Nottinghamshire Minerals Local Plan Representations - by respondent Volume 11 of 11 Respondent number 7873 - 7910 7873 29912 7873 29912 7874 29914 7874 29914 7875 29915 7875 29915 7876 29916 7876 29916 7877 29917 7877 29917 7878 29919 7878 29919 7879 29921 7879 29921 7879 30000 7880 29925-29927 7780 29925 7880 29926 7880 29927 From John Gillespie 27 3 2016 Planning Policy Team, Notts County Council County Hall West Bridgford Nottingham NG2 7QP Nottinghamshire Minerals Local Plan Submission Draft Representation Form Office use only Person No. 7881 Rep No. 29945-29946 Part A - Personal Details Personal details Agent details (where applicable) Title Mr - First Name John - Last name Gillespie - Address line 1 - Address line 2 - Address line 3 - Postcode - Email not available - Organisation not applicable - this is a personal response - Group not applicable - this is a personal response - Wishes for notification The submission of the Minerals Local Plan for independent examination yes please The publication of the recommendations of the inspector yes please The adoption of the Minerals Local Plan yes please I wish to participate at the oral part of the examination, if possible with other commitments. Signature Date 27 March 2016 Name John Gillespie 1 of 23 Office use only Person No. 7881 Rep No. 29945 Part B - Your representation 1. To which part of this document does this representation relate? Policy MP1 Site code - Map/Plan - Paragraph 4.10 - 4.14 Other 2. Do you consider the identified part of the document to be: Legally compliant? Yes No Sound? Yes No √ 3. Do you consider the identified part of the document to be unsound because it is not: (1) Positively √√ (2) Justified? √ (3) Effective ? √ (4) Consistent with prepared? national policy? 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). 1. Paragraph 4.10 shows the annual aggregate production from 2002 to 2011. It is clear from this that the requirement for sand and gravel has decreased over the period in question. Of course, during this period there has been an economic downturn (in 2006 - 9) followed by a marked recovery, including an increase in house- building. Despite this, the actual production of sand and gravel has decreased over the whole period. 2. The production over years 2002 - 2004 averaged 3.22 m tonnes p.a. whereas the production over 2009 - 2011 averaged 1.51 m tonnes p. a. - only 46.9% as much. Even taking the first four years and comparing with the last four years the change is from an average of 3.19 to 1.73 - only 54.3% as much. 3. Furthermore there is no allowance made for the contribution from re-used aggregate, yet under MP5 (page 63) in the plan this re-use is clearly stated to take place, though no quantities or even estimate of quantities are given. Furthermore it is stated in para. 4.70 et seq. that government policy encourages this re-use to take place and that the Nottinghamshire and Nottingham Replacement Waste Plan has policies to promote “both temporary and permanent facilities for recycling aggregate centres” - para 4.71. It is quite possible, though not quantified anywhere in the report, that the increasing contribution from recycled aggregate is contributing to the significant reduction in demand for ‘new’ aggregate - of about 50% over the 20 year period as pointed out. 4. Overall therefore, bearing in mind that it is clearly of benefit to avoid overproduction from primary sites, in the interests of • conserving future supplies of finite sand and gravel resources, • reducing ecological damage to Nottinghamshire, • reducing the need for major traffic increases from specific sites - as recycled aggregate will be on balance produced from more, smaller sites operating over a few years at most, rather than over a 20 year period, it appears impossible to justify the figure in para. 4.10 of 2.58 m tonnes p.a., which represents approximately 50% more p.a. than the average production over the four years from 2008 - 2011. 