Nottinghamshire Minerals Local Plan Representations

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.

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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. 7881 Rep No. 29946 Part B - Your representation

1. To which part of this document does this representation relate?

Policy DM1 Site code MP2p Map/Plan Subject Paragraph 5.8 - 5.20 Other area plan C15

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).

12 The policies in Chapter 5 are sound, in my view. However policies DM1, DM2, DM5, DM6, DM7, DM8 and DM9 are not applied correctly in the case of site MP2p - Flash Farm. Bearing in mind the discrepancies already identified in my paras. 1 to 10, including the overestimates of actual sand and gravel which will be needed over the 19 year period even before the significant contribution of recycled aggregate is included, Flash Farm site MP2p - and others - should be removed from the list of allocated sites.

13 Regarding policy DM1 - protecting local amenity Potential adverse impacts are certain to include • visual intrusion • noise • transport • potential delays to essential emergency services such as ambulance services to hospital. The much-used and publicised walking route “Trent Valley Way” runs alongside one border of the site. The visual intrusion, dust and noise from the site will have a serious adverse effect on the possible enjoyment of walkers; in effect they will be deterred from using this key section of Trent Valley Way as it approaches the National Heritage site of Newark, including the outlying Civil War defences near to Kelham Bridge. Inspection of OS Explorer map 271 ‘Newark on Trent’ makes clear that there is no suitable alternative route for the Trent Valley Way as it approaches Newark - upstream in the Trent valley from the west. The only alternative diversion would be for the TVW to follow the Trent river towpath from east of Fiskerton to Newark, thus removing the route from key viewpoints and tourist features including Upton Hall, the ascents to Micklebarrow Hill and Averham Park, and the descent along the west edge of Kelham Hills wood. The latter descent would be effectively ruined by the intrusion of the immediately adjacent prospect of the extensive site in operation.

This visual intrusion would also adversely affect the at-present remarkably attractive prospect of the Trent Valley and Newark with Beacon Hill from the western high ground and, in the far distance to the south-west, of the horizon ridge including Beauvoir Castle. At present this view is partly affected by the power station at Staythorpe, but the overall prospect is still a key feature of views for many walkers, countryside users (and local residents); this prospect also helps to aid tourism in the area - a key contributor to the local economy.

14 The proposed site is close to the A617, and just across this road from the village of Averham with Manners Sutton primary school directly on the A617. Averham already suffers traffic noise, and light and air pollution, from the A617 traffic (here including traffic to and from the A612 to Southwell as well). The effect of

5 of 23 further noise, light and air pollution from the site is bound to be very detrimental.

6 of 23 Office use only Person No. 7881 Rep No. 29946

15 The document could be made sound, in part by the removal of site MP2p - Flash Farm. The Flash Farm site is set to produce 2.75 million tonnes over the nineteen years - an amount forming about 10% of the over-allocation of sites already referred to.

16 Furthermore, Flash Farm has already been allocated the Overall site appraisal operational score of -10, among the most negative scores of all the sites under consideration - a good reason on its own for the removal of the site. Reasons for this are gone into below.

6. Have you raised this issue previously (during earlier stages of consultation)? Yes √ No If Yes, please give details By letter - 31 12 2015

To the chairman of the Planning Committee, Notts County Council County Hall West Bridgford Nottingham

Signature Date

Name John Gillespie

7 of 23 Office use only Person No. 7881 Rep No. 29946 Part B - Your representation

1. To which part of this document does this representation relate?

Policy DM2 Site code MP2p Map/Plan Subject Paragraph 5.8 - 5.20 Other area plan C15

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).

17 Regarding policy DM2 - Water resources and flood risk. Although the site in question is low-lying, I am not aware of any flood risk as regards the site itself. However, any transport to the east of the site - that is to the A1 or A46 trunk roads- requires the use of the A617 towards Newark. About one year in three or four, this road has to be closed for several days owing to flooding from the Trent between Kelham and Newark. The alternative routes (via the A616 and South Muskham) are steeply graded and unsuitable for heavy aggregate vehicles. During such closures, long-distance lorries use alternative routes where possible, but this option is not available for traffic from Flash Farm, as the only alternative available is to use the A617 westbound to the A614 junction north of Nottingham, making a detour of at least 20 miles. Note that the A612 through Southwell is closed to vehicles with a tare weight of over 7.5 tonnes.

