Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports Contents

Statement of Consultation Related to Minerals Technical Consultation Reports (December 2010), Waste and Low Carbon Technical Consultation Reports (May 2011)

Contents

1. INTRODUCTION 5

The Role of the Statement of Consultation 5 Durham County Council Statement of Community 6 Involvement Future consultation on the County Durham Plan 6

2. CONTINUOUS ENGAGEMENT CONSULTATION 9

Who was consulted? 9 How were the public and other stakeholders consulted? 9 How the representations were taken into account 10

A. RESPONSES TO TECHNICAL CONSULTATION REPORT 'TOWARDS A MINERALS DELIVERY STRATEGY FOR 12 COUNTY DURHAM'

Question 1 - Residual Need 12 Question 2 - Aggregate Landbanks 15 Question 3 - Magnesian Limestone 18 Question 4 - Carboniferous Limestone 24 Question 5 - Dolerite 25 Question 6 - Sand and Gravel 26 Question 7 - High Grade Dolomitic Limestone 28 Question 8 - Agricultural Lime 31 Question 9 - Brickmaking Raw Materials 37 Question 10 - Surface Mined Coal and Fireclay 40 Question 11 - Natural Building and Roofing Stone 41 Question 12 - Silca Sand 42 Question 13 - Vein Minerals 43 Question 14 - East Durham Limestone Plateau 44

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports Contents

Question 15 - West Durham Coalfield and Wear Lowlands 59 Question 16 - Tees Lowlands 64 Question 17 - North Pennines 67 Question 18 - Dales Fringe 71

B. RESPONSES TO TECHNICAL CONSULTATION PAPER 75 'ENERGY MINERALS'

Question 1 - Issues and Options for Surface Coal Mining 75 Question 2 and 3 - Should the County Durham Plan contain a policy for surface mined coal extraction and 78 fireclay extraction? How can it be improved? Question 4 - Planning constraints in the exposed coalfield 82 Question 5 - Use of a GIS based constraints map 85 Question 6 - What are your views on the application of a 88 constraints based approach? Question 7 - Conventional Oil and Gas Development 91 Question 8 - Coal Bed Methane 91 Question 9 - Methane from Coal Mines 92 Question 10 - Underground Coal Gasification 93

C. RESPONSES TO TECHNICAL CONSULTATION PAPER 95 'NEW MINERALS AND WASTE SITES IN COUNTY DURHAM'

Question 1 - Revised Criteria for identifying Strategic Sites 95 Question 2 - Strategic Site at Todhills Brickworks 104 Question 3 - Strategic Site at Low Harperley 105 Question 4 - Strategic Waste Allocation at Thrislington 107 Quarry Question 5 - Basal Permian Sand at Thrislington Quarry 115 Question 6 - Thrislington Quarry eastern extension 121

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports Contents

Question 7 - Southern allocation at Thrislington Quarry 123 Question 8 - Strategic site proposal Heights Quarry 126 Question 9 - Proposed surface mine coal sites 135 Question 10 - Waste Handling Facility Langley Park 227 Industrial Estate North Question 11 - Waste Transfer Station Old Brickworks, 228 Bishop Auckland Question 12 - Criteria for Non Strategic Minerals Sites 230 Question 13 - Criteria for non-strategic Waste Sites 234

D. RESPONSES TO TECHNICAL CONSULTATION PAPER 'SAFEGUARDING MINERAL RESOURCES FOR THE 235 FUTURE'.

Question 1 - To distinguish between resource and 235 operator proposals. Question 2 - Should we buffer the resource boundary 240 Question 3 - Coal resources underlying urban areas 247 Question 4 - Other minerals underlying urban areas 250 Question 5 - Draft development managment approach for 254 mineral safeguarding Question 6 - Guidelines for development which would not 261 be viewed as sterilising development within a MSA Question 7 - Potential development management policy 267 for safeguarding mineral related infrastructure

E. RESPONSES TO TECHNICAL CONSULTATION REPORT 272 'TOWARDS A WASTE DELIVERY STRATEGY'

Question 1 - Approach to assessing existing and future 272 capacity

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports Contents

Question 2 - Key Locational Principles 280 Question 3 - Safeguarding Waste Sites 283 Question 4 - North Durham Delivery Area 289 Question 5 - Central Durham Delivery Area 290 Question 6 - East Durham Delivery Area 291 Question 7 - South Durham Delivery Area 292 Question 8 - West Durham Delivery Area 293

F. RESPONSES TO TECHNICAL CONSULTATION REPORT 'TOWARDS A STRATEGY FOR LOW CARBON ENERGY 296 IN COUNTY DURHAM'

Question 1 - An Energy Hierarchy 296 Question 2 - Renewable electricity and heat targets 306 Question 3 - AONB wind energy policy 312 Question 4 - Broad Areas of Least Constraint 318 Question 5 - District heating schemes 324 Question 6 - Local targets for decentralised energy 327 Question 7 - A Carbon Offset Fund 329 Question 8 - North Durham Delivery Area approach 334 Question 9 - East Durham Delivery Area approach 340 Question 10 - Central Durham Delivery Area approach 344 Question 11 - South Durham Delivery Area approach 345 Question 12 - West Durham Delivery Area approach 351

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports Introduction 1

1 Introduction

The Role of the Statement of Consultation

1.1 The purpose of this Statement of Consultation is to show how Durham County Council has engaged with key stakeholders and the local community in the development of the County Durham Plan. The need for a new County Durham Plan arose when the new county-wide Unitary Council was established on 1st April 2009 to replace the existing County Council and all of the seven District Councils in County Durham. The County Durham Plan will set out the priorities for development in the County up to 2030 and when adopted it will include an overall spatial vision along with both the strategic and detailed elements of the planning framework for County Durham. In doing this, it will also act as a key delivery mechanism for the aspirations and priorities of Durham's Sustainable Community Strategy and the Regeneration Statement.

1.2 This Statement of Consultation reports upon six separate consultations which took place as part of a process of continuous engagement which occurred between publication of the Core Strategy Issues and Options Paper in June 2010 and up to and alongside the Core Strategy Policy Directions Consultation Paper in May 2011. These are:

Technical Consultation Paper: Towards a Minerals Delivery Strategy for County Durham (December 2010);

Technical Consultation Paper: Energy Minerals in County Durham (December 2010);

Technical Consultation Paper: New Minerals and Waste Sites in County Durham (December 2010);

Technical Consultation Paper: Safeguarding Mineral Resources for the future - Further consultation on Mineral Safeguarding Areas in County Durham December 2010);

Technical Consultation Paper:Towards a Waste Delivery Strategy for County Durham (May 2011);

Technical Consultation Paper: Towards Towards a Strategy for Low Carbon Energy in County Durham (May 2011)

1.3 This Statement of Consultation will outline the following key information:

Who was consulted on these Technical Consultation Papers;

When consultation and other engagement happened;

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 5 1 Introduction

How were the public and other stakeholders consulted;

The results of the Policy Directions consultation; and

How the representations were taken into account.

1.4 Copies of all of the Statements of Consultation which have been prepared can be downloaded from the Councils website at: http://www.durham.gov.uk/Pages/Service.aspx?ServiceId=8754

Durham County Council Statement of Community Involvement

1.5 The preparation of the Statement of Community Involvement (SCI) is a statutory requirement as part of the County Durham Plan development process. The Council originally published its Statement of Community Involvement in May 2010. However, as a result of the recent changes to the planning system as a result of the Localism Act and the new National Planning Policy Framework, a revised SCI has been prepared to take into account its requirements.

1.6 The Council's revised SCI (July 2012) is an important document in relation to how future consultation events are conducted in order to ensure a proper engagement with the community is continued. The purpose of the SCI is to explain how we will formally engage those who have an interest in matters relating to development in an area and in the preparation of the forthcoming County Durham Plan. It will include details of monitoring requirements to ensure that community engagement will be properly undertaken. The SCI is available to download from the Councils website at: www.durham.gov.uk/cdp

Future consultation on the County Durham Plan

1.7 Since these Technical Consultation Reports were published the principle of 'Localism' has emerged, established in the Localism Act and through the National Planning Policy Framework (NPPF) which was introduced in March 2012. This introduced various new planning initiatives, including Neighbourhood Planning. The Localism Act and the NPPF will have a significant impact on the preparation of the County Durham Plan. Primarily the County Durham Plan will be a Local Plan, comprising one main document, rather than a Local Development Framework.

6 Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports Introduction 1

1.8 The Council's Local Plan converts work undertaken to prepare an overarching Core Strategy and combines that with other work undertaken to now include other matters such as housing, employment and retail allocations, and development management policies within a single planning document. The LDS explains that there is still a need for separate planning document on Minerals and Waste Policies and Allocations. The Minerals and Waste Policies and Allocation document will be progressed following adoption of the Local Plan. The timescale for the preparation of the Minerals and Waste Policies and Allocations document is also explained within the LDS.

1.9 Following consultation on the Local Plan Preferred Options in September 2012, further consultation will be undertaken on the Local Plan during 2013, with adoption of the main Local Plan expected to follow in Summer 2014.

Key Stages in the preparation of the Local Plan

Stage Expected date Regulation

Front loading: Preparation of LDF Technical Papers & Preparation of Issues February 2009 - October 2009 (Regulation 25)

Consultation on the Core Strategy Issues Paper October 2009 - November 2209 (Regulation 25)

Consultation on Core Strategy Issues and Options Paper and County Durham June 2010 - August 2010 (Regulation 25) Settlement Study

Consultation on Durham City Green Belt Site Assessment Part 2; County Durham December 2010 - February 2011 (Regulation 25) Settlement Study (December 2010); Need for a North West Durham Green Belt; Towards a Minerals Delivery Strategy for County Durham; Energy Minerals in County Durham; New Minerals and Waste Sites in County Durham; Safeguarding Mineral Resources for the future - further consultation on Mineral Safeguarding Areas in County Durham

Consultation on Core Strategy Policy Directions Paper; Towards a Strategy for Low May 2011 - July 2011 (Regulation 25) Carbon in County Durham; Towards a Waste Delivery Strategy for County Durham

Consultation on Local Plan Preferred Options; Lambton Estate Supplementary September 2012 - December 2012 Planning Document; Aykley Heads Supplementary Planning Document; Sniperley Supplementary Planning Document; Sherburn Supplementary Planning Document; North of the Arnison Centre and Newton Hall Supplementary Planning Document; Infrastructure Delivery Plan; and Community Infrastructure Levy Rationale and Preliminary Charging Schedule.

Publication July/August 2013 (Regulation 27)

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 7 1 Introduction

Stage Expected date Regulation

Submission of Local Plan November 2013 (Regulation 30)

Pre-examination meeting January 2014

Examination March 2014 (Regulation 34)

Receipt of Inspectors binding report May 2014 (Regulation 35)

Adoption of Local Plan July 2014 (Regulation 36)

1.10 Details of the key stages in the preparation of the Local Plan are set out in the Council's revised Local Development Scheme(i). The Local Development Scheme (LDS) is an essential part of the plan preparation process. It is a Project Plan that represents an agreement with central government outlining the arrangements for producing the new Local Plan for County Durham. It is the starting point for all interested parties to find out about the Council’s emerging planning policies in respect to a particular area or issue. It illustrates the relationship between the individual documents currently proposed and how they fit into the Council’s wider strategies.

1.11 The revised LDS supersedes any previously adopted by the council. It provides a revised outline of policy documents that this unitary authority will produce over the next four years and the timescale for their production. If necessary the LDS will be revised over time to reflect progress in plan preparation and to programme in subsequent policy documents.

i The Council's Local Development Scheme can be viewed on the Council's website at: http://www.durham.gov.uk/Pages/Service.aspx?ServiceId=8755

8 Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports Continuous Engagement Consultation 2

2 Continuous Engagement Consultation

Who was consulted?

2.1 We consulted directly all those who have expressed an interest in the development of the County Durham Plan. However in doing so we also sought to specifically target the minerals, waste and low carbon industry. A database had been previously put together using existing databases from the former County Council and the former seven District Councils. This database was further added to following requests from members of the public, organisations and consultants and now consists of nearly 4,000 individual consultees. The database was used as a basis to engage consultees on these Technical Consultation Papers. It will continue to be used and further updated when necessary as part of the ongoing consultation process. Other means of consultation are referred to in the next section.

2.2 The ‘database of consultees’ comprises of bodies, organisations and individuals that come under the following four categories:

Specific Consultation Bodies (These are specific consultation bodies) and must be consulted in accordance with the Act and Regulations);

Government Departments;

General Consultation Bodies; and,

Other Consultees.

2.3 For a more detailed list showing the types of consultee please refer to County Council's revised Statement of Community Involvement July 2012, Appendix A – Who are the Consultees?’ This document is available to download from the Councils website at: http://www.durham.gov.uk/Pages/Service.aspx?ServiceId=8750.

How were the public and other stakeholders consulted?

2.4 Consultation on the Technical Consultation Reports took place during two periods of time, the four mineral related technical consultation reports were subject to consultation between 3 December 2010 and 11 February 2011; and the low Carbon and waste technical consultation reports were subject to consultation between 23 May 2011 and 11 July 2011. However, representations received after these dates were also accepted.

2.5 Part of the consultation event took the form of consulting those bodies organisations and individuals on the ‘database of consultees’ referred to above. Email notifications were sent to all consultees on our database with an email address and in addition letters were also sent out to those who did not have an email address.

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 9 2 Continuous Engagement Consultation

2.6 Copies of these Technical Consultation Reports were also made available for reference purposes at Durham County Customer Access Points and Libraries.

2.7 Information relating to these Technical Consultation Reports including a copy of the document itself was placed on the Council’s interactive website http://durhamcc-consult.limehouse.co.uk/portal/planning/.

2.8 During the consultation period for the Mineral Technical Consultation reports officers attended a number of consultation events including presentations to Parish and Town Council's. The period of consultation for the Low Carbon and Waste Technical Consultation Reports coincided with the consultation period for the Core Strategy Policy Directions Paper. During the seven week consultation period of the Core Strategy Policy Directions Consultation Paper, officer’s from the Planning Policy Team attended over 90 events including roadshows, stakeholder workshop, County Council Member events, parish council meetings and attending AAP Boards and Forums. These events included 36 permanent and roaming exhibitions across the County during May and June. Details of these events were publicised in the local press and on the DCC website. The exhibitions which were held in each location for at least two weeks and staff were available to answer questions.

2.9 Appendix A to F provides a comprehensive series of tables containing representations made in response to each of the questions which was posed and the Councils responses to these representations and and this forms the main part of this Statement of Consultation.

How the representations were taken into account

2.10 In total 584 representations were recorded as received to these six technical consultation reports. Responses were received from a range of organisations including statutory consultees such as the Environment Agency and Natural England, minerals and waste trade organisations operators and members of the local community. The majority of the representations received from members of the local community related to industry proposed mineral sites. In particular, a number of petitions were sent to the Council totalling 1041 objecting signatures were submitted to the Council stating opposition to new opencast coal mining in and around Pittington, West Rainton and Leamside and Sherburn Villages.

Summary table detailing responses to Technical Consultation Reports

Technical Consultation Report Number of Recorded responses Respondents

Technical Consultation Paper: Towards a Minerals Delivery 96 18 Strategy for County Durham (December 2010)

Technical Consultation Paper:Energy Minerals in County Durham 48 11 (December 2010)

10 Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports Continuous Engagement Consultation 2

Technical Consultation Report Number of Recorded responses Respondents

Technical Consultation Paper:New Minerals and Waste Sites in 224 155. County Durham (December 2010) In addition a number of petitions were submitted containing over 1041 signatures opposing new opencast coal mining in and around Pittington, West Rainton and Leamside and Sherburn Villages.

Technical Consultation Paper:Safeguarding Mineral Resources 58 15 for the future - Further consultation on Mineral Safeguarding Areas in County Durham December 2010)

Technical Consultation Paper:Towards a Waste Delivery Strategy 123 30 for County Durham (May 2011)

Technical Consultation Paper: Towards Towards a Strategy for 35 15 Low Carbon Energy in County Durham (May 2011)

2.11 All representations were taken into account during work to prepared the Local Plan Preferred Options consultation paper.

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 11 A Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham'

A Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham'

Question 1 - Residual Need

Residual Need - Do you have any comments on our revised calculations for residual need?

Respondent Question 1 - Residual Need Do you have any comments on our Council Response revised calculations for residual need? Mr David Atkinson Under separate cover Lafarge has provided recent reserve information The reserve estimates provided will be used to Lafarge Aggregates Ltd for Thrislington which will assist the Council in updating Table 7. calculate residual need.

Para 10.23 of the Local Plan Preferred Options states taking into account the extent of permitted reserves on 31st December, and additional permissions issued since that date, that there are more than sufficient permitted reserves within County Durham aggregate mineral sites to meet future need over the plan period to 2030. Nevertheless , the Council will undertake further work on residual need through the preparation of a Local Aggregate Assessment. The Council's Local Aggregate Assessment will be published in 2013.

Ms G Gibson It is appreciated Durham County Council over the years has had a Comments noted in relation to Durham County CPRE good track record of restoring sites and monitoring resources and Council's track record. their quarrying and we trust the authority will continue its good work. The County is seeking to develop a measured Attached is comment from C.P.R.E. Co Durham Branch. In addition approach to mineral extraction which is based upon we would like to make the following general comment: We have a a robust and credible evidence base. In relation to responsibility to make best use of our precious resources many of future forecasts, the Council will undertake further which are nationally, if not internationally, important so best use can work on residual need through the preparation of a be made of them. This must be done taking into account the Local Aggregate Assessment. The Council's Local residential amenity of those in the areas involved and the effect on Aggregate Assessment will be published in 2013.

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Respondent Question 1 - Residual Need Do you have any comments on our Council Response revised calculations for residual need? the landscape. What is important is there is a measured approach The County Durham Plan will address the and clear policy on the County's resources which is fully transparent environmental impacts of mineral working and and fully consulted. The ability to comment at the various stages is suitable policies will be put into place which protects appreciated. There needs to be a clear evidence-based system for the environment and local amenity, the approach will monitoring and reviewing future demand. With the disappearance of consider cumulative impact which will take into GONE, the future and the reporting mechanism for NERAWP is fragile account spatial and temporal impacts. to say the least. It is not clear how CLG will generate its forecasts of future demand or to what extent this will be based on regional or sub regional intelligence. Over the period of the strategy, technological and economic forces may give recycled 'secondary'' mineral products a greater range of use and more value. Systems for recycling minerals would be much preferred to continued extraction of primary minerals. The strategy could set a priority preference for reprocessing secondary minerals.

There is an indication that spatial buffer zones will be set between sites to minimise cumulative impact. There is also a strong argument for temporal buffer zones i.e. a period of several years between site working in the same area, also to minimise cumulative impact. Cumulative impact concerns should also cover cumulative impact across development types e.g. mineral extraction, landfill site, windfarm, etc.

The Mineral Delivery Areas align well with the Natural England National Character Areas, and should more positively reflect Natural England's revised objectives for these areas as well as the Co Durham Character Area Strategy. Q1 - Do you have any comments on our revised calculations for residual need? No.

Natural England Page 24 Review of existing Mineral Permissions - we have a meeting Regarding page 33 - we agree that through the planned 16th February 2011 to discuss in detail the approach to restoration of sites opportunities should be ROMPs and section 63 reviews under the Habitats Regulations, so considered to deliver geodiversity benefits. will not provide further advice on the proposed approach in this document until after that meeting.

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Respondent Question 1 - Residual Need Do you have any comments on our Council Response revised calculations for residual need? Page 33 Sustainability Appraisal - could also deliver geodiversity opportunities.

Mr Bryan Huntley No comments on the revised calculations for residual need. Noted. The Council will undertake further work on Darlington Borough residual need through the preparation of a Local Council Aggregate Assessment. The Council's Local Aggregate Assessment will be published in 2013. Mrs Margaret Forster Coxhoe Parish Council has no comments to make on the 'Towards Noted. Coxhoe Parish Council a Minerals Delivery Strategy for County Durham' Consultation Document'. Robin Beveridge As you are aware One North East is currently responsible for the Support to overall approach noted. One North East development, delivery and review of the Regional Economic Strategy (RES) on behalf of North East England. The RES sets out how greater and sustainable prosperity will be delivered to all of the people of the North East over the period to 2016. Our comments relating to the documents are set out below: Overall, the mineral related technical consultation reports appear to represent comprehensive coverage of the evidence, key issues and options. They are considered by the Agency to provide a sound platform upon which to develop a robust mineral policy approach through the Core Strategy DPD, the Minerals and Waste Policies and Allocations DPD and the Development Management DPD. One North East is broadly supportive of the reports' content and the Council's suggested way forward. As set out in Minerals Policy Statement 1 and reflected in 'Towards a Mineral Delivery Strategy' minerals are essential to the nation's prosperity and quality of life. A planned approach, as proposed through the Durham LDF, will ensure that the need for minerals and the impacts of extraction and processing are managed in an integrated way.

14 Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham' A

Question 2 - Aggregate Landbanks

Aggregate Landbanks - Do you have any comments on our intended approach?

Respondent Question 2 - Aggregate Landbanks - Do you have Council Response any comments on our intended approach? Ms G Gibson We agree with the Council's intended approach. There Our intended approach is set out in the Preferred Options policy CPRE is merit in a range of landbanks so the best use is made 53 'Meeting the Need for Primary Aggregates'. This approach is of each mineral and so the minerals with specialist uses based upon the requirements of the NPPF which requires a 10 remain in production and are protected from year crushed rock and seven year sand and gravel landbank to inappropriate use. be maintained. Due to uncertainties over whether information on permitted reserves of different types of crushed rock and sand and gravel will continue to be provided by operators and current uncertainty over our ability to continue to supply dolerite we cannot commit to maintaining different types of crushed rock and sand and gravel landbanks. The Council will however continue to seek to maintain a landbank of high grade dolomite. This is currently being met by the existing permissions at Thrislington Quarry. Mr M Charis We support the identification of separate landbanks for Our intended approach is set out in the Preferred Options policy Mineral Planning minerals where they can be so separated. Whilst it 53 'Meeting the Need for Primary Aggregates'. This approach is Association would appear that you have sufficient mineral for the based upon the requirements of the NPPF which requires a 10 crushed rock landbanks, we believe that you should year crushed rock and seven year sand and gravel landbank to be flexible enough to consider not just the extent of the be maintained. Due to uncertainties over whether information landbank but also its distribution between quarries, and on permitted reserves of different types of crushed rock and in so doing that you consider the need to preserve sand and gravel will continue to be provided by operators and production capacity and avoid over dependence on a current uncertainty over our ability to continue to supply dolerite few units or sources of material. we cannot commit to maintaining different types of crushed rock and sand and gravel landbanks. The Council will however continue to seek to maintain a landbank of high grade dolomite. This is currently being met by the existing permissions at Thrislington Quarry.

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 15 A Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham'

Respondent Question 2 - Aggregate Landbanks - Do you have Council Response any comments on our intended approach? Through work to prepare the first annual Local Aggregate Assessment we will consider further our ability to maintain future supplies of aggregate. This will consider the distribution of aggregate between quarries and productive capacity.

While we note the Mineral Planning Association's comment in relation to "avoid over dependence on a few units or sources of material" it would not be appropriate to permit new working in instances where the County's existing mineral sites could meet the scale of working which is required to be achieved over the plan period. Allowing new working in such circumstances would increase the scale of environmental disturbance in the County and undermine the ability of existing sites to be worked in line with their existing planning permissions.

Mr David Atkinson Lafarge support the Council's intended approach to Our intended approach is set out in the Preferred Options policy Lafarge Aggregates Ltd identify and maintain a 15 year landbank for high grade 53 'Meeting the Need for Primary Aggregates'. This approach is dolomite (Magnesian Limestone) for use in the steel based upon the requirements of the NPPF which requires a 10 and chemical industries - note however that the text of year crushed rock and seven year sand and gravel landbank to any policy and supporting text should refer to a be maintained. Due to uncertainties over whether information landbank of at least 15 years. This reflects the position on permitted reserves of different types of crushed rock and that the limestone produced at Thrislington is nationally sand and gravel will continue to be provided by operators and and regionally important. As noted above it is important current uncertainty over our ability to continue to supply dolerite because of its high purity which makes the Magnesian we cannot commit to maintaining different types of crushed rock Limestone produced at the quarry suitable for use in and sand and gravel landbanks. The Council will however the production of burnt dolomite which in turn is used continue to seek to maintain a landbank of high grade dolomite. as a steelmaking slag flux, where the dolomitic lime This is currently being met by the existing permissions at replaces some of the quicklime (CaO) used in slag Thrislington Quarry. It should be noted that in July 2011 the production. In addition to increasing slag fluidity, the Council issued the planning permission to work the Minerals presence of magnesia also helps to protect, and thus Local Plan allocation east of the A1M). This permission will improve the life of, the steel vessel's refractory linings, enable the working of 29 million tonnes of magnesian limestone which are made of magnesia. including an estimated 11.35 million tonnes of high grade dolomite over a 32 year period from commencement. This

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Respondent Question 2 - Aggregate Landbanks - Do you have Council Response any comments on our intended approach? Thrislington Quarry is also important for the supply of permission should enable the County to meet and maintain a 15 basal Permian sands which are mixed with limestone year landbank for high grade dolomitic (magnesian limestone) dust on-site to form a concreting sand. The strategy for all or the majority of the plan period to 2030. recognises that maintaining supplies of sand and gravel is a key issue for the Core Strategy and Thrislington The scale and current importance of Thrislington Quarry as a Quarry can continue to play an important role in source of sand is noted. In this respect given that the existing maintaining the sand and gravel landbank consistent permission for sand extraction expires in January 2015 we with the comment above this should be maintained for understand that Lafarge is intending to prepare and submit a at least 7 years. planning application to enable a continuation of working.

Lafarge has no objection to the Council's intended approach to condition new planning permissions with the requirement to submit annual submission of information detailing the extent of remaining permitted reserves and sales to ensure the satisfactory operation of the landbank policy. Permitted reserve and sales information for Thrislington Quarry are currently submitted to the Council on an annual basis. There is comment in the paper about the extent of sand reserves at Thrislington and as noted above a return has been provided to the Council reflecting the current reserve estimate.

Mr Bryan Huntley Agree with the intended approach. Our intended approach is set out in the Preferred Options policy Darlington Borough 53 'Meeting the Need for Primary Aggregates'. This approach is Council based upon the requirements of the NPPF which requires a 10 year crushed rock and seven year sand and gravel landbank to be maintained. Due to uncertainties over whether information on permitted reserves of different types of crushed rock and sand and gravel will continue to be provided by operators and current uncertainty over our ability to continue to supply dolerite we cannot commit to maintaining different types of crushed rock and sand and gravel landbanks. The Council will however

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 17 A Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham'

Respondent Question 2 - Aggregate Landbanks - Do you have Council Response any comments on our intended approach? continue to seek to maintain a landbank of high grade dolomite. This is currently being met by the existing permissions at Thrislington Quarry. Mr Michael Hodges With regard to the sand and gravel landbank, we Comments noted. Our intended approach is set out in the Sherburn Stone Co Ltd appreciate you have noted the views expressed by Preferred Options policy 53 'Meeting the Need for Primary those respondents supporting Option D 'define Aggregates'. specialist landbanks for building and asphalting sand and concreting sand' in reply to Question 50 of the Core We acknowledge that information has in the past been made Strategy Issues and Options Paper. Accordingly, we available by operators to enable the Council to calculate would simply re-affirm our view that specialist landbanks specialist landbanks for sand and gravel. In this respect it has for sand and gravel should be defined. been demonstrated that Durham's basal permian sand quarries contain both sand which is suitable for concreting purposes and building and asphalting sand. Approximately two thirds of the deposit is believed to be suitable for concreting sand. Similarly, the planning application which members resolved to grant at Low Harperley near Wolsingham will also be able to produce both types of material.

Nevertheless having considered this matter further our view is that given deposits within quarries are combined, it may be difficult to successfully operate a landbank policy for different types of sand and gravel. In addition as quarries are producing both types of material and there is no evidence of a shortage of either material we do not now consider that there is a need to differentiate between concreting sand or building and asphalting sand.

Question 3 - Magnesian Limestone

Magnesian Limestone - Given the extent of permitted reserves of Magnesian Limestone we do not consider that there is any need for further provision during the plan period. Do you agree or disagree?

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Respondent Question 3 - Magnesian Limestone - Given the extent of permitted reserves of Council Response Magnesian Limestone we do not consider that there is any need for further provision during the plan period. Do you agree or disagree? Mr Bryan Agree that there is no need for further permissions for Magnesian Limestone during Our intended approach is set out in the Preferred Huntley the plan period. Options policy 53 'Meeting the Need for Primary Darlington Aggregates'. Please also see paragraphs 10.25 to Borough 10.34 of the Local Plan Preferred Options Report. Council However, through work to prepare the first annual Local Aggregate Assessment we will consider further our ability to maintain future supplies of magnesian limestone aggregate. This will consider the distribution of aggregate between quarries and productive capacity.

Mr M Charis Agreed, subject to consideration of production capacity and flexibility of distribution Our intended approach is set out in the Preferred Mineral within the landbank Options policy 53 'Meeting the Need for Primary Planning Aggregates'. Please also see paragraphs 10.25 to Association 10.34 of the Local Plan Preferred Options Report.

However, through work to prepare the first annual Local Aggregate Assessment we will consider further our ability to maintain future supplies of magnesian limestone aggregate. This will consider the distribution of aggregate between quarries and productive capacity.

Mr David Paragraph 3.21 of the paper quotes a reserve figure for the Eastern Extension at The figure quoted in paragraph 3.21 is incorrect Atkinson 16.35 million tonnes. Is this an estimate of the aggregates component of the potential the figure which should have been used is Lafarge reserve? This may need clarity. Until the permission for the Eastern Extension is approximately 17,350,00 tonnes. Paragraph 8 of Aggregates released, Lafarge's position will be that this area should be allocated as a strategic the committee report which considered the Ltd site. This is consistent with the statement in the paper that we need to ensure that extension to Thrislington Quarry east of the A1(M) the County's Magnesian Limestone sites will be able to continue to supply sufficient stated, "It is proposed to extract approximately mineral over the plan period. Note that updated reserve and sales figures have been 29 million tonnes of Magnesian Limestone over provided so that Table 8 may be updated. Subject to the release of the Eastern 32 years and final restoration would be achieved

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Respondent Question 3 - Magnesian Limestone - Given the extent of permitted reserves of Council Response Magnesian Limestone we do not consider that there is any need for further provision during the plan period. Do you agree or disagree? Extension consent Lafarge would concur with the Council's approach that given the within the 2 years before the site enters aftercare extent of permitted reserves of Magnesian Limestone there is no need for further (5 years statutory aftercare, and an additional 5 provision during the plan period. Nevertheless, Magnesian Limestone permitted years). About 11.35 million tonnes of stone would reserves, such as those at Thrislington Quarry, should be safeguarded beyond the be used for high grade purposes." plan period through the designation of appropriate Mineral Safeguarding Areas and Minerals Consultation Areas. The planning permission to extend Thrislington Quarry east of the A1(M) was issued in July 2011, accordingly the Council now considers that Lafarge have now withdrawn proposals to re-allocate both the eastern and southern Minerals Local Plan allocations as strategic allocations.

Lafarge's support in relation to the council's position that there is now no need for further provision during the plan period is noted.

The Council's approach to mineral safeguarding has been consulted upon in the Technical Consultation Report "Safeguarding Mineral Resources for the future - further consultation on Mineral Safeguarding Areas in County Durham". A separate schedule of responses has been prepared which addresses consultee comments.

Mr R Molloy There are currently five operators reducing magnesian limestone in County Durham Our intended approach is set out in the Preferred W & M i.e. Lafarge of Thrislington Quarry, Tarmac at Coxhoe Quarry, W&M Thompson at Options policy 53 'Meeting the Need for Primary Thompson Bishop Middleham Quarry, Sherburn Stone at Crime Rigg Quarry and Stonegrave Aggregates'. Please also see paragraphs 10.25 to (Quarries) Aggregates at Aycliffe Quarry. All of these have their own designated work forces 10.34 of the Local Plan Preferred Options Report. Ltd and business set ups which make a substantial contribution to the socio-economic wellbeing of Country Durham and, in particular, provide significant levels of local The Council is currently preparing its first annual employment which, by its very nature, can not be moved elsewhere in the Country, Local Aggregate Assessment. Through this key Europe or further afield as has been the case much of the local employment in and piece of work we will review our current approach around the magnesian limestone escarpment area. Furthermore, with five operators to ensure that the intended approach is sound

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Respondent Question 3 - Magnesian Limestone - Given the extent of permitted reserves of Council Response Magnesian Limestone we do not consider that there is any need for further provision during the plan period. Do you agree or disagree? producing magnesian limestone aggregates for the construction industry there is a and delivers the steady and adequate supply of healthy competition in this market with benefits to the local construction industry and crushed rock aggregate that it is required. Should the wider community. Limited remaining reserves in the existing planning permission the Local Aggregate Assessment conclude that areas of three quarries will, without additional planning permissions, result in the a different approach is required this will be cessation of mineral extraction operations at Aycliffe Quarry in 2014, Bishop reflected in the Submission Local Plan. Middleham Quarry in 2015 and Crime Rigg Quarry in 2022. Without the grant of Paragraphs 10.31 to 10.32 of the Local Plan additional planning permissions at one or more of these three quarries, this would Preferred Options addresses the issues of only leave two producers of magnesian limestone i.e. Lafarge at Thrislington Quarry Agricultural Lime. and Tarmac at Coxhoe Quarry as well as Tarmac's ability to recommence production at their currently mothballed quarries at Cornforth, Quarrington Quarry and Hawthorn Quarry. This would result in, at best, a duopoly of magnesian limestone production in County Durham with only Tarmac and Lafarge as producers. The announcement on 18 February 2011 that Lafarge Cement UK, Lafarge Aggregates and Concrete UK and Tarmac Quarry Materials would be combined in a 50:50 joint venture between Lafarge SA and Anglo-American Plc would therefore, together with the Council's currently preferred strategy to grant no more planning permissions for magnesian limestone extraction, result in a monopoly of magnesian limestone production in County Durham. In September of 2010 the Office of Fair Trading (OFT) announced that it was investigating whether the UK aggregates market is functioning properly. The aim of the investigation is to reveal whether there is sufficient competition of producers of aggregates and to evaluate how the current structure of the market affects the intensity and conditions of this competition. Amongst other things, the OFT will focus on how the planning system and competitive forces interact and affect services and value for money provided to customers in determining the supply of aggregates at a local and national level. The magnesian limestone landbank position in County Durham is such that, in simple arithmetical terms, there is sufficient provision to maintain an overall ten year crushed rock landbank at 2030. The Council's current preferred strategy assumes that, as the other quarries referred to above become exhausted, Lafarge at Thrislington Quarry and Tarmac at their various quarries will step up production and meet the shortfall in production resulting from the exhaustion of Aycliffe, Bishop Middleham and Crime Rigg Quarries. The Council do not, however, provide any evidence base as to why it assumes that Lafarge and Tarmac will increase production to meet this shortfall. Discussions with Council

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Respondent Question 3 - Magnesian Limestone - Given the extent of permitted reserves of Council Response Magnesian Limestone we do not consider that there is any need for further provision during the plan period. Do you agree or disagree? Officer's indicate that this assumption is based on conversations with Lafarge and Tarmac to the effect that if the Council was not to grant any extensions to the soon to be exhausted Aycliffe, Bishop Middleham and Crime Rigg Quarries, would Lafarge and Tarmac be prepared to increase production to meet the shortfall? It is understood that Lafarge and Tarmac responded positively to this invitation which is not surprising given that the Council was effectively presenting them with the opportunity to take over the market share of the operators of the three quarries which would become exhausted and therefore effectively assume a dominant market position. While it is not suggested that this was necessarily the intention of the Council, it is submitted that the Council's preferred strategy would produce this very situation. As well as removing local competition in the production of magnesian limestone, the Council's preferred strategy would also result in the loss of employment and economic activity at Aycliffe, Bishop Middleham and Crime Rigg Quarries. Notwithstanding this, it is considered that the Council has not given sufficient regard to the fact that magnesian limestone is not an homogeneous product and that insufficient regard has been given to the need to maintain production of specialist products such as agricultural lime. This is, however, considered further in section 4 of this document with respect to question 8 'Agricultural Lime'. If the Council's preferred strategy prevails and no extension to Bishop Middleham Quarry is permitted (and a similar approach prevails in respect of Aycliffe and Crime Rigg Quarries), this will have the following effects:

- Production of high quality lime from Bishop Middleham Quarry will cease and there is no evidence presented by the Council that this would be replaced by other quarries;

- Thirty three direct jobs and, at least the same number again in in-direct jobs, would be lost due to the cessation of mineral extraction operations at Bishop Middleham Quarry;

-Lafarge, probably together with Tarmac, as the proposed joint venture between these two companies would be gifted by the Council a dominant market position to the detriment of the construction industry and the wider economy.

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Respondent Question 3 - Magnesian Limestone - Given the extent of permitted reserves of Council Response Magnesian Limestone we do not consider that there is any need for further provision during the plan period. Do you agree or disagree? For these reasons, and what is set out above in section 3 of this document, we do not agree with the Council's position set out in question 3 and consider that an alternative approach be adopted which is sensitive to the wider economic needs of the area in terms of the maintenance of local businesses and employment and the supply of magnesian limestone minerals to the various markets at reasonable and competitive prices by the Council not gifting a market dominant position to one or two producers. Furthermore we consider that a more thorough and sensitive approach be taken with regard to the potential environmental effects of extensions to quarries rather than what appears to be a somewhat cursory conclusion by the Council with respect to the cumulative impact of magnesian limestone extraction in the Thrislington/Cornforth/Bishop Middleham area. This matter is explored further in section 5 of this document.

Ms G Gibson Agree. Our intended approach is set out in the Preferred CPRE Options policy 53 'Meeting the Need for Primary Aggregates'. Please also see paragraphs 10.25 to 10.34 of the Local Plan Preferred Options Report.

However, through work to prepare the first annual Local Aggregate Assessment we will consider further our ability to maintain future supplies of magnesian limestone aggregate.

Natural Page 17 Hawthorne Quarry East Durham - please note Natural England provided Comment noted. The future of this quarry will be England a scoping response to this review submission on 4 March 2009. considered by the Council's development management team. Mr Michael We strongly disagree that there is no need for further provision for the extraction of Our intended approach is set out in the Preferred Hodges Magnesian Limestone during the plan period. Consideration of Table 8 on page 16 Options policy 53 'Meeting the Need for Primary Sherburn of the Report shows that during both 2007 and 2008 sales of Magnesian Limestone Aggregates'. Please also see paragraphs 10.25 to Stone Co Ltd were spread between 5/6 quarries operated by 5 separate companies with no single 10.34 of the Local Plan Preferred Options Report. site having significantly greater sales than the others. Further, the three sites

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Respondent Question 3 - Magnesian Limestone - Given the extent of permitted reserves of Council Response Magnesian Limestone we do not consider that there is any need for further provision during the plan period. Do you agree or disagree? scheduled to close during the plan period, namely Aycliffe, Bishop Middleham and The Council is currently preparing its first annual Crime Rigg, combined accounted for over 50% of the total sales of Magnesian Local Aggregate Assessment. Through this key Limestone in 2007 and 2008. Although the landbank for Magnesian Limestone is piece of work we review our current approach to extensive, further consideration of Table 8 highlights the fact that the scheduled ensure that the intended approach is sound and closures of Aycliffe, Bishop Middleham and Crime Rigg Quarries will result in the delivers the steady and adequate supply of landbank being almost entirely bound up in four very large sites, three of which are crushed rock aggregate that it is required. Should operated by one Company, Tarmac. It is worth noting that at the beginning of 2011 the Local Aggregate Assessment conclude that it was reported in the Media that Anglo American, Tarmac's parent company, are a different approach is required this will be committed to selling Tarmac and are to approach potential buyers one of which reflected in the Submission Local Plan. includes Lafarge, the operator of Thrislington Quarry, the other remaining site in Co Durham with extensive reserves of Magnesian Limestone. The second bullet point on Page 17 of the Report states that Tarmac have supplied evidence which indicates that its current Magnesian Limestone sites are operating significantly below capacity due to market competition. The implication of this and the subsequent analysis in the Report of potential production from the various sites over the plan period is that as sites close and market competition diminishes, Tarmac will increase production at their sites thereby increasing their market share. By the latter stages of the plan period it is clear that Tarmac, or rather whoever it is that owns Tarmac, will become by far the dominant supplier. Mineral Planning Statement 1 (MPS1) states that a large existing landbank bound up in very few sites should not be allowed to stifle competition. It is clear that, in the absence of further permissions being granted during the plan period, there is a real possibility that this will occur. Such a situation would clearly be detrimental to local industry and we therefore firmly believe that further provision for Magnesian Limestone extraction should be made in the Plan.

Question 4 - Carboniferous Limestone

Carboniferous Limestone - Given the extent of permitted reserves of Carboniferous Limestone we consider that there is a need for further provision during the plan period. Do you agree or disagree?

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Respondent Question 4 - Carboniferous Limestone - Given the extent of Council Response permitted reserves of Carboniferous Limestone we consider that there is a need for further provision during the plan period. Do you agree or disagree? Mr Bryan Huntley Agree that, on the basis of maintaining current sales, there is a need for Support noted. The Preferred Options policy 53 Darlington Borough further provision during the plan period. 'Meeting the Need for Primary Aggregates' sets out Council the chosen approach to Carboniferous Limestone. Mr M Charis Agreed, subject to consideration of production capacity and flexibility of Support noted. The Preferred Options policy 53 Mineral Planning distribution within the landbank 'Meeting the Need for Primary Aggregates' sets out Association the chosen approach to Carboniferous Limestone. Ms G Gibson It is appreciated the Council has based the need for further reserves on Support noted. The spatial approach to future CPRE the best information available, but we would wish any allocation to be working of this mineral we are seeking to develop located to have the minimum impact on the landscape. aims to minimise impacts upon the landscape. The Preferred Options policy 53 'Meeting the Need for Primary Aggregates' sets out the chosen approach to Carboniferous Limestone. Mr Michael Hodges We agree that there is a need for further provision for the extraction of Support noted. The Preferred Options policy 53 Sherburn Stone Co Ltd Carboniferous Limestone during the plan period. 'Meeting the Need for Primary Aggregates' sets out the chosen approach to Carboniferous Limestone.

Question 5 - Dolerite

Dolerite - Given the extent of permitted reserves of Dolerite we do not consider that there is any need for further provision during the plan period. Do you agree or disagree?

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Respondent Question 5 - Dolerite - Given the extent of permitted reserves Council Response of Dolerite we do not consider that there is any need for further provision during the plan period. Do you agree or disagree? Mr Bryan Huntley Agree that, given the extent of permitted reserves of Dolerite, there Support noted. The Preferred Options policy 53 Darlington Borough is no need for further provision during the plan period. 'Meeting the Need for Primary Aggregates' sets out Council the chosen approach to Dolerite. See also paragraphs 10.40 to 10.43 of the Local Plan Preferred Options Report. Mr M Charis Agreed, subject to consideration of production capacity and Support noted. The Preferred Options policy 53 Mineral Planning flexibility of distribution within the landbank 'Meeting the Need for Primary Aggregates' sets out Association the chosen approach to Dolerite. See also paragraphs 10.40 to 10.43 of the Local Plan Preferred Options Report. Ms G Gibson Agree. Support noted. The Preferred Options policy 53 CPRE 'Meeting the Need for Primary Aggregates' sets out the chosen approach to Dolerite. See also paragraphs 10.40 to 10.43 of the Local Plan Preferred Options Report. Natural England Page 20 Force Garth Quarry - Landbank for Dolerite - please note Support noted. The Preferred Options policy 53 Natural England have commented (31 March 2010 and subsequent 'Meeting the Need for Primary Aggregates' sets out meeting with interested parties) on the scope of the Review of the chosen approach to Dolerite. See also paragraphs Minerals Permission at this site which is due for submission in 10.40 to 10.43 of the Local Plan Preferred Options July 2011 as well as a regulation 63 Habitats Regulations Review. Report.

Question 6 - Sand and Gravel

Sand and Gravel - Do you have any comments on this analysis?

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Respondent Question 6 - Sand and Gravel - Do you have any Council response comments on this analysis? Mr Bryan Huntley From the analysis, it is not clear which figure is being used The figure which was used to identify future requirements Darlington Borough Council to calculate the landbank. Is it the forecast need figure of in 'Towards a Minerals Delivery Strategy for County 312,500 tonnes per annum or is it 300,000 tonnes per Durham' emanates from the North East Regional annum (assuming 100,000 tonnes per annum from the 3 Aggregates Working Party (NERAWP) recommended quarries at Thrislington, Crime Rigg and Old Quarrington)? sub-regional apportionment of the North East component Footnote i) below Table 10 does not appear to be included of the Government's National and Regional Aggregate within the Table. Supply Guidelines 2005-2020 (published June 2009). The NERAWPs final report on the sub-regional apportionment of the National and Regional Aggregate Supply Guidelines 2005-2020 recommended a sand and gravel apportionment for County Durham of 5 million tonnes over the 16 year period 2005 to 2020. This figure was confirmed by CLG in September 2011. The 312,500 tonne figure is derived by dividing 5 million tonnes by 16 years. This figure was used used to calculate the annual target for production, which must be achieved in order to ensure County Durham meets its contribution to regional production requirements. This figure has also been used to calculate residual need over the entire life of the County Durham Plan to 2030. Paragraph 3.33 sought merely to illustrate the potential role of existing sites whilst outlining the requirements of planning permissions at each site. As a matter of fact the planning permission at some sites may enable a higher annual extraction.

Please note Policy 53 of the Local Plan Preferred Options 'Meeting the Need for Primary Aggregates' sets out the chosen approach to sand and gravel. See also paragraphs 10.44 to 10.47 of the Local Plan Preferred Options Report. Please also note that further work will be undertaken on sand and gravel through work to prepare the Council's first Local Aggregate Assessment. Production of a Local Aggregate Assessment is necessary in order to meet the requirements of the National Planning Policy Framework.

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Respondent Question 6 - Sand and Gravel - Do you have any Council response comments on this analysis? Mr David Atkinson Note that Lafarge has updated the basal Permian sand Please note Policy 53 of the Local Plan Preferred Options Lafarge Aggregates Ltd reserve position at Thrislington which has reduced the 'Meeting the Need for Primary Aggregates' sets out the reserve estimate at the end of 2009. This therefore reduces chosen approach to sand and gravel. See also paragraphs the overall extent of permitted reserves and landbank in 10.44 to 10.47 of the Local Plan Preferred Options Report. Table 10 and the statement in the first bullet of paragraph Please also note that further work will be undertaken on 3.33 requires updating. Lafarge is seeking to secure a sand and gravel through work to prepare the Council's strategic allocation for the sand resource at Thrislington as first Local Aggregate Assessment. Production of a Local this can continue to make a significant contribution to sand Aggregate Assessment is necessary in order to meet the and gravel requirements with minimal impacts on people or requirements of the National Planning Policy Framework. the environment. A plan showing the extent of the reserve has been provided to the Council. The analysis of potential additional supplies from resources that have yet to gain planning permission needs to be treated with some caution and there is an opportunity through this Core Strategy and associated DPDs to review the potential supply position to ensure that the most sustainable resources are allocated notwithstanding any current planning application activity. Mrs G Gibson No Noted. CPRE

Question 7 - High Grade Dolomitic Limestone

High Grade Dolomite - Once planning permission is issued to work the extension to Thrislington Quarry east of the A1(M) more than sufficient high grade dolomitic (Magnesian Limestone) will be permitted to meet the long term needs. Do you agree or disagree?

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Respondent Question 7 - High Grade Dolomite - Once planning Council Response permission is issued to work the extension to Thrislington Quarry east of the A1(M) more than sufficient high grade dolomitic (Magnesian Limestone) will be permitted to meet the long term needs. Do you agree or disagree? Mr Bryan Huntley Agree that, once planning permission is issued to work the Agreement noted. The Preferred Options policy 53 Darlington Borough Council extension to Thrislington Quarry east of the A1(M) more than 'Meeting the Need for Primary Aggregates' sets out the sufficient high grade dolomitic (Magnesian Limestone) will be chosen approach to magnesian limestone. No new or permitted to meet the long term needs. extended magnesian limestone workings will be permitted for either aggregate or agricultural lime production during the Plan period. Policy 54 'High Grade Dolomite' also sets out that it is expected that over the Plan period to 2030 supplies of high grade dolomite will be met from existing permitted reserves at Thrislington Quarry and its extension east of the A1(M) and further working will only be permitted where need can be demonstrated. Mr M Charis Agreed Agreement noted. The Preferred Options policy 53 Mineral Planning Association 'Meeting the Need for Primary Aggregates' sets out the chosen approach to magnesian limestone. No new or extended magnesian limestone workings will be permitted for either aggregate or agricultural lime production during the Plan period. Policy 54 'High Grade Dolomite' also sets out that it is expected that over the Plan period to 2030 supplies of high grade dolomite will be met from existing permitted reserves at Thrislington Quarry and its extension east of the A1(M) and further working will only be permitted where need can be demonstrated. Mr David Atkinson Lafarge agree with the Councils approach that once planning Noted. Given the issue of this planning permission, the Lafarge Aggregates Ltd permission has been issued for the Eastern Extension to Council now considers that it is no longer necessary Thrislington Quarry, sufficient high grade dolomite will be for the council to consider the proposed re-allocation permitted to meet the long term needs of the County. Until of the Minerals Local Plan allocations at Thrislington such time that the permission is released, Lafarge will pursue Quarry east and south of the A1(M). a strategic allocation in the Eastern Extension area.

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dolomite will be met from existing permitted reserves at Thrislington Quarry and its extension east of the A1(M) and further working will only be permitted where need can be demonstrated.

The Preferred Options policy 58 seeks to safeguard mineral resources via the designation of mineral safeguarding areas.

Gillian Gibson Agree. Agreement noted. The Preferred Options policy 53 CPRE 'Meeting the Need for Primary Aggregates' sets out the chosen approach to magnesian limestone. No new or extended magnesian limestone workings will be permitted for either aggregate or agricultural lime production during the Plan period. Policy 54 'High Grade Dolomite' also sets out that it is expected that over the Plan period to 2030 supplies of high grade dolomite will be met from existing permitted reserves at Thrislington Quarry and its extension east of the A1(M) and further working will only be permitted where need can be demonstrated.

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Question 8 - Agricultural Lime

Agricultural Lime - We do not believe that there is any need to make provision for the extraction of agricultural lime. Do you agree or disagree?

Respondent Question 8 - Agricultural Lime - We do not believe that Council Response there is any need to make provision for the extraction of agricultural lime. Do you agree or disagree? Mr Bryan Huntley Agree that that there is no need to make provision for the Support noted. Our intended approach is set out in the Darlington Borough extraction of agricultural lime. Preferred Options policy 53 'Meeting the Need for Primary Council Aggregates'. Please also see paragraphs 10.25 to 10.34 of the Local Plan Preferred Options Report. Paragraphs 10.31 to 10.32 of the Local Plan Preferred Options addresses the issues of Agricultural Lime. Mr M Charis Agreed. Support noted. Our intended approach is set out in the Mineral Planning Preferred Options policy 53 'Meeting the Need for Primary Association Aggregates'. Please also see paragraphs 10.25 to 10.34 of the Local Plan Preferred Options Report. Paragraphs 10.31 to 10.32 of the Local Plan Preferred Options addresses the issues of Agricultural Lime. Mr David Atkinson Lafarge agree with the Council that there is no need to make Support noted. Our intended approach is set out in the Lafarge Aggregates Ltd specific additional provision for the extraction of agricultural Preferred Options policy 53 'Meeting the Need for Primary lime in the County Durham Plan. As well as having the Aggregates'. Please also see paragraphs 10.25 to 10.34 of capability to produce agricultural lime from the quarry the Local Plan Preferred Options Report. Paragraphs 10.31 Steetley Dolomite produce a product know as phastlime as to 10.32 of the Local Plan Preferred Options addresses the a beneficial by-product from its process. Information has issues of Agricultural Lime. been provided to the Council under separate cover.

Mr R Molloy The Council's position on agricultural lime is primarily based Our intended approach is set out in the Preferred Options W & M Thompson upon their contention that agricultural lime is produced as a policy 53 'Meeting the Need for Primary Aggregates'. Please (Quarries) Ltd by-product of magnesian limestone working. No evidence also see paragraphs 10.25 to 10.34 of the Local Plan

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Respondent Question 8 - Agricultural Lime - We do not believe that Council Response there is any need to make provision for the extraction of agricultural lime. Do you agree or disagree? is presented to support this contention despite evidence to Preferred Options Report. Paragraphs 10.31 to 10.32 of the the contrary having previously put forward by ourselves to Local Plan Preferred Options addresses the issues of the Council in March 2009 in the submission for a proposed Agricultural Lime. extension for Bishop Middleham Quarry in response to the call for new minerals and waste sites. The production of agricultural lime at Bishop Middleham Quarry is from specific horizons in the magnesian limestone sequence which are too soft for aggregates production. Mineral from this soft upper horizon at Bishop Middleham Quarry can readily be crushed down to us low as 2mm particle size which is ideally suited for spreading on agricultural land and has high solubility and therefore is particularly effective in neutralising acidic soils. Similar horizons are known to exist at Marsden Quarry in Tyne and Wear which also produces a high quality agricultural lime for the UK and export markets. While it is true that agricultural lime can be produced as a by-product of aggregates production and kiln waste from dolomite production, these produce a harder and larger particle size agricultural lime product which, it is submitted, is of lower quality than the material produced from the softer magnesian limestone horizons at Bishop Middleham and Marsden Quarries being generally less effective in neutralising acidic soils. Paragraph 4.6 of the Council's document states that Lafarge Aggregates could increase their production of agricultural lime from Thrislington Quarry and that, similarly, Tarmac have advised that their quarries could potentially produce agricultural lime. No evidence is presented to substantiate this, however, it is understood from conversations with Council Officers that this information was elicited in meetings between the Council and these operators where presumably the question was put that if production was to cease at Bishop Middleham Quarry (due to the Council not granting planning permission for an extension)

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Respondent Question 8 - Agricultural Lime - We do not believe that Council Response there is any need to make provision for the extraction of agricultural lime. Do you agree or disagree? could Lafarge and Tarmac to fill the market gap created. It is not surprising that both Lafarge and Tarmac apparently answered in the affirmative given that they were effectively being given the opportunity to take over another company's agricultural lime business. Agricultural lime production information provided on page 26 of the Council's document indicates that the Tarmac Quarries currently produce no agricultural lime and that the two largest producers are Lafarge at Thrislington Quarry with 56% of the market in 2008 (234,500 tonnes) and Thompsons at Bishop Middleham Quarry with 37% (155,000 tonnes). In Lafarge's planning application for the eastern extension to Thrislington Quarry it is stated that approximately 100,000 tonnes per annum of the total projected 1.2 million tonnes per annum total production would comprise material for agricultural lime and concrete batching. While Thompsons do not have any access to Lafarge's production figures for agricultural lime they have expressed surprise that the production is apparently so high based upon what is said in Lafarge's planning application and anecdotal evidence within the industry as to the extent of agricultural lime sales from quarries within County Durham. A recent event in the North East agricultural lime market illustrates the capability of producers to meet unexpected demands for high quality agricultural lime. Due to a temporary operational situation at Marsden Quarry, the Marsden operator was unable to provide sufficient high quality lime to meet its existing export contracts. Lafarge, Tarmac and Thompsons were approached to provide the high quality lime required but only Thompsons at Bishop Middleham Quarry were able to provide the quantity and quality of lime required. Bearing in mind all that is said above, we do not agree with the Council's position set out in question 8 i.e. that there is no need to make provision for

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Respondent Question 8 - Agricultural Lime - We do not believe that Council Response there is any need to make provision for the extraction of agricultural lime. Do you agree or disagree? the extraction of agricultural lime. It is submitted that good quality agricultural lime is a specialist product and that it is apparent that this can only be produced from certain quarries. The Council current strategy in not permitting any further extensions to magnesian limestone quarries would, as described above in section 3, also create an over dominant market position for Lafarge and Tarmac (or the proposed Lafarge/Tarmac joint venture) notwithstanding the limited capability of these operators producing high quality material. Mrs G Gibson Agree. Support noted. Our intended approach is set out in the CPRE Preferred Options policy 53 'Meeting the Need for Primary Aggregates'. Please also see paragraphs 10.25 to 10.34 of the Local Plan Preferred Options Report. Paragraphs 10.31 to 10.32 of the Local Plan Preferred Options addresses the issues of Agricultural Lime. Mr Michael Hodges We strongly disagree that there is no need to make any Our intended approach is set out in the Preferred Options Sherburn Stone Co Ltd provision for the extraction of agricultural lime during the policy 53 'Meeting the Need for Primary Aggregates'. Please plan period. We believe the Council has approached the also see paragraphs 10.25 to 10.34 of the Local Plan issue of agricultural lime incorrectly. Agricultural lime is an Preferred Options Report. Paragraphs 10.31 to 10.32 of the industrial mineral and therefore, unlike aggregates, there is Local Plan Preferred Options addresses the issues of no requirement to consider and/or assess need for the Agricultural Lime. mineral. Consequently the questions of landbank, production and consumption are not relevant. The only matter which requires being addressed is whether manufacture and export from a particular location can be undertaken without unacceptable impact to the environment. The Council's position, if accepted, will restrict the manufacture and export of an important industrial product. Agricultural lime is a generic term covering a wide variety of specifications the production of which is a complex industrial process. The UK specifications for agricultural lime and ground agricultural

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Respondent Question 8 - Agricultural Lime - We do not believe that Council Response there is any need to make provision for the extraction of agricultural lime. Do you agree or disagree? lime vary due in their grading or fineness, chemical composition and neutralising value but generally tend to be less onerous than mainland Europe with UK customers being more amenable to taking lower grade products. In mainland Europe, the main export market, there are many different specifications again dependant on fineness, chemical composition and neutralising value. However there are no ISO type standardised specifications for Europe there being for example Danish specifications, German specifications and Benelux specifications. The German specification for ground agricultural lime is similar to but finer than UK ground agricultural lime while the Danish specification is finer still and the Benelux specification even finer. On page 26 of the Report, it is stated that it is assumed that the need for agricultural lime can be met as a by-product of the extraction of Magnesian Limestone for crushed rock and high grade dolomite. It is then stated that Lafarge have advised the Council that production of agricultural lime at Thrislington Quarry could be increased whilst Tarmac have advised that their quarries could potentially produce agricultural lime. However, agricultural lime is an industrial mineral manufactured using specific processes to achieve detailed specifications and not all deposits of Magnesian Limestone are suitable for manufacturing a product to meet the various specifications. For example, the deposit at Crime Rigg Quarry is not suitable for producing Danish specification ground agricultural lime but is suitable for making a product for the market in Scotland. The deposit at Witch Hill Quarry is different and is perfectly suited to the production of Danish specification ground agricultural lime. It cannot therefore be assumed that the production of agricultural lime as a by-product of the extraction of Magnesian Limestone for crushed rock aggregate and high grade dolomite at

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Respondent Question 8 - Agricultural Lime - We do not believe that Council Response there is any need to make provision for the extraction of agricultural lime. Do you agree or disagree? Thrislington Quarry and by Tarmac at their quarries will be suitable for export to mainland Europe. Nevertheless, all of the authority's considerations regarding the need for agricultural lime have no relevance to the planning process for the aforementioned reasons. The market volumes for agricultural lime consumption in Denmark and Germany are relatively stable from one year to the next. What varies are the sources of supply with Durham competing with Estonia, Rugen Island, the Harz Mountains quarries and domestic Danish Production. For some years Estonian lime was very competitive but costs have risen and it appears that Estonia has declined as a force in the market. This is a dynamic market and there are great opportunities for manufacturers of agricultural lime in Co Durham to export a highly refined industrial mineral into this market. Clearly this would be advantageous for employment in and the economy of Co Durham and the North East region as well as being good for the balance of payments. It should not be the function of the County Durham Plan to restrict this economically beneficial activity. For the Council to prevent manufacturing and exports without a sound environmental reason would be a travesty of the planning system. We therefore firmly believe that further provision should be made in the Plan for the extraction of Magnesium Limestone for the manufacture of agricultural lime to maintain diversity of supply and ensure the opportunity to produce and export a valuable commodity is not lost. Sherburn Stone Co Ltd is currently working a bed at Hart Quarry near Hartlepool which is suitable for producing Danish specification agricultural lime and this product is exported via Hartlepool docks. However, this is unlikely to remain the case indefinitely and therefore in order to maintain the opportunity to export agricultural lime to mainland Europe, the Company would seek to manufacture it at Witch

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Respondent Question 8 - Agricultural Lime - We do not believe that Council Response there is any need to make provision for the extraction of agricultural lime. Do you agree or disagree? Hill Quarry with the product being shipped via Seaham Docks. We believe that the Council has not fully considered the agricultural lime question. If necessary, it would be our intention to put forward detailed evidence at the public examination regarding the manufacture and export of different specifications of agricultural lime. If need be we will also need to put forward detailed evidence regarding industrial minerals and their proper consideration within the mineral planning system.

Question 9 - Brickmaking Raw Materials

Brick making raw materials - Do you have any comments on our approach to brickmaking raw materials?

Respondent Question 9 - Brick making raw materials - Do you have Council Response any comments on our approach to brickmaking raw materials? Mr Bryan Huntley Agree with the approach to brick making raw materials. Support noted. Preferred Options policy 55 sets out the Darlington Borough Council chosen approach to brick making raw materials. Mr David Brewer CoalPro fully supports the approach set out. Support noted. Preferred Options policy 55 sets out the Confederation of UK Coal chosen approach to brick making raw materials. Producers (COALPRO) Mr C Ball UK Coal supports the intended approach towards brick making Support noted. Preferred Options policy 55 sets out the UK Coal Mining Ltd raw materials, and would highlight that surface coal mining chosen approach to brick making raw materials. scheme often represent the only economically viable means of extracting fire clay. Ms G Gibson We agree with the Council's approach. Support noted. Preferred Options policy 55 sets out the CPRE chosen approach to brick making raw materials.

