has been put forward or investigated.

SUMMARY

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

This email is acknowledgement of the receipt of your representation. TIt is NO confirmation that the representation has yet been registered. You will not receive any further notification by email that your representation has been registered until the end of the participation period.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29518

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29518 Document: Minerals Local Plan Submission Draft Section: SP5 Justification Support/Object: Object

The A617 currently handles on average 18000 vehicles a day and carries an increasing number of HGV's along this route as it is the main link from Mansfield to Newark and the A1. With the expansion of a number of haulage companies within the area this will further increase. The proposed site of Flash farm will introduce slow moving and contaminated vehicles onto this route creating further congestion and additional surface debris hazards as well as emerging vehicle hazards. As the A617 passes through Kelham and narrows over the bridge this has been the location of a number of incidents involving HGV's and other vehicles resulting in the significant delays and inconvenience to residents. On regular occasion's traffic is tailing back from the Newark island into and beyond Kelham Village and once this road is blocked there is no direct route for emergency vehicles coming to the area from either direction. The addition of further HGV's to this road is not a sustainable solution and no proposal on the alternative transportation solutions has been put forward or investigated.

SUMMARY

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

This email is acknowledgement of the receipt of your representation. It Tis NO confirmation that the representation has yet been registered. You will not receive any further notification by email that your representation has been registered until the end of the participation period.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29519

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29519 Document: Minerals Local Plan Submission Draft Section: DM1: Protecting local amentity Support/Object: Object

The visual impact of the flash farm site would be immense resulting from its elevated position over the surrounding villages of Kelham and Averham, more so of recent now Notts County Council has seen fit to recently remove the woodland bordering the A617 which could have screened the Flash farm site to some extent. The increase in noise and air pollution as a result of the proposal and the additional road traffic will impact on the surrounding residents and their health. The Trent valley already has a higher than average occurrence of respiratory conditions, eg asthma with a major contributor being the increase of Diesel particulate matter from increased road transport and dust generated by earth workings.

SUMMARY

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29520

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29520 Document: Minerals Local Plan Submission Draft Section: DM1 Justification Support/Object: Object

The visual impact of the flash farm site would be immense resulting from its elevated position over the surrounding villages of Kelham and Averham, more so of recent now Notts County Council has seen fit to recently remove the woodland bordering the A617 which could have screened the Flash farm site to some extent. The increase in noise and air pollution as a result of the proposal ande th additional road traffic will impact on the surrounding residents and their health. The Trent valley already has a higher than average occurrence of respiratory conditions, eg asthma with a major contributor being the increase of Diesel particulate matter from increased road transport and dust generated by earth workings.

SUMMARY

The visual impact of the flash farm site would be immense resulting from its elevated position over the surrounding villages of Kelham and Averham, more so of recent now Notts County Council has seen fit to recently remove the woodland bordering the A617 which could have screened the Flash farm site to some extent. The increase in noise and air pollution as a result of the proposal and the additional road traffic will impact on the surrounding residents and there health. The Trent valley already has a higher than average occurrence of respiratory conditions, eg asthma.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29521

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29521 Document: Minerals Local Plan Submission Draft Section: DM8: Cumulative impact Support/Object: Object

The proposed flash farm site at Averham will result in a significant increase in traffic volumes in and around Newark, with the majority being Heavy Goods Vehicles, this would further exacerbate the problems with traffic congestion in the Newark area. This factor has not been properly taken into account within the Plan. The use of the sites will also create noise and air pollution in the surrounding villages as well as in the town of Newark and this factor has also not been properly considered within the Plan. Increased traffic through local villages Heavy traffic on the route to Newark ‐ a road that already suffers badly for traffic jams Heavy lorries over Kelham bridge that is not rsuitable fo lorries and if they meet on the bridge they are not able to pass without mounting the footpath presenting a further danger to pedestrians using the bridge. Adverse impact on the local economy Adverse impact on the rural landscape Damage to human health as a result of the increases noise and air pollution. Flooding and water management Historic environment at danger Cumulative impact of other developments in the area Loss of productive farmland Loss of local amenity and a failure to demonstrate a need to open this new greenfield site

SUMMARY

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared 1 ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29522

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29522 Document: Minerals Local Plan Submission Draft Section: DM8 Justification Support/Object: Object

The proposed flash farm site at Averham will result in a significant increase in traffic volumes in and around Newark, with the majority being Heavy Goods Vehicles, this would further exacerbate the problems with traffic congestion in the Newark area. This factor has not been properly taken into account within the Plan. The use of the sites will also create noise and air pollution in the surrounding villages as well as in the town of Newark and this factor has also not been properly considered within the Plan. Increased traffic through local villages Heavy traffic on the route to Newark ‐ a road that already suffers badly for traffic jams Heavy lorries over Kelham bridge that is not suitable for lorries and if they meet on the bridge they are not able to pass without mounting the footpath presenting a further danger to pedestrians using the bridge. Adverse impact on the local economy Adverse impact on the rural landscape Damage to human health as a result of the increases noise and air pollution. Flooding and water management Historic environment at danger Cumulative impact of other developments in the area Loss of productive farmland Loss of local amenity and a failure to demonstrate a need to open this new greenfield site

SUMMARY

The proposed flash farm sitem at Averha will result in a significant increase in traffic volumes in and around Newark, with the majority being Heavy Goods Vehicles, this would further exacerbate the problems with traffic congestion in the Newark area. The use of the sites will also create noise and air pollution in the surrounding villages as well as in the town of Newark and this factor has also not been properly considered within the Plan. Increased traffic through local villages Heavy traffic on the route to Newark Heavy lorries over Kelham bridge that is not suitable for lorries.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29523

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29523 Document: Minerals Local Plan Submission Draft Section: DM9: Highways safety and vehicle movements/routeing Support/Object: Object

The A617 currently handles on average 18000 vehicles a day and carries an increasing number of HGV's along this route as it is the main link from Mansfield to Newark and the A1. With the expansion of a number of haulage companies within the area this will further increase in a unregulated manor. The road has had its speed limit reduced previously to 50 MPH as a result of previous road safety initiatives and with vehicle related incidents still increasing this must be addressed. The proposed site of Flash farm will introduce slow moving and contaminated vehicles onto this route creating further congestion and additional surface debris hazards as well as slow emerging vehicle hazards. As there is currently little in the way of screening since Notts County Council recently remove the mature woodland bordering the A617, vehicle engine noise, audible reversing notifications and other plant equipment noise will travel easily and cause impact to residents of Averham and Kelham. The Minerals plan for the Flash farm site does not address the current state of the roads, highways, traffic flows and densities nor does it present a workable traffic solution for the A617 through Kelham and Averham. The Plan also makes no effort to investigate alternative transport solutions for this proposed site.

SUMMARY

The road has had its speed limit reduced previously to 50 MPH as a result of previous road safety initiatives and with vehicle related incidents still increasing this must be addressed. The proposed site of Flash farm will introduce slow moving and contaminated vehicles onto this route creating further congestion and additional surface debris hazards as well as slow emerging vehicle hazards. The Minerals plan for the Flash farm site does not address the current state of the roads, highways, traffic flows and densities nor does it present a workable traffic solution for the A617 through Kelham and Averham.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29524

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29524 Document: Minerals Local Plan Submission Draft Section: DM9 Justification Support/Object: Object

The A617 currently handles on average 18000 vehicles a day and carries an increasing number of HGV's along this route as it is the main link from Mansfield to Newark and the A1. With the expansion of a number of haulage companies within the area this will further increase in a unregulated manor. The road has had its speed limit reduced previously to 50 MPH as a results of previou road safety initiatives and with vehicle related incidents still increasing this must be addressed. The proposed site of Flash farm will introduce slow moving and contaminated vehicles onto this route creating further congestion and additional surface debris hazards as well as slow emerging vehicle hazards. As there is currently little in the way of screening since Notts County Council recently remove the mature woodland bordering the A617, vehicle engine noise, audible reversing notifications and other plant equipment noise will travel easily and cause impact to residents of Averham and Kelham. The Minerals plan for the Flash farm site does not address the current state of the roads, highways, traffic flows and densities nor does it present a workable traffic solution for the A617 through Kelham and Averham. The Plan also makes no effort to investigate alternative transport solutions for this proposed site.

SUMMARY

The road has had its speedt limi reduced previously to 50 MPH as a result of previous road safety initiatives and with vehicle related incidents still increasing this must be addressed. The proposed site of Flash farm will introduce slow moving and contaminated vehicles onto this route creating further congestion and additional surface debris hazards as well as slow emerging vehicle hazards. The Minerals plan for the Flash farm site does not address the current state of the roads, highways, traffic flows and densities nor does it present a workable traffic solution for the A617 through Kelham and Averham.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the local minerals plan.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29544

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29544 Document: Minerals Local Plan Submission Draft Section: DM10: Airfield safeguarding Support/Object: Object

Not all active safeguarded airfields are included in DM10 list and at least one non‐operational (closed) airfield is still listed as safeguarded.

Rectory Farm airfield at Averham has Safeguarding document in place at Newark and Sherwood District Council (planning dept) and falls well within 8mile radius of Flash Farm preferred site ‐ no account of this has been taken for this in the Plan and therefore the Plan is neither sound, nor positively prepared in this respect. It is likely that other airfields have similar safeguarding policy lodged with local authorities. All safeguarded airfields should be listed at DM10. Safeguarded airfield operators should be contacted to ensure all aviation safety related mitigation measures are considered before deciding on preferred minerals sites list.

NCC MPA should check for airfield safeguarding documents lodged with local authorities and revise list as required.

Hucknall airfield closed permanently in early 2015. It is no longer operational and therefore unlikely to be able to be safeguarded as an airfield.

Chapter 5 Para 5.108 ‐ factually incorrect.

Plan 5 Factually incorrect.

SUMMARY

Not all active safeguarded airfields are included in DM10 list and at least one non‐operational (closed) airfield is still listed as safeguarded.

CHANGE TO PLAN

Flash Farm, site MP2p should be removed from the plan

The document is unsound because it is not: 1 i. Positively prepared ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 29 March 2016 13:25 To: Subject: Representation received. ID:29545

Averham, Kelham & Staythorpe Parish Council (Mr J Burbidge),

Thank you for your representation which we received as follows:

Representation ID: 29545 Document: Minerals Local Plan Submission Draft Section: DM10 Justification Support/Object: Object

Not all active safeguarded airfields are included in DM10 list and at least one non‐operational (closed) airfield is still listed as safeguarded.

NCC MPA should check for airfield safeguarding documents lodged with local authorities and revise list as required.

Hucknall airfield closed permanently in early 2015. It is no longer operational and therefore unlikely to be able to be safeguarded as an airfield.

Chapter 5 Para 5.108 ‐ factually incorrect.

Plan 5 Factually incorrect.

SUMMARY

Not all active safeguarded airfields are included in DM10 list and at least one non‐operational (closed) airfield is still listed as safeguarded.

CHANGE TO PLAN

Flash Farm, site MP2p is removed from the plan.