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18 As stated and justified above, the document could be made sound, in part by the removal of site MP2p - Flash Farm among other sites.

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 Office use only 9 of 23 Person No. 7881 Rep No. 29946 Part B - Your representation

1. To which part of this document does this representation relate?

Policy DM5 Site code MP2p Map/Plan Subject Paragraph 5.8 - 5.20 Other area plan C15

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).

19 Regarding policy DM5 - Landscape character. My comments relating to policy DM1 apply.

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20 As stated and justified above, the document could be made sound, in part by the removal of site MP2p - Flash Farm among other sites.

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

11 of 23 Office use only Person No. 7881 Rep No. 29946 Part B - Your representation

1. To which part of this document does this representation relate?

Policy DM6 Site code MP2p Map/Plan Sheet C Paragraph 5.68 - Other site 15 5.73

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).

21 Policy DM6 states that proposals for minerals development will be supported where it can be demonstrated that: a) There will not be an adverse impact on any designated or non-designated heritage assets and/or their settings; b) Public benefits related to the development outweigh the harm to, or loss of, any designated or non- designated heritage assets and/or their settings. Where this is the case, the harm or loss should be mitigated as far as possible.

Quite apart from the major historical asset of Kelham Hall and its associated outbuildings, there are at least two other major heritage assets to the immediate east of the site at Flash Farm which would be put at risk from a significant increase in heavy vehicle movements on the A617 to the east of the site. These are: i Kelham Bridge, ii The toll road through Kelham (on the line of the modern A612 and A617),

22 Kelham Bridge carries the A617 east over part of the Trent. It is 160 years. Its arched elevation - it rises nearly 2 metres at the centre compared with each end - and its two narrow carriageways (measuring a total of only 4.9 metres wide, that is only 2.45 m each), coupled with narrow but essential pedestrian walkways (for both pedestrians and dismounted cyclists) and an abrupt very sharp right-angled bend at the east abutment mean that regularly (often every 10 minutes or so throughout the day), traffic in both directions comes to a complete halt to allow westbound wide or articulated vehicles to slowly swing across the eastbound carriageway to traverse the bridge proper. Every few years one or other of the brick parapets essential for safety are damaged or partially broken, necessitating an awkward repair. The volume of traffic on the A617 (see below) is such that such repair work causes major disruption to traffic flows. All this is in addition to the damage being done to the bridge - itself a significant historical monument.

Even a quite small increase in daily traffic flows will exacerbate these problems and so lead to a significant further increase in travel times between Kelham and the A46 and Newark. In turn, even a small increase in eastbound traffic will lead to longer travel times for westbound traffic on its journey 9 miles to the junction with the A614, to the east of Rainworth. Thus a predicted flow of 85 vehicles leaving the proposed site each day, with the same 85 vehicles returning, together with vehicle movements for personnel arriving at or leaving the site, and construction and maintenance vehicles, causing a total flow of 200 or more HGVs a day on the A617 - most via the A46 - would add a significant extra volume - and delays - to the existing traffic over the bridge.

12 of 23 23 The present road from Kelham to Southwell (then dividing to go to Farnsfield/Mansfield, and to Nottingham via Oxton), goes back many centuries. It was once a turnpike road, with toll houses at Kelham, Edingley and Oxton, one of which survives to this day. The road predates Kelham Hall, probably by many centuries. The narrowness of the A617 through Kelham village, constrained by buildings on both sides, and the blind bend in the middle of the village, are evidence of this age. There is no scope to widen the road through the village.

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24 By not using the Flash Farm site, possible damage to Kelham Bridge from additional large and heavy vehicles using the A617 east of the site would be avoided.

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 14 of 23 Office use only Person No. 7881 Rep No. 29946 Part B - Your representation

1. To which part of this document does this representation relate?

Policy DM7 Site code MP2p Map/Plan sheet C Paragraph 5.83 - 5.89 Other site 15

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).