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Respondent Question 9 - Brick making raw materials - Do you have Council Response any comments on our approach to brickmaking raw materials? Mr N Spence Birtley factory is located in Gateshead and its existing quarry The Council is committed to working with Ibstock Brick Ibstock Brick Ltd Property is in County Durham and there is no allocated replacement. and Gateshead Borough Council to ensure that sufficient Manager North As the geology of the existing deposits of similar materials feedstock is available to meet the long term needs of follow the Team Valley, suitable future reserves should be this brickworks. Should Ibstock Bricks seek to deepen identified and considered for protection. At current usage we the quarry they will need to discuss the scope and estimate that there is less than 20 years remaining of practicality of this proposal with the Council's consented reserve. We believe in the first instance that an development management team. We note Ibstock Bricks opportunity exists to deepen the quarry to provide a source representations in respect of Lamesley and consider of further resource that the potential for this area to provide a resource for the Union Brickworks should be considered further, so We have also made representations to Gateshead in respect as to provide an alternative source of brickclay should of Lamesley, which is the nearest allocated resource to Birtley. a proposal to deepen the existing clay pit not be First impressions are that whilst the type of clay may be appropriate. suitable for future use albeit the resource is unproven and outside our control. With reference to the comment in relation to Mineral Consultation Areas, please see response to question 2 The proposal to identify Mineral Consultation Areas is fully of the Technical Consultation Paper 'Safeguarding supported as a means of ensuring that minerals are not Mineral Resources for the future". Rather than defining sterilised by development. Buffer zones are also appropriate Mineral Safeguarding Areas and Mineral Consultation and thus should be made use of to ensure that the mineral Areas which we note we are now advised we can not resource is not potentially constrained by nearby built do, we will develop an approach on the basis of Option development where there would be a need to protect amenity. A of question 2. This would require the Council to An example of good practice by the BGS in its document 'A designate Mineral Safeguarding Areas based upon the guide to mineral safeguarding in England', October 2007' page mineral resource and require that the development 23 of the BGS guide stating buffer zones to be 'stand-off limits management policy ensures that non minerals to protect nearby residents and on the other hand protect the development within the vicinity of the MSA, existing (mineral) resource from sterilisation by nearby development' mineral sites, any strategic and any non strategic site This BGS guide is commonly accorded significant weight in should consider whether development would sterilise decision making terms. In this instance applying the necessary future mineral extraction. (Brick clay) 50m buffer zone With reference to the comment in relation to fireclay, we recognise that fireclay is a scarce resource which should not wasted or sterilised. We will seek the full recovery

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Respondent Question 9 - Brick making raw materials - Do you have Council Response any comments on our approach to brickmaking raw materials? We acknowledge that fireclay has been sourced from open of fireclay when surface mined coal is worked provided cast coal sites in Northumberland and we actively seek to it is of the correct technical and aesthetic properties for source materials as close to our brickworks as possible. On brick manufacture If the fireclay is not able to be used account of the high technical specification required for brick immediately we will also require its stockpiling or on manufacture, only a small proportion of opencast sites, site storage for future use. produce fireclay suitable for brick manufacture. Government planning guidance on coal mining emphasises the importance Preferred Options policy 55 sets out the chosen of fireclay and urges the full examination of every opportunity approach to brick making raw materials. to produce it from any proposed site. These principles should be reflected in the development plan and effectively applied when applications for permissions are considered. The DTLR report Brick Clay: Issues for Planning also recommends that planning authorities and industry seek, through policies and decisions, to address the supply of fireclay. Open cast coal schemes should be encouraged to incorporate in working schemes provisions for stockpiling or on-site storage to guarantee full exploitation and avoidance of sterilisation. The heavy clay and opencast industries need to work better together to ensure a full assessment of the suitability and marketability of fireclays available from any site before submission of an application for planning permission. We would welcome the assistance of the MPA to ensure that the brick industry is able to take advantage of any opportunities and not just be used by operators to justify open cast coal schemes. Such an approach will avoid sterilisation of a scarce resource, encourage a close match between supply and demand on a local or regional basis, and be compatible with the principles of sustainable development.

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Question 10 - Surface Mined Coal and Fireclay

Surface Mined Coal and Fireclay - Do you have any comments in relation this particular aspect of surface mined coal. (Please note surface mined coal is addressed in detail in our Energy Minerals consultation paper). Do you agree or disagree with our analysis?

Respondent Question 10 - Surface Mined Coal and Fireclay - Do you have Council Response any comments in relation this particular aspect of surface mined coal. (Please note surface mined coal is addressed in detail in our Energy Minerals consultation paper). Do you agree or disagree with our analysis? Mr David Brewer Confederation of UK Coal Producers agrees with the analysis. Support noted. Preferred Options policy 56 sets out Confederation of UK Coal the chosen approach to surface mined coal and Producers (COALPRO) fireclay. Miss Rachael Bust Support. The Coal Authority supports the general approach to not Support noted. Preferred Options policy 56 sets out Coal Authority setting any targets for surface mined coal as this is in line with the chosen approach to surface mined coal and national planning policy in MPG3. fireclay. Mr C Ball UK Coal note and accept the reference at Para 4.10 to the guidance Support noted. Preferred Options policy 56 sets out UK Coal Mining Ltd in MPG3 'that it is not for the planning system to seek to set limits the chosen approach to surface mined coal and on or targets for any particular source or level of energy supply, and fireclay. that it is rather for individual operators to determine the appropriate level of output in the light of market conditions.' Ms G Gibson Where surface coal is mined fireclay with the technical properties This is the Council's approach. Preferred Options CPRE for brick making should also be extracted so the maximum use is policy 56 sets out the chosen approach to surface made of all resources. mined coal and fireclay. Mr T Bolton The Parish Council agrees with the County Council;s analysis in Support noted. Preferred Options policy 56 sets out Eldon Parish Council relation to surface mined coal and fireclay ((Question 10) and also the chosen approach to surface mined coal and supports the suggested approach in relation to the Minerals Delivery fireclay. Strategy for the West Durham Coalfield and Wear Lowlands Minerals Delivery Area.

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Question 11 - Natural Building and Roofing Stone

Natural Building and Roofing Stone - Do you have any comments in relation to natural building and roofing stone? Do you agree with our analysis?

Respondent Question 11 - Natural Building and Roofing Stone - Council Response Do you have any comments in relation to natural building and roofing stone? Do you agree with our analysis? Mr Bryan Huntley From the information provided, it is difficult to comment While there are no regional or sub-regional targets for natural Darlington Borough Council on the Council's conclusion that "further small scale building and roofing stone production, the Council sought to permissions will be required in order to ensure continuity attempt to quantify the need for new working through of supply of building and roofing stone to meet local and undertaking research into the pattern of working, scale of regional needs" when there is no quantification of those production and extent of remaining permitted reserves in needs and little information on how many suppliers there existing sites. Unfortunately, very limited information was are and where they are located. Could the continuity of provided by operators on the extent of sales and remaining supply be maintained by increasing output at existing permitted reserves and only one operator Windy Hill Quarry quarries, for instance. Or, would one large scale Co identified a need for a new allocation in the County Durham operation be more sustainable than several small scale Plan, (planning permission now granted). We were however operations? able to identify the limited extent of recent sales using ONS information. In addition we also identified that four of County Durham's eight building stone quarries were due to cease extraction during the plan period in accordance with their existing planning permissions, (please refer to paragraph 4.13 of the consultation report).

We have sought to adopt a permissive approach which allows continuity of supply subject to environmental safeguards in accordance with paragraph 144 of the NPPF. This is set out in policy 57 of Preferred Options. We anticipate continued working being maintained by a small number of small scale quarries, this has been the pattern of previous working, output at many sites has been low (no more than 1000 to 2000 tonnes per annum), with sporadic working based upon periods of

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Respondent Question 11 - Natural Building and Roofing Stone - Council Response Do you have any comments in relation to natural building and roofing stone? Do you agree with our analysis? demand. We believe that this pattern of working is best suited to ensure a continued supply of stone with different technical and aesthetic properties.

Mr M Charis Agreed Support noted. We have sought to adopt a permissive Mineral Planning approach which allows continuity of supply subject to Association environmental safeguards in accordance with paragraph 144 of the NPPF. This is set out in policy 57 of Preferred Options. Mrs G Gibson Provision should be made for building and roofing stone This will be a key part of the approach of the County Durham CPRE as the use of suitable local materials is important to Plan. We have sought to adopt a permissive approach which permit repair and construction of buildings in sympathy allows continuity of supply subject to environmental with the landscape. Permissions should be carefully safeguards in accordance with paragraph 144 of the NPPF. controlled and it is noted this matter is addressed This is set out in policy 57 of Preferred Options. elsewhere in the minerals policy documents

Question 12 - Silca Sand

Silica Sand - Do you have any comments in relation to silica sand? Do you agree with our analysis?

Respondent Question 12 - Silica Sand - Do you have any Council Response comments in relation to silica sand? Do you agree with our analysis? Mr M Charis In order to comply with MPG15 you need to Silica Sand production at Weatherhill Quarry has now Mineral Planning Association demonstrate that there is a minimum 15 year landbank ceased. Production has ceased following many years of at each production site for silica sand and refer to this low level and intermittent working. Accordingly, the Council in the DPD will not seek to identify a landbank for silica sand. However,

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Respondent Question 12 - Silica Sand - Do you have any Council Response comments in relation to silica sand? Do you agree with our analysis? it is intended that the extent of the silica sand resource will be safeguarded. Mrs G Gibson Yes, If sufficient reserves exist further reserves will not Silica Sand production at Weatherhill Quarry has now CPRE need to be permitted. However, there should be ceased. Production has ceased following many years of provision to protect sites for the future. low level and intermittent working. Accordingly, the Council will not seek to identify a landbank for silica sand. However, it is intended that the extent of the silica sand resource will be safeguarded.

Question 13 - Vein Minerals

Vein Minerals - Do you have any comments in relation to vein minerals? Do you agree with our analysis?

Respondent Question 13 - Vein Minerals - Do you have any Council Response comments in relation to vein minerals? Do you agree with our analysis? Ms G Gibson The lack of current commercial interest does not The technical consultation report "Safeguarding Mineral CPRE forecast what could happen in the future. There is talk Resources for the future - further consultation on Mineral of worldwide fluorspar reserves becoming depleted Safeguarding Areas in County Durham" addresses this issue so the currently uneconomic veins in Co Durham may and proposes that fluorspar is safeguarded. Please note given become economically workable so should be the location of fluorpsar resources in Upper Weardale and its protected. tributary valley, the Rookhope Burn Valley, within the North Pennines AONB we believe it very unlikely that fluorspar resources will be under threat from sterilisation.

The Local Plan Preferred Options Report seeks to safeguard fluorspar veins.

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Question 14 - East Durham Limestone Plateau

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

Mr Bryan Huntley Agree with the approach for the East Durham Limestone The Local Plan Preferred Options seeks to simplify the Darlington Borough Council Plateau Minerals Delivery Area approach to future mineral provision and tackles the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period. Mr Lee Weatherall As with ATH Resources response to the Issues and Options The Local Plan Preferred Options seeks to simplify the ATH Resources paper on this issue (question 51) they welcome the principle approach to future mineral provision and tackles the need of the Minerals Delivery Areas identified. ATH Resources for mineral extraction for specific minerals rather than via acknowledge the statements provided that these are not Mineral Delivery Areas. The Preferred Options sets out intended to identify 'no go' areas for minerals extraction but the chosen approach to providing for minerals throughout rather to advise what minerals extraction is most likely to the plan period. occur in each area and provide information on the key constraints that will be relevant. However in order to help Policy 56 of the Local Plan Preferred Options addresses clarify this approach ATH Resources would consider a surface mined coal and fireclay. In relation to MPG3, the statement which confirms that the proposed extraction of any exceptions tests and allocations for new surface coal minerals resources which are located within the boundaries mining, paragraph 10.123 is clear that for surface mined of a delivery area, but not identified as being of principal coal sites, environmental acceptability will be the key test. importance in that area, will not be disadvantaged by those For allocations the Council will not consider whether there resources not being named. For example the West Durham may be any national, local or community benefits which

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Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

Coalfield and Wear Lowlands Delivery Area is the only one could outweigh adverse impacts. In this respect the which mentions surface coal as a principal resource, but the Council will only consider the exceptions tests in extent of the surface coal resources does extend into all four determining planning applications. of the other delivery areas. It is also felt that the policy would benefit from a reference to the exception tests provided in paragraph 8 of MPG3, although it is acknowledged that it may not be possible to map this issue with the subsequent allocations in the Policies and Allocations DPD. S Wickerson Thank you for giving us the opportunity to provide comments The Local Plan Preferred Options seeks to simplify the Environment Agency on the above document. Having gone through the report, approach to future mineral provision and tackles the need overall we support the way you have identified delivery areas for mineral extraction for specific minerals rather than via and the method with which you have done so. Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout Our main concern is the status of the Magnesian Limestone the plan period. principal aquifer which may have implications for proposals in the East Durham Limestone Plateau Delivery Area in The Council recognises the role of the Agency in relating particular. The Magnesian Limestone principal aquifer is an to protection of water resources including groundwater important source of groundwater, supplying multiple potable (both qualitative and quantitative aspects) and the supplies in the area. As such, we strive to ensure protection importance of the major aquifer in East Durham. of the aquifer, preventing deterioration in its quality and derogation of its resource i.e. reduction in available/potential The current position of the Wear Magnesian Limestone quantity. The Wear Magnesian Limestone groundwater body groundwater body is noted and the continued Agency (GWB) has been classified as being at 'POOR Status' with modelling. respect to the water balance test under the Water Framework Directive (WFD). This means that there may not be enough Through the consideration of allocations we can only water entering the Magnesian limestone aquifer to support undertake a level of assessment which is appropriate for the current licensed abstractions. As a result we are currently a planning document. Should the Council seek to allocate reviewing the water balance of the aquifer to determine the any site for further site for mineral working on the aquifer sustainability of current abstractions and to predicted the policy criteria will specifically require a hydro-geological potential impact of consenting additional supplies. From work risk assessment (HRA) to be submitted with the planning

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Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

completed to date, it has been identified that there may not application. The assessment will require detail regarding be sufficient recharge to the aquifer (which predominantly both groundwater (dewatering) and surface water occurs on western areas of the aquifer where drift cover is management operations during all stages of the thin or absent) to support the existing licensed abstractions development, from pre-operational to full restoration. indefinitely. If this modelled assessment is confirmed it is unlikely that we would consent additional abstractions in Environment Agency support for a cumulative impact some areas of the aquifer where the assessed impact on policy noted. In addition it should be noted that the Council water resources is deemed unacceptable. expects to prepare a development management policy which seeks to require consideration of water resources Without site specific hydrological risk assessments, we cannot (surface water and ground water quantity and quality). give you a firm view on how likely it is that some proposed works could not be carried out without impacting the aquifer. Therefore the information we have at present is not sufficient for us to raise any questions of soundness at this point, however this potential constraint to further extensions (both with regards to size and duration) in this area should be considered in this process. Allowing the operation of additional quarries/waste sites or extensions to existing ones has the potential to reduce the amount of recharge to the aquifer; making the situation worse rather than improving it. Consequently, the LPA and site operators should consider the cumulative impact of extensions to existing quarries, particularly for sites proposed along the Magnesian Limestone escarpment; the main recharge zone for the aquifer. This could potentially impact the sites at Thrislington, Cornforth, Coxhoe (Raisby) and Bishop Middleham.

Section 5.9, page 35 of the report states that a 'cumulative impact policy would seek to ensure that decisions taken minimise cumulative impacts and ensure that impacts do not

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Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

exceed that would be acceptable if produced from a single site.' We agree with the need to include this policy within any subsequent minerals and waste policy document. Once at the application stage, an assessment of the cumulative impact to water resources from any of the proposed mineral and waste sites should be submitted by the site operator as part of any hydrogeological risk assessment (HRA) submitted with the planning application. These assessments should include detail regarding both groundwater (dewatering) and surface water management operations during all stages of the development, from pre-operational to full restoration. The amount of work required will be on par with what was necessary to support the most recent Thrislington application. We have several maps identifying the most sensitive areas of the aquifer if you would find this of use.

Miss C Kinnear We do not wish to comment on the provision of minerals Support for restoration strategies noted. This will certainly RSPB within this Minerals Development Area, however should such apply to new sites. In terms of existing mineral sites, the extraction proceed, we would support the restoration Council is required to consider updating existing strategies detailed. We agree with the expectation for permissions with modern working and restoration restoration to deliver objectives and priorities of supporting conditions and agree schemes of working on a regular strategies, however suggest that this should apply to future basis, (every 15 years). As part of this process the Council mineral sites in addition to existing ones. We feel the wording will consider whether improved restoration schemes can 'where applicable' is not required since this applicability be delivered. should already be considered by planners. The wording 'where applicable' was meant to highlight that not all strategies may be applicable in any particular case

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Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

Mr M Charis Subject to our comments (made separately) on MCAs, we Policy 58 of the Local Plan Preferred Options set out our Mineral Planning support the intended approach. approach to Mineral Safeguarding Areas. The mineral Association resources to be safeguarded are identified in Appendix Q. Mr David Atkinson The proposed spatial delivery strategy and the outline of the The Local Plan Preferred Options seeks to simplify the Lafarge Aggregates Ltd content of the strategy looks acceptable in principle - clearly approach to future mineral provision and tackles the need Lafarge's interest would relate to the East Durham Limestone for mineral extraction for specific minerals rather than via Plateau Minerals Delivery Area. The points raised by the Mineral Delivery Areas. The Preferred Options sets out MPA in their response are valid however in that recognising the chosen approach to providing for minerals throughout issues such as strategic transport corridors and the the plan period. importance of the area's to the overall supply picture would be appropriate. With regard to the East Durham Limestone Policy 54 of the Local Plan Preferred Options recognises Plateau Minerals Delivery Area we welcome the the importance of Thrislington Quarry and seeks to protect acknowledged importance of Thrislington Quarry in supplying high grade dolomite resources for long term use. Policy high grade dolomite to the steel and chemical industries both 58 of the Local Plan Preferred Options set out our during the plan period (Eastern extension) and in the long approach to Mineral Safeguarding Areas. The mineral term by safeguarding future resources through designating resources to be safeguarded are identified in Appendix a Minerals Safeguarding Area for Magnesian Limestone and Q. to protect the high grade dolomite reserve from encroachment by non-minerals development via Mineral Consultation Areas. Please note Policy 53 of the Local Plan Preferred Options Note however that our comments are subject to the issue of 'Meeting the Need for Primary Aggregates' sets out the planning permission for the Eastern extension of Thrislington chosen approach to sand and gravel. See also paragraphs Quarry. In terms of the Basal Permian Sands, Lafarge would 10.44 to 10.47 of the Local Plan Preferred Options Report support the allocation of the Permian Sands as a strategic which states, "Lafarge Aggregates has proposed two new resource within the Core Strategy. Further detailed comments areas of sand extraction within Thrislington Quarry as regarding this specific issue are made in response to the new allocations. Similarly, a proposal has been made for consultation paper 'New Minerals and Waste Sites in County the reallocation of the existing Minerals Local Plan Area Durham'. However, we endorse the findings of your of Search at Hummerbeck, near West Auckland. However, given the extent of permitted reserves we do not consider

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Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

sustainability appraisal that a balance of supply would be that there is a need for any new allocations for sand and appropriate and that sand extraction should be focused on gravel working." Please also note that further work will be existing sites. undertaken on sand and gravel through work to prepare the Council's first Local Aggregate Assessment. Production of a Local Aggregate Assessment is necessary in order to meet the requirements of the National Planning Policy Framework.

Mr R Molloy The Council's strategy for mineral extraction in the East The Local Plan Preferred Options seeks to simplify the W & M Thompson Durham Limestone Plateau Minerals Delivery Area is primarily approach to future mineral provision and tackles the need (Quarries) Ltd derived from its position as set out in relation to questions 3 for mineral extraction for specific minerals rather than via and 8 described above i.e. that no further planning Mineral Delivery Areas. The Preferred Options sets out permissions for magnesian limestone production should be the chosen approach to providing for minerals throughout granted and that as agricultural lime production is a the plan period. by-product of magnesian limestone extraction, no further revision needs to be made for this. Our position in respect Our intended approach is set out in the Preferred Options of questions 3 and 8 is set out above in sections 3 and 4 of policy 53 'Meeting the Need for Primary Aggregates'. this document and accordingly we do not agree with the Please also see paragraphs 10.25 to 10.34 of the Local Council's approach on the minerals delivery strategy for the Plan Preferred Options Report. Paragraphs 10.31 to 10.32 East Durham limestone plateau minerals delivery area. As of the Local Plan Preferred Options addresses the issues the Council's strategy is solely based upon the landbank and of Agricultural Lime. agricultural lime assumptions / approaches currently adopted by the Council, there is no consideration of the environmental The Council is currently preparing its first annual Local acceptability of potential extensions to ensure the continuation Aggregate Assessment. Through this key piece of work of quarrying operations at quarries such as Bishop we review our current approach to ensure that the intended Middleham. While we consider that there is a compelling approach is sound and delivers the steady and adequate case for an extension and therefore the continuation of supply of crushed rock aggregate that it is required. quarrying operations at Bishop Middleham for socio-economic Should the Local Aggregate Assessment conclude that a and agricultural lime need, reasons as well as avoidance of different approach is required this will be reflected in the the planning system creating a monopoly in magnesian Submission Local Plan.

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Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

limestone production, we also consider that such an extension The Local Plan Preferred Options report is clear that non would be environmentally acceptable and not give rise to any strategic sites will be considered through the preparation cumulative impact issues. The environmental acceptability of the Minerals and Waste Policies and Allocations of mineral extraction operations cannot be determined Document. Although it should be noted that this daughter through the development plan process but will require a document will need to be prepared so that it conforms planning application and detailed environmental impact with the overall policy approach of the main Local Plan assessment, however, we have made a preliminary appraisal document. of the potential environmental effects and methods of mitigation associated with an extension to Bishop Middleham Quarry and these are briefly set out below. Potential Environmental Effects and Methods of Mitigation associated with an extension to Bishop Middleham Quarry Landscape and Visual Effects Quarrying operations in the extension area would potentially be visible from the south and the immediate area to the south west, east of the motorway. However, these potential views of quarrying operations would be effectively screened by the creation of the screening landforms around the perimeter of the proposed quarry extension. These would be formed from soil and drift material stripped from the proposed mineral extraction area. The proposed extension would be no more visible than the existing quarrying operations at Bishop Middleham Quarry. In the longer term, restoration of the site will bring about beneficial effects on the landscape as the site would be restored to a combination of agricultural land and natural habitat with additional tree and hedgerow planting compared with the existing rather bland landform characteristic of modern arable farming landscapes. Ecological Effects Ecological effects would be limited to the loss of some sections of hedgerow and hedgerow trees within the extension area. The arable land

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Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

within the extension area is of relatively low ecological value and quarrying operations would therefore have a low ecological impact. The screening landforms would provide a variety of new habitats which would improve the ecological value of the area both during quarrying operations and in the longer term. The restoration of the site would also bring about ecological improvements compared with the current ecological value of the site. Archaeology and Cultural Heritage There are no recorded archaeological features present within the proposed extension area. However, it is possible that unrecorded archaeological features may be present within the site. It would therefore be necessary to undertake a more detailed evaluation of the site, including trenching, in order to assess the archaeological importance of the site. The presence of unrecorded features of archaeological importance within the site would be unlikely to restrict its future use for mineral extraction as any features of importance which might be discovered would be the subject of a detailed programme of recording prior to mineral extraction taking place. Soils and Agriculture The agricultural land capability of the site is likely to be in the range Grade 2-3B, this being limited by soil depth and possibly draughtiness. The temporary loss of agricultural land would not give rise to any serious adverse effect on farm viability and, in overall terms, the impacts of agriculture are not considered to be significant. Good soil handling techniques will mitigate the potential effects on soil resources. Noise The ambient noise levels in and around the extension area will be relatively high due to the proximity of the A1 motorway and existing quarry operations. Movement of quarrying

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 51 A Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham'

Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

operations into the extension area are anticipated to result in a minor decrease in noise levels at the nearest residential properties at Highland House and Highland Farm as the working area would move further away from these. The effect of noise from the existing quarry on Bishop Middleham is well within permitted guidelines and, as the extension area would be no nearer to Bishop Middleham than the existing quarry workings, then there would be no significant change compared with the current situation. Vibration Limited small-scale blasting currently takes place in the quarry to loosen the harder lower layers of limestone before these are removed by excavator. The blasting is carefully controlled and vibration levels are monitored at nearby properties for each blast. The nearest sensitive receptors are at Highland House and Highland Farm but as quarrying operations move away from these into the extension area, the potential effects on these properties from blasting will inevitably decrease. As quarrying operations in the extension area would not approach any nearer to Bishop Middleham village than the existing quarry operations, there would be no additional impacts from blasting. Air Quality A comprehensive dust management scheme is in place at the existing quarry and this is effective in ensuring that there are no significant adverse dust impacts on properties or habitats within the vicinity of the quarry. The current dust management control regime would be extended to the proposed extension area and as this is further away from Highland House and Highland Farm, and no nearer to Bishop Middleham than the current quarry, there would be much less potential for significant adverse dust effects on dwellings. Water There are no surface

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Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

water features within the extension area or adjacent areas. As with the existing quarry, working in the extension would, however, require the management of surface water to prevent the release of silt and sediment to local watercourses. A detailed hydrogeological assessment would be required to determine the depth of extraction in the extension area in order that there should be no adverse impact upon groundwater. Thompsons have demonstrated in their working of the Bishop Middleham Quarry that the quarry can be worked in an environmentally acceptable manner and all of the indications are that this would continue to be the case in the proposed extension area. Although a detailed proposal for the extension would need to be the subject of a careful and extensive environmental impact assessment process, it is already apparent that the site could be worked without any significant additional environmental impact, indeed, some of the potential impacts would be reduced compared with the current situation as quarry working moves further away from existing dwellings. It is also noteworthy that planning policy, both at national and regional level, favours the working of extensions to existing quarries rather than opening up new quarries where this can be achieved in an environmentally acceptable manner. To conclude in respect of question 14. We do not agree with the Council's strategy for mineral extraction in the East Durham Limestone Plateau Minerals Delivery Area for the following reasons:

(1) The strategy would have the affect of the Council gifting total market domination of magnesian limestone production in County Durham to the Lafarge/Tarmac joint venture

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 53 A Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham'

Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

company (or, indeed, if this joint venture does not materialise there would still be an over dominant market position for Lafarge and Tarmac). This would be detrimental to both the construction and agricultural lime industries and the wider economy.

(2) The preferred strategy would inevitably lead to substantial loss of employment in the quarries and associated businesses which would be denied any future beyond the exhaustion of currently permitted reserves.

(3) Production of high quality lime from Bishop Middleham Quarry would cease and there is no evidence presented by the Council that this would be replaced by other quarries. Furthermore, the Council present no evidence that an extension to Bishop Middleham Quarry which would ensure the continued operation of the quarry business, would give rise to any significant unacceptable impacts. Our own preliminary environmental appraisal of the extension indicates that there would be no significant unacceptable impacts and this may well also be the case with respect to extensions to other quarries on the magnesian limestone escarpment. This being the case, and bearing in mind all that is set above, we clearly fundamentally disagree with the Council's current strategy for the East Durham Limestone Plateau Minerals Delivery Area.

54 Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham' A

Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

Ms G Gibson The Strategy seems well thought out, though we would wish The Local Plan Preferred Options seeks to simplify the CPRE to see any workings minimise their impact on the landscape approach to future mineral provision and tackles the need and residential amenity. In addition it is noted there is for mineral extraction for specific minerals rather than via provision for restoration of worked sites which is very Mineral Delivery Areas. The Preferred Options sets out important. the chosen approach to providing for minerals throughout the plan period. Natural England Page 34 Other strategies that need to be considered include The Local Plan Preferred Options seeks to simplify the the North Pennines AONB Management Plan, the North approach to future mineral provision and tackles the need Pennines AONB Geodiversity Action Plan, the Durham for mineral extraction for specific minerals rather than via Geodiversity Audit, Limestone Landscapes Management Mineral Delivery Areas. The Preferred Options sets out Plan and the Durham Heritage Coast Management Plan. the chosen approach to providing for minerals throughout Also need to consider the Durham Green Infrastructure the plan period. In particular Policy 53 of the Local Plan Strategy once it is published and the Derwent Valley and Preferred Options 'Meeting the Need for Primary Pennine Fringe IBDA project. Page 35 Option B/Paragraph Aggregates' sets out the chosen approach to future 5.10“ We do not agree that Option B may be the most aggregate working. preferable when considered on an individual site basis. Whilst recognising this option appears to make economic sense, In relation to proposals for future working and also there is also a need to consider carefully the environmental extensions, the Local Plan Preferred Options includes a and cumulative impacts of extending existing quarries suite of policies which will be used once the plan is particularly those in the vicinity of European and national adopted to determined proposals for the winning of nature conservation designations. In some instances working of minerals. In particular Policy 42 addresses provision of new sites may be preferable to site extensions internationally designated sites. which may have significant adverse effects on European and national nature conservation sites. New sites may have fewer A policy will be prepared and included within the Minerals constraints associated with them, and may provide more and Waste Policies and Allocations document which will opportunities for enhancement of biodiversity and/or address the restoration, after use and after care of mineral geodiversity. Page 41 Paragraph 5.21 Any proposals at sites. Restoration policies will seek to reflect and deliver Thrislington to deepen and/or extend the site for basal objectives and requirements of relevant supporting Permian sands needs to take into account any potential strategies including amongst others the County Durham impacts on the conservation objectives of the Thrislington Biodiversity Action Plan and the County Durham

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 55 A Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham'

Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

Special Area of Conservation, Thrislington Plantation SSSI Landscape Strategy. Where applicable other strategies and Thrislington NNR, through both the SA and HRA process will also influence the approach that will be required for (not just the HRA process). Page 47 All restoration strategies the restoration of mineral sites. - other strategies that need to be considered where relevant include the North Pennines AONB Management Plan, the North Pennines AONB Geodiversity Action Plan, the Durham Geodiversity Audit, Limestone Landscapes Management Plan, National Character Area profiles and the Durham Heritage Coast Management Plan. Also need to consider the Durham Green Infrastructure Strategy once published and the Derwent Valley and Pennine Fringe Integrated Biodiversity Delivery Area project. It is important to retain significant brownfield biodiversity and not see this is lost through inappropriate restoration. Where appropriate to do so, with extensions to existing sites there may also be opportunities to improve old restoration schemes for biodiversity/geodiversity. Mr Michael Hodges For the reasons set out in response to Question 4 and more The Local Plan Preferred Options seeks to simplify the Sherburn Stone Co Ltd importantly question 8, we believe the approach should be approach to future mineral provision and tackles the need to make provision for further Magnesian Limestone extraction for mineral extraction for specific minerals rather than via in the East Durham Limestone Plateau Minerals Delivery Mineral Delivery Areas. The Preferred Options sets out Area. This will ensure that the opportunity to produce and the chosen approach to providing for minerals throughout export a valuable commodity in the form of agricultural lime the plan period. is not lost and also, in accordance with the requirements of MPS1, help to ensure the landbank for Magnesian Limestone Our intended approach is set out in the Preferred Options aggregates does not become bound up in very few sites, policy 53 'Meeting the Need for Primary Aggregates'. operated by just two companies, which may otherwise stifle Please also see paragraphs 10.25 to 10.34 of the Local competition. In this context we firmly believe the proposal for Plan Preferred Options Report. Paragraphs 10.31 to 10.32 an extension to Witch Hill Quarry should be considered for of the Local Plan Preferred Options addresses the issues allocation in the Plan. This would generate 5,000,000 tonnes of Agricultural Lime. In addition the Council is aware that

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Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

of Magnesian Limestone of which approximately half would Sherburn Stone currently have planning permission and be suitable for the production of agricultural lime for export have declared reserves of agricultural lime at both Witch to mainland Europe and half for the production of aggregates. Hill and Running Waters Quarry's. Both of these sites have The proposal would also have the benefit of being in accord not been worked for a number of years and still contain with the recommended spatial approach identified on page reserves suitable for aggregate extraction and agricultural 35 of the Report i.e. it would represent an extension to an lime. Furthermore the Council notes that planning existing site as per Option B of Question 52 of the Issues permission was granted in 2011 for an extension to and Options Paper and given its location, it would meet the Sherburn Stone's Hart Quarry in Hartlepool which provided aims and objectives of Option D in that it would not comprise further reserves for both magnesian limestone aggregate further working in the vicinity of Thrislington, Cornforth and and agricultural lime. In overall terms the Council Bishop Middleham Quarries. It is not anticipated that the estimates that Sherburn Stone's sites (Witch Hill, Running proposed extension to Witch Hill Quarry would have any Waters and Crime Rigg Quarries and Hart Quarry in significant environmental impacts for the following reasons: Hartlepool) currently provide unworked available reserves of approximately 3.5 million tonnes of agricultural lime The landform is such that, like the existing quarry, the and between 8 and 9 million tonnes of magnesian extension would not give rise to significant visual and limestone aggregate. The Council considers that Sherburn landscape impacts. Stones should be able to meet its needs to supply existing markets from these sites. There would be no adverse impact from quarry traffic as the site entrance is located on the A181 giving direct access to We note that comments in relation to competition and how the strategic road network and good road links to Seaham this would result in a potential duopoly and the docks. announcement of the potential joint venture between Anglo American and Lafarge Aggregates. In this respect it is our The water table is at depth below the quarry floor and understanding for the merger to go ahead Anglo American therefore there would be no hydrogelogical impact. must divest control of Coxhoe Quarry, should the joint venture go ahead, ownership of this quarry would be In terms of noise and air quality, no significant issues have transferred to another operator. Potentially after 2015, if arisen during previous working in the quarry and therefore it the joint venture were allowed to proceed this would mean is not anticipated that the proposed extension would result that permitted reserves would remain in quarries owned in any subsequent adverse impacts as the site would by Sherburn Stone (Crime Rigg, Witch Hill and Running

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 57 A Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham'

Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

continued to be worked in accordance with the guidance set Waters), the joint venture (Old Quarrington, Cornforth out in Annexes 1 and 2: Dust and Noise of Minerals Policy West, Cornforth East and Thirslington Quarry) and a new Statement 2. operator (Coxhoe Quarry). These eight quarries would constitute only part of the crushed rock landbank for No nuisance or damage has arisen from blasting operations County Durham. As stated in response to question 2 the at during previous operations at quarry. As current blasting Council does not intend to identify a separate crushed practices would be maintained, this would ensure that rock landbanks. In addition the Local Plan Preferred vibrations are kept to the same level and within the limits set Options considered the issue of competition. Paragraph out in the current planning permissions. Regular monitoring 10.50 states, "The National Planning Policy Framework would be undertaken to ensure compliance with the stated requires that mineral planning authorities should ensure limits. that a large landbank bound up in very few sites does not stifle competition. However, we are of the view that County The area within which the extension would be located is Durham is no different to many other parts of the Country comprised of mono culture agricultural fields and is therefore where following many years of merger and acquisition the thought to be of little ecological interest. No adverse impacts County's aggregate sites are now in more limited on the ecological importance of the area are therefore ownership than in the past. Currently there are 15 crushed predicted. rock sites (including 3 which produce sand) operated by nine different companies and 5 sand and gravel sites There are no known archaeological features which would be (including the 3 which also produced crushed rock) directly affected by an extension. operated by four companies. Although we do accept that within the crushed rock landbank there are some mineral The restoration of the quarry would take into account the commodities only worked by a small number of operators objectives and strategies of the County Durham Landscape and in some sites there are extensive permitted reserves, Strategy and Durham Biodiversity Plan and in particular would there is no evidence that the concentration of permitted include provision for the creation of Magnesian Limestone reserves is stifling competition and distorting the price of Grassland. Since Sherburn Stone Co Ltd submitted the aggregates in the North East Region." proposal for an extension to Witch Hill Quarry, the Company has acquired the freehold ownership of Running Waters The Council is currently preparing its first annual Local Quarry. Accordingly, if planning permission were granted for Aggregate Assessment. Through this key piece of work the proposed extension to Witch Hill Quarry, Sherburn Stone we review our current approach to ensure that the intended

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Respondent Question 14 - East Durham Limestone Plateau Council Response

We would welcome your views on our Minerals Delivery Strategy for the East Durham Limestone Plateau Minerals Delivery Area?

Co Ltd is in a position to and would be willing to relinquish approach is sound and delivers the steady and adequate the existing planning permission for Magnesian Limestone supply of crushed rock aggregate that it is required in the extraction at Running Waters Quarry and undertake future. Should the Local Aggregate Assessment conclude restoration thereof at the earliest opportunity. The current that a different approach is required this will be reflected planning permission allows for mineral extraction to be in the Submission Local Plan. undertaken at the quarry until February 2042 and therefore such a proposal would bring about significant benefits to the The Local Plan Preferred Options report is clear that East Durham Limestone Plateau by facilitating the early proposals to extend mineral sites such as Witch Hill are restoration of a visible site on the edge of the escarpment. non strategic in nature and will be considered through the The restoration would be subject to detailed discussion with preparation of the Minerals and Waste Policies and Durham County Council and would again take into account Allocations Document. Although it should be noted that the objectives and priorities of the County Durham Landscape this daughter document will need to be prepared so that Strategy and Durham Biodiversity Plan. We note and agree it conforms with the overall policy approach of the main with the Council's comments regarding a possible lateral Local Plan document. extension to Crime Rigg Quarry north of the B1283 in connection with the extraction of Basal Permian Sand.

Question 15 - West Durham Coalfield and Wear Lowlands

West Durham Coalfield and Wear Lowlands - We would welcome your views on our Minerals Delivery Strategy for the West Durham Coalfields and Wear Lowlands Minerals Delivery Area?

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 59 A Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham'

Respondent Question 15 - West Durham Coalfield and Wear Lowlands - Council Response We would welcome your views on our Minerals Delivery Strategy for the West Durham Coalfields and Wear Lowlands Minerals Delivery Area? Mr Bryan Huntley Agree with the approach for the West Durham Coalfield and Wear The Local Plan Preferred Options seeks to simplify Darlington Borough Lowlands Minerals Delivery Area. the approach to future mineral provision and tackles Council the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period. Mr David Brewer CoalPro considers that in the Intended Approach, the statement The Local Plan Preferred Options seeks to simplify Confederation of UK Coal that the DPD will seek to identify environmentally acceptable sites the approach to future mineral provision and tackles Producers (COALPRO) and areas of search for the extraction of surface mined coal should the need for mineral extraction for specific minerals be qualified by recognising the alternative community benefit test rather than via Mineral Delivery Areas. The Preferred set out in Government guidance (para 8 of MPG3). Options sets out the chosen approach to providing for minerals throughout the plan period.

Policy 56 of the Local Plan Preferred Options addresses surface mined coal and fireclay. In relation to MPG3, the exceptions tests and allocations for new surface coal mining, paragraph 10.123 is clear that for surface mined coal sites, environmental acceptability will be the key test. For allocations the Council will not consider whether there may be any national, local or community benefits which could outweigh adverse impacts. In this respect the Council will only consider the exceptions tests in determining planning applications.

Mr Lee Weatherall As with ATH Resource's response to the Issues and Options paper The Local Plan Preferred Options seeks to simplify ATH Resources on this issue (question 51) they welcome the principle of the the approach to future mineral provision and tackles Minerals Delivery Areas identified. ATH Resources acknowledge the need for mineral extraction for specific minerals the statements provided that these are not intended to identify ' rather than via Mineral Delivery Areas. The Preferred no go' areas for minerals extraction but rather to advise what Options sets out the chosen approach to providing minerals extraction is most likely to occur in each area and provide for minerals throughout the plan period.

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Respondent Question 15 - West Durham Coalfield and Wear Lowlands - Council Response We would welcome your views on our Minerals Delivery Strategy for the West Durham Coalfields and Wear Lowlands Minerals Delivery Area? information on the key constraints that will be relevant. However Policy 56 of the Local Plan Preferred Options in order to help clarify this approach ATH Resources would addresses surface mined coal and fireclay. In relation consider a statement which confirms that the proposed extraction to MPG3, the exceptions tests and allocations for new of any minerals resources which are located within the boundaries surface coal mining, paragraph 10.123 is clear that for of a delivery area, but not identified as being of principal surface mined coal sites, environmental acceptability importance in that area, will not be disadvantaged by those will be the key test. For allocations the Council will resources not being named. For example the West Durham not consider whether there may be any national, local Coalfield and Wear Lowlands Delivery Area is the only one which or community benefits which could outweigh adverse mentions surface coal as a principal resource, but the extent of impacts. In this respect the Council will only consider the surface coal resources does extend into all four of the other the exceptions tests in determining planning delivery areas. It is also felt that the policy would benefit from a applications. reference to the exception tests provided in paragraph 8 of MPG3, although it is acknowledged that it may not be possible to map this issue with the subsequent allocations in the Policies and Allocations DPD. Miss C Kinnear We do not wish to comment on the provision of minerals within The Local Plan Preferred Options seeks to simplify RSPB this Minerals Development Area, however should such extraction the approach to future mineral provision and tackles proceed, we would support the restoration strategies detailed. We the need for mineral extraction for specific minerals agree with the expectation for restoration to deliver objectives and rather than via Mineral Delivery Areas. The Preferred priorities of supporting strategies, however suggest that this should Options sets out the chosen approach to providing apply to future mineral sites in addition to existing ones. We feel for minerals throughout the plan period. the wording 'where applicable' is not required since this applicability should already be considered by planners. Support for restoration strategies noted. This will certainly apply to new sites. In terms of existing mineral sites, the Council is required to consider updating existing permissions with modern working and restoration conditions and agree schemes of working on a regular basis, (every 15 years). As part of this process the Council will consider whether improved restoration schemes can be delivered.

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 61 A Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham'

Respondent Question 15 - West Durham Coalfield and Wear Lowlands - Council Response We would welcome your views on our Minerals Delivery Strategy for the West Durham Coalfields and Wear Lowlands Minerals Delivery Area? The wording 'where applicable' was meant to highlight that not all strategies may be applicable in any particular case.

Mr M Charis Subject to our comments (made separately) on MCAs, we support The Local Plan Preferred Options seeks to simplify Mineral Planning the intended approach. the approach to future mineral provision and tackles Association the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period. Mr C Ball UK Coal welcomes the support for coal identified in the intended The Local Plan Preferred Options seeks to simplify UK Coal Mining Ltd approach towards West Durham Coalfield and Delivery area, and the approach to future mineral provision and tackles further considers that the approach should reflect the guidance in the need for mineral extraction for specific minerals MPG3 about the alternate community benefits that the extraction rather than via Mineral Delivery Areas. The Preferred of coal can bring. Options sets out the chosen approach to providing for minerals throughout the plan period.

Policy 56 of the Local Plan Preferred Options addresses surface mined coal and fireclay.

Mrs G Gibson The Strategy seems well thought out, though we would wish to The Local Plan Preferred Options seeks to simplify CPRE see any workings minimise their impact on the landscape and the approach to future mineral provision and tackles residential amenity. In addition it is noted there is provision for the need for mineral extraction for specific minerals restoration of worked sites which is very important. rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period. The Local Plan Preferred Options explains that restoration of mineral sites will be addressed by the Minerals and Waste Policies and Allocations document.

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Respondent Question 15 - West Durham Coalfield and Wear Lowlands - Council Response We would welcome your views on our Minerals Delivery Strategy for the West Durham Coalfields and Wear Lowlands Minerals Delivery Area? Natural England Page 34 Other strategies that need to be considered include the The Local Plan Preferred Options seeks to simplify North Pennines AONB Management Plan, the North Pennines the approach to future mineral provision and tackles AONB Geodiversity Action Plan, the Durham Geodiversity Audit, the need for mineral extraction for specific minerals Limestone Landscapes Management Plan and the Durham rather than via Mineral Delivery Areas. The Preferred Heritage Coast Management Plan. Also need to consider the Options sets out the chosen approach to providing Durham Green Infrastructure Strategy once it is published and for minerals throughout the plan period. the Derwent Valley and Pennine Fringe IBDA project. Page 47 All restoration strategies - other strategies that need to be considered where relevant include the North Pennines AONB Management Plan, the North Pennines AONB Geodiversity Action Plan, the Durham Geodiversity Audit, Limestone Landscapes Management Plan, National Character Area profiles and the Durham Heritage Coast Management Plan. Also need to consider the Durham Green Infrastructure Strategy once published and the Derwent Valley and Pennine Fringe Integrated Biodiversity Delivery Area project. It is important to retain significant brownfield biodiversity and not see this is lost through inappropriate restoration. Where appropriate to do so, with extensions to existing sites there may also be opportunities to improve old restoration schemes for biodiversity/geodiversity. Mr T Bolton The Parish Council agrees with the County Council's analysis in The Local Plan Preferred Options seeks to simplify Eldon Parish Council relation to surface mined coal and fireclay (Question 10) and also the approach to future mineral provision and tackles supports the suggested approach in relation to the Minerals the need for mineral extraction for specific minerals Delivery Strategy for the West Durham Coalfield and Wear rather than via Mineral Delivery Areas. The Preferred Lowlands Minerals Delivery Area. Options sets out the chosen approach to providing for minerals throughout the plan period. Mr Michael Hodges We support the Council's strategy for the West Durham Coalfield The Local Plan Preferred Options seeks to simplify Sherburn Stone Co Ltd and Wear Lowlands Minerals Delivery Area. the approach to future mineral provision and tackles the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 63 A Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham'

Question 16 - Tees Lowlands

Tees Lowlands - We would welcome your views on our Minerals Delivery Strategy for the Tees Lowlands Minerals Delivery Area?

Respondent Question 16 - Tees Lowlands - We would welcome your Council Response views on our Minerals Delivery Strategy for the Tees Lowlands Minerals Delivery Area? Mr Bryan Huntley Agree with the approach for the Tees Lowlands Minerals The Local Plan Preferred Options seeks to simplify the Darlington Borough Council Delivery Area approach to future mineral provision and tackles the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period. Miss C Kinnear We do not wish to comment on the provision of minerals within The Local Plan Preferred Options seeks to simplify the RSPB this Minerals Development Area, however should such approach to future mineral provision and tackles the need extraction proceed, we would support the restoration for mineral extraction for specific minerals rather than strategies detailed. We agree with the expectation for via Mineral Delivery Areas. The Preferred Options sets restoration to deliver objectives and priorities of supporting out the chosen approach to providing for minerals strategies, however suggest that this should apply to future throughout the plan period. mineral sites in addition to existing ones. We feel the wording 'where applicable' is not required since this applicability should Support for restoration strategies noted. This will already be considered by planners. certainly apply to new sites. In terms of existing mineral sites, the Council is required to consider updating existing permissions with modern working and

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Respondent Question 16 - Tees Lowlands - We would welcome your Council Response views on our Minerals Delivery Strategy for the Tees Lowlands Minerals Delivery Area? restoration conditions and agree schemes of working on a regular basis, (every 15 years). As part of this process the Council will consider whether improved restoration schemes can be delivered via discussions with individual operators.

The wording 'where applicable' was meant to highlight that not all strategies may be applicable in any particular case.

Mr M Charis We support the intended approach. The Local Plan Preferred Options seeks to simplify the Mineral Planning Association approach to future mineral provision and tackles the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period. Mrs G Gibson The Strategy seems well thought out, though we would wish The Local Plan Preferred Options seeks to simplify the to see any workings minimise their impact on the landscape approach to future mineral provision and tackles the need CPRE and residential amenity. In addition it is noted there is for mineral extraction for specific minerals rather than provision for restoration of worked sites which is very via Mineral Delivery Areas. The Preferred Options sets important. out the chosen approach to providing for minerals throughout the plan period.

All new mineral working will need to be environmentally acceptable and consider impacts on amongst other things the County's landscape and residential amenity.

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 65 A Responses to Technical Consultation Report 'Towards a Minerals Delivery Strategy for County Durham'

Respondent Question 16 - Tees Lowlands - We would welcome your Council Response views on our Minerals Delivery Strategy for the Tees Lowlands Minerals Delivery Area? Geodiversity Audit, Limestone Landscapes Management Plan via Mineral Delivery Areas. The Preferred Options sets and the Durham Heritage Coast Management Plan. Also need out the chosen approach to providing for minerals to consider the Durham Green Infrastructure Strategy once throughout the plan period. it is published and the Derwent Valley and Pennine Fringe IBDA project.

Page 47 All restoration strategies - other strategies that need to be considered where relevant include the North Pennines AONB Management Plan, the North Pennines AONB Geodiversity Action Plan, the Durham Geodiversity Audit, Limestone Landscapes Management Plan, National Character Area profiles and the Durham Heritage Coast Management Plan. Also need to consider the Durham Green Infrastructure Strategy once published and the Derwent Valley and Pennine Fringe Integrated Biodiversity Delivery Area project. It is important to retain significant brownfield biodiversity and not see this is lost through inappropriate restoration. Where appropriate to do so, with extensions to existing sites there may also be opportunities to improve old restoration schemes for biodiversity/geodiversity.

Mr Michael Hodges We support the Council's strategy for the Tees Lowlands The Local Plan Preferred Options seeks to simplify the Sherburn Stone Co Ltd Minerals Delivery Area. approach to future mineral provision and tackles the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period.

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Question 17 - North Pennines

North Pennines - We would welcome your views on our Minerals Delivery Strategy for the North Pennines Minerals Delivery Area?

Respondent Question 17 - North Pennines - We would welcome your Council Response views on our Minerals Delivery Strategy for the North Pennines Minerals Delivery Area? Mr Bryan Huntley Agree with the approach for the North Pennines Minerals The Local Plan Preferred Options seeks to simplify the Darlington Borough Council Delivery Area. approach to future mineral provision and tackles the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period. Mr Lee Weatherall As with ATH Resource's response to the Issues and Options The Local Plan Preferred Options seeks to simplify the ATH Resources paper on this issue (question 51) they welcome the principle approach to future mineral provision and tackles the of the Minerals Delivery Areas identified. ATH Resources need for mineral extraction for specific minerals rather acknowledge the statements provided that these are not than via Mineral Delivery Areas. The Preferred Options intended to identify 'no go' areas for minerals extraction but sets out the chosen approach to providing for minerals rather to advise what minerals extraction is most likely to occur throughout the plan period. in each area and provide information on the key constraints that will be relevant. However in order to help clarify this Policy 56 of the Local Plan Preferred Options addresses approach ATH Resources would consider a statement which surface mined coal and fireclay. In relation to MPG3, confirms that the proposed extraction of any minerals resources the exceptions tests and allocations for new surface which are located within the boundaries of a delivery area, but coal mining, paragraph 10.123 is clear that for surface not identified as being of principal importance in that area, will mined coal sites, environmental acceptability will be not be disadvantaged by those resources not being named. the key test. For allocations the Council will not consider For example the West Durham Coalfield and Wear Lowlands whether there may be any national, local or community Delivery Area is the only one which mentions surface coal as benefits which could outweigh adverse impacts. In this a principal resource, but the extent of the surface coal resources respect the Council will only consider the exceptions does extend into all four of the other delivery areas. It is also tests in determining planning applications. felt that the policy would benefit from a reference to the exception tests provided in paragraph 8 of MPG3, although it

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Respondent Question 17 - North Pennines - We would welcome your Council Response views on our Minerals Delivery Strategy for the North Pennines Minerals Delivery Area? is acknowledged that it may not be possible to map this issue with the subsequent allocations in the Policies and Allocations DPD. Miss C Kinnear We do not wish to comment on the provision of minerals within The council's approach to preference extensions and RSPB this Minerals Development Area. The council's approach to re-workings over new sites will take account of the preference extensions and re-workings over new sites should environmental acceptability of the proposals. take account of the environmental acceptability of the proposals. In considering site re-workings, existing biodiversity interest In considering site reworking, we will consider that may have developed in the inactive site must be accounted biodiversity interests. The weight which will be attached for. If a new site would cause less damage then this should be will be consistent with the protection afforded to the the preferred option. Proposals for further working should avoid biodiversity interest. impacts on all sites of importance for biodiversity, rather than just international nature conservation sites as stated. Support for restoration strategies noted. This will certainly apply to new sites. In terms of existing mineral We agree with the expectation for restoration strategies to sites, the Council is required to consider updating deliver objectives and priorities of supporting strategies, existing permissions with modern working and however suggest that this should apply to future mineral sites restoration conditions and agree schemes of working in addition to existing ones. We feel the wording 'where on a regular basis, (every 15 years). As part of this applicable' is not required since this applicability should already process the Council will consider whether improved be considered by planners. restoration schemes can be delivered.

The wording 'where applicable' was meant to highlight that not all strategies may be applicable in any particular case. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period.

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Respondent Question 17 - North Pennines - We would welcome your Council Response views on our Minerals Delivery Strategy for the North Pennines Minerals Delivery Area? Pennines AONB is noted and we are pleased to see the than via Mineral Delivery Areas. The Preferred Options importance given to the protection the designation brings. In sets out the chosen approach to providing for minerals addition it is noted there is provision for restoration of worked throughout the plan period. sites which is very important. All new mineral working will need to be environmentally acceptable and consider impacts on amongst other things the County's landscape and residential amenity.

Natural England Page 34 Other strategies that need to be considered include The Local Plan Preferred Options seeks to simplify the the North Pennines AONB Management Plan, the North approach to future mineral provision and tackles the Pennines AONB Geodiversity Action Plan, the Durham need for mineral extraction for specific minerals rather Geodiversity Audit, Limestone Landscapes Management Plan than via Mineral Delivery Areas. The Preferred Options and the Durham Heritage Coast Management Plan. Also need sets out the chosen approach to providing for minerals to consider the Durham Green Infrastructure Strategy once it throughout the plan period. is published and the Derwent Valley and Pennine Fringe IBDA project.

Page 39 Paragraph 5.17 We agree with the approach in paragraph 5.17. It should also refer to European as well as national sites such as SSSI and NNR.

Page 39 Paragraph 5.18/Page 54 This approach may not be the most preferable when considered on an individual site basis. Whilst recognising this option appears to make economic sense, there is also a need to consider carefully the environmental and cumulative impacts of extending existing quarries particularly those in the vicinity of European and national nature conservation designations, avoiding such designations where possible, and in the North Pennines AONB. In some circumstances the provision of a new site outside the North Pennines Delivery Area may be preferable to existing site extensions which may have significant adverse effects on European and national nature conservation sites and landscape

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Respondent Question 17 - North Pennines - We would welcome your Council Response views on our Minerals Delivery Strategy for the North Pennines Minerals Delivery Area? designations. New sites may have fewer constraints associated with them, and may provide more opportunities for enhancement of biodiversity and/or geodiversity.

Mr Michael Hodges We support the Council's strategy for the North Pennines The Local Plan Preferred Options seeks to simplify the Sherburn Stone Co Ltd Minerals Delivery Area. approach to future mineral provision and tackles the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period. Councillor John Shuttleworth In general, I support the Minerals Delivery Strategy for the The Local Plan Preferred Options seeks to simplify the North Pennines. In saying this I have already commented that approach to future mineral provision and tackles the I would support the allocation of an extension to Heights Quarry. need for mineral extraction for specific minerals rather This is an important source of local employment, which is than via Mineral Delivery Areas. The Preferred Options needed within the valley. sets out the chosen approach to providing for minerals throughout the plan period.

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Respondent Question 17 - North Pennines - We would welcome your Council Response views on our Minerals Delivery Strategy for the North Pennines Minerals Delivery Area? Mr M Charis No comment. The Local Plan Preferred Options seeks to simplify the Mineral Planning Association approach to future mineral provision and tackles the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period.

Question 18 - Dales Fringe

Dales Fringe - We would welcome your views on our Minerals Delivery Strategy for the Dales Fringe Minerals Delivery Area.

Respondent Question 18 - Dales Fringe - We would welcome your views Council Response on our Minerals Delivery Strategy for the Dales Fringe Minerals Delivery Area. Mr Bryan Huntley Agree with the approach for the Dales Fringe Minerals Delivery The Local Plan Preferred Options seeks to simplify the Darlington Borough Council Area. approach to future mineral provision and tackles the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period. Mr Lee Weatherall As with ATH Resource's response to the Issues and Options The Local Plan Preferred Options seeks to simplify the ATH Resources paper on this issue (question 51) they welcome the principle of approach to future mineral provision and tackles the the Minerals Delivery Areas identified. need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options ATH Resources acknowledge the statements provided that sets out the chosen approach to providing for minerals these are not intended to identify 'no go' areas for minerals throughout the plan period. extraction but rather to advise what minerals extraction is most likely to occur in each area and provide information on the key

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Respondent Question 18 - Dales Fringe - We would welcome your views Council Response on our Minerals Delivery Strategy for the Dales Fringe Minerals Delivery Area. constraints that will be relevant. However, in order to help clarify Policy 56 of the Local Plan Preferred Options addresses this approach ATH Resources would consider a statement which surface mined coal and fireclay. In relation to MPG3, confirms that the proposed extraction of any minerals resources the exceptions tests and allocations for new surface which are located within the boundaries of a delivery area, but coal mining, paragraph 10.123 is clear that for surface not identified as being of principal importance in that area, will mined coal sites, environmental acceptability will be not be disadvantaged by those resources not being named. For the key test. For allocations the Council will not example the West Durham Coalfield and Wear Lowlands consider whether there may be any national, local or Delivery Area is the only one which mentions surface coal as a community benefits which could outweigh adverse principal resource, but the extent of the surface coal resources impacts. In this respect the Council will only consider does extend into all four of the other delivery areas. It is also the exceptions tests in determining planning felt that the policy would benefit from a reference to the exception applications. tests provided in paragraph 8 of MPG3, although it is acknowledged that it may not be possible to map this issue with the subsequent allocations in the Policies and Allocations DPD.

Miss C Kinnear We do not wish to comment on the provision of minerals within Support for restoration strategies noted. This will RSPB this Minerals Development Area, however should such extraction certainly apply to new sites. In terms of existing mineral proceed, we would support the restoration strategies detailed. sites, the Council is required to consider updating We agree with the expectation for restoration to deliver existing permissions with modern working and objectives and priorities of supporting strategies, however restoration conditions and agree schemes of working suggest that this should apply to future mineral sites in addition on a regular basis, (every 15 years). As part of this to existing ones. We feel the wording 'where applicable' is not process the Council will consider whether improved required since this applicability should already be considered restoration schemes can be delivered. The wording by planners. 'where applicable' was meant to highlight that not all strategies may be applicable in any particular case.

The Local Plan Preferred Options seeks to simplify the approach to future mineral provision and tackles the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals

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Respondent Question 18 - Dales Fringe - We would welcome your views Council Response on our Minerals Delivery Strategy for the Dales Fringe Minerals Delivery Area. throughout the plan period. Restoration of mineral sites will be addressed by the Minerals and Waste Policies and Allocations document.

Ms G Gibson The Strategy seems well thought out, though we would wish to Support noted. All new mineral working will need to be CPRE see any workings minimise their impact on the landscape and environmentally acceptable and consider impacts on residential amenity. In addition it is noted there is provision for amongst other things the County's landscape and restoration of worked sites which is very important. residential amenity. The Local Plan Preferred Options seeks to simplify the approach to future mineral provision and tackles the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period. Natural England Page 34 Other strategies that need to be considered include The Local Plan Preferred Options seeks to simplify the the North Pennines AONB Management Plan, the North approach to future mineral provision and tackles the Pennines AONB Geodiversity Action Plan, the Durham need for mineral extraction for specific minerals rather Geodiversity Audit, Limestone Landscapes Management Plan than via Mineral Delivery Areas. The Preferred Options and the Durham Heritage Coast Management Plan. Also need sets out the chosen approach to providing for minerals to consider the Durham Green Infrastructure Strategy once it is throughout the plan period. published and the Derwent Valley and Pennine Fringe IBDA project.

Page 39 Paragraph 5.17 We agree with the approach in paragraph 5.17.

It should also refer to European as well as national sites such as SSSI and NNR.

Page 47 All restoration strategies - other strategies that need to be considered where relevant include the North Pennines AONB Management Plan, the North Pennines AONB

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Respondent Question 18 - Dales Fringe - We would welcome your views Council Response on our Minerals Delivery Strategy for the Dales Fringe Minerals Delivery Area. Geodiversity Action Plan, the Durham Geodiversity Audit, Limestone Landscapes Management Plan, National Character Area profiles and the Durham Heritage Coast Management Plan. Also need to consider the Durham Green Infrastructure Strategy once published and the Derwent Valley and Pennine Fringe Integrated Biodiversity Delivery Area project.

It is important to retain significant brownfield biodiversity and not see this is lost through inappropriate restoration. Where appropriate to do so, with extensions to existing sites there may also be opportunities to improve old restoration schemes for biodiversity/geodiversity.

Mr Michael Hodges We support the Council's strategy for the Dales Fringe Minerals The Local Plan Preferred Options seeks to simplify the Sherburn Stone Co Ltd Delivery Area. approach to future mineral provision and tackles the need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period. Mr M Charis Subject to our comments (made separately) on MCAs, we The Local Plan Preferred Options seeks to simplify the Mineral Planning support the intended approach. approach to future mineral provision and tackles the Association need for mineral extraction for specific minerals rather than via Mineral Delivery Areas. The Preferred Options sets out the chosen approach to providing for minerals throughout the plan period.

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Question 1 - Issues and Options for Surface Coal Mining

Issues and Options for coal - Do you agree with our conclusion that their are no realistic issues and options/alternative strategies for surface mined coal extraction other than to plan in accordance with the requirements of national policy as set out in MPG3? (If you believe that there are issues and options/alternative strategies that we have not considered for surface mined coal please explain providing as much detail as possible.)

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Respondent Question 1 - Issues and Options for coal - Do you agree Council Response with our conclusion that their are no realistic issues and options/alternative strategies for surface mined coal extraction other than to plan in accordance with the requirements of national policy as set out in MPG3? Mr David Brewer Yes. This recognises the provisions of MPG3 in full, which Support for policy based upon national policy in MPG3 Confederation of UK Coal should also apply in the Minerals Delivery Strategy and in the noted. NPPF replaces MPG3. Policy 56 'Surface Mined Producers (COALPRO) Technical Consultation Report on Minerals and Waste Sites. Coal and Fireclay' of Preferred Options sets out the chosen approach. G K Wilson Para 2.28 Line 11 & 12 Refers to "an important part of a secure We note your comments in relation to the role of imports Derwentside Valley and diverse energy supply" We would argue that it is only and domestic coal production. In this regard we need Protection Society secure if kept as a strategic supply which would be available to have regard to the Government's latest Energy Policy only in times of real emergency. We imported 38m/tons of which while notwithstanding the aim of reducing coal in 2009. Clearly there is coal available to import at present dependence on fossil fuels and reducing green house but this may not always be so and what reserves we have gas emissions still considers the role of domestic coal would be of extreme value when such a situation arose. The as part of the UK's energy mix. country should import what we need while it is available and affordable. The government should provide advice on this but Comments noted in relation to MPG3. The approach I think it is an important point. outlined seeks to develop a constraints based approach which takes fully into account the latest work on We agree on the whole with your conclusion in Question 1 in landscape character in County Durham. NPPF replaces that we believe that MPG3 has withstood the test of time MPG3. Policy 56 'Surface Mined Coal and Fireclay' of reasonably well. However considering the fact that landscape Preferred Options sets out the chosen approach. and environmental considerations are now even of more concern it is important that such areas of constraint should form part of any mineral planning policy.