The document is unsound because it is not: i. Positively prepared 1 ii. Justified iii. Effective iv. Consistent with national policy

How you would like your representation to be considered at the independent examination: Written representation.

2 Office use only Person No: 784

Rep Nos: 29621 - 23 Part A – Personal details

Personal details Agent details (where applicable) Title Ms First name Carol Last name Standish Address line 1 Southwell Town Council Address line 2 Address line 3 Postcode Email For those replying on behalf of an organisation or group:

Organisation Southwell Town Council Job title Town Clerk

If you are replying on behalf of an organisation or group, how was the response approved and how many people does it represent? This response was approved at the meeting of the Full Council on 17th February 2016

Do you wish to be notified of any of the following? (please tick as appropriate) The submission of the Mineral Local Plan for independent examination yes The publication of the recommendations of the inspector Yes The adoption of the Minerals Local Plan yes If agent details are provided contact will be made through them unless otherwise instructed.

If your representation(s) is seeking a change, do you consider it necessary to participate at the oral part of the examination? Please note that if you do not participate at the oral examination your representations will be dealt with as written representations and carry the same weight as those presented orally. Yes, I wish to participate at No, I do not wish to participate no the oral examination at the oral examination

If you would like to participate at the oral part of the examination, please outline why you consider this to be necessary. Please note that participation in the oral hearing sessions is at the discretion of the Inspector.

Signature Date 23rd March 2016 Name Carol Standish If you are submitting your representation electronically you do not need to provide a signature. Office use only Person No: 784 Part B – Your representation Rep No: 29621 - 23 Please read the guidance note before completing this section.

1. To which part of the document does this representation relate? Policy Site code Map/Plan Paragraph Other x

2. Do you consider the identified part of the document to be: Legally compliant? Yes No Sound? Yes No No If you do not consider the identified part of the document to be sound, please continue to question 3. In other cases please go to question 4. If you think the identified part of the document is not legally compliant and is unsound and therefore want to answer ‘no’ to both parts of this question, please fill in two separate forms.

3. Do you consider the identified part of the document to be unsound because it is not: (1) Positively (4) Consistent with (2) Justified? (3) Effective? x prepared? national policy? You can select more than one test if you feel it is appropriate.

Southwell Town Council notes that the proposed sites are not in the parish of Southwell. However, it does wish to comment on the proposed Plan. The Council objects to some elements of the Plan

The Estimated Total Aggregate Demand in the Draft Plan for 2012-2030 is calculated using Annual Aggregate Production figures from 2002 to 2011, based on data from the Nottinghamshire Local Aggregates Assessment, published in July 2013, and are significantly out of date.

Production of ‘greenfield’ aggregate is falling. This Council strongly supports the use of recycled aggregates. Its use has reduced the requirement for new quarrying across the country, and believes that the same approach should be adopted in Nottinghamshire. The Plan estimates production need of around 49m tonnes in the Plan period. However, the increased use of recyclate will give a need of less than 40m tonnes.

The Plan should be amended to reflect significantly decreased use of new quarried aggregate.

The Council also notes that the 20 year Plan period is in excess of the seven year plan period suggested by the Sub- Regional Apportionment and National Planning Policy Framework.

The Plan should be amended to reflect a seven year Plan period.

The Council notes that the C612 [previously the A612] which runs through Southwell is subject to a 7.5tonne HGV limit.

In the event of the Draft Plan being adopted, it will expect the limits to be rigidly enforced. Any traffic between the A617 at Averham, and the processing plant at Fiskerton must be required to use the existing HGV routes via Newark and the A46.

The Plan should be amended to ensure appropriate transport plans

6. Have you raised this issue previously (during earlier stages of consultation)? Yes No If Yes, please give details

Signature Date 23rd March 2016 Name Carol Standish If you are submitting your representation electronically you do not need to provide a signature Office use only Person No: 792

Rep Nos: 29700-29701 Part A – Personal details

Personal details Agent details (where applicable) Title Mr First name John Last name Mann MP Address line 1 Address line 2 Address line 3 Postcode Email For those replying on behalf of an organisation or group:

Organisation Job title Member of Parliament for Bassetlaw

If you are replying on behalf of an organisation or group, how was the response approved and how many people does it represent?

Do you wish to be notified of any of the following? (please tick as appropriate) The submission of the Mineral Local Plan for independent examination YES The publication of the recommendations of the inspector YES The adoption of the Minerals Local Plan YES If agent details are provided contact will be made through them unless otherwise instructed.

If your representation(s) is seeking a change, do you consider it necessary to participate at the oral part of the examination? Please note that if you do not participate at the oral examination your representations will be dealt with as written representations and carry the same weight as those presented orally. Yes, I wish to participate at No, I do not wish to the oral examination participate at the oral X examination

Signature Date 24th March 2016 Name John Mann MP If you are submitting your representation electronically you do not need to provide a signature. Office use only Person No: 792 Part B – Your representation Rep No: 29700-29701 Please read the guidance note before completing this section.

1. To which part of the document does this representation relate? Policy Site code Map/Plan Paragraph Other

2. Do you consider the identified part of the document to be: Legally compliant? Yes No Sound? Yes No If you do not consider the identified part of the document to be sound, please continue to question 3. In other cases please go to question 4. If you think the identified part of the document is not legally compliant and is unsound and therefore want to answer ‘no’ to both parts of this question, please fill in two separate forms.

3. Do you consider the identified part of the document to be unsound because it is not: (1) Positively (4) Consistent with (2) Justified? (3) Effective? prepared? national policy? You can select more than one test if you feel it is appropriate.

POINT ONE

I understand that the GEART rule 1 guidelines indicate that a 30% increase in HGV movements requires a separate assessment of the impacts. In the Strategic Transport Assessment, it suggests that MP2n (Botany Bay) would lead to an additional 76 two way HGV movements on the A638 Great North road (page 53). Furthermore, the Strategic Transport Assessment suggests that MP2m (Barnby Moor) would lead to an additional 42 two way HGV movements on the A638 Great North road (page 21).

The assessment states that there are between 300-500 two way HGV movements on this road per day. My concern is that these two sites are being considered separately, therefore the separate impact of these two sites would represent an increase of less than 30% and thus not needing further assessment under GEART rule 1. However, as the quarries would use the same road (the A638) and are located very close to each other, they should be considered jointly, therefore the overall increase in HGV traffic would be 39.3% (118 HGV movements). According to this calculation, under GEART rule 1, further assessment is required.

POINT TWO

The GEART rules also suggest that “the average or total daily traffic flows provide insufficient information for any real understanding of the environmental effects, and the analysis needs to be presented for much more specific time periods”. (P12, GEART). The Strategic Transport Assessment explains the effect of the traffic flow per day on an averaged out basis and does not detail the timings of the movements. It appears therefore that the GEART rules have not been adhered to a more detailed traffic assessment needs to be undertaken. 5. Please set out what change(s) you consider necessary to make the identified part of the document legally compliant or sound, having regard to the test(s) identified in question 3 (if applicable). Please state why this change will make it legally compliant or sound and suggest revised wording of policy or text. Please be as precise as possible. Please expand the box as necessary or attach additional sheets. If attaching sheets, please clearly mark these with the part of the document the representation relates to and your name.

Please note: You should provide as much information/justification in your representation as you feel necessary and appropriate because once you have submitted your representation there will not normally be a subsequent opportunity to submit anything else unless requested to do so by the planning inspector. As explained in my answer to question four, further traffic assessments need to be undertaken according to the GEART rules in order to rectify the two points raised.

6. Have you raised this issue previously (during earlier stages of consultation)? Yes No If Yes, please give details n/a

Signature Date 24/3/16 Name John Mann MP, Member of Parliament for Bassetlaw If you are submitting your representation electronically you do not need to provide a signature Office use only Person No: 810 Rep Nos: Part A – Personal details 29714-29715

Personal details Agent details (where applicable) Title Mrs First name C Last name Millward Address line 1 Address line 2 Address line 3 Postcode Email For those replying on behalf of an organisation or group:

Organisation Norwell Parish Council Job title Clerk

If you are replying on behalf of an organisation or group, how was the response approved and how many people does it represent? Response unanimously approved at parish council meeting on 23 March 2016

Do you wish to be notified of any of the following? (please tick as appropriate) The submission of the Mineral Local Plan for independent examination X The publication of the recommendations of the inspector X The adoption of the Minerals Local Plan X If agent details are provided contact will be made through them unless otherwise instructed.

Signature Date 25.3.16 Name Mrs C Millward If you are submitting your representation electronically you do not need to provide a signature. Office use only Person No: 810 Part B – Your representation Rep No: 29714-29715 Please read the guidance note before completing this section.

1. To which part of the document does this representation relate? Policy DM8 Site code MP2p Map/Plan Paragraph Other 29415 29714 2. Do you consider the identified part of the document to be: Legally compliant? Yes X No Sound? Yes No X If you do not consider the identified part of the document to be sound, please continue to question 3. In other cases please go to question 4. If you think the identified part of the document is not legally compliant and is unsound and therefore want to answer ‘no’ to both parts of this question, please fill in two separate forms.

3. Do you consider the identified part of the document to be unsound because it is not: (1) Positively (4) Consistent with (2) Justified? X (3) Effective? X prepared? national policy? You can select more than one test if you feel it is appropriate.

They also object specifically to any extraction at Flash Farm, Averham, because of the serious negative impact of the increased HGV traffic on A617 at Kelham Bridge and consequent adverse effect on traffic flow around Newark. Any more traffic congestion around Newark will almost certainly lead to significant numbers of drivers using unsuitable country lanes and driving through villages such as Norwell to bypass Newark. This will be exacerbated whenever there are road closures, which will inevitably become more numerous with the overall increase in traffic. The cumulative impact of vehicles serving gravel extraction at this site coupled with the already increased traffic around Newark following the dualling of A46 will damage the economic viability of Newark and the surrounding area and risks paralysing the area for residents and businesses.

The parish council therefore believes that, for these reasons, the document is unjustified and ineffective in the above respects 5. Please set out what change(s) you consider necessary to make the identified part of the document legally compliant or sound, having regard to the test(s) identified in question 3 (if applicable). Please state why this change will make it legally compliant or sound and suggest revised wording of policy or text. Please be as precise as possible. Please expand the box as necessary or attach additional sheets. If attaching sheets, please clearly mark these with the part of the document the representation relates to and your name.

6. Have you raised this issue previously (during earlier stages of consultation)? Yes No If Yes, please give details

Signature Date 23.3.16 Name Mrs C Millward If you are submitting your representation electronically you do not need to provide a signature Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 21:20 To: Subject: Representation received. ID:29375

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29375 Document: Minerals Local Plan Submission Draft Section: Strategic Objectives, SO2: Providing an adequate supply of minerals Support/Object: Object

The data used to identify demand is out of date, and inflates the demand stated/quoted. Predictions for future demand are insufficient in that they do not quote any data, or reflect actual trends, let alone build in any reflection of recycling rates.