25 As already detailed in my comments on DM5 above (my paras. 1 - 10 and 19), the proposals for Flash Farm will have a significantly unacceptable impact on the attractiveness for users of the Trent Valley Way (one of the principal rights-of-way routes in the county) and on the use of other rights of way in the area. As already explained, there is no satisfactory diversionary route - let alone one of ‘an equivalent interest or quality’ - for the Trent Valley Way as it nears its eastern terminus.

This consequence would of course be avoided were the Flash Farm site not to be included in the Minerals Local Plan. As already explained, this can be achieved by using more realistic overall calculations for Annual aggregate production for the 19 years of the plan’s duration, to be stated in a revised version of Table 1 in para. 4.10.

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26 Revise the allocation of sites so that Flash Farm is not included.

Revise the data in Fig 4.1.

The requirements of policy DM7 will then be met - at least in respect of the Flash Farm site - and potential damage to a major public right of way will be avoided.

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 16 of 23 Office use only Person No. 7881 Rep No. 29946 Part B - Your representation

1. To which part of this document does this representation relate?

Policy DM8 Site code MP2p Map/Plan Sheet C Paragraph 5.90 - Other site 15 5.101

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).

27 Policy DM8 sets out the circumstances under which proposals for minerals development will be supported. It will be seen from the foregoing comments relating to policies DM1 through to DM7 that there is no way by which the proposed site at Flash Farm can be accepted.

For this reason, the Flash Farm site cannot meet the requirements of policy DM8.

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28 The requirements of Policy DM8 can be met only by removing site MP2p - Flash Farm - from the list of sites suitable for allocation under the Minerals Local Plan.

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

18 of 23 Office use only Person No. 7881 Rep No. 29946 Part B - Your representation

1. To which part of this document does this representation relate?

Policy DM9 Site code MP2p Map/Plan sheet C Paragraph 5.96 - Other site 15 5.101

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).

29 Policy DM9 requires four features of each proposal to be demonstrated.

None of the features listed can be met by the Flash Farm proposal, apart from feature d) relating to putting in place measures to prevent material such as mud contaminating the public highway,

It is this policy, which I support, that underlies and makes clear my concern that the choice of this site is totally misguided.

30 DM9a requires it to be demonstrated that ‘the highway network can satisfactorily and safely accommodate the vehicle movements, including peaks in vehicle movements, likely to be generated’. Referring to para. 5.98 it is confirmed that ‘Highways England is responsible for the trunk road network which, in Nottinghamshire, includes the M1, A1, A46 A52 and A453’. This confirms that there is no question that this responsibility extends to the A617. Yet the only two routes from the site in question are along the A617 - • three miles to the east to its junction with the A46, and through that to o the A1 a mile to the east (giving access to the north and south) - o the A52 and finally the M1 to the south west (giving access to the south-west) and o the A17(T) to the south and south-east. • no less than nine miles to the west to its junction with the A614(T) - the trunk road which gives access to Nottingham to the south and to Ollerton, Worksop and to the A1 to the north.

It is therefore essential that the key link of the A617 - both eastwards and westwards - is capable of meeting the demands of policy DM9a.

There is serious doubt that this is the case.

31 DM9b requires that the vehicle movements likely to be generated would not cause an unacceptable impact on the environment and/or disturbances to local amenity. The related policy DM9c requires that where appropriate, adequate vehicle routing schemes have been put in place to minimise the impact of new traffic on local communities.

Again there is serious doubt that either of these is the case.

32 I fully support the content of DM9 (paras. 5,96 to 5.101). I seek to justify this position in the following

19 of 23 paragraphs.

33 Taking first of all condition DM9a, I turn to the well-known almost daily problems encountered by the existing traffic travelling east along the A617 from Averham to its junction with the A46 close to Newark. It is a regular feature of travel on this route that long hold-ups are often encountered at the junction, caused in the main by heavy traffic in both directions on the A46 (particularly the case now since vehicles of over 7.5 tonnes gross are prohibited on the A612 north east of Lowdham).

Recently the increase in frequency of trains on the Nottingham - Newark Castle line has added further to this problem. This is unlikely to be reduced in the future.