Mr Lee Weatherall Footnote 3, Page 10 The footnote explains that the sites which ATH Resources agreement for the consideration of their ATH Resources ATH Resources has submitted to date, Pittington North, sites as non strategic sites in the Minerals and Waste Pittington South and Eldon Blue House, will be considered as Policies and Allocations DPD noted. Support for policy strategic sites with all of the other surface mine sites submitted based upon national policy in MPG3 noted. NPPF considered initially through the Policies and Allocations DPD replaces MPG3. Policy 56 'Surface Mined Coal and with SA and HRA undertaken on them. Please see our Fireclay' of Preferred Options sets out the chosen comments on the New Minerals and Waste Sites document, approach. which confirms that ATH Resources agree that their submitted

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Respondent Question 1 - Issues and Options for coal - Do you agree Council Response with our conclusion that their are no realistic issues and options/alternative strategies for surface mined coal extraction other than to plan in accordance with the requirements of national policy as set out in MPG3? sites should not be considered as strategic and request they are considered alongside the other proposed surface mine sites in the Minerals and Waste Policies and Allocations DPD. Question 1 ATH Resources agree with the conclusion that planning for surface coal mines should be made in accordance with national policy as set out in MPG3. Mrs Margaret Forster Coxhoe Parish Council has no comments to make on the Noted. Coxhoe Parish Council 'Energy Minerals' Consultation Document'. Miss Rachael Bust The Coal Authority support a policy approach based upon Support for policy based upon national policy in MPG3 Coal Authority national planning policy in MPG3 and welcome the recognition noted. NPPF replaces MPG3. Policy 56 'Surface Mined that County Durham indicates that seeking to impose undue Coal and Fireclay' of Preferred Options sets out the restraint on surface coal extraction would be unsound. Such chosen approach. a criteria based approach will also help the Council and operators have sufficient flexibility over the plan period to respond to the changing requirements of the energy market. Mr C Ball UK Coal supports the approach outlined at Para 1.5 of not Support for not departing from the guidance set out in UK Coal Mining Ltd departing from the guidance set out in MPG3. Similarly we MPG3 noted. also welcome the acknowledgement contained at Para 2.6 of benefits that UK Coal restoration schemes have brought to Comment in relation to paragraph 2.8 noted. NPPF the North East. We are also pleased to see the replaces MPG3. Policy 56 'Surface Mined Coal and acknowledgement at Para 2.15 of the important role that coal Fireclay' of Preferred Options sets out the chosen plays in the electricity generation market. With regard to Para approach. 2.8 we would highlight the Eldon Deep Extension should be included in the list of sites that has been granted planning permission since 2000. Response to Question 1 UK Coal agrees that the best approach towards surface coal mining is the guidance set out in MPG3, and are of the view that there are no realistic alternatives to this policy.

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Question 2 and 3 - Should the County Durham Plan contain a policy for surface mined coal extraction and fireclay extraction? How can it be improved?

Development Management Policy for coal and fireclay. Should the County Durham Plan contain a development management policy for surface mined coal and fireclay extraction?

Do you have any suggestions on how this potential policy could be improved?

Respondent Question 2 and 3 - Development Management Policy for coal and Council Response fireclay Mr T Bolton The Parish Council supports the development by the County Council of Support noted. Policy 56 'Surface Mined Coal and Eldon Parish Council policies for a constraint based approach in relation to the extraction of Fireclay' of Preferred Options sets out the chosen coal. It further supports the development management policy for surface approach. mined coal and fireclay along the lines suggested in the consultation document. Mr Bryan Huntley Agree that the proposed draft policy is acceptable Support for development management policy for Darlington Borough surface mined coal and fireclay extraction noted. Council Policy 56 'Surface Mined Coal and Fireclay' of Preferred Options sets out the chosen approach.

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Respondent Question 2 and 3 - Development Management Policy for coal and Council Response fireclay Mr Bryan Huntley Agree that, with or without a policy based on "no go areas", the County Support for development management policy for Darlington Borough Durham Plan should contain a development management policy for surface mined coal and fireclay extraction noted. Council surface mined coal and fireclay extraction. Policy 56 'Surface Mined Coal and Fireclay' of Preferred Options sets out the chosen approach. Mr David Brewer Yes. This is essential in the absence of specific sites allocation. Support for development management policy for Confederation of UK surface mined coal and fireclay extraction noted. Coal Producers Policy 56 'Surface Mined Coal and Fireclay' of (COALPRO) Preferred Options sets out the chosen approach.

Site allocations will be considered through a separate document.

Mr David Brewer Yes. Whilst agreeing in general terms that piecemeal working of surface We note the comment in relation to piecemeal Confederation of UK mined coal sites should not be allowed, it is important that market realities working and extensions. The wording as drafted Coal Producers should not be ignored. Provision should be made, therefore, for site is in accord with saved policy M8 of the County (COALPRO) extensions in certain circumstances, subject to the other provisions of Durham Minerals Local Plan. We would however the draft policy, in circumstances where the longevity of a contract to anticipate that in appropriate circumstances a supply coal is limited by market considerations. departure may be considered. Policy 56 'Surface Mined Coal and Fireclay' of Preferred Options sets out the chosen approach. G K Wilson Regarding Question 2 - we agree that the County Durham Plan should Support for development management policy for Derwentside Valley contain a development management policy. We also believe that a local surface mined coal and fireclay extraction noted. Protection Society Distinctive Policy should be applied to County Durham in that most of the We note the comments in relation to Coke making, coal, particularly in the west of the County is coking coal and it should however, we can not distinguish between the uses not be extracted for anything other than coke making. To use this coal that coal is used for. As set out in the Technical for Power Stations, for which it has been and still is being used, is a gross Consultation Paper "Safeguarding Mineral waste of the energy value of the coal. Power Stations are not designed Resources for the Future' surface coal resources to burn this coal (CEGB Report on Boiler Tests using coking coal) MPG3 will be safeguarded and prior extraction will be alludes to this in that "coal resources are to be safeguarded for future considered to avoid sterilisation. Policy 56 'Surface working" Mined Coal and Fireclay' of Preferred Options sets out the chosen approach.

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Respondent Question 2 and 3 - Development Management Policy for coal and Council Response fireclay G K Wilson In principal we support the inclusion of a development management policy Support noted. Fireclay occurs in association with Derwentside Valley for surface mined coal with the proviso that fireclay extraction is only to surface mined coal, Its production is dependent Protection Society be allowed in association with coal extraction. upon surface mined coal extraction. Policy 56 'Surface Mined Coal and Fireclay' of Preferred Options sets out the chosen approach. Mr Lee Weatherall It is considered that a development management style policy would be Support for development management policy for ATH Resources beneficial in the County Durham Plan due to the extent of coal resources surface mined coal and fireclay extraction noted. in the authority and the level of interest from the industry in working sites. We note the comment in relation to piecemeal With regard to the contents of the policy it is considered that any issues working and extensions. The wording as drafted which could be included will need to be supported by full justification is in accord with saved policy M8 of the County explaining why they are locally relevant. If this is done it is considered it Durham Minerals Local Plan. We would however will give confidence to both the industry and to other interested parties anticipate that in appropriate circumstances a as to what issues will need to be considered in applications and to ensure departure may be considered. Policy 56 'Surface they are dealt with appropriately. The point made in the suggested policy Mined Coal and Fireclay' of Preferred Options and about working not taking place in a piecemeal manner is considered to its reasoned justification sets out the chosen be an acceptable principle. However we are concerned that the policy approach. does not reflect the reality of many situations where subsequent extensions to a site cannot always be considered at the outset for a variety of legitimate reasons, but they can be proved to be worked in an acceptable manner subsequently. If an extension can be proven to be worked in this way, including through the assessment of cumulative effects of working over an extended period of time, then it should be permitted. Miss Rachael Bust The Coal Authority would support the inclusion of a criteria based policy Support for development management policy for Coal Authority in the Minerals and Waste Policies and Allocations DPD dealing with surface mined coal and fireclay extraction noted. surface coal proposals, particularly given that specific sites have been Our intention is the approach to coal and the scope advocated for potential allocation. There does however need to be some for further surface mined coal extraction will be recognition in the Core Strategy of surface coal in an over-arching minerals recognised in the minerals section of the County strategic policy. The proposed policy indicated follows the general Durham Plan. approach of MPG3 and is therefore sound in its overall approach. It then goes onto set out helpful criteria to be considered when assessing Proposed amendment (i) accepted. In relation to benefits. The Coal Authority however considers that criteria i) should proposed amendment (v). The National Planning include reference to addressing mining legacy issues and the reworking Policy Framework now refers to "national" benefits

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Respondent Question 2 and 3 - Development Management Policy for coal and Council Response fireclay of existing sites, the following wording addition is suggested: "...i) the and this has now been incorporated into the contribution of the proposal towards the comprehensive reclamation of wording of Policy 56 'Surface Mined Coal and areas of derelict or contaminated land or the remediation of mining legacy Fireclay' of the Local Plan Preferred Options. or the reworking of previously extracted sites to address legacy and management issues;..." The Coal Authority also considers that that there should be recognition of the potential contribution that sites could make to the indigenous supply of coal in line with the overall national planning objectives set out in MPS1. The suggested wording is as follows: "...v) the contribution sites could make to the indigenous supply of coal and the proximity and national needs of the energy generation industry." Mr C Ball UK Coal considers that the draft "Potential Surface Coal and Fireclay Support noted. Policy 56 'Surface Mined Coal and UK Coal Mining Ltd Policy" is suitably worded and would provide a reasonable basis for Fireclay' of Preferred Options sets out the chosen determining planning applications to extract coal and fireclay. approach. Mr C Ball UK Coal considers that there is merit in including a management policy Support for development management policy for UK Coal Mining Ltd for surface mined coal and fireclay extraction, particularly in light of the surface mined coal and fireclay extraction noted. Government's acknowledged intention to abolish Regional Spatial Policy 56 'Surface Mined Coal and Fireclay' of Strategies (RSSs). Preferred Options sets out the chosen approach. Mr N Spence We acknowledge that fireclay has been sourced from open cast coal sites We recognise that fireclay is a scarce resource Ibstock Brick Ltd in Northumberland and we actively seek to source materials as close to which should not wasted or sterilised. We will seek Property Manager our brickworks as possible. On account of the high technical specification the full recovery of fireclay when surface mined North required for brick manufacture, only a small proportion of opencast sites, coal is worked provided it is of the correct technical produce fireclay suitable for brick manufacture. Government planning and aesthetic properties for brick manufacture If guidance on coal mining emphasises the importance of fireclay and urges the fireclay is not able to be used immediately we the full examination of every opportunity to produce it from any proposed will also require its stockpiling or on site storage site. These principles should be reflected in the development plan and for future use. NPPF replaces MPG3. Policy 56 effectively applied when applications for permissions are considered. The 'Surface Mined Coal and Fireclay' of Preferred DTLR report Brick Clay: Issues for Planning also recommends that Options sets out the chosen approach. planning authorities and industry seek, through policies and decisions, to address the supply of fireclay. Open cast coal schemes should be encouraged to incorporate in working schemes provisions for stockpiling or on-site storage to guarantee full exploitation and avoidance of sterilisation. The heavy clay and opencast industries need to work better

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Respondent Question 2 and 3 - Development Management Policy for coal and Council Response fireclay together to ensure a full assessment of the suitability and marketability of fireclays available from any site before submission of an application for planning permission. We would welcome the assistance of the MPA to ensure that the brick industry is able to take advantage of any opportunities and not just be used by operators to justify open cast coal schemes. Such an approach will avoid sterilisation of a scarce resource, encourage a close match between supply and demand on a local or regional basis, and be compatible with the principles of sustainable development.

Question 4 - Planning constraints in the exposed coalfield

Planning Constraints in the exposed coalfield - Have we identified all of the planning constraints within the exposed coalfield? Are there any additional constraints which need to be considered as part of a constraints based approach to surface mined coal?

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Ms S Wickerson With regards to questions 4 and 5, we feel your list of potential constraints Comments noted. The County Durham Environment Agency highlights the main environmental issues associated with mineral developments. Local Plan Preferred Options includes a We would support the idea of the creation of a GIS based constraint map. We Proposals Map which identifies the range have found these tools useful ourselves, and we do have GIS layers available of environmental sites and designations for your use that cover some of the constraints you mention. Please feel free which are constraints on all mineral to contact me for a list of data we hold. We also believe that Table 3 would be working. Links are provided to the useful for developers. Although this might be beyond the scope of what you Environment Agency website where are intending with this table, it might also be of use to include links to key relevant Environment Agency constraints legislation, for example for ground and surface water, the Water Framework can be viewed. This approach will ensure Directive, etc. that up to date Environment Agency constraints are always viewable. Consideration will be given to the inclusion of such constraints on the interactive Proposals Map which will accompany the Submission Local Plan.

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Respondent Question 4 - Planning Constraints in the exposed coalfield. Have we Council Response identified all of the planning constraints within the exposed coalfield? Are there any additional constraints which need to be considered as part of a constraints based approach to surface mined coal? Miss Rachael Bust Comment/Objection - The issue of planning constraints that affect mineral Comments noted. The County Durham Coal Authority extraction apply to all minerals and not just surface mined coal, this is therefore Local Plan Preferred Options includes a not an issue which should be addressed in isolation for energy minerals. It is Proposals Map which identifies the range considered that these issues are best addressed through the site allocation of environmental sites and designations process using site selection criteria for all mineral allocations and at the stage which are constraints on all mineral of determining planning applications. The proposal to map all of the relevant working. constraints appears to be a potential approach towards identifying 'no-go' or 'areas of restraint' which have previously been found unsound and inappropriate and the Council have indicated in Question 1 that they no longer propose to use. All relevant constraints will be the subject of other policies in the County Durham Core Strategy or other relevant DPD and as such to address these in isolation relating to coal would be inappropriate and would result in the unnecessary duplication of policies within the overall LDF. If the County Durham Plan were to propose such an approach only in relation to surface coal proposals then The Coal Authority will object to the approach being fundamentally UNSOUND. Natural England Page 21 Paragraph 2.35/Table 2/Question 4/Table 3 It is also not clear why Comments noted. The County Durham potential constraints identified through PPS should also be considered and Local Plan Preferred Options includes a referenced (for example PPS5 (historic env), PPS7 (AONB/landscape) , PPS9 Proposals Map which identifies the range (biodiversity and geodiversity), PPS17 (recreation) . This section could also of environmental sites and designations highlight key positive guidance available which needs to be taken into account which are constraints on all mineral for specific constraints (for example County Durham BAP, NP AONB working. Management Plan, Geodiversity Action Plans etc) An SA appraisal of this option may also highlight issues that need to be identified as constraints. Table 2/Table 3 - this omits SSSI/NNR, National Priority BAP habitats. County Durham Priority BAP habitats. (There may also be very small areas of SPA/SAC/Ramsar sites, however difficult to assess accurately from the scale of map provided on coalfield resource area- lpa need to check)

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Question 5 - Use of a GIS based constraints map

A GIS based approach. Given the size of the exposed coalfield some constraints such as Scheduled Ancient Monuments and Listed Buildings may be too small to be mapped on an printed Ordnance Survey base. Should we seek to identify all of the relevant constraints through an electronic GIS based constraints map?

Respondent Question 5 - A GIS based approach Council Response Mr Bryan Huntley Probably not necessary to identify all SAMs and Listed The County Durham Local Plan Preferred Options includes Darlington Borough Council Buildings on a map,simply refer to them as a collective a Proposals Map which identifies the range of in the policy. environmental sites and designations which are constraints on all mineral working. Only legible constraints are mapped on an OS base, relevant policies of the Plan refer to certain small scale constraints/designations. Mr David Brewer No. Coal Pro considers that this would be extremely The County Durham Local Plan Preferred Options includes Confederation of UK Coal difficult and correspondingly expensive. Such constraints a Proposals Map which identifies the range of Producers (COALPRO) can be taken into account in development policies. environmental sites and designations which are constraints on all mineral working. Only legible constraints are mapped on an OS base, relevant policies of the Plan refer to certain small scale constraints/designations. G K Wilson The answer to Question 5 - Seems sensible to use GIS Comments noted. The County Durham Local Plan Preferred Derwentside Valley Protection based constraint map. Options includes a Proposals Map which identifies the Society range of environmental sites and designations which are

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Respondent Question 5 - A GIS based approach Council Response constraints on all mineral working. Only legible constraints are mapped on an OS base, relevant policies of the Plan refer to certain small scale constraints/designations. Mr Lee Weatherall It is noted that national and international The County Durham Local Plan Preferred Options includes ATH Resources biodiversity/geodiversity designations are not included a Proposals Map which identifies the range of on the constraints list. The list presently includes environmental sites and designations which are constraints protected species at European and National levels, but on all mineral working. Only legible constraints are mapped not designated land (SPAs, SACs, Ramsar sites, SSSIs, on an OS base, relevant policies of the Plan refer to certain NNRs etc). Only regional and local designations are small scale constraints/designations. included. It is considered that these constraints need to be included to provide a comprehensive coverage of all constraints in order for operators to be able to consider all of the relevant issues. As set out in paragraphs 2.3.5 and 2.3.7 the constraints identified should not be considered as 'no go' areas for extraction. It is the felt the use of a GIS resource to identify the constraints would be a useful tool given the issues of legibility identified but also because the resource will be more easily updated should the constraints change during the plan period. S Wickerson With regards to questions 4 and 5, we feel your list of Comments noted. The County Durham Local Plan Preferred potential constraints highlights the main environmental Options includes a Proposals Map which identifies the Environment Agency issues associated with mineral developments. We would range of environmental sites and designations which are support the idea of the creation of a GIS based constraints on all mineral working. Links are provided to constraint map. We have found these tools useful the Environment Agency website where relevant ourselves, and we do have GIS layers available for your Environment Agency constraints can be viewed. This use that cover some of the constraints you mention. approach will ensure that up to date Environment Agency Please feel free to contact me for a list of data we hold. constraints are always viewable. Consideration will be We also believe that Table 3 would be useful for given to the inclusion of such constraints on the interactive developers. Although this might be beyond the scope Proposals Map which will accompany the Submission Local of what you are intending with this table, it might also Plan. be of use to include links to key legislation, for example for ground and surface water, the Water Framework Directive, etc.

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Respondent Question 5 - A GIS based approach Council Response Miss Rachael Bust Comment/Objection - The issue of planning constraints The County Durham Local Plan Preferred Options includes that affect mineral extraction apply to all minerals and a Proposals Map which identifies the range of Coal Authority not just surface mined coal, this is therefore not an issue environmental sites and designations which are constraints which should be addressed in isolation for energy on all mineral working. Only legible constraints are mapped minerals. It is considered that these issues are best on an OS base, relevant policies of the Plan refer to certain addressed through the site allocation process using site small scale constraints/designations. selection criteria for all mineral allocations and at the stage of determining planning applications. The proposal to map all of the relevant constraints appears to be a potential approach towards identifying 'no-go' or 'areas of restraint' which have previously been found unsound and inappropriate and the Council have indicated in Question 1 that they no longer propose to use. All relevant constraints will be the subject of other policies in the County Durham Core Strategy or other relevant DPD and as such to address these in isolation relating to coal would be inappropriate and would result in the unnecessary duplication of policies within the overall LDF. If the County Durham Plan were to propose such an approach only in relation to surface coal proposals then The Coal Authority will object to the approach being fundamentally UNSOUND. Mr C Ball UK Coal does not think that all the relevant constraints Comments noted. The County Durham Local Plan Preferred UK Coal Mining Ltd should be mapped on a printed Ordnance Survey base. Options includes a Proposals Map which identifies the We do however see merit in showing all relevant range of environmental sites and designations which are constraints on the GIS based map. constraints on all mineral working. Only legible constraints are mapped on an OS base, relevant policies of the Plan refer to certain small scale constraints/designations. Natural England Question 5 - this is possible - for example similar Comments noted.The County Durham Local Plan Preferred material already exists on http://www.magic.gov.uk Options includes a Proposals Map which identifies the range of environmental sites and designations which are constraints on all mineral working. Only legible constraints are mapped on an OS base, relevant policies of the Plan refer to certain small scale constraints/designations.

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Question 6 - What are your views on the application of a constraints based approach?

Application of a constraints based approach - We would welcome your views on the application of a constraints based approach?

Respondent Question 6 - Application of a constraints based approach Council Response Mr David Brewer CoalPro supports the application of a constraints based The County Durham Local Plan Preferred Options Confederation of UK Coal approach supplemented by appropriate development policies. includes a Proposals Map which identifies the range of Producers (COALPRO) environmental sites and designations which are constraints on all mineral working. Only legible constraints are mapped on an OS base, relevant policies of the Plan refer to certain small scale constraints/designations. Mr Lee Weatherall ATH Resources would agree with the statements provided The County Durham Local Plan Preferred Options ATH Resources in paragraphs 2.35 and 2.37 that the constraints information includes a Proposals Map which identifies the range of used should not be used to identify 'no go' areas for environmental sites and designations which are development, but rather it should be used to allow the industry constraints on all mineral working. Only legible to identify what the relevant constraints are in their areas of constraints are mapped on an OS base, relevant policies interest and provide information about their nature. The of the Plan refer to certain small scale industry will then be able to use this information to assess constraints/designations. whether their proposals would be appropriate in these areas or to influence the design of their proposals. The Local Plan Preferred Options does not include a 'No Go' approach to surface coal mining.

Mr C Ball UK Coal would be prepared to accept a constraints based The County Durham Local Plan Preferred Options UK Coal Mining Ltd approach towards potential mineral sites, providing that the includes a Proposals Map which identifies the range of advice contained at Para 2.35 - that the constraints are being environmental sites and designations which are identified in order to provide information, and that there is no constraints on all mineral working. Only legible intention to create "no go" areas for mineral development - constraints are mapped on an OS base, relevant policies is made explicit as part of any new policy. Otherwise the of the Plan refer to certain small scale danger exists that the constraints based approach may constraints/designations. become a needlessly restrictive policy towards mineral development, contrary to government guidance. The Local Plan Preferred Options does not include a 'No Go' approach to surface coal mining.

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Respondent Question 6 - Application of a constraints based approach Council Response Miss Rachael Bust Comment/Objection - Given our comments above we do not The County Durham Local Plan Preferred Options Coal Authority support the approach in principle, therefore we do not support includes a Proposals Map which identifies the range of the identification of any of the potential constraints, all of environmental sites and designations which are which duplicate national planning policy considerations in constraints on all mineral working. Only legible MPS1, MPS2 or MPG3. A number of the potential constraints constraints are mapped on an OS base, relevant policies need to be tested through the relevant policy process anyway, of the Plan refer to certain small scale for example local sites of landscape importance need to be constraints/designations. tested against the national policy set out in PPS7. If the County Durham Plan were to propose such an approach only The Local Plan Preferred Options does not include a 'No in relation to surface coal proposals then The Coal Authority Go' approach to surface coal mining. will object to the approach being fundamentally UNSOUND. Miss Rachael Bust Site/Policy/Paragraph/Proposal - Coal Mining Legacy Support Support noted. The County Durham Local Plan Preferred Coal Authority - The County Durham plan has responded positively towards Options includes a Proposals Map which identifies the addressing the issue of coal mining legacy, the proposal to range of environmental sites and designations which cover the issue in the Core Strategy DPD through a possible are constraints on all mineral working. The Interactive Sustainable Development Policy is supported. The Coal Proposals Map include a link to the Coal Authority Authority also supports the recognition that further guidance website where coal mining legacy information can be will then be set out in the emerging Development viewed. Management DPD and it will be taken into account in the allocation process for all non-mineral sites in the Allocations DPD. G K Wilson Regarding Question 6 we feel that a constraints based The County Durham Local Plan Preferred Options Derwentside Valley Protection approach would possibly discourage some of the most includes a Proposals Map which identifies the range of Society damaging planning applications. We also believe that in order environmental sites and designations which are to take care of cumulative impact a 5 year moratorium needs constraints on all mineral working. to be implemented to run between final restoration of one site and a further site in a general area. Regard needs to be In planning for minerals we will consider the need for a taken on Government Policy, albeit unwritten, that no cumulative impact policy in the Minerals and Waste opencast mining should be allowed in the Derwent Valley. Policies and Allocations document. This policy has been in operation since 1970 and

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Respondent Question 6 - Application of a constraints based approach Council Response consequently 9 out of 9 applications have been dismissed We note the concern and opposition to further coal on Appeal. The Planning Authorities were Durham, mining in the Derwentside Valley. In planning for coal Gateshead and Northumberland. The Secretary's of State we are having regard to national policy. Neither national who signed the dismissal notices were as diverse as Tony policy or the existing Minerals Local Plan states that no Benn and Nicholas Ridley. opencast mining should be allowed in the Derwent Valley.

Mr Bryan Huntley Disagree that there are no realistic alternative strategies for Comments noted. However, the Council is required to Darlington Borough Council surface mined coal extraction other than to plan in plan in accordance with national policy as set out in the accordance with the requirements of national policy as set NPPF. out in MPG3.The present Government has made it clear that it is in favour of democratic local decision making that reflects Paragraph 2.24 of the Technical Consultation Report the local area's vision. The Localism Bill sends a clear signal "Energy Minerals" addresses the subject of local that local authorities can respond to local needs. Therefore, landscape designations, it states that "We discounted the previous approaches to surface mined coal, based on the option of a 'no-go area' approach based upon local landscape designations and "no go areas", would be landscape considerations because this type of approach acceptable. would not be consistent nor accord with the the provisions of national planning policy guidance as set out in MPG3 and can not be now justified on landscape grounds. In this respect PPS7 is particularly important as it advises against the retention or expansion of local landscape designations and instead suggests utilising tools such as landscape character assessment. In this respect the Council now has a detailed Landscape Strategy based upon a detailed Landscape Character Assessment which would enable landscape character to be addressed through a development management policy.

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Question 7 - Conventional Oil and Gas Development

Oil and Gas - Taking into account the available evidence we do not believe that there is a need to address conventional oil and gas development in the County Durham Plan. Do you agree or disagree? (If you believe that there is a need for such policies please explain why).

Respondent Question 7 - Oil and Gas Council Response Comments noted. We have chosen not to address conventional oil and gas development in the Preferred Options for the County Durham Plan. Conventional Agree that the evidence suggests that there is no need to oil and gas development will be addressed in the Mr Bryan Huntley address conventional oil and gas development in the County Minerals and Waste Policies and Allocations Darlington Borough Council Durham Plan document.

Question 8 - Coal Bed Methane

Coalbed Methane - Taking into account the available evidence we do not believe that there is a need to address CBM development in the County Durham Plan. Do you agree or disagree? (If you believe that there is a need for such policies please explain why).

Respondent Question 8 - Coalbed Methane Council Response Mr Bryan Huntley Agree that the evidence suggests that there is no need to address coal Comments noted. Darlington Borough bed methane in the County Durham Plan Council Miss Rachael Bust Comment/Support - The Coal Authority acknowledges that there are no Comments noted. A policy will be developed to Coal Authority Coal Bed Methane licences issued in County Durham, nor are there any support UCG and all emerging coal technologies current proposals for Coal Mine Methane or Abandoned Mine Methane including CBM, CMM and AMM in the Minerals and Waste Policies and Allocations document.

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Respondent Question 8 - Coalbed Methane Council Response The Council acknowledge that there is a need for flexibility to address Underground Coal Gasification even though at present the only UCG licence is off-shore at Sunderland. The Council therefore propose a policy to address UCG in the Minerals and Waste Policies and Allocations DPD because of the longer term potential across the North East. The Coal Authority would support such a policy approach; however this policy could address all emerging coal technologies including CBM, CMM and AMM in addition. This would allow suitable flexibility for these emerging technologies which are likely to grow over the plan period to be planned for given that new licensing is occurring all the time and the potential for where such proposals may be technically feasible may also change over the plan period.

Question 9 - Methane from Coal Mines

Methane from Coal Mines. Do you agree that there is no need to prepare specific policies on abandoned mine methane and coal mine methane in the County Durham Plan?

Respondent Question 9 - Methane from Coal Mines Council Response Mr Bryan Huntley Agree that the evidence suggest that that there is no need to prepare specific Support noted. Darlington Borough policies on abandoned mine methane and coal mine methane in the County Council Durham Plan Miss Rachael Bust Comment/Support - The Coal Authority acknowledges that there are no Coal Support noted. Coal Authority Bed Methane licences issued in County Durham, nor are there any current proposals for Coal Mine Methane or Abandoned Mine Methane. The Council acknowledge that there is a need for flexibility to address Underground Coal Gasification even though at present the only UCG licence is off-shore at Sunderland. The Council therefore propose a policy to address UCG in the Minerals and Waste Policies and Allocations DPD because of the longer term potential across the North East. The Coal Authority would support such a policy

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Respondent Question 9 - Methane from Coal Mines Council Response approach; however this policy could address all emerging coal technologies including CBM, CMM and AMM in addition. This would allow suitable flexibility for these emerging technologies which are likely to grow over the plan period to be planned for given that new licensing is occurring all the time and the potential for where such proposals may be technically feasible may also change over the plan period.

Question 10 - Underground Coal Gasification

Underground Coal Gasification - Do you agree that the Minerals and Waste Policies and Allocations DPD should set out a decision making framework to determine planning applications for UCG development?

Respondent Question 10 - Underground Coal Gasification Council Response Mr Bryan Huntley Agree that the evidence suggests that the Minerals and Waste Comments noted. Darlington Borough Policies and Allocations DPD should set out a decision making Council framework to determine planning applications for underground coal gasification development. Miss Rachael Bust Comment/Support - The Coal Authority acknowledges that there Comments noted. Coal Authority are no Coal Bed Methane licences issued in County Durham, nor are there any current proposals for Coal Mine Methane or Abandoned Mine Methane. The Council acknowledge that there is a need for flexibility to address Underground Coal Gasification even though at present the only UCG licence is off-shore at Sunderland. The Council therefore propose a policy to address UCG in the Minerals and Waste Policies and Allocations DPD because of the longer term potential across the North East. The Coal Authority would support such a policy approach; however this policy could address all emerging coal technologies including CBM, CMM and AMM in addition. This would allow suitable flexibility for these emerging technologies which are likely to grow over the plan period

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Respondent Question 10 - Underground Coal Gasification Council Response to be planned for given that new licensing is occurring all the time and the potential for where such proposals may be technically feasible may also change over the plan period.

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Question 1 - Revised Criteria for identifying Strategic Sites

Strategic Minerals and Waste Sites - We would welcome your views on our revised criteria for identifying strategic minerals and waste sites?

Respondent Question 1 - Strategic Minerals and Waste Sites - We would welcome your views Council Response on our revised criteria for identifying strategic minerals and waste sites

Trustees Langley In respect of the deliverability of sites, careful thought needs to be given in the current We understand the argument as made, however, given Estate market to whether you should insist on having a committed operator at this stage. Our that strategic allocations are central to the delivery of experience elsewhere is that it is extremely difficult to get an operator to commit to a the strategy it is important that they are deliverable site without waste contracts in place. Those placing waste contracts are unwilling to and are able to be relied upon. It is important to place them for a plant which is not yet built let alone one which is not allocated. We recognise that not all waste development needs to be agree that the site must be capable of delivery but that must be viewed in the context first allocated in the Plan. The criteria based approach of the current economic climate and the lengthy chain of contractual relationships which taken in policy 62 of Preferred Options is based on the need to be created to commit an operator to a site. combination approach preferred by respondents, providing flexibility in the absence of suitable strategic waste sites.

Mr Bryan Huntley Agree with the revised criteria for identifying strategic minerals and waste sites, but Agreed change to be made to bullet 3, bullet to read, Darlington Borough should the third bullet refer to the "agreement of the landowner and the owner of the "Sites need to be deliverable e.g. A committed operator Council mineral rights", as the two are not always the same person. with the agreement of the landowner and the owner of the mineral rights."

Mr David Brewer CoalPro accepts that potential coal sites are not strategic in terms of the definition Acceptance that potential coal sites are not strategic adopted but considers that they should be considered as 'strategic' in the wider sense is noted. No change made. The Preferred Options Confederation of UK to the UK as a whole. Any coal not produced in the UK, including from Co. Durham, outlines our approach in policy 56 'Surface Mined Coal Coal Producers will have to be imported, with consequent loss of economic benefit to the UK, including and Fireclay'. (COALPRO) to Co. Durham, and higher overall carbon emissions.

Mr Kyle Maylard As identified within the appendix to this document, the Agency provided responses to Comments noted. However, minerals can only be Highways Agency the Minerals and Waste components of the Core Strategy, in relation to overall minerals worked where they occur. In considering site and waste spatial policy and the strategic minerals and waste sites. The principles of allocations views have been sought from the Council's those comments can be transferred to those sites identified within this document. In Highways Development Control Team. For sites summary those comments highlighted that:

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Respondent Question 1 - Strategic Minerals and Waste Sites - We would welcome your views Council Response on our revised criteria for identifying strategic minerals and waste sites

Site section criteria should include reference to locating sites in accessible locations; allocated in the Preferred Options a planning application will need to be made which includes a Consideration should be given to the need for significant developments to be supported transport assessment. by Transport Assessments and would wish to see demand management measures implemented.

Irrespective of the classification of a site as "strategic" in the Core Strategy or elsewhere in a separate DPD, the Agency would wish full consideration to be given to the transport implications of individual sites and the cumulative impact of the whole plan.

The Agency appreciates that section 9 of the document sets out some of the considerations that will be given when further considering the sites. Included in these elements of appraisal is the impact on the strategic transport network and an appraisal of the cumulative impact. The Agency supports such appraisal and will utilise the findings of this to provide more detailed comments in relation to the impacts at the SRN.

Mrs Susan Carmedy The Parish Council agrees with the principles of the document and the criteria for Support noted. The criteria based approach taken in Brandon & Byshottles allocation of strategic waste sites. The Council particularly would welcome site(s) with policy 62 of Preferred Options is based on the Parish Council anaerobic digestion plants such as that proposed for Langley Park North Industrial combination approach preferred by respondents, Estate. New technologies should be embraced as they developed. providing flexibility in the absence of suitable strategic waste sites.

Mr Lee Weatherall In light of additional information now supplied on how strategic sites will be identified Agreement with strategic site criteria and agreement ATH Resources and why (para 3.11), ATH Resources agree with the revised criteria for strategic sites. to consider Pittington North, Pittington South and Eldon As such, they advise that they no longer wish to see their submitted sites at Pittington Blue House as non-strategic sites noted. North, Pittington South and Eldon Blue House considered as strategic sites. Paragraph 5.21 states that there are concerns over the deliverability of the of both the Eldon Blue Comments in relation to deliverability noted. The House and Pittington North sites. At Eldon Blue House there are concerns over whether Council will consider these sites once work to prepare the site could be worked in relation to the planning permission to work brick making the Minerals and Waste Policies and Allocations DPD materials at Eldon. As mentioned in our original submission on the Eldon Blue House commences. The Council has reconsidered its site, ATH Resources believe that the proposed workings here could be worked in timescale for future work following the publication of partnership with the brick making material operations, or if no agreement can be reached the draft National Planning Policy Framework. with the operator of this, then there is scope to work the coal without affecting these operations. ATH Resources has subsequently been in discussions with Wienerberger over this issue and potential schemes to work the site either in conjunction, or separately with them, have been discussed and evaluated. Negotiations are still ongoing with regard to these schemes but if the two sites were to be worked in conjunction it is likely

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Respondent Question 1 - Strategic Minerals and Waste Sites - We would welcome your views Council Response on our revised criteria for identifying strategic minerals and waste sites

that points of access and certain pieces of infrastructure and facilities could be shared between the two operators. If they were to be worked separately the Eldon Blue House boundary and amount of resources may have to be amended slightly but this would not necessarily affect the viability of the proposals. Separate access and operational/welfare facilities could be provided with access to the A696 to the north. At Pittington North, ATH Resources have secured the long term rights to the underlying minerals via a lease agreement on the land they have submitted and have been in negotiations with the landowners concerned. They are aware of UK Coal's interest in some of the site (their Field House submission) but are not aware of any implications of this at the present time which would currently prevent them from working the site. They consider that all submitted sites will have a degree of uncertainty about them at this submission stage and that the fact they have secured the minerals lease and have been discussing the proposals with the landowners should provide sufficient clarity on deliverability at this time. This is in accordance with the information provided in paragraph 7.3.

Mr Lee Weatherall Chapter 8 With regard to the call for new sites made in Chapter 8, ATH Resources Comments noted. If further additional sites are ATH Resources have no sites which they wish to submit at this time but do wish to make you aware submitted to be considered as allocations they will be that there are potential sites within County Durham which they are currently considering. considered via the Minerals and Waste Policies and I understand that no timetable is currently in place for receipt of any new sites or their Allocations DPD. The Council will keep ATH Resources analysis and I would be grateful to be kept informed of any decisions which are made informed of the timetable of all future documents. on the timetable for this work. This will allow ATH Resources to make a decision as to whether they will progress with the submission of any other sites.

Mr David Atkinson Further Consultation on Criteria for Strategic Sites - Section 3 Lafarge welcome the Comments noted. Lafarge Aggregates Ltd general approach set out in the consultation document with regard to Thrislington Quarry; in particular, the continued allocation of the Eastern and Southern Extensions The planning permission for the eastern extension to until such time as planning permission is issued for the Eastern Extension. Thrislington Quarry east of the A1(M) was issued in July 2011. Accordingly the Council will not now Once permission has been issued, Lafarge agree that the Eastern Extension area is consider the eastern or southern MLP allocations as to be removed from the Plan whilst at the same time not pursuing the allocation of the County Durham Plan allocations. Southern Extension. Nevertheless, paragraph 3.5 states that 'Lafarge Aggregates Ltd' suggested that both the basal Permian sand resources within Thrislington Quarry and Factual error noted related to sand. the eastern extension to Thrislington Quarry should be considered as strategic until such time as planning permission is issued. The existing area of working at Thrislington Quarry is subject to an extant planning permission which runs This statement is factually incorrect. The basal Permian sand resources are not related to 2015. The existing permitted reserves within the to the planning permission for the Eastern Extension to Thrislington Quarry. As such, existing area of working are recognised as an important they should be regarded as a strategic resource in their own right irrespective of the

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Eastern Extension and its pending planning permission. Furthermore, a distinction may component of the County Durham's sand and gravel need to be made between the permitted basal Permian sand reserves, as revised by landbank and are required to meet needs over the plan Lafarge, and the additional basal Permian sand resources identified within the existing period to 2030. operational quarry area. In paragraph 3.10 it is noted that the reserve estimates can be updated following the submission of further information by Lafarge. Lafarge endorse The Council will consider the need for the basal the criteria for sand and gravel strategic sites i.e. they potentially comprise 15 years permian sand reserves at Thrislington to be recognised supply, can supply 150 000 tonnes per annum and contain over 2.5 million tonnes of as a strategic site. reserve. The existing and potential reserve at Thrislington Quarry meets these criteria. As requested we will make a distinction between the Question 1 (Views on Revised Criteria for Identifying Strategic Minerals and Waste permitted reserves in the existing consented Sites) permission, as one strategic site, and we will also consider the additional unpermitted reserves as a Strategic Minerals Sites Following on from the above, Lafarge supports the revised second strategic site. criteria for identifying strategic minerals sites and the revised definition of strategic minerals sites. With respect to the subsequent text we endorse the approach to the In considering our approach to future sand supply and Eastern Extension at Thrislington and we will review our position once the planning strategic sites we will need to consider the scale of permission is issued. We endorse the need to allocate strategic sites for sand and permitted and unpermitted potential reserves at gravel and put forward the basal Permian sands at Thrislington as a strategic allocation. Thrislington Quarry and the contribution that each could make to ensuring a steady and adequate supply 4.2.2 Strategic Waste Sites Although Lafarge generally support the revised definition of sand. In addition we must also consider residual of strategic waste sites with the following caveats: Inert/ construction and demolition need over the plan period, taking into account the scale waste is not considered within the potential for strategic sites. This waste stream of permitted reserves of sand, the productive capacity accounts for a significant proportion of arisings within the County and needs to be of individual sites and the details and end date of considered along with other waste streams; Further explanation and/ or clarity is sought existing permissions. as to what is meant by "any proposal which would manage 25% or more of a total waste stream"; at the allocation stage we are often looking at general potential we may The document itself in the Sustainability Appraisal not have a clear idea of technology, throughput and so on. The waste streams would Recommendation and Reasoning acknowledges that also need proper definition. Would it not be more appropriate to consider general land 25% of a total waste stream could be restrictive and available, strategic sites would need to be a specific hectarage for example. accepts that it needs to be flexible. The Council would require more information than merely the size of a site, in order to assess its suitability against the criteria. The EA have produced guidance which gives rough hectarage for differing waste technologies and this would give a rough idea of the type of technology a site would be able to accommodate. Size alone is not sufficient to allocate a potential strategic site. Details of the potential technology(ies) and waste streams taken would be required. It is not considered possible

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to make an allocation for a strategic waste site at Thrislington Quarry at this stage in the Plan. The approach taken in Preferred Options policies 61 (Waste Management Provision) and 62 (Location of New Waste Facilities) provides a flexible approach to providing for new capacity in the absence of a strategic waste site.

G Gibson It is appreciated Durham County Council over the years has had a better track record Comments noted in relation to the County Council's CPRE than some of restoring sites and monitoring resources and their quarrying and we trust track record. the authority will continue its good work. The Council has sought to develop a measured Attached is comment from C.P.R.E. Co Durham Branch. approach to surface mined coal which is line with current national policy and which provides certainty In addition we would like to make the following general comment: We have a to both the industry and the public on the matters upon responsibility to make best use of our precious resources many of which are nationally, which planning applications for minerals working will if not internationally, important, so best use can be made of them. This must be done be determined. taking into account the residential amenity of those in the areas involved and the effect on the landscape. What is important is there is a measured approach and clear policy Request for the consideration of freight access noted. on the County's resources which is fully transparent and fully consulted. The ability to This requirement is implicit as part of consideration of comment at the various stages is appreciated. Criteria for strategic sites should include the environmental impacts of mineral extraction. It is assessment for freight access. Recommendations to Co Durham LTP3 include the envisaged that the minerals related transport policies need to identified preferred freight routes (through the Tyne & Wear Freight Partnership will require consideration of a range of matters or similar), and the sites need to be well located in relation to these routes. A clear including movement by rail and strategic lorry routes. preference for rail rather than road access to strategic sites should be expressed. And In addition we will consider the approach to road to value to and integration with the existing road and rail transport networks (beyond the rail mineral handling facilities including the life of the development) should be a consideration for any new infrastructure. If there safeguarding of permanent facilities. is no need or connection, then the transport infrastructure should be removed as part of the remediation programme. Note these transport considerations apply to both In considering any requirement for the rail minerals extraction, waste landfill and anaerobic digester sites. Remediation might transportation of minerals the limited potential for the sensibly include other uses for a worked site appropriate to the location (and needs of movement of minerals by rail should be noted. This is the local community) beyond environmental enhancement or landfill. Para 1.4 This due to the limited rail infrastructure in County Durham. paragraph outlines, we think, a 2 level approach to allocating new minerals and waste sites, splitting policy between the 'Core strategy' and a separate 'Minerals and Waste The restoration of mineral sites to appropriate high Policies and Allocations DPD'. This seems confusing and splits consideration of the quality after uses is noted. topic between strategic and non-strategic sites, however they are defined. Is the latter to be an extension of the former? In our opinion there is room for confusion at the

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moment. Q1 - There is an apparent logic in the criteria and the fact that only certain The approach of the plan is to only consider strategic minerals which occur in sufficient quantity can be the subject of strategic sites. However, sites in the Local Plan. Other sites will be considered perhaps some clear criteria are required to show how applications for non strategic in the Minerals and Waste Policies and Allocations sites (such as at Old Quarrington) will be considered vis a vis strategic sites. C.P.R.E. DPD. welcomes the fact that no opencast site is to be regarded as 'strategic' in Co Durham, but is now aware that an application has in fact been made in respect of the Pittington It should be noted that no coal application has yet to area. be made in the area of Pittington (correct as August 2011).

Natural England General comments on potential minerals and waste site allocations: The Council will have full regard to the comments made relating to the identified non-strategic sites as part of Extension to Bishop Middleham Quarry work on considering non-strategic allocations.

The site is within 200m of the Bishop Middleham Quarry SSSI. In considering the Draft Method for the appraisal of strategic and proposed allocation, the assessment needs to take into account any potential impacts non-strategic minerals and waste sites. These on the conservation objectives of the SSSI. comments have been taken into account in our appraisal methodology. Washpool Craggs, Bolihope Burn in Weardale

This site is within the North Pennines Moors Special Area of Conservation and Special Protection Area and Bollihope, Pikestone, Eggleston and Woodland Fells Site of Special Scientific Interest. These sites are protected for a number of reasons, notably acid grassland, blanket bog and heathland as well as breeding raptor and wading bird species. In considering the proposed allocation the assessment needs to take into account any potential impacts on the conservation objectives of the North Pennines Moors Special Area of Conservation and Special Protection Area and Bollihope, Pikestone, Eggleston and Woodland Fells Site of Special Scientific Interest through both the SA and HRA process (not just the HRA process). In addition the site is within the North Pennines AONB, the LPA needs to consider any potential significant adverse impacts on the special qualities of the AONB, taking into consideration the objectives of the North Pennines AONB management plan.

Extension to Coxhoe Quarry (formally known as Raisby), 2km north west of Trimdon, 1km east of Coxhoe and 9.5km south of Kelloe

Trimdon Limestone Quarry SSSI lies close to/slightly within the site boundary. The site also includes the Raisby Way and Trimdon Grange Quarry Local Nature Reserve. In considering the proposed allocation, the assessment needs to take into account any

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potential impacts on the conservation objectives of the SSSI. Area of Search for sand and gravel at Hummerbeck. There is a local wildlife site within this area of search. The site is particularly important for its water fowl and changes to hydrology and disturbance would be detrimental to the ecological integrity of this site. Any allocation should be sensitive to the ecological importance of the site locally and seek to mitigate/compensate for any impact caused.

Bradley, 3km east of Consett and 1km from Leadgate

There is currently a planning application with the County Council for this site. Please note our previous responses to the planning application for this site (letters dated 5 February 2008 to 26 July 2010 plus additional matters to date).

Marley Hill, south west of Marley Hill and south east of Byermoor

This site is close to Causey Bank Mires SSSI, and includes an area of Ancient Semi-natural woodland. In considering the proposed allocation, the assessment needs to take into account any potential impacts on the conservation objectives of the SSSI and on the ancient semi natural woodland.

Broadwood Quarry, near Frosterley

Please note this proposed allocation lies adjacent to the North Pennines AONB. The LPA needs to consider any potential significant adverse impacts on the special qualities of the AONB, taking into consideration the objectives of the North Pennines AONB management plan.

Draft Method for the appraisal of strategic and non-strategic minerals and waste sites: Page 61/62 Paragraph 9.3

- Biodiversity and Geodiversity - this list needs amending to read : European protected species and National BAP priority habitats and species; Derwent Valley and Pennine Fringe Integrated Biodiversity Delivery Area Project.

- Landscape - this should also add Durham Heritage Coast.

- Land and Water - this should also consider National Trails and open access land.

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Page 63 Restoration - this should also consider the County Durham Green Infrastructure Strategy and Derwent Valley and Pennine Fringe IBDA management plan once it is published.

Ms S Wickerson Section 3, Question 1. The criteria for assessing strategic sites, particularly waste sites, Support noted to the criteria for assessing strategic Environment Agency seem quite appropriate. sites.

We welcome the reference to generating energy from waste but ask you to consider The future approach to waste management including whether a more general reference to the waste hierarchy, including heat recovery and the use of the Waste Hierarchy is set out in the recycling in general, would be more relevant. Preferred Options, which also sets out the approach to landfilling and landraise in policy 63. We are aware Section 4 considers the proposed strategic mineral sites. We ask that, in considering of the issue raised in relation to inert waste and their designation, the Authority addresses not only the impact of the extraction and landfilling. We recognise that there is significant processing operations on the environment but also their subsequent restoration. That inert/construction and demolition void space already is, whether the operator has a practicable proposal to restore the site to an acceptable available in existing inert landfill sites. At the end of profile given the likely restrictions on landfill and groundwater protection requirements, 2010 we identified that 7,882,000 tonnes of capacity particularly in the East Durham Limestone Delivery Area. We have reason to believe remained. In these circumstances and in the context that there are not large quantities of inert waste available to restore these sites, and of the need for a step change in the quantity of inert that some restoration plans have been delayed as a result. waste to be reused and diverted from landfill there is no additional requirement for new inert capacity in When considering the feasibility of restoring these site, the above should be taken into County Durham. account. Site specific comments: Todhills Brickworks, Heights Quarry, Washpool Craggs, Bishop Middleham Quarry, Witch Hill, Cornforth Quarry, Coxhoe Quarry, Low In considering proposals for new minerals and waste Harperley, Hummerbeck, Bradley, Castle Dene / Hurbuck, Randolf, Marley Hill, Field sites consideration will be given to the approach House, Eldon Blue House, and Broadwood Quarry We have no objection to the inclusion proposed by the prospective operator to restoration. of the proposed sites as a preferred option. Abstraction for dewatering purposes in The emerging approach of the County Durham Plan mines, quarries and engineering works can have unacceptable impacts on environmental requires high quality and prompt restoration which features supported by groundwater, for example, wetlands, watercourses, ponds or delivers environmental benefits. may derogate existing protected licensed water supplies, or lead to deterioration of in groundwater quality. In order to assess the potential impacts from the works proposed Following the adoption of the County Durham Plan we request that the a hydrogeological risk assessment (HRA) forms part of any planning applications will be determined on the basis subsequent planning application. As part of the HRA, the site operator should assess of the new policies of the County Durham Plan. and address the risks posed to all ground and surface water resources (quality and Appropriate planning applications will require a flow) within the vicinity of the site. If any of the identified risks can not be sufficiently hydro-geological risk assessment. We are currently mitigated the proposals may be deemed unacceptable. Additional Comments for Randolf undertaking work to draft new development The site includes a length of Oakley Cross Beck, which is prone to flooding and there management policies and will consider whether we are severe flood problems immediately downstream. In principle no objections from a should specifically require a hydro-geological risk assessment.

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flood risk viewpoint, but we will require conditions relating to surface water controls at a later stage. The development should consider opportunities to reduce this existing problem if possible.

Mrs Margaret Forster Coxhoe Parish Council has no comments to make on the Proposed new Minerals and Noted. Coxhoe Parish Council Waste Sites Consultation Document

Mr Michael Hodges We note the Council's revised criteria for identifying strategic minerals sites and agree Support for strategic site criteria noted. Sherburn Stone Co Ltd with the intended approach. The Council does not consider the proposed mineral With regard to Carboniferous Limestone, it should be understood that the proposal to processing hub at Broadwood Quarry to be strategic. allocate the processing plant at Broadwood Quarry as a central processing point is to It is not in itself fundamental to the delivery of the facilitate the processing of Carboniferous Limestone extracted from abandoned, County Durham Plan. Nevertheless this proposal un-restored sites in and around the North Pennines AONB. These are usually visually together with proposal to work Washpool Crags in the intrusive and often dangerous. Restoration would be costly and is unlikely to occur North Pennines will be considered via the Minerals and unless funded through limited mineral extraction. The principal therefore is to undertake Waste Policies and Allocations DPD. a rolling programme of mineral extraction and restoration at a number of such sites with the mineral being transported 'as dug' to Broadwood Quarry for subsequent processing to eliminate the impact of crushing and screening on site. Whilst each individual site would intentionally be worked and restored over a short timescale, say 4 to 5 years, to minimise impact on the local environment, the combined timescale of the programme of sites to worked and restored would potentially exceed 15 years with the overall volume of mineral recovered undoubtedly making a significant contribution to meeting the forecast need for Carboniferous Limestone.

Ms Janice Brabban In general, we would agree with Durham County Council's revised criteria. In particular, Support for strategic site criteria noted. Durham County Badger we would not like to see surface mined coal sites being designated as strategic, and Group would prefer them to be considered by the submission of a planning application by the As stated in the consultation paper, surface coal sites operator at the time. In this way, environmental information would be more up-to-date are not to be considered as strategic, they will either and comprehensive, relying more on recent fieldwork rather than desk studies. However, be considered first as an allocation followed by a we would also request that in considering effects on the environment and wildlife, the planning application or by a planning application. cumulative effects of current or recent mineral extraction in adjacent areas be also Planning applications will be accompanied by taken into account, rather than looking at each application in isolation. Some areas environmental statements. within the county have been subjected to repeated upheaval due to mineral extraction, resulting in loss of bio-diversity which restoration plans does not always correct.

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Until the policies of the new County Durham Plan are adopted all planning applications will be determined against the saved policies of the County Durham Minerals Local Plan.

Request for policy on cumulative impact noted, this will be developed as part of work to prepare the Minerals and Waste Policies and Allocations DPD.

Question 2 - Strategic Site at Todhills Brickworks

Area of Search at Todhills Brickworks - Please use this question to make any comments on this strategic site proposal.

Respondent Question 2 - Area of Search at Todhills Brickworks - Please use this question Council Response to make any comments on this strategic site proposal.

Mr Bryan Huntley Question the approach to allocate a single site as an "Area of Search". Surely the Comments noted. The term Area of Search originated Darlington Borough point of an Area of Search is that there are several potential sites in different from the extant Minerals Local Plan Allocation. Council geographical locations which would perform differently when assessed against the criteria for identifying strategic minerals sites. Having identified an Area of Search, the next question would be: "Which site(s) should be identified as a strategic minerals site"? The only appropriate question at Todhills Brickworks is: "Should this site be allocated as a strategic site for brick clay and shale extraction"? On the Council's own evidence, the answer would be "Yes".

Mrs G Gibson While acknowledging the existence of such works already in this area, it is close to Comments noted. CPRE the deep valley of the River Wear here. C.P.R.E. notes the proposals and feels it has to accept them, but would wish to emphasise that every effort has to be made to protect views from and over the valley.

Ms S Wickerson We have no objection to the inclusion of the proposed site as a preferred option. Comments noted. Environment Agency Abstraction for dewatering purposes in mines, quarries and engineering works can have unacceptable impacts on environmental features supported by groundwater,

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Respondent Question 2 - Area of Search at Todhills Brickworks - Please use this question Council Response to make any comments on this strategic site proposal.

for example, wetlands, watercourses, ponds or may derogate existing protected A hydrogeological risk assessment (HRA) will be required licensed water supplies, or lead to deterioration of in groundwater quality. In order as part of any subsequent planning application. The site to assess the potential impacts from the works proposed we request that a operator will be required to assess and address the risks hydrogeological risk assessment (HRA) forms part of any subsequent planning posed to all ground and surface water resources (quality application. As part of the HRA, the site operator should assess and address the and flow) within the vicinity of the site. risks posed to all ground and surface water resources (quality and flow) within the vicinity of the site. If any of the identified risks can not be sufficiently mitigated the proposals may be deemed unacceptable.

Miss C Kinnear Despite the plan to restore this site to agricultural land, BAP habitat can also be Comments noted. RSPB incorporated. For example, native species hedges, ponds or areas of neutral grassland could be included, as suggested within your restoration approach for the Mineral Delivery Areas. Brickworks have previously been restored to wetland habitat, an opportunity which is not common in the county. This site presents a valuable chance to contribute to the BAP habitat creation targets by creating wetland, for example reedbed. The suitability of this opportunity should be investigated by the council.

Question 3 - Strategic Site at Low Harperley

Low Harperley - Please use this question to make any comments on this strategic site proposal.

Respondent Question 3 - Low Harperley - Please use this question to make any Council response comments on this strategic site proposal.

Mr Bryan Huntley Agree that, subject to the results of further Sustainability Appraisal As a result of a member resolution to grant planning permission Darlington Borough assessment, Low Harperley should be allocated as a strategic site for on a planning application for sand and gravel extraction in July Council sand and gravel. 2011, this strategic site allocation will be considered no further. Planning permission is expected to be issued in the next few months.

Ms G Gibson It is noted a planning application has been submitted and this site is The Consultation Paper 'Towards a Minerals Delivery Strategy in CPRE designated as a Mineral Consultation Area. We think the split between County Durham' (December 2010) set out our calculations and sand and gravel should be clarified and also the type of sand. The reason forecast for residual need for further sand extraction over the plan for this is the application for sand extraction at Old Quarrington, also period to 2030. While these calculations were later revised to take

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Respondent Question 3 - Low Harperley - Please use this question to make any Council response comments on this strategic site proposal.

expected to last some 15 to 20 years. Are both sites needed? If this site into account new information from operators on the extent of proceeds, is there any need for extraction at the Old Quarrington site, permitted reserves at existing sites significant further new working which has not been identified as a strategic site? This site is in an was needed. extremely attractive area. I note the issues re transport. If this site is, despite its attractive location, deemed acceptable, is the nearby Weardale The member resolution to grant planning permission at both Low Railway a possible transport route (not mentioned in the consultation Harperley and Old Quarrington will help ensure that a steady and document, but of course the railway now has permission to transport coal adequate supply of sand and gravel is maintained over the plan from the approved site at Tow Law) period to 2030.

Natural England Low Harperley east of Wolsingham. Please note our previous comments As a result of a member resolution to grant planning permission on the planning application for this site letter dated 30th September 2009. on a planning application for sand and gravel extraction in July It is not clear why the intended approach suggests that 'we are minded 2011, this strategic site allocation will be considered no further. to allocate' when in paragraph 4.10 it states that a definitive Planning permission is expected to be issued in the next few recommendation has not been reached, due to additional Sustainability months. Appraisal work is required. Further detail should be provided on the additional SA work required.

Ms S Wickerson We have no objection to the inclusion of the proposed site "and As a result of a member resolution to grant planning permission Environment Agency Hummerbeck" as a preferred option. Abstraction for dewatering purposes on a planning application for sand and gravel extraction in July in mines, quarries and engineering works can have unacceptable impacts 2011, this strategic site allocation (Low Harperley) will be on environmental features supported by groundwater, for example, considered no further. Planning permission is expected to be issued wetlands, watercourses, ponds or may derogate existing protected licensed in the next few months. water supplies, or lead to deterioration of in groundwater quality. In order to assess the potential impacts from the works proposed we request that the a hydrogeological risk assessment (HRA) forms part of any subsequent planning application. As part of the HRA, the site operator should assess and address the risks posed to all ground and surface water resources (quality and flow) within the vicinity of the site. If any of the identified risks can not be sufficiently mitigated the proposals may be deemed unacceptable. Additional comments for Low Harperley and Hummerbeck: The proposal will result in major alterations to the existing hydrology and the flooding regime, and a flood risk assessment will be essential. Without a satisfactory flood risk assessment we may object under PPS25. With regards to gravel extraction, this can be a damaging process to watercourses both in terms of water quality and biodiversity. A large buffer should be kept between any extraction area and the watercourse. No

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Respondent Question 3 - Low Harperley - Please use this question to make any Council response comments on this strategic site proposal.

extraction should be permitted within the watercourse itself. Any proposal would need to be subject to the appropriate assessments and consents at the application stage.

Mr Michael Hodges We support the allocation of Low Harperley as a strategic site for the Support from proposer of site noted. Sherburn Stone Co Ltd extraction of sand and gravel.

Miss C Kinnear Should this site be allocated as a strategic site, we would welcome the As a result of a member resolution to grant planning permission RSPB delivery of BAP habitat. This area would be suitable for wet woodland on a planning application for sand and gravel extraction in July since this would complement other sites in the area. There is also potential 2011, this strategic site allocation will be considered no further. for the other parts of the site to contribute to BAP habitat targets, for Planning permission is expected to be issued in the next few example, by including native species hedges, ponds or areas of neutral months. grassland.

Councillor John I agree that, subject to the results of further assessment and consultation As a result of a member resolution to grant planning permission Shuttleworth with the local people, Low Harperley should be considered as a strategic on a planning application for sand and gravel extraction in July site for sand and gravel. However, it is important that through further 2011, this strategic site allocation will be considered no further. assessment work, the Council undertakes that it is satisfied this site is Planning permission is expected to be issued in the next few environmentally acceptable and can be worked and restored without months. damaging the environment or the tourist economy of Weardale. I would however support the creation of the jobs that this site would provide and the approach that is proposed to the sites after-use, the proposed fishing lakes and recreational lake for water sports would be good for the tourist economy.

Question 4 - Strategic Waste Allocation at Thrislington Quarry

Thrislington Quarry - Waste allocation - Please use this question to make any comments that you may have on either this strategic site proposal or the approach outlined above.

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Respondent Question 4 - Thrislington Quarry - Waste allocation - Please use this Council Response question to make any comments that you may have on either this strategic site proposal or the approach outlined above.

Mr Bryan Huntley Putting aside the potential impacts on protected wildlife habitats for the Comments noted. Darlington Borough moment, the Thrislington site appears to be a very sustainable site for waste Council management. Therefore, subject to the results of further Sustainability All allocations will be subject to Sustainability Assessment and Assessment and Habitats Regulation assessment, the Thrislington Quarry Habitats Regulation assessment. Further information has been should be allocated as a Strategic Waste site. submitted but does not allow an adequate assessment in order to demonstrate that any potential impacts or emissions from proposed waste operations at the site would not cause significant damage and undermine the integrity of the SAC, either alone or in combination with other plans and projects. It is not therefore considered possible to make an allocation for a strategic waste site at Thrislington Quarry at this stage in the Plan. The approach taken in Preferred Options policies 61 (Waste Management Provision) and 62 (Location of New Waste Facilities) provides a flexible approach to providing for new capacity in the absence of a strategic waste site.

Mr David Atkinson 4.3.1 Introduction The western part of the existing Thrislington Quarry is Further information has been submitted but does not allow an Lafarge Aggregates Ltd allocated as a potential location for the development of waste management adequate assessment in order to demonstrate that any potential facilities in the adopted Durham Waste Local Plan (Policy W58). Lafarge impacts or emissions from proposed waste operations at the strongly support the retention of this allocation so that Thrislington Quarry site would not cause significant damage and undermine the remains a strategic waste site in the emerging County Durham Plan and integrity of the SAC, either alone or in combination with other notably the Core Strategy. In addition, Lafarge is seeking to promote an plans and projects. It is not therefore considered possible to extension of the current WLP allocation to include an additional area of land make an allocation for a strategic waste site at Thrislington west of the C69. This would therefore include land around Thrislington Works Quarry at this stage in the Plan. The approach taken in Preferred (Steetley Dolomite) and include the wider landholding that includes the site Options policies 61 (Waste Management Provision) and 62 access and rail head (see enclosed figure Appendix A). It is likely that waste (Location of New Waste Facilities) provides a flexible approach development would be located adjacent to Thrislington Works and there are to providing for new capacity in the absence of a strategic waste opportunities to the north of the Works for example. The following provides a site. rationale for this approach: An extension would provide more flexibility to accommodate waste development. It would extend the allocation into what is essentially an industrial complex that in itself would be compliant with PPS10; Flexibility is important so that a range of waste technologies can be accommodated in optimum locations within the Thrislington complex (see below); There would be potential synergies with Steetley Dolomite's operations for example, opportunities may exist for any waste development to share some of the existing Steetley infrastructure to reduce potential cumulative landscape and visual amenity effects; It would allow the allocation to include

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the existing site infrastructure; It would allow the inclusion of sustainable transport options to and from the site. The potential for waste development at Thrislington Quarry to play an important role in managing future waste arisings in County Durham is recognised in paragraph 4.12 of the technical consultation document. Not only does Thrislington have a strategic advantage with its potential to accommodate significant capacity (e.g. 250 000 tonnes per annum) and a range of facilities, according to need, the site is located centrally in the county, in close proximity to the key centres of population and areas for planned future expansion; it also has suitable access to the strategic highway network and offers potential for the sustainable transport of waste using the rail network. Nevertheless, paragraph 4.12 sets out four issues that remain to be addressed, namely: The potential impact on the Thrislington Plantation SAC/ SSSI/ NNR through HRA; The potential impact on groundwater, particularly from any proposed landfill element; The compatibility of proposed waste facilities with permitted and proposed minerals operations at the quarry; and The potential impact of additional traffic generated as a result of the waste development proposal on the strategic transport network. These four issues are addressed below. 4.3.2 Waste Technologies and Types It is envisaged that the allocation including the extended area could accommodate the development of a strategic waste recovery facility, for example energy from waste including Advanced Thermal Treatment, Mechanical Biological Treatment and strategic recycling. The extended area in particular would offer energy from waste opportunities. The existing void could continue to provide opportunities for waste treatment including strategic recycling of both inert and non-hazardous waste (municipal, commercial and industrial), building upon existing activities. It would continue to also offer opportunities for inert infilling linked to an overall restoration strategy. The extended allocation would provide an opportunity to develop a Resource Recovery Park with the potential to play a strategic role in meeting the County's waste management needs. As such, the revised area should be allocated as a strategic waste site in the County Durham Plan and specifically in the Core Strategy. Non-hazardous landfill is not being promoted by Lafarge Aggregates at this time. This remains a longer terms option that would be dependent upon the operational requirements of the on-going quarry and restoration activity within the site. The following addresses locational issues associated with the proposed allocation and addresses the issues raised by the Issues and Options Paper. 4.3.3 Thrislington Plantation SAC, SSSI and NNR To the immediate south of the existing operational quarry is the Thrislington Plantation SAC.