CHANGE TO PLAN

*Use the most recent LAA data *Acknowledge declining trends even during recessional recovery *Identify an estimate model which is more accurate than simply stating an allowance for "5 years of famine and 5 years of feast" ‐ the "feast" has yet to be justified or quantified

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 21:28 To: Subject: Representation received. ID:29376

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29376 Document: Minerals Local Plan Submission Draft Section: Strategic Objectives, SO5: Minimising impacts on communities Support/Object: Object

This document does not fully include the potential impacts to residents (or indeed road user) health and safety. No consideration has been given to associated problems. For example, noise surveys carried out in Kirklington and Hockerton on the A617, have shown that existing noise levels already exceed World Health Organisation (WHO) recommendations, and additional HGV traffic will exacerbate this further (along with any air pollution).

CHANGE TO PLAN

*Remove Flash Farm from the MLP as it is not required if up to date data is used.

The document is unsound because it is not: ii. Justified

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 21:37 To: Subject: Representation received. ID:29377

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29377 Document: Minerals Local Plan Submission Draft Section: SP2 Justification Support/Object: Object

• Date range of sales data is out of date ‐ The proposals for the MLP include average sand and gravel requirements over the period 2002‐2011 (which NCC have advised is based on sales). Whilst it is acknowledged that there needs to be a cut‐off point, more up to date information is currently available which both could (and should) be used. It is understood that figures for 2015 are due to be published in the near future. However, the Local Aggregates Assessment (published in 2015) includes data for the period 2004‐2013, and demonstrates a long‐term, continuing trend for actual sales being lower than forecast. It is understood that other counties, i.e. Lincolnshire, Derbyshire and Warwickshire, have been required to use their most up to date data in their MLP submissions.

• Predictions for demand/growth are not realistic ‐ The recession has seen aggregate production fall significantly at local, and national, levels. Comparing the average annual sales for Nottinghamshire over each 10 year period, 2002‐2011 is 2.58m tonnes p.a. whilst 2004 ‐2013 is 2.24m tonnes p.a.

The MLP looks at mineral development within the County over the next 14 years to 2030. When the County’s average annual sales are calculated, it gives predicted demand of 36.12m tonnes using 2002‐2011 data, and 31.36m tonnes using 2004‐2013 data. Using more up to date figures clearly demonstrates a demand which is at least 4.76m tonnes less than currently proposed, and therefore negates the need for Flash Farm to be used at all – especially as there are a number of sites currently in operation or in reserve which have not yet been used to capacity, if at all, which could be used first.

Planning Practice Guidance states there should be particular emphasis on the last 3 years of data – which shows that there are no trends to suggest an increase in demand even during a period of supposed recovery.

NCC have stated that their figures for predicted demand show 5 years of recession and 5 years of growth (despite a 30year period of decline). It is acknowledged that a ‘buffer zone’ would be a sensible precaution in the event of demand rising, however, it could be naïve to assume a 50:50 split. In fact, no information has been provided to show what the growth predictions are based on ‐ in terms of length or amount. The current proposals for demand would require an unrealistically high growth in sales to be achieved, especially when compared to the downward trend of lower sales.

SUMMARY

Gravel requirements have been based on data which is out of date, inflating potential need when average demand is actually lower. Planning Practice Guidance states the need for emphasis on the last three years of data ‐ this has not been demonstrated. Future demand predictions are insufficiently factually based.

CHANGE TO PLAN 1

*include most recent LAA figures to show most up to date sales trends *identify a more accurate model for predicting future demand rather *Remove Flash Farm from the MLP as existing sites can fulfil demand (based on more up to date and accurate figures)

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 21:45 To: Subject: Representation received. ID:29378

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29378 Document: Minerals Local Plan Submission Draft Section: SP5 Justification Support/Object: Object

• Traffic data – Initially the transport assessment also used out of date data without the inclusion of recent traffic surveys. It is acknowledged that an amendment has now been added to include a survey from September 2015. However, it is a real concern that the increase in traffic is seen as ‘negligible’. It seems that predictions are compared to overall traffic volumes and would show a relatively low percentage increase. However, no data is included to show a breakdown of vehicle types. When comparing predicted HGV volumes against current usage, the increase will show as a much higher percentage and will be even higher when empty HGVs arriving on site prior to loading are factored into overall numbers. Furthermore insufficient information is included with regard to traffic movements bring inert waste to/from the site once all gravel has been extracted. Although this is less likely to be HGVs, an increase in smaller vehicles (such as trade vans) still poses a risk which hasn’t been clearly accounted for.

• Transport policy considerations – Transport policy assessments are at a very high level and look only at vehicle volumes/movements. No consideration has been given to associated problems. Noise surveys carried out in Kirklington and Hockerton on the A617, have shown that existing noise levels already exceed World Health Organisation (WHO) recommendations, and additional HGV traffic will exacerbate this further (along with any air pollution). Local congestion points, such as Kelham Bridge and the Cattle Market roundabout at Newark, do not appear to have been considered – they are already overloaded yet do not receive even a mention in the assessment. Increases in traffic on the A617 will impact safety not only at junctions, but in terms of NHS ambulance access and response time, between Kings Mill and Newark Hospitals.

No consideration has been given to other local projects which will further affect traffic flow and volumes, such as the Yearsley/Brakes development at Bilsthorpe – this could add up to 164 HGVs through the villages plus additional staff transport. Again, a significant percentage increase to existing HGV traffic levels. It is appreciated that the transport assessment cannot cover every eventuality, however, consideration to existing new developments makes a real difference).

SUMMARY

Proposed increases in traffic may be quoted as being negligible when looking at overall levels, however, the increase in HGV traffic compared to existing HGV traffic is substantial. Most recent data fails to include a breakdown of vehicle types using the A617. Insufficient details is provided with regard to proposals for infill stages. No considerationn has bee demonstrated for local traffic issues/congestion, or for projects which will further increase HGV traffic in the area (for which planning permission has already been granted).

CHANGE TO PLAN

1 *provide further detail on/assessment of vehicle type and associated health impacts ‐ demonstrate recognition/acknowledgement *Remove Flash Farm from the MLP as it is not required

The document is unsound because it is not: ii. Justified

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 21:53 To: Subject: Representation received. ID:29379

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29379 Document: Minerals Local Plan Submission Draft Section: SP6 Justification Support/Object: Object

Section 3.74 states "Minerals proposals therefore need to take into account the likely impacts upon both the local highway network and nearby communities arising from increased levels of traffic. Potential impacts could include congestion, road safety, noise, dust, and vehicle emissions". Transport policy assessments are at a very high level and look only at vehicle volumes/movements. No consideration has been given to associated problems. Noise surveys carried out in Kirklington and Hockerton on the A617, have shown that existing noise levels already exceed World Health Organisation (WHO) recommendations, and additional HGV traffic will exacerbate this further (along with any air pollution). Local congestion points, such as Kelham Bridge and the Cattle Market roundabout at Newark, do not appear to have been considered – they are already overloaded yet do not receive even a mention in the assessment. Increases in traffic on the A617 will impact safety not only at junctions, but in terms of NHS ambulance access and response time, between Kings Mill and Newark Hospitals

SUMMARY

Insufficient consideration has been given to associated problems with increased HGV traffic e.g. noise/air pollution and congestion. The A46/A1 junctions are already busy and suffer from congestion. the Government has stated intent to invest in improving the A46 around Newark which suggests it is nationally recognised to be unable to cope with existing traffic levels and patterns.

CHANGE TO PLAN

*complete a more thorough assessments of traffic impacts in the surrounding area, and associated issues *Remove Flash Farm from the MLP altogether

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 22:10 To: Subject: Representation received. ID:29380

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29380 Document: Minerals Local Plan Submission Draft Section: MP1 Justification Support/Object: Object

• Recycling does not appear to have been factored in – Developers across the industry are actively encouraged to increase the recycling of materials, which will naturally decrease the demand for new aggregate. Although this recycling does not appear to be effectively measured, recycling rates are highly likely to increase, especially in light of the introduction, and subsequent increase, of a Landfill Tax. This will reduce demand for new minerals, and also reduce inert waste backfill supply.

1 SUMMARY

Inaccuracy of data used to identify demand means predictions have been over inflated. The proposals do not take into account all possible supply options in terms of the availability of secondary or recycled aggregates ‐ not identified/sufficiently quantified despite being highly likely to further decrease future demand on 'new' resource.

CHANGE TO PLAN

*Use most recent LAA data for accuracy and consistency with approaches taken by other Councils e.g. Lincolnshire *Reassess forecasts realistically based on downward trends over the last 30 years. Future requirement is unlikely to increase at the rates needed to justify currently quoted levels of gravel. *Remove Flash Farm which is surplus to requirements even without full utilisation of existing sites.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 22:12 To: Subject: Representation received. ID:29381

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29381 Document: Minerals Local Plan Submission Draft Section: Table 1 Annual aggregate production Support/Object: Object

Out of date data has been used

CHANGE TO PLAN

Using most recent data would reduce average demand and negate the need for Flash Farm's inclusion.

The document is unsound because it is not: i. Positively prepared ii. Justified

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 22:15 To: Subject: Representation received. ID:29382

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29382 Document: Minerals Local Plan Submission Draft Section: MP2 Justification Support/Object: Object

Over inflation of demand means that gravel requirements could be met by maximising the use of existing sites, and new sites twould no be required. The shortfall is not as large as quoted if accurate data is used.

CHANGE TO PLAN

*remove Flash Farm from the MLP proposals

The document is unsound because it is not: ii. Justified iii. Effective

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 22:19 To: Subject: Representation received. ID:29383

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29383 Document: Minerals Local Plan Submission Draft Section: DM1 Justification Support/Object: Object

With consideration to 5.16 ‐ Transport policy assessments are at a very high level and look only at vehicle volumes/movements. No consideration has been given to associated problems. Noise surveys carried out in Kirklington and Hockerton on the A617, have shown that existing noise levels already exceed World Health Organisation (WHO) recommendations, and additional HGV traffic will exacerbate this further (along with any air pollution).

CHANGE TO PLAN

*Remove Flash Farm from the MLP

The document is unsound because it is not: i. Positively prepared ii. Justified

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 22:22 To: Subject: Representation received. ID:29384

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29384 Document: Minerals Local Plan Submission Draft Section: DM5 Justification Support/Object: Object

Insufficient information has been provided with regard to what will be done with the site once gravel has been extracted and inert waste used to fill the site ‐ insufficient information has been provided not only with regard to the type/amount/sourcing of the waste but also what the site will look like at the end of its 'life' / once 'restored'.

CHANGE TO PLAN

*Additional details to be provided as above

The document is unsound because it is not: ii. Justified

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 22:28 To: Subject: Representation received. ID:29385

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29385 Document: Minerals Local Plan Submission Draft Section: DM8 Justification Support/Object: Object

Although the proposals do make comment on the weight restrictions around Southwell, they do not acknowledge the recent redevelopment and expansion of the Yearsley/Brakes business at Belle Eau Park which will lead to an increase in HGV traffic. Neither do they acknowledge existing congestion points at Kelham and around Newark itself. Lack of clarity with regard to the latter/infill stages exacerbates concerns about the types of vehcles which will be on the roads. There is no mention of increasing emergency service usage between Newark and Kings Mill Hospitals.