Admittedly, there are long-term plans to improve the A617/A46 junction, but these are still very much in the planning phase and their extended process of implementation - should they finally be given the go-ahead - is likely to produce yet more delays. There are plans for a new road to be constructed to the south-west of Newark to enable traffic to and from the south-west of Newark on the A46 to link up with the A1 at Balderton/Fernwood on the A1. However, it is by no means clear that this single-track road will result in a major reduction in traffic at the A617/A46 junction or at the A46/A1/A17 junction to the east of Newark.

34 As already noted in para. 22 above, the narrow bridge at Kelham routinely causes further hold-ups when long and/or wide vehicles travelling westwards require eastbound traffic to halt to enable the wide/long vehicles to have space enough to round the sharp bend at the east side of the bridge and when two wide/long vehicles attempt to cross the bridge simultaneously in opposite directions. These manoeuvres are routinely and safely accomplished several times an hour - but at the cost of further delays to traffic in both directions.

35 Traffic also has to negotiate the sharp bend in Kelham village and the T-junction on the A617 with the road to South Muskham (a shortcut to the A1 north for light traffic) - a cause of further delay and - especially when eastbound traffic is stationary owing to a hold-up at the bridge - of significant air pollution for the residents of Kelham.

All traffic between the Flash Farm site and the east (and probably north and south via the A1) would have to pass through Kelham.

36 Traffic between the Flash Farm site and the west and north-west - that is, to the majority of the rest of the county - would have to travel west along the A617 for at least 9 miles to its junction with the A614, and in many cases even further along the A617.

The whole of the A617 from the A46 junction to the A614 - that is 12 miles altogether - is governed by an overall 50 mph speed limit, with 30 mph limits where the road passes through Hockerton and Kirklington. This speed limit has had to be imposed in the interests of road safety, taking into account the many bends, constrictions and narrow stretches on the road.

In addition there are major inclines on the route - to the immediate west of the Flash Farm site to the junction with the Averham Park/Caunton road, on both sides of Lodge Farm in Upton parish, to the east of Hockerton, to the immediate east of Kirklington.

37 The junction already referred to, less than a mile west of the Flash Farm site, is blind and dangerous. The side-road in question routinely acts as an unofficial bypass for light traffic in the event of hold-ups due to accidents, breakdowns or flooding on the A617 to the east or west. At such times, the junction can be hazardous to use, especially bearing in mind the difficulties encountered by HGV drivers in suddenly confronting any junction hold-ups from the hill to the immediate east.

The route to the west also passes through two villages with 30 mph restrictions at Hockerton and Kirklington. The road through Kirkington has a sharp bend and side-road junction immediately at the bottom of the long hill at the east entrance to the village. There is an S-bend in the middle of the village, immediately followed by a well-used side-road junction with limited vision at the west end. As with Kelham, residents in both these villages would be subject to increased noise and air pollution should the Flash Farm site be sanctioned.

20 of 23 In addition, the road to WInkburn, Maplebeck and Kneesall meets the A617 at a junction west of Hockerton with limited vision.

38 Section 4.9 of the the Strategic Transport Assessment Addendum (February 2016) analyses the current conditions of the A617 and its traffic demands. Para. 4.9.3 states that - Over a 12 hour operating day traffic to and from the site would equate to 7 loads an hour (14 two-way HGV movements) . . . and that - The County Council would want to ensure that traffic generated from this site is kept to an absolute minimum.

39 This paragraph makes no allowance for daily personnel journeys by transport drivers, management staff, operatives to and from the Flash Farm site , journeys to and from the site made by vehicles for maintenance contractors, plant installers etc. This means that the total number of vehicle movements per day to and from the site would be increased between 90 and 120 movements per day, giving a total increase of between 260 and 290 movements per day, or say 23 more movements per hour on the A617 - that is one every 2.6 minutes.

40 The requirements of para. 4.9.3 could be met by removing the Flash Farm site from the list of aggregate sites to be developed.