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The site has been designated primarily because it contains the largest of the few surviving stands of CG8 Seslaria albicans Scabiosa columbaria grassland, which is confined to the Magnesian Limestone of County Durham and Tyne and Wear, north-east England. It now mainly found as small scattered stands. The site is characterised by heath, scrub, maquis and garrigue (5%), dry grassland (85%) and broad-leaved deciduous woodland (10%). The site is also a SSSI and NNR. The grassland was translocated from the north of the site as part of the quarry development and Lafarge has a management agreement with Natural England. The site is located immediately adjacent to the operational quarry and close to the other activities in the site including recycling and ready mix operations. It has thrived over the years and it is not considered that off-site impacts associated with any further waste development would not materially impact on the existing environmental baseline. This would apply to the following: Noise no particular species would be impacted by changes in the noise environment; Dust dust levels are unlikely to increase the main effects would be during construction. This can be mitigated by standard measures and waste operations (save any inert recycling and infilling) would be within buildings and would not generate effects. Any inert operations would not generate effects that would be materially different to existing quarrying operations; Surface and groundwater the site is not groundwater dependent and would not be affected by changes in surface water management. However, it is recognised that should waste recovery operations include thermal treatment then there would be the potential for off-site impacts due to emissions from any stack. For this reason Lafarge has completed an initial assessment that has focused particularly on oxides of nitrogen. This is attached as Appendix B. The model used in the assessment was the ADMS 4.2 advanced atmospheric dispersion model that has been developed and validated by Cambridge Environmental Research Consultants. The model has been used extensively throughout the UK for regulatory compliance purposes and is accepted as an appropriate air quality modelling tool by the Environment Agency and local authorities. For the purposes of the preliminary and generic assessment it was assumed that a facility would be located to the north of the existing Thrislington Works and would have a capacity of around 120 000 tpa. We used data for a generic plant based on Entec's experience of similar plants operating in the UK. The assessment concludes that for all of the receptor points within the Thrislington SAC, the process contributions towards total acid deposition rate are less than 1% of the minimum critical load for a 75m stack and, thus, can be regarded as

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insignificant. 4.3.4 Groundwater Lafarge recognise the importance of protecting groundwaters in the vicinity of the site. The Environment Agency 1:100 000 scale Groundwater Vulnerability Map shows the Magnesian Limestone and Yellow Sands to be Major Aquifers. Beneath the limestone the Coal Measures are identified as a Minor Aquifer. During the course of the previous inquiry into the extant Waste Local Plan, Lafarge successfully argued that non-hazardous landfill should not be specifically excluded from the allocation. This was on the grounds that mitigation could overcome any objections in principle from the Environment Agency - primarily through appropriate landfill design and engineering. In its position statement on the location of landfills with respect to groundwater protection, the Environment Agency actively discourages the location of landfill developments with a long term pollution potential in areas where water resources are particularly sensitive and appropriate risk assessments need to be undertaken. Whilst Lafarge believe these arguments could be successfully repeated again, as noted above the Company is not at this time promoting the site for non-hazardous landfill. It is unlikely that an area of the site could be identified in the short to medium term that could accommodate a non-hazardous landfill in view of the land area needed for the on-going quarry operations. However, there remains potential to dispose of inert materials on-site as part of the overall site restoration. These materials would not have the potential for pollution. With regard to other waste treatment operations within the quarry void dealing with non-hazardous waste, any development would have to be engineered so that run-off from the site is collected and properly attenuated. All areas for the storage and processing of waste would need to ensure that there would be no potential for sub-surface pollution. The measures to achieve this are standard and would not represent a design challenge. There would therefore be no material risk to the aquifers. 4.3.5 Relationship with Minerals Operations The advantage of extending the potential waste allocation west of the C69 is that it extends the area capable of accommodating waste treatment infrastructure, but also potentially removes an element of any Resource Park outside the main operational area. There will be on-going operations within the void and in view of the extent of permitted reserves it is likely that Lafarge will require an extension of time beyond 2015 to secure extraction of the remaining reserve. There will also be on-going transport movements to and from the Eastern Extension. Therefore it is recognised that any strategic waste management proposals would need to be closely linked with ongoing and any future minerals operations at Thrislington Quarry. It is also recognised that

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the development of waste management activities would impact on the restoration of the quarry as a development platform would be needed. However, restoration could easily allow for the potential development of waste facilities in accordance with a strategic waste site allocation by the grading of the area down to around 100 m AOD. The existing quarry could therefore accommodate built waste management infrastructure and on-going works and be structured and phased to ensure that this can happen. 4.3.6 Traffic Actual traffic levels associated with any waste development would depend on the nature of the development and the sources of waste arisings which will impact on the nature of the vehicles transporting waste. If we assume for example a 250 000 tonne per annum resource park and a combination of 20 tonne and 10 tonne vehicles, around 180-200 HGV movements could be generated per day. The advantage of a resource park however would be that vehicle movements could be reduced through facility integration for example residual materials from recycling and other forms of recovery could be processed through an on-site energy from waste facility as a fuel. The extant planning permission for the site, approved in 2002, does not impose a limit on traffic movements to and from the main site entrance onto the C69 (Entrance 1). It does place a limit at Entrance 2 onto Garmondsway Road: an average of 180 HGVs per day (based on a four-week period), or a maximum of 250 in any one day. The proposals for the Eastern Extension would ultimately see the closure of Entrance 2 and its replacement with a new entrance onto Stobbs Cross Lane. Higher purity limestone would continue to be transported to Steetley Dolomite through a new tunnel under the A1(M) and the existing tunnel under the C69. With regard to any waste development, access would be from the C69 and would not conflict with the export of construction aggregates from the Eastern Extension. The C69 is an unrestricted two-lane single carriageway running north to south, and is of adequate width to cater for HGVs. It has been upgraded over time and is primarily rural in nature with few residential properties fronting the carriageway. It continues past two roundabouts before joining the A177 dual carriageway. From here, traffic continues briefly along the A177 and then onto the A688, a wide single carriageway, before joining the A1(M) at Junction 61.

Ms G Gibson C.P.R.E. would not wish to make any comment over and above those already Noted. CPRE made

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Natural England Thrislington Quarry "Waste Management/Eastern extension/Southern Further information has been submitted but does not allow an extension/ extension to basal Permian sand extraction area" adequate assessment in order to demonstrate that any potential impacts or emissions from proposed waste operations at the In considering the proposed allocations at Thrislington Quarry, the assessment site would not cause significant damage and undermine the needs to take into account any potential impacts on the conservation objectives integrity of the SAC, either alone or in combination with other of the Thrislington Special Area of Conservation, Thrislington Plantation SSSI plans and projects. It is not therefore considered possible to and Thrislington NNR, through both the SA and HRA process (not just the make an allocation for a strategic waste site at Thrislington HRA process). In particular we would also welcome further details on the Quarry at this stage in the Plan. The approach taken in Preferred proposed waste operations and restoration plan/after uses planned for the Options policies 61 (Waste Management Provision) and 62 site from Lafarge Aggregates Ltd, in order for the local authority to accurately (Location of New Waste Facilities) provides a flexible approach assess all the various proposals under the HRA and SA process. Please note to providing for new capacity in the absence of a strategic waste our previous responses to the planning application for the eastern extension. site. (7 April 2006 and subsequent response 4 December 2006).

Ms S Wickerson Thrislington Quarry The applicant will need to apply for an Environmental Further information has been submitted but does not allow an Environment Agency Permit to carryout the intended waste management activities - recovery, adequate assessment in order to demonstrate that any potential recycling and composting. It is advisable that the applicant refers to the impacts or emissions from proposed waste operations at the Environment Agency's Position Statement for 'Composting and Potential site would not cause significant damage and undermine the Health Effects' . The EA will take into account before authorising any new integrity of the SAC, either alone or in combination with other composting facility located where the composting operations would be within plans and projects. It is not therefore considered possible to 250 metres of sensitive receptors. Before granting a permit the EA need to make an allocation for a strategic waste site at Thrislington be satisfied that the Site Specific Bioaerosol Risk Assessment shows that Quarry at this stage in the Plan. The approach taken in Preferred bioaerosols can and will be maintained at acceptable levels at the sensitive Options policies 61 (Waste Management Provision) and 62 receptors. Thrislington Quarry lies in a highly sensitive environmental setting (Location of New Waste Facilities) provides a flexible approach as the Magnesian Limestone principal aquifer underlies the site. In addition, to providing for new capacity in the absence of a strategic waste extraction of large amounts of sand and rock, through quarrying works, has site. removed protective drift deposits and the unsaturated zone of the aquifer. As such, we do not recommend the inclusion of Thrislington Quarry as a preferred option for the disposal of waste. If an application to dispose of waste at Thrislington were to be taken forward it is likely that we would only consider a proposal for the disposal of inert waste, not hazardous or non-hazardous. Any application to dispose of waste requires an environmental permit and must meet the requirements of our landfill location policy. For information, if it is proposed for any part of the waste to be deposited sub water table it is our policy to refuse the application.

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Miss C Kinnear We do not wish to comment on the strategic nature of the site. We approve Further information has been submitted but does not allow an RSPB of the council's intention to address the potential impact on the SAC. We are, adequate assessment in order to demonstrate that any potential however, concerned regarding the lack of a restoration plan for the site. The impacts or emissions from proposed waste operations at the restoration of the site should contribute towards BAP habitat targets, and site would not cause significant damage and undermine the complement the other sites of biodiversity interest in the area. In particular, integrity of the SAC, either alone or in combination with other restoration to magnesian limestone grassland would extend the existing habitat plans and projects. It is not therefore considered possible to forming the Thrislington Plantation NNR and help to buffer one of the most make an allocation for a strategic waste site at Thrislington important stands of this nationally scarce habitat. Further, such restorations Quarry at this stage in the Plan. The approach taken in Preferred would help to link the local sites of biodiversity importance. Should restoration Options policies 61 (Waste Management Provision) and 62 not be achievable (eg. due to lack of funding) or be more successful without (Location of New Waste Facilities) provides a flexible approach the addition of waste to the site, then this site should not be allocated as a to providing for new capacity in the absence of a strategic waste waste site. site.

Mr Mike Smith BMPC are concerned that the proposal for waste development at Thrislington Comments noted. The County Council are aware of the Bishop Middleham Quarry would be detrimental to the local area in a number of ways: a) It is Environment Agency's advice on the location of landfill Parish Council well known that a large aquifer lies underneath this site that supplies part of development on the Magnesian Limestone principal aquifer and the Hartlepool area with its domestic water supply. It is also well known that the issues surrounding the SAC/SSSI and NNR and in the lining of such a quarry to prevent seepage in to this water supply would combination effects with the existing workings and proposed prove extremely difficult due to the fissures and fractures experienced in a extension. limestone quarry. b) The potential detrimental impact on The Thrislington Special Area of Conservation/ Site of Special Scientific Interest and Thrislington Further information has been submitted but does not allow an Plantation National Nature Reserve and the surrounding countryside. c) The adequate assessment in order to demonstrate that any potential combination of extending the mineral workings to the East of the site, and the impacts or emissions from proposed waste operations at the development of the Strategic Waste site, will increase the flow of traffic through site would not cause significant damage and undermine the the local area to an unacceptable and dangerous level. integrity of the SAC, either alone

or in combination with other plans and projects. It is not therefore considered possible to make an allocation for a strategic waste site at Thrislington Quarry at this stage in the Plan. The approach taken in Preferred Options policies 61 (Waste Management Provision) and 62 (Location of New Waste Facilities) provides a flexible approach to providing for new capacity in the absence of a strategic waste site.

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Mr Thomas Baker Waste Allocation Further information has been submitted but does not allow an Natural England adequate assessment in order to demonstrate that any potential The rudimentary analysis of the air pollution associated with a generic facility impacts or emissions from proposed waste operations at the of the type proposed would seem to suggest that the impact in terms of site would not cause significant damage and undermine the eutrophication and acid deposition on the SAC/SSSI would be insignificant. integrity of the SAC, either alone or in combination with other plans and projects. It is not therefore considered possible to Table 4.5 of Appendix B would only seem to consider critical load in terms of make an allocation for a strategic waste site at Thrislington nitrogen acidification, rather than in terms of the functional relationship between Quarry at this stage in the Plan. The approach taken in Preferred acidic sulphur and acidic nitrogen. It is therefore not clear whether the process Options policies 61 (Waste Management Provision) and 62 contribution also makes such a consideration/assumption. It is not clear (Location of New Waste Facilities) provides a flexible approach whether, as a result of the change of use from mining dolomitic limestone and to providing for new capacity in the absence of a strategic waste sand to infilling with inert waste, there will be a change in the amount of dust site. deposited on nearby land. We would therefore expect more information to be presented on the anticipated change in dust regime, given the effect this can have on the botanical interest associated with the SAC/NNR/SSSI Overall they should be providing enough information to enable you to complete a rigorous HRA (addressing Thrislington as well as the other suite of N2K sites in and around Durham). We therefore look forward to finding out more information regarding the council's preferred options for mineral and waste policies in the coming future.

Question 5 - Basal Permian Sand at Thrislington Quarry

Thrislington Quarry - Basal Permian Sand

Should we consider the identified land within Thrislington Quarry as a strategic mineral site allocation? (In providing your reply please explain why this site should or should not be considered).

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Respondent Question 5 - Should we consider the identified land within Thrislington Quarry Council Response as a strategic mineral site allocation?

Mr David Atkinson Based on the information submitted by Lafarge regarding the revised permitted The Council notes that within Thrislington Quarry, Lafarge Lafarge Aggregates Ltd reserves and additional basal Permian sand resources within the existing have identified a number of areas containing sand. The Thrislington Quarry, Lafarge support the allocation of the western area of additional existing area of working at Thrislington Quarry which is resource (i.e. that area adjacent to the existing permitted area for the extraction subject to an extant planning permission is now estimated of Basal Permian Sand) as a strategic mineral site allocation, whilst identifying the by Lafarge to contain 2.35 million tonnes of permitted eastern additional area as a strategic sand reserve for long term use beyond 2030. reserves, with two further areas containing approximately Thrislington Quarry's sand sales at the end of 2009 were ~123 000 tonnes (during 6 million tonnes. The existing permitted reserves within a period when sales across the UK have been low and the potential to increase the quarry are recognised by the Council as an important this production) and Lafarge has submitted updated reserve estimates (~2.3 million component of the County Durham's sand and gravel tonnes) and additional basal Permian sand resource estimates (6 million tonnes). landbank and are required to meet needs over the plan As such, Thrislington Quarry would satisfy the revised strategic minerals sites period to 2030. We understand that Lafarge intend to criteria which set out that individual site's would need to make a significant submit a planning application to extend the life of this contribution to annual production requirements. In terms of the on-going operations, permission before 2015. On the basis of need further it is clear that an application will need to be made to extend the life of the site working within this area is supported. beyond 2015 but the allocation would also allow flexibility within the void so that the resource could be exploited in the most technically efficient manner. In relation to the two further areas within the quarry, while it is accepted that both areas in quantitative terms meet Should the Council decide not to allocate the western additional area as a strategic the criteria for a strategic site outlined in the Technical mineral site allocation, at the very least, the basal Permian sand reserves and Consultation Report 'New Minerals and Waste Sites in resources identified at Thrislington Quarry should be safeguarded for the long County Durham', a strategic site should only be allocated term, i.e. beyond 2030 using the same approach as that adopted for high grade if it is of fundamental importance to the delivery of the dolomite under Policy M18 of the Minerals Local Plan and which is being proposed strategy of the County Durham Plan. Paragraph 5.10 of for the County Durham Plan and specifically the Core Strategy. the the Technical Consultation Report 'New Minerals and Waste Sites in County Durham' stated that a key consideration is need. Paragraph 5.10 was drafted on the basis of the information the Council held in November 2010. In considering the need for additional sand and gravel working we must have regard and use the latest and best available information. We must consider new information from Lafarge which advises that the extent of permitted reserves in the existing permitted area is in fact 2.35 million tonnes and not 3 million tonnes as stated in the Technical Consultation Report. We must take into account revised information on permitted reserves at Old Quarrington Quarry, reported as 1,688,400 tonnes in July 2010. We must also take into account recent planning permissions. The planning permission issued in September 2010 to extend Crime Rigg Quarry allows a further 70,000 tonnes of basal permian sand to be worked.

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Respondent Question 5 - Should we consider the identified land within Thrislington Quarry Council Response as a strategic mineral site allocation?

In addition it also allows the recovery of 581,000 tonnes of sand previously sterilised by the pillar of land separating the two halves of Crime Rigg Quarry to be recovered. We must also take into account recent member resolutions to grant permission for new working at Low Harperley (2,500,000 tonnes) and an extension to Old Quarrington and Cold Knuckles Quarry (415,800 tonnes). The latest position statement on need has been published in the Local Plan Preferred Options report (September 2012). This position statement considers that subject to planning permission being re-issued for further sand extraction, from the current working area at Thrislington Quarry, which expires on 18 January 2015, that more than sufficient sand and gravel is already permitted to meet forecast need without any further provision. On this basis there does not appear to any justification for identifying either of the two additional areas identified within Thrislington Quarry by Lafarge Aggregates for further sand extraction during the plan period.

It is important to note that the approach that must be taken is to ensure a steady and adequate supply of sand and gravel in accordance with the scale of working recommended by the NERAWP recommended apportionment of the Government's June 2009 National and Regional Aggregate Supply Guidelines. Crucially if further additional permitted reserves were granted at Thirslington Quarry and worked at an accelerated during the plan period there is a risk that other planning permissions for sand working in County Durham may not be worked in accordance with their existing planning permissions. Given the current economic recession and the significant fall in sales of sand and gravel this is already a real risk which can not be exacerbated.

The basal permian sand at Thrislington Quarry will be safeguarded via a Mineral Safguarding Area.

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Respondent Question 5 - Should we consider the identified land within Thrislington Quarry Council Response as a strategic mineral site allocation?

Mr Bryan Huntley Q5A The new evidence of permitted reserves supplied by Lafarge appear to Noted. Darlington Borough indicate that there is no need to allocate the two identified areas within Thrislington Council Quarry as a strategic mineral site for Basal Permian Sand extraction. The intent of the Council in seeking views on question 5b was to seek views on how the Council can identify Q5B. As to the merit in identifying these areas as strategic sand reserves, it really areas which should be afforded a degree of priority for depends on what status this type of designation would confer on the site? longer term working beyond the plan period. A parallel Presumably, the designation has a lower status than allocating the area as a can be drawn with the approach that was taken to the strategic minerals site and a strategic minerals site designation offers no guarantee area east of the allocation at Thrislington Quarry (east of that extraction will be acceptable. Therefore, what does a strategic reserve site the A1(M) where a high grade dolomite reserve was mean and would it make a difference to an operator's decision to invest in the site? identified under Policy M18 of the Minerals Local Plan. From the Council's point of view, things can change significantly over 20 years. Does the Council want to give an indication now of its intentions when those intentions could change over the next 20 years?

Ms G Gibson Given the history of this area and the amount of sand that currently has permission Noted. CPRE plus other sites in the area that have permission (such as Old Quarrington) C.P.R.E. questions whether these sites should be declared strategic sites at the present time. C.P.R.E. would prefer to reserve its position for a future date.

Natural England Thrislington Quarry - Waste Management/Eastern extension/Southern extension/ All strategic and non-strategic minerals and waste sites extension to basal Permian sand extraction area. will be subject to sustainability appraisal and habitats regulation assessment. Through this process all relevant In considering the proposed allocations at Thrislington Quarry, the assessment biodiversity impacts will be considered including those needs to take into account any potential impacts on the conservation objectives on SACs and SSSIs. of the Thrislington Special Area of Conservation, Thrislington Plantation SSSI and Thrislington NNR, through both the SA and HRA process (not just the HRA Further information has been submitted but does not process). allow an adequate assessment in order to demonstrate that any potential impacts or emissions from proposed In particular we would also welcome further details on the proposed waste waste operations at the site would not cause significant operations and restoration plan/after uses planned for the site from Lafarge damage and undermine the integrity of the SAC, either Aggregates Ltd, in order for the local authority to accurately assess all the various alone or in combination with other plans and projects. It proposals under the HRA and SA process. Please note our previous responses is not therefore considered possible to make an allocation to the planning application for the eastern extension. (7 April 2006 and subsequent for a strategic waste site at Thrislington Quarry at this response 4 December 2006). stage in the Plan. The approach taken in Preferred Options policies 61 (Waste Management Provision) and 62 (Location of New Waste Facilities) provides a flexible approach to providing for new capacity in the absence of a strategic waste site.

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Respondent Question 5 - Should we consider the identified land within Thrislington Quarry Council Response as a strategic mineral site allocation?

Ms S Wickerson Eastern extension to Thrislington Quarry east of the A1(M), north of existing Bishop Following the adoption of the County Durham Plan Environment Agency Middleham Quarry (and proposed extension to Bishop Middleham Quarry) and planning applications will be determined on the basis of south of Cornforth Quarry. the new policies of the County Durham Plan. Appropriate planning applications will require a hydrogeological risk Abstraction for dewatering purposes in mines, quarries and engineering works assessment. We are currently undertaking work to draft can have unacceptable impacts on environmental features supported by new development management policies and will consider groundwater, for example, wetlands, watercourses, ponds or may derogate existing whether we should specifically require a hydro-geological protected licensed water supplies, or lead to deterioration of in groundwater quality. risk assessment. Over the past few years we have provided detailed technical advice regarding the proposed eastern extension at Thrislington Quarry and recommended the inclusion of a number of bespoke planning conditions to any subsequent planning decision issued. Undertaking the planning permission, in accordance with the conditions imposed should ensure protection of the Magnesian Limestone principal aquifer by successfully mitigating the risks posed by the extraction of limestone and basal sands. If any of the identified risks can not be sufficiently mitigated the proposal may be deemed to be unacceptable. If the operator wishes to apply for further extraction works at the site e.g. southern extension we would request that they undertake and submit a hydrogeological risk assessment (HRA) as part of any subsequent planning application. As part of the HRA the site operator should assess and address the risks posed to all ground and surface water resources (quality and flow) within the vicinity of the site.

If both proposals, to extend Thrislington quarry to the south and Bishop Middleham quarry to the north west are taken forward there is a potential for the two site boundaries to a butt each other and a risk that they will become connected. In such case, the operator(s) will have to consider the cumulative impact posed by both sites on the water balance of the underlying groundwater aquifer.

Miss C Kinnear We have no opinion regarding whether or not this site should be a strategic site, All strategic and non-strategic minerals and waste sites RSPB however, impacts on the SAC and the local SSSIs should be considered in the have been/will be subject to Sustainability Appraisal and decision of whether the site should be allocated. Further, if the site is allocated a Habitats Regulation Assessment. Through this process restoration plan for the site should be proposed, preferably contributing to the all relevant biodiversity impacts are considered including Local BAP habitat targets and complimenting the SAC and local SSSIs. For those on SACs and SSSIs. example, restoration to magnesian limestone grassland would extend the existing habitat forming the Thrislington Plantation NNR and help to buffer one of the most The emerging approach to the restoration of sites is set important stands of this nationally scarce habitat. Further, such restorations would out in the technical consultation report "Towards a help to link the local sites of biodiversity importance. In future documents it would Minerals Delivery Strategy for County Durham". The

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Respondent Question 5 - Should we consider the identified land within Thrislington Quarry Council Response as a strategic mineral site allocation?

be helpful to include a map which labels the Thrislington Quarry, Eastern and approach proposed seek to deliver the objectives of key Southern extensions, especially when the map contains a number of proposed relevant strategies including the Durham BAP. A second site allocations. key strategy which we will have regard to and seek to deliver is the Durham Green Infrastructure Strategy. For example the approach which was outlined for the East Durham Limestone Plateau stated, "Restoration strategies of existing mineral sites will be expected to deliver the objectives and priorities of supporting strategies (where applicable) including the County Durham Landscape Strategy and Durham Biodiversity Plan. Priorities for restoration will include the creation of Magensian Limestone grassland, wetland, bare rock and scree habitats, native ash woodland and native species hedges. In accordance with the Waste Delivery Strategy and due to environmental circumstances any restoration proposal for mineral sites within this area would need to demonstrate that the major aquifer was protected."

Mr Mike Smith A) BMPC understand that the reserves of Basal Permian Sand at Thrislington Support for not allocating additional areas of sand at Bishop Middleham Parish Quarry far exceed the figures required (as specified in the report). Therefore there Thrislington Quarry noted. In developing our approach Council is no need to identify either of the sites as strategic mineral site allocations. B) We we have sought to use the best and most update do not feel there is any merit in identifying these areas as a strategic sand reserve information available. We have used published sources at this time because it is difficult to predict the demand for this product over the of information such as the North East Regional next 20 years. It would also concern BMPC as to what the status of the strategic Aggregates Working Party (NERAWP) Annual Aggregates sand reserve would be e.g. does the identification of such a site mean that the Monitoring Reports, we have undertaken surveys of County Council is giving authorisation for future development to take place? reserves and taken into account new information received from mineral operators. Through this process we believe we have now a robust assessment of the extent of permitted reserves of sand in different mineral sites across County Durham. We are required to seek to provide a steady and adequate supply of minerals including sand and gravel to meet to local needs and make a contribution to regional and national need. Our forecasts on future need are based upon the NERAWP recommended sub-regional apportionment of the Government's National and Regional Aggregate Supply Guidelines.

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Respondent Question 5 - Should we consider the identified land within Thrislington Quarry Council Response as a strategic mineral site allocation?

Mr Thomas Baker Basal Permian Sand Given there is more certainty with regard to sand extraction, Policy 53 'Meeting the Need for Primary Aggregates' sets we would expect more information with regard to the dust produced by such out the chosen approach to sand and gravel over the Natural England operations, as this can have both an impact on nutrient loads of the Plan period. Any planning application would be required SSSI/SAC/NNR, as well as reducing the ability of the plants there to to submit environmental information in order to address photosynthesise. It is also not clear whether there would be any hydrological impact these issues. on Thrislington SAC/SSSI/NNR as a result of any proposal.

Question 6 - Thrislington Quarry eastern extension

Thrislington Quarry Eastern site allocation - If planning permission is not issued for this proposal should we still consider this land as a strategic mineral site allocation? (In providing your reply please explain why this site should or should not be considered).

Respondent Question 6 - Thrislington Quarry Eastern site allocation - If planning permission Council Response is not issued for this proposal should we still consider this land as a strategic mineral site allocation?

Mr Bryan Huntley As no permission has been issued yet and the site meets the criteria, then the land Planning permission for eastern site allocation was Darlington Borough should be allocated as a strategic mineral site for Magnesian Limestone extraction. issued in July 2011. Accordingly the eastern site Council allocation will be considered no further in the County Durham Plan process.

Mr David Atkinson Should planning permission not be issued for the Eastern Extension at Thrislington Planning permission for eastern site allocation was Lafarge Aggregates Ltd Quarry, for whatever reason, then the area currently allocated for future mineral issued in July 2011. Accordingly the eastern site working under Policy M56 of the saved Minerals Local Plan should continue to be allocation will be considered no further in the County allocated as a strategic minerals site in the County Durham Plan. The Eastern Durham Plan process. Extension area is recognised, including by the Council in various previously prepared planning documents, as the only area in Great Britain, other than Whitwell in Derbyshire, containing high grade dolomite for use in the steel and chemical industries. As such, it is a nationally important mineral resource that must be safeguarded.

Ms G Gibson For the reasons outlined above, C.P.R.E. would represent that this site, which is Planning permission for eastern site allocation was CPRE practically adjacent to the above one, should also not be designated now and C.P.R.E. issued in July 2011. Accordingly the eastern site would again prefer to reserve its position. allocation will be considered no further in the County Durham Plan process..

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Natural England Thrislington Quarry - Waste Management/Eastern extension/Southern extension/ Planning permission for eastern site allocation was extension to basal Permian sand extraction area. issued in July 2011. Accordingly the eastern site allocation will be considered no further in the County In considering the proposed allocations at Thrislington Quarry, the assessment needs Durham Plan process. to take into account any potential impacts on the conservation objectives of the Thrislington Special Area of Conservation, Thrislington Plantation SSSI and Thrislington Further information has been submitted with regard NNR, through both the SA and HRA process (not just the HRA process). In particular to the strategic waste allocation but does not allow we would also welcome further details on the proposed waste operations and an adequate assessment in order to demonstrate that restoration plan/after uses planned for the site from Lafarge Aggregates Ltd, in order any potential impacts or emissions from proposed for the local authority to accurately assess all the various proposals under the HRA waste operations at the site would not cause and SA process. Please note our previous responses to the planning application for significant damage and undermine the integrity of the the eastern extension. (7 April 2006 and subsequent response 4 December 2006). SAC, either alone or in combination with other plans and projects. It is not therefore considered possible to make an allocation for a strategic waste site at Thrislington Quarry at this stage in the Plan. The approach taken in Preferred Options policies 61 (Waste Management Provision) and 62 (Location of New Waste Facilities) provides a flexible approach to providing for new capacity in the absence of a strategic waste site.

Ms S Wickerson Thrislington Eastern extension to Thrislington Quarry east of the A1(M), north of Planning permission for eastern site allocation was Environment Agency existing Bishop Middleham Quarry (and proposed extension to Bishop Middleham issued in July 2011. Accordingly the eastern site Quarry) and south of Cornforth Quarry. allocation will be considered no further in the County Durham Plan process. Abstraction for dewatering purposes in mines, quarries and engineering works can have unacceptable impacts on environmental features supported by groundwater, for example, wetlands, watercourses, ponds or may derogate existing protected licensed water supplies, or lead to deterioration of in groundwater quality. Over the past few years we have provided detailed technical advice regarding the proposed eastern extension at Thrislington Quarry and recommended the inclusion of a number of bespoke planning conditions to any subsequent planning decision issued. Undertaking the planning permission, in accordance with the conditions imposed should ensure protection of the Magnesian Limestone principal aquifer by successfully mitigating the risks posed by the extraction of limestone and basal sands. If any of the identified risks can not be sufficiently mitigated the proposal may be deemed to be unacceptable. If the operator wishes to apply for further extraction works at the site e.g. southern

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extension we would request that they undertake and submit a hydrogeological risk assessment (HRA) as part of any subsequent planning application. As part of the HRA the site operator should assess and address the risks posed to all ground and surface water resources (quality and flow) within the vicinity of the site. If both proposals, to extend Thrislington quarry to the south and Bishop Middleham quarry to the north west are taken forward there is a potential for the two site boundaries to abutt each other and a risk that they will become connected. In such case, the operator(s) will have to consider the cumulative impact posed by both sites on the water balance of the underlying groundwater aquifer.

Dr Richard Fong Yes Planning permission for eastern site allocation was issued in July 2011. Accordingly the eastern site allocation will be considered no further in the County Durham Plan process.

Question 7 - Southern allocation at Thrislington Quarry

Thrislington Quarry southern extension - We do not consider that this site should be allocated. Do you agree? (In providing your reply please explain why this site should or should not be allocated).

Respondent Question 7 - Thrislington Quarry southern extension - We do not consider that Council Response this site should be allocated. Do you agree?

Mr Bryan Huntley The answer to this questions depends upon an honest assessment of which party is Planning permission for eastern site allocation was Darlington Borough holding-up the issue of the planning permission. If the answer is the Council, then the issued in July 2011. As a result of this there will now Council site should be allocated to safeguard the operator's position. The allocation should be more than sufficient high grade dolomitic motivate the Council to issue the permission before the Plan is adopted, otherwise it limestone to meet the long term needs of the steel will have a strategic site which it does not support in an adopted plan. If the operator industry from this site. Accordingly, the proposal by is guilty of delaying the issue of the planning permission (e.g. by not signing a s106 Lafarge Aggregates, which required the Council to agreement) then the site should not be allocated. That should motivate the operator consider the extant Minerals Local Plan allocation to comply by removing its fall back position. west of the A1(M) but south of the existing quarry void will be considered no further in the County Durham Plan process. Preferred Options policy 54

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Respondent Question 7 - Thrislington Quarry southern extension - We do not consider that Council Response this site should be allocated. Do you agree?

'High Grade Dolomite' sets out the chosen approach to high grade dolomitic limestone. It is expected that Thrislington's reserves will provide for need over the Plan period. Proposals will only be permitted where it can be demonstrated that reserves at Thrislington are not sufficient.

Mr David Atkinson Provided planning permission is issued for the Eastern Extension to Thrislington Quarry, Planning permission for eastern site allocation was Lafarge Aggregates Ltd Lafarge will no longer seek to promote the allocation of the proposed southern extension. issued in July 2011. As a result of this there will now be more than sufficient high grade dolomitic limestone to meet the long term needs of the steel industry from this site. Accordingly, the proposal by Lafarge Aggregates, which required the Council to consider the extant Minerals Local Plan allocation west of the A1(M) but south of the existing quarry void will be considered no further in the County Durham Plan process. Preferred Options policy 54 'High Grade Dolomite' sets out the chosen approach to high grade dolomitic limestone. It is expected that Thrislington's reserves will provide for need over the Plan period. Proposals will only be permitted where it can be demonstrated that reserves at Thrislington are not sufficient.

Ms G Gibson C.P.R.E. agrees with the comments of the Council that this site should not be so Planning permission for eastern site allocation was CPRE designated. issued in July 2011. As a result of this there will now be more than sufficient high grade dolomitic limestone to meet the long term needs of the steel industry from this site. Accordingly, the proposal by Lafarge Aggregates, which required the Council to consider the extant Minerals Local Plan allocation west of the A1(M) but south of the existing quarry void will be considered no further in the County Durham Plan process. Preferred Options policy 54 'High Grade Dolomite' sets out the chosen approach to high grade dolomitic limestone. It is expected that Thrislington's reserves will provide for need over the Plan period. Proposals will only be permitted where

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Respondent Question 7 - Thrislington Quarry southern extension - We do not consider that Council Response this site should be allocated. Do you agree?

it can be demonstrated that reserves at Thrislington are not sufficient.

Natural England Thrislington Quarry - Waste Management/Eastern extension/Southern extension/ Planning permission for eastern site allocation was extension to basal Permian sand extraction area. issued in July 2011. As a result of this there will now be more than sufficient high grade dolomitic In considering the proposed allocations at Thrislington Quarry, the assessment needs limestone to meet the long term needs of the steel to take into account any potential impacts on the conservation objectives of the industry from this site. Accordingly, the proposal by Thrislington Special Area of Conservation, Thrislington Plantation SSSI and Thrislington Lafarge Aggregates, which required the Council to NNR, through both the SA and HRA process (not just the HRA process). In particular consider the extant Minerals Local Plan allocation we would also welcome further details on the proposed waste operations and restoration west of the A1(M) but south of the existing quarry plan/after uses planned for the site from Lafarge Aggregates Ltd, in order for the local void will be considered no further in the County authority to accurately assess all the various proposals under the HRA and SA process. Durham Plan process. Preferred Options policy 54 Please note our previous responses to the planning application for the eastern extension. 'High Grade Dolomite' sets out the chosen approach (7 April 2006 and subsequent response 4 December 2006). to high grade dolomitic limestone. It is expected that Thrislington's reserves will provide for need over the Plan period. Proposals will only be permitted where it can be demonstrated that reserves at Thrislington are not sufficient.

Ms S Wickerson Thrislington Eastern extension to Thrislington Quarry east of the A1(M), north of existing Planning permission for eastern site allocation was Environment Agency Bishop Middleham Quarry (and proposed extension to Bishop Middleham Quarry) and issued in July 2011. As a result of this there will now south of Cornforth Quarry. be more than sufficient high grade dolomitic limestone to meet the long term needs of the steel Abstraction for dewatering purposes in mines, quarries and engineering works can industry from this site. Accordingly, the proposal by have unacceptable impacts on environmental features supported by groundwater, for Lafarge Aggregates, which required the Council to example, wetlands, watercourses, ponds or may derogate existing protected licensed consider the extant Minerals Local Plan allocation water supplies, or lead to deterioration of in groundwater quality. Over the past few west of the A1(M) but south of the existing quarry years we have provided detailed technical advice regarding the proposed eastern void will be considered no further in the County extension at Thrislington Quarry and recommended the inclusion of a number of bespoke Durham Plan process. Preferred Options policy 54 planning conditions to any subsequent planning decision issued. Undertaking the 'High Grade Dolomite' sets out the chosen approach planning permission, in accordance with the conditions imposed should ensure to high grade dolomitic limestone. It is expected that protection of the Magnesian Limestone principal aquifer by successfully mitigating the Thrislington's reserves will provide for need over the risks posed by the extraction of limestone and basal sands. If any of the identified risks Plan period. Proposals will only be permitted where can not be sufficiently mitigated the proposal may be deemed to be unacceptable. If it can be demonstrated that reserves at Thrislington the operator wishes to apply for further extraction works at the site e.g. southern are not sufficient. extension we would request that they undertake and submit a hydrogeological risk assessment (HRA) as part of any subsequent planning application. As part of the HRA the site operator should assess and address the risks posed to all ground and surface

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Respondent Question 7 - Thrislington Quarry southern extension - We do not consider that Council Response this site should be allocated. Do you agree?

water resources (quality and flow) within the vicinity of the site. If both proposals, to extend Thrislington quarry to the south and Bishop Middleham quarry to the north west are taken forward there is a potential for the two site boundaries to a butt each other and a risk that they will become connected. In such case, the operator(s) will have to consider the cumulative impact posed by both sites on the water balance of the underlying groundwater aquifer.

Mr Thomas Baker Strategic Dolomite Sites (Southern Extension) Having read over the information there Planning permission for eastern site allocation was Natural England remains a large amount of uncertainty with regards to what is actually being proposed issued in July 2011. As a result of this there will now as you know, a lot hinges on whether the legal agreements associated with the Eastern be more than sufficient high grade dolomitic Extension can be tied up and the planning permission issued. With this level of limestone to meet the long term needs of the steel uncertainty hanging over Lafarge's interest in this strategic process I think it is limited industry from this site. Accordingly, the proposal by what Natural England can say at this point, until such a time that their intentions are Lafarge Aggregates, which required the Council to clear and information to support the preferred option is assessed through a Habitat consider, the extant Minerals Local Plan allocation Regulation Assessment. west of the A1(M) but south of the existing quarry void will be considered no further in the County Durham Plan process. Preferred Options policy 54 'High Grade Dolomite' sets out the chosen approach to high grade dolomitic limestone. It is expected that Thrislington's reserves will provide for need over the Plan period. Proposals will only be permitted where it can be demonstrated that reserves at Thrislington are not sufficient.

Question 8 - Strategic site proposal Heights Quarry

Heights Quarry - Should we consider the proposed Area of Search at Heights Quarry as a strategic mineral site allocation? (In providing your reply please explain why this site should or should not be considered).

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Respondent Question 8 - Heights Quarry - Should we consider the proposed Area of Search at Council Response Heights Quarry as a strategic mineral site allocation?

Mr Geoff Storey The Heights Quarry extension is of strategic importance to the supply of Carboniferous Support noted. Aggregate Industries Limestone for use in ready mixed concrete and as a dry aggregate. Heights Quarry is also UK Ltd a site of strategic importance in relation to the supply of asphalt. A consolidating application The role of Heights Quarry in providing ready mixed has the potential to deliver landscape and restoration benefits. Biodiversity and geo-diversity concrete, carboniferous limestone as a dry action plans will also be an integral part of an extension development scheme. aggregate and in asphalt production is noted. Continued supply of these materials are all required to ensure that the Council can deliver its aspirations for development over the plan period.

Preferred Options policy 59 allocates land west of Heights Quarry as a strategic site and indicates that proposals will be permitted for the winning and working of carboniferous limestone where in accordance with policy 53 (Meeting the Need for Primary Aggregates), Policy 42 (Internationally Designated Sites) and other relevant policies of the Plan, but will be subject to conditions and/or legal agreements which, amongst others, will provide specifically for:

a. The surrendering of existing permitted reserves within the

northern sector of the existing site (Heights Quarry) in exchange

for new permitted reserves; and

b. An acceptable scheme of phased working and restoration for

both Heights Quarry and its western extension which seeks to

minimise significant adverse impacts and maximises and delivers

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Respondent Question 8 - Heights Quarry - Should we consider the proposed Area of Search at Council Response Heights Quarry as a strategic mineral site allocation?

a range of environmental benefits including landscape and

biodiversity enhancement measures, and which specifically

provides for the diversion and enhancement of the Weardale Way.

Mr Bryan Huntley It would appear that the proposed extension will be needed within the plan period and the Support subject to consideration of the potential Darlington Borough site meets the criteria. Therefore, subject to consideration of the potential impacts on the impacts on the AONB and the nature conservation Council AONB and the nature conservation designations being acceptable, the land should be designations being acceptable noted. Preferred allocated as a strategic minerals site for the extraction of Carboniferous Limestone. Options policy 59 allocates land west of Heights Quarry as a strategic site and indicates that proposals will be permitted for the winning and working of carboniferous limestone where in accordance with policy 53 (Meeting the Need for Primary Aggregates), Policy 42 (Internationally Designated Sites) and other relevant policies of the Plan (including AONB policy), but will be subject to conditions and/or legal agreements which, amongst others, will provide specifically for:

a. The surrendering of existing permitted reserves within the

northern sector of the existing site (Heights Quarry) in exchange

for new permitted reserves; and

b. An acceptable scheme of phased working and restoration for

both Heights Quarry and its western extension which seeks to

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Respondent Question 8 - Heights Quarry - Should we consider the proposed Area of Search at Council Response Heights Quarry as a strategic mineral site allocation?

minimise significant adverse impacts and maximises and delivers

a range of environmental benefits including landscape and

biodiversity enhancement measures, and which specifically

provides for the diversion and enhancement of the Weardale Way.

Ms G Gibson C.P.R.E. believes the issues regarding the overburden need to be clarified so far as possible Preferred Options policy 59 allocates land west of CPRE before any decision is made to extend this quarry. As acknowledged, this is a very sensitive Heights Quarry as a strategic site and indicates that area in landscape terms and it would be almost criminal to permit an extension that then proposals will be permitted for the winning and led to unacceptable damage while moving the overburden. For this reason, C.P.R.E. working of carboniferous limestone where in considers this issue needs to be resolved before the site is declared a strategic site. accordance with policy 53 (Meeting the Need for Primary Aggregates), Policy 42 (Internationally Designated Sites) and other relevant policies of the Plan, but will be subject to conditions and/or legal agreements which, amongst others, will provide specifically for:

a. The surrendering of existing permitted reserves within the

northern sector of the existing site (Heights Quarry) in exchange

for new permitted reserves; and

b. An acceptable scheme of phased working and restoration for

both Heights Quarry and its western extension which seeks to

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Respondent Question 8 - Heights Quarry - Should we consider the proposed Area of Search at Council Response Heights Quarry as a strategic mineral site allocation?

minimise significant adverse impacts and maximises and delivers

a range of environmental benefits including landscape and

biodiversity enhancement measures, and which specifically

Natural England Extension to Heights Quarry, near Eastgate. This quarry extension is located entirely within Preferred Options policy 59 allocates land west of the North Pennines Area of Outstanding Natural Beauty (AONB). The LPA needs to Heights Quarry as a strategic site and indicates that consider any potential significant adverse impacts on the special qualities of the AONB, proposals will be permitted for the winning and taking into consideration the objectives of the AONB management plan, and on the working of carboniferous limestone where in conservation objectives of the nature conservation interests adjacent and near to the site. accordance with policy 53 (Meeting the Need for This is particularly important given the prominent location of the proposed site. The site is Primary Aggregates), Policy 42 (Internationally also adjacent to a number of SSSI, local wildlife sites, and upland heath BAP habitat, and Designated Sites) and other relevant policies of the the Weardale Way runs across the proposed site. Plan, but will be subject to conditions and/or legal agreements which, amongst others, will provide specifically for:

a. The surrendering of existing permitted reserves within the

northern sector of the existing site (Heights Quarry) in exchange

for new permitted reserves; and

b. An acceptable scheme of phased working and restoration for

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Respondent Question 8 - Heights Quarry - Should we consider the proposed Area of Search at Council Response Heights Quarry as a strategic mineral site allocation?

both Heights Quarry and its western extension which seeks to

minimise significant adverse impacts and maximises and delivers

a range of environmental benefits including landscape and

biodiversity enhancement measures, and which specifically

Ms S Wickerson We have no objection to the inclusion of the proposed sites as a preferred option. Preferred Options policy 59 allocates land west of Environment Agency Abstraction for dewatering purposes in mines, quarries and engineering works can have Heights Quarry as a strategic site and indicates that unacceptable impacts on environmental features supported by groundwater, for example, proposals will be permitted for the winning and wetlands, watercourses, ponds or may derogate existing protected licensed water supplies, working of carboniferous limestone where in or lead to deterioration of in groundwater quality. In order to assess the potential impacts accordance with policy 53 (Meeting the Need for from the works proposed we request that the a hydrogeological risk assessment (HRA) Primary Aggregates), Policy 42 (Internationally forms part of any subsequent planning application. As part of the HRA, the site operator Designated Sites) and other relevant policies of the should assess and address the risks posed to all ground and surface water resources Plan, but will be subject to conditions and/or legal (quality and flow) within the vicinity of the site. If any of the identified risks can not be agreements which, amongst others, will provide sufficiently mitigated the proposals may be deemed unacceptable. specifically for:

a. The surrendering of existing permitted reserves within the

northern sector of the existing site (Heights Quarry) in exchange

for new permitted reserves; and

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Respondent Question 8 - Heights Quarry - Should we consider the proposed Area of Search at Council Response Heights Quarry as a strategic mineral site allocation?

b. An acceptable scheme of phased working and restoration for

both Heights Quarry and its western extension which seeks to

minimise significant adverse impacts and maximises and delivers

a range of environmental benefits including landscape and

biodiversity enhancement measures, and which specifically

provides for the diversion and enhancement of the Weardale Way. A planning application with an accompanying environmental statement will be required. The planning application will consider the detailed acceptability of this site proposal. A hydrogeological risk assessment (HRA) will be required as part of any subsequent planning application.

Miss C Kinnear We do not wish to comment on whether this site should be a strategic mineral site. We Comments noted. RSPB approve of the Council's intent to consider environmental impacts. However, the Council should also consider how restoration could contribute to local BAP habitat targets, The Council is seeking to require that modern high particularly given the proximity to the North Pennine Moors SPA and the high biodiversity quality restoration schemes are always delivered. value of the AONB generally. The site's location and the objectives of key supporting strategies which are relevant are a key determinant of the approach taken. Preferred Options policy 59 allocates land west of Heights Quarry as a strategic site and indicates that proposals will be permitted for the winning and working of carboniferous limestone where in accordance with policy 53 (Meeting the Need for Primary Aggregates), Policy 42 (Internationally Designated Sites) and other relevant policies of the

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Respondent Question 8 - Heights Quarry - Should we consider the proposed Area of Search at Council Response Heights Quarry as a strategic mineral site allocation?

Plan, but will be subject to conditions and/or legal agreements which, amongst others, will provide specifically for:

a. The surrendering of existing permitted reserves within the

northern sector of the existing site (Heights Quarry) in exchange

for new permitted reserves; and

b. An acceptable scheme of phased working and restoration for

both Heights Quarry and its western extension which seeks to

minimise significant adverse impacts and maximises and delivers

a range of environmental benefits including landscape and

biodiversity enhancement measures, and which specifically

provides for the diversion and enhancement of the Weardale Way.

Councillor John I agree that the site should be allocated as a strategic mineral site. The quarry is an Support noted. The economic benefit of continued Shuttleworth important employer of local people. Your document says that the site would secure the working will be a material consideration when we jobs of the 23 people already working at Heights Quarry and the indirect jobs associated consider proposals through the Development with the quarry (some 40 - 50 jobs). More employment opportunities are needed in Weardale Management process. Preferred Options policy 59 and it is important that they are not lost. I know that Heights Quarry has been worked for allocates land west of Heights Quarry as a strategic many years without any problems and I am therefore certain the extension area could also site and indicates that proposals will be permitted be worked without concern or complication. for the winning and working of carboniferous

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Respondent Question 8 - Heights Quarry - Should we consider the proposed Area of Search at Council Response Heights Quarry as a strategic mineral site allocation?

limestone where in accordance with policy 53 (Meeting the Need for Primary Aggregates), Policy 42 (Internationally Designated Sites) and other relevant policies of the Plan, but will be subject to conditions and/or legal agreements which, amongst others, will provide specifically for:

a. The surrendering of existing permitted reserves within the

northern sector of the existing site (Heights Quarry) in exchange

for new permitted reserves; and

b. An acceptable scheme of phased working and restoration for

both Heights Quarry and its western extension which seeks to

minimise significant adverse impacts and maximises and delivers

a range of environmental benefits including landscape and

biodiversity enhancement measures, and which specifically

provides for the diversion and enhancement of the Weardale Way.

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Question 9 - Proposed surface mine coal sites

Proposed surface mine coal sites - We do not intend to identify either Eldon Blue House, Pittington North or Pittington South as strategic sites in the Core Strategy DPD. Do you agree or disagree? (In providing your reply please explain why these sites should or should not be allocated).

Respondent Question 9 - Proposed surface mine coal sites - We do not intend to identify Council Response either Eldon Blue House, Pittington North or Pittington South as strategic sites in the Core Strategy DPD. Do you agree or disagree

Mr Lee Weatherall In light of additional information now supplied on how strategic sites will be identified Acceptance of strategic sites criteria noted. Our ATH Resources and why (para 3.11), ATH Resources agree with the revised criteria for strategic approach to surface mined coal and fireclay is set out sites. As such, they advise that they no longer wish to see their submitted sites at in policy 56 of the Preferred Options. Pittington North, Pittington South and Eldon Blue House considered as strategic sites.

Paragraph 5.21 states that there are concerns over the deliverability of both the Eldon Blue House and Pittington North sites. At Eldon Blue House there are concerns over whether the site could be worked in relation to the planning permission to work brick making materials at Eldon. As mentioned in our original submission on the Eldon Blue House site, ATH Resources believe that the proposed workings here could be worked in partnership with the brick making material operations, or if no agreement can be reached with the operator of this, then there is scope to work the coal without affecting these operations. ATH Resources has subsequently been in discussions with Wienerberger over this issue and potential schemes to work the site either in conjunction, or separately with them, have been discussed and evaluated. Negotiations are still ongoing with regard to these schemes but if the two sites were to be worked in conjunction it is likely that points of access and certain pieces of infrastructure and facilities could be shared between the two operators. If they were to be worked separately the Eldon Blue House boundary and amount of resources may have to be amended slightly but this would not necessarily affect the viability of the proposals. Separate access and operational/welfare facilities could be provided with access to the A696 to the north. At Pittington North, ATH Resources have secured the long term rights to the underlying minerals via a lease agreement on the land they have submitted and have been in negotiations with the landowners concerned. They are aware of UK Coal's interest in some of the site (their Field House submission) but are not aware of any implications of this at the present time which would currently prevent them

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from working the site. They consider that all submitted sites will have a degree of uncertainty about them at this submission stage and that the fact they have secured the minerals lease and have been discussing the proposals with the landowners should provide sufficient clarity on deliverability at this time. This is in accordance with the information provided in paragraph 7.3.

Chris Taylor I agree that these sites should not be identified as strategic sites in the Core Strategy Agreement that these sites should not be identified as DPD. strategic sites noted.

With particular reference to the two Pittington sites, the proposed transport With reference to the two Pittington sites, the documents arrangements are unsatisfactory and vague. There is no clear route from the section on transport was drafted incorrectly and in fact proposed sites to junction 60 of the A1M via the A689 to the sites and any access related to the Eldon Blue House site. to the sites would have to make use of the local road network which is not suitable for large amounts of traffic movements. It is clear that the time frame for these sites The environmental impacts of the proposed surface does not make them suitable for inclusion as strategic sites in the core strategy mined coal sites will be fully considered when we prepare DPD. In the case of the Pittington South proposal, I also believe this would be the allocations document. At that stage all unsuitable because of the large negative impact on the extremely nearby residential representations made to this document will be taken into areas in Pittington. account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr John Carroll I fully agree with your intention not to include the above sites as strategic sites in Agreement that these sites should not be identified as the core strategy DPD. The housing estate of Priors Grange lies within a few yards strategic sites noted. of the proposed Pittington South site allocation. I am therefore concerned about the environmental impact in terms of noise, air pollution, traffic, land disturbance The environmental impacts of the proposed surface and the detrimental effect on house values with such an industrial undertaking on mined coal sites will be fully considered when we prepare this site. In recent history, this area has been subject to many deep mines and the the allocations document. At that stage all subsequent ecological damage caused by them. Much time, energy and money representations made to this document will be taken into has been invested to retrieve this area from past mining damage and to make account. Our approach to surface mined coal and fireclay acceptable the landscape we now enjoy. Previous mining scars were and are is set out in policy 56 of the Preferred Options. unacceptable. The Pittington South proposal, the Field House proposal and the Pittington North proposals would take us back to the dreadful years of mining pollution that many residents in this area can still remember and the many years it took to rectify the area. These proposals do not benefit County Durham in any shape or form so why should local people bear the brunt of coal extraction and the subsequent environmental damage to our beautiful village and wider local environment. The neighbouring villages of Sherburn, Belmont and Rainton and their

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populations would also be affected by these proposals which I feel is too high a price just to extract cheap coal. The proposals would inevitably cause a massive impact on this beautiful area and have a catastrophic effect on the lives of those people who have invested their lives in this area and the years it has taken to rectify previous mining damage. These proposals should be totally rejected and not included in any Strategy Plan.

Mr. Mark Potts I agree with the comment above. The plan shows the proposed mineral extraction Agreement that these sites should not be identified as sites immediately adjacent to residential properties. The roads required for access strategic sites noted. are not suitable for the huge amount of traffic this proposal would generate. The environmental impacts of the proposed surface mined coal sites will be fully considered when we prepare the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr William Sleep I agree totally with the comment above the plan indicates that the proposed site Agreement that these sites should not be identified as would be immediately adjacent to pittington village also the road system in the strategic sites noted. village would not be capable of supporting the huge increase in traffic that an opencast site would generate. The environmental impacts of the proposed surface mined coal sites will be fully considered when we prepare the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr John Carr I totally agree with the Council's decision as this would be detrimental to the village Agreement that these sites should not be identified as of High Pittington strategic sites noted.

The environmental impacts of the proposed surface mined coal sites will be fully considered when we prepare the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

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Mrs Jacqueline Dooley I strongly agree that these sites should not be identified as strategic sites in the Agreement that these sites should not be identified as Core Strategy DPD. The sites are extremely close to residential areas, and any strategic sites noted. working would have an extremely detrimental effect on living conditions in these villages and on the surrounding landscape. The local infrastructure is not strong The environmental impacts of the proposed surface enough to cope with the unspecified number of lorries which would be needed - mined coal sites will be fully considered when we prepare this is shown by the detrimental effects of the number of lorries which already pass the allocations document. At that stage all through High and Low Pittington, causing noise and pollution to properties in close representations made to this document will be taken into proximity to the narrow roads. The area has been heavily mined in the past and account. Our approach to surface mined coal and fireclay some instability of land has been experienced within the village - even surface is set out in policy 56 of the Preferred Options. mining would cause vibration from machinery and haulage which could have implications in the surrounding area. Villages such as these in County Durham are also presently being explored, opened up and publicised in terms of tourism, with footpaths and cycle ways becoming much more prominent, and large areas of surface mining, with its extreme visual impact, would undermine this to a great extent. Coal mining in any form is dirty and dusty, and causes pollution which blankets the surrounding area. Cleaner, greener forms of energy could be explored, with a more beneficial effect on local landscape and population.

Mr George Clouston I strongly agree that these sites should not be allocated as strategic sites in the Agreement that these sites should not be identified as core strategy DPD. The two Pittington sites are directly adjacent to residential areas strategic sites noted. and there would be a significant amount of noise, air and light pollution that would have a very detrimental affect on the local environment and quality of life for local The environmental impacts of the proposed surface residents. Also the local infrastructure is inadequate for such a major development. mined coal sites will be fully considered when we prepare The road infrastructure would not be able to cope with the inevitable increase in the allocations document. At that stage all heavy duty lorries. Highway safety would also be significantly affected. The local representations made to this document will be taken into roads and footpaths are used by walkers, joggers, cyclists and horse riders of all account. Our approach to surface mined coal and fireclay ages and increased heavy vehicle traffic would undoubtedly increase road danger. is set out in policy 56 of the Preferred Options. The proposed development would also mean the loss of several public rights of way including footpaths, bridle ways and cycle paths which are directly within the sites. There would also be serious damage to local wildlife and natural habitats. There are 3 Sites of Special Scientific Interest (SSSIs) in the immediate area. The High Moorsley and Moorsley Bank SSSIs are directly within the proposed Pittington North site and the Pittington South Site would be within 100m of the Pittington Hill SSSI. SSSIs are legally protected under the Wildlife and Countryside Act 1981, as amended by the Countryside and Rights of Way (CROW) Act 2000 and the Natural Environment and Rural Communities (NERC) Act 2006. Overall these proposals would be disastrous for the local environment and local residents and should be totally rejected.

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Mrs. Maureen Jones I fully agree that these proposed sites are not included in any Strategic Plan. The Agreement that these sites should not be identified as proposed sites would inevitably change the characteristics of this beautiful village strategic sites noted. with the current infrastructure in terms of roads and accessibility to public footpaths, historic sites and local amenities, not being able to cope with the increased The environmental impacts of the proposed surface industrialisation this mining would bring. Pittington is a small beautiful rural village mined coal sites will be fully considered when we prepare with an historic church, (St Laurence Church), on the edge of the proposed site the allocations document. At that stage all which is used by villagers and visited by tourists. Wildlife habitats are also ranged representations made to this document will be taken into over this land with many varieties of birds and animals using the natural setting. account. Our approach to surface mined coal and fireclay This landscape is just beginning to settle after many years of previous mining is set out in policy 56 of the Preferred Options. environmental damage and the proposal puts at risk the many years it has taken for this area to re- establish itself. This landscape offers many people access to beautiful countryside e.g walking and cycling, which would be lost if mining was ever granted to this area.

Ms Amanda Carroll I strongly agree that the sites of Eldon Blue House, Pittington North or Pittington Agreement that these sites should not be identified as South should NOT be identified as strategic sites in the Core Strategy DPD. The strategic sites noted. sites all closely border established rural residential areas, particularly the larger villages of High and Low Pittington, which have sizeable populations. High Pittington The environmental impacts of the proposed surface has a Primary School servicing the surrounding villages. This is attended by the mined coal sites will be fully considered when we prepare villages' children up to the age of eleven. The school is only a stones throw from the allocations document. At that stage all the proposed sites. My three year old daughter attends the nursery school and is representations made to this document will be taken into due to start her school place in September. Mining on these sites would have a account. Our approach to surface mined coal and fireclay potentially devastating effect on the wellbeing of her and all the other children in is set out in policy 56 of the Preferred Options. the villages by them being subjected to the inevitable consequential air pollution, noise and increased traffic danger (both at school and home). The large open air green space of the school field is currently an attractive asset to the school and village but I would be desperately unhappy at the thought of my daughter playing out there in such close proximity to mining sites, breathing in the dust and foul smells and risking the contraction of longer term health problems. Any approval of development on these sites would be with blatant disregard for the health and wellbeing of my daughter and all these children (as well as all adults in the surrounding area). Substantial investment has been made locally in my lifetime (having lived here since early childhood) to regenerate the countryside after the spoils of coal mining. I remember the grey ugly towering 'slag heaps' that dominated the landscape around us when I was younger. I am proud to now say I live here - in an area of outstanding natural beauty - with Pittington Hill (designated as a World Heritage Site for its valuable limestone eco system), and also the beautiful and historic St Laurence Church, again both only a stone's throw from these proposed

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sites. There is much to appeal to Tourists, visitors and Walkers currently. The proposed development sites all include extensive and well used footpaths, bridle ways and cycle tracks that would be rendered defunct. It would be an utter travesty and immoral disgrace for development to proceed as it would flout and destroy the real value of these assets and reverse the efforts made to achieve the much needed regeneration (not to mention the disgusting disregard for the public money already invested in that which would be effectively wasted). The area has benefited economically from the expansion of the village with new housing development in the past thirty years but mining on these sites would cause economic disaster for local property owners as house values inevitably plummeted. I can't think of an aspect of quality of life that would not be blighted for local residents should this development be permitted on these sites. The operators should be ashamed of their shallow prioritisation of commercial gain over local heritage and peoples health, wellbeing, economic security and life quality in selecting these sites. Ultimately this is an area that has enjoyed greenbelt status and any notion of transferring the sites in question from beautiful open countryside to heavy industry must be vehemently rejected.

Mr Bryan Huntley Agree that surface mine coal sites should not be considered strategic and proposals Agreement that these sites should not be identified as should be considered through the Minerals and Waste Policies and Allocations strategic sites noted. Our approach to surface mined Darlington Borough DPD coal and fireclay is set out in policy 56 of the Preferred Council Options.

Mrs Katharine Milburn Yes I agree strongly with DCC that Pittington North and Pittington South should not Agreement that these sites should not be identified as be identified as strategic sites within the Core Strategy DPD. Pittington is a small strategic sites noted. village and the infrastructure struggles to cope with the huge trucks for the local logging plant at Sherburn Hill. Traffic calming measures are due to be put in place The environmental impacts of the proposed surface shortly. The roads are not in good condition and could not cope with the additional mined coal sites will be fully considered when we prepare load of vehicles to and from the mining sites. The two sites are very close to mature the allocations document. At that stage all housing developments and a local primary school. Noise would definitely be a representations made to this document will be taken into serious concern to all residents. The village of Pittington is already doing it's bit for account. Our approach to surface mined coal and fireclay RENEWABLE energy as we are now surrounded by wind farms. To force coal is set out in policy 56 of the Preferred Options. mining in addition to the wind farms on a village the size of Pittington is completely un viable Pittington is a village of outstanding natural beauty which attracts many ramblers and visitors. The proposed open cast mines would ruin this and the sites would take years/if ever return to their previous natural state.