CHANGE TO PLAN

*realistic/"bigger picture" thinking required

The document is unsound because it is not: i. Positively prepared ii. Justified

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 22:38 To: Subject: Representation received. ID:29386

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29386 Document: Minerals Local Plan Submission Draft Section: DM9: Highways safety and vehicle movements/routeing Support/Object: Object

The A617 cannot easily accommodate the additional HGV traffic which will be generated from the site, especially in light of the cumulative effect from the Yearsley/Brakes development at belle Eau Park. Traffic surveys do not sufficiently place attention/weighting to the increase in HGV traffic specifically ‐ only to overall traffic. There are a number of sections of the road which will create hotspots/slow movement e.g. hills and Kelham Bridge.e Th road quality will exacerbate noise issues especially for empty lorries heading to the site. Lack of depth with regard to "infill" traffic too.

CHANGE TO PLAN

*Remove Flash Farm from the MLP as it is not required.

The document is unsound because it is not: iii. Effective

How you would like your representation to be considered at the independent examination: Written representation.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 22:50 To: Subject: Representation received. ID:29387

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29387 Document: Minerals Local Plan Submission Draft Section: DM12 Justification Support/Object: Object

Developers across the industry are actively encouraged to increase the recycling of materials, which will naturally decrease the demand for new aggregate. Although this recycling does not appear to be effectively measured, recycling rates are highly likely to increase, especially in light of the introduction, and subsequent increase, of a Landfill Tax. This will reduce demand for new minerals, and also reduce inert waste backfill supply. The draft plan states that “materials such as inert waste will need to be imported to ensure that the site can be restored and returned to a beneficial after‐use” but also that “material may not necessarily be available in the required quantities and timescales as the introduction and application of Landfill Tax has reduced the amount of inert waste available”. It is unclear as to how much waste will be required, and over what timeframe, which thereby throws further questions up regarding where the waste will come from and the type/volume of traffic needed to transport it (all bringing further associated concerns regarding road safety and pollution). Flash Farm would need the equivalent to waste from the entire county each year to fill it – this is a highly unrealistic prospect. No information has been provided as to the landscaping and finishing of the land once it is (eventually) filled so it is not possible to comment on what it may look like, and subsequent impacts of that.

SUMMARY

There is a lack of clarity with regard to recycling rates. Also with regard to where the landfill will come from and how (and associated impacts ‐ particularly traffic). Insufficiently quantifiable information means that comments cannot accurately be made with regard to the later stages of the site's lifespan. It is felt that the ability to effectively fill the hole left by the extraction has been grossly overestimated, and that the site will be 'incomplete' for many years longer than stated.

CHANGE TO PLAN

*Provide more specific data with regard to existing and anticipated recycling rates *Clearly outline expectations for infill provision ‐ what, how much, from where, envisaged end date *Clearly state what the site will look like at the end of it's life and any anticipated ongoing effects, environmental or otherwise.

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 22:55 To: Subject: Representation received. ID:29388

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29388 Document: Minerals Local Plan Submission Draft Section: Chapter 6: Implementation and Monitoring Support/Object: Support

It is vital that a regular review of the Plan takes place to ensure that existing sites are prioritised and are being utilised effectively. This should then negate the need for new sites being used unnecessarily. The LAA figures should be up to date and included within the plan to accurately identify demand and forecast future need. If emphasis is to be placed on the last three years, as well as overall trends, this should assist with more accurate prediction of future demand.

1 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 23:00 To: Subject: Representation received. ID:29389

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29389 Document: Minerals Local Plan Submission Draft Section: Sand and gravel delivery schedule Support/Object: Object

• Date range of sales data is out of date ‐ The proposals for the MLP include average sand and gravel requirements over the period 2002‐2011 (which NCC have advised is based on sales). Whilst it is acknowledged that there needs to be a cut‐off point, more up to date information is currently available which both could (and should) be used. It is understood that figures for 2015e are du to be published in the near future. However, the Local Aggregates Assessment (published in 2015) includes data for the period 2004‐2013, and demonstrates a long‐term, continuing trend for actual sales being lower than forecast. It is understood that other counties, i.e. Lincolnshire, Derbyshire and Warwickshire, have been required to use their most up to date data in their MLP submissions.

The MLP looks at mineral development within the County over the next 14 years to 2030. When the County’s average annual sales are calculated, it gives predicted demand of 36.12m tonnes using 2002‐2011 data, and 31.36m tonnes using 2004‐2013 data. Using more up to date figures clearly demonstrates a demand which is at least 4.76m tonnes less than currently proposed, and therefore negates the need for Flash Farm to be used at all – especially as there are a number of sites currently in operation or in reserve which have nott ye been used to capacity, if at all, which could be used first.

SUMMARY

The figures used to identify demand are not up to date therefore the schedule cannot be either. using the most up to date LAA figures will mean that Flash Farm can be removed from the schedule altogether.

CHANGE TO PLAN

1 *Produce a new schedule based upon more up to date figures ‐ this should demonstrate the need to remove Flash Farm from the MLP altogether

The document is unsound because it is not:

How you would like your representation to be considered at the independent examination: Written representation.

2 Eilidh McCallum

From: Nottinghamshire County Council Sent: 24 March 2016 23:15 To: Subject: Representation received. ID:29392

Kirklington Parish Council (Helen Cowlan),

Thank you for your representation which we received as follows:

Representation ID: 29392 Document: Minerals Local Plan Submission Draft Section: MP2p ‐ Flash Farm Support/Object: Object

Kirklington Parish Council feels that demand for gravel has been substantially over‐estimated, and inert infill availability underestimated. Using more up to date sales/demand data would show that Flash Farm is not required. Whilst the need for gravel extraction is acknowledged, it is not the most appropriate site, and the site should not be used at this stage (if at all). It is felt that Flash Farm should not be included as part of the MLP for health and safety concerns primarily related to additional HGV traffic through a small village which cannot support it. It is already dangerous to turn onto the A617, and the volume of current traffic is unacceptable especially with the Church, Village Hall and a school being on the main road, and which has narrow footpaths. Kirklington residents recently submitted a petition of 200+ signatures showing the strength of feeling of our residents, many of whom have written in themselves to express their individual concerns. There are also concerns about the ability of the wider area to cope with the traffic and associated issues e.g. Kelham Bridge/Cattle Market roundabout at Newark, A46/A1 junctions.

SUMMARY

*Out of date data used *Overestimation of demand *Underestimation of infill/site 'completion' *Underestimation of % increase of HGV traffic compared to existing and its importance/impacts

CHANGE TO PLAN

*Remove Flash Farm from the MLP

The document is unsound because it is not: i. Positively prepared ii. Justified iii. Effective

How you would like your representation to be considered at the independent examination: Written representation.

2 880 29928 880 29928

Office use only Person No: 883 Rep Nos: Part A – Personal details 29749

Personal details Agent details (where applicable) Title Mr First name Andrew Last name Hall Address line 1 Address line 2 Address line 3 Postcode Email For those replying on behalf of an organisation or group:

Organisation Hockerton Parish Meeting Job title Chairman

If you are replying on behalf of an organisation or group, how was the response approved and how many people does it represent? Parish meeting 24th March 2016. This response was approved unanimously and is representative of the whole village 120 people

Do you wish to be notified of any of the following? (please tick as appropriate) The submission of the Mineral Local Plan for independent examination Yes The publication of the recommendations of the inspector Yes The adoption of the Minerals Local Plan Yes If agent details are provided contact will be made through them unless otherwise instructed.

Signature Date 28th March 2016 Name Andrew Hall If you are submitting your representation electronically you do not need to provide a signature. Office use only Person No: 883 Part B – Your representation Rep No: 29749 Please read the guidance note before completing this section.

1. To which part of the document does this representation relate? Policy x Site code Map/Plan x Paragraph Other

2. Do you consider the identified part of the document to be: Legally compliant? Yes No Sound? Yes No x If you do not consider the identified part of the document to be sound, please continue to question 3. In other cases please go to question 4. If you think the identified part of the document is not legally compliant and is unsound and therefore want to answer ‘no’ to both parts of this question, please fill in two separate forms.

3. Do you consider the identified part of the document to be unsound because it is not: (1) Positively (4) Consistent with x (2) Justified? x (3) Effective? x x prepared? national policy? You can select more than one test if you feel it is appropriate.

4. Please give details of why you consider the identified part of the document is not legally compliant or is unsound, having regard to the test(s) identified in question 3 (if applicable). Please expand box as necessary or attach additional sheets. If attaching sheets, please clearly mark these with the part of the document the representation relates to and your name. The villagers of Hockerton feel this to be an unsound proposal because it is based upon outdated information, unrealistic predictions, overlooks recycling and infill, and completely disregards the concerns of residents (together with those from surrounding villages) in relation to increased heavy traffic on roads that are already overloaded. The predictions have been based upon sales figures from 2002-2011, whereas the Local Aggregates Assessment for the period 2004-2013 is more up to date and relevant. These figures show clearly that long term demand is falling, and that production from Flash Farm will be totally surplus to requirements as unused quantities from current sites or those in reserve will still be available. Furthermore, no account has been taken of recycling and infill. It is understood the proposed developer is looking to bring in infill waste which will further increase the volume of heavy traffic through the village adding to noise and air pollution. Increased recycling and the new landfill tax may also mean that landfill is not readily available, bringing into question exactly what type of waste is being used and from what distance. 5. Please set out what change(s) you consider necessary to make the identified part of the document legally compliant or sound, having regard to the test(s) identified in question 3 (if applicable). Please state why this change will make it legally compliant or sound and suggest revised wording of policy or text. Please be as precise as possible. Please expand the box as necessary or attach additional sheets. If attaching sheets, please clearly mark these with the part of the document the representation relates to and your name.

Please note: You should provide as much information/justification in your representation as you feel necessary and appropriate because once you have submitted your representation there will not normally be a subsequent opportunity to submit anything else unless requested to do so by the planning inspector. Hockerton Parish feel that more up to date information should have been used, including 2015 traffic information, and that an imminent report (to be produced after the deadline for these comments) will substantiate the view that Flash Farm is surplus to the requirements of this plan.

6. Have you raised this issue previously (during earlier stages of consultation)? Yes x No If Yes, please give details In 2014, at an earlier stage of this process, Hockerton Parish made representations against this proposal, on the grounds of unacceptable traffic volumes, increased noise and air pollution, and the impact on local villages. Many of Hockerton’s residents also wrote personally to express their individual concerns

Signature Date 28th March 2016 Name Andrew Hall If you are submitting your representation electronically you do not need to provide a signature 890 29868 890 29868

Office use only Person No: 891

Rep Nos: 29625 Part A – Personal details

Personal details Agent details (where applicable) Title Mr First name Bev Last name Angell Address line 1 Address line 2 Address line 3 Postcode Email For those replying on behalf of an organisation or group:

Organisation Barton in Fabis Parish Council Job title Clerk to the Council

If you are replying on behalf of an organisation or group, how was the response approved and how many people does it represent? Approved unanimously at meeting of Barton in Fabis Parish Council 17/3/2016 (all 5 councillors present), representing Barton in Fabis (population approx. 250)

Do you wish to be notified of any of the following? (please tick as appropriate) The submission of the Mineral Local Plan for independent examination x The publication of the recommendations of the inspector x The adoption of the Minerals Local Plan x If agent details are provided contact will be made through them unless otherwise instructed.