41 The hazards of the route are substantiated by the data in para. 4.9.6. At the very least this data supports the removal of Flash Farm from the list of aggregate sites to be exploited - certainly its inclusion could in no way be seen as ameliorating these hazards. In addition, any further road safety measures would be unlikely to reduce air pollution or danger to other drivers, their passengers or to pedestrians in both villages.

42 Table 5.3 in the Traffic Impact Assessment section of the Addendum shows that the proportion of HGVs in the total traffic flow on the A617 is 5.4% through Kelham and 8.0% through Kirklington, with current daily totals of HGVs of 855 and 970. Taking into account the revised totals from para. 39 above, this means that the increase in HGVs arising from traffic to and from the Flash Farm site of 85, plus an additional 15 HGVs for plant and maintenance would result in increases of total HGV flow on the A617 of between 10 and 11%. Such increases on noise and air pollution and road safety are too heavy a cost to bear for the questionable benefit of the use of the Flash Farm site.

43 The capacity of the A617 to absorb further traffic increases is brought into question by the data in table 5.4. This shows that, although the capacity of some of the roads in the area to absorb more traffic over the last nine years is evident (shown by the significant increases in AADTs over the period in question), other roads have shown much lower percentage increases, suggesting that they afre nearing or have already rreached tgheirf maximum capacity at times.

For instance, the A46 southwest of Newark showed a steady AADT increase from 25050 to 30450 between 2007 and 2015 - a rise of 27.6%. East of the A617 junction the increase on the A46 was from 26500 to 29500 - or 11.3%.

In contrast, on the A617 west of the Flash Farm site, the change was from 11250 to 12200 - a rise of only 1.08%, while east of Flash Farm the change was from 17300 to 15950 - an actual fall of 9.2%. A likely deduction from these figures is that traffic to the west of Flash Farm is nearing capacity, while traffic to the east of Flash Farm is already at capacity at times, being increasingly constrained, owing to congestion encountered at Kelham Bridge and at the A617/A46 roundabout near Newark.

This is further evidence that Flash Farm should be deleted from the proposed aggregate sites, unless its inclusion is seen as essential. However, a re-examination of the likely demand for aggregate, taking into account the contribution from re-used materials and using a more plausible forecast for total requirements in the future (as was not done in the Minerals Local Plan Consultation document), makes clear that the county’s requirements for aggregate over the next 19 years is very unlikely not to be met, even if Flash Farm is removed from the list of sites and its forecast contribution is not included.

21 of 23 44 Condition DM9b states that ‘The vehicle movements likely to be generated would not cause an unacceptable impact on the environment and/or disturbance to local amenity’. It is clear from the previous paragraphs that the inclusion of Flash Farm would cause ‘a significant impact on the environment and disturbance to local amenity’.

45 One matter of concern is the need to allow essential services to local communities along the A617 to continue to be provided. An example of this is the use of the A617 by vehicles of the East Midlands Ambulance Service. Figures provided by the service show that in 2012 an average of 240 vehicles per month attended an NG address and transferred a patient to King’s Mill Hospital, Mansfield via the A617. In 2013 the figure was 250 v.p.m, in 2014 it was 275 vehicles per month and in 2015 it was 296 vehicles per month. It is clearly essential that the traffic levels on the A617 should not be allowed to grow unnecessarily. This is another reason why Flash Farm should not be included in the list of aggregate sites.

46 Condition DM9b can be met by removing Flash Farm from the list of possible aggregate sites.

This is quite feasible on account of the initial over-generous estimate of future demand for aggregate, including the non-inclusion of the contribution from re-used materials, outlined in Table 1 (para 4.10) of the Minerals Local Plan Consultation and already addressed in this response.

22 of 23 Office use only Person No.

Rep No.

47 The removal of the Flash Farm site from the list of aggregate sources is very desirable from many points of view as outlined above. Its removal is sound owing to the over-generous predictions of future aggregate requirements and the non-inclusion of contributions from re-used materials in these figures.