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Ms Lynn Patterson I fully support your intention not to identify Pittington North and South as strategic Agreement that these sites should not be identified as sites in the Core Strategy DPD for the following reasons (particularly in relation to strategic sites noted. Pittington South, but equally applicable to North). 1) General Disturbance - a blight on the properties immediately bordering the proposed site and severe disturbance The environmental impacts of the proposed surface to the village as a whole. 2) Loss of privacy - site boundary is only 10metres from mined coal sites will be fully considered when we prepare the boundary of adjacent properties. 3) Noise, dust, smell, vibration - huge impact the allocations document. At that stage all on the local residents and their health due to air pollution, note also the close representations made to this document will be taken into proximity of the local primary school to the site. Surface mining is likely to have an account. Our approach to surface mined coal and fireclay adverse effect on old deeper mine workings with possible subsidence damage to is set out in policy 56 of the Preferred Options. existing properties in the immediate vicinity. 4) Light pollution - any artificial light from the site would impact on adjacent homes and road users in the immediate area. 5)Effect on highway safety/adequacy of infrastructure - junctions and roads around the village are locally regarded as dangerous due to impaired visibility. The village has also suffered high volumes of heavy vehicles carrying logs and timber products to and from Taylormade at Sherburn Hill. Traffic calming measures are due to be installed within the village, resulting in a much greater volume of traffic along Lady Piece Lane which would be used to transport the coal off site. 6)Effect on public rights of way - the South site would destroy two public footpaths used regularly by local residents, visitors and walking groups. 7) Effect on wildlife and landscape features - old field boundaries and hedgerows would be destroyed or disturbed. These support a burgeoning wildlife community e.g.partridge, pheasant, goldfinch, bullfinch, woodpecker, tawny owl,long tailed tit, curlew, lapwing, skylark and sparrowhawk as well as more common garden birds.

Mr James Waugh I agree that the council should not identify pittington north or pittington south as Agreement that these sites should not be identified as strategic sites in the core strategy DPD. The villages of high and low pittington strategic sites noted. would suffer from all aspects of the extraction and restoration of the sites, this would include noise dirt and additional traffic. The roads in the area are in a poor condition The environmental impacts of the proposed surface as they already suffer from the heavy traffic that goes to the sawmill at Sherburn mined coal sites will be fully considered when we prepare Hill. the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr David Brewer CoalPro agrees that these sites should not be identified as strategic but considers Agreement that these sites should not be identified as Confederation of UK Coal that the wider strategic implications should be recognised (see response to Q.1) strategic sites noted. Producers (COALPRO) by affording them a high level of protection.

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As stated in the Technical Consultation Report "Safeguarding Mineral Resources for the Future", mineral resources will be safeguarded via the designation of Mineral Safeguarding Areas (MSAs). Government guidance is clear that there is no presumption that resources defined in MSAs will be worked. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Rachel Boll I write to register my objections to the proposals for opencast mining in Pittington. Agreement that these sites should not be identified as I am a resident of Pittington, and grew up in the village. I chose to return to the strategic sites noted. village as an adult because of the peace of the village, and the fact that it is surrounded by open countryside. Firstly, I believe that the publication of this The environmental impacts of the proposed surface consultation has been inadequate. A search on the internet and indeed even of the mined coal sites will be fully considered when we prepare Durham Council website does not easily reveal the consultation document, and the allocations document. At that stage all even having located the document the link to it consistently fails. You published representations made to this document will be taken into this consultation on 1st December, yet there has been no open notification in and account. Our approach to surface mined coal and fireclay around the village, and word of mouth only reached the residents of the village in is set out in policy 56 of the Preferred Options. the New Year, leaving us little time to formulate a properly considered response. The subsequent difficulty in locating the document only adds to this. My house would be less than 30 metres from the boundary of the proposed site. If I cannot be properly notified of the consultation, who has been? There are legitimate objections to this proposal which need to be carefully considered. The land behind Priors Grange which you propose should be mined is home to extensive array of wildlife including owls, woodpeckers, finches, tits, pheasants rabbits, stoats, weasels and squirrels. There is also at least one sparrow hawk resident in the village, who can often been seen hunting over the proposed sites, as well as barn owls and kestrels. Little owls also reside in the village. If both proposed sites were to be worked, the disruption to this wildlife would be extensive. There are also waterways throughout the proposed sites which will play host to their own array of wildlife including kingfishers, herons and ducks which will undoubtedly be affected by mining of the land. Part of the hill in the village has been designated as a SSSI, the noise, pollution and traffic associated with opencast mining will clearly impact upon this precious environment which needs to be protected. There are traffic concerns within Pittington, of which you will be well aware. There are existing difficulties with the number of HGVs passing through the village to the Taylormade Timber yard on Sherburn Hill, this has long been a source of concern, and only last summer the

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residents were advised of a plan of traffic calming measures intended to be introduced into the village to address residents concerns. (Strange that this so widely publicised as to be posted through our doors, when the proposal for an opencast mine is left hidden on the Internet!?!) If, or when, these traffic calming measures are introduced, the HGVs are then more likely to use Lady Piece's Lane, which will add to the traffic on that road before you even begin to contemplate the traffic involved in an opencast mine site. The access for residents in and out of the village will then be adversely affected as well. The junction where the village road joins Lady Piece's Lane is already a tricky junction, where accidents happen on a not infrequent basis, the introduction of a large number of HGVs will only exacerbate this situation. The roads which would access your proposed sites are small country roads, the surfaces of which already suffer significant damage as a result of the HGV loads which are passing over them. The crossroads at Low Pittington currently clearly demonstrate the damage caused, they are in a shocking state of repair. The safety of the children who attend the popular village school is clearly a major concern, and an increase in the number of HGVs in the vicinity clearly increases the risks to children. The noise of a working opencast mining site will clearly disrupt the residents of the village and the school. The aforementioned Taylormade site can already be heard working through the night, the light pollution caused by the site is widely evident. Are we to now become sandwiched between 2 heavy duty 24 hour working sites? To conclude, this consultation has been wildly inadequate, and I urge the Council to give proper consideration to the impact upon a very precious environment before authorising any progress on these plans.

Mr Brian Hardy Hi as you will probably realise from my email address I have been taking part in the The environmental impacts of the proposed surface various consultations to do with the the county plan for Durham City and the mined coal sites will be fully considered when we prepare greenbelt and villages around it, I live in Pittington. If I recall correctly I suggested the allocations document. At that stage all a priority should be low-cost affordable housing for the inhabitants of Durham. representations made to this document will be taken into However over the weekend I have been horrified to read, in the Sunderland and account. Our approach to surface mined coal and fireclay Northern Echo's about the possibility of coal opencast mining taking place on the is set out in policy 56 of the Preferred Options. greenbelt all around Pittington/Hallgarth/Rainton. This seems so wrong on so many levels, following on from all the pit closures Durham City and its environs has been gradually returning to a beautiful, peaceful place to live and bring up children. Now the environmental effects of opencast mining, the noise, dust, dirt, the traffic and the 'rape' of the land, all the natural plants, trees and animals will be be lost. I've some friends and relatives that live in Northumberland and I saw the effect 'opencast mining had on its communities (plus very few local jobs as specialists from all over the UK & world were brought in as they tend to go from site to site), all that the

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villages around and about got after 20/30 years of misery was a promise of a large sculpture, that could only be seen from the air anyway. I suppose I am lucky I am not expecting to move anywhere in the near future, but the whole area will now be hit by 'planning blight'.

Mr Liam Sheils I don't think that there is much that I can add to the reasoned comments already The environmental impacts of the proposed surface posted here by my neighbours. For all of the reasons gone into at length, the mined coal sites will be fully considered when we prepare proposed developments would be catastrophic for Pittington and the surrounding the allocations document. At that stage all settlements and would be fiercely resisted by all local residents. I find it almost representations made to this document will be taken into laughable that developments of this nature would be proposed within a couple of account. Our approach to surface mined coal and fireclay hundred metres of a nationally significant church, barely explored or excavated is set out in policy 56 of the Preferred Options. ruins dating to medieval times and a Scheduled Ancient Monument (the same level of protection as Stonehenge, I'm led to believe), not to mention habitats for Great Crested Newts and bats. Of course there are also the homes of hundreds of families and the much loved village primary school - all, presumably, to be blighted by noise, dust, pollution, traffic, loss of footpaths and byways and damage to the visual environment. We already have to suffer the HGV traffic generated by Taylormade Timber and the noise from night-time operations. I do hope that the residents of Pittington and the surrounding settlements can rely upon our council officials to ensure that no development of this type is ever allowed on the proposed sites.

Ms Philipson I strongly agree that these should NOT be identified as strategic sites. The 2 Agreement that these sites should not be identified as Pittington sites are, to start, far too close to residential areas. Residents would suffer strategic sites noted. directly from the light pollution, noise, dirt and dust, reduced air quality, smell, vibration and potential loss of privacy and general loss of the wide benefits of living The environmental impacts of the proposed surface in a peaceful, rural landscape. The environment would suffer a permanent loss of mined coal sites will be fully considered when we prepare its ecosystems and biodiversity, including established hedgerows, waterways, trees the allocations document. At that stage all and plants and a range of birds, animals and insects (some of which are in SSSIs representations made to this document will be taken into protected by law). The roads around Pittington are winding/hilly minor rural roads, account. Our approach to surface mined coal and fireclay they wouldn't be physically suitable (or safe for drivers/pedestrians) if there was is set out in policy 56 of the Preferred Options. any increased movement of heavy lorries/equipment on them. I would also doubt the adequacy of the entire infrastructure around Pittington (particularly drainage and water supply) to support surface mining and I have additional concerns about potential impact on the historic environment in and around Pittington, particularly the church. These surface coal mining sites should not be approved at any time in order to protect local residents and the local environment.

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Mrs Lynne Pattison The planned sites around Pittington are too close to public residential homes and The environmental impacts of the proposed surface families. The village of Pittington will be devastated if this plan goes ahead the lives mined coal sites will be fully considered when we prepare of the families who live here will be effected dramatically. The site is a short distance the allocations document. At that stage all away from the primary school where children aged from 3 to 11 years attend. The representations made to this document will be taken into dust, noise and air pollution will have an irreversible effect on their health and account. Our approach to surface mined coal and fireclay well-being. The quality of life will change for everyone who lives and works within is set out in policy 56 of the Preferred Options. Pittington and the surrounding areas. I live in Pittington with my 3 young children and would be devastated if these plans go ahead and they become indoor children as the outside air would be so full of dust and fumes that they where simply unable to play outside as children should.

Mrs Paula Wain I strongly agree that these should NOT be identified as strategic sites. It is clear Agreement that these sites should not be identified as from the comments on this forum that any thought of opencast mining on the edge strategic sites noted. of Pittington will always be opposed for all the reasons outlined so eloquently by other residents. I have faith that the proposals to develop opencast mines in these The environmental impacts of the proposed surface sites will be continue to be seen for what they are: COMPLETELY UNACCEPTABLE. mined coal sites will be fully considered when we prepare the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr Gordon J Brown Pittington opencast proposal."YES I AGREE WITH THE DCC ASSESSMENT THAT Agreement that these sites should not be identified as THESE TWO LOCATIONS- SHOULD NOT BE CONSIDERED AS STRATEGIC strategic sites noted. MINERAL RESOURCES"For the following reasons. The environmental impacts of the proposed surface 1. Noise from vehicles and machinery mined coal sites will be fully considered when we prepare the allocations document. At that stage all 2. Dust, mud, debris on the roads. representations made to this document will be taken into account. Our approach to surface mined coal and fireclay 3. Exhaust fumes is set out in policy 56 of the Preferred Options.

4. Increase in traffic. Access to the A690 is difficult at the best of times with large vehicles it will be nigh on impossible to turn right to head towards Sunderland.

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5. Increase in the areas 'carbon footprint' from machinery and vehicles, also from burning of the coal obtained from the sites. 6. Loss of arable land. The crops that are grown there now will have to be grown elsewhere in the UK or imported from abroad, adding to the price of the product and again increasing the 'carbon footprint'.

7. Roads too small and poorly maintained too handle the increased traffic.

8. The development proposed by Ramside Hall (golf course) would be affected.

9. General quality of life will be severely affected by all of above.

Mr Dave Arnott My only comments would be on the operator proposed locations for Pittington: The environmental impacts of the proposed surface There is a groundswell of concern on the thoughts to mine near Priors Grange on mined coal sites will be fully considered when we prepare the grounds of dust, noise, vehicle movements and amenity. A number of my the allocations document. At that stage all neighbours are very frightened of any works happening so near to the houses. representations made to this document will be taken into There is a feeling, justified or not that this consultation was quick and not well account. Our approach to surface mined coal and fireclay publicised. For my own part a neighbour told me. is set out in policy 56 of the Preferred Options.

Mr Tim Roberts I agree, these areas are entirely unsuitable due to their proximity to long-established Agreement that these sites should not be identified as rural and semi rural communities. The environmental effects cannot be outweighed strategic sites noted. by such short-term economic benefits from these extraction proposals. There would be limited or no benefit to the local community. Any "job creation" would be The environmental impacts of the proposed surface short-term, and would have little impact on these communities. The local mined coal sites will be fully considered when we prepare infrastructure would not support such an increase in heavy transport. Many of the the allocations document. At that stage all communities affected are already subjected to the largest, and heaviest HGV traffic, representations made to this document will be taken into (quarry and timber,) on roads neither strong enough, nor wide enough to safely account. Our approach to surface mined coal and fireclay accommodate such movement. Properties on these routes vibrate as the vehicles is set out in policy 56 of the Preferred Options. pass and brake heavily. Such lorries are often driven at speeds not conducive to the safety of other road users and pedestrians. I am sceptical about the proposal to remove from Pittington North via the A689. I do not believe it is practical, and that in fact they would seek to change to route via A690. This would put an unnecessary extra burden on an infrastructure already at braking point. At least one residential road has an apparent speed limit of 60mph which the local authorities have refused to reduce due to lack of evidence, (IE death/injury.) i cannot envisage more HGV able to drive on this road at these speeds. The Pittington North proposal backs straight onto my property and business, and there are clear implications for

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me in many areas. There is the increased risk of land shift, impact due noise/dust of the operations and transportation. Effect on property value. Effect on my business which currently relies on there being a low-level of background noise.

Mr William Kellett 1: The site for Pittington South abuts housing along one long boundary. Any working The environmental impacts of the proposed surface would inflict on these residents environmental pollution in the form of: Dust.... from mined coal sites will be fully considered when we prepare the extraction and removal process to be followed later by infill operations. Noise.... the allocations document. At that stage all there will be inevitably noise associated with ALL open cast operations which cannot representations made to this document will be taken into be removed or even reduced to an acceptable level by preventative measures. account. Our approach to surface mined coal and fireclay Dirt.... from the wheels and from the transport of materials associated with open is set out in policy 56 of the Preferred Options. cast operations. 2: Proximity of the ancient church St. Lawrence which is regularly visited by people from all over the world. Opencast operations would deter such visits. 3: Proximity of the SSI at Pittington Hill...This site contains a pocket of an extremely rare species of grass ,a relic of the last Ice Age, and as such, one of only a handful in the UK. This grass would be badly damaged,if not totally wiped out by dust carried by the prevailing wind and settling on the grass. There are no preventative measures that would prevent this. 4: Effect on the water table.... Leakage from operations would infiltrate into the limestone strata polluting streams and waterways. Water is also extracted for drinking purposes from boreholes sunk into the limestone. 5 Traffic...... There is already a heavy burden of traffic by timber and timber products going to and from the Taylormade timber works at Sherburn Hill. This traffic operates 7 days a week and 24 hours a day. Heavy vehicles from existing quarrying operations in the area also pass through Pittington on roads which were never designed to take such traffic. 6...... Fauna.... there are known to be active badger sites in the area as well as protected species of birds and Bats. 7...... Maps of former mining activities show the existence of 5 known mining sites on the Pittington South site which may have removed much of the coal allegedly lying near the surface. If so then open cast operations would need to go much deeper and take much longer than the forecasts provided. 6 Footpaths...Several footpaths run through the site and which could not be easily nor safely diverted.. namely Footpaths.23. [between High Pittington and Low Pittington emerging opposite the Blacksmiths Arms Public House.... 25; Between Low Pittington and Sherburn Village. I wish to add these observations as part of your process of consultation. Addendum to my original submission. 1) Footpath 25; This very well used footpath is is part of a cycle/walkway route from Hetton-le-Hole to Sherburn Village and beyond. There is only a limited alternative route via the main Pittington-Sherburn Village road 2) Pittington Beck. This beck flows through a flat flood plain to the North-East of the Low Pittington--High Pittington road. As such, it has regularly

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overflowed and caused flooding in the area North of this road ( photographic evidence available. )The beck meanders through a 90 degree turn at one point. One area is, and has been fenced off for over 30 years because of the marsh conditions which represent a danger to livestock. This beck then passes,via a culvert ,under the road to enter the proposed site for open cast operations, passing through the centre at its lowest point. Any mining operations would, in all probability, cause flooding to the properties adjacent to the beck. In 2003, for example,as a result of the sever rainfall and consequent rise in the level of the beck Paddock House as well as 2 adjacent terrace houses were flooded. Paddock House was so badly affected as to render it uninhabitable for a considerable period of time. The result of the beck bursting its banks also resulted in sever flooding in the field to the rear of our property coming to the boundary of our garden.

Mrs Lisa Bowes As a resident of Priors Grange my opinion is that Yes I AGREE with the DCC Agreement that these sites should not be identified as assessment that these two locations SHOULD NOT be considered as strategic strategic sites noted. mineral resources. This been for the following reasons: 1. Noise from vehicles and machinery 2. Dust, mud, debris on the roads. 3. Exhaust fumes 4. An increase in The environmental impacts of the proposed surface traffic. Access to the A690 is difficult at the best of times with large vehicles it will mined coal sites will be fully considered when we prepare be nigh on impossible to turn right to head towards Sunderland. 5. Increase in the the allocations document. At that stage all areas 'carbon footprint' from machinery and vehicles, also from burning of the coal representations made to this document will be taken into obtained from the sites. 6. Loss of arable land. The crops that are grown there now account. Our approach to surface mined coal and fireclay will have to be grown elsewhere in the UK or imported from abroad, adding to the is set out in policy 56 of the Preferred Options. price of the product and again increasing the 'carbon footprint'. 7. The roads surrounding the proposed site are far too small and poorly maintained too handle the increased traffic. 8.. General quality of life will be severely affected by all of above. 9. House prices in Priors Grange as well as other areas of the village will be affected as who would consider buying a house near to a site like this.

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4. An increase in traffic. Access to the A690 is difficult at the best of times with large vehicles it will be nigh on impossible to turn right to head towards Sunderland.

5. Increase in the areas 'carbon footprint' from machinery and vehicles, also from burning of the coal obtained from the sites.

6. Loss of arable land. The crops that are grown there now will have to be grown elsewhere in the UK or imported from abroad, adding to the price of the product and again increasing the 'carbon footprint'

7. The roads surrounding the proposed site are far too small and poorly maintained too handle the increased traffic.

8. General quality of life will be severely affected by all of above.

9. House prices in Priors Grange as well as other areas of the village will be affected as who would consider buying a house near to a site like this.

Melanie Eve I was horrified to discover plans to carry out open cast coal mining at the rear of The environmental impacts of the proposed surface my home in Low Pittington. I can't sleep for the wood lorries going past the front of mined coal sites will be fully considered when we prepare my house from 3 am to midnight, and I am in despair at the thought of noise at the the allocations document. At that stage all rear of my home too. We have tried to sell and move to a quieter spot without any representations made to this document will be taken into success, having open cast planned for the back of the house will mean we never account. Our approach to surface mined coal and fireclay can sell up and move, and have implications on house prices for the whole parish. is set out in policy 56 of the Preferred Options. Please pass this on as an objection, or forward me the appropriate forms to lodge my complaint.

Rachel Cornelius I would like to raise an objection against the plans to create an open cast coal mine The environmental impacts of the proposed surface in the Pittington area. As described in the document attached open cast coal mines mined coal sites will be fully considered when we prepare affect the landscape, communities, wildlife, carbon emissions, noise pollution, traffic the allocations document. At that stage all etc. The roads are already bad enough with the logging waggon's that come in and representations made to this document will be taken into out, you can sit for over 30 mins just to get out the junction onto the A690 some account. Our approach to surface mined coal and fireclay mornings waiting for the trucks to get out. My youngest daughter had asthma quite is set out in policy 56 of the Preferred Options. badly when she was younger and the article in the link below describes the affect on children's respiratory health.

http://ukpmc.ac.uk/abstract/MED/10810095/reload=0;jsessionid=B92518B8B7187580A2318B19FADFCE50.jvm4

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Besides the health risks, I would say most of the people living in Pittington do so because they enjoy the surrounding area. Pittington is a quiet, happy and relaxed place to live and a lot of people walk regularly with their children and dogs (myself included) and wouldn't want to see the area spoiled for the sake of a coal mine. I think if this were to go ahead it would not only be an eyesore and an inconvenience but would have an adverse affect on the general wellbeing of the local residents.

Lee Bryan I strongly agree that Eldon Blue House, Pittington North or Pittington South should Agreement that these sites should not be identified as not be identified as strategic sites in the Core Strategy DPD. I believe that these strategic sites noted. sites should not be allocated for the following reasons; Environmental impact -dust, noise, water pollution, waste, effect on local wildlife and habitats, increase in heavy The environmental impacts of the proposed surface transport movements, increase in risk to health and safety to local residents, loss mined coal sites will be fully considered when we prepare of arable land, visual impact, loss of public areas for rambling, dog walking, cycling the allocations document. At that stage all and a reduction in tourism. I moved to Pittington 2 years ago because of its semi-rural representations made to this document will be taken into location and sense of community. My 2 children attend the local Primary School account. Our approach to surface mined coal and fireclay and I am currently the Chair of Governors. Children also attend the Primary school is set out in policy 56 of the Preferred Options. from other areas and the increase in risk to their health and safety would not be acceptable. The village hall is well used by clubs and organisations including Pittington Brass Band, again with a number of members coming from outside of the village. If the area was surrounded by open cast members would move away making the clubs unsustainable. The areas surrounding Pittington have outstanding views, sites of special scientific interest, a grade 1 listed church and grade 2 listed buildings. I feel that open cast mining would have a devastating impact on the area and community.

Mrs Sandra O'Connor I agree with DCC assessment that neither sites at Pittington should be considered Agreement that these sites should not be identified as as strategic mineral resources. As a resident of Priors Grange, I believe that the strategic sites noted. proposed South Pittington site is in too close proximity to residential housing and the resultant dust and noise pollution would have a serious effect on local residents The environmental impacts of the proposed surface quality of life. The local road infra-structure could not cope with the increase in mined coal sites will be fully considered when we prepare heavy vehicular traffic. The local roads are already under pressure due to the volume the allocations document. At that stage all of traffic going to and from Taylormade Timber Yard. There would be a severe representations made to this document will be taken into impact on local wild-life. The surrounding landscape of Pittington would be spoilt. account. Our approach to surface mined coal and fireclay It is an area enjoyed by cyclists and walkers. I believe that the long-term is set out in policy 56 of the Preferred Options. environmental impact far outweighs the short term economic gain.

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Mrs Christina Hardy I agree. There would be an adverse impact on the quality of the environment for Agreement that these sites should not be identified as nearby residential settlements. There would be loss of amenity of cycle paths. There strategic sites noted. would be adverse impact on transport routes. It would also be destructive of the green belt. The environmental impacts of the proposed surface mined coal sites will be fully considered when we prepare the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr George ARMATAGE I agree. Sites too near to housing and would cause excessive noise and dirt pollution Agreement that these sites should not be identified as apart from the additional volume of heavy traffic on country roads. Also, the value strategic sites noted. of the properties in Pittington would decrease. The environmental impacts of the proposed surface mined coal sites will be fully considered when we prepare the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mrs Berni Whitaker I agree with DCC's intention to not identify Pittington North or South as strategic Agreement that these sites should not be identified as sites - the proposed sites lying as they do in close proximity to settlements areas strategic sites noted. would have a devastating impact on a beautiful part of the county. Noise and air pollution, dirt and dust, and traffic congestion for 6 years whilst coal is extracted The environmental impacts of the proposed surface and land re mediated is too high a price to pay for quality of life and to the mined coal sites will be fully considered when we prepare environment itself. I understand the need to improve GVA by producing more the allocations document. At that stage all domestic goods but the balance needs to be carefully considered and in this case representations made to this document will be taken into the impact on land and life far outweighs the economic benefit of a few tons of coal. account. Our approach to surface mined coal and fireclay If these sites are to be deemed not strategic and proposals were to come forth from is set out in policy 56 of the Preferred Options. developers to be considered through the Minerals and Waste Policies and Allocations or through the planning system then it would be hoped that DCC would refuse these on the same basis as the strategic sites argument. Lets keep County Durham green and preserve our environment making it sustainable well into the future.

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Mrs Jay Hastie I strongly agree that Eldon Blue House, Pittington North or Pittington South should Agreement that these sites should not be identified as NOT be identified as strategic sites in the Core Strategy DPD for the following strategic sites noted. reasons. The environmental impacts of the proposed surface 1.This is a rural community and the road network around the villages would not mined coal sites will be fully considered when we prepare support the substantial increase in heavy traffic., it is already under pressure from the allocations document. At that stage all heavy traffic to and from Taylormade Timber and local quarries. The Blacksmith's representations made to this document will be taken into crossroads is already a black spot for accidents. account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options. 2 The cycle and bridle ways are well used by walkers, cyclist and horse riders as are the village roads where footpaths are limited. This would be impossible if the proposal were to go ahead. This would have a negative effect on the quality of life and recreational pursuits of the community. The Council have a duty to protect this land for the community.

3 Businesses such as Hallgarth Manor, Blacksmiths Pub, Homer Hill Farm Shop and Ramside Golf club would suffer and jobs would be lost.

4 The living environment would deteriorate due to increase noise and dust pollution day and night.

5 It would be very close to the historically and culturally significant Hallgarth hamlet and grade 1 listed St Lawrence Church which currently attracts many visitors.

6 the stunning and important views from Pittington hill across Durham and including Durham Cathedral and Castle would be destroyed.

7 The close proximity to dwellings in the villages would have a very negative effect on house prices in the area, people would not wish to move into the area, this in turn would have a negative effect on the village school as new families would not move into the area.

8 Pittington Quarry site is a Site of Special Interest because of the special plants that grow there. The prevailing wind will carry dust and pollution over our village and into the quarry. this could never be replaced. As a parent and now a grandparent I have enjoyed raising a family in this environment and if it were to be destroyed by

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such a development it would be intolerable. I would urge the council to take note of the unanimous views expressed on this site and do not identify these areas as strategic sites for mineral extraction. Thank you.

Miss Claire Hodgson We have just learnt of this proposal, for open cast coal mining at High & Low The environmental impacts of the proposed surface Pittington, adjacent to the A690 as well, and write to object. Open cast will ruin the mined coal sites will be fully considered when we prepare area, the traffic flow, the ability of many to use the walks and bridleways for walking, the allocations document. At that stage all cycling and equestrian activities. We both enjoy outdoor activity's 'one of us rides, representations made to this document will be taken into the other walks' and this proposal will spoil both paths and bridleways. It will also account. Our approach to surface mined coal and fireclay make the roads affected far too busy and dangerous. That is of course, quite apart is set out in policy 56 of the Preferred Options. from the bad effect it will have on general living conditions. Currently there is a nice corridor of countryside between Durham City & Sunderland, and that will be badly affected.

Mr Christopher Barrett I wish to object to the proposed open cast although I am well aware that these The environmental impacts of the proposed surface objections get us nowhere. I could write pages on why I object but I will restrict mined coal sites will be fully considered when we prepare myself to the obvious; The local roads already struggle to cope with the traffic they the allocations document. At that stage all have and I do not suppose you intend to build new ones or even widen the existing representations made to this document will be taken into ones. One only has to look at the history other sites used for open casting to see account. Our approach to surface mined coal and fireclay that the land never returns to any sort of productivity. With the population and climate is set out in policy 56 of the Preferred Options. problems facing us it is food production we should concentrate on rather than producing more pollution. The income generated by the sites will short term and not local. We were assured after the last series that we would not have to endure any more. The close proximity to schools and SSSI.

Mr Roger Marsden This is a beautiful area rich with diverse wildlife and very close to the historic city The environmental impacts of the proposed surface of Durham - This would be very close to the historically and culturally significant mined coal sites will be fully considered when we prepare Hallgarth area which of course includes St Lawrence church which is grade I listed the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mrs Suzanne Pickering Agree! Pittingon is currently a quite village and an area of high landscape value. Agreement that these sites should not be identified as The small country roads in and around the village can not cope with the increase strategic sites noted. in traffic and larger vehicles. Noise and pollution day and night will effect peoples quality of life especially children and asthma sufferers. Areas of recreation will be The environmental impacts of the proposed surface ruined footpaths, bridleways, arable land, wildlife which there is so few of now, need mined coal sites will be fully considered when we prepare to be protected. the allocations document. At that stage all

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representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mrs A Kellett I submit a strong objection to the proposed opencast mining development at Low Agreement that these sites should not be identified as Pittington for the following reasons:- 1. Station Road consists of 5 terraced houses, strategic sites noted. in these there are 5 small children. Having looked at blocks of 5 houses in other parts of Pittington, there are no examples where such a concentration of small The environmental impacts of the proposed surface children live parallel to an already dangerous road. Therefore â€“ any increase in mined coal sites will be fully considered when we prepare the volumes of heavy traffic would further endanger the lives of those boys. 2. The the allocations document. At that stage all cross road junction at Low Pittington has a prominent history for RTAs in the 33 representations made to this document will be taken into years I have lived here, and monitored the RTAs, they average 1 per month. An account. Our approach to surface mined coal and fireclay increase to the already flow of heavy vehicles would add to the potential for a fatal is set out in policy 56 of the Preferred Options. accident at this junction. 3. There are 2 bus stops on Station Road; the stop serving the no 65 to Seaham Harbour is particularly hazardous. As the stop is well used by elderly residents and mums with babies in buggies, crossing this road is dangerous. Any increase in the volume of heavy vehicles adds to the risk of injury to these people. 4. At present, the 30 mph disc on Station Road is situated approx 150 metres from the crossroads. However, the majority of motorists ignore this sign and brake approx 10 metres from the crossroads. Indeed on numerous occasions the cross the junction having braked too late, many do not even stop at the crossroads. Yet again, any increase in the volume of heavy vehicles would exacerbate an already dangerous junction. 5. As a resident of Station Road, I have some difficulty at times turning right into my yard for parking my car. Nowhere in Pittington do other residents have the same problem, bearing in mind, when I turn right into my yard the volume of traffic onto Station Road feeds from 3 roads. Any increase in the volume of vehicles thereby endanger my life whilst attempting this manoeuvre. 6. The proposal for opencast coal mining on this site would result in heavy plant machinery and subsequent noise. The development would also produce filth, dust, indirect contravention of the Clean Air Act and thereby contaminate the environment and be detrimental to my health and well-being. 7. Some years ago, a considerate time and money was spent reducing the risk of flooding along the approach to Station Road. Any development that would interfere with the topography of the land adjoining Station Road would undo any work done and leave this road under a substantial amount of slurry, dirty water from the site. 8. Across the junction from the cross roads there is a colony as smooth backed newts. As there are an endangered species any development would jeopardise its habitat and its existence. 9. A number

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of years ago, when renovating our house, the Archaeology Dept, Durham University visited us, as we found a medieval dwelling beneath our existing foundations. The Archaeology department dated our home to 1740, and the adjacent cottage to 1743. Any increase in heavy traffic and vibration from heavy plant machinery would endanger the structural integrity of our dwelling. As the first dwelling to be built in Low Pittington, and therefore historically the oldest home in Low Pittington, I feel that its future should not be compromised by this development.

Dr Quentin Anstee I agree that the sites Pittington North (including Field House), Pittington South and Agreement that these sites should not be identified as Eldon Blue House should NOT be identified as strategic sites. These areas are strategic sites noted. entirely unsuitable due to their proximity to long-established rural and semi rural communities. In recent history, County Durham has been subject to many deep The environmental impacts of the proposed surface mines and the subsequent ecological damage caused by them. Much time, energy mined coal sites will be fully considered when we prepare and money has been invested to retrieve this area from past mining damage and the allocations document. At that stage all to build the reputation of County Durham to one based on a 'Knowledge Economy' representations made to this document will be taken into of skill-led industries and tourism. Development in the Pittington North (Field House), account. Our approach to surface mined coal and fireclay Pittington South and Eldon Blue House proposal areas would be a retrograde step is set out in policy 56 of the Preferred Options. for County Durham. I oppose any application for mineral extraction in these areas on the basis that they run contrary to the interests of the local community and the broader interests of County Durham. In particular I would like to highlight the following: 1. The Pittington North (Field House) and Pittington South sites are immediately adjacent to residential properties in Rainton Gate, Low and High Pittington. The neighbouring villages of Sherburn, Belmont and Rainton and their populations would also be affected by these proposals. I am therefore concerned about the environmental impact in terms of noise, air pollution, traffic, land disturbance and the detrimental effect on house values. None of which can be entirely mitigated against by the developers and so these developments cannot be considered environmentally acceptable. 2. Harm to the reputation of County Durham and local businesses. The areas neighbouring the Pittington North (Field House) and Pittington South sites contain several hotels (Ramside Hall, Hallgarth Manor, etc). As such these areas draw visitors (both through tourism and business travel) into the area. Proximity to surface mining in the 'shop window' of the County would not only adversely impact on these businesses directly but would harm the regions reputation impacting on tourism in general and the ability of businesses in the region to attract high quality staff and investment. 3. Lack of Economic Benefit to Local Community. The levels of employment that these proposals are likely to generate are very low and are only short term jobs. Given that employment law would necessitate mining companies to first offer jobs to their existing staff from worked-out

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sites elsewhere, it is extremely unlikely that these jobs would benefit the local community. There are no local businesses that require large coal supply and so, as the developers concede, the coal would need to be moved to Yorkshire and other areas of the country. As already mentioned, the traffic disruption, noise and pollution would adversely impact on local businesses and would threaten the existing employment of many local people and development of further long-term jobs in exchange for a short-term mining dividend for companies based in other parts of the UK. Thus, mining on these proposed sites would not contribute to or maintain economic growth but would actually threaten existing business. 4. Harm to Wildlife, Natural Habitats and the Environment. There are a number of legally protected Sites of Special Scientific Interest (SSSIs) in the immediate area. The High Moorsley and Moorsley Bank SSSIs are directly adjacent to (and possibly within) the proposed Pittington North site whilst the Pittington South Site would be within a short distance of the Pittington Hill SSSI. The area has a diverse flora and fauna and is used and enjoyed by walkers, joggers, cyclists and riders of all ages both from local communities and from farther afield. The proposed development threatens these SSSI and will also deprive the community of several footpaths, bridle ways and cycle paths. Further, as the sites are largely agricultural land on the edge of the greenbelt and not derelict or contaminated, no argument can be made that these proposals offer any benefit in terms of land reclamation. 5. Lack of Supporting Infrastructure. The transport of coal off-site, either via the A690 or A689 and onwards would substantially increase the burden of traffic on the already congested and small roads around the proposed mine sites. Many of the communities affected are already subjected to heavy HGV traffic (quarry and timber) on roads neither strong enough, nor wide enough to satisfactorily accommodate such movement. Properties on these routes vibrate as the vehicles pass and brake heavily.

Morris I agree that these sites should not become surface mine coal sites for the following Agreement that these sites should not be identified as reasons: *damage to wildlife and loss of habitats *proximity to residential homes strategic sites noted. *danger from lorries to cyclists, horse riders and pedestrians on the narrow roads around the sites *loss of public footpaths and bridleways *adverse effects of dust The environmental impacts of the proposed surface and noise on local population *adverse effects on local businesses and tourist mined coal sites will be fully considered when we prepare attractions *increase in release of carbon the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

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Mrs Kate Macpherson I agree that with the statement above that Pittington North, Pittington South and Agreement that these sites should not be identified as Eldon Blue House SHOULD NOT be identified as strategic sites in the core strategy strategic sites noted. DPD. These sites should not be allocated for a number of significant reasons: 1) The area identified is a beautiful area of countryside that is used extensively for The environmental impacts of the proposed surface recreational purposes. We all value the surrounding countryside, including the mined coal sites will be fully considered when we prepare stunning views from Pittington Hill over Durham and to the North. Cycle route 20 the allocations document. At that stage all runs right through the centre of the proposed North Pittington site. My family is representations made to this document will be taken into amongst the many locally that use the area for cycling, walking and running. Allowing account. Our approach to surface mined coal and fireclay mine development would curtail those activities for local people and visitors alike. is set out in policy 56 of the Preferred Options. 2) The road network around the villages is already under pressure from heavy wagons visiting Taylormade Timber and local quarries. It is at present extremely precarious to walk to High Pittington from Low Pittington or out to Homer Hill Farm Shop. Driving conditions are also hazardous. Allowing up to 60 additional wagons per day into the area will make an already difficult situation even worse. The infrastructure cannot cope with this extra traffic. Driving, cycling and walking between our villages and out to the A690/A1 will be dangerous and increased road traffic accidents are likely. The noise of increased traffic will be detrimental to the well being of many households who already put up with heavy wagons passing their homes for most of the day and night. 3) Pittington Quarry is designated as a site of special scientific interest. The prevailing wind will carry dust and pollution from the mines over our villages and into the quarry causing environment damage that is unacceptable. An already fragile ecosystem will be damaged and the plethora of plants, birds and wildlife around our villages will be damaged beyond repair. Although developers and mineral companies often offer to 'improve' land after they have finished, there is simply no need to improve our area. It's great as it is. We love our countryside and don't wish to see it damaged, rather protected and maintained. 4)Although the proposals may bring some jobs to the area, those jobs will only offer short term employment . The development will have a far greater negative impact on existing business in the area such as the Hallgarth Manor Hotel, Ramside Golf Club and Homer Hill Farm shop. Theses businesses rely on visitors to the area who want to enjoy the beautiful surrounding countryside. They are unlikely to visit if the mines go ahead. I would hope to see the council investing in green and sustainable business that will attract visitors to our area and enhances the beautiful natural resources on our doorstep. Short term gain to the detriment of the landscape and those that live in this area should simply not be a part of your strategy. 5) I realise that mining companies suggest that they will do everything they can to reduce dust and noise pollution. They may minimise damage to the health of those of us living here but tthey cannot completely negate the effects of pollution in our villages. I am

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deeply worried about the affect the noise, the dust and the pollution will have on the health of our residents and on the countryside. 6) As a parent I am deeply concerned about the effect these proposals will have on the health and quality of life for my child and all the children who live here and who attend the thriving village school. Getting them safely to and from school will be hazardous, their learning environment will be compromised and their ability to play and exercise outside (at school and home) will be limited. Please take into consideration the unanimous views expressed in all the comments on this site and do not identify these areas as strategic sites for mineral extraction.

Dr Colin Macpherson I agree that the sites Pittington North (including Field House), Pittington South and Agreement that these sites should not be identified as Eldon Blue House should NOT be identified as strategic sites for minerals extraction. strategic sites noted. These are semi-rural sites that are in need of no improvements, indeed, they have already been considerably improved to reclaim them from the impact of prior deep The environmental impacts of the proposed surface coal mining. The area around Pittington provides significant recreational amenities mined coal sites will be fully considered when we prepare and sustains several businesses which rely on visitors wishing to come to an the allocations document. At that stage all attractive environment. It also hosts a number of important sites of natural heritage. representations made to this document will be taken into As such, it would be entirely inappropriate to allow mining development at these account. Our approach to surface mined coal and fireclay sites and I am entirely opposed to any proposal to allow mining there. I am is set out in policy 56 of the Preferred Options. particularly concerned about: 1: The roads, lanes, paths and bridleways around the Pittington North and South sites are heavily used by walkers, horse riders and cyclists. Several access routes through the countryside would be lost and there would be a negative impact upon the visual aspect of many more if these developments were permitted. This would affect local residents on a daily basis, but would also diminish the attraction of our community to visitors and tourists who come to visit St. Lawrence Church, to tackle the national coast-to-coast cycle route (Route 20, which is part of both proposed development sites), or simply to enjoy the beautiful countryside that Pittington offers. 2. I commute past both sites to Durham, sometimes by car and sometimes by bicycle. My son is a pupil at Pittington Primary School, to which many children are brought by car. There is already a very significant problem on the roads adjacent to both sites with heavy lorries from the Taylormade Timber plant in Sherburn Hill and from local quarries. The existing traffic load has been the subject of repeated requests for traffic calming from the community. Any further development would only amplify the existing problem. It would make many people feel even less safe than they do presently on the narrow country roads around the sites. From a personal point of view it would reduce the chance that I would continue to try and reduce my own carbon footprint by using my bicycle rather than my car. 3. Two Sites of Special Scientific Interest, at High

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Moorsley and Pittington Hill, lie just a few hundred metres from the proposed Pittington North development. Both are outstanding examples of the Permian magnesian limestone, with more extensive outcrop than almost any other publicly accessible locations in the County, and they support a diverse array of limestone grasses. These SSSIs deserve protection both for their distinctive geology and ecology, and for the spectacular view that they offer across North County Durham, incorporating the magnesian limestone escarpment, Durham Cathedral, Penshaw Hill, the Angel of the North and (on a clear day) the Cheviot. The ecology of both Pittington Hill and Coalford Beck Marsh (less than 500m south of the proposed Pittington South development) has led to their designation as County Wildlife Sites. These too need to be protected from mining development. 4. The proposed mining is likely to bring little economic benefit to the local community. Most employment opportunities will be offered to existing staff and will, anyway, only last as long as the projected lifetime of each site (no more than 5.5 years). Existing businesses close to the proposed sites, such as Hallgarth Manor Hotel, Ramside Golf Club and Homer Hill Farm Shop, rely on attracting visitors. Damaging the appeal of Pittington and its surroundings could damage these businesses and offset the short-term gains in job numbers from the mines. Any coal extracted will not support business within the County. A more 'strategic' approach to these coal reserves would be to leave them in the ground in case the country ever finds itself in real energy crisis when overseas sources are not available. 5. Having visited many mines, as part of my work, I am aware of the measures that developers take to minimise the impact of noise, dirt and pollution; from the workings themselves, the processing of raw materials and the heavy lorries that transport the resources of site. I am also aware that the effectiveness of such measures are all highly dependent on the weather and that they are not able to provide anything like 100% protection to local populations from the impact of noise and dirt upon their day-to-day lives. The proposed developments lie immediately north and west of Pittington and so prevailing winds will transport noise and pollution over the villages (including the SSSIs mentioned above) on a regular basis. As a parent, I am particularly concerned of the proximity of the proposed Pittington South site to Pittington Primary School, and the potential impact that noise and pollution could have on the ability of children to enjoy an appropriate environmnet for work and play at the school.

Mrs Sarah Parker I object to the proposal of Pittington North or South being used as a strategic site Agreement that these sites should not be identified as for open cast mining. My concerns involve the increase of road traffic in a populated strategic sites noted. and already busy area. The proposed area contains areas of historic and

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archaeological interest. The visual impact will be devastating on the village of The environmental impacts of the proposed surface Pittington. A number of important natural areas will be adversely affected by the mined coal sites will be fully considered when we prepare proposed sites. the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr Matthew Briggs I agree and support the council in their intention NOT to identify these areas as Agreement that these sites should not be identified as strategic sites in the Core Strategy DPD. Having read the proposal, I strongly object strategic sites noted. to any extraction in this area failing to find any justification for extraction of coal. Alternative methods of energy generation and more extensive use of non greenhouse The environmental impacts of the proposed surface gas producing methods are vastly under-utilised. The massive increase in traffic mined coal sites will be fully considered when we prepare and pollutants will have a detrimental effect on health and the surrounding area the allocations document. At that stage all adding as many as 60 HGV's per day. Access on to the A690 is already dangerous representations made to this document will be taken into and many accidents have occurred at the Rainton Gate junction. Whilst short term account. Our approach to surface mined coal and fireclay employment will benefit, it is long term employment which will give sustainable is set out in policy 56 of the Preferred Options. growth to the county. The proposed development will sever existing public rights of way and well known cycle routes and the quality of life of local residents and passers by will be severely affected. Following the end of the extraction, there is no stated standard which improvements must meet. The statement is very non specific and I am concerned that should this proposal go through, we would be left with an dangerous eyesore or even worse, the area used for landfill. There is no need to improve the land after mining has ceased. Simply do not commence mining in the 1st place and we retain the use of a beautiful part of this county for future generations

Mrs Kathleen Fall I wish to confirm that the areas of Eldon Blue House, Pittington North and Pittington Agreement that these sites should not be identified as South should NOT be considered for any mining development. The area identified strategic sites noted. covers several well used footpaths, bridleways & cycle paths linking the Pittington's with Belmont, Sherburn, Rainton & Rainton Meadows. St Laurence Church (Grade The environmental impacts of the proposed surface 1 listed building) has recently registered as a Small Pilgrim Place, a move that will mined coal sites will be fully considered when we prepare encourage people to walk to the area to visit, using existing footpaths. Pittington the allocations document. At that stage all Hill & quarry are sites of Special Scientific Interest and home to at least 1 extremely representations made to this document will be taken into rare orchid. Many people enjoy the walks and views from the area, dust and noise account. Our approach to surface mined coal and fireclay pollution from any would ruin is set out in policy 56 of the Preferred Options.

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K Emery As a resident of Moorsley for over 40 years I and my family have used the walkways The environmental impacts of the proposed surface and cycle routes around Moorsley to Pittington. Some of these have recovered from mined coal sites will be fully considered when we prepare previous industrial use and nature has restored the areas. The walkways and cycle the allocations document. At that stage all routes are enjoyed for the recreation of residents and visitors alike .I would be representations made to this document will be taken into against any scarring of these tranquil beauty spots. account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr Peter Johnson I understand that Durham County Council is currently consulting on a proposal to Agreement that these sites should not be identified as name two sites next to the villages of High and Low Pittington as strategic mineral strategic sites noted. resources, with a view to possible future open cast mining in the area. I wish to register my objection to the proposal on the following grounds. 1 It would constitute The environmental impacts of the proposed surface significant interference with the use of the area for leisure and recreation. My mined coal sites will be fully considered when we prepare personal interest is in cycling and walking but other interests (e.g. birdwatching, the allocations document. At that stage all botanical exploration, photography) will be adversely affected. Pittington Hill and representations made to this document will be taken into its surroundings are a very beautiful part of Durham and provide an easily accessible account. Our approach to surface mined coal and fireclay area of countryside for those living in Durham city. 2 There would be serious adverse is set out in policy 56 of the Preferred Options. environmental effects through the additional noise, dust and heavy transport. Already there are strains on the public infrastructure caused by quarries; open cast mining would exacerbate these difficulties. 3 The job creation argument should be looked at with some scepticism as there may well be adverse effects employment effects nearby, caused as the direct result of the mining. The two sites are a wonderful part of our heritage and bring pleasure to many, many people in the surrounding area. They need to be developed further for recreational purposes, not set back by the proposals under consideration.

Amanda Watson I agree with DCC assessment that neither sites at Pittington should be considered Agreement that these sites should not be identified as as strategic mineral resources. As a resident of Priors Grange, I believe that the strategic sites noted. proposed South Pittington site is too close to residential housing and the resultant dust and noise pollution would have a serious effect on local residents quality of The environmental impacts of the proposed surface life. The local road infra-structure could not cope with the increase in heavy vehicular mined coal sites will be fully considered when we prepare traffic. The local roads are already under pressure due to the volume of traffic going the allocations document. At that stage all to and from Taylormade Timber Yard. There would be a severe impact on local representations made to this document will be taken into wild-life. The surrounding landscape of Pittington would be spoilt. It is an area account. Our approach to surface mined coal and fireclay enjoyed by cyclists and walkers. I believe that the long-term environmental impact is set out in policy 56 of the Preferred Options. far outweighs the short term economic gain.

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Mrs Diane Clifford The sites listed as Pittington North and South are both very close to residential Agreement that these sites should not be identified as settlements and contain, among other advantages, cycleways that are heavily used, strategic sites noted. both for leisure and as local commuter routes. They are areas of considerable beauty and have a healthy wildlife population. The access roads onto the A690 are The environmental impacts of the proposed surface narrow and lined with houses. West Rainton has been very close to Opencast mined coal sites will be fully considered when we prepare mining in the past and The Meadows housing estate was built over an old mining the allocations document. At that stage all site, causing huge complications during the building. Rainton Meadows Reserve representations made to this document will be taken into (Durham Wildlife Trust) is on an old opencast site and runs up the A690, opposite account. Our approach to surface mined coal and fireclay part of the proposed mine. The noise and dirt pollution would have an adverse effect is set out in policy 56 of the Preferred Options. upon local amenities such as the Homer Hill Farm shop. In the Durham Times of January 23rd there is an announcement of Ramside Country Club's plans to extend the golf course and build houses on a corner of their site to finance their project. This would be ruined by an Opencast operation. Who would want to buy a new house that breathed in the dust from the mining operation and viewed the operation from its garden? This is not nimbyism. These villages are, at present, free from the adverse effects of their industrial past. People work very hard to maintain this environment. It would be tragic if all that work was to be wasted.

MR Robin Morris I agree with the above statement I am opposed to any form of opencast development. Agreement that these sites should not be identified as It will destroy the quality of life we moved to Pittington to enjoy. In particular it will strategic sites noted. impact :- 1 Landscape Opencasting would destroy the existing landscape which is pleasant, rural, and recognised as having high landscape value. Overburden mounds The environmental impacts of the proposed surface would dominate the landscape and be visually intrusive spoiling views to Pittington mined coal sites will be fully considered when we prepare hill and the land beyond. 2 Noise Opencasting is a noisy operation. Blasting is noisy. the allocations document. At that stage all Warning sirens for blasting are required to be noisy. Drag lines and diggers are representations made to this document will be taken into noisy. Reverse claxons are noisy for all vehicles on site. Opencasting as proposed account. Our approach to surface mined coal and fireclay is close to the settlements of High and Low Pittington. The prevailing winds are is set out in policy 56 of the Preferred Options. from the West and South West. These will guarantee to carry the noise into the villages. 3 Dust Air quality in Pittington is very good. Opencasting will destroy air quality. It will make breathing difficult. Good quality air supports an extensive range of bird species and mammals. These will suffer. 4 Water Surface water drainage will be adversely affected particularly in Low Pittington where there are already problems with flooding. Leachate from coal washing and waggon wheel washing is likely to pollute water courses and to have a corresponding negative impact on aquatic and bird life. 5 Roads The roads around Pittington are heavily patched. Heavy lorries will further weaken their structure. Lorry movements will go past the doors of houses in Low Pittington and Sherburn. Access is unsuitable. 6 Restoration Opencast operators have a poor reputation for restoration. Both proposed sites at

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Pittington north and Pittington south are used for arable production of crops such as wheat, barley, rape and potatoes. It is extremely difficult to restore arable land back to full production. Arable land should not be used up in this way, probably for ever. 7 Amenity Being able to go walking and cycling around the village is all part of the quality of life which is shared by residents and visitors to Pittington. This would be very much restricted by opencasting. Visitors to the county encouraged by advertisements for the Land of Prince Bishops and the Passionate people Passionate places would be put off by opencasting.

Mrs Alison Metcalf I strongly agree that these should NOT be identified as strategic sites in the Core Agreement that these sites should not be identified as Strategy DPD. The sites are extremely close to residential areas and would have strategic sites noted. a detrimental effect on the entire area and the people living there. There is also a primary school in Pittington and the dust from this mining could well have a long The environmental impacts of the proposed surface term effect on the health of children and adults alike. There is also a considerable mined coal sites will be fully considered when we prepare amount of wildlife which should be protected from such pollution. The entire road the allocations document. At that stage all infrastructure could not cope with the extra traffic associated with such a huge representations made to this document will be taken into development. These proposals should be totally rejected. account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mrs Karin Younger I strongly agree that these should NOT be identified as strategic sites in the Core Agreement that these sites should not be identified as Strategy DPD. Reasons: * The result would be a blot on the landscape,both whilst strategic sites noted. in production, but also in that the areas afterwards, could never revert back to how they are now. The open countryside would be damaged irrevocably. * There is The environmental impacts of the proposed surface already a large amount of heavy traffic thundering through the village and causing mined coal sites will be fully considered when we prepare difficulty and potential danger when crossing the A690 at Rainton Gate- this would the allocations document. At that stage all exacerbate the problem *The Hallgarth Manor hotel is a local employer. One of the representations made to this document will be taken into sites appears to be across the road from the hotel. People are highly unlikely to account. Our approach to surface mined coal and fireclay want to book a stay there- or have their wedding held there. This would have a is set out in policy 56 of the Preferred Options. potential impact on employment and the local economy. * ' A number of protected species and designated nature sites lie either within the site or within 2km radius of the site' - therefore shouldn't the sites be protected. * There would be a huge environmental impact to local housing in terms of pollution, light pollution, noise pollution * Property prices would be affected * Visitors would not want to come to the area. I srongly object to the proposals

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Mr & Mrs D Taylor It has just come to our attention of a proposed surface coal mine site at Pittington The environmental impacts of the proposed surface North and Pittington South. Pittington North which is actually in West Rainton Parish mined coal sites will be fully considered when we prepare is the area where we live and we wish to make our objections to this proposed site. the allocations document. At that stage all Firstly our concerns is the Environment, the damage it is going to do to the open representations made to this document will be taken into countryside for i.e. wildlife, noise, dust and a lot of it and the public bridle path which account. Our approach to surface mined coal and fireclay actually is the Wearside Walks is adjacent to the proposed site. Volume of traffic is set out in policy 56 of the Preferred Options. would be horrendous i.e. the Lorries. The mess they make in wet weather on the roads which is dangerous plus in dry weather more dust to contend with which will go into the atmosphere and we will also have to think about the health of our children. Its a shame that someone can come along and propose an open surface coal mine in such a beautiful area as this and it would be devastation if this proposal went ahead.

Mr K Broy Mr wife and I have seen the proposed plans for two opencast mines over at South The environmental impacts of the proposed surface Pittington, the other North Pittington, the latter is actually in the parish of West mined coal sites will be fully considered when we prepare Rainton. We are absolutely horrified at the proposal for two opencast mines in this the allocations document. At that stage all area. The one at 'North Pittington' is so gigantic we hate to think what the fall out representations made to this document will be taken into would do for the environment. This is a predominately agricultural area. It is also account. Our approach to surface mined coal and fireclay the natural habitat for wildlife, i.e. deer, rabbits, hedgehogs, squirrels, foxes, is set out in policy 56 of the Preferred Options. partridges and badgers, also wildlife vegetation. We do not want the lives of adults and our children blighted by the fumes from heavy machinery, lorries etc, also dirt and dust from the actual excavation of coal. We are no experts, but it has long been known that coal dust can damage a persons health. The coal dust will not stay in place, but will pollute the atmosphere. There are schools nearby with young children of all ages "from nursery to fifth formers'“ what price their health. As for the country roads, they were not built for heavy industrial traffic. Finally you will see from our address our home lies on the borders of West Rainton, Pittington and Hetton-le-Hole parishes, our one aim is to safeguard the country life of ourselves and neighbours.

M Mercer After hearing about the council consulting on two proposed open cast sites in my Agreement that these sites should not be identified as area I feel I must register my objections in the strongest possible manner. As a strategic sites noted. resident of Low Pittington I am horrified at the damage this would do to our beautiful and I thought protected environment which I understood to be of â 'Special Scientific The environmental impacts of the proposed surface Interest'. Along with already heavy traffic delivering timber to Taylormade are we mined coal sites will be fully considered when we prepare now to endure a fleet of coal trucks making both walking and driving hazardous we the allocations document. At that stage all are still awaiting the traffic calming measures promised by the Council last year. representations made to this document will be taken into And what about our ancient, beautiful, grade I listed Church of St Lawrence being account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

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sited next to an opencast quarry, do you think that the tourists will flock to a site of that nature not to mention the noise, dust and general pollution. Please, please leave our village as it is. Its far too precious to spoil for a shovel full of coal.

Mr Dave Drinkwater I write to register my objection to these proposals on various grounds: 1. The Agreement that these sites should not be identified as countryside involved contains some of the best walking possibilities in the West strategic sites noted. Rainton/Pittington/Belmont area, over which I regularly lead and take part in rambles involving quite large numbers of people. 2. The village of Pittington would suffer The environmental impacts of the proposed surface serious disruption from the works and the traffic. 3. Either West Rainton (via the mined coal sites will be fully considered when we prepare A690) or Moorsley (on a very narrow road) or Belmont (on a rather too well-used the allocations document. At that stage all road) would perforce suffer greatly from the increased traffic. 4. Some beautiful representations made to this document will be taken into countryside would be defaced for a considerable period. It is my sincere hope that account. Our approach to surface mined coal and fireclay these proposals will not be pursued. is set out in policy 56 of the Preferred Options.

Mr Peter Hawdon Grounds for objection Destruction of the landscape? Public footpaths. Major increase The environmental impacts of the proposed surface in heavy traffic on narrow country roads. Pollution of clean air with coal dust. Noise. mined coal sites will be fully considered when we prepare Detrimental affect on house prices and environment. Mining and further use of fossil the allocations document. At that stage all fuels is known to increase global warming. We believe this would not even be representations made to this document will be taken into proposed if the area was near somewhere such as Shincliffe. account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr Ian Baillie I am writing to you to register my concern at the discussions on opencast mining The environmental impacts of the proposed surface around Pittington and sincerely hope this never goes ahead. We very much like the mined coal sites will be fully considered when we prepare beautiful open rolling countryside around Pittington which is one of the reasons we the allocations document. At that stage all moved to our present address in High Pittington 20 years ago. Opencast mining in representations made to this document will be taken into the surrounding fields would ruin the beauty and attraction of this area making it account. Our approach to surface mined coal and fireclay very unpleasant to live here. I would imagine the vast majority of people in this area is set out in policy 56 of the Preferred Options. would not want opencast mining on their doorsteps. I would also think the Ramside Hotel would strongly oppose this as it would totally spoil the pleasant setting of this large and successful hotel and golf course and put visitors off from coming.

Mrs Lesley Richardson I agree these should NOT be identified as strategic [or otherwise] sites. I can only Agreement that these sites should not be identified as agree with everything written previously. I cannot see ANY benefit to our community strategic sites noted. whatsoever. Whatever happened to the "greener energy" we are all being encouraged to support or is money talking again? The environmental impacts of the proposed surface mined coal sites will be fully considered when we prepare the allocations document. At that stage all

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representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mrs Helen Morris I strongly agree that these sites should not be identified as strategic sites. I note Agreement that these sites should not be identified as that ATH Resources no longer intend to propose that they are identified, but I think strategic sites noted. it important that residents should continue to submit comments in case this position changes. There is nothing to stop this company (or another company) putting in a The environmental impacts of the proposed surface planning application to opencast in Pittington in the future. It appears from the mined coal sites will be fully considered when we prepare comments from ATH Resources that they do intend to opencast in the area in any the allocations document. At that stage all event. The Pittington North and South sites are close to a large number of homes, representations made to this document will be taken into and residents' lives would be blighted by noise, dust and dirt for many years to account. Our approach to surface mined coal and fireclay come, both from the sites themselves and from the huge volumes of traffic. This is set out in policy 56 of the Preferred Options. would all also have a serious negative impact on visitors to the area (and other Durham residents) who come to walk and cycle on local lanes, on children at the village primary school, on local businesses particularly those relying on visitors, and on the wildlife and plants in this pleasant rural area.

Mrs Carole Straughan I Would like to object strongly to the proposed Open Cast Mining Sites In The Agreement that these sites should not be identified as Pittington area Of Durham, Pittington is a small village Which Is Of Scientific Interest. strategic sites noted. The Village Has been bombarded already by the Taylor Made Wood Lorries , Our roads Are not designed to take these large lorries. We already have far too many The environmental impacts of the proposed surface passing through our village at all times of the day and night. Many of the community mined coal sites will be fully considered when we prepare walk from Low Pittington up to High Pittington to take their children to the local the allocations document. At that stage all school, it is already very dangerous due to the amount of heavy vehicles passing representations made to this document will be taken into through. I do believe we have to think carefully about the safety aspect of our account. Our approach to surface mined coal and fireclay community , the amount of traffic would increase considerably. We Also have The is set out in policy 56 of the Preferred Options. Very Old and wonderful St Lawrence Church which many visitors come to see, I think an open cast mining site will deter people from coming. We also should consider the many organisations that use our public footpaths , of which there are many, there is also an increased risk to safety with the added traffic for them. On these grounds I Object To Open Cast Mining in Pittington And Surrounding Areas And Would Ask that The Council Vote Against it also.

Mrs Margaret Pattinson I agree that these sites should not should not become surface coal mine sites for Agreement that these sites should not be identified as the following reasons: 1 Devastating effect on the areas rich flora and fauna. strategic sites noted. Pittington Hill is a Site of Special Scientific Interest in County Durham. The hill slopes

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and former quarry support an extensive area of primary magnesian limestone The environmental impacts of the proposed surface grassland. High Moorsley is also designated. These areas are too important and mined coal sites will be fully considered when we prepare significant and must be protected. The pollution from the surface mining will effect the allocations document. At that stage all these sites irrevocably. Once lost they will be gone forever. The County Assessment representations made to this document will be taken into Methodology states that the Natural Environment will be a significant constraint to account. Our approach to surface mined coal and fireclay development. Please act on this. 2 The area concerned is an outstanding semi-rural is set out in policy 56 of the Preferred Options. area, which over time have been reclaimed from the effects of mining and heavy industry. This area is much valued by the people who live here and those who visit. Apart from those who come for the countryside there are visitors to St Lawrence Church, whose present building dates from 1100 and is a Grade 1 listed building, those who visit Hallgarth Manor. There are business operating in the area to which such a development which be detrimental. 3 The roads, paths, bridleways in this area are much used by walkers, horse riders, cyclists. Access to the countryside would be lost or severely curtailed for these groups. The outstanding views of the surrounding countryside and the cathedral would be blighted by this development. 4 Durham City is a World Heritage Site. Bill Bryson called it a 'perfect little city' and it is highlighted time and again as an outstanding place to visit. Such development on the Eastern edge of the city will directly affect this. Imagine as a visitor arriving at Junction 62, being faced with coal lorries thundering down the A690, and a blighted landscape as you make your way to Hallgarth Manor hotel to stay on a visit to this 'perfect little city'. As a long time resident of Durham I would be ashamed if my city was revealed like this. 5 In employment terms I feel that the development would destroy more jobs than it creates and bring little or no benefit to the communities. Damage to the appeal of Pittington and surrounding areas would damage business particularly in the long term i.e. Hallgarth Manor Hotel, Ramside Hall Hotel, Homer Hill Farm Shop. I would assume that the coal being extracted will leave the county, so not supporting business in the county. 6 Transport is a significant issue. This is an area which, apart from the A690, is served by rural roads. There will be noise, pollution, dirt and heavy lorries moving to and from the site. The roads are not suitable for the extra traffic. Surrounding villages already have traffic issues; this will make them very much worse. 7 The area is much valued by people who choose to make their homes here and bring up families. Pittington Primary School is too close to this development. The children should not be exposed to such pollution and noise and destruction of their natural environment. Apart from getting them to and from school safely, the compromise to their learning environment, what about health issues? Any increases in pollution need to be considered alongside the issues of breathing difficulties, asthma. What will the air quality be? Weather cannot be controlled, wind will blow wherever! In conclusion, I recommend

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refusal to any application for mineral extraction on the basis that they run contrary not only to the residents of the local communities, but also to the interests of the county.