Signature Date 17/3/2016 Name Bev Angell Clerk to Barton in Fabis Parish Council If you are submitting your representation electronically you do not need to provide a signature. Office use only Person No: 891 Part B – Your representation Rep No: 29625 Please read the guidance note before completing this section.

1. To which part of the document does this representation relate? Policy MP2 Site code Map/Plan Paragraph 4.15 Other

2. Do you consider the identified part of the document to be: Legally compliant? Yes x No Sound? Yes x No If you do not consider the identified part of the document to be sound, please continue to question 3. In other cases please go to question 4. If you think the identified part of the document is not legally compliant and is unsound and therefore want to answer ‘no’ to both parts of this question, please fill in two separate forms.

3. Do you consider the identified part of the document to be unsound because it is not: (1) Positively (4) Consistent with No (2) Justified? No (3) Effective? No No prepared? national policy? You can select more than one test if you feel it is appropriate.

6. Have you raised this issue previously (during earlier stages of consultation)? Yes No X If Yes, please give details

Signature Date 17/3/16 Name Bev Angell If you are submitting your representation electronically you do not need to provide a signature 896 29929-29934 Off,ce use only Person No: Part B - Your representation 896 Rep No: 29929-30 Please read the guidance note before completing this section.

1 Tow h"IC h pa rt0 fth e d ocumentd oes th"1s representa. t1on re ate ? SP4and Policy Vision Site code MP2r Map/Plan Paragraph Other Statement

2. Do ou consider the identified artof the document to be: l:e all com liant? Yes ./ No Sound? Yes No ./ Ifyou do not consider the identified partof the document to be sound, please continue to question3. In other cases please go to question 4. Ifyou think the identified part of the document is not legally compliant and is unsound and therefore want to answer 'no' to both partsof this question, please fillin two separateforms.

3. Do ou consider the ident ified art of the document to be unsound because it is not: (1) Positively (4) Consistent with ./ (2) Justified? ./ (3) Effect ve? re ared? i national olic ? You can select more than one testif you feel it is appropriate.

SP4 3.42 29929 FLOODING: Burton Joyce is an area vulnerable to climate change and flood risk. Much of the village is a high flood-risk area. In extreme weather conditions, the destabilisation of the Trent Bank by gravel workings could alter the flow of the river, putting homes on both sides of the river in danger. Recent alterations in climate and flood defences upstream from BurtonJoyce means that earlier standard assessments of flood risk underestimate the problem here and should be reconsidered. The document states (DM2 3) "Proposals for mineral extraction that increase flood risk to local communities will not be supported unless the risks can be fully mitigated" - we would suggest that until such time as a correct assessment of the flood risk at this site is undertaken it is not possible to fully mitigate the flood risk.

By indicating the necessity to raise flood defences, the prospective operators of Shelford West appear to accept the greater risk of flood by quarrying at this site whilst the document (Policy SP4 -Climate Change, 1b) clearly states "Avoiding areas of vulnerability to climate change and flood risks". We would argue that avoidance is possible and that the document provides insufficient consideration of the following points:

1. The Minerals Local Plan Consultation Submission Draft 2016 does not include a methodology or justification for individual site selection -we would suggest that this demonstrates a lack of clear strategy in the Plan and an apparent ad-hoc selection of sites.

2. Priority does not appear to have been given to the extension of existing sites (SP2 1b) nor adequately demonstrated the need to allow for development on non-allocated sites.

The lack of a detailed and up to date assessment of flood risks at the Shelford site combined with the lack of adequate methodology and/or justification for site selection makes the choice of this site unsound.

29930 LOW CARBON ECONOMY: We do not consider proposals for the removal of material at the site supports the requirement to reduce greenhouse emissions. The inappropriateness of original plans of October 2014was supposedly mitigated by the addition of barging to reduce the quantity of material to be transportedby an over burdened local road system - particularly the A6097. We would argue that barging has not proved to be a practical proposition in comparable sites and the apparent lack of thoroughness in checking the viability of barging as a major element in the choice of Shelford West makes the draft plan unsound.

We would furthersuggest that even if barging is introduced at this site it would only result in a short river journey, following which the gravel would be further moved by road - essentially the A612 - which is the major road connection for Burton Joyce residents and which has already seen a significant increase in the volume of traffic and particularly heavy duty vehicles. We would argue that these slow, stop-start lorry movement along our urban roads and the longer journey times to get to major markets would generate significantly greater emissions than more optimal sites. The significantly increased number of traffic movements created by the selection of Shelford West compared to Barton-in-Fabishas not been considered or commented on in reporting consultation responses to either the decision-making Council Committees or the public.

We understand that the potential developer has indicated that they intend to transport 1 BOk tonnes of aggregates via a conveyor to the processing plant for screening before returning it back to the barge wharf- this approximates to a total of 680,000 tons per annum being moved by a conveyor belt - the amount of energy required to operate this conveyor system would be substantial and clearly contravenes the stated policy to "reducing the impact from development on climate change", again making the choice of Shelford West unsound. The practicality of the use of a conveyor in the manner described by the developer and the impact of moving 680k tonnes p.a. by this means has been ignored. This is an important element of the selection process.

The above issues contravene the policy requirement to minimise the impact of operational practices on climate change. 5. Please set out what change(s) you consider necessary to make the identified partof the document legally compliant or sound, having regard to the test(s) identified in question 3 (if applicable). Please state why this change will make it legallyPlease compliant expand the or box sound necessary and suggestor attach revised additional wording sheets. of policy If attaching or text. sheets,Please please be as preciseclearly mark as possible.these with the part of the documentas the representation relatesto and your name.

Pleasenote: You should provideas much information/justification in your representation you feel necessaryand appropriatebecause once youhave submitted your representation there willnot normallyas be a subsequent ortunit to submit an hin else unless re uested to do b the tannin ins ector. o so A scientificassessment of closeness of sites to market should be produced with an analysis of data provided in assessing the tonne-miles impact on the environment.

The energy requirements of barge loading and conveyor transport should be properly assessed relative to those of other sites.

A correct assessment of the flood risk at this site is undertaken.

The increased number of traffic movements created by the selection of ShelfordWest compared to Barton-in-Fabis should be transparently considered and reported.

6. Have you raisedthis issue previously (during earlier stages of consultation)? Yes I N o I./ If Yes, please give details

Signature I Date I If you are submittingyour representation electronicallyyou do not need to provide a signature Off100 use only Person No: Part 8- Your representation 896 Rep No: 29931-32 Please read the guidance note before completing this section.

1. To which artof the document does this re resentation relate? Other 29931 29932 ou consider the identified artof the document to be: Le all com liant? Yes ./ No Sound? Yes No ./ If you do not consider the identified partof the document to be sound, please continue to question 3. In other cases please go to question 4. If you think the identified part of the document is not legally compliant and is unsound and therefore want toanswer 'no' to both partsof this question, please fill in two separate forms.

3. Do ou consider the identified art of the document to be unsound because it is not: (1) Positively (4) Consistent with ,/ (2} Justified? ,/ (3} Effective? re ared? national olic ? You can select more than one test ifyou feel it is appropriate.

4. Please give details of why you consider the identified partof the document is not legally compliant or is unsoundJ having regard to the test(s) identified in question 3 (if applicable). Please expand box as necessary or attach additional sheets. If attaching sheets, please clearlymark these with the partof the document the re resentation relates to and our name.

We do not consider the Local Aggregate Assessment figure sound or reliable. Historically, the demand for minerals has been regularly below the estimated expectations. We believe that there is not the need for further quarrying, especially in sensitive areas close to residential development such as the Shelford site MP2r.

We suggest that further investigation is required into projections put forward which are contrary to the justification of the requirement for 49.02 million tonnes. 5. Please set out what change(s) you consider necessary to make the identified(if part of the document legally compliant or sound, having regard to the test(s) identified in question 3 applicable). Please state why this change will make it legallyPlease compliant expand the or box sound as necessary and suggestor attach revised additional wording sheets. of policy If attaching or text. sheets,Please pleasebe as preciseclearlymark as possible.these with the partof the document the representation relates to and your name.

Further analysis required work using other data submissions, more recent trend information and substitution information regarding recycled building materials.

The over-emphasis on supply-side information needs to be balanced by an examination of demand and where it occurs.

6. Have you raised this issue previously {during earlierI staaesI ./ of consultation)? Yes No If Yes, please give details

4-\ Signature j Date :2 3 \ l .b • I If you aresubmitting �your (V"\'O� representation electronicallyyou do not need to provide a signature Off,ce use only Person No: Part B - Your representation 896 Rep No: 29933 Please read the guidance note before completing this section.

1. To which art of the document does this re resentation relate? Other

ou consider the identified art of the document to be: Le all com liant? Yes ./ No Sound? Yes No ./ If you do not consider the identified partof the document to be sound, please continue to question3. In other cases please go to question 4. If you think the identified part of the document is not legallycompliant and is unsound and therefore want to answer 'no' to both parts of this question, please fill in two separate forms.

3. Do ou consider the identified art of the document to be unsound because it is not: (1) Positively (4) Consistent with ./ (2) Justified? ./ (3) Effective? re ared? national olic ? You can select more than one test if you feel it is appropriate.

Removal We do not consider proposals for the removal of material at the site MP2r sound. The inappropriateness of original plans of October2014 was supposedly mitigated by the addition of barging, to reduce the quantity of material to be transported by an overburdened local road system, particularlythe A6097. However, barging has not proved a practical proposition in comparable sites, and if set up, even if not put to use, would be destructive of the local environment to Burton Joyce, and if used would result only in a short river journey, following which gravel would be further movedby road, essentially the A612, the major road connection for BurtonJoyce residents.

Notably, the Addendum to the STA (February 2016), while recognising the possibility of not barging materials fails to examine the implications. The Highways authority state that the use of barging should be "thoroughly investigatedn and this has not been carried out.

We believe that the selection of Shelford West goes against the requirements of SP5 in that sites should be close to markets and the main highway network and that the effect of the number of vehicle movements for aggregates from the Shelford West site has not been properly examined. 5. Please set out what change(s) you consider necessary to make the Identified part of the document legally compliant or sound,it having regard to the test(s) identified in question 3 (if applicable). Please state why this change will make legallyPlease comp expandliant the or boxsound as necessary and suggestor attach revised additional wording sheets. of policy If attaching or text.sheets, Please pleasebe as clearlyprecisemark as possible.these with the part of the document therepresentation relates to and your name.

Please note: You should provide as much information/justification in yourrepresentation youfeel necessaryand appropriate because once you have submittedyour representation there will not normallyas be a subsequent ortuni to submit an hin else unless re uested to do b the lannin ins ector. o so A thorough investigation of traffic movementsfrom potential sites serving the south of the county needs to be carried out.