At this point, the key requirements are for • the figures in table 4.1 to be questioned and recalculated to ensure that the figures quoted in the table are justifiable and realistic, rather than unnecessarily generous estimates which would result in avoidable damage to the environment and people’s wellbeing for years to come; • the contribution from re-used materials towards to total aggregate requirement to be quantified and taken into account in the revised figures for table 4.1

6. Have you raised this issue previously (during earlier stages of consultation)? Yes √ No If Yes, please give details By letter - 31 12 2015

To the chairman of the Planning Committee, Notts County Council County Hall West Bridgford Nottingham

Signature Date 27 March 2016

Name John Gillespie

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From: gerry burgess Sent: 28 February 2016 20:54 To: Development Planning Subject: Proposed plan for gravel extraction at Coddington (Drove Lane)

Follow Up Flag: Follow up Flag Status: Flagged

Sirs,

We are in receipt of notification of proposed gravel extraction in Coddington. We would like to add a strong voice against these plans . There are already severe traffic problems in and around this area and this would only add to those problems significantly.

Yours sincerely Marie and Gerald Burgess

Dovecote Farm

1 7884 29959

From: sweyin khinhtun Sent: 01 March 2016 13:22 To: Development Planning Subject: Nottinghamshire County Council's Minerals Plan

To whom it may concern

I am one of the residents at Kelham and I strongly object the proposed gravel extraction at Flash Farm, Averham.

A617 is already congested and increasing traffic through the village will increase the road traffic accidents. Many children have to walk to and fro (home and the bus stops at near Fox Inn/ infront of Kelham hall) along the small pavements and it is too dangerous for them when many lorries drive especially through the blind curve near old post office. In winter, it is dark, the roads are slippery and not safe for the pavement users.

Our village is one of the most beautiful rural areas and the adverse visual impacts on our lovely surrounding areas should not be permitted. It will also have psychological impacts on the villagers by destroying their quiet and nice community and reducing the admiration and appreciation of their own home and environment.

As a healthcare professional, I have serious concerns regarding noise, vibration and air pollution.

Moreover, Kelham bridge has been already overused by the heavy lorry and has to closed on many occasions. It has serious adverse impact on the villagers' daily life and economy. Addition of further heavy lorry traffic to the already overwhelmed Kelham bridge is totally inconsiderate.

The house prices can also be going down because of this project and once permitted, it would last for 14 years.

We are totally not happy with this plan. Please consider my objections seriously and hope planning permission is not granted.

Swe Dr Swe Khin-Htun Kelham

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From: Jane Holt Sent: 04 March 2016 19:12 To: Development Planning Subject: Proposed Gravel Extraction at Flash Farm, Averham

Follow Up Flag: Follow up Flag Status: Flagged

Please note my objection to this use of Flash Farm. I have been a resident of Rolleston for nearly 31 years and believe that if this gravel extraction plan in granted it will cause the following difficulties ‐ Increased traffic Noise, pollution, vibration, increased risk of accidents due to heavy lorry traffic on country roads Risk of long delays and accidents on Kelham bridge, possible road closures leading to adverse impact residents and businesses in Newark and surrounding villages The spoiling of an attractive rural area

Jane Holt

Sent from my iPad

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From: Rose Kilb Sent: 06 March 2016 12:45 To: Development Planning Subject: Objection to proposed gravel extraction

Follow Up Flag: Follow up Flag Status: Flagged

Dear sir or madam,

I am writing to lodge my objection to the proposed gravel extension at Flash Farm, Averham.

As a local resident, I am concerned at the increase in traffic and noise as the congestion on Kelham Bridge already has a detrimental effect on commuting, as well as being increasingly dangerous when busy.

Having seen the removal of trees from the area, I also agree that any work on this site will greatly impact the aesthetics of the rural area leading to many wishing to relocate.

I hope that this email we suffice in registering my concerns.

Kind Regards,

Rose Hayes

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From: Steve Hambidge Sent: 11 March 2016 09:47 To: Development Planning Subject: Proposed gravel extraction at Coddington

Follow Up Flag: Follow up Flag Status: Flagged

Both my husband & I strongly object to the above. Traffic is the main reason, all traffic islands that will be involved in this, suffer greatly already from congested traffic and during the summer months when people travel to the East coast, long delays are experienced.