5. In the adopted Nottinghamshire Waste Core Strategy (dated January 2015) it is stated that there are 1 million tonnes a year of construction and demolition waste available annually for recycling; this is forecast to rise to 2.75 million tonnes per annum for the years 2015 to 2030 - that is, over the majority of the duration for the Minerals Local Plan. In addition the Waste Core Strategy has a target of utilising 70% of construction and demolition waste through recycling, giving an annual target figure of utilising in excess of 1.9 million tonnes 2 of 23 per year. 6. Based on the figures quoted, and even without taking into account the significant and desired contribution from recycling, a more realistic though still generous estimate of demand for 2012 to 2030 would appear to be no more than 2 million tonnes per year with a total estimated demand of 38 million tonnes, a reduction of over 11 million tonnes over the 19 years. When the contribution from recycled aggregate is taken into account, this figure drops by a further 36.1 million tonnes. So, if even only 25% of such recycled waste is utilised, the total estimated demand drops by a further 9.025 million tonnes over the plan period to only 29 million tonnes. 7. We note that the total contribution of all the proposed new sites is as follows (para 4.47 et seq.): Barnby Moor MP2m - total less than 1 m tonnes Botany Bay MP2n - about 2.4 m tonnes Coddington MP2o - about 10 m tonnes Flash Farm MP2p - about 2.8 m tones Shelford MP2r - about 7 m tonnes giving a total from the five sites over the 19 years of 23.2 million tonnes - or about 1.22 m tonnes p.a. - nearly half of this from Coddington. 8. If the data in 7. is compared with the figures in para. 4.10, it can be seen that the realistic figure of 38 m tonnes could be met by contributions from no more than two of the proposed five sites (Coddington and Barnby or Coddington and Botany Bay for instance - to include sources from both the Trent and Idle valleys), obviating the need to use Shelford, Flash Farm and the remaining one of the two Idle valley source - Barnby or Botany Bay. If recycled aggregate is allowed to be included, four of the five new sites could be dropped. 9. In chapter 6. ‘Appraisal of Minerals Local Plan Sites’, a thorough appraisal of each potential site is laid out. In paragraphs 6.47 et seq., to summarise the factors contributing to the sites’ appraisals which have been quantified in the previous paragraphs, table 6.3 gives an overview of the site appraisal scores. In this table, scores for the sites above, with their river locations, are as follows: site code site name river location Overall site appraisal operational score PA01 Barnby Moor north Notts - Idle -13 PA06 Botany Bay north Notts - Idle -8 PA10 Coddington Newark - Trent -6 PA17 Flash Farm Newark - Trent -10 PA40/41 Shelford W and E South Notts - Trent combined -8 (-6 and -10) This table shows that the two high-scoring Trent valley sites - Flash Farm and Shelford East and West - do not need to be used at all in order to meet the more realistic output for the whole county, as outlined above in 5. As pointed out in para 8 above, if even 25% of recycled waste is utilised - a surely most attainable target - then the demand can be satisfied by Coddington alone, meaning that none of the four sites with more negative operational site appraisal scores - that is Barnby Moor, Botany Bay, Flash Farm and Shelford - need to be utilised. 3 of 23 Office use only Person No. 7881 29946 Rep No. 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. 10 Para. 4.10 should be made consistent with the findings set out in my paras. 1 to 9 above so as to be sound. It should read: Based on the findings of the Local Aggregates Assessment published in July 2013 (December 2011 data) and taking into account the needs to • conserve future supplies of finite sand and gravel resources, • reduce ecological damage to Nottinghamshire, • reduce the need for major traffic increases from specific sites, the LAA Average Production figure and estimated total aggregate demand is as follows: LAA derived annual production Estimated demand 2012 - 2030 figure excluding contributions inclusive (19 years) from recycled waste Sand and gravel 1.55 29.0 Sherwood Sandstone 0.46 8.74 Limestone 0.08 1.52 The overall LAA derived annual production figure in million tonnes - including the contribution from recycled waste - is 2.025 million tonnes. 11 The necessary reduction in production could be achieved by the removal of Flash Farm (MP2p) and Shelford (MP2r) from the list of allocated sites. There are powerful reasons for removing MP2p from the list of sites in order that the allocation should comply with Policies DM1, DM2, DM5, DM6, DM7, DM8 and DM9. The reasons relating to DM1 are outlined in my paras. 12 to 15 below. 6. Have you raised this issue previously (during earlier stages of consultation)? Yes No √ If Yes, please give details Signature Date 27 March 2016 Name John Gillespie 4 of 23 Office use only Person No.