The implications of barging not being used as a means of moving 180k tonnes of aggregates to Colwick need to be rigorously examined.

A proper and fact-based analysis of the practicality and viability of barging from Shelford West needs to be conducted and the probability determined of this mode of transporting materials actually being used in practice.

6. Have you raised this issue previously (during earlierI stagesI./ of consultation)? Yes No H Yes, please give details

l 3 \Ii.. :signature Date ?4 I I If you are submittingyour J representation electronicallyyou do not need to provide a signature Office useonly Person No: Part B - Your representation 896 Rep No: 29934 Please read the guidance note before completing this section.

1. To which art of the document does this re resentation relate? Policy Site code MP2r Map/Plan Paragraph Other

2. Do ou consider the identified art of the document to be: Le all com liant? Yes ../ No Sound? Yes No ../ If you do not consider the identified partof the document to be sound, please continue to question 3. In othercases please go to question4. If you think the identified partof the document is not legally compliant and is unsound and thereforewant toanswer 'no' to both partsof this question, please fill in two separate forms.

3. Do ou consider the identified artof the document to be unsound because it is not: (1) Positively (4) Consistent with .., (2) Justified? .., (3) Effective? re ared? national olic ? You can select more than one test if you feel it is appropriate.

Policy DM5 states that there should be no adverse impact on the character and distinctiveness of the landscape. We would argue that the large scale industrialisation of the riverside less than 200 metres across the river from Burton Joyce would have a catastrophic impact on the character and distinctiveness of the landscape. The Burton Joyce Riverbank is a popular local green space and forms 'an important partof people's day-to day lives' not only of Burton Joyce residents but for many visitors to the area who choose to picnic, exercise and generally enjoy the amenity.

Whilst accepting that it is a legal approach to limit considerations of impacts to the area within 200m of the extraction site, we do not consider this sound. The Burton Joyce riverbank, a popular local green space, is within 200m of site MP2r, and hundreds of homes within the village are only just beyond that boundary. Moreover, the prevailing winds would exacerbate the problems caused by noise (apparently pumping would continue 24 hours a day on such dry-extraction sites) and dust which would afflict local residents.

We consider the proposed "restoration to wetland" after exhaustion of the Shelford site would not meet the requirement for sound biodiversity-led restoration. There is already an over-supply of "wetland" - essentially holes full of stagnant water- in this part of the Trent Valley, and adding more would in no way balance the varied habitat that would have been destroyed. Further, the proximity of large open areas of stagnant water to residential areas is likely to lead to atmospheric saturation, causing increased fogs in the valley and on local roads, and possible health problems through breathing or rheumatic conditions.

Insufficient attention has been paid to this element of the selection criteria and there is no evidence to show that the impacts have been properly assessed or that the wider communities' views have been considered. 5. Please set out what change(s) you consider necessaryto make the identified part of the document legally compliant or sound, having regard to the test(s) identifiedin question 3 (if applicable). Please statewhy this change will make it legally compliant or sound and suggest revised wordingof policy or text. Please be as precise as possible. Please expand the box as necessaryor attach additional sheets. If attaching sheets, please clearlymark these with the partof thedocument the representation relates to and your name.

There needs to be furtherassessment of landscape impact in general for the proposed ShelfordWest site and the views of the wider community need to be taken into account.

6. Have you raised this issue oreviouslv Cdurim1 earlier stages of consultation)? Yes I No I ./ If Yes, please give details

I Signature I Date If you aresubmitting I your representation electronicallyyou do not need to provide a signature

Office use only Person No: 969

Rep Nos: Part A – Personal details 29967-29968

Personal details Agent details (where applicable) Title Mr First name Richard Last name Mapletoft Address line 1 Address line 2 Address line 3 Postcode Email For those replying on behalf of an organisation or group:

Organisation Rushcliffe Borough Council Job title Planning Policy Manager

If you are replying on behalf of an organisation or group, how was the response approved and how many people does it represent?

Do you wish to be notified of any of the following? (please tick as appropriate) The submission of the Mineral Local Plan for independent examination  The publication of the recommendations of the inspector  The adoption of the Minerals Local Plan  If agent details are provided contact will be made through them unless otherwise instructed.

Signature Date Name If you are submitting your representation electronically you do not need to provide a signature. Office use only Person No: 969 Part B – Your representation Rep No: 29967-29968 Please read the guidance note before completing this section.

1. To which part of the document does this representation relate? Policy MP2 Site code MP2r Map/Plan Paragraph 4.52 Other

2. Do you consider the identified part of the document to be: Legally compliant? Yes No  Sound? Yes No  If you do not consider the identified part of the document to be sound, please continue to question 3. In other cases please go to question 4. If you think the identified part of the document is not legally compliant and is unsound and therefore want to answer ‘no’ to both parts of this question, please fill in two separate forms.

3. Do you consider the identified part of the document to be unsound because it is not: (1) Positively (4) Consistent with (2) Justified?  (3) Effective?  prepared? national policy? You can select more than one test if you feel it is appropriate.

Legally Compliant SA - 29967 MP2r - 29968 Strategic Environmental Assessment/Sustainability Appraisal

Rushcliffe Borough Council is concerned that the Sustainability Appraisal’s assessment of site MP2r (Shelford West) is not correct and that the focus upon a scoring system of each site’s economic, social and environmental effects does not adequately consider the existence of significant effects which by themselves (or cumulatively) would normally prevent development. There is also concern that the SA does not clearly outline the reasons the sites where selected in light of the alternatives (as required by The Environmental Assessment of Plans and Programmes Regulations 2004 and National Planning Policy Guidance).

Site Matrix

The SA assessment of Shelford West within the Draft Preferred Approach (October 2013) identified negative effects upon biodiversity, sustainable transport, heritage assets, landscape, flood risk, soil, and human health and quality of life objectives. Whilst the site scored positively against objectives that ensured mineral supply, efficient use of resources, and economic growth, these numerous negative effects resulted in the site being excluded within the Draft Preferred Approach.

Since the Preferred Approach, two further consultations have amended the Shelford West proposal, these were the Preferred Approach Consultation on Sand and Gravel in May 2014 and Preferred Approach Shelford West and Shelford East in October 2014. These changes altered the site boundary avoiding direct land take from the Swallow Plantation Local Wildlife Site (LSW). Significant transportation infrastructure, including a wharf on the River Trent (enabling transportation by barge) and conveyor to the A6097 (where a HGV loading area will be located) resolved the access and transportation issues and enabled a significant proportion of minerals (180,000 tonnes per annum) to be transported by barge.

The SA supporting the draft Preferred Approach recorded -2 (operational impacts) and -1 (long term impacts) against the SA’s townscape and landscape objective. This score has not altered even though significant amendments to the proposed allocation have been made. Most notably the inclusion of a 600m wharf on the River Trent and a 2km aggregate conveyer from the site to a 10 hectare HGV loading area adjacent to the A6097 (which was described within the October 2014 consultation as a ‘processing plant’).

The landscape impact of this additional infrastructure does not appear to have been considered within later iterations of the SA, including the submission draft. The effect upon landscape and openness are critical given the site’s location within the Green Belt.

It is not clear whether the conveyor and HGV/processing area will have implications upon the SA’s assessment of the site’s impacts upon ecology, heritage assets, flood risk, soil (the area is Grade 2 and 3 agricultural land), air quality, and quality of life.

Paragraph 21 of the NPPG on SA states that: “Further assessment may be required if the changes have not previously been assessed and are likely to give rise to significant effects.” Given the scale of the conveyor and HGV loading/processing area, in addition to the positive transportation benefits, the implications of these elements should be assessed and considered.

Rushcliffe Borough Council is concerned that the scoring of effects on biodiversity does not reflect the potential impacts on four Local Wildlife Sites which are in close proximity of the site (Swallow Plantation, Shelford Carr, Manor Lane Bank and River Trent: Burton Joyce to Lowden). Whilst they are not directly affected, until the hydrological and hydrogeological, noise and dust impacts on these sites are determined, these effects cannot be ruled out. Furthermore an area of priority habitat (Coastal and Floodplain Grazing Marsh) may also be affected. Due to the extent of locally important nature conservation interest, Rushcliffe Borough Council believes the SA should determine a negative impact of -2 against the SA’s biodiversity objective rather than -1.

Scoring Effects

The SA’s overall conclusions are unhelpful as they do not appropriately weight effects or compare these effects against alternatives. Critically the scoring of performance against objectives and selection of sites according to an overall score conceals constraints which, alone or cumulatively, should lead to a site being ruled out.

The Planning Advisory Service Principles of plan making on sustainability appraisal state that planning authorities should:

“Be careful with mathematical models which can be difficult to use to determine significance. It can be tempting to allow formulae and scoring to lead to an artificial 'certainty' in the model. A comparison of scores on issues which are actually quite subjective can be more unhelpful.”

Although what is considered significant is not explicit in the appraisal, there are significant issues in the SA report, other than transport and accessibility which, due to the inclusion of the conveyer and HGV/processing plant, has resulted in the site being selected. It is appraised that there is a significant negative impact on the historic environment (loss of pillow mound and adverse impact on the setting of listed buildings within Shelford), and on the landscape during operation; a potentially highly significant impact on flood risk, and also on best and most versatile agricultural land and soil.

As stated above these effects are likely to be greater, given the addition of a 2km conveyer and 10ha HGV loading area.

In terms of the Equality Impact Assessment, the ‘local area’ has a higher than ‘Rushcliffe level’ of residents with a long-term activity-limiting illness or disability who may be disproportionately affected by the; “very negative effect from noise, dust, traffic and disruption of rights of way.” As the site scored -3 against the human health and quality of life objective (and cannot be scored lower), the effects upon these residents should be given greater consideration.

Site Selection

The SA’s conclusion outlines which sites scored poorly and therefore which sites should not be selected, however paragraph 11 states that “it should be borne in mind that the numerical scoring was used to aid comparisons between sites but was not intended to be definitive.” Whilst this is welcomed and supports Rushcliffe Borough Councils concern that the score should not be the sole determinant of site selection, it is not clear in the SA the reasons, beyond the site scores, for selecting the preferred sites. There is no clear explanation why the Sand and Gravel sites in South Nottingham have been selected in light of alternatives.

The NPPG on SA states that “The sustainability appraisal should outline… the reasons for selecting the preferred approach in light of the alternatives. It should provide conclusions on the overall sustainability of the different alternatives, including those selected as the preferred approach in the Local Plan.” (Paragraph 018)

Site selection has been deferred to the Site Selection Background Paper. The conclusions are based on the SA. Rushcliffe Borough Council is concerned that the consideration of site MP2r within Table 2 does not reflect the conclusions of the SA. Table 2 states that the Shelford Western site has been fully assessed and appraised with no issues highlighted, however as stated in the SA, there are several significant issues which need addressing and may preclude the site’s selection. Consistent with National Policy

Green Belt Policy

NPPF paragraph 90 states that mineral extraction is not inappropriate in Green Belt provided it preserve the openness of the Green Belt and does not conflict with the purposes of including land in Green Belt. Whilst the extraction itself is considered appropriate – as it will not detract from the openness of the Green Belt – Rushcliffe Council considers the wharf, conveyer and HGV loading area/processing plant as inappropriate as they are likely to detract from the Green Belt’s openness and conflict with the purposes of including the land within it, notably the safeguarding of the countryside from encroachment. Although the impacts on the local environment are limited to the period of operation, this operational period is considerable (20 years).