This alone should make it common sense that NO APPROVAL will be given

Yours

Mr & Mrs S.A. Hambidge Barnby in the Willows

This email has been sent from a virus-free computer protected by Avast. www.avast.com

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From: Penny Green < > Sent: 24 March 2016 14:50 To: Development Planning Subject: Nottinghamshire County Council's Minerals Plan - Proposed Gravel Extraction at Flash Farm, Averham

I object to the proposed gravel extraction for the following reasons:‐

‐ There are already too many massive lorries passing over Kelham Bridge which was not designed to take the weight of these vehicles. It is a bottleneck now and the bridge could possibly collapse.

‐ Already these lorries constantly mount the pavement. They brake off their wing mirrors and other vehicle parts in their endeavour to pass each other, making it extremely unsafe for pedestrians.

‐ Far too many accidents have occurred already, making closure of the A617 impractical and frustrating for all.

‐ Drainage covers and pot holes on A617 are constantly being repaired every few months because of the existing heavy traffic.

‐ The historic area and listed buildings within the pretty conservation areas of Kelham and adjacent villages are being damaged by the constant vibration, pollution, dust and noise which has a massive impact on village life.

I am not entirely convinced that this pubic consultation will have any major impact on these proposals but I consider that if approval is given for this gravel pit it would make the conservation areas turn into an ugly industrial site.

Regards Penny Green

Sent from my iPad

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From: Every Occasion Events Ltd Sent: 24 March 2016 16:49 To: Development Planning Subject: Nottinghamshire County Councils Minerals Plan- Proposed Gravel Extraction at Flash Farm, Averham.

To whom it may concern

Please take this email as a personal objection to the local proposed gravel extraction at Flash Farm, Averham.

I am a local resident living in the rural area of Averham with my wife and young family. Our house is situated alongside the A617 and facing the open fields of the planned gravel extraction.

I have major noise concerns living so close to the planned site and all the extra traffic travelling along the A617. As the A617 is already a very busy road which I use many times a day through my business and taking my children to and from school.

I have serious concerns over the increased noise, vibration and pollution that the gravel pit and extra vehicles would cause as our village is so close to the planned site and the overall impact it will have on the rural area and all the local wildlife.

The A617, Kelham Bridge and the A1 are frequently overwhelmed with heavy traffic and our local village and town of Newark is brought to a stand still on a regular basis due to accidents and increased traffic which has a serious impact on the local area without adding the additional lorries to the roads from the gravel site. Kelham bridge or the surrounding area will not cope with all the additional traffic. When Kelham Bridge is closed the area comes to a complete standstill as the small village roads cannot cope with the traffic we have now without the additional large gravel lorries.

Also the proposed Gravel Pit is close to the local school in the village which is situated next to the main road and all the extra pollution from the increased traffic is a major concern to me that my daughter and all the children attending will be in constant contact with all the extra pollution the site will cause.

Averham is a beautiful area in which we do not need a Gravel Extraction Site.

Kind Regards

David Wilson

www.every-occasion.com

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From: Kate Turner < Sent: 26 March 2016 12:15 To: Development Planning Subject: Proposed Gravel Extraction at Flash Farm, Averham

Dear Sir/Madam

I am very concerned about Flash Farm being used as a site for sand and gravel extraction. I actually live at Cheveral House which is at Hockerton and is on the main A617. I have lived here for nearly 15 years and have witnessed many accidents right outside my own gate!!! The traffic is terrible with big lorries actually shaking the house. We have had several run off the road and end up in the ditch next to the house and recently we had a massive accident right outside the gate. Neighbours have had lorries take out their hedges and we are always worried about our own safety. The thought of more traffic is just frightening. We have to turn into our gateway and a member of our family has already had someone run into the back of them!!! The road is not coping with the traffic as it is. It needs more maintenance as alongside the edge of the road are big drops and we often have tyre marks where a lorry has run down the edge towards the house before gaining control again. Some have not gained control and have over turned. By increasing more lorries along an already poorly kept surface is unthinkable. Also the pollution is going to increase and I already suffer from Asthma!!

I totally object to this proposed plan as to increase traffic along this already congested road would certainly make the road even more dangerous to everyone and certainly increase the risk to my family and home!!!