Mrs Jean Henderson We wish object to the proposal of Open-cast Mining at Pittington. We agree with Agreement that these sites should not be identified as question 9 of the consultation on New Minerals and Waste Sites by Durham County strategic sites noted. Council. We live in Pittington and use Lady's Piece Lane every day, whether travelling towards the A690 or the A181, this road would be badly affected by an The environmental impacts of the proposed surface open-cast mine, and traffic would bypass the Lady's Piece Lane coming through mined coal sites will be fully considered when we prepare the village passing the school. The road through the village already has a problem the allocations document. At that stage all with heavy traffic going to and from the Taylormade Timber Yard. I walk my dog representations made to this document will be taken into around this area every day and should this proposal go ahead I would be hampered account. Our approach to surface mined coal and fireclay by the disruption caused by heavy lorries and the large earth moving equipment is set out in policy 56 of the Preferred Options. used by the Contractors. Low and High Pittington is a quiet and pretty rural village and the residents take pride in keeping the village and their homes looking smart, clean and tidy there are views form most areas across a large part of the City including the Cathedral and Castle, we should be proud of our heritage and protect it.

Mr Maurice Urwin I agree that these sites should NOT be identified as strategic and wish to register Agreement that these sites should not be identified as my opposition to any proposal to allow open cast mining at the sites. It is almost strategic sites noted. unbelievable that either ATH or UK Coal Mining Ltd can view such proposals as being either socially or environmentally acceptable. Such companies obviously The environmental impacts of the proposed surface employ professional experts to circumvent any objections made. They will also be mined coal sites will be fully considered when we prepare well versed in claiming that disruption, noise and adverse health risks will be minimal the allocations document. At that stage all and acceptable and the restoration work will be first class. I respectfully ask therefore representations made to this document will be taken into that the planning authorities bear the following in mind. account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options. 1 QUALITY OF LIFE The lives of hundreds if not thousands of residents in Pittington, Rainton Gate, West Rainton and Sherburn would be adversely affected by the noise, dust, traffic, floodlights, loss of amenities, declining property values etc

2. HEALTH The junior school at Pittington would be literally yards from the Pittington South site. To try and counter objections on the grounds of health, mining companies apparently often cite a 2001 Newcastle University Study which indicated that open cast mining appears to only have small detrimental effects on children. However it should be pointed out that:- The monitoring sites in the Newcastle study were between 400 and 1400 metres from operational activity. At the proposed sites

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Pittington North and South there are schools and residential housing far closer than this. The Newcastle study only measured PM10 (10 micron) levels which can be expelled by the lungs and not the finer particles (2.5 microns) which are acknowledged to cause damage to the lining of the lungs. The study only looked at the effects on children and not on the elderly or people with existing complaints. On the other hand there are many other studies which do strongly link open cast mining with a number of diseases For example campaigners in Douglasdale opposed to open cast mining used 12 scientific, peer reviewed, published studies of 'diseases in coal effected populations' carried out in the UK, Europe, India and America seeking to support their case - 10 of the reviews indicated causes for health concerns. The only studies which found there was little or no effects to worry about were the 2 carried out by Newcastle University.

3. WORLD HERITAGE Pittington North Site adjoins the A690, one of the major routes into the city of Durham. The open cast mine would be in full view of anyone travelling along this main road and only 1.1 miles from the outskirts of Durham - not exactly an impressive welcome to a city justly proud of its World Heritage status.

4. HOUSE VALUES The housing market in the area would collapse. No-one would want to buy a house in Priors Grange, Low Pittington, most of High Pittington, Rainton Gate or the South East edge of West Rainton next to the A690 and probably Sherburn would suffer too.

5. HOTELS The Hallgarth Manor Hotel would be devastated. Who would want to stay in a hotel literally overlooking an open cast mine? The Ramside Hotel wishes to upgrade its facilities to attract major golf tournaments. Which top class player would want to admire the open cast mine as they play their round of golf? In one corner of the golf course the proposed site would only be a road width away.

6.HISTORY Very close to the proposed site is the ancient church of St. Lawrence which is Grade 1 listed and regularly visited by people from all different parts of the country.

7.THE NEIGHBOURING COUNCIL ACKNOWLEDGES THE VIRTUES OF THE AREA The proposed sites are close to Pittington Hill which is noted for some rare species of plants and an SSSI. The neighbouring county acknowledges the beauty of this limestone ridge and the surrounding area. It is specifically referred to in

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Sunderland's Development Plan. 'Moorsley Road' is perhaps the most rural part of the City. This land comprises a steep, north-facing scarp and upper slopes of projecting limestone ridge at Moorsley; there is open grass and shrub cover on steeper ground with large arable fields on the more gentle slopes. This is a very prominent landform; the road rises steeply from Low Moorsley and affords panoramic views to West Rainton (particularly St Mary'S church) and the extensive open countryside of the Durham Plain which lies beyond. Any development between Moorsley and East Rainton will need to be of a high standard and should not detract from the rural appearance of the area.

8. DESTROYING GOOD MULTI PURPOSE FARMLAND There are 5 grades of land according to the Ministry of Agriculture. That covered by the mining proposals is Grade 3 agricultural i.e. officially listed as suitable for extensive arable cropping, rotational grassland e.g. cereals, oilseed rape and beans or grass leys for dairy cows, beef, or sheep.

9. ACCIDENTS HAPPEN! Any leakage from operations would infiltrate into the limestone strata in the area, undoubtedly polluting streams and waterways. The following two pieces of information re the mining company ATH are worrying to say the least. "In July 2010 ATH was fined for flouting environmental law by building on protected land in the course of its Scottish mining operations."and the following information was in the Scottish Paper - "ATH Resources is also at the centre of a pollution probe after hundreds of gallons of sludge from another of their open-cast mines at Kirkconnel in Dumfries and Galloway escaped into one of Scotland's most famous trout-fishing rivers in June. ATH chief, Mr Black added that he was "disappointed" about the incident".

10 THOUSANDS OF TRUCK JOURNEYS Traffic going to and from the Taylormade timber works at Sherburn Hill seven days a week, already imposes a burden on residents. Heavy vehicles from existing quarrying operations in the area also pass through Pittington and Rainton Gate on roads which were never designed to take such traffic. The following are the figures quoted for Pittington North site and Pittington South site - 54 months 'coaling' to extract reserves of 2,500,000 tonnes and 42 months 'coaling' to extract reserves of 800,000 tonnes respectively. This equates to moving an average of 2,333 tonnes EVERY DAY for years! Large lorries would be travelling through Pittington, Sherburn or perhaps Bowburn or Coxhoe or

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Haswell or Trimdon --The exact route is hard to judge as ATH merely state that they would intend to utilise junction 60 where the A689 meets the A1M near Sedgefield.

11. COAL FIRED POWER STATIONS CLOSING The need for coal will decline.- in 2015 one third of the UK's coal fired generating capacity will have to close because it breaches EU rules aimed at reducing levels of pollution caused by burning coal in power stations not fitted with the technology to remove Sulphuric Acid and Nitrous Oxide from their emissions. No new coal fired power stations are to be built unless they are equipped with proven Carbon Capture and Storage technology which does not exist at the moment. Plants not meeting EU directives and opted out i.e. due to close in 2015 Ferrybridge (SSE) 1,000; Didcot A (RWE nPower) 2,000; Tilbury (RWE npower) 1,520; Kingsnorth (E.ON) 2,000; Ironbridge (E.ON) 1,000; Cockenzie (Scottish Power) 1,152. Total 8,672MW

12 BUFFER ZONES Apparently in Scotland and Wales a legally enforceable 'buffer zone' of 500 metres has to be incorporated between open cast mines and residences. Andrew Bridgen, the MP for North West Leicestershire is calling for the same restriction in England in a private members bill. Needless to say open cast mining companies oppose this bill but I believe it has had its second reading in Parliament.

13.THE SCARS LAST FOR YEARS Having been born in this area 64 years ago, the son of a miner, brought up in Murton and working for 32 years in Houghton, I can well remember the devastation mine workings wrought on this area. It is rather ironic therefore, that on their web site, UK coal are using a photograph of Rainton Meadows (opposite East Rainton) to demonstrate their restitution schemes whilst at the same time seeking to devastate agricultural land on the opposite side of the road at Rainton Gate.

Mr Gerry Burnham I agree that Pittington North and Pittington South should not be identified as strategic Agreement that these sites should not be identified as sites in the Core Strategy DPD for various reasons including the following: strategic sites noted.

1. The local road infrastructure could not cope with the increased volume of heavy The environmental impacts of the proposed surface vehicles mined coal sites will be fully considered when we prepare the allocations document. At that stage all

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2. There would be an adverse effect on all wildlife including protected species representations made to this document will be taken into account. Our approach to surface mined coal and fireclay 3. There would be a loss of public footpaths, bridleways and cycleways within the is set out in policy 56 of the Preferred Options. sites

4. Pittington Quarry and Pittington Hill are designated as sites of special scientific interest

5. Increased levels of dust, dirt and noise would impact on the health and wellbeing of the local community

6. The site identified is in close proximity to the ancient and beautiful grade I listed St Laurence church which attracts many visitors to the area

Mr Peter Wilson I read with horror and disbelief the proposals to have open cast mining at two sites Agreement that these sites should not be identified as in the village of Pittington. My objections are as follows: 1. Damage to existing strategic sites noted. landscape - The area of Durham is still scarred with the consequences of mining. These proposals would destroy the existing environment, its flora and fauna for a The environmental impacts of the proposed surface considerable time - if not indefinitely 2. Open cast mining would have a severe and mined coal sites will be fully considered when we prepare detrimental effect to those who live in the village - the quality of life of all residents, the allocations document. At that stage all but especially those whose houses are in close proximity to the sites would be representations made to this document will be taken into severely effected. 3. House prices would be adversely effected in the area 4. The account. Our approach to surface mined coal and fireclay village primary school is very close to one of the sites. Noise and pollution problems is set out in policy 56 of the Preferred Options. are going to cause issues for the children I believe. 5. The ancient church of St Laurence is close to one of the sites. A large open cast site nearby will do little to encourage visitors 6. The local Halgarth Manor Hotel's trade will surely suffer as a consequence of this proposal - who wants to visit an area with an open cast site? Who wants to have their wedding reception at an open cast site? This will result in a reduction in staffing with this local employer 7. Footpaths and cycleways will be effected and hence visitors will not use them further effecting local business and trade. 8. The roads in the village are already congested with large lorries gong to and from the Tailormade site. Any increase caused by the open cast sites would be severely detrimental to those who live on the main road and to those residents who cross it and render the roads almost unusable by the local commuter 9. The desire for coal is hardly in keeping with the modern trend for promoting and developing "greener" ways of generating electricity. We need to preserve coal stocks and reduce carbon dioxide and sulphur dioxide emissions which result from burning

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fossil fuels. Furthermore I am disturbed that the only way I found out about this proposal was via a notice in the news agents window put there by a local parish councillor and resident. Such a radical idea - radical in the sense that if, God forbid, it were to go ahead it would destroy the local environment and severely affect the residents - should surely have involved all residents being informed via letter/flier through their letter box. Such a lack of information from Durham Council is a little naughty isn't it? Unless of course you didn't want us to know! Open casting in Pittington? No thank you!

Mrs Brenda Urwin I agree that the sites Pittington North (including Field House) and Pittington South Agreement that these sites should not be identified as should NOT be identified as strategic sites for the following reasons:- 1. They would strategic sites noted. be much too close to existing communities. West Rainton, Rainton Gate, High and Low Pittington and Sherburn would be hugely affected by mining activities and extra The environmental impacts of the proposed surface traffic. These are all lovely quiet villages and the disruption would be massive. Also mined coal sites will be fully considered when we prepare Belmont and Carrville are close enough to possibly be affected, as are High Moorsley the allocations document. At that stage all and East Rainton in the Sunderland area. 2. The coal would need to be transported representations made to this document will be taken into from the site over a long period and the proposed route utilising the A689 and account. Our approach to surface mined coal and fireclay junction 60 on the A1M must inevitably take the lorries through many other villages. is set out in policy 56 of the Preferred Options. The roads are not wide or in good condition and constant heavy traffic would make them even worse. There would also the problems with noise, dust etc. 3. Inevitably dust would be created during the mining process and this may have some impact on the health of people in the villages adjacent to the sites. In Pittington the school is a short distance from the proposed site and Cheveley Park School at Belmont is also not too far away and there is a possibility of an increase in respiratory diseases such as asthma. 4. There would also be an impact on the environment. No doubt the contractors would state that the land would be returned to its previous state. Even if this was at all possible it would take years and the biodiversity in these areas would be lost forever. 5. The villages around Durham, once main coal mining areas, have over the past decades undergone extensive restoration and been subject to much expenditure to improve the environment. Coal mines and coal tips have gone and the areas utilised for other purposes such as housing, shopping (e.g. Dalton Park) and for leisure pursuits such as walking and cycling. Surely it would be a backward step to allow opencast mining. Durham Cathedral and Castle can be seen from the A690 at Rainton Gate ,will the opencast site be seen from the historic city of Durham. 6. The proposed sites lie close to two high class hotels Ramside Hall and Hallgarth Manor, how will their businesses be affected by the proximity of opencast with the dust, noise and pollution. Visitors from all over the world stay at these hotels to enjoy Durham'S heritage and beautiful countryside - I doubt if this

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would continue. 7. With regard to the creation of employment, by law contractors would have to redeploy their own employees from worked out sites before employing any from the local area. In any event the numbers would be small and have little impact on employment in the local area.

Mr Terry Sangster We strongly agree with this. The sites, particularly Pittington South, are far too close Agreement that these sites should not be identified as to residential housing and to Pittington Primary School. The noise and pollution strategic sites noted. caused would destroy the local environment and affect the health of many local residents. The danger to young children from heavy vehicles cannot be overstated. The environmental impacts of the proposed surface The infrastructure is totally unsuitable for such a venture and attempts to alter this mined coal sites will be fully considered when we prepare would certainly destroy the local environment further. We urge you to ensure that the allocations document. At that stage all common sense prevails and, furthermore, to never again consider these sites for representations made to this document will be taken into the purpose of opencast mining or any similar venture. account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr M Stabler I am writing as I strongly oppose to the proposal to grant permission for a opencast Agreement that these sites should not be identified as to be sited in the West Rainton Area (parish boundaries). Over the last 25 years strategic sites noted. West Rainton has been blighted by a series of opencast's enough is enough. I could detail the reasons why permission should not be granted, but you have probably The environmental impacts of the proposed surface heard them all before. The simple reason is West Rainton has had enough and we mined coal sites will be fully considered when we prepare have finally got back to a state of normality after decades of opencasting. In addition the allocations document. At that stage all there has been a statutory failure of the County Council to consult correctly in relation representations made to this document will be taken into to this proposal according to your own records the consultant proposes commence account. Our approach to surface mined coal and fireclay in November 2010 ending 14 February 2011 official a period of approximately 10 is set out in policy 56 of the Preferred Options. weeks when in fact West Rainton & Leamside Parish Council and the population of the area only became aware of the proposal two weeks ago.

Ms I A Orton I would like to express my dismay that the council may give permission for mining The environmental impacts of the proposed surface in these areas. They are too close to residential areas and will desecrate areas of mined coal sites will be fully considered when we prepare natural beauty and also protected areas at Pittington Hill and Hallgarth. The local the allocations document. At that stage all roads are also inadequate for the heavy lorries that would be used in the operation. representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

A R & J Selby Having recently heard of the proposed open cast coal mining at Pittington, we should Agreement that these sites should not be identified as like to protest most vehemently against the scheme, on the following grounds. 1. strategic sites noted. COUNTRYSIDE. The two areas are sites of outstanding countryside beauty, which can be seen for many miles around, from Moorsly to Sherburn, and Rainton Gate

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to Durham Cathedral. The views are enjoyed by many residents of High and Low The environmental impacts of the proposed surface Pittington. We personally have extensive views over the rolling English countryside mined coal sites will be fully considered when we prepare of the two areas. 2. AMENITY. We regularly enjoy walks along the footpath towards the allocations document. At that stage all Sherburn. I cycle twice per week, along Lady's Piece Road, from Low to High representations made to this document will be taken into Pittington, and less frequently along cycle route 20 to Easington. Parties of ramblers account. Our approach to surface mined coal and fireclay and cycling groups regularly visit and enjoy the area. 3. EXTRACTION. The is set out in policy 56 of the Preferred Options. earthworks and coal extraction will cause noise, light pollution, dust and ground vibrations, and will require large consumption of diesel fuel. 4. ROAD TRANSPORT. The expensive haulage of coal on local roads will be a devastating overload with their capacity. They are already overloaded by timber waggons and quarry trucks which run from 4a.m to 10p.m. The consequences include noise, vibration damage to houses, damage to the road pavement, and particularly danger to cyclists and pedestrians. Low Pittington crossroads is a black spot, where already accidents occur far too frequently. 5. BLIGHT. The Pittingtons are two delightful villages with a Saxon/Norman Church, an excellent primary school, and a good range of properties ranging from starter to Â£1m. The blight from the proposals will prevent any incoming families, and no house will be saleable. Local businesses will suffer, too. The reputation of Pittington seems to be doomed. 6. SUSTAINABLE ENERGY. The whole direction of international policy on energy production is towards renewable sources and away from fossil fuels especially coal. The County Durham strategy, as defined in the "Minerals Local Plan2 2000 states: Policy M7 Within the exposed coalfield area there will be a presumption against proposals for the opencast mining of coal and/or fireclay unless: a) They are environmentally acceptable, or can be made so by planning conditions obligations; or b) They provide local or community benefits which clearly outweigh the adverse impacts of the proposal...... This application clearly fails on both counts.

Mr. David Turnbull 1: The site for Pittington South abuts a large number of domestic dwellings along The environmental impacts of the proposed surface one long boundary to its east side. Any working would inflict on these residents, mined coal sites will be fully considered when we prepare environmental pollution in the form of: Dust.... from the extraction and removal the allocations document. At that stage all process to be followed later by infill operations. Noise.... there will be inevitably representations made to this document will be taken into noise associated with any aspect of open cast operations which cannot be removed account. Our approach to surface mined coal and fireclay or even reduced to an acceptable level by preventative measures. I have is set out in policy 56 of the Preferred Options. experienced this during the open cast work on the nearby Middle Rainton site in the late 80s, this site was considerable further away that the proposed sites across the Pittington area viz 1 mile and the periods of blasting, albeit during daylight hours impacted on adjacent housing; this noise would be significantly higher at Pittington. Dirt.... from the wheels and from the transport of materials associated with open

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cast operations, as well as damage to road surfaces on the access/egress routes; these are chip and tar coated and have been maintained like this for a number of years and are not of a suitable standard to accept extra vehicular traffic of this type without significant maintenance and improvement. The increase in heavy LGVs using routes would significantly impact on these, especially if cleaning measures are instigated on these routes. 2: Proximity of the ancient church St. Lawrence and historic ancient village of Hallgarth which is regularly visited by people from all over the world. Opencast operations would deter such visits, it would also significantly impact on these sites with the close proximity blasting work used to loosen coal. 3: Proximity of the Sight of Scientific Interest (SSI) at Pittington Hill...This site contains a pocket of an extremely rare species of grass ,a relic of the last Ice Age, and as such, one of only a handful in the UK. This grass would be badly damaged,if not totally wiped out by dust carried by the prevailing wind and settling on the grass. There are no preventative measures that would prevent this. 4: Effect on the water table.... Leakage from operations would infiltrate into the limestone strata polluting streams and waterways. Water is also extracted for drinking purposes from boreholes sunk into the limestone. 5 Traffic...... There is already a heavy burden of traffic by timber and timber products going to and from the Taylormade timber works at Sherburn Hill. This traffic operates 7 days a week and 24 hours a day. Heavy vehicles from existing quarrying operations in the area also pass through Pittington on roads which were never designed to take such traffic. 6...... Fauna.... there are known to be active badger sites in the area as well as protected species of birds and Bats. 7...... Maps of former mining activities show the existence of 5 known mining sites on the Pittington South site which may have removed much of the coal allegedly lying near the surface. If so then open cast operations would need to go much deeper and take much longer than the forecasts provided. 6 Footpaths...Several footpaths run through the site and which could not be easily nor safely diverted.. namely Footpaths.23. [between High Pittington and Low Pittington emerging opposite the Blacksmiths Arms Public House.... 25; Between Low Pittington and Sherburn Village.

Ms G Gibson The area surrounding Pittington is attractive. It is assumed the route, should Agreement that these sites should not be identified as permission be granted, would be north to the A690 and then to the Carrville strategic sites noted. CPRE Interchange. Certainly traffic south through Sherburn to the A688 and the Bowburn Interchange would not be appropriate and should be prevented. But for the reasons The environmental impacts of the proposed surface given by the Council CPRE would agree that this should not be a strategic site or mined coal sites will be fully considered when we prepare even a non strategic one the allocations document. At that stage all

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representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Lynn Thompson i would like to add my voice to those who are opposing the digging of opencast Agreement that these sites should not be identified as mines on greenbelt land near Pittington, Sherburn and West Rainton. i feel it is strategic sites noted. quite wrong to do this sort of thing on land that has been designated as a green space and should remain as such. If you cannot respect the integrity of green belt The environmental impacts of the proposed surface land here then i am concerned about what you will do to green spaces in other mined coal sites will be fully considered when we prepare areas of Durham. the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr. Brian Ward My house is situated on Pittington Road, Rainton Gate and is one of sixteen houses The environmental impacts of the proposed surface plus Homer Hill Farm (with two more houses) along the 400 yards before the road mined coal sites will be fully considered when we prepare joins the A690. I write to object to any suggestion that the possibility of open cast the allocations document. At that stage all coal mining be included in any planning documents concerning the Pittington and representations made to this document will be taken into West Rainton area, in particular that designated as Field House on Map 6 Land account. Our approach to surface mined coal and fireclay north of Pittington...... (Most of this is in the Parish of West Rainton). I set out my is set out in policy 56 of the Preferred Options. reasons below.

1. A great number of people would be adversely affected by the development. Apart from the houses on Pittington Road there are many on the north side of the A690 in Rainton Gate where the affects of the workings, the traffic movements, noise and drift of dust and other waste matter would make life unpleasant.

2. Traffic. Pittington Road is still basically a country road which now bears far too much traffic both in numbers and size of vehicles. Housing developments from Pittington and beyond have resulted in almost continuous flows in both directions to Sunderland and to join the A1 (M) at Carrville. There is regular traffic of timber Lorries with trailers to and from the timber yard near Sherburn Hill, which cross the A690 dual carriageway. This is a dangerous crossing point where several accidents have occurred (I have lived here for 43 years and have experience of this). There would be a great many vehicles using the opencast site which would exacerbate

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an already dangerous situation. Anew traffic island directly from the site to the A690 would present a solution but hardly justifiable for the comparatively short time it would be needed.

3. Wild Life. Being a rural area there is a variety of wild life. This includes Pheasants (families regularly visit our gardens), Owls, other birds (Wrens, Tits of all sorts, Goldfinches, Bullfinches, Collard Doves, Pigeons etc.). All of these would be affected.

4. Public footpaths. There are public footpaths crossing the area marked as Field House, one running along the edge of my property to the corner of Pittington Road opposite Homer Hill Farm. This was a useful shortcut from the village of West Rainton to Pittington which would be lost.

Conclusion. I understand that at present there is a presumption against open casting in this part of the County. I cannot see any benefit in allowing it in the future mining companies would be unlikely to employ local people and would probably provide transport and facilities outside County Durham. The one certain consequence would upset and distress to residents some, like me, quite old and looking for peace and quiet. I Object,

Canon Lesley Moreley I wish to record my support for the Council's recommendation NOT to identify The environmental impacts of the proposed surface Pittington North or Pittington South as strategic sites in the Core Strategy DPD. mined coal sites will be fully considered when we prepare Pittington remains one of the most attractive areas of open countryside east of the allocations document. At that stage all Durham. The rolling farmland is attractive at all seasons and the changing seasons representations made to this document will be taken into can be observed through the year from vantage points around Pittington. The account. Our approach to surface mined coal and fireclay stunning views to the north and west from Pittington Hill are very special and the is set out in policy 56 of the Preferred Options. despoiling of them would be a loss to the County as a whole. To attract visitors and tourists Durham needs to enhance it rural scenery not detract from it. We need to sell Durham as a place of beauty and the landscape around Pittington should be preserved not degraded. The area designated is used for leisure activities as it is covered with well used rights of way (including national cycle routes), paths and tracks in use by walkers, horse riders and cyclists. It is used not only by local resident but by visitors from further afield. The loss of these amenities would be a disaster to the area and I suspect to local businesses. The ancient church at High Pittington, is a Grade 1 listed building of considerable historical and architectural significance. It dates from the same time as the Cathedral and is historically linked to the cathedral as the site of the Prior's Grange. The local church is currently developing a 'Pilgrim

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Walk' for tourists from the cathedral to the church. The South Pittington Site would come close to the church and have a very negative impact on its tourist value. Pittington Hill is an SSSI and contains a valuable collection of rare plants which might be adversely affected by dust and grime from the mine. Open-cast mining would destroy the present landscape and it could not be resorted to its former condition. The large excavations would no doubt be water filled and produce a completely different landscape. The short term value of the mineral asset needs to be weighed against the permanent damage to the environment. The short term extraction of 4-5 years would result in permanent damage/alteration to the landscape. For short term gain we would lose a long term environment. The short term employment benefits might be outweighed by the economic impact on local businesses which derive benefit from their rural location, such as the recently opened Homer Hill Farm Shop, Ramside Hall Hotel and Golf Course and Hallgarth Manor Hotel. These businesses attract people, often from some distance, into the area and help drive the local economy. The industrialisation of the area with all that implies would be very harmful to these businesses. For the long term we need to attract visitors into the area not discourage them. It is inevitable that whatever the assurances given the working of either or both these sites will have a very negative impact on the neighbourhood and on residents. There will be noise, there will be dust, there will be heavy lorries to transport the earth being removed and the coal being excavated. This will result in noise and dust pollution to the villages. It cannot be otherwise. Living conditions for residents will deteriorate. A point not included in the strategy is the value of the land as productive agricultural land. The value of the mineral resource needs to be weighed against the value of the land as a food resource. At a time of rising food prices and global shortages of cereal crops the permanent loss of productive agricultural land needs to taken into serious consideration. Last year's Government Food 2030 strategy document indicates a new priority for farming and food production. The era of cheap food is over and this requires a re-evaluation of our land use. I strongly support the Council in resisting any change that might lead to the exploitation of this lovely part of Durham for Open-cast Coal Mining.

Mr J Lambert It has come to my attention that there are proposals to develop an extensive The environmental impacts of the proposed surface opencast mine in the vicinity of Low Pittington and High Pittington and I wish to mined coal sites will be fully considered when we prepare register my objection to the proposals. I live in Sherburn Village. My principle concern the allocations document. At that stage all is the very considerable increase in lorry traffic through Sherburn Village that this representations made to this document will be taken into proposal could generate. As it is since the opening of the link road between Sherburn account. Our approach to surface mined coal and fireclay Village and Coxhoe there has been a very significant increase in Lorry traffic through is set out in policy 56 of the Preferred Options.

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Sherburn Village. This passes along Grand View, Mill Lane and Hope Street before arriving at the mini roundabout at the crossroads in the centre of Sherburn Village. These roads are totally unsuited to this level of traffic (much of which is en route to Taylormade Timber at Sherburn Hill) and constitutes a real danger to public safety. I have no doubt that there will be a serious accident before long. Any further increase in traffic will undoubtedly damage the environment and fabric of Sherburn Village as well as further increasing levels of risk to public safety. Accordingly I wish to register my objection to the proposed development.

Ms Julie Brown As part of your consultation process & as a resident of Pittington, I wish to add my The environmental impacts of the proposed surface views; Former mining activities up to the 1950's show the existence of 5 known mined coal sites will be fully considered when we prepare mining sites on the Pittington South site, so it is already known that mining has the allocations document. At that stage all already take place here and the majority of the coal will have already been mined. representations made to this document will be taken into Pittington South site has a large housing estate along one boundary. The residents account. Our approach to surface mined coal and fireclay of the whole village will suffer from dust/dirt pollution caused by the extraction of is set out in policy 56 of the Preferred Options. coal, traffic excess caused by removal of coal by large lorries on small roads not made to take such traffic and daily noise associated with open cast mining. There is also the Grade 1 listed, St. Laurence's Church, dating from AD1000 which is less than 1 mile from the proposed mining. The Church is of historic interest, regularly visited by people from all over and any such mining operation would deter such visits. This in turn would have a knock-on effect for visitors staying at the nearby Hallgarth Manor Hotel, who largely come due to the rural aspect and/or church. The Hallgarth Manor is a large employer of local residents and if tourism to the village were to suffer because of the visual impact on the landscape due to open cast mining, then the Hallgarth would cut staffing and ultimately there would be job losses. Any leakage from the mining operations would also pollute nearby becks/streams causing havoc to wildlife. Public Footpaths 23 & 25 would be affected by the mining area. These could not be safely diverted with major traffic movement and large machinery within the mining area.

Mrs Judy Power I fully agree with the decision not to identify these sites as strategic. Industrial Agreement that these sites should not be identified as development on these sites would have a disastrous effect on the biodiversity in strategic sites noted. these areas. Pittington Hill is a SSSI and therefore in its locality there are many nationally uncommon species, particularly fauna and bird populations. In the The environmental impacts of the proposed surface woodland and gardens bordering the proposed Pittington South site there are at mined coal sites will be fully considered when we prepare least 5 bird species populations of sustainable numbers which are listed as being the allocations document. At that stage all of the highest conservation concern and have BAP status. There are also a further

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5 species listed as being of medium conservation concern. Any industrial activity representations made to this document will be taken into in this proposed area could have a devastating impact on these population account. Our approach to surface mined coal and fireclay strongholds. Furthermore I cannot see any economic benefit to the local area from is set out in policy 56 of the Preferred Options. this development, while the village will suffer a massive environmental blow. The proposed development at Pittington South is extremely close to a residential area and the impact on the quality of life and the health of the residents would be a major concern.

Mr & Mrs T Garnon I attach the response of 6 households to the proposals: Agreement that these sites should not be identified as strategic sites noted. 1 Introduction The environmental impacts of the proposed surface 1.1 This is a response to the application from ATH Resources p.l.c. to allocate three mined coal sites will be fully considered when we prepare surface mined coal sites as strategic sites in the core strategy plan at Pittington the allocations document. At that stage all North, Pittington South and Eldon Blue House. Those of us who reside in Priors representations made to this document will be taken into Grange adjacent to the Pittington South site, would contest any planning application account. Our approach to surface mined coal and fireclay on grounds specific to ourselves whenever such application was made as the effect is set out in policy 56 of the Preferred Options. on our properties would be so devastating. However, in this response we will focus on the strategic objections which apply to everyone in the area, rather than those objections which apply only to dwellings close to the site.

1.2 we agree with the council's proposed response to question 9(1) that these sites should not be identified as strategic sites in the Core Strategy DPD.

1.3 In order to make this document easier to read, we will set out our objections in Part 2 followed , in Part 3, by quotations from the Minerals Local Plan of December 2000 as 'saved' by further decisions in 2007. The parts printed in bold are those we consider directly applicable to our objections. Steps to mitigate the adverse effects of open cast mining on this particular site are , in our submission, practically impossible due to the nature of the area, its roads and the proximity of dwellings.

2 Our objections

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is quoted as saying his company is always looking for potential sites but 'we have no plans to progress any projects through the planning system in County Durham'. If the site is designated as strategic for coal extraction, many long term residents , some elderly, will be subjected to worry by the spectre of future development and its effect on house prices due to most potential buyers being deterred from considering the purchase of property which will foresee ably be blighted by such development. The house prices in the area are higher than those for similar houses in a less attractive environment as is evidenced by their Council Tax banding . In short, ATH and any other companies interested are asking the Council to depart fundamentally from the overall objectives of their previous strategy plans , so they can hold in reserve an improved chance of obtaining planning permissions , at the expense of the financial and social welfare of the local inhabitants . We believe that is totally wrong.

2.2 The sites in question are anything but derelict, are in the Green Belt , and if they are not already Areas of High Landscape Value ( AHLV's), certainly would meet the criteria for being so designated. Pittington Hill was notified to the Secretary of State on 23rd July 1987 as a Site of Special Scientific Interest under the Wildlife and Countryside Act 1981.The plant life there would be susceptible to damage by dust pollution. Visitors to the area never fail to be impressed by its beauty making comments like 'we didn't' expect to find a place like this in County Durham.. Scars of the past caused by quarrying of Magnesian Limestone have, over decades , become 'blended' into the landscape. Aesthetically,this proposal would turn the clock back by a century.

2.3 Copses of deciduous trees indigenous to the U.K. provide little visual screening especially in winter. Planting of fast growing conifers to provide visual screening would change fundamentally the appearance of the countryside.

2.4 The sites are sloping and include waterways ( mainly streams) . If several hundred thousand tonnes of coal are removed restoration would involve landfill or an acceptance that the contours of the area would change radically. Either option would create a risk of subsidence, landslip and potential pollution of watercourses.

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emit more carbon into the atmosphere. At a time when the Council are quite rightly encouraging local residents to re-cycle where possible to combat global warming, it would be a bitter irony if the efforts residents are making were counteracted by this proposed development.

2.6 The first Transport related objection relates to 'amenity'. Dealing primarily with the Pittington South site, there is absolutely no route to and from it which does not pass within a few metres of several residential properties. Through Sherburn, Belmont, Low and High Pittington or Littletown there are narrow roads , lined with dwellings and no scope for road alteration unless dwellings were acquired and demolished. The large lorries used by Taylormade Timber at Sherburn Hill are well driven and comparatively infrequent but illustrate the traffic problems caused when they have to negotiate these roads . They are clean by nature of the goods they carry . A high frequency use by lorries carrying coal or earth would be disastrous to local amenity 2.7 More worrying is road safety and traffic flow. The right turn for vehicles travelling North on the A 690 then turning towards Pittington at Rainton Gate is a difficult bottle neck, even for cars which can accelerate rapidly across the southbound carriageway at busy periods. For large goods vehicles which are slow to accelerate, it is so difficult that, even at fairly quiet times of day, tail backs of other vehicles occur. Despite the speed limit on the A 690 there is a high risk of accidents. Presently, the view which greets people approaching from this direction is of rolling countryside with Priors Grange being made invisible by effective established woodland on the horizon . If the sites were used for coal extraction there would be eyesores to the left and straight ahead. The next hazard is the crossroads at the Blacksmiths in Low Pittington which has restricted views to the right. The alternative approach through Sherburn involves negotiating a mini roundabout in an area where pedestrian use is heavy. We fear that the unavoidable increase in heavy traffic would greatly increase the risk of serious accidents.

2.8 It is sometimes said new sites 'create' jobs. The possible creation of a few short term jobs should be set against the distinct probability that permanent established businesses such as Hallgarth Manor Hotel, Homer Hill Farm Shop and Ramside Hall will all be adversely affected by the establishment of a neighbouring business which is visually unattractive, dirty and noisy. We predict 'net loss' of jobs

2.9 St Laurence Church is regarded as the 'jewel in the Crown' of the diocese architecturally and locationally. Its view will become awful.

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2.10 Footpaths and the National Cycle Route through the area will be transformed from attractions to the County and City of Durham into places to avoid.

Conclusions - We believe the passages quoted above in the existing Minerals Local Plan should continue to inform the Council's approach to the proposals from Mineral and Coal resourcing companies . We submit this proposal is totally contrary to such policies and should be roundly rejected at this early stage. Unless it is, there will be a blight on not only the financial welfare of residents whose property values are adversely affected but also a clear and present danger that people who live in, and have grown to love, this area will be subjected to the stress and worry that their neighbourhood may in the foreseeable future become an ugly, noisy, dirty environment in which to live. We strongly urge the Council to reject the request for an allocation of this land as a strategic site for surface mined coal ,or any other mineral, extraction.

Miss Lindsay Burnham I strongly agree with Durham County Council's assessment that Pittington North Agreement that these sites should not be identified as and Pittington South should NOT be made strategic sites for surface coal mining. strategic sites noted. My reasons are as follows: There would be a huge negative impact on the countryside, wildlife and birds as an opencast mine is highly inappropriate in this The environmental impacts of the proposed surface area of natural beauty. At a time when we are being encouraged to take the car mined coal sites will be fully considered when we prepare less and walk more, it seems foolish to destroy footpaths, bridleways and cycleways. the allocations document. At that stage all Increased traffic noise and pollution levels would have a detrimental affect on the representations made to this document will be taken into quality of life for residents. This type of business would not provide sustainable local account. Our approach to surface mined coal and fireclay employment. An opencast mine would deter tourism which adds to the local economy is set out in policy 56 of the Preferred Options.

Sir Peter Vardy We write to lend our support to the current protest against the proposal for open The environmental impacts of the proposed surface cast mining in Rainton Gate and the surrounding areas. Our objections are as mined coal sites will be fully considered when we prepare follows: the allocations document. At that stage all representations made to this document will be taken into SSSI: The area adjacent to the proposed site is a Site of Special Scientific Interest. account. Our approach to surface mined coal and fireclay Both protected species and nature sites are close by. As known to you, this is a is set out in policy 56 of the Preferred Options. green belt area.

ENVIRONMENT: The environmental impact will be monumental. The increase in both air and noise pollution due to heavy duty vehicles and wagons will be highly significant to our villages, as well as to the wildlife.

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HAZARD: The A690 is already one of the most busiest routes in the County. The junctions particularly on this road are already extremely dangerous and difficult to navigate. The impact of heavy duty vehicles and wagons on this main road will pose further major hazards. In addition, both Robin Lane and Hazard Lane are extremely small. Large vehicles using these minor roads will create significant wear and tear, as well as posing additional threats to the surrounding communities and the personal safety of the families living there.

HEALTH: The proximity of the mining to houses in Middle Rainton is at the absolute minimum which is extremely alarming. The pollution and landfill so close to residential areas is bound to have health repercussions on the local communities.

DAMAGE: Historical damage is highly likely to occur, many listed buildings and ancient monuments are extremely close by. In addition, there is the high risk of archaeological disturbance during the mining itself.

FINANCIAL: For all of the above reasons, as well as the smell and the unsightliness of open cast mining, house prices will be significantly reduced, affecting all of the investments made into our homes and villages. In light of the above, we appeal to Durham County Council to immediately decline this proposal and assist ATH Resources in the location of an alternative and more suitable location.

Mrs Dawn Duncan I totally agree with the councils decision not to identify North and South as strategic Agreement that these sites should not be identified as sites as open cast mines. I agree because of the following: 1. This would have strategic sites noted. significant impact on the health of the residents in this area. Particularly due to the close proximity to houses and to the school. As a health professional i have seen The environmental impacts of the proposed surface 1st hand the impact of coal dust on the lives of individuals and there is significant mined coal sites will be fully considered when we prepare evidence to back this up. As a mother of a young child i would not wish my child to the allocations document. At that stage all live in an area or go to school in an area with an open cast mine on the door step. representations made to this document will be taken into 2. The beauty of living in Pittington is the rural feel which would be totally destroyed. account. Our approach to surface mined coal and fireclay 3. The house prices would be reduced. 4.The level of traffic would be totally is set out in policy 56 of the Preferred Options. unacceptable and cause increased safety issues.

Mrs Margaret Juniper The villages of Low and High Pittington will be dramatically affected by any open The environmental impacts of the proposed surface cast mining in either the Pittington North or the Pittington South sites, therefore I mined coal sites will be fully considered when we prepare fully support the decision to not identify these sites as key strategic sites in the Core the allocations document. At that stage all Strategy DPD. The residents of Pittington largely enjoy a semi rural life, in close representations made to this document will be taken into

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proximity to Durham City and therefore it has become a popular residential area. account. Our approach to surface mined coal and fireclay The beauty of this area includes the access to the countryside with its diverse is set out in policy 56 of the Preferred Options. habitats and wildlife and the thriving community, revolving around the primary school, church and village hall. The villages of High and Low Pittington already experience the disruption, noise, vibration and dust pollution of HGVs that carry timber and further HGVs that carry materials to the quarry at Sherburn Hill. The road infrastructure of this area already suffers and it would not be able to sustain further traffic of this type. In addition the very close proximity of the proposed sites to residential areas, poses further problems of noise and dirt pollution to all residents and may well have adverse effects on health. Therefore, I would confirm that I feel that the preservation of the quality of life for the residents of Pittington, plus the protection of this environment and community far outweighs the short term economic gain of these extraction proposals.

Mrs Jacqui Bushby I wish to add my comments in order to AGREE with the above statement : Reasons Agreement that these sites should not be identified as for this include the following: 1) In this age of sustainable fuels & environmental strategic sites noted. protection, sacrificing ANY area of this small and over populated country to heavy industry for short-term gain is unjustifiable. The developers may claim that the coal The environmental impacts of the proposed surface is potentially 'economically extractable' but at what cost to the environment and mined coal sites will be fully considered when we prepare residents?? Proposing to sacrifice parts of beautiful countryside on the doorstep of the allocations document. At that stage all semi-rural residential areas is completely absurd. The land in County Durham must representations made to this document will be taken into be protected for residents & visitors to enjoy. It does not requiring 'improving' . account. Our approach to surface mined coal and fireclay Residents & visitors love the views as they are and would not wish to have them is set out in policy 56 of the Preferred Options. temporarily defaced on the vague promise of post mining 'improvements' How could a developer even dream of 'improving' this natural scene?? 2) This proposed site is very close to houses and a primary school. I believe, despite the developers claims to the contrary, that pollution from noise, dust and heavy traffic would be immense and detrimental to life styles & health. Heavy traffic through Pittington is already excessive & residents STILL await long-since promised calming measures. Any vehicles associated with the proposed mines would obviously only make the current situation worse. 3) Visitors to the area would diminish which would in turn negatively affect local businesses, including Hallgarth Hotel, Homer Hill Farm Shop and Ramside Golf Club. Other local businesses (and home owners) may also be financially damaged by noise & pollution. The claim that jobs may be created by the mines is irrelevant, especially if existing jobs are subsequently lost. The mine would employ existing, experienced workers rather than local people, therefore it is of no benefit to the local community whatsoever. 4) There are local areas of Special Scientific interest and an ancient church. These would lose visitors and

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potentially be permanently damaged by pollution. The Negative Effects From This Proposal Would Be Severe And In Some Cases Permanent, Suffered Long After The Mining Had Finished.

Mr William Lax I agree that Pittington North and Pittington South should not be identified as strategic Agreement that these sites should not be identified as sites in the Core Strategy DPD for a number of reasons. 1. The local road strategic sites noted. infrastructure is already finding it hard to cope with the amount of traffic with the result traffic calming measures are being installed throughout the village. 2. The The environmental impacts of the proposed surface proposed sites are far to close to existing housing and the resultant dust and dirt mined coal sites will be fully considered when we prepare would adversely affect the health of villagers. Thirdly,could not cope with the the allocations document. At that stage all increased volume of heavy vehicles 3. There would be an adverse effect on flora representations made to this document will be taken into and forna including protected species 4. There would be a loss of public footpaths, account. Our approach to surface mined coal and fireclay bridleways and cycleways within which are extensively used by the community and is set out in policy 56 of the Preferred Options. ramblers. 5. The site identified is close to the grade I listed St Laurence church which attracts many visitors to the area. 6. The trade to Hallgarth Manor Hotel would be impacted by the loss of visitor numbers which would impact employment in the village.

Mrs Claire Merrie I agree that the sites Pittington North (including Field House) and Pittington South Agreement that these sites should not be identified as should NOT be identified as strategic sites for the following reasons:- * Dust / dirt strategic sites noted. pollution caused by the extraction of coal * Traffic excess which is already a major issues in the village * Far too close to residential housing and PIttington Primary The environmental impacts of the proposed surface School mined coal sites will be fully considered when we prepare the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr Andrew John White We write to object to these proposed developments. We have several arguments Agreement that these sites should not be identified as that we wish you to consider and to ensure our views are accurately and properly strategic sites noted. presented to any decision makers considering any planning proposals that may arise. The environmental impacts of the proposed surface mined coal sites will be fully considered when we prepare LOCALISM ISSUES We are mindful of and agree with the Governments strategy the allocations document. At that stage all of delegating power to local communities. We are part of the Steering Group representations made to this document will be taken into preparing the Parish Plan, I (AJW) am the group's chair and my wife (GMJ) is the account. Our approach to surface mined coal and fireclay joint secretary of the group. From this perspective we have to advise you that the is set out in policy 56 of the Preferred Options.

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proposed Open Casting developments would prevent almost all conceivable developments that we are considering for the improvement to and sustainability of life in the village and in our view these objections alone should be sufficient - if that is proper consideration is given to the Governments Localism Agenda. We also have other objections and these are summarised below.

RECREATIONAL & ENVIRONMENTAL ISSUES We believe that the County Council is particularly concerned that land in County Durham is protected so that people can use it for recreation and rights of way. Many people enjoy walking or riding horses or bikes (especially on the national cycle routes that run through the areas) around the proposed sites and the developments will seriously affect or prevent their enjoyment. The developments will deface two beautiful parts of our county. The council should realise how much residents and visitors value the stunning views from Pittington Hill over Durham and Rainton and how local people and tourists will be less willing to visit if they are ruined by allowing open cast mining right next to High and Low Pittington. Pittington Quarry is a Site of Special Scientific Interest because of the special plants that grow there. The prevailing wind will carry dust and pollution over our villages and into the quarry. This is potentially harmful to the health of residents and the local our environment. Generally, the quality of life enjoyed by the local residents will be affected by these developments. All of High and Low Pittington lie within 500 meters of these sites and these developments would not be permitted north of the border, why should we have to suffer them. The areas 'Carbon Footprint' will increase with the intense use of vehicles and machinery and from burning the coal obtained from the sites.

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Sherburn Hill and large trucks from local quarries. The local residents protest regularly and the Durham County Planners were made aware of the residents concerns in a well attended public meeting in Pittington Parrish Hall towards during the second half of 2010. There will be additional noise pollution from vehicles and machinery. There will be additional dust, mud and debris on the roads. There will be additional HGV exhaust fumes emitted. All of High and Low Pittington lie within 500 meters of these sites. The roads within the area are inadequate and poorly maintained. This situation will be made worse if these developments go ahead.

ECONOMIC ISSUES We need to protect existing businesses and jobs and promote the development of long term jobs. If these developments go ahead then the proposed development of Ramside Hotel and Golf Course will be adversely affected. Developers will argue that the mines will bring 60-70 jobs to the county. But the proposed mines will only provide work for 4 to 5 years and will have a negative impact on existing local businesses, such as Hallgarth Manor Hotel, Ramside Hotel and Golf Club and Homer Hill Farm Shop, which rely on visitors. Other existing businesses may be damaged by noise and pollution. The County Council must be mindful of the need to protect existing jobs that enhance the beauty of our countryside and attract visitors into our community and they must be vigilant on our behalf. There will be a loss of arable land. The crops that are currently grown there will have to be grown elsewhere or imported adding to prices of products and again increasing 'Carbon Footprint' The point has been made that all of High and Low Pittington lie within 500 meters of these developments. The value of properties within the villages will be blighted indefinitely and the ability to buy and sell houses within the village and for home owners to move in or out of the village will be severely and badly affected.

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mineral rights and are in "negotiation with the landowners concerned," and that this "should provide sufficient clarity on deliverability at this time." We believe that this means that there will be an application for open casting soon. It will not matter that these sites are defined as strategic or otherwise. We expect the Planning Authorities and the County Council to protect the interests of the voting local residents and disallow any such application. Developers often offer to 'improve' land after they finish mining. There is no need for improvements to these sites; we love the countryside as it is. We expect the County Council to be mindful of our views and protect us from these developments.

Mr Mark Frazer I would like to comment on the following section of the report:"3.11 We do not believe Agreement that these sites should not be identified as that strategic sites are either needed or required for other minerals in County strategic sites noted. Durham: (Surface mined coal)"I support the objection to the approval of surface mined coal sites (Pittington North, Pittington South and Field House) for the following The environmental impacts of the proposed surface reasons: The extraction (and subsequent combustion of) fossil fuels is widely held mined coal sites will be fully considered when we prepare to be a retrograde step in terms of environmental impact on local, national and the allocations document. At that stage all global levels. The sustained use of non-renewable fuel sources is not an objective representations made to this document will be taken into of the current government. The following statements are taken from a recent draft account. Our approach to surface mined coal and fireclay policy document: 1.64 The Government believes that there is an urgent need for a is set out in policy 56 of the Preferred Options. diverse range of new nationally significant energy infrastructure. The UK faces a major challenge in moving to a low carbon economy and industry needs to be able to deliver significant amounts of new energy infrastructure over the coming decades and beyond to 2050. 1.65 New infrastructure is needed to replace closing power stations, to switch to low carbon forms (including renewable's, nuclear and fossil fuels with CCS)... ' The Government Response to the Consultation on the Draft National Policy Statements for Energy Infrastructure' (Dept. of Energy and Climate Change, October 2010) Localised effects would include: Greatly increased air, noise and light pollution on residents of the established housing in very close proximity to the proposed sites. Negative health impacts (especially of a respiratory nature) on the residents of the area, especially the most vulnerable such as the very young and the elderly, due to increased levels of airborne particulate matter. My daughter and many of her schoolmates will spend the vast majority of their waking hours, at home and school, within 250 metres of one of the proposed sites. The loss of good quality arable land. Greatly increased levels of heavy traffic on an inadequate road network. The County has a proud mining heritage, however, it is now time to move forwards and away from a carbon-based economy.

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Mr Ian Miller As occupants of Rainton Gate we would like to object to the proposals to develop The environmental impacts of the proposed surface opencast coal sites at Pittington North and Pittington South. This area has not long mined coal sites will be fully considered when we prepare recovered from its mining industry past and is now part of the rural landscape. An the allocations document. At that stage all opencast coal site is now totally inappropriate especially the effect it would have representations made to this document will be taken into on the local environment which is dedicated to farming and leisure at present. account. Our approach to surface mined coal and fireclay Specifically it would affect rights of way, bridle paths and other footpaths in the is set out in policy 56 of the Preferred Options. vicinity as well as the SSSI nearby at Pittington Hill. The site would be too close to existing housing with all the associated visual impact, noise, dirt, traffic fumes etc. The increased traffic could be the last straw for what are only local country roads which are not designed for regular heavy traffic We have lived here for 20 years but we will not look forward to the next 10 if this proposal goes ahead

Mrs Claire Frazer I would like to object to the proposal of open cast mines - Pittington North and The environmental impacts of the proposed surface Pittington South. Localised effects would include: Greatly increased air, noise and mined coal sites will be fully considered when we prepare light pollution on residents of the established housing in very close proximity to the the allocations document. At that stage all proposed sites. Negative health impacts (especially of a respiratory nature) on the representations made to this document will be taken into residents of the area, especially the most vulnerable such as the very young and account. Our approach to surface mined coal and fireclay the elderly, due to increased levels of airborne particulate matter. My daughter and is set out in policy 56 of the Preferred Options. many of her school friends will spend the vast majority of their waking hours, at home and school, within 250 metres of one of the proposed sites. The loss of good quality arable land. Greatly increased levels of heavy traffic on an inadequate road network. There is currently traffic calming measures being installed in Pittington. The County has a proud mining heritage, however, it is now time to move forwards and away from a carbon-based economy. I have lived in Pittington for the past 10 years have seen the village grow and develop during this time. I believe open cast mines would set the village back years.

Ms Marion Foster I wish to place my objection to the proposed open cast mine in Pittington. There The environmental impacts of the proposed surface are many reasons, a few are listed below:- Road Traffic - The roads to - and through mined coal sites will be fully considered when we prepare - Pittington are very narrow, with blind hills and many bends. There is an increased the allocations document. At that stage all risk of accidents with the increased volume of traffic this proposal would bring. representations made to this document will be taken into Wildlife - We have a wonderful and varied amount of animals and birds in and account. Our approach to surface mined coal and fireclay around our village. These would suffer greatly. Environment- There would be an is set out in policy 56 of the Preferred Options. increased amount of dust and debris, everyone and everything would suffer the effects of this. Noise - There would be considerable noise pollution if this were to go ahead. Gas Emissions- Again, all living things will suffer as a result. There is a likelihood of health problems which would cause problems for the already overstretched Health Service. Rights of Way - Some of our footpaths in the area

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would be closed, this would affect dog walkers, ramblers and our children. Visual - We have some stunning countryside around our village - the natural beauty of our surroundings would be destroyed.

Dr Horst Puschmann I strongly oppose any potential plans to open a surface mine in either North or South The environmental impacts of the proposed surface Pittington - or indeed anywhere at all. In a world that absolutely needs to look at mined coal sites will be fully considered when we prepare the proper use of sustainable energies, any proposal involving mining fossil fuel is the allocations document. At that stage all counter-productive and, if approved, will result in a further increase of the CO2 representations made to this document will be taken into concentration in the atmosphere. account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Ms Eileen Berry I agree with Question 9 of the consultation on New Minerals and Waste Sites. Our Agreement that these sites should not be identified as beautiful, accessible countryside will be blighted for years if open cast mining is strategic sites noted. allowed. There will be such a negative impact on local business, notably The Hallgarth Manor and The Ramside hotels, which employ local people but depend The environmental impacts of the proposed surface on tourism. The amount of coal traffic will just add to the dangers on our roads that mined coal sites will be fully considered when we prepare already exist from the wood and quarry lorries. the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Miss Lauren Mould I am writing to express my concerns about the mining that is planned to take place The environmental impacts of the proposed surface Pattison in Pittington. As I am only fourteen I haven't lived it Pittington for all that long but I mined coal sites will be fully considered when we prepare still think its fair that I can have my say. I completely disagree with the plans and the allocations document. At that stage all think it is outrageous, that you haven,t informed people properly about what you representations made to this document will be taken into have planned to do, and the meeting that took place in the village hall on 18/01/1011. account. Our approach to surface mined coal and fireclay The effects the mining will have on everyone in Pittington, and the village it self are is set out in policy 56 of the Preferred Options. unreal. The noises of all the machinery day AND night will be horrific, also for how small the village is it is very busy already, and that's without all the trucks going back and forth from the mine! Then after that you want to make the hole from mining into a land fill, which will also have large effects on the people in Pittington and their life styles. Children might not have the opportunity to play outside as the air condition is too bad. Also the pollution will be appalling! I am not having my brother and sister not able to venture outside, and play because of this. There is loads of countryside around this area, why is it so important that you need to do it here right next to houses where people live? If needed I will take this further and I dont think that I will be the only one!

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Professor Peter Tymms I object to the proposed open cast mine. I live in Rainton Gate on Pittington road The environmental impacts of the proposed surface and am horrified by a) The potential for noise and dirt b) The destruction of beautiful mined coal sites will be fully considered when we prepare countryside even if it will be put back as it was c) The threat to a site of special the allocations document. At that stage all scientific interest d) The low level of employment promised and the awful use of a representations made to this document will be taken into dirty energy source account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr David Whelan I wish to register my concern at the open cast mining proposal in North & South The environmental impacts of the proposed surface Pittington. My complaint is based on the following: * Traffic: I do not believe that mined coal sites will be fully considered when we prepare the current road infrastructure could handle large numbers of heavy vehicles. They the allocations document. At that stage all would rip up the road surface whilst cornering and cause a continuous need for representations made to this document will be taken into repairs and patching for the council. The damaged road surfaces would also present account. Our approach to surface mined coal and fireclay a hazard to the many cyclists who use the roads in the area. Many of the country is set out in policy 56 of the Preferred Options. roads in the area have no footpaths or very narrow unmade paths. These are already difficult to walk on and, from personal experience, pedestrians feel intimidated by the the speed and size of the vehicles that already use these paths without adding large numbers of heavy trucks. The additional contamination of the road surfaces and subsequently, the water ways when it rains * Pollution: It is inevitable that any such activity would cause + Noise pollution for the local communities. + Dust / Airborne pollution. + Noise pollution from both the actual mining and the transport to & from the site + Pollution of the local wildlife's habitat. * Local amenities: Several footpaths & bridleways in both areas would disappear. I (and many of my family & friends) use these to walk on a daily basis and regularly cycle, they are an invaluable asset to the area providing quiet, safe and pleasant routes not only for local people but also many visitors to the area. Pittington Hill is a site of special site of scientific interest and also a place where I regularly walk to enjoy the wonderful panoramic views over County Durham, i do not want this site ruined by dust and other pollutants or my view destroyed by an open cast mine. Please register my opposition to any proposals for mining in this area.

Mrs Julie Stobbs I strongly agree with the County Council that the two Pittington sites should NOT Agreement that these sites should not be identified as be included as strategic sites in the Core Strategy DPD. I am pleased to see that strategic sites noted. ATH Resources are now also accepting that inclusion would be inappropriate. My reasons are myriad and would support the excellent response that you have already The environmental impacts of the proposed surface received from many local people, especially in the Pittingtons. The main concerns mined coal sites will be fully considered when we prepare I would like to highlight are however: 1. The proximity to Pittington Hill Site of Special the allocations document. At that stage all Scientific Interest and adjoining County Wildlife Site. As someone who has worked

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in nature conservation within County Durham for over thirty years I am extremely representations made to this document will be taken into aware of the ecological value of this particular site and have led several guided account. Our approach to surface mined coal and fireclay walks there titled "Flowers and Views from Pittington Hill". Amongst the plants of is set out in policy 56 of the Preferred Options. note are the rare blue moor grass (Sesleria albicans) which is a speciality of restricted parts of County Durham and five species of orchid (early purple, lesser twayblade, frog orchid, northern marsh and common spotted). While it is obviously unclear what effects opencasting would have on designated nature conservation sites such as Pittington Hill I strongly feel that a precautionary approach should be adopted in respects of these "jewels in the crown". 2. To the north is Moorsley Banks SSSI (within Sunderland) which again contains blue moor grass and many other interesting plant species including pyramidal orchid. Together these two sites form a fantastic linked corridor along the western edge of the magnesian limestone escarpment in the northern part of its area. 3. A third site of note which could possibly be affected by any opencast working is Coalford Beck Marsh County Wildlife Site to the south of Pittington, especially if the drainage were to be affected. 4. There is a record of great crested newts occurring along the old railway line (at approx. NZ 323446). Given the high density of (the protected) great crested newt at the ponds on the Ramside Golf Course site and the knowledge that this species normally occupies a large area of terrestrial 'hinterland' there would of course need to be extensive surveys undertaken before any planning application could be seriously considered. [Hopefully however the very strong arguments which have been expressed against the working of these sites will mean that such action will not be necessary.] 5. Having been co-author of a study of roadside verges of botanical importance undertaken in 2005 and 2006 I am aware that the verge on the north side of Moorsley Road is particularly significant botanically, containing the aforementioned rare blue moor grass as well as many other species of note. The City of Sunderland, within which this site exists, were particularly interested in learning of our findings and our management recommendations of felling some of the ash in order to keep the site open for the benefit of the herbaceous flora. 6. As many of the conburbations in the North East continue to grow in size the areas of agricultural and generally undeveloped land that exist around the old pit villages in this part of the county assume an ever greater importance in terms of open countryside and quality of life for the people who live there. 7. As the County Council is only too aware, a large number of rights of way would be affected by the proposals. In particular I have a concern about the dismantled railway, part of which is designated as bridleway no. 25 West Rainton. Not only does this comprise part of Sustrans route 20 but it is also a valuable wildlife resource supporting many interesting species of plant which benefit from the nearby proximity of the magnesian

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limestone escarpment. I would be pleased to supply a list of this flora to you if this should prove helpful at any stage. The corollary to this point is that this track is greatly enjoyed by a large number of people for informal recreation including walking, Nordic walking, cycling and horse riding. It is a valuable link with other rights of way and permissive paths in the area and forms an important part of the purple clover leaf walk, one of three published walks produced by the West Rainton Green Group and funded by the Parish Paths Partnership. 8. While not wishing to comment in any length on other issues such as traffic, site boundaries being within 500 metres of housing, damage to local business etc. as they have been very adequately covered by other people I would just like to reaffirm my great concern that this area of priceless County Durham countryside should be even considered for opencast coal mining at all.

Ms Gloria Mary Juniper We write to object to these proposed developments. We have several arguments Our emerging approach to surface mined coal and that we wish you to consider and to ensure our views are accurately and properly fireclay is set out in policy 56 of the Local Plan Preferred presented to any decision makers considering any planning proposals that may Options. arise. Objections will of course be weighed in the planning LOCALISM ISSUES We are mindful of and agree with the Government's strategy balance. Whilst the Localism agenda encourages of delegating power to local communities. We are part of the Steering Group increased public participation in the planning system to preparing the Parish Plan, I (AJW) am the group's chair and my wife (GMJ) is the secure the right development for their area, it cannot be joint secretary of the group. From this perspective we have to advise you that the used to prevent legitimate development or allocations proposed Open Casting developments would prevent almost all conceivable in the Plan. developments that we are considering for the improvement to and sustainability of life in the village and in our view these objections alone should be sufficient if that With regard to environmental and recreational and health is proper consideration is given to the Governments Localism Agenda. We also & safety and economic issues, these impacts of all the have other objections and these are summarised below. proposed surface mined coal sites will be fully considered when we prepare the allocations document, RECREATIONAL & ENVIRONMENTAL ISSUES We believe that the County Council as these sites are not allocated as strategic sites in the is particularly concerned that land in County Durham is protected so that people County Durham Plan. At that stage all representations can use it for recreation and rights of way. Many people enjoy walking or riding made to this document will be taken into account. Any horses or bikes (especially on the national cycle routes that run through the areas) applications which then come forward once the Local around the proposed sites and the developments will seriously affect or prevent Plan is adopted through the Development Management their enjoyment. The developments will deface two beautiful parts of our county. process will be considered against policy 56. The council should realise how much residents and visitors value the stunning views from Pittington Hill over Durham and Rainton and how local people and tourists will be less willing to visit if they are ruined by allowing open cast mining right next to High and Low Pittington. Pittington Quarry is a Site of Special Scientific Interest

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because of the special plants that grow there. The prevailing wind will carry dust and pollution over our villages and into the quarry. This is potentially harmful to the health of residents and the local our environment. Generally, the quality of life enjoyed by the local residents will be affected by these developments. All of High and Low Pittington lie within 500 meters of these sites and these developments would not be permitted north of the border why should we have to suffer them. The area's 'Carbon Footprint' will increase with the intense use of vehicles and machinery and from burning the coal obtained from the sites.

HEALTH & SAFETY ISSUES Coal will need to be transported off the sites in heavy Lorries (possibly as many as 60 per day, which will be one every 15 minutes or so) and of course empty Lorries will have to get to the sites (60 per day). If this is down Lady's Piece Lane through Sherburn village along the new road to Coxhoe and on to the A1(M) this will seriously impact traffic that already uses this road and it will become increasingly congested, dangerous and inconvenient, particularly in the centre of Sherburn. If access is attempted via the A690 then the already dangerous Rainton crossroad will become even more hazardous. Access to the A690 is difficult at the best of times and if a large number of HGV's start using this crossroad it will become nearly impossible to turn right to go to Sunderland. Additionally the already dangerous crossroad at the entrance to Low Pittington (next to the Blacksmith's Arms) will become even more hazardous. Additional Heavy traffic will only add to the problems we already have with the Taylormade Timber logging trucks visiting Sherburn Hill and large trucks from local quarries. The local residents protest regularly and the Durham County Planners were made aware of the residents' concerns in a well attended public meeting in Pittington Parish Hall towards during the second half of 2010. There will be additional noise pollution from vehicles and machinery. There will be additional dust, mud and debris on the roads. There will be additional HGV exhaust fumes emitted. All of High and Low Pittington lie within 500 meters of these sites. The roads within the area are inadequate and poorly maintained. This situation will be made worse if these developments go ahead.