In accordance with the NPPF, as inappropriate development, these elements require very special circumstances. Very special circumstances will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. Substantial weight is given to any harm to the Green Belt.

As no assessment of the transport infrastructure’s impact on openness and Green Belt purposes has been weighed against other considerations (i.e. benefits of the site’s allocation), there is no justification for allocating the site with the Green Belt. Rushcliffe Council therefore considers Site MP2r contrary to Green Belt policy as set out in the NPPF.

Given the existence of alternative Sand and Gravel sites outside the Green Belt and the scale of inappropriate transport infrastructure, Rushcliffe Borough Council believes the benefits of this site’s location would have to be exceptional in order to allocate the site.

Avoid, mitigate or compensate

NPPF Paragraph 152 states that significant adverse impacts on any of the three dimensions of sustainable development should be avoided and “wherever possible, alternative options which reduce or eliminate such impacts should be pursued. Where adverse impacts are unavoidable, measures to mitigate the impact should be considered. Where adequate mitigation measures are not possible, compensatory measures may be appropriate.”

To ensure these effects are avoided, and comply with the NPPF, Rushcliffe Borough Council believes the significant effects identified within the SA justify a re-appraisal of the site against reasonable alternatives. If sites with less adverse impacts are not available or deliverable, further evidence that mitigation of effects (including the effects of the transport infrastructure) on the environment will be effective should be provided before the site is allocated.

Justified

Due to concerns regarding the SA, the absence of an assessment of the transportation infrastructure on the openness and purposes of the Green Belt, and non-compliance with the NPPF’s policy of avoiding effects rather than mitigating or, as a last resort, compensating, Rushcliffe Borough Council do not consider site MP2r justified. 5. Please set out what change(s) you consider necessary to make the identified part of the document legally compliant or sound, having regard to the test(s) identified in question 3 (if applicable). Please state why this change will make it legally compliant or sound and suggest revised wording of policy or text. Please be as precise as possible. Please expand the box as necessary or attach additional sheets. If attaching sheets, please clearly mark these with the part of the document the representation relates to and your name.

Until concerns regarding the SA and site selection process have been resolved Rushcliffe Borough Council does not support the inclusion of site MP2r within the Nottinghamshire Minerals Plan. It should be removed.

6. Have you raised this issue previously (during earlier stages of consultation)? Yes  No If Yes, please give details Concerns regarding the SA were included within representations on the Draft Preferred Approach Shelford West and Shelford East.

Signature Date Name If you are submitting your representation electronically you do not need to provide a signature Office use only Person No: 1006 Rep Nos: Part A – Personal details 29855-29856

Personal details Agent details (where applicable) Title Mr First name Colin Last name Wilkinson Address line 1 Address line 2 Address line 3 Postcode Email For those replying on behalf of an organisation or group:

Organisation RSPB Job title Senior Conservation Planner

If you are replying on behalf of an organisation or group, how was the response approved and how many people does it represent? Contents of response delegated to officer level. The RSPB is a charity with over 1.1 million members, however like any such organisation individual members are fully entitled to disagree with the details of our response.

Signature Colin Wilkinson Date 23 March 2016 Name - If you are submitting your representation electronically you do not need to provide a signature. Office use only Person No: 1006 Part B – Your representation Rep No: 29855 Please read the guidance note before completing this section.

1. To which part of the document does this representation relate? Policy SP2 Site code Map/Plan Paragraph Other

2. Do you consider the identified part of the document to be: Legally compliant? Yes X No Sound? Yes X No If you do not consider the identified part of the document to be sound, please continue to question 3. In other cases please go to question 4. If you think the identified part of the document is not legally compliant and is unsound and therefore want to answer ‘no’ to both parts of this question, please fill in two separate forms.

N/A – however, please see attached letter. 5. Please set out what change(s) you consider necessary to make the identified part of the document legally compliant or sound, having regard to the test(s) identified in question 3 (if applicable). Please state why this change will make it legally compliant or sound and suggest revised wording of policy or text. Please be as precise as possible. Please expand the box as necessary or attach additional sheets. If attaching sheets, please clearly mark these with the part of the document the representation relates to and your name.

N/A – however, please see attached letter.

6. Have you raised this issue previously (during earlier stages of consultation)? Yes Yes No If Yes, please give details Please refer to the RSPB’s representations on the Issues and Options (2012) and Preferred Options (2013) stages of the MLP.

Signature Colin Wilkinson Date 24 March 2016 Name - If you are submitting your representation electronically you do not need to provide a signature Office use only Person No: 1006 Part B – Your representation Rep No: 29856 Please read the guidance note before completing this section.

1. To which part of the document does this representation relate? Policy Site code Map/Plan Paragraph Other Appx 3

N/A – however, please see attached letter.

Signature Colin Wilkinson Date 24 March 2016 Name - If you are submitting your representation electronically you do not need to provide a signature Steven Osborne-James Senior Planning Officer Nottinghamshire County Council

By email only

29 March 2016

Dear Mr Osborne-James,

Re: Nottinghamshire Minerals Local Plan – Submission Draft Formal Consultation

Thank you for consulting the RSPB on the Nottinghamshire Minerals Local Plan (MLP) Submission Draft.

We do consider the MLP to be sound and legally compliant, and we acknowledge you are therefore under no obligation at all to consider any further comments we make. However, we suggest a couple of minor amendments that in our opinion would raise this MLP to the standard of a national exemplar in the way it addresses biodiversity-related issues and landscape-scale conservation approaches. We hope that there is still opportunity for our suggestions to be incorporated into the MLP as minor amendments.

Context Since the Preferred Options consultation in 2013, key stakeholders have come together – through a series of workshops organised and facilitated by the RSPB and Nature After Minerals (NAM) - to identify how minerals development can help give nature a home on a landscape-scale in the Trent and Tame River Valleys. Two key milestones this partnership working have been the production of the following publications:

1. Bigger and Better – how Minerals Local Plans can help give nature a home on a landscape scale in the Trent and Tame River Valleys (2015); 2. Bigger and Better – giving nature a home in the Trent Valley: Newark to South Clifton Concept Plan (2016).

These documents have been endorsed by a wide range of organisations. They are intended to complement the existing good work that is already taking place to enhance biodiversity. They

Midlands Regional Office

The RSPB is part of BirdLife International, a partnership of conservation organisations rspb.org.uk working to give nature a home around the world.

Suggested additional minor amendments to the MLP:

The MLP already addresses many of the principles that are set out in the above two documents. In particular we support the proposal in the relevant Site Allocation Development Briefs in Appendix 3, to implement a master-planning process for the cluster of sites between Newark and South Clifton. The Concept Plan provides a natural starting point for this master-planning process. As such, we would like to see the Concept Plan explicitly referred to in the MLP.

Whilst we support the reference to a master-planning approach in Appendix 3, we believe that this approach should also be reiterated within the main body of the MLP, ideally in the new supporting text for Policy SP2 (Biodiversity-led restoration). This would also be an appropriate place to explicitly reference the first Bigger and Better document as this document encapsulates many of the aspirations set out in this text.

Based on the points outlined above, the specific amendments that we would like to see in the MLP are as follows (new text underlined):

In Appendix 3: Site Allocation Development Briefs:

All sites within the Newark to South Clifton Cluster (i.e. Langford Lowfields, Besthorpe, Cromwell): Amend the text relating to master-planning to explicitly reference the Newark to South Clifton Concept Plan (i.e. ‘The approach to restoration ... should ideally be co-ordinated through a Master- planning process, or similar, as exemplified by the Newark to South Clifton Concept Plan ...’)

MP2h (Langford Lowfields West) / MP2 l (Cromwell South) Add the sentence relating to master-planning that is included in the Site Allocation Development Briefs for other sites within this cluster (i.e. ‘The approach to restoration ... should ideally be coordinated through a Master-planning process ...’).

In the justification text for Policy SP2 (Biodiversity-led restoration):

Paragraph 3.18: ‘This landscape-scale approach seeks to look beyond small protected sites to deliver nature conservation on a larger scale across the countryside. The Trent and Idle Valleys are considered to be a key area for such a landscape-scale approach with opportunities for cross- boundary action between Minerals Planning Authorities to enable a coordinated, strategic approach to maximise the restoration potential of individual sites. This approach is exemplified in ‘Bigger and Better: how Minerals Local Plans can help give nature a home on a landscape scale in the Trent and Tame River Valleys’.

Paragraph 3.19: ‘By creating new habitats, and contributing to landscape-scale nature conservation, considerable progress can be made towards creating a countryside that is more permeable to wildlife by establishing linkages, stepping stones and corridors of habitat and more

Midlands Regional Office

The RSPB is part of BirdLife International, a partnership of conservation organisations rspb.org.uk working to give nature a home around the world.

Patron: Her Majesty the Queen Chairman of Council: Professor Steve Ormerod, FIEEM Chief Executive: Mike Clarke Regional Director: Emma Marsh The Royal Society for the Protection of Birds (RSPB) is a registered charity: England and Wales no. 207076. Scotland no. SC037654 coherent ecological networks which are more resilient to future pressures such as climate change and which allow the movement and dispersal of wildlife species. This is particularly relevant for clusters of mineral sites such as the sites between Newark and South Clifton, as exemplified in ‘Bigger and Better – giving nature a home in the Trent Valley: Newark to South Clifton Concept Plan’. Reasoned justification: We envisage that the two Bigger and Better documents will have a key role to play over the lifetime of the MLP, particularly given their level of endorsement by such a wide range of stakeholders (including, variously, Natural England, the Environment Agency, CEMEX and Tarmac, the Wildlife Trusts for the counties involved, the Angling Trust, and the Trent Rivers Trust).

We believe these documents merit the same sort of consideration and reference as other key documents like the Nottinghamshire Local Biodiversity Action Plan and National Character Area profiles, and nature-conservation initiatives such as Living Landscapes, Futurescapes and biodiversity opportunity mapping. All these are currently referred to by the submission-draft MLP.

By incorporating these suggested amendments, we believe that the Nottinghamshire MLP will truly be an outstanding, national exemplar for the biodiversity-led restoration of mineral sites. The RSPB responds to Mineral Local Plans all around the UK and we often cross-refer to the latest visible example of best practice in each major policy area. The Nottinghamshire MLP could be just such an example for other mineral planning authorities to follow.

Yours sincerely,

Colin Wilkinson MSc MRTPI Senior Conservation Planner

Midlands Regional Office

The RSPB is part of BirdLife International, a partnership of conservation organisations rspb.org.uk working to give nature a home around the world.