Yours faithfully

Kate Turner

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From: Di Collington < Sent: 27 March 2016 09:45 To: Development Planning Subject: Proposed Gravel Extraction at Flash Farm Averham

I am lodging an objection to the proposed site for gravel extraction on the following grounds:

As a resident of Averham it has been virtually impossible to travel into Newark on the A617 at all times during the rush hours and during the summer period, all through the year on Monday, Thursday and Friday due to heavy traffic buildup especially mornings and from mid afternoon. This has become totally unacceptable and businesses must be affected as a result. It is now impacting very much on daily life especially when you have to attend appointments and can't guarantee you get there on time. The A617 is well known for hold ups where motorists are the last to be considered when the bridge is under repair. Chaos was the word I would describe it as the last repair took weeks and traffic was at a standstill. It took me nearly two hours to get into Newark.

We now have a caravan park on Kelham hall which adds further to the congestion as there are at least 200 touring caravans coming in and out of the entrance onto the A617 during the summer and special rallies are held all year round.

Kelham Bridge endures an overwhelming flow of heavy goods traffic, vibration, accidents all adding to the chaos we have to suffer constantly. Not to mention the impact it has on the town which should be an attractive market town where people want to visit but are put off because of the traffic problems. Ie can 't believ that this proposal is even being considered as pollution will increase in a rural area with a school very close to the proposed site, which has just had to accept a Power Station much bigger than originally proposed.

When this proposal was put forward the developers sent out information to residents which implied that it was a "done deal". Also I notice that trees and bushes along the side of the A617 have been chopped down and it looks like the road is already being prepared to be widened near Averham Flash to accommodate the plan. I hope this is not the case and that good judgement will prevail to refuse this plan in the best interests of everyone concerned. It is called "the knock‐on effect". Lots of people, both local and countrywide, who visit this well loved area both for business and pleasure will be affected. They are the "knock‐on effect". For once let common sense prevail.

Mrs Di Collington Averham resident Sent from my iPhone

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From: Sally Briggs-Price > Sent: 29 March 2016 10:39 To: Development Planning Subject: Proposed Gravel Extraction Drove Lane Coddington

Proposed Gravel Extraction Drove Lane Coddington

Objection

As a resident of Coddington I am fully aware that the Trent valley is and will be an area required for mineral extraction. I am not against mineral extraction Per Se, but I am voicing my objection to the access and exits from this proposed development site by heavy lorries & equipment.

Since the dueling of the A46 and the development of the Curry’s warehouse and rerouting the A17 coupled with poor entry & exit to the A1, the immediate access roads struggle to cope now with the volume of traffic, often becoming gridlocked particularly during rush hour and following road traffic incidents.

Despite a weight limit heavy trucks can often be seen driving through Coddington, which also becomes a ''rat run'' for normal traffic during peak hours, this results in dangerous conditions when crossing the old A17 to access the school.

I would suggest that if development goes ahead suitable upgrading of the local roads are undertaken by the quarry operators as part of the planning consent, or suitable ''haul roads'' are built to link the quarry with the A1 and bypass the A46/A17 and local roads.

Kind Regards

Sally Briggs‐Price

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1 From: Sally Briggs-Price Sent: 29 March 2016 10:39 To: Development Planning Subject: Proposed Gravel Extraction Drove Lane Coddington

Proposed Gravel Extraction Drove Lane Coddington

Objection

As a resident of Coddington I am fully aware that the Trent valley is and will be an area required for mineral extraction.

I am not against mineral extraction Per Se, but I am voicing my objection to the access and exits from this proposed development site by heavy lorries & equipment.

Kind regards

Sally Briggs‐Price

2 7910 30063

From: ETE Wastemin (Economy, Transport & Environment)

Sent: 21 April 2016 13:40 To: Development Planning Subject: Response to Nottimghamshire County Council - Submission Minerals Plan 2016

Dear Sir/Madam

Just to confirm that the officer response dated 24 03 2016 should now be regarded as the County and City Councils formal response to the Submission Plan.

Development Plans Team Economy, Transport and Communities | Derbyshire County Council

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