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businesses may be damaged by noise and pollution. The County Council must be mindful of the need to protect existing jobs that enhance the beauty of our countryside and attract visitors into our community and they must be vigilant on our behalf. There will be a loss of arable land. The crops that are currently grown there will have to be grown elsewhere or imported adding to prices of products and again increasing 'Carbon Footprint' The point has been made that all of High and Low Pittington lie within 500 meters of these developments. The value of properties within the villages will be blighted indefinitely and the ability to buy and sell houses within the village and for home owners to move in or out of the village will be severely and badly affected.

DEVELOPER ARGUMENTS Any company trying to develop a mine will argue that they intend to use the most modern methods to control the impact of dust and noise on areas outside the mine. This may minimise damage to the health of people but there will still be noise and pollution in our villages. Although the County Council may not be influenced as strongly by this as by other factors, please be assured that we, the voting local residents do feel very strongly that these developments should not be allowed to go ahead. Question 9 Submission 60 from ATH Resources states "ATH resources agree with the revised criteria for strategic sites. As such they advise that they no longer wish to see their submitted sites at Pittington North, Pittington South and Eldon Blue House considered as strategic sites." In relation to Pittington North, the bottom of their submission states that they have secured mineral rights and are in "negotiation with the landowners concerned," and that this "should provide sufficient clarity on deliverability at this time." We believe that this means that there will be an application for open casting soon. It will not matter that these sites are defined as strategic or otherwise. We expect the Planning Authorities and the County Council to protect the interests of the voting local residents and disallow any such application. Developers often offer to 'improve' land after they finish mining. There is no need for improvements to these sites; we love the countryside as it is. We expect the County Council to be mindful of our views and protect us from these developments.

Dr Geoff Nowell I agree with the statement that the sites of Pittington North, Pittington South and Agreement that these sites should not be identified as Eldon Blue House should NOT be identified as strategic sites for minerals extraction. strategic sites noted. I have been a resident of High Pittington for 9 years and the one thing that attracted me to this village in the first place was its semi-rural setting and Pittington Hill with

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its spectacular views. I would never have considered moving to the area if there The environmental impacts of the proposed surface was an open cast coal mine on the doorstep. Now that I have two young children mined coal sites will be fully considered when we prepare it is of even greater importance to me and my family that we still live in this semi-rural the allocations document. At that stage all community, with access to numerous footpaths, cycleways and countryside of representations made to this document will be taken into outstanding beauty. I am completely opposed to any proposal to allow mining in account. Our approach to surface mined coal and fireclay this area and my main concerns with the proposal are: 1. The area identified for is set out in policy 56 of the Preferred Options. mining is a beautiful area of countryside that has already taken many years to recover from past mining activities. It is currently used by many people, not just from the local area, for recreational purposes including walking, running, cycling, birdwatching and horse riding. Several footpaths and cycle paths, including Cycle Route 20, would be lost if this area were developed for open cast mining severely curtailing these activities. Mining would also have a major visual impact on many other local footpaths. 2. There are two SSSIs (Pittington Hill and High Moorsley) that lie within a few hundred meters of the proposed open cast sites. These SSSIs are designated as such for their primary Magnesian Limestone flora and indeed Pittington Hill is actually the one of the largest areas of primary magnesian limestone grassland in County Durham. In addition to the rare flora, these SSSI sites also support a diverse and important fauna and represent very important examples of the Permian Magnesian Limestone. The views from these sites over County Durham are simply outstanding, and are an attraction to many walkers. Open cast mining would threaten the flora and fauna of these SSSIs since they are immediately down prevailing wind of the proposed mining sites and so will experience increased, and unacceptable, levels of dust and pollution. Open cast mining would also utterly ruin the spectacular views. 3. The road network around Low and High Pittington is not designed to cope with high volumes of traffic and is already under strain from the existing volume of HGVs associated with local quarries and those that deliver to Taylormade Timber. These vehicles frequently exceed the speed limit between Low and High Pittington and it is already becoming hazardous to walk between the two villages, especially with young children. Indeed it is partly because of this that traffic calming measures are currently being put in place. Why add to the existing problem? Lady's Piece Lane, Lane being the operative word, is frequently used by walkers, runners and cyclists and yet there is no footpath or cycle provision. If it were to become the main thoroughfare for an undetermined number of HGV movements per day this would become an extremely unsafe route for other users. I am very concerned about the safety of my two young children with the possible increase in HGV traffic on our narrow, poorly maintained, roads, especially when footpath provision and upkeep is relatively poor. 4. As a parent of two children I am obviously very concerned about increased levels of noise, pollution and dirt that will arise as

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a direct result of mining activity and the increased HGV traffic required to service and support that activity. Although the developers will aim to keep dust to a minimum, as a geologist I have visited a number of different open cast mines and I am aware that the effectiveness of such measures is dependant on many factors and they cannot guarantee complete suppression of dust and protection of the community. Furthermore, they cannot alleviate noise pollution or the pollution arising from the increased HGV traffic. With one child already at the very popular and highly rated Pittington Primary School and one to start in 2 years time I am also very concerned about the proximity of the Pittington South site to the school and the effects of noise and pollution on their education and ability to play outside in an appropriate safe and clean environment. 5. In the short term the proposed mining may indeed create some, limited, local employment. In the long term, however, it will undoubtedly have a negative effect on many of the local businesses including Hallgarth Manor, Ramside Golf Club, Homer Hill Farm and the Blacksmiths Arms that rely on visitors to the area, many of whom come because of the surrounding countryside. The presence of two open cast mines on the doorstep is no doubt going to deter those visitors and damage those businesses. The short-term gain in jobs could potentially lead to a long-term loss of jobs. 6. It is estimated Pittington North would yield 2.5 million tonnes of coal while Pittington South would yield 800K tones. Sounds a lot but it represents just 83 and 27 days consumption for a coal-fired power station such as DRAX. Five and half years of direct inconvenience and misery for the local community, together with several more years of recovery, for just 110 days of the most polluting form of power generation. Is this really the sort of strategy we should be following rather than developing renewable energy sources? Leave the coal where it is for now and until there is a more critical need.

Mr Thomas Whitaker As a resident of High Pittington I agree that Pittington North and Pittington South Agreement that these sites should not be identified as sites should NOT be included in the Core Strategy DPD. There are numerous strategic sites noted. reasons for this: 1. The sites are extremely close to local residential communities and the noise and air pollution will be horrendous for local residents. In particular The environmental impacts of the proposed surface there is a excellent local Primary School adjacent to one of the sites and the noise mined coal sites will be fully considered when we prepare and air pollution would be catastrophic. 2. The proposed areas are used by walkers the allocations document. At that stage all and joggers and have several public rights of way, these areas would be destroyed representations made to this document will be taken into for the local community. 3. The Warnley to Wear national cycle route is used by account. Our approach to surface mined coal and fireclay local and national cyclists as well as walkers. This route would be covered by the is set out in policy 56 of the Preferred Options. open cast site. 4. Local retail and hotel businesses would suffer hugely from the increased pollution and disruption. These businesses employ local people and the proposals could therefore damage the local economy. 5. The proposed sites are

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very close to an area of special scientific interest, this is a nationally recognised and protected area. Pollution caused by the proposals would have devastating consequences for the rare flora and fauna. 6. Pittington Hill and the surrounding area enjoys fantastic panoramic views of the North East from the Pennines to the Cheviot Hills. Allowing opencasting activity in the area would be a terrible scar on the landscape. 7. The local road infrastructure simply cannot support more heavy goods vehicles and plant machinery. The main road through High Pittington currently has no safe crossing facilities for children going to the Primary School and a large group of children have to stand on a very narrow pavement to wait for the bus to Belmont Comprehensive. The houses currently suffer from noise and air pollution from the heavy goods vehicles going to the sawmill. Increasing heavy goods vehicles will exacerbate serious current traffic problems and pollution. 8. The County should be looking for cleaner, renewable energy solutions.

Mr Thomas Whitaker As a resident of High Pittington I agree that Pittington North and Pittington South The environmental impacts of the proposed surface sites should NOT be included in the Core Strategy DPD. There are numerous mined coal sites will be fully considered when we prepare reasons for this: 1. The sites are extremely close to local residential communities the allocations document. At that stage all and the noise and air pollution will be horrendous for local residents. In particular representations made to this document will be taken into there is a local Primary School adjacent to one of the sites and the noise and air account. Our approach to surface mined coal and fireclay pollution would be catastrophic. 2. The proposed areas are used by walkers and is set out in policy 56 of the Preferred Options. joggers and have several public rights of way, these areas would be destroyed for the local community. 3. The Warnley to Wear national cycle route is used by local and national cyclists as well as walkers. This route would be covered by the open cast site. 4. Local retail and hotel businesses would suffer hugely from the increased pollution and disruption. These businesses employ local people and the proposals could therefore damage the local economy. 5. The proposed sites are very close to an area of special scientific interest, this is a nationally recognised and protected area. Pollution caused by the proposals would have devastating consequences for the rare flora and fauna. 6. Pittington Hill and the surrounding area enjoys fantastic panoramic views of the North East from the Pennines to the Cheviot Hills. Allowing opencasting activity in the area would be a terrible scar on the landscape. 7. The local road infrastructure simply cannot support more heavy goods vehicles and plant machinery. The main road through High Pittington currently has no safe crossing facilities for children going to the Primary School and a large group of children have to stand on a very narrow pavement to wait for the bus to Belmont Comprehensive. The houses currently suffer from noise and air pollution from the

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heavy goods vehicles going to the sawmill. Increasing heavy goods vehicles will exacerbate serious current traffic problems and pollution. 8. The County should be looking for cleaner, renewable energy solutions.

Dr. Jeremy Kendal I strongly agree that there should be NO mining in these areas. In regard the Agreement that these sites should not be identified as Pittington sites, the mining would be particularly damaging to the local ecology and strategic sites noted. landscape and have detrimental visual impact in addition to extra traffic and pollution in the form of noise, dust, the potential for gas emissions, and runoff from the The environmental impacts of the proposed surface proposed sites. These pollutants would have a severe effect on Pittington as the mined coal sites will be fully considered when we prepare prevailing wind is in the direction of the proposed site towards the village. Pittington the allocations document. At that stage all is currently a lovely village to live in due to the considerable effort and financial representations made to this document will be taken into investment of the local community and council. This would effectively be entirely account. Our approach to surface mined coal and fireclay wasted if the village were to be spoilt by the mining. The village is home to a thriving is set out in policy 56 of the Preferred Options. primary school which is one of the best in the Durham area. Again the impact on the school and the children's environment would be severe. One of the major benefits for all Pittington residents and for the school pupils is to be able live in a clean country environment, which would be ruined by the mining. In addition, the village contains important heritage sites for the area such as the Norman church, St. Lawrance, and Hallgarth manor. The environmental changes listed above would spoil these sites, which should be preserved, and substantially reduce their attraction to visitors. Overall, the visual scarring of the landscape and the pollution of the local environment would considerably reduce the standard of living to local residents, reduce the economic health of the local population (residents that have moved to the area because it is an attractive place to live will be inclined to leave if the mining goes ahead) and ruin the flora and fauna in the local area. Also, the considerable environmental concerns cannot be dissociated from the health consequences for the local population that would result from mining (e.g. derived from noise, dust, gaseous and aqueous pollutants) - there is a considerable environmental and medical literature highlighting the negative consequences of open cast coal mining and similar practices. In the 21st Century, even considering practices such as open cast mining in such close vicinity to a community is distasteful in the extreme and any such plans should be thrown out without hesitation.

Dr Rachel Kendal As a resident of High Pittington I strongly agree with the decision NOT to identify Agreement that these sites should not be identified as the above areas as strategic sites for mineral extraction. The proposed sites closely strategic sites noted. border both High Pittington and Low Pittingon and indeed the entire boundary of the housing estate of Priors Grange looks to be within 50ms of the proposed mining.

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It is simply outrageous that the mining company would even consider it reasonable The environmental impacts of the proposed surface to suggest such a site for open cast mining. Would the directors of these companies mined coal sites will be fully considered when we prepare accept such a mining site on their door step? The negatives simply do not outweigh the allocations document. At that stage all any positives to be gained. The environmental impact (SSSI on Pittington Hill), let representations made to this document will be taken into alone the economic impact upon home owners and business owners (Hallgarth account. Our approach to surface mined coal and fireclay Manor, Ramside Hall & Golf Club, Blacksmiths Pub, Homer Hill Farm Shop), adverse is set out in policy 56 of the Preferred Options. health effects from the pollution (residents & Pittington Primary School), dangers (increased HGV traffic on already stressed roads/hazardous junctions) is clearly not justified in an age where reliance on fossil fuels is discouraged. Moreover, the proposed site would interfere with national cycle routes and footpaths at a time when we are all encouraged to reduce our carbon footprint by using our cars less. The area has only recently recovered from previous mining and is now a beautiful part of County Durham which attracts considerable numbers of visitors both for walking and cycling as well as to visit the grade 1 listed St Laurence Church which would be less than 1 mile away from the proposed site. Any short term gain in jobs (5 years or so) would never approach compensation for the lost revenue to the area and the dramatic reduction in their house prices and quality of life that the residents would experience. In summary, the proposal makes absolutely no sense given local, national and global strategies for environmental and historical heritage conservation coupled with a reduction in our carboon footprint.

Mr Les Stobbs It is unlikely that I can add any hitherto unexpressed reasons for excluding these Agreement that these sites should not be identified as sites from strategic designation but I know that it's important for as many people as strategic sites noted. possible to make known their opposition. I agree with all of the arguments which cite their wildlife and leisure amenity value. I share the grave misgivings over the The environmental impacts of the proposed surface effect which increased heavy traffic with its associated noise, emissions and wear mined coal sites will be fully considered when we prepare & tear will have on the already busy minor roads AND the severe reduction in quality the allocations document. At that stage all of life for those who live immediately adjacent - they are not alone in appreciating representations made to this document will be taken into this beautiful piece of Durham countryside and the wider community will suffer. account. Our approach to surface mined coal and fireclay There is much use made of the footpaths in this area, not only by the immediate is set out in policy 56 of the Preferred Options. local population. There are a couple of statements which I must question - I cannot say REFUTE because they are respectively (a) subjective and (b) requiring much more proof of viability. (a) Rainton Meadows nature reserve is presented as proof of the success of reclamation work. I have lived next to it for 10 years and it's only recently that it has come to resemble anything other than an obvious open-cast site struggling to achieve its balance with wildlife or even scenic appeal. (b) ATH referred to "potential for links into the national rail network to be use (sic)". I hope that this

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is just the same slip of cut & paste from another application which has them referring to the A689 as a removal route. The prospect of their resurrecting the derelict Leamside railway line and offsetting the cost against their profits seems optimistic.

Mr Mark Dutton We strongly agree that Eldon Blue House, Pittington North and Pittington South Agreement that these sites should not be identified as should not be identified as strategic sites in the Core Strategy DPD, for a range of strategic sites noted. compelling reasons: - the unreasonable and unjustifiable general disturbance and high degree of intrusion and damage these proposals would have on the local The environmental impacts of the proposed surface environment - problems the proposed mining sites would cause nearby settlements mined coal sites will be fully considered when we prepare in terms of the associated noise, dust, and smell they would generate -the negative the allocations document. At that stage all effect on existing trees, hedgerows and other landscape features in this area -the representations made to this document will be taken into negative effect on wildlife, native species, natural habitats and features protected account. Our approach to surface mined coal and fireclay by law (SSSIs etc - e.g. Pittington Hill) -the negative impact on good quality is set out in policy 56 of the Preferred Options. agricultural land -the negative effect on surface and groundwater resources and on local infrastructure -the effect on highway safety that high volumes of heavy plant would bring - this is already an issue locally with the nearby local timber plant and the proposals would only exacerbate matters -the negative effect on local air quality that would inevitably occur -the potential negative effect on well used local paths, trails and public rights of way This list is not exhaustive by any means but serves to illustrate just some of the many negative impacts these proposals would inevitably produce. I trust that they are not included within the Core Strategy DPD, and are also completely rejected should they be brought forward through some other route within the planning process at a later stage.

Dr James Blowey I strongly agree that the sites Pittington North (including Field House) and Pittington Agreement that these sites should not be identified as South should NOT be identified as strategic sites for minerals extraction. My family strategic sites noted. has lived at 1 Station Houses, which is also known as 1 Pittington Crossing and 1 Railways Cottages, since June 1994. 1 Station Houses lies inside the hatched The environmental impacts of the proposed surface region of North Pittington and is mentioned in the current consultation document. mined coal sites will be fully considered when we prepare For us, any development of these sites would cause significant noise, dirt and light the allocations document. At that stage all pollution. Also there would be loss of amenity as we can see Field House Farm representations made to this document will be taken into from our house and most of the Pittington South Site. Our house is an old building account. Our approach to surface mined coal and fireclay built of stone set on bare earth and in recent years we have extended and enhanced is set out in policy 56 of the Preferred Options. the house to four bedrooms so that we can accommodate our two children aged 10 and 12 and enjoy the beautiful area in which we live. If the site were developed for mineral extraction it would adversely impact on our children for their remaining years at home in ways outlined below and we have high concerns that vibration would be felt by the house structure. We have chosen to live in this location as it is

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in close proximity to Durham City while being in the green belt and we greatly value the countryside. The whole family go for frequent walks and bike rides travelling north and south along Cycle Route 20 linking up with Hetton Lyons Park, Rainton Meadows and the Weardale Way which overlooks both sites. In summer we pick green hazelnuts to make chocolate spread, wild raspberries and blackberries to make jam. We pick litter from along the road outside our house and along Route 20. We also trim the hawthorn hedge along the road outside our house, common to Pittington North, to make it safe for pedestrians. We are not the only people who use Route 20 for pleasure. It is well used, especially in summer, by cyclists and numerous walkers. There is also wildlife that would be affected that we enjoy: owls; rabbits; hares; foxes; badgers. In summary, open cast mining in this area would be significantly detrimental to our family life and by implication other local residents and visitors to Durham. We also have considerable fear that our physical and mental health would be impacted upon by any mineral extraction in close proximity to our home.

Dr Richard Remedios There are several reasons why I agree that there should be NO mining in the said Agreement that these sites should not be identified as areas strategic sites noted.

Environmental The environmental impacts of the proposed surface mined coal sites will be fully considered when we prepare • Effect of mineral-related pollution on local population including a highly rated and the allocations document. At that stage all popular primary school representations made to this document will be taken into account. Our approach to surface mined coal and fireclay • Effect of noise pollution on local population is set out in policy 56 of the Preferred Options.

• Effect of above on businesses such as Ramside Hall Hotel and the Homer Hill Farm Shop

• Damage caused by heavy lorries; already evident in High and Low Pittington

• General defacement of one of the most beautiful areas in Durham

Danger

• Heavy lorries using what are essentially minor roads

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• The effect of heavy lorries on cyclists and walkers

Heritage

• Loss of cycleways and public rights of way

• Pittington Quarry is a site of special scientific interest

• Norman church, St. Lawrence

• Hallgarth Manor

Jobs

• Rather than creating jobs, the projects will discourage other businesses locating in the nearby area.

• A better use of the areas would be to develop Ramside Hall and build on the considerable reputation the golf course and hotel adds to the area.

As a resident in High Pittington, I cannot think of one feature of the proposed project that is either good in itself or does not have a valid, reasonable and sensible counter argument. Durham CC have done well to protect the areas under their jurisdiction and as a result our districts have become highly sought-after exactly because of the efforts by the CC. In an era where we are trying to consider sources for renewable energy, practices such as open cast mining in such close vicinity to a set of vibrant and popular residential communities is backward-looking.

Given the weight of opinion of people who have used this site and the many others who I have spoken but are not confident letter-writers and/or are not comfortable with technology, it is clear that this proposal does not have any substantial support from the local community and therefore the proposal should not be taken any further.

MRS CARY KAYLL I wholeheartedly agree with Durham County Council that the Pittington areas should Agreement that these sites should not be identified as NOT be included in the Core Strategy DPD. This would seem to me to be a strategic sites noted. short-term profit for the mining companies, and massive long-term loss for the local

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community, both human, animal and plant. Surely there are other mineral-rich parts The environmental impacts of the proposed surface of the countryside that can be exploited, places that don't have schools, homes, mined coal sites will be fully considered when we prepare churches, businesses right beside them? There is nothing to recommend this the allocations document. At that stage all proposal, and lots of reasons to reject it: 1. this would have a devastating effect on representations made to this document will be taken into the local ecology 2. cycle routes and footpaths would be destroyed 3. travel by road account. Our approach to surface mined coal and fireclay would become even more dangerous, especially at the crossroads beside the is set out in policy 56 of the Preferred Options. Blacksmith's Arms - I have lost count of how many accidents there have been there in the past 20 years 4.noise and air pollution would have a detrimental effect on every living thing in the area 5. the schoolchildren at Pittington Primary would be exposed to dangers from increased traffic, and the aforementioned pollution On a personal note, I walk in the hills above Pittington with my dogs on a daily basis and have spent countless happy hours admiring the views from the top of Pittington Hill. I urge you to consider the long-term effect on this beautiful countryside, and not to be swayed by any short-term financial gain. Quality of life, surely, has to be high up the agenda when considering to mine, or NOT to mine....

Dr Rattray I am a resident of Sherburn Village and i am emailing to respond to the consultation Agreement that these sites should not be identified as on Minerals and Waste that is open until today. In relation to question 9 I wish to strategic sites noted. answer yes for the following reasons: The two areas under discussion for open cast mining near to the Village of Pitington are areas of green space which provide The environmental impacts of the proposed surface invaluable facilities for walkers and cyclists. They are areas of beauty and provide mined coal sites will be fully considered when we prepare much needed access to the countryside. In addition to this their proximity to the the allocations document. At that stage all near by quarry which is an area of natural beauty and preservation due to the representations made to this document will be taken into species of plants that grow their is of significance. Increased pollution in the area account. Our approach to surface mined coal and fireclay would inevitably have an effect on the plants and wildlife in the area and this is, in is set out in policy 56 of the Preferred Options. my view, an unacceptable consequence of a proposed project that would bring limited regeneration and jobs to the area. The proposals as i understand them are likely to create approximately 70 jobs but the damage they could cause to tourism and existing local business could in effect result in the loss of as many jobs as is created. Local hotels, golf clubs, and restaurants build a reputation, at least in part, based on their location and to my knowledge being located near to an Open Cast mine does not sit well with this. The increased traffic, with associated pollution, again is cause for concern the infrastructure in the area would not seem to be able to support the kinds of increased heavy goods transport that would be using the small country roads. In addition the increased risks of road accidents with so many heavy goods vehicles passing through local villages makes my concern levels increase. overall, I feel that such proposals at this time offer little to the local economy and area and would cause significant upset, pollution and distress, not to mention

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any potential health risks, with only minimal benefits. I hope that you will consider these issues in the decision making process and trust that you will listen to the voices of the local community.

Mrs Sharon Riddle I'm writing to object strongly to the proposal for starting open-cast mining in Pittington The environmental impacts of the proposed surface and Rainton, and I strongly agree with Question 9 in the consultation document. I mined coal sites will be fully considered when we prepare believe that open-cast mining would completely spoil this lovely village, and Pittington the allocations document. At that stage all would become a blot on the Durham landscape. I'm aware that some jobs would representations made to this document will be taken into be created in the short term - but the long term effect would be disastrous for our account. Our approach to surface mined coal and fireclay communities. The villages and the surrounding area would be dirty, polluted and is set out in policy 56 of the Preferred Options. would lead to people avoiding living or working here. Local businesses, like Haswell's farm shop, Pittington Village Shop, the Hairdressers and Hallgarth Manor (which should be encouraged) will suffer. Although I'm not an health expert, I'm also certain that this would cause a health risk - in particular to residents near the proposed mines, and school children at Pittington Primary School. I love living in Pittington, and really enjoy the countryside. We have a dog, and walk regularly in places where we love the view of Durham Cathedral, e.g. from Pittington Hill. I would hate it if that view was marred by an open-cast mine, or the clean air that we breathe starts to contain coal dust, or the peace and quiet that we enjoy is spoiled by the noise from the mine and increased traffic. Our church, St Laurence's is going through the process of officially joining the Small Pilgrim Places network. This is all about helping people find places of peace where they will feel spiritually nourished, and centres on a historic trail which links Durham Cathedral and St Laurence Church, Pittington. The trail crosses the south of the proposed Pittington mine. This walk was done three times in 2010 by people from Pittington and further afield, and it is planned that information will be produced which helps others do the walk independently. I believe that the proposed mining plans would present a massive barrier in this plan to help people experience peace and wellbeing.

Ms Carol Woods In response to Question 9. I agree that the site at Pittington north and the site at Agreement that these sites should not be identified as Pittington South should not be strategic sites for the county council. Both sites are strategic sites noted. Constituency Organiser in the Division which I represent on the county council and there are many reason why these two sites are not appropriate to develop for opencast coal mining. 1. The environmental impacts of the proposed surface Issues relating to traffic movements from both sites would have an adverse effect mined coal sites will be fully considered when we prepare on Pittington, West Rainton and Sherburn Village, with a knock on effect on Belmont. the allocations document. At that stage all The junction at Pittington with the A690 is not adequate to take the increased volume representations made to this document will be taken into of traffic and in the other direction the traffic would have to go via the centre of account. Our approach to surface mined coal and fireclay Sherburn Village to get to the motorway producing an unacceptable level of traffic is set out in policy 56 of the Preferred Options.

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in an already busy road network. 2. There are two conservation areas and a SSSI in the area all of which would be adversely affected if the sites were to be developed. 3. Both sites are in close proximity to houses, at Pittington Crossing and at Priors Grange and Low Pittington. Mining on these sites would produce unacceptable levels of noise and dust in these area. At Pittington Crossing the farmer has concerns about the impact on his animals in the nearby field. 4. I am also informed that great crested newts live in the ponds on the scrambles and so they would also need to be considered as they are a protected species. 5. The rights of way across the sites would also be affected and would no longer be available for local people to walk and enjoy. I hope that not only will the council not include these sites in their strategic plan but would also not be in favour of any development of the sites as they are valuable green space for the surrounding villages.

Dr Robert Dominy I do NOT support the proposed North and South Pittington Mine Sites Please find Agreement that these sites should not be identified as below my observations and comments on the proposal. 1. The proposal adopts an strategic sites noted. outdated approach to mining that has unnecessary impact on the community, visitors to Durham and the environment. Recent advances in Underground Coal Gasification The environmental impacts of the proposed surface technology are ideally suited to the recovery of the huge quantities of remaining mined coal sites will be fully considered when we prepare deep coal in the region in a safe, environmentally friendly way. Durham County the allocations document. At that stage all Council is ideally positioned to take the lead in the adoption of this new technology. representations made to this document will be taken into In that context the continued opening of old-technology, open-cast extraction sites account. Our approach to surface mined coal and fireclay for relatively small deposits of coal is unnecessary, backward-looking, and goes is set out in policy 56 of the Preferred Options. against all of the County Councils efforts to give the county a modern, clean image. To mine so close to Durham City and within a small, attractive rural village is simply irresponsible and it should be noted that two of the largest businesses in and around Pittington are major tourism centres, namely the Hotels at Ramside Hall and Hallgarth Manor. They and others rely heavily on trade from outside the villages and the impact on those businesses is likely to be severe with a consequent effect on employment. Any new, local jobs that may be created by the mining would be short term (less than 4 years) and unlikely to compensate for the local job losses that result. 2. Pittington is a recreation centre attracting both residents and visitors. In the spring, summer and autumn many walkers and cyclists pass through the village every weekend and Durham County Council itself organises walks from Pittington. The network of disused railway lines, footpaths and particularly the magnificent views from the SSSI at Pittington Hill all attract recreational visitors. Those magnificent views, including those of Durham Cathedral and Penshaw Monument would be totally destroyed by the two proposed quarries that would be in the worst possible locations. Experience of the great efforts that have been made

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over the years by Durham County Council to landscape old coal sites suggests that it takes decades, not years for a mine site to recover to anything like its original state. Even with the most careful recovery of the proposed sites following the completion of extraction, the view from Pittington Hill is unlikely to return to its current state for decades and it can be strongly argued that it never will. 3. Both sites and particularly the Pittington south site are located astonishingly close to the villages of Low Pittington and High Pittington. Both villages already suffer from severe noise and vibration created by excessively large, articulated timber trucks that regularly cause house windows to rattle and ornaments to shake as they accelerate up the steep hill from Low Pittington to High Pittington. The addition of even more noise and vibration pollution from heavy on-road and off-road vehicles is totally unacceptable. 4. After several years of waiting, County Durham residents and visitors are still waiting for the completion of the section of the cycle route from Pittington to Durham. Many local residents, including me, would love to be able to leave our cars at home cycle to work in Durham if it were possible to do so without having to detour along fast roads that are dangerous for cyclists. The proposed mine sites would not only kill-off any hope of the route being completed but would more than double the length of the existing break in the route. The cycle route could arguably be diverted but only by making it much less direct and accessible. In conclusion the proposal adopts outdated and unnecessary mining for a short-term extraction programme that will have short and long term impact on the community, on visitors and on the environment that are out of all proportion to the limited benefits from the coal extraction.

Mr Tim Knight I would like to raise my objections to the badly advertised and atrociously placed Agreement that these sites should not be identified as plans for open-cast mines in Pittngton. My wife and I moved to High Pittington, with strategic sites noted. a view to providing a better quality of life for our family. Part of this quality of life is the beautiful scenery which we enjoy throughout every month of the year. I am The environmental impacts of the proposed surface disturbed by the thought that every single day, when I travel to and from my home mined coal sites will be fully considered when we prepare I will have no option, but to travel through a scarred landscape, and deal with heavier the allocations document. At that stage all traffic on the roads, and unnecessary noise. My wife and I have also spent the last representations made to this document will be taken into few years in losing a lot of weight, and a majority of that effort has been thanks to account. Our approach to surface mined coal and fireclay jogging in the local area. We fear we will no longer be able to continue in this venture, is set out in policy 56 of the Preferred Options. as we wouldn't enjoy the scenery as much. But we would also fear more for our safety, as we already have concerns over sharing our route with the heavy logging vehicles that traverse down the narrow roads already. The mines will also be extremely close to businesses, schools and homes. There can be no other possibility but for it to have a negative impact on the businesses or value of the houses in the

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vicinity. It would cause too great a long term impact, for such a short term gain. Despite the mining company's claim to be able to limit the impact around them, there is no way they can guarantee this, or even measure a way on how effective they will be in this.. I was filled with so much anger when I heard about the council even considering destroying the wonderful and beautiful countryside around us, especially when we had put so much effort in finding a better life for our children. The fact that you have not even openly mentioned it to the residents of Pittington is both underhanded and immoral. We are all objecting to the plans and will continue to fight against them,

Ms Andrea M Jones We write to object to these proposed developments. We have several arguments Agreement that these sites should not be identified as that we wish you to consider and to ensure our views are accurately and properly strategic sites noted. presented to any decision makers considering any planning proposals that may arise. The environmental impacts of the proposed surface mined coal sites will be fully considered when we prepare LOCALISM ISSUES the allocations document. At that stage all representations made to this document will be taken into We are mindful of and agree with the Governments strategy of delegating power account. Our approach to surface mined coal and fireclay to local communities. We are part of the Steering Group preparing the Parish Plan, is set out in policy 56 of the Preferred Options. I (AJW) am the group’s chair and my wife (GMJ) is the joint secretary of the group. From this perspective we have to advise you that the proposed Open Casting developments would prevent almost all conceivable developments that we are considering for the improvement to and sustainability of life in the village and in our view these objections alone should be sufficient – if that is proper consideration is given to the Governments Localism Agenda. We also have other objections and these are summarised below.

RECREATIONAL & ENVIRONMENTAL ISSUES

We believe that the County Council is particularly concerned that land in County Durham is protected so that people can use it for recreation and rights of way. Many people enjoy walking or riding horses or bikes (especially on the national cycle routes that run through the areas) around the proposed sites and the developments will seriously affect or prevent their enjoyment.

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The developments will deface two beautiful parts of our county. The council should realise how much residents and visitors value the stunning views from Pittington Hill over Durham and Rainton and how local people and tourists will be less willing to visit if they are ruined by allowing open cast mining right next to High and Low Pittington.

Pittington Quarry is a Site of Special Scientific Interest because of the special plants that grow there. The prevailing wind will carry dust and pollution over our villages and into the quarry. This is potentially harmful to the health of residents and the local our environment.

Generally, the quality of life enjoyed by the local residents will be affected by these developments. All of High and Low Pittington lie within 500 meters of these sites and these developments would not be permitted north of the border – why should we have to suffer them.

The areas “Carbon Footprint” will increase with the intense use of vehicles and machinery and from burning the coal obtained from the sites.

HEALTH & SAFETY ISSUES

Coal will need to be transported off the sites in heavy Lorries (possibly as many as 60 per day, which will be one every 15 minutes or so) and of course empty Lorries will have to get to the sites (60 per day). If this is down Lady’s Piece Lane through Sherburn village along the new road to Coxhoe and on to the A1(M) this will seriously impact traffic that already uses this road and it will become increasingly congested, dangerous and inconvenient, particularly in the centre of Sherburn. If access is attempted via the A690 then the already dangerous Rainton crossroad will become even more hazardous. Access to the A690 is difficult at the best of times and if a large number of HGV’s start using this crossroad it will become nearly impossible to turn right to go to Sunderland. Additionally the already dangerous crossroad at the entrance to Low Pittington (next to the Blacksmith’s Arms) will become even more hazardous.

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Additional Heavy traffic will only add to the problems we already have with the Taylormade Timber logging trucks visiting Sherburn Hill and large trucks from local quarries. The local residents protest regularly and the Durham County Planners were made aware of the residents concerns in a well attended public meeting in Pittington Parish Hall towards during the second half of 2010.

There will be additional noise pollution from vehicles and machinery. There will be additional dust, mud and debris on the roads. There will be additional HGV exhaust fumes emitted. All of High and Low Pittington lie within 500 meters of these sites.

The roads within the area are inadequate and poorly maintained. This situation will be made worse if these developments go ahead.

ECONOMIC ISSUES

We need to protect existing businesses and jobs and promote the development of long term jobs. If these developments go ahead then the proposed development of Ramside Hotel and Golf Course will be adversely affected. Developers will argue that the mines will bring 60-70 jobs to the county. But the proposed mines will only provide work for 4 to 5 years and will have a negative impact on existing local businesses, such as Hallgarth Manor Hotel, Ramside Hotel and Golf Club and Homer Hill Farm Shop, which rely on visitors. Other existing businesses may be damaged by noise and pollution. The County Council must be mindful of the need to protect existing jobs that enhance the beauty of our countryside and attract visitors into our community and they must be vigilant on our behalf.

There will be a loss of arable land. The crops that are currently grown there will have to be grown elsewhere or imported adding to prices of products and again increasing “Carbon Footprint”

The point has been made that all of High and Low Pittington lie within 500 meters of these developments. The value of properties within the villages will be blighted indefinitely and the ability to buy and sell houses within the village and for home owners to move in or out of the village will be severely and badly affected.

DEVELOPER ARGUMENTS

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Any company trying to develop a mine will argue that they intend to use the most modern methods to control the impact of dust and noise on areas outside the mine. This may minimise damage to the health of people but there will still be noise and pollution in our villages. Although the County Council may not be influenced as strongly by this as by other factors, please be assured that we, the voting local residents do feel very strongly that these developments should not be allowed to go ahead.

Question 9 Submission 60 from ATH Resources states "ATH resources agree with the revised criteria for strategic sites. As such they advise that they no longer wish to see their submitted sites at Pittington North, Pittington South and Eldon Blue House considered as strategic sites." In relation to Pittington North, the bottom of their submission states that they have secured mineral rights and are in "negotiation with the landowners concerned," and that this "should provide sufficient clarity on deliverability at this time." We believe that this means that there will be an application for open casting soon. It will not matter that these sites are defined as strategic or otherwise. We expect the Planning Authorities and the County Council to protect the interests of the voting local residents and disallow any such application.

Developers often offer to “improve” land after they finish mining. There is no need for improvements to these sites; we love the countryside as it is. We expect the County Council to be mindful of our views and protect us from these developments.

Mr & Mrs M Burton I have read the above report and together with my wife would like to object to two The environmental impacts of the proposed surface of the possible sites for mineral extraction. (i) Land to the North of Pittington and mined coal sites will be fully considered when we prepare (ii) Land to the South of Pittington. I would like to object to these proposals on the the allocations document. At that stage all following grounds; 1. The proposed sites are very close to residential properties representations made to this document will be taken into and the noise and dust would have a seriously detrimental effect on the health and account. Our approach to surface mined coal and fireclay well being of the people who live there (including me and my family). 2. The increase is set out in policy 56 of the Preferred Options. in lorry traffic to what are already busy roads (especially at peak times) would add to noise and pollution and would also increase congestion. 3. The sites at the moment are pleasant green areas and include some well used walking and cycling paths. The natural beauty and recreational facilities would be lost for some considerable time whilst the open cast sites were in use.

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Mrs W C Rowell I write to register a strong objection to the proposed opencast coal mining site at Agreement that these sites should not be identified as Pittington. Since moving to Belmont in 1975, my husband and I have continually strategic sites noted. used the adjacent field and tracks for running, walking and visiting friends in both Low and High Pittington. During this time we have been pleased to note the amount The environmental impacts of the proposed surface of walkers using the designated paths and tracks which continues to increase. This mined coal sites will be fully considered when we prepare morning, in the interests of both health and saving fuel, I took the walking route the allocations document. At that stage all from Renny's Lane along to the Blacksmiths Arms at Low Pittington to visit Homer representations made to this document will be taken into Hill Farm Shop. I do this once or twice a week. What will happen to this footpath account. Our approach to surface mined coal and fireclay which is heavily used, if permission is given? On the Pittington Road section of my is set out in policy 56 of the Preferred Options. route I was considerably discomforted by the speed and closeness of large traffic:

1 log lorry + trailer, 1 cement mixer and at least 3 HGVs in only 10 minutes of walking. (As hedge branches protrude over the path it is impossible to move aside). More heavy traffic is unthinkable. Runners from other parts of the country, and even from abroad, are so impressed by the area when they join local running clubs and explore the surroundings of Durham. What impression would they take away if this development goes ahead? Speaking as a southerner who loves my 'adopted'' county' please do not turn the clock back to the days when I first arrived here.

Mr & Mrs J L Fenwick We strongly agree that these areas should NOT be identified as strategic sites in Agreement that these sites should not be identified as the Core Strategy DPD. strategic sites noted.

Reasons: The environmental impacts of the proposed surface mined coal sites will be fully considered when we prepare • This is a beautiful area. There are stunning views from Pittington Hill over Durham the allocations document. At that stage all and Rainton. Opencast mining will destroy the pleasant rural environment and be representations made to this document will be taken into detrimental to both flora and fauna. Pittington Hill is already deemed a site of special account. Our approach to surface mined coal and fireclay scientific interest. Opencasting here will also be devastating for the City of Durham is set out in policy 56 of the Preferred Options. as tourism will also be affected.

• Walkers and cyclists would be hugely restricted by opencast mining. Public rights of way could become blocked and access made more difficult.

• Extra trucks transporting coal, in conjunction with existing trucks hauling logs to Taylormade would make life intolerable for local residents as well as visitors.

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• There would be a safety issue for the community as Pittington is home to many families with young children and also older residents

• As the sites are in close proximity to villages and houses, the dust, the noise and the light pollution will impact hugely on the quality of life of the residents

• Businesses in Pittington and the surrounding areas would be adversely affected (e.g. Ramside Hall Hotel, The Hallgarth Manor, Homer Hill Farm Shop). Residential property values would also suffer

Mr & Mrs M Hickson I was dismayed at the above proposal. Pittington once a mining village which suffered The environmental impacts of the proposed surface when the mines closed, is trying hard to regenerate. It has much to recommend it, mined coal sites will be fully considered when we prepare a good primary school, new small housing developments, an attractive hotel with the allocations document. At that stage all lots of character, delightful countryside, farming, walks. The jewel in the crown is representations made to this document will be taken into the historic St Lawrences Church with graveyard and protected conservation areas. account. Our approach to surface mined coal and fireclay The villages are justly proud and pulling together, all ages to make their village a is set out in policy 56 of the Preferred Options. vibrant, healthy and attractive environment. What we lack are facilities i.e. doctors, pharmacy etc which we either have to bus (poor service) or car or preferably walk to Sherburn or Carrville. Already the roads are not good the access for walking appalling, parents often seen pushing prams / pushchairs on the road with little ones struggling behind. Timber lorries crashing through the main street shaking houses, frightening pedestrians, increased traffic would make an already difficult journey surmountable. Our village needs to go forward, the proposed mine would drag it back to the days of unemployment, dreary, demoralised, roads a nightmare, no business will invest, houses will remain unsold and families will move out to villages that continue to regenerate. In short we object to the proposal.

B M Thackeray I wish to object most strongly to the above proposal, the reasons being: 1. It is very The environmental impacts of the proposed surface close to Priors Grange and will affect people's lives for up to 6 years, lowering the mined coal sites will be fully considered when we prepare value of property 2. Green Belt land will be encroached upon, environmentally it the allocations document. At that stage all will be a disaster 3. The road network is not suitable for the 24 hour traffic that will representations made to this document will be taken into be travelling up and down to Yorkshire, not to mention the noise, dust and disruption account. Our approach to surface mined coal and fireclay it will cause. The extra heavy traffic on the A690 will be most detrimental to the is set out in policy 56 of the Preferred Options. area. It is an unnecessary project that is far too close to people's homes, causing unnecessary stress and disruption to people's lives.

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Mr John E Cotton Conscious of my potential NIMBY tag but confident that my views will be shared Agreement that these sites should not be identified as by the vast majority of Durham people, I am writing to object to the proposal to strategic sites noted. develop open-cast coal mining north and south of Low Pittington. Through my wife's work in enterprise within Durham University Business School and more recently The environmental impacts of the proposed surface self employed we have regularly hosted large groups of trainees and delegates, mined coal sites will be fully considered when we prepare often from Eastern Europe. One of our first ports of call for such groups in a bid to the allocations document. At that stage all set the scene of the beauty of the Durham city area, the harmony between Durham representations made to this document will be taken into and its surrounds and the spectacular scene beyond has always been Pittington account. Our approach to surface mined coal and fireclay Hill. The prospect if that view being trashed and the Green Belt so radically is set out in policy 56 of the Preferred Options. surrendered and scarred is truly appalling. This development would deface one of the beautiful parts of our County. Similarly, Pittington Hill itself, the focal point of a network of beautiful walks and a Site of Special Scientific Interest would undoubtedly suffer. Prevailing winds would carry dust and pollution over the village of Low Pittington and into the quarry areas damaging the rare orchids currently still to be found. Incidentally, every day we see walkers in ones and twos but often in large walking groups bound for Pittington Hill and its trails bringing trade to our local community. We welcome them but I don't see them traversing two major open cast sites to get here! I recently wrote to object further housing and potential traveller development to the north of Front Street Low Pittington on the basis that heavy traffic through the village was already at saturation point and further access a danger. I also feared the first stage of a constant nibbling at the Green Belt. In relation to the traffic, sadly there have been a number of quite serious accidents in that area since with the road itself succumbing in places to the heavy traffic associated with Taylormade near Sherburn Hill. At least that traffic is periodic in nature. The constant heavy traffic associated with coal extraction, 50+ heavy Lorries a day have I read? , would undoubtedly make matters even worse affecting road safety, noise levels, National Cycle Route cyclists and ramblers in this area. The developers will claim job creation but really how many? And for how many years only. How does that compare with the potential adverse effect on a resurgent Hallgarth Manor Hotel and Blacksmiths Arms, a buoyant and possibly expanding Ramside Hall Hotel, a thriving Homer Hill Farm Shop and even a new village shop investment in Pittington itself? No doubt the developers will offer to 'improve' land when they finish mining but note my introductory point. Currently we have no need to improve our local surroundings and a great deal of work goes into preserving their beauty and distinctiveness. It means a great deal too local residents and visitors from far and wide. I hope that our Councillors and Planning Officers will stick by their guns,

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protect the planning definition of this area and balance dubious employment claims of the developers against predictable long term harm to employment prospects locally in a damaged Green Belt area.

Mr Richard Sterling I object to open cast mining in the Pittington area of Durham City. The area has a Agreement that these sites should not be identified as natural beauty and is indeed quite picturesque. It certainly does not need to be strategic sites noted. enhanced; in fact it should not be disturbed. All the usual wildlife and plants can be found there. People use this area for various health activities and gain a great deal The environmental impacts of the proposed surface of pleasure from the area. All this would be sacrificed if mining took place. I have mined coal sites will be fully considered when we prepare lived most of my life on the Durham Coalfield and remember the pits and pit heaps. the allocations document. At that stage all Winning coal, processing and transporting it caused a great deal of noise, air representations made to this document will be taken into pollution and dirt. I would not like to see the return of air borne illnesses, filthy country account. Our approach to surface mined coal and fireclay lanes and coal SLURRY everywhere. It would not surprise me if evidence of pollution is set out in policy 56 of the Preferred Options. from this site was detected as far away as the centre of Durham City.

Mrs R Tones I am writing to strongly object to the proposal to use the two sites near Pittington Agreement that these sites should not be identified as for open cast coal mining. I can hardly believe the proposal has even got off the strategic sites noted. ground. The area is lovely countryside on the outskirts of a city and used by hundreds of people to walk, ride and just look at, as they drive along the country lanes. I have The environmental impacts of the proposed surface spent many lovely hours on the Pittington Hills admiring the views and taking our mined coal sites will be fully considered when we prepare dog for walks. The area is full of flora and fauna and should be kept in its current the allocations document. At that stage all state. None of the roads are fit for heavy industrial traffic and the pollution caused representations made to this document will be taken into by both exhaust fumes and dust from the mining does not bear thinking about. The account. Our approach to surface mined coal and fireclay contractor may intend to put the area back to its original or even better state but is set out in policy 56 of the Preferred Options. that is a non-starter. The thought of years of disruption and devastation to our lovely countryside is heartrending and frightening. We love the way things are just now and DO NOT WANT ANY OF THE LAND TO BE DISTURBED. I can only hope and pray that common sense will prevail and the proposal is rejected.

Mrs K M Tweddle I wish to register my objections to this development:- 1. Concerning access to the Agreement that these sites should not be identified as countryside for walking, cycling and horse riding the proposed areas for the North strategic sites noted. Pittington Mine Site and the South Pittington mine Site are both crisscrossed by Recognised Cycle tracks (Route 20) and a myriad of Parish Paths which ought to The environmental impacts of the proposed surface be open to the public to enjoy the freedom of the countryside. Members of West mined coal sites will be fully considered when we prepare Rainton Green Group have in the last three years surveyed the paths in their parish, the allocations document. At that stage all had all the stiles, hedges, surfaces, etc. Put in excellent condition, published and representations made to this document will be taken into printed a leaflet of walks that they have supplied to the public (copy enclosed) and account. Our approach to surface mined coal and fireclay should this development go ahead will make the leaflet particularly the Purple Clover is set out in policy 56 of the Preferred Options.

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Walk obsolete. 2. It is principally the fact that this is NOW a rural area after so much mining in the past that attracts visitors and residents into this district. We as a community are just beginning to attract businesses and amenities such as hotels, restaurants and cafe's to establish themselves here and if this development were to take place there would be such a loss to the likes of Homer Hill Farm Shop, The Blacksmiths Arms, Hallgarth Manor Hotel and more in West Rainton. I speak, as Chair of West Rainton and Leamside Partnership and our committee have worked tirelessly over a number of years to improve the quality of life and the development of amenities for residents of West Rainton. This after a huge Opencast Development on another side of our village at Rye Hill. 3. Between the villages of West Rainton, Pittington, and Sherburn are many related families and much interaction and visiting between families. The Doctors surgery in West Rainton is much used by residents of Pittington and Sherburn, and the doctor's surgery in Sherburn is much used by residents of Pittington and West Rainton. If the roads between these villages are too clogged by heavy lorry traffic from these mineral extraction sites it would add to the problems of these residents. Sherburn Sports Centre is also the only recreational site for all these villages. 4. The noise, dust, loss of access, nuisance factors, caused by a major mineral extraction over such a long period of time resulting in such hardship and distress to our village communities must be emphasised. 5. I do not see any benefits at all to offset any of these objections and as an environmentalist (BSc in Botany and Zoology) the fact that these areas are so close to Pittington Hill a 'site of special scientific interest'“dismays me. I do hope you take all of these considerations into account.

Mr & Mrs D Hastie I attach the response of 6 households to the proposals Agreement that these sites should not be identified as strategic sites noted. Mr and Mrs J Fenwick 1 Introduction The environmental impacts of the proposed surface Mr J Jobson 1.1 This is a response to the application from ATH Resources p.l.c. to allocate three mined coal sites will be fully considered when we prepare surface mined coal sites as strategic sites in the core strategy plan at Pittington the allocations document. At that stage all Mr & Mrs J Lumley North, Pittington South and Eldon Blue House. Those of us who reside in Priors representations made to this document will be taken into Grange adjacent to the Pittington South site, would contest any planning application account. Our approach to surface mined coal and fireclay Mr & Mrs S Pickering on grounds specific to ourselves whenever such application was made as the effect is set out in policy 56 of the Preferred Options. on our properties would be so devastating. However, in this response we will focus Mrs Ayleen Smith on the strategic objections which apply to everyone in the area, rather than those objections which apply only to dwellings close to the site.

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1.2 WE AGREE WITH THE COUNCIL’S PROPOSED RESPONSE TO QUESTION 9(1) THAT THESE SITES SHOULD NOT BE IDENTIFIED AS STRATEGIC SITES IN THE CORE STRATEGY DPD.

1.3 In order to make this document easier to read, we will set out our objections in Part 2 followed , in Part 3, by quotations from the Minerals Local Plan of December 2000 as “ saved” by further decisions in 2007. The parts printed in bold are those we consider directly applicable to our objections. Steps to mitigate the adverse effects of open cast mining on this particular site are , in our submission, practically impossible due to the nature of the area, its roads and the proximity of dwellings.

2 Our objections

2.1 The proposal to designate the sites for open cast mining would pave the way for planning applications which, if granted, would ruin the landscape, damage local amenity, and cause environmental pollution both directly through dust and noise and indirectly through the side effects of extraction and transportation ( see further below). In the Durham Times on 3 February 2011, a spokesman for ATH Resources is quoted as saying his company is always looking for potential sites but “ we have no plans to progress any projects through the planning system in County Durham “. If the site is designated as strategic for coal extraction, many long term residents , some elderly, will be subjected to worry by the spectre of future development and its effect on house prices due to most potential buyers being deterred from considering the purchase of property which will foreseeably be blighted by such development. The house prices in the area are higher than those for similar houses in a less attractive environment as is evidenced by their Council Tax banding . In short, ATH and any other companies interested are asking the Council to depart fundamentally from the overall objectives of their previous strategy plans , so they can hold in reserve an improved chance of obtaining planning permissions , at the expense of the financial and social welfare of the local inhabitants . We believe that is totally wrong.

2.2 The sites in question are anything but derelict, are in the Green Belt , and if they are not already Areas of High Landscape Value ( AHLV’s), certainly would meet the criteria for being so designated. Pittington Hill was notified to the Secretary of State on 23rd July 1987 as a Site of Special Scientific Interest under the Wildlife and Countryside Act 1981.The plant life there would be susceptible to damage by

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dust pollution. Visitors to the area never fail to be impressed by its beauty making comments like “ we didn’t expect to find a place like this in County Durham”. Scars of the past caused by quarrying of Magnesian Limestone have, over decades , become “ blended “ into the landscape. Aesthetically,this proposal would turn the clock back by a century.

2.3 Copses of desiduous trees indigenous to the U.K. provide little visual screening especially in winter. Planting of fast growing conifers to provide visual screening would change fundamentally the appearance of the countryside.

2.5 No amount of modern methods of extraction will avoid substantial dust and noise pollution. Machinery fuelled by oil, emitting carbon dioxide and monoxide, will be used to extract and transport fossil fuels which, wherever they are burned, will emit more carbon into the atmosphere. At a time when the Council are quite rightly encouraging local residents to re-cycle where possible to combat global warming, it would be a bitter irony if the efforts residents are making were counteracted by this proposed development.

2.6 The first Transport related objection relates to “ amenity”. Dealing primarily with the Pittington South site, there is absolutely no route to and from it which does not pass within a few metres of several residential properties. Through Sherburn, Belmont, Low and High Pittington or Littletown there are narrow roads , lined with dwellings and no scope for road alteration unless dwellings were acquired and demolished. The large lorries used by Taylormade Timber at Sherburn Hill are well driven and comparatively infrequent but illustrate the traffic problems caused when they have to negotiate these roads . They are clean by nature of the goods they carry . A high frequency use by lorries carrying coal or earth would be disastrous to local amenity

2.7 More worrying is road safety and traffic flow. The right turn for vehicles travelling North on the A 690 then turning towards Pittington at Rainton Gate is a difficult bottle neck, even for cars which can accelerate rapidly across the southbound

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carriageway at busy periods. For large goods vehicles which are slow to accelerate, it is so difficult that, even at fairly quiet times of day, tail backs of other vehicles occur. Despite the speed limit on the A 690 there is a high risk of accidents. Presently, the view which greets people approaching from this direction is of rolling countryside with Priors Grange being made invisible by effective established woodland on the horizon . If the sites were used for coal extraction there would be eyesores to the left and straight ahead. The next hazard is the crossroads at the Blacksmiths in Low Pittington which has restricted views to the right. The alternative approach through Sherburn involves negotiating a mini roundabout in an area where pedestrian use is heavy. We fear that the unavoidable increase in heavy traffic would greatly increase the risk of serious accidents.

2.8 It is sometimes said new sites “ create” jobs. The possible creation of a few short term jobs should be set against the distinct probability that permanent established businesses such as Hallgarth Manor Hotel, Homer Hill Farm Shop and Ramside Hall will all be adversely affected by the establishment of a neighbouring business which is visually unattractive, dirty and noisy. We predict a “ net loss” of jobs.

2.9 St Laurence Church is regarded as the “ jewel in the Crown “ of the diocese architecturally and locationally. Its view will become awful.

2.10 Footpaths and the National Cycle Route through the area will be transformed from attractions to the County and City of Durham into places to avoid.

4 Conclusions

We believe the passages quoted above in the existing Minerals Local Plan should continue to inform the Council’s approach to the proposals from Mineral and Coal resourcing companies . We submit this proposal is totally contrary to such policies and should be roundly rejected at this early stage. Unless it is, there will be a blight on not only the financial welfare of residents whose property values are adversely affected but also a clear and present danger that people who live in, and have grown to love, this area will be subjected to the stress and worry that their neighbourhood may in the foreseeable future become an ugly, noisy, dirty environment in which to live. We strongly urge the Council to reject the request for an allocation of this land as a strategic site for surface mined coal ,or any other mineral, extraction.

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Ms Janice Brabban The Badger Group agrees with the Council's decision not to identify these three Agreement that these sites should not be identified as sites as strategic, as we think that these sites, together with the other surface mine strategic sites noted. Durham County Badger developments, should be the subject of a simple planning application if they wish Group to go ahead. We understand that ATH has now withdrawn their request for Pittington The environmental impacts of the proposed surface North, Pittington South, and Eldon Blue House to be considered as strategic. The mined coal sites will be fully considered when we prepare Group's preference for a planning application, rather than allocation to the Core the allocations document. At that stage all Strategy DPD or even to the Minerals and Waste Policies Allocations DPD is representations made to this document will be taken into because we feel these latter two might offer a slight presumption that planning account. Our approach to surface mined coal and fireclay approval would follow, and that environmental studies may not therefore be so is set out in policy 56 of the Preferred Options. detailed and comprehensive. Eldon Blue House, in particular, is an example of adjacent mineral extraction sites having an increasingly adverse effect on biodiversity. For example, badger foraging in this area could now be affected by three separate schemes â€“ extension to Eldon Quarry, proposed Eldon Blue House surface mine, and the recent Eldon Deep UK Coal site, none of which are able to restore the land sufficiently well for use by badgers.

Mr Phil Keay Hetton School is a Sunderland secondary school of nearly 900 students. They The environmental impacts of the proposed surface spend a good deal of their time outside on the exposed playing fields both for PE mined coal sites will be fully considered when we prepare Hetton School lessons and during break and lunch times. The site is also used by the community the allocations document. At that stage all after school and at weekends. I am extremely concerned that prevailing winds from representations made to this document will be taken into such a nearby surface mined coal site will cause a dust and air quality problem for account. Our approach to surface mined coal and fireclay my students as well as those from our co-located primary school. is set out in policy 56 of the Preferred Options.

A number of petitions were sent to the Council totalling 1041 objecting signatures. Agreement that these sites should not be identified as The petitions all stated their opposition to opencast coal mining in and around strategic sites noted. Pittington, West Rainton and Leamside and Sherburn Villages. The petitions stated that the sites are to close to our villages and will have an adverse effect on the The environmental impacts of the proposed surface environment for residents, wildlife and visitors. mined coal sites will be fully considered when we prepare the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr A Pearson My view is that opencast mining should not be allowed on that site for the following Agreement that these sites should not be identified as reasons: The villages of Leamside and Rainton have already been plagued over strategic sites noted. many years with a number of opencast sites and residents are already sick of them. The site is only separated from West Rainton by the A690 road and is far too near

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some decent quality housing which would be subjected to noise and dust from 24 The environmental impacts of the proposed surface hour mining, The five and a half year time would make it impossible for any residents mined coal sites will be fully considered when we prepare there to sell their property is they wished to move. Worse still some quality expensive the allocations document. At that stage all properties on the site are directly in the site boundary and it would be a travesty of representations made to this document will be taken into justice to subject them to these conditions. Any proposed works would be done account. Our approach to surface mined coal and fireclay close to Homer House Farm and may even consume some of their land which they is set out in policy 56 of the Preferred Options. raise cattle for their business. I have no connection with them, other than buying some of their food products so cannot be certain on this point. This site could be very detrimental to their business, which has now been centred on this location and extended with an excellent Farm Shop and Cafe at no doubt considerable expense to diversify their operations. It would be wrong to penalise an expanding business, which benefits the local community and provides employment. The farming industry already finds it difficult to continue existence these days without tying their hands behind their back. Lorries exiting the site would further congest the already dangerous cross roads at the Pittington Lane A690 junction. The applicant's note on rail access is a red herring and a non starter based on my experience at Marks Quarry where for several years I chaired the consultation committee meetings. Network Rail costs for providing a connection then to what was an adjacent & complete rail line were uneconomic for the duration of the works. Costs for the Pittington site would now be far greater as a link would have to be provided to what was the Leamside Line, much of which has now been dismantled or vandalised and would need complete renewal at a cost of many million pounds. I do not see such cost being acceptable for a five and a half year operating period. In summary this land should not be considered for such development.

Mr George Riddle I want to register my objection to the possibility of open cast operations near Agreement that these sites should not be identified as Pittington. We already suffer from an unduly high proportion of heavy lorry traffic strategic sites noted. from the quarries and timber yard near here without introducing yet more hazards and congestion on roads which were never designed to cope with the current levels The environmental impacts of the proposed surface of traffic. The proposal would seriously affect the enjoyment of the countryside for mined coal sites will be fully considered when we prepare many people, and cut across one of the oldest paths in the county from Durham the allocations document. At that stage all Cathedral to St Laurence church. St Laurence congregation have only recently representations made to this document will be taken into established connections with the Small Pilgrim Places network in promoting the account. Our approach to surface mined coal and fireclay historic path for both local people and visitors to the region. Similar initiatives in is set out in policy 56 of the Preferred Options. other parts of the country have been shown to attract large numbers of visitors. I hope that this proposed mine will not come to fruition.

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Ms Alice Weightman I am writing to say I oppose the proposition for open cast mining in the Pittington, Agreement that these sites should not be identified as West Rainton area. I oppose this proposal because: 1 a development of this nature strategic sites noted. may damage the environment, through the destruction of local landscape and protected areas, like the SSSI of Pittington Hill and Conservation Area at Hallgarth The environmental impacts of the proposed surface 2 it will cause disruption through the movement of heavy lorries 3 It may be the mined coal sites will be fully considered when we prepare cause of loss of public rights of way and bridleways. the allocations document. At that stage all representations made to this document will be taken into account. Our approach to surface mined coal and fireclay is set out in policy 56 of the Preferred Options.

Mr David Berry I wish to state my objection to the proposed coal mining at Pittington. I agree with Agreement that these sites should not be identified as question 9 of the consultation on new minerals and waste sites. The area has lots strategic sites noted. of well used public pathways and national cycleways that pass through the proposed development areas. The road infrastructure is unsuitable for the number of lorries The environmental impacts of the proposed surface that are likely to be needed for the mining. The area borders on the new development mined coal sites will be fully considered when we prepare at the "Ramside" which would be unlikely to proceed with an adjoining mine, and the allocations document. At that stage all would bring many more long term jobs into the local area. The quarry has many representations made to this document will be taken into rare plants of national significance and may well be damaged by the prevailing account. Our approach to surface mined coal and fireclay wind,as will the health of the local residents. Lastly the view from Pittington hill is is set out in policy 56 of the Preferred Options. superb,from Bowes moor to the Cheviots the development must impact on the local > tourist trade(hallgarth hotel +homer hill) So Please reject the proposed Mining Planning application.

Natural England Land near High Pittington (Pittington North). This site partly includes and lies adjacent The environmental impacts of the proposed surface to the Moorsley Banks SSSI and High Moorsley SSSI. The eastern boundary of the mined coal sites will be fully considered when we prepare site is not shown on the map as the boundary between County Durham and the the allocations document. At that stage all City of Sunderland. Quarrying close to these grassland sites could potentially result representations made to this document will be taken into in damage through dispersal of particulates and through direct loss of habitat. In account. Our approach to surface mined coal and fireclay considering the proposed allocation, the assessment needs to take into account is set out in policy 56 of the Preferred Options. any potential impacts on the conservation objectives of the SSSI. It is not clear in the text on Page 42 if Field House is the site proposed by UK Coal Mining Ltd. Pittington South. The site neighbours Pittington Hill SSSI. Quarrying close to this grassland sites could potentially result in damage through dispersal of particulates and through direct loss of habitat. In considering the proposed allocation, the assessment needs to take into account any potential impacts on the conservation objectives of the SSSI. Eldon Blue House, land between Shildon and Coundon.

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There is a local grassland wildlife site within the boundary of Eldon Blue House, and a significant area of deciduous woodland. Any allocation should be sensitive to the ecological importance of the site locally and to the county as a whole.

Ms S Wickerson We have no objection to the inclusion of the proposed sites as a preferred option. The environmental impacts of the proposed surface Environment Agency Abstraction for dewatering purposes in mines, quarries and engineering works can mined coal sites will be fully considered when we prepare have unacceptable impacts on environmental features supported by groundwater, the allocations document. At that stage all for example, wetlands, watercourses, ponds or may derogate existing protected representations made to this document will be taken into licensed water supplies, or lead to deterioration of in groundwater quality. In order account. Our approach to surface mined coal and fireclay to assess the potential impacts from the works proposed we request that the a is set out in policy 56 of the Preferred Options. hydro-geological risk assessment (HRA) forms part of any subsequent planning application. As part of the HRA, the site operator should assess and address the risks posed to all ground and surface water resources (quality and flow) within the vicinity of the site. If any of the identified risks can not be sufficiently mitigated the proposals may be deemed unacceptable. Additional Comments for Randolf The site includes a length of Oakley Cross Beck, which is prone to flooding and there are severe flood problems immediately downstream. In principle no objections from a flood risk viewpoint, but we will require conditions relating to surface water controls at a later stage. The development should consider opportunities to reduce this existing problem if possible.

Miss Rachael Bust The Coal Authority recognises the tensions in identifying what strategic sites for Comments noted. Our approach to surface mined coal Coal Authority minerals should be identified as such in the Core Strategy. The concept of identifying and fireclay is set out in policy 56 of the Preferred sites which are integral to the delivery of the County Durham Core Strategy itself Options. is in theory a sound basis upon which to determine strategic issues. This works well in policy areas such as housing, employment and waste, however this approach does not easily fit the arena of minerals where in most cases sites are meeting a regional or indeed national requirement for minerals. The Sub Regional Apportionments for aggregates and sand and gravel do help the County meet its apportionment requirement, but in fact this is for a contribution to a wider regional and national need for building materials to help the overall growth agenda. Consequently it may be more appropriate not to identify strategic sites for some minerals and not others as the justification utilised appears to be questionable. This is particularly the case with regard to brick-making raw materials where there is no apportionment target to be delivered, if the MPA intend to persist in the identification of strategic sites. It is not appropriate for The Coal Authority to comment on the

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proposed status of sites put forward by individual operators. The Coal Authority has a general duty to ensure that the overall strategic context will ensure the continuation of an economically viable coal industry.

Miss Lisa Overend Sherburn Village Parish Council are not in favour of either the site at Pittington North The environmental impacts of the proposed surface Sherburn Village Parish or Pittington South being a strategic site for opencast coal mining in the County mined coal sites will be fully considered when we prepare Council Durham plan. The Council and many residents in Sherburn Village are concerned the allocations document. At that stage all that the development of either site would increase the volume of traffic through the representations made to this document will be taken into village centre to unacceptable levels. The B181 is already an extremely busy road account. Our approach to surface mined coal and fireclay and the opening of the new road from Byers Garth to the motorway has substantially is set out in policy 56 of the Preferred Options. increased traffic. Both site might use this route to the motorway and it would be extremely detrimental to the village. Sherburn Stone and Taylormade use the roads in the village to access the sites they have in Sherburn Hill, this means that the village already has a lot of heavy lorries on its roads and more would be unacceptable. Sherburn Village Centre is a conservation area that the council is constantly working to upgrade and an increase in noisy, dusty and dirty lorries would have an adverse effect on the environment, which the council has managed to substantially improve in recent years. Both sites have rights of way across them that are used by local people for recreation and the loss would be loss for the community. The green space around Sherburn village adds to the pleasure of living in a village, if the Pittington South Site was to be developed it would affect residents on the Pittington side of the village who would be subject to noise and dust. The parish council therefore would agree with the county council that these two sites are not strategic for the county and hope that the county would not only not designate them in the County Durham Plan, but also not be supportive of any subsequent planning application.

Mr Keith Lowes As you will appreciate, the immediate concerns relate to the proposed surface Noted. Our approach to surface mined coal and fireclay Sunderland City Council mining site at Pittington (submitted by ATH Resources), where the Pittington North is set out in policy 56 of the Preferred Options. site extends into Sunderland's administrative area. Sunderland supports the conclusions reached by Durham County Council that the site(s) should not be allocated within Durham's emerging Core Strategy as strategic sites in their own right. Given the proximity of these sites to Sunderland, particularly the Pittington North site, I feel that it would also be of benefit to work jointly on considering merits of these proposals.

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Mr T Bolton The Parish Council does not wish to make any specific comments or representations Noted. Our approach to surface mined coal and fireclay Eldon Parish Council at this point on the proposal for a new surface mined coal site at Blue House Farm, is set out in policy 56 of the Preferred Options. Eldon. However, the Council would expect to be consulted at an early stage should any firm proposals (i.e. a planning application) be submitted for the future development of the site, at which time the Parish Council would then intend to comment in detail.

Question 10 - Waste Handling Facility Langley Park Industrial Estate North

Waste Handling Facility - Langley Park Industrial Estate North - Do you agree that we should not consider the proposal for a waste facility at Langley Park North Industrial Estate as strategic site allocation, and that the proposal should instead be considered through the Minerals and Waste Policies and Allocations DPD? (In providing your reply please explain why this site should or should not be considered).

Respondent Question 10 - Waste Handling Facility - Langley Park Industrial Estate North - Do Council Response you agree that we should not consider the proposal for a waste facility at Langley Park North Industrial Estate as strategic site allocation, and that the proposal should instead be considered through the Minerals and Waste Policies and Allocations DPD?

Mr Bryan Huntley Agree that the proposal for a waste facility at Langley Park North Industrial Estate should Support for not considering this site as a Darlington Borough Council not be considered as a strategic site allocation, and that the proposal should instead be strategic site noted. The approach taken in considered through the Minerals and Waste Policies and Allocations DPD. Preferred Options policies 61 (Waste Management Provision) and 62 (Location of New Waste Facilities) provides a flexible approach to providing for new capacity.

Mrs Susan Carmedy The Parish Council agrees with the principles of the document and the criteria for allocation Support for not considering this site as a Brandon & Byshottles Parish of strategic waste sites. The Council particularly would welcome site(s) with anaerobic strategic site noted. The approach taken in Council digestion plants such as that proposed for Langley Park North Industrial Estate. New Preferred Options policies 61 (Waste technologies should be embraced as they developed Management Provision) and 62 (Location of New Waste Facilities) provides a flexible approach to providing for new capacity.

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Ms G Gibson C.P.R.E. cannot add to the comments of the officers but does note permission has been Comments noted. The County Durham Plan CPRE granted for an anaerobic digestion plant at Newton Aycliffe which may significantly affect Preferred Options sets out the scale of the the need for other such plants in the County. There is of course also the existing permission County's future waste management for such a plant at Old Quarrington which may or may not proceed. challenge. Significant new waste management capacity is required to make a step change in the method of waste management from disposal via landfill to recycling and recovery. The approach taken in Preferred Options policies 61 (Waste Management Provision) and 62 (Location of New Waste Facilities) provides a flexible approach to providing for new capacity, as no strategic sites have been allocated.

Ms S Wickerson Under the Environmental Permitting (England and Wales) Regulations 2010 the applicant Comments noted. The approach taken in Environment Agency will be required to apply for a permit. Due to the location of the proposed site, the applicant Preferred Options policies 61 (Waste is advised to refer to the Environment Agency's Position Statement for 'Composting and Management Provision) and 62 (Location Potential Health Effects from Bioaerosols'. Applicants for new composting operations within of New Waste Facilities) provides a flexible 250 metres of workplaces or dwellings are required to carry out a Site Specific Bioaerosol approach to providing for new capacity. Risk assessment. Before granting a permit the EA needs to be satisfied that the Site Specific Bioaerosol Assessment shows that bioaerosols can be and will be maintained no higher than acceptable levels at the sensitive receptors..

Question 11 - Waste Transfer Station Old Brickworks, Bishop Auckland

Waste Transfer Station Old Brickworks, Bishop Auckland - Do you agree that we should not consider the proposal for a waste facility at the former Newton Cap Brickworks as strategic site allocation, and that the proposal should instead be considered through the Minerals and Waste Policies and Allocations DPD? (In providing your reply please explain why this site should or should not be considered)

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Respondent Question 11 - Waste Transfer Station Old Brickworks, Bishop Auckland - Do Council Response you agree that we should not consider the proposal for a waste facility at the former Newton Cap Brickworks as strategic site allocation, and that the proposal should instead be considered through the Minerals and Waste Policies and Allocations DPD?

Mr Bryan Huntley Agree that the proposal for a waste facility at Newton Cap Brickworks should not be Support noted. The approach taken in Preferred Darlington Borough Council considered as a strategic site allocation, and that the proposal should instead be Options policies 61 (Waste Management considered through the Minerals and Waste Policies and Allocations DPD. Provision) and 62 (Location of New Waste Facilities) provides a flexible approach to providing for new capacity.

Mr P Seagrave 1.Involvement in the process Our thanks to the County for letting us know of this latest The County Council note the points made and Seagraves (Contractors) Ltd round in the consultation process. The Seagrave family, who are experienced in waste understand the arguments put forward. recovery, are keen to continue to be involved in this and related parts of the emerging LDF so that they understand fully what public policy is asking of them. They have The site does not meet the criteria for taken professional advice and committed funds and are seeking to ensure a viable consideration as a strategic site. The site was use for an existing underused and un-aesthetic site. The basic position is welcome assessed under the criteria and is not considered in its simplicity: here is an under-performing site close to the centre of a major town, to be a potential strategic site. This does not indeed within easy walking distance of the town's core centre. Any sound LDF should prevent the site from being considered for promote it for its highest and best use. The question is: what is that highest and best allocation in the future (any site which is not use? The Seagrave family see the LDF's suite of waste policies as being the critical allocated in the main County Durham Plan documents which will tell them whether there is an express public desire exhibited by document may still be considered in the Minerals the Planning Authority for their site to perform its potentially considerable waste transfer and Waste Policies and Allocations DPD, function or whether they should look to other parts of the LDF to allocate it for an alongside any other non-strategic site), however alternative use, presumably housing. 2. The Site's geographical position. The main it will not be an allocation which is central to the holes in the ground in County Durham are where there has been extensive aggregate delivery of the Plan's strategy. Whilst capacity is extraction and they are largely in the centre or east. Waste streams however are not specified, the size of the site (3ha) would generated all over the County and distances in the west are great. The site is extremely suggest that it is not of a strategic nature. well placed with access off a newly constructed road of good quality. It can intercept and act as a recycling / transfer point for all of Weardale and related areas including the considerable developments there will be around Bishop Auckland. Even if the same material were going to Wade's at Newton Aycliffe, let alone up onto the limestone The approach taken in Preferred Options policies plateau there would be considerable savings in HGV road miles and fuel. There seems 61 (Waste Management Provision) and 62 to be a strong sustainablity case for the site. If it is wanted then presumably it should (Location of New Waste Facilities) provides a be allocated for / reserved for that use. The family continue to be involved in both flexible approach to providing for new capacity. metal recycling and pallet /wood recycling. They have the expertise to do it. They are looking for encouragement to invest further the considerable sums (as well as the management time and energy diverted from their other businesses) to bring the site forward and into use as a major waste transfer and recovery site. 3. Suggested Meeting We respectfully suggest that after this submission is received then a joint meeting with someone from mineral section and the wider LDF team would be useful to decide

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what use the LDF is going to ask of this site. It clearly cannot be left underused and greenfields further from the town centre used instead. 4. Formal Submission We respectfully ask that the Core Strategy or other Strategic Waste Document be made sound by words along the following lines: The former brickworks at Bishop Auckland is a valuable site which a sound plan must bring into re-use; it will be reserved as a waste transfer site to deal with the reduction of as much waste as possible emanating from the broad Weardale area. If this use proves uneconomic to deliver then the site will be allocated for an alternative use. I have looked at the broad words used to discuss or distinguish strategic sites but suggest- most respectfully- that they add little to planning common sense and one might as well say that suitable sites will be selected and the strategic function of each discussed in a pen picture; but keep it flexible.

Ms G Gibson C.P.R.E. cannot add to the comments of the officers but does note permission has Comments noted. The County Durham Plan CPRE been granted for an anaerobic digestion plant at Newton Aycliffe which may significantly Preferred Options sets out the scale of the affect the need for other such plants in the County. There is of course also the existing County's future waste management challenge. permission for such a plant at Old Quarrington which may or may not proceed. Significant new waste management capacity is required to make a step change in the method of waste management from disposal via landfill to recycling and recovery. The approach taken in Preferred Options policies 61 (Waste Management Provision) and 62 (Location of New Waste Facilities) provides a flexible approach to providing for new capacity, as no strategic sites have been allocated.

Ms S Wickerson We have no in principle concerns regarding this site. Noted. Environment Agency

Question 12 - Criteria for Non Strategic Minerals Sites

Criteria for Non Strategic Minerals Sites - Taking into account the above, do you have any further comments? (Please note that these criteria will be used in conjunction with the appraisal method outlined in section 9).

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Respondent Question 12 - Criteria for Non Strategic Minerals Sites - Taking into account the Council Response above, do you have any further comments?

Mr Bryan Huntley Assuming that the final bullet point applies to all sites, it may add clarity to make it the Comment noted. Criteria for non-strategic minerals Darlington Borough fourth bullet point. That way, the first bullets apply to all sites while the remaining bullets and waste sites and the approach to their allocation Council are mineral-specific. Should the third bullet refer to "agreement of the landowner and are set out in the Preferred Options. The final bullet the owner of mineral rights" as the two are not always the same person. point which relates to transport has been combined with the second bullet point which relates to the environment.

Mr David Brewer Yes. For surface mined coal sites, the key test of environmental acceptability should We do not agree that the potential allocations for coal Confederation of UK Coal be qualified by the alternative community benefit test as set out in Government guidance working should benefit from the exception tests Producers (COALPRO) (para.8 of MPG3). The alternative tests are given full recognition in the Technical provided by paragraph 8 of MPG3 (now NPPF) as our Consultation Report 'Energy Minerals in County Durham' and should be duplicated aim is to allocate only environmentally acceptable here. sites. However, a Development Management policy for coal has now been prepared and included within the Local Plan Preferred Options. We do not consider that operators will be able or willing to demonstrate that allocations provide local or community benefit at a plan level as that would mean they accept schemes are environmentally unacceptable. It is our experience that identification and quantification of local and community benefits to outweigh the adverse impacts of environmentally unacceptable schemes only comes forward through consideration of planning applications.

Mr Lee Weatherall The key test identified for surface coal mine sites should be quantified by the exception We do not agree that the potential allocations for coal ATH Resources test provided in paragraph 8 of MPG3 with regard to community benefits. While the working should benefit from the exception tests Mr Neil Marlborough issue of community benefits may not be one for which there is a significant amount of provided by paragraph 8 of MPG3 (now NPPF) as our information available at the allocation stage, if a proposal is able to identify anything aim is to allocate only environmentally acceptable Entec UK Ltd of relevance, then it should be taken into account. sites. However, a Development Management policy for coal has now been prepared and included within the Local Plan Preferred Options. We do not consider that operators will be able or willing to demonstrate that allocations provide local or community benefit at a plan level as that would mean they accept schemes are environmentally unacceptable. It is our experience that identification and quantification of local and community benefits to outweigh the adverse

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Respondent Question 12 - Criteria for Non Strategic Minerals Sites - Taking into account the Council Response above, do you have any further comments?

impacts of environmentally unacceptable schemes only comes forward through consideration of planning applications.

Miss Rachael Bust The proposed criteria for non-strategic minerals appear broadly suitable, however the We do not agree that the potential allocations for coal Coal Authority specific approach towards surface mined coal focuses only upon environmental working should benefit from the exception tests acceptability which is not fully in line with national planning policy set out in MPG3. provided by paragraph 8 of MPG3 (now NPPF) as our MPG3 sets out a sequential approach to determining the acceptability of surface coal aim is to allocate only environmentally acceptable proposals and does allow for schemes that are not environmentally acceptable to be sites. However, a considered where community benefits arise. MPG3 Paragraph 8 states: 'In applying the principles of sustainable development to coal extraction, whether opencast or Development Management policy for coal has now deep-mine, and to colliery spoil disposal, the Government believes there should normally been prepared and included within the Local Plan be a presumption against development unless the proposal would meet the following Preferred Options. We do not consider that operators tests: i. Is the proposal environmentally acceptable, or can it be made so by planning will be able or willing to demonstrate that allocations conditions or obligations? ii. If not, does it provide local or community benefits which provide local or community benefit at a plan level as clearly outweigh the likely impacts to justify the grant of planning permission?' The that would mean they accept schemes are criteria set out in the County Durham Plan need to accord with this national planning environmentally unacceptable. It is our experience policy approach. that identification and quantification of local and community benefits to outweigh the adverse impacts of environmentally unacceptable schemes only comes forward through consideration of planning applications.

Ms G Gibson C.P.R.E. thinks we do need to specify the difference between strategic and non strategic Criteria for non-strategic minerals and waste sites CPRE e.g. 1) Does the difference purely relate to size/quantity of the mineral? 2) What is the and the approach to their allocation are set out in the difference likely to be in planning terms? 3) In short, is one more likely to receive Preferred Options. permission than the other? Will the fact that there is a strategic supply of a given mineral mean that permission is less likely to be granted for the same mineral at a non strategic site?

Ms S Wickerson Section 7, Question 12. The reference to 'environmentally acceptable' non-strategic In considering allocations we will also consider the Environment Agency mineral sites considers assessment under Sustainability Appraisal and the Habitats proposed method of working and restoration. Directive. We consider that the criteria should make it explicit that these assessments include the restoration proposals for landfills in addition to the extraction and processing operations.

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Respondent Question 12 - Criteria for Non Strategic Minerals Sites - Taking into account the Council Response above, do you have any further comments?

Mr Michael Hodges For the reasons set out in response to Question 3 and Question 8 of the Technical The Local Plan Preferred Options Report (Policy 53) Sherburn Stone Co Ltd Consultation Report '˜Towards a Minerals Delivery Strategy for County Durham', we sets out the Councils emerging approach to are firmly of the opinion that further provision should be made for the extraction of aggregate minerals and agricultural lime. The Local Magnesian Limestone during the plan period. We are therefore concerned about the Plan Preferred Option report also proposes a single criteria which states that, in relation to aggregates minerals sites, the extent and crushed rock landbank. distribution of existing permitted reserves and the likelihood of its extraction, current landbank size for the mineral, principal end uses and residual need over the plan period Further work will be undertaken on aggregate supply will all be key considerations. Given that, on the face of it, there is a large landbank for through the Council's Local Aggregate Assessment. Magnesian Limestone, the application of this criterion could lead to no proposal for See responses to question 3, 8 and 14 of Towards a Magnesian Limestone extraction being allocated in the plan. We have however identified Minerals Delivery Strategy for County Durham as in response to Question 8 of the Technical Consultation Report 'Towards a Minerals contained in this Statement of Consultation. Delivery Strategy for County Durham' that the question of need and landbanks does not apply to agricultural lime.

Further in response to Question 3 that there is concern that the landbank for Magnesian Limestone aggregates will become bound up in very few sites during the Plan Period contrary to MPS1. Accordingly careful consideration needs to be exercised to ensure that proposals for non-strategic magnesian limestone sites are not prevented from being allocated through the application of this criterion.

Miss C Kinnear We agree with the key considerations for Aggregate minerals sites, particularly in Comments noted. The reference to principal end uses relation to the consideration of principal end uses. However, we believe that related to the end use of the minerals. Consideration RSPB consideration of end use should not be limited to aggregates sites, but include all of the proposed approach to restoration will be mineral sites. considered under the environmental criteria.

Ms Janice Brabban For non-strategic mineral sites, including surface mining sites, if the land supports This is a matter of fine detail which will need to be Durham County Badger protected species such as the badger, the criteria should include a requirement that a addressed by the Development Management team Group restoration plan be produced which re-instates the earthworm content of the original when considering planning applications for the soil within a five-year period. At the moment, using current 'best practice' soil-handling winning and working of minerals. techniques this does not happen, as earthworms do not survive in stored soils, and therefore following mineral extraction, loss of badger foraging is long-term. This is a well-known problem, and needs to be addressed by developers' restoration plans as a condition of planning approval.

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Question 13 - Criteria for non-strategic Waste Sites

Criteria for non-strategic Waste Sites - Taking into account the above, do you have any further comments? (Please note that these criteria will be used in conjunction with the appraisal method outlined in section 9).

Respondent Question 13 - Criteria for non-strategic Waste Sites - Taking into Council Response account the above, do you have any further comments?

Mr Bryan Huntley In the first bullet point, delete the word "outset". Accepted. This is a typographical error. Criteria for Darlington Borough Council non-strategic minerals and waste sites and the approach to their allocation are set out in the Preferred Options.

Ms G Gibson There is an apparent logic in the criteria, but the division between Criteria for non-strategic minerals and waste sites and the CPRE strategic and non-strategic sites could be confusing, especially as they approach to their allocation are set out in the Preferred will, we understand, be dealt with in different documents. Similar Options. comments to the above could also apply here.

Ms S Wickerson Section 7, Question 13. The criteria as written are generally sound. We Comments noted. Criteria for non-strategic minerals and waste Environment Agency repeat our point from Question 1, that the Authority consider whether a sites and the approach to their allocation are set out in the broader reference to the waste hierarchy to encourage recycling in Preferred Options. Through the assessment of sites there is addition to exploiting waste heat would be appropriate. an implicit consideration of acceptability in relation to policy. This will include the site's ability to deliver the waste hierarchy and the wider aims of the Plan. The Plan's wider aims include where appropriate the promotion of opportunities for delivering decentralised energy from waste. The criteria have been changed accordingly, however, in order to make it explicit that opportunities for decentralised energy from waste will be exploited. This is in line with the updated strategic aims.

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D Responses to Technical Consultation Paper 'Safeguarding Mineral Resources for the future'.

Question 1 - To distinguish between resource and operator proposals.

Should we distinguish between operator proposed mineral sites which are not allocated for working within the plan period and any larger Mineral Safeguarding Area? If so how should we do this?

Respondent Question 1 - Should we distinguish between operator proposed mineral Council response sites which are not allocated for working within the plan period and any larger Mineral Safeguarding Area? If so how should we do this? Miss Rachael Bust The Coal Authority supports the intended approach to identifying Mineral The arguments of the Coal Authority are Coal Authority Safeguarding Areas (MSAs), however we do not consider that it is desirable noted. On reflection we agree that there is to distinguish between operator proposed mineral sites which are not merit in keeping the approach as simple as allocated for working within the plan period and any larger MSA. To introduce possible. We will not distinguish operator such a distinction would effectively introduce a two tier approach to proposed sites which are not allocated for safeguarding which could undermine the broad approach to safeguarding. working within the Plan period and any larger If areas of future potential extraction were wanted to be shown these should Mineral Safeguarding Area. All operator be shown as areas of search or similar designation. proposed sites which are not allocated for working during the Plan period will be safeguarded by the general Mineral Safeguarding Area designation. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mrs Margaret Forster Coxhoe Parish Council has no comments to make on the 'Safeguarding Noted. Preferred Options policy 58 sets out Coxhoe Parish Council Mineral Resources for the future' Consultation Document. our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

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Respondent Question 1 - Should we distinguish between operator proposed mineral Council response sites which are not allocated for working within the plan period and any larger Mineral Safeguarding Area? If so how should we do this? Mr David Brewer There is an argument for a half-way house. One way might be to designate See response to the Coal Authority above. Confederation of UK Coal such sites/areas as Minerals Consultation Areas. Please note we have been advised that a Producers (COALPRO) 'Unitary Council' we can not identify Mineral Consultation Areas. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr Bryan Huntley There is no need to distinguish between operator proposed mineral sites Noted. On reflection we agree that there is Darlington Borough Council which are not allocated for working within the plan period and any larger merit in keeping the approach as simple as MSA as the MSA policy will be sufficient to safeguard sites which contain possible. We will not distinguish operator economically important minerals. proposed sites which are not allocated for working within the plan period and any larger Mineral Safeguarding Area. All operator proposed sites which are not allocated for working during the Plan period will be safeguarded by the general mineral safeguarding area designation. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr M Charis If the MSA works as it is intended, i.e. with due consideration of the Noted. On reflection we agree that there is Mineral Planning information known about the importance of the mineral interest in the land merit in keeping the approach as simple as Association compared to the importance of alternative development, then it should be possible. We will not distinguish operator an easy matter to determine their relative merits. In addition, if a site is being proposed sites which are not allocated for promoted for future working, it should already be in the hands of the industry working within the plan period and any larger and alternative proposals are unlikely to arise. However, even if this is not Mineral Safeguarding Area. All operator the case, it would be the developer's responsibility to show why the mineral proposed sites which are not allocated for interest should be overridden. In short, there is no need to have a hierarchy working during the Plan period will be of safeguarded sites. Either they are, or they're not. safeguarded by the general mineral

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Respondent Question 1 - Should we distinguish between operator proposed mineral Council response sites which are not allocated for working within the plan period and any larger Mineral Safeguarding Area? If so how should we do this? safeguarding area designation. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr David Atkinson Regardless of whether a mineral resource has been identified using BGS Noted. In defining Mineral Safeguarding Lafarge Aggregates Ltd mapping data or proposed by a mineral operator, all economically viable or Areas the Council intends to use British potentially economically viable mineral resources should be safeguarded Geological Survey data, Coal Authority data in accordance with national policy as set out in MPS1. As indicated in and any data supplied by mineral operators. previous representations to consultations on the County Durham Plan, All operator proposed sites which are not Lafarge has identified significant additional Basal Permian Sand resources allocated for working during the plan period within the existing Thrislington Quarry (central and southern parts) which will be safeguarded. The basal permian sand are considered to be of strategic importance and could make a valuable resource at Thrislington Quarry will be contribution to Durham's future sand requirements. As such, this resource safeguarded as part of our Mineral should be safeguarded both during the plan period and beyond. Further Safeguarding Areas. Preferred Options details comments relating to the safeguarding of the Basal Permian Sand policy 58 sets out our approach to resources at Thrislington are set out in the response to the consultation safeguarding minerals resources. MSAs are paper 'New Minerals and Waste Sites in County Durham' set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr C Ball Para 2.2 UK Coal welcome the intention outlined in Para 2.2 of the Noted. On reflection we agree that there is UK Coal Mining Ltd "Safeguarding Mineral Resources for the Future" document of using the merit in keeping the approach as simple as Coal Authority's Surface Coal Resource Plan to identify Mineral Safeguarding possible. We will not distinguish operator Areas (MSAs). We feel that this is consistent with the approach identified proposed sites which are not allocated for in MPS1 of using best available information to identify mineral resources. working within the plan period and any larger Mineral Safeguarding Area. All operator Response to Question 1 UK Coal would be happy to see a distinction made proposed sites which are not allocated for between sites that are allocated for working in the plan period and the rest working during the Plan period will be of the MSA. This would have the advantage of giving a clear indication of safeguarded by the general mineral which sites are considered more likely to be worked within the plan period. safeguarding area designation. Preferred

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Respondent Question 1 - Should we distinguish between operator proposed mineral Council response sites which are not allocated for working within the plan period and any larger Mineral Safeguarding Area? If so how should we do this? UK Coal feels that the policy should be worded to give a greater degree of Options policy 58 sets out our approach to protection to these sites, as they are considered to be the most deliverable safeguarding minerals resources. MSAs are within the region. set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Ms G Gibson It is appreciated Durham County Council over the years has had a good Noted. CPRE track record of restoring sites and monitoring resources and their quarrying and we trust the authority will continue its good work. The threat of sterilisation will not be an overriding reason which would justify Attached is comment from C.P.R.E. Co Durham Branch. In addition we mineral extraction in itself. In this respect would like to make the following general comment: We have a responsibility national policy in NPPF requires to make best use of our precious resources many of which are nationally, consideration of prior extraction. if not internationally, important so best use can be made of them. This must be done taking into account the residential amenity of those in the areas Any proposal for the extraction of surface involved and the effect on the landscape. What is important is there is a coal would be considered in relation to measured approach and clear policy on the County's resources which is policy framework which is in place. When fully transparent and fully consulted. The ability to comment at the various considering future proposals we will stages is appreciated. consider the restoration of sites taking into account all relevant matters including The approach is good - but threat of sterilisation by an imminent development landscape character. should never be an excuse for ill-considered approval for minerals extraction (as has happened elsewhere). The MSA policy will be prepared alongside other policies i.e. Policies to safeguard waste The MSA should be compared and aligned with other safeguarding policies sites and mineral processing and and strategies e.g. protection of rail or road lines, wildlife corridors and other transportation infrastructure. However, it key habitats to avoid future conflict. They should also be compared with should be noted that a MSA designation e.g. areas of search for wind farms to avoid future cumulative impact issues. does not mean that mineral extraction will Strategic remediation approaches informed by National Character Area be permitted in the future, but merely that objectives should be defined for each MSA. The safeguarding of existing economically important mineral resources and future rail and port infrastructure is noted. However, what mechanisms are believed to occur in that location. are in place (in the absence of RSS) to safeguard the port facilities outside Accordingly consideration of cumulative Co Durham which are named as alternatives to Seaham? Q1 - It is important impact for this matter is not applicable. when considering minerals to look beyond the plan period. All potential

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Respondent Question 1 - Should we distinguish between operator proposed mineral Council response sites which are not allocated for working within the plan period and any larger Mineral Safeguarding Area? If so how should we do this? reserves should be considered and protection made as appropriate. It is The County Council can not safeguard important reserves which could be used in the future, beyond this plans facilities outside of County Durham, the period, are not sterilised by inappropriate development. relevant LPA for each area must seek to safeguard relevant mineral transportation facilities within their area. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

Mr T Bolton The Parish Council would support the approach proposed in the document This response relates to paragraph 2.2 of the Eldon Parish Council in relation to safeguarding of all of the area identified by the Coal Authority consultation paper. Response noted. on its Coal Resource Plans. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Natural England Page 10 Environmental Designations We agree that environmental This response relates to paragraph 2.8 of the designations should not be considered in designating MSAs, as the consultation paper. As set out in the designation of a MSA does not provide any presumption that resources will consultation paper, environmental be worked. Page 34 This section should also make clear that other planning designations will not be taken into account policies will also be taken into consideration (such as protection of the natural in designating MSAs. Preferred Options environment) when considering non mineral development proposals. policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

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Question 2 - Should we buffer the resource boundary

Rather than identify on the proposals map the safeguarded mineral resource area and a wider MSA designation which encompasses the safeguarded mineral resource and a buffer to help prevent encroaching proximal development we would welcome views on two alternative approaches:

Option A - Designate MSAs based upon the mineral resource only and require through the use of criteria in the development management policy that non minerals development within the vicinity of the MSA, existing mineral sites, any strategic and any non strategic site should consider whether development would sterilise future mineral extraction; or Option B - Designate MSAs based upon the mineral resource only and in order to prevent encroaching proximal development on the most important safeguarded areas designate some form of mineral consultation area around existing mineral sites, and proposed strategic and non strategic sites . We favour option B. Which approach do you favour? (Please explain your answer).

Respondent Question 2 - Rather than identify on the proposals map Council Response the safeguarded mineral resource area and a wider MSA designation which encompasses the safeguarded mineral resource and a buffer to help prevent encroaching proximal development. Miss Rachael Bust The principle of wanting to protect the minerals on the fringe Preference for Option A noted. Coal Authority of MSAs from sterilisation by adjacent development not within the actual MSA is laudable. In two tier areas this can be Rather than defining Mineral Safeguarding Areas and achieved by the use of a Mineral Consultation Area (MCA) Mineral Consultation Areas which we note we are now that is larger in extent than the MSA. County Durham is not a advised we can not do, we are developing an approach two-tier area and therefore the use of an MCA could cause on the basis of Option A. This would require the Council unnecessary confusion and inconsistency of terminology to designate Mineral Safeguarding Areas based upon the between County Durham and the national policy approach set mineral resource and require that the development out in MPS1 and in the BGS Guide to Mineral Safeguarding. management policy ensures that non minerals Option B is also premised upon the use of a differential development within the vicinity of the MSA, existing approach within MSAs, i.e. general MSAs and the 'most mineral sites, any strategic and any non strategic site important safeguarded areas'. As indicated in Question 1, The should consider whether development would sterilise Coal Authority do not support such a differential and could not future mineral extraction. therefore support Option B. Our preference would be 'Option

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Mr Bryan Huntley Option B is favoured because it will flag-up to developers the Preference for Option B noted. Darlington Borough need to specifically address the potential impact of the Council proximity of their proposed development on the existing mineral Rather than defining Mineral Safeguarding Areas and operation and vice versa. While a buffer zone can be inflexible, Mineral Consultation Areas which we note we are now a Mineral Consultation Area can result in appropriate proximal advised we can not do, we are developing an approach development which is closer to the mineral operation in some on the basis of Option A. This would require the Council locations than others,without being approved as an exception to designate Mineral Safeguarding Areas based upon the to the policy. mineral resource and require that the development management policy ensures that non minerals development within the vicinity of the MSA, existing mineral sites, any strategic and any non strategic site should consider whether development would sterilise future mineral extraction. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

Sue A Brett As Durham is a unitary authority, there is no requirement in Rather than defining Mineral Safeguarding Areas and Cumbria County Council MPS1 to provide MSAs AND MCAs; the latter may be provided Mineral Consultation Areas which we note we are now in two-tier areas, where there needs to be consultation between advised we can not do, we are developing an approach

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Given the extent of the proposed mineral safeguarding areas which are extensive we will not designate a buffer around all of the mineral resources. This would further increase the size of the proposed mineral safeguarding areas and lead to a degree of confusion between where the resource lies and does not lie. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

Mr David Brewer CoalPro favours Option B because it represents a clearer Preference for Option B noted. Confederation of UK Coal policy approach and leaves no doubt that development should Producers (COALPRO) not take place within such proximal areas other than by Rather than defining Mineral Safeguarding Areas and exception. Mineral Consultation Areas which we note we are now advised we can not do, are developing an approach on the basis of Option A. This would require the Council to designate Mineral Safeguarding Areas based upon the mineral resource and require that the development management policy ensures that non minerals development within the vicinity of the MSA, existing mineral sites, any strategic and any non strategic site should consider whether development would sterilise

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Mr Lee Weatherall With both options ATH Resources welcome the importance Preference for Option B noted. ATH Resources which is given to the fact that existing extraction sites and allocations need safeguarding from encroaching development. Rather than defining Mineral Safeguarding Areas and It is considered that option B provides a clearer approach in Mineral Consultation Areas which we note we are now that interested parties will be able to view definitive areas of advised we can not do, we are developing an approach where a potential issue is relevant and that this issue will have on the basis of Option A. This would require the Council to be considered. to designate Mineral Safeguarding Areas based upon the mineral resource and require that the development management policy ensures that non minerals development within the vicinity of the MSA, existing mineral sites, any strategic and any non strategic site should consider whether development would sterilise future mineral extraction. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

Mr C Ball With regard to MSAs, the preferred option of UK Coal would Preference for Option B noted. UK Coal Mining Ltd be the adoption of Option B. This is as we consider that clearly defining Mineral Consultation Areas that adjoin MSAs Rather than defining Mineral Safeguarding Areas and represents the most effective means of preventing the Mineral Consultation Areas which we note we are now encroachment of proximal development that may potentially advised we can not do, we are developing an approach sterilise mineral resources into these important areas. We on the basis of Option A. This would require the Council consider that the other option, that of a criteria based approach, to designate Mineral Safeguarding Areas based upon the will be more difficult to apply and so potentially less effective. mineral resource and require that the development

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Mr M Charis We would rather that you defined the MSA to include proximal Given the extent of the proposed mineral safeguarding Mineral Planning land (a buffer) for the whole outcrop as well as land underlain areas which are extensive we will not designate a buffer Association by a mineral deposit and had one designation. This is the around all of the mineral resources. This would further approach recommended by the BGS Guidance. In addition, increase the size of the proposed Mineral Safeguarding the Guidance clearly states that MCAs are a tool for use where Areas and lead to a degree of confusion between where there are two tier authorities, which is not the case in Durham. the resource lies and does not lie. The only exception to It appears to us that the only justification of using an MCA is this is Magnesian Limestone, where we have identified to protect infrastructure where this is outside of the resource the resource to be safeguarded on the the basis of the area. MSAs should contain all the buffering that is needed to Lower Permian outcrop of the Magnesian Limestone and protect the resource from sterilisation. Therefore, we cannot buffered the eastern edge of the outcrop to take into support either of your options and we would urge you to follow account the likelihood of quarries working down through the advice of the BGS document closely. the Middle Permian Magnesian Limestone into the lower Permian Magnesian Limestone. This will ensure that a significant area of the resource is safeguarded, including the most productive part of the Permian Magnesian Limestone in County Durham and where the majority of the County's magnesian limestone quarries and all the proposals for new allocations for working lie.

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Mr David Atkinson Lafarge support the Council's preferred Option B to designate Preference for Option B noted. Lafarge Aggregates Ltd MSAs based upon the mineral resource only and to designate some form of Mineral Consultation Area around existing Rather than defining Mineral Safeguarding Areas and mineral sites and proposed strategic and non strategic sites Mineral Consultation Areas which we note we are now in order to prevent the encroachment of non mineral (proximal) advised we can not do, we are developing an approach development on safeguarded areas. on the basis of Option A. This would require the Council to designate Mineral Safeguarding Areas based upon the mineral resource and require that the development management policy ensures that non minerals development within the vicinity of the MSA, existing mineral sites, any strategic and any non strategic site should consider whether development would sterilise future mineral extraction. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

Ms G Gibson Option B is preferred, as designating a Mineral Consultation Preference for Option B noted. CPRE Area will bring certainty, clarity and consistency. Rather than defining Mineral Safeguarding Areas and Mineral Consultation Areas which we note we are now advised we can not do, we are developing an approach on the basis of Option A. This would require the Council to designate Mineral Safeguarding Areas based upon the

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Mr T Bolton The Council further supports Option B in relation to designation Preference for Option B noted. Eldon Parish Council of minerals safeguarding areas. Rather than defining Mineral Safeguarding Areas and Mineral Consultation Areas which we note we are now advised we can not do, we are developing an approach on the basis of Option A. This would require the Council to designate Mineral Safeguarding Areas based upon the mineral resource and require that the development management policy ensures that non minerals development within the vicinity of the MSA, existing mineral sites, any strategic and any non strategic site should consider whether development would sterilise future mineral extraction. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

Mr N Spence The proposal to identify Mineral Consultation Areas is fully Preference for Option B noted. Ibstock Brick Ltd Property supported as a means of ensuring that minerals are not Manager North sterilised by development. Buffer zones are also appropriate

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Respondent Question 2 - Rather than identify on the proposals map Council Response the safeguarded mineral resource area and a wider MSA designation which encompasses the safeguarded mineral resource and a buffer to help prevent encroaching proximal development. and thus should be made use of to ensure that the mineral Rather than defining Mineral Safeguarding Areas and resource is not potentially constrained by nearby built Mineral Consultation Areas which we note we are now development where there would be a need to protect amenity. advised we can not do, we are developing an approach An example of good practice by the BGS in its document 'A on the basis of Option A. This would require the Council guide to mineral safeguarding in England', October 2007' page to designate Mineral Safeguarding Areas based upon the 23 of the BGS guide stating buffer zones to be 'stand-off limits mineral resource and require that the development to protect nearby residents and on the other hand protect the management policy ensures that non minerals (mineral) resource from sterilisation by nearby development' development within the vicinity of the MSA, existing This BGS guide is commonly accorded significant weight in mineral sites, any strategic and any non strategic site decision making terms. In this instance applying the necessary should consider whether development would sterilise (Brick clay) 50m buffer zone. future mineral extraction. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

Question 3 - Coal resources underlying urban areas

Do you agree that surface coal resources underlying urban areas should not be excluded from Mineral Safeguarding Areas?

Respondent Question 3 - Do you agree that surface coal resources Council Response underlying urban areas should not be excluded from Mineral Safeguarding Areas? Mr Bryan Huntley Agree that surface coal resources underlying urban areas should Noted. Coal underlying urban areas will not be Darlington Borough not be excluded from MSAs. excluded from MSAs. Preferred Options policy 58 sets Council out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

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Respondent Question 3 - Do you agree that surface coal resources Council Response underlying urban areas should not be excluded from Mineral Safeguarding Areas? Sue A Brett Although it seems logical that coal underlying urban areas is Noted. Coal underlying urban areas will not be Cumbria County Council already sterilsed, it would be very difficult to define these urban excluded from MSAs. Preferred Options policy 58 sets areas - do you include villages or groups of houses? - will owners out our approach to safeguarding minerals resources. worry that their property is blighted? Furthermore, the Coal MSAs are set out in Appendix Q with detailed Authority argument that pockets of regeneration within urban areas boundaries shown on the Local Plan Proposals Map. have the potential for prior extraction or to ameliorate land stability, is sensible. Mr David Brewer Yes. CoalPro strongly supports the Coal Authority's position and Noted. Coal underlying urban areas will not be Confederation of UK Coal rationale. excluded from MSAs. Preferred Options policy 58 sets Producers (COALPRO) out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr Lee Weatherall ATH Resources agree that minerals resources underlying urban Noted. Coal underlying urban areas will not be ATH Resources Ltd areas should not automatically be excluded from the safeguarding excluded from MSAs. Preferred Options policy 58 sets areas and that it would be practical to assess these on the basis out our approach to safeguarding minerals resources. of the minerals resource being considered. With regard to surface MSAs are set out in Appendix Q with detailed coal, ATH Resources would agree with the comments made by boundaries shown on the Local Plan Proposals Map. the Coal Authority on the Issues and Options that coal extraction can be suitable in urban areas. Miss Rachael Bust The Coal Authority is of the view that surface coal resources Coal underlying urban areas will not be excluded from Coal Authority underlying urban areas should not be excluded from MSAs for the MSAs. reasoning we have put to you previously and is set out in Para 2.10. Public Examinations elsewhere such as Bristol City and the Previously worked sites will not be excluded from Black Country have confirmed that it is necessary and appropriate MSAs. to safeguard mineral resources in urban areas in order to comply with MPS1. The Council will use information provided by the Coal Authority to define mineral safeguarding areas for Representation No.5 Site/Policy/ Paragraph/Proposal - Previously surface mined coal. Worked Mineral Sites Support - The Coal Authority would support the intended approach not to exclude previously worked areas from MSAs.

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Respondent Question 3 - Do you agree that surface coal resources Council Response underlying urban areas should not be excluded from Mineral Safeguarding Areas? Site/Policy/Paragraph/Proposal - Surface Mined Coal Support - Deep Coal Resources - The Council will seek to use The Coal Authority supports the intended approach of safeguarding the information supplied by the Coal Authority which all of the surface coal resource identified on the plans supplied by delineates areas of deep coal. In doing so it will seek us. to address the requirements of paragraph 3.21 of Annex 4 of MPS1. Representation No.7 Site/Policy/Paragraph/ Proposal - Deep Coal Resources Comment - The Coal Authority is arranging to supply Support for potential Core Strategy Safeguarding the requested data on deep coal resources to the Council. Policy noted. Preferred Options policy 58 sets out our Representation No.8. approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries Site/Policy/Paragraph/Proposal - Potential Core Strategy shown on the Local Plan Proposals Map. Safeguarding Policy Support- The Coal Authority supports the broad approach to MSAs and the commitment to show them on the Key Diagram and then on the Proposals Map.

Mr C Ball UK Coal agrees that surface coal resources that underlie urban Noted. Coal underlying urban areas will not be UK Coal Mining Ltd areas should not be excluded from MSAs for the reasons identified excluded from MSAs. by the Coal Authority, that are set out at Para 2.10 of this document. We also consider that this is in line with the national As set out in the consultation paper previously worked objective of mineral planning identified in paragraph 9 of MPS1 " sites not be excluded from MSAs. to safeguard mineral resources as far as possible ". UK Coal support the Intended Approach, identified at Para 2.14, of not With regard to the Wolsingham Coal Disposal Point, excluding previously worked sites form the MSA, and particularly while we note the requirements of paragraph 13 of supports the overall intention (set out in the Sustainability Appraisal MPS1 it is our view that it is not appropriate to Recommendation on Page 27) of safeguarding all the land safeguard temporary facilities. Amongst other identified on the Coal Authority's Coal Resource Plan. considerations, including the availability of alternative locations and existing facilities i.e Wardley Coal Depot Para 2.47 It is considered that, with regard the safeguarding of in Gateshead, the Council would wish to ascertain that rail transhipments and rail alignments, there would be merit in this site can be operated without unacceptable adverse adding Wolsingham Disposal Point to the list of facilities to be impacts on the local environment and amenity . If the protected. This site offers the opportunity to promote the Wolsingham Coal Depot was a permanent facility it sustainable transport of minerals by rail in accordance with the would be safeguarded. Preferred Options policy 58 policy identified in Para 13 of MPS1: "safeguard existing, planned sets out our approach to safeguarding minerals

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Respondent Question 3 - Do you agree that surface coal resources Council Response underlying urban areas should not be excluded from Mineral Safeguarding Areas? and potential railheads, wharfage and associated storage, handling resources. MSAs are set out in Appendix Q with and processing facilities for the bulk transport by rail, sea or inland detailed boundaries shown on the Local Plan waterways of minerals, particularly coal and aggregates;" It would Proposals Map. also accord with the advice contained in Para 47 of Planning Policy Guidance Note 13 that with regard to minerals, "Local authorities should seek to enable the carrying of material by rail or water wherever possible."

Ms G Gibson Surface coal resources underlying urban areas should be included Noted. Coal underlying urban areas will not be CPRE in M.S.A.s so that if regeneration, restoration and stabilisation of excluded from MSAs. Preferred Options policy 58 sets sites is beneficial (particularly for environmental reasons) the work out our approach to safeguarding minerals resources. can be carried out - though with full due regard to residential MSAs are set out in Appendix Q with detailed amenity and the impact on the landscape. boundaries shown on the Local Plan Proposals Map.

Question 4 - Other minerals underlying urban areas

Do you agree that other minerals such as magnesian limestone, carboniferous limestone igneous rock and sand and gravel underlying urban areas should be excluded from Mineral Safeguarding Areas?

Respondent Question 4 - Do you agree that other Council Response minerals such as magnesian limestone, carboniferous limestone igneous rock and sand and gravel underlying urban areas should be excluded from Mineral Safeguarding Areas? Mr Bryan Huntley Agree that other minerals such as magnesian The principle of prior extraction will be applied to all minerals where they Darlington Borough limestone, carboniferous limestone igneous can be extracted acceptably, which can be accessed from the surface Council rock and sand and gravel underlying urban and whose duration of working is not likely to be prolonged. Preferred areas should be excluded from MSA's. Options policy 58 sets out our approach to safeguarding minerals

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Respondent Question 4 - Do you agree that other Council Response minerals such as magnesian limestone, carboniferous limestone igneous rock and sand and gravel underlying urban areas should be excluded from Mineral Safeguarding Areas? resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr M Charis The arguments used by the Coal Authority for The principle of prior extraction will be applied to all minerals where they Mineral Planning prior extraction of coal from urban renewal can be extracted acceptably, which can be accessed from the surface Association schemes are applicable to most minerals and and whose duration of working is not likely to be prolonged. Preferred we support them. Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries The principle of prior extraction should be shown on the Local Plan Proposals Map. applied to all minerals where they can be extracted acceptably. This would favour In relation to bullet 3 the Council will require mineral assessments to be minerals that can easily be accessed from the produced in accordance with the advice provided by the British Geological surface and whose duration of working is not Survey in their updated guidance on 'Mineral Safeguarding Areas in likely to be prolonged, such as sand and England: Good Practice Advice', BGS 2011. gravel. The case for using this argument for hard rock is less obvious because of its thickness and working methods.

We think you are treading on dangerous ground by arguing that scale of resources and duration of extraction should be reasons for the exclusion of urban areas for MSAs.

First, every tonne of mineral extracted from urban renewal schemes prolongs the life of existing permitted reserves and puts back the time when difficult decisions need to be made to create new sources of mineral. Second, discussion about prior extraction should take place as early in the

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Respondent Question 4 - Do you agree that other Council Response minerals such as magnesian limestone, carboniferous limestone igneous rock and sand and gravel underlying urban areas should be excluded from Mineral Safeguarding Areas? development planning process as possible to give adequate time for extraction to be carried out. Once the application has been made it is usually too late to think seriously about minerals. This means that potential conflicts need to be addressed at the LDF stage. This will have three positive effects; developers will benefit from the additional certainty that the potential for prior extraction needs to be built into their investigation and design of the site; developers will be able to factor in the revenue and valuation consequences in their acquisition strategies; and the economics of development can more easily accommodate the delay inherent in potential prior extraction of minerals. Third, the proposed assessment of the potential impacts on underlying mineral resources must be more clearly specified for the assistance of developers who may not have the relevant expertise to evaluate mineral deposits. It is imperative for local authorities to specify that investigation of the resource should be to the same standards that our members employ to evaluate a deposit.

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Respondent Question 4 - Do you agree that other Council Response minerals such as magnesian limestone, carboniferous limestone igneous rock and sand and gravel underlying urban areas should be excluded from Mineral Safeguarding Areas? Mr David Atkinson Lafarge agree with the Council's intended The principle of prior extraction will be applied to all minerals where they Lafarge Aggregates Ltd approach that other minerals such as can be extracted acceptably, which can be accessed from the surface magnesian limestone, carboniferous limestone, and whose duration of working is not likely to be prolonged. Preferred igneous rock, and sand and gravel underlying Options policy 58 sets out our approach to safeguarding minerals urban areas should be excluded from MSAs resources. MSAs are set out in Appendix Q with detailed boundaries so long as the term urban area is properly shown on the Local Plan Proposals Map. defined - i.e. it relates built development associated with the larger concentrations of population in the County.

Potential Core Strategy Safeguarding Policy Lafarge support the proposed potential Core Strategy Safeguarding Policy, in particular the specific reference to Magnesian Limestone (including areas of high grade dolomite) and Basal Permian Sand. We do, however, suggest a few minor amendments to improve the text of the policy, namely: "County Durham has the following mineral resources which are either currently of economic importance of or have the potential to became become important in the future: .....". We note and welcome the safeguarding of both rock and sand resources at Thrislington Quarry and its extension.

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Respondent Question 4 - Do you agree that other Council Response minerals such as magnesian limestone, carboniferous limestone igneous rock and sand and gravel underlying urban areas should be excluded from Mineral Safeguarding Areas? Ms G Gibson In view of the resources of the minerals listed The principle of prior extraction will be applied to all minerals where they CPRE in Question 4, those underlying urban areas can be extracted acceptably, which can be accessed from the surface could be excluded from the M.S.A.'s. However, and whose duration of working is not likely to be prolonged. Preferred this would bring an inconsistency in treatment Options policy 58 sets out our approach to safeguarding minerals between coal and the other minerals. resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr Lee Weatherall ATH Resources agree that minerals resources The principle of prior extraction will be applied to all minerals where they ATH Resources underlying urban areas should not can be extracted acceptably, which can be accessed from the surface automatically be excluded from the and whose duration of working is not likely to be prolonged. Preferred safeguarding areas and that it would be Options policy 58 sets out our approach to safeguarding minerals practical to assess these on the basis of the resources. MSAs are set out in Appendix Q with detailed boundaries minerals resource being considered. shown on the Local Plan Proposals Map.

With regard to surface coal, ATH Resources would agree with the comments made by the Coal Authority on the Issues and Options that coal extraction can be suitable in urban areas.

Question 5 - Draft development managment approach for mineral safeguarding

We would welcome your views on the draft development management policy approach. Do you agree with the proposed approach, if not why not?

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Respondent Question 5 - We would welcome your views Council response on the draft development management policy approach. Do you agree with the proposed approach, if not why not? Mr Bryan Huntley Agree with the Development Management Support noted. Following considerations of representations and Darlington Borough Policy approach consideration of new BGS guidance on mineral safeguarding published Council in 2011 the Council has decided to modify its approach a revised development management policy is proposed based upon the BGS Guide Mineral Safeguarding in England: Good Practice Advice, (2011). Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr David Brewer CoalPro agrees with the proposed approach. Support noted. Following considerations of representations and Confederation of UK Coal consideration of new BGS guidance on mineral safeguarding published Producers (COALPRO) in 2011 the Council has decided to modify its approach a revised development management policy is proposed based upon the BGS Guide Mineral Safeguarding in England: Good Practice Advice, (2011). Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr David Atkinson Lafarge support the proposed approach (i.e. Support for draft development management policy and guidelines noted. Lafarge Aggregates Ltd Option 2) to the draft Development Following considerations of representations and consideration of new Management Policy and agree with the BGS guidance on mineral safeguarding published in 2011 the Council guidelines for development which would not has decided to modify its approach a revised development management be viewed as sterilising development within policy is proposed based upon the BGS Guide Mineral Safeguarding in an MSA. England: Good Practice Advice, (2011). Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Ms G Gibson C.P.R.E. agrees with the "Potential Strategy Support for draft development management policy and guidelines noted. CPRE Safeguarding Policy". Option 2 is preferred, Following considerations of representations and consideration of new provided the assessment is thorough and BGS guidance on mineral safeguarding published in 2011 the Council particular note is taken of the final paragraph has decided to modify its approach a revised development management "In instances where the proposed...". policy is proposed based upon the BGS Guide Mineral Safeguarding in

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Respondent Question 5 - We would welcome your views Council response on the draft development management policy approach. Do you agree with the proposed approach, if not why not? England: Good Practice Advice, (2011). Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Miss Rachael Bust The Coal Authority would prefer a detailed Support for draft development management policy and guidelines noted. Coal Authority mineral safeguarding development Following considerations of representations and consideration of new management policy along the lines of Option BGS guidance on mineral safeguarding published in 2011 the Council 2. This option includes a commitment to has decided to modify its approach a revised development management seeking the prior extraction of minerals where policy is proposed based upon the BGS Guide Mineral Safeguarding in possible which is a requirement of MPS1 and England: Good Practice Advice, (2011). Preferred Options policy 58 sets MPG3. However The Coal Authority do not out our approach to safeguarding minerals resources. MSAs are set out support the use of a 5Ha threshold for in Appendix Q with detailed boundaries shown on the Local Plan determining whether prior extraction in the Proposals Map. surface coal MSA needs to be assessed, there are numerous examples of prior The Coal Authority's objection to the use of 5ha threshold is noted. In extraction having been carried out this respect we note that the Coal Authority evidence identifies 48 successfully, even within urban area and examples of prior extraction of coal in existing urban areas from 1995 to conurbations, on sites much smaller than 5Ha 2008. However only three of these sites were in County Durham. We in size. The approach is therefore likely to lead consider that these figures reinforce our view that such prior extraction to the unnecessary sterilisation of surface coal of coal is a rare occurrence, but nevertheless do consider that prior mineral resources contrary to MPS1. The Coal extraction of coal should be considered when regeneration and Authority accepts that there needs to be redevelopment occur. We understand that other authorities in the region guidelines for development which not be including South Tyneside and Gateshead and Newcastle are proposing viewed as sterilising development within a a 1h a exemption and that the Coal Authority is in agreement with this MSA. The ability to successfully implement threshold. We are therefore intending to revise the 5ha exemption MSA policy is important, and excluding threshold and reduce it to 1ha. householder development, change of use of existing buildings and advertisements as examples seem wholly proportionate. The Coal Authority does not however support the concept of removing all development within

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Respondent Question 5 - We would welcome your views Council response on the draft development management policy approach. Do you agree with the proposed approach, if not why not? urban areas under 5Ha in extent. Whilst The Coal Authority is supportive of the overall approach in general, we must object to one specific aspect of the implementation of the Policy. The Coal Authority is pleased to note that the Council are seeking to encourage prior extraction of mineral resources to avoid their permanent sterilisation by non-mineral development proposals within MSAs, in line with MPS1. However, the selection of a 5ha threshold for non-mineral development proposals within urban areas appears to be arbitrary and is not evidence-led. The key factor counting against the inclusion of one generic site size threshold for consideration of prior extraction in urban areas is that the range of minerals listed for safeguarding are all very different. A "one size fits all" blanket approach cannot simply be applied, due to the differing nature of mineral resources, the key differences in the manner with which they are extracted, and also the varying circumstances of their economic viability at a small scale of extraction. The Coal Authority therefore seeks removal of this threshold, to be replaced by a requirement for developers to prove to the Local Planning Authority as part of the planning application that prior extraction is not viable on smaller urban sites.

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Respondent Question 5 - We would welcome your views Council response on the draft development management policy approach. Do you agree with the proposed approach, if not why not? As a matter of policy The Coal Authority is seeking the inclusion of a requirement for prior extraction in relation to all development proposals in the areas of surface coal resource without the use of thresholds or other sifting criteria. However, The Coal Authority recognises the practical difficulties the Local Planning Authority has to resolve in making this requirement feasible in the development management process. The Coal Authority have numerous examples of prior extraction of coal during regeneration schemes in the urban areas. The smallest of these examples in the heavily urbanised Black Country as an example was only 0.3ha in size, yet was deemed economically viable, and The Coal Authority has many other examples of viable prior extraction of surface coal resources on redevelopment sites in urban areas of less than 5ha. The prior extraction of any remnant surface coal resources as part of redevelopment or regeneration proposals in urban areas can be the most economically viable method of removing any potential land instability problems caused by past mining activity at shallow depth. To apply an arbitrary threshold for consideration of prior extraction in urban areas without appropriate evidence in the Core Strategy is unnecessary and runs contrary to minerals safeguarding guidance set out in MPS1 and the BGS Guide to Mineral Safeguarding.

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Respondent Question 5 - We would welcome your views Council response on the draft development management policy approach. Do you agree with the proposed approach, if not why not? Mr Lee Weatherall It is considered that the proposed approach Support noted. Having considered objections to the proposed 5ha ATH Resources to a Development Management Policy is exemption the Council intends to revise its approach,see response to acceptable in principle. However the use of Coal Authority. Preferred Options policy 58 sets out our approach to 5ha in the fourth bullet point of Policy Option safeguarding minerals resources. MSAs are set out in Appendix Q with 2 is considered to be too high as smaller detailed boundaries shown on the Local Plan Proposals Map. schemes could also be viable depending on the circumstances involved. The Coal Authority's response to the Issues and options report, which is acknowledged as being relevant elsewhere in this document, refers to sites as small as 2ha. Mr C Ball UK Coal considers that the model policy set Comment noted. Following considerations of representations and UK Coal Mining Ltd out by the British Geological Survey provides consideration of new BGS guidance on mineral safeguarding published a reasonable basis for protecting MSAs, and in 2011 the Council has decided to modify its approach a revised would be content for this policy to be adopted. development management policy is proposed based upon the BGS Guide Mineral Safeguarding in England: Good Practice Advice, (2011). Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr M Charis The BGS guidance was formulated in Comment noted. Following considerations of representations and Mineral Planning discussion with all major stakeholders and consideration of new BGS guidance on mineral safeguarding published Association agreed by the industry as a model approach. in 2011 the Council has decided to modify its approach a revised We would need to be given very good reasons development management policy is proposed based upon the BGS Guide for departing from it. We see three problems Mineral Safeguarding in England: Good Practice Advice, (2011). Preferred with your proposed approach. First, you Options policy 58 sets out our approach to safeguarding minerals specify that it needs to be determined whether resources. MSAs are set out in Appendix Q with detailed boundaries it is likely for mineral to be extracted in the shown on the Local Plan Proposals Map. foreseeable future. With respect, that is not the objective of safeguarding mineral which is for the long term and future generations. If

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Second, you specify that prior extraction should not impose abnormal costs and delays in development. It will be easy for a developer to circumvent the safeguarding intention using these words because he can leave a development until the last minute and claim that he faces abnormal costs in getting the mineral out and preparing the land for development.

Our comments above on the advisability of flagging up mineral interests in LDPs should apply here. Third, your assumption that only coal needs to be subject to the requirement for prior extraction is flawed and we will object if this approach is continued. Moreover, you should be aware that South Tyneside Council has recently offered to amend its safeguarding criteria to reduce the exempt area from 5ha to 1ha following objections to its LDD.

Mr Michael Hodges Just looking at the report on 'Safeguarding It would not be practical for the Council to consult all mineral operators Sherburn Stone Co Ltd Mineral Resources'. Regarding Question 5 on all planning applications lodged for development within a Mineral will the minerals industry be consulted when Safeguarding Area. The Council will notify mineral operators and seek there is an application lodged for non-minerals views only on planning applications near to existing mineral sites and development in an MSA i.e. will we get an allocated strategic and non-strategic mineral sites. Preferred Options opportunity to comment on the applicant's policy 58 sets out our approach to safeguarding minerals resources.

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Respondent Question 5 - We would welcome your views Council response on the draft development management policy approach. Do you agree with the proposed approach, if not why not? assessment undertaken to comply with Option MSAs are set out in Appendix Q with detailed boundaries shown on the 2 - Potential Minerals Safeguarding Local Plan Proposals Map. Development Management Policy? Mr Anthony Northcote The Peak District National Park Authority Support noted. Fluorspar will be safeguarded. Preferred Options policy Peak District National Park welcome and support the approach towards 58 sets out our approach to safeguarding minerals resources. MSAs are Authority safeguarding the Fluorspar mineral resource set out in Appendix Q with detailed boundaries shown on the Local Plan within County Durham which recognises the Proposals Map. importance and scarcity of this resource.

Question 6 - Guidelines for development which would not be viewed as sterilising development within a MSA

Do you agree or disagree with our guidelines for development which would not be viewed as sterilising development within a Mineral Safeguarding Area?

Respondent Question 6 - Do you agree or disagree with our guidelines for Council Response development which would not be viewed as sterilising development within a Mineral Safeguarding Area? Mr Bryan Huntley Agree with the Guidelines for development which would not be viewed Support for guidelines noted. Agree guideline Darlington Borough Council as sterilising development within a MSA. However, suggest that guideline 8 is inappropriate as it is not a guideline. 8 is inappropriate because it is not a guideline. It is a separate policy, Guideline 8 will be incorporated within the or should be part of a separate policy, addressing proposed development development management policy or reasoned which does not fall within the guidelines. justification. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

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Respondent Question 6 - Do you agree or disagree with our guidelines for Council Response development which would not be viewed as sterilising development within a Mineral Safeguarding Area?

Mr David Brewer CoalPro agrees with the Guidelines in general terms provided it is Support for guidelines noted. In relation to Confederation of UK Coal recognised that even for quite small developments, extraction of some small developments and coal, following the Producers (COALPRO) incidental coal may be appropriate, or even essential, for ground stability consideration of comments made by others reasons. including the Coal Authority we now propose that surface coal mineral safeguarding areas will underlie urban areas. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr Lee Weatherall It is considered that the proposed approach to a Development Following considerations of representations ATH Resources Management Policy is acceptable in principle. However the use of 5ha and consideration of new BGS guidance on in the fourth bullet point of Policy Option 2 is considered to be too high mineral safeguarding published in 2011 the as smaller schemes could also be viable depending on the circumstances Council has decided to modify its approach involved. The Coal Authority's response to the Issues and options report, a revised development management policy which is acknowledged as being relevant elsewhere in this document, is proposed based upon the BGS Guide refers to sites as small as 2ha. Mineral Safeguarding in England: Good Practice Advice, (2011). Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

The objection to the use of 5ha threshold is noted. In this respect we note that the Coal Authority evidence identifies 48 examples of

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Respondent Question 6 - Do you agree or disagree with our guidelines for Council Response development which would not be viewed as sterilising development within a Mineral Safeguarding Area? prior extraction of coal in existing urban areas from 1995 to 2008. However only three of these sites were in County Durham. We consider that these figures reinforce our view that such prior extraction of coal is a rare occurrence, but nevertheless do consider that prior extraction of coal should be considered when regeneration and redevelopment occur. We understand that other authorities in the region including South Tyneside and Gateshead and Newcastle are proposing a 1h a exemption and that the Coal Authority is in agreement with this threshold. We are therefore intending to revise the 5ha exemption threshold and reduce it to 1ha.

Miss Rachael Bust The Coal Authority would prefer a detailed mineral safeguarding Following considerations of representations Coal Authority development management policy along the lines of Option 2. This option and consideration of new BGS guidance on includes a commitment to seeking the prior extraction of minerals where mineral safeguarding published in 2011 the possible which is a requirement of MPS1 and MPG3. However The Coal Council has decided to modify its approach Authority do