Office use only Person No: 1021

Rep Nos: 29703-29706 Part A – Personal details

Personal details Agent details (where applicable) Title Mr First name Ben Ayres Last name c/o Hanson Quarry Products Europe Limited

Land & Mineral Resources Department Address line 1 Hanson UK

Address line 2

Address line 3 Postcode Email For those replying on behalf of an organisation or group: Organisation Hanson Quarry Products Europe Limited Job title Land and Planning Manager

If you are replying on behalf of an organisation or group, how was the response approved and how many people does it represent? N/A

Signature Ben Ayres Date 24th March 2016 Name Ben Ayres c/o Hanson Quarry Products Europe Limited If you are submitting your representation electronically you do not need to provide a signature. Office use only Person No: Part B – Your representation 1021 Rep No: 29703=29705 Please read the guidance note before completing this section.

1. To which part of the document does this representation relate? MP2 1.b MP2m & Insert 5 Policy & MP2. Site code Map/Plan Paragraph - Other - MP2o) & 13 2

2. Do you consider the identified part of the document to be: Legally compliant? Yes  No Sound? Yes  No If you do not consider the identified part of the document to be sound, please continue to question 3. In other cases please go to question 4. If you think the identified part of the document is not legally compliant and is unsound and therefore want to answer ‘no’ to both parts of this question, please fill in two separate forms.

6. Have you raised this issue previously (during earlier stages of consultation)?n/a Yes No If Yes, please give details

Signature Date Name Ben Ayres c/o Hanson Quarry Products Europe Limited If you are submitting your representation electronically you do not need to provide a signature 29706

From: Ayres, Ben J (Wetherby) GBR Sent: 24 March 2016 15:55 To: Development Planning Cc: Steven Osborne-James Subject: RE: Nottinghamshire Minerals Local Plan Submission Draft Attachments: representation-form.doc

Dear Sir/Madam,

Nottinghamshire Minerals Local Plan Submission Draft

Please find attached the represtation form completed on behalf of Hanson Quarry Products Europe Limited.

Hanson Quarry Products Europe Limited supports policy MP2 1.b (New sand & gravel sites at Barnby Moor (ref MP2m) and Coddington (MP2o) and policy MP2. 2 regarding proposals to extract specialist grey sand reserves.

We would also like to comment specifically on information contained within the development brief information (Appendix 3) for Barnby Moor (ref MP2m). Whilst we would expect that this type of detail will be addressed as part of the pre submission consultation and development work (which Hanson will undertake as part of the preparation of the application and EIA) during 2017, we felt it was important that they also raised as part of the plan process.

Chapter 6 MP2m-Barnby Moor- Quarry restoration

The above section states the following:

Restoration of the site should be primarily biodiversity-led, however the high quality agricultural soils should be taken into account in the final restoration proposal reflecting policy DM3; Agricultural land and soil quality. Target restoration will depend on landform, hydrology and substrate characteristics.

Hanson comment: Whilst the site provides an opportunity for biodiversity-led restoration, we are pleased with the reference to agriculture as the site has to be economically self-sustainable following restoration and as such there needs to be a balance between biodiversity (reedbeds), agriculture, low key amenity and uses such as the continuation of rotational willow coppicing.

Chapter 6 MP2m-Barnby Moor - Water and flooding section The above section states the following:

-No plant or equipment or storage of aggregate or overburden should be in the Main Drain area and no excavation within 30m of the top of the bank forming the Main Drain -Ensure 9 metre easement from watercourse that runs through the site from south to north is suitable to withstand ingress from water into the quarry.

Hanson comment: The total mineral reserve of 1.1mt within the proposed allocation assumes that the route of the Main Drain is altered as a result of extraction of mineral. The drain will form an integral part of the final restoration scheme for the site. Hanson will consult with the IDB and other statutory bodies on this site specific development and restoration proposal prior to any planning application and EIA is submitted for the site.

If you have any questions on this submission then please contact me .

1 Ben Ayres Land and Planning Manager Land & Mineral Resources Department Hanson UK

From: On Behalf Of Development Planning Sent: 12 February 2016 09:27 Subject: Nottinghamshire Minerals Local Plan Submission Draft

Please see attached letter regarding a formal consultation period on the Nottinghamshire Minerals Local Plan Submission Draft.

The consultation period runs from Monday 15 February to Tuesday 29 March 2016.

Planning Policy Team - Nottinghamshire County Council [email protected] 0300 500 80 80 www.nottinghamshire.gov.uk/minerals

Planning Policy Team Nottinghamshire County Council County Hall, West Bridgford Nottingham, NG2 7QP

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All orders are subject to Hanson’s Standard Conditions of Sale, a copy of which can be obtained at http://www.hanson.co.uk/standard-terms-and-conditions

Each of Hanson Aggregates, Hanson Aggregates UK, Hanson Bath & Portland Stone, Hanson Construction Projects, Hanson Contracting, Hanson Premix, Hanson Recycling, Ashbridge Concrete and Supamix is a trading name of Hanson Quarry Products Europe Limited. Hanson Quarry Products Europe Limited is a private limited company incorporated in England and Wales with registered number 00300002 and with registered address Hanson House, 14, Castle Hill, Maidenhead, Berkshire SL6 4JJ . Hanson Quarry Products Europe Limited is a member of the HeidelbergCement Group. 2 This e-mail and any attachment transmitted with it are confidential and are intended for the named person’s use only. The contents of the e-mail may contain sensitive and private or legally privileged information. If you have received this e-mail in error, please delete it (and any attachment) from your system and notify the sender immediately. You should not retain, copy or print the contents of this e-mail (or any attachment) nor should you, directly or indirectly, disclose or distribute the contents to anyone.

3 1036 30036

My Ref: Local Plan Your Ref: Contact: Matthew Grant Email: Planning Policy Development

Sent by email Tel: www.nottinghamcity.gov.uk

23 March 2016

Dear Lisa

SUBMISSION DRAFT CONSULTATION ON THE NEW NOTTINGHAMSHIRE MINERALS LOCAL PLAN

I write in response to your consultation on the new Nottingham Minerals Local Plan.

The Plan identifies sites and sets out policies against which all minerals development proposals will be assessed and determined. The overall aim is to ensure that sufficient minerals are provided to meet expected demand in the most sustainable way and to safeguard proven mineral resources from being unnecessarily sterilised by other development.

Of most relevance to the City it is noted that sand and gravel extraction is not proposed at Barton in Fabis which could have potentially adjoined or crossed over the administrative boundary into the City. Your decision to not allocate at Barton in Fabis is justified by the clear background evidence contained within the accompanying Sustainability Appraisal. It is also noted that the appraisal for the site despite the separate methodology applied is broadly consistent with that undertaken by the City in the Publication Version of the Land and Planning Policies Part 2 Local Plan Sustainability Appraisal (see page 991 to 996 in Appendix 8: Sustainability Appraisals of Sites Not Taken Forward into the LAPP).

Therefore, on behalf of the Nottingham City Council, we wish to raise no objections to the plan due to legal compliance or soundness of your plan.

Yours sincerely

Matthew Grant Senior Planner (Policy) Direct line : 1041 30059-30062 Mike Ashworth Strategic Director ~DERBYSHIRE Council ~County Improving life for local people

• Planning Policy Team Nottinghamshire County Council Telephone: Fax: County Hall E-mail: West Bridgford Our Ref: CM/Notts Minerals LP Nottingham NG2 7QP Your Ref: • Date: 29 March 2016

Dear Madam/Sir

Nottinghamshire Minerals Local Plan Submission Draft

Derbyshire County Council (DCC) has the following technical officer comments on landscape character and highway issues. There are no soundness or legal compliance issues. These comments are in addition to the separate officer comments dated 24 March 2016, which are subject to endorsement by the Derby and Derbyshire Joint Advisory Committee in its capacity representing the Mineral Planning Authorities for Derby City Council and DCC.

1. Strategic Objectives

30059 S06: Protecting and enhancing natural assets There is concern that a biodiversity-led restoration objective (S06) may lead to negative impacts on landscape character and the historic environment in pursuit of ecological enhancements in so far as proposed sites border Derbyshire. As a member of the Lowland Derbyshire and Nottinghamshire Local Nature Partnership (LNP), DCC is aware that the LNP has targeted the Trent Valley as a priority area for environmental enhancement (http://ldnlnp.org/focus-areas/). The LNP is pursuing a multi-faceted approach to the ongoing planning of the Trent Valley to ensure that it maximises the delivery of economic, social and environmental benefits, which will require planning authorities to protect the best parts of the landscape and historic environment whilst developing a new character for the area that better responds to the challenges it faces. See also comments under Section 4, Development Management Policies, Social and Environmental Impacts.

3. Location of Sites

30060 Policy MP9: Industrial Dolomite Provision It is welcomed that the Local Plan Submission Draft no longer indicates an intention to allocate an extension to the Whitwell Quarry site on land to the south

www.derbyshire.gov.uk IS\T~ lOR '"' PEOPI.E -2-

of Creswell Crags near Holbeck. Through work with DCC, it has been determined that:

• the working life of Whitwell Quarry, with current planning permission, will extend to 2025; and • this timeframe may be further extended beyond the 2030 end date of the Nottinghamshire Minerals Local Plan through potential extensions at the site, dependent on demonstrable need and other relevant planning considerations.

This approach is welcomed given the landscape and historic sensitivities associated with the site and the fact that any future application to work these potential site extensions would need to be supported by a Heritage Impact Assessment to determine the level of harm that might be incurred on Creswell Crags and its setting. The potential for assessing impacts on the historic environment is adequately addressed through Policy DM6: Historic Environment.

4. Development Management Policies

30061 Social and Environmental Impacts The emerging plan provides a sufficient policy context for assessing social and environmental impacts associated with mineral extraction. Whilst there are specific development management policies addressing most environmental issues, and the overall restoration policy (DM12) is relatively inclusive for environmental issues, it may be more helpful if there was less emphasis on a biodiversity-led restoration. This would enable the overall outcomes for social and environmental enhancement to be maximised. For example, there are likely to be conflicts between recreational and wildlife objectives, and it is difficult to appreciate how the visual dimension of the landscape would be considered so that restored sites do not conflict with the established character of the wider landscape.

30062 Policy DM9: Highways Safety and Vehicle Movements I Routeing It is noted that Policy DM9 provides for the provision of vehicle routeing schemes to minimise the impact of traffic on local communities. A number of the proposed sites are close to the Derbyshire/ Nottinghamshire county boundary; therefore DCC requests that your Council consults DCC as Highway Authority on any planning applications relating to the proposed sites that potentially involve routing heavy goods vehicles on Derbyshire's roads. DCC would also wish to be party, where appropriate, to any such routing agreements.

Yours faithfully

Rob Murfin, Planning Service Manager Economy, Transport and Environment PUBLIC -3-

Copies: Christine Massey, Policy and Monitoring Team Leader Michelle Spence, Development Plans Richard Stansfield, Development Plans Carol Barnett, Development Plans Adam Lathbury, Conservation and Design Gary Ellis, Conservation and Design Geoff Blissett, Development Control Andrew Waterhouse, Spatial Planning Group Manager, Derby City Council

PUBLI C 1073 29875-29885 1073 29875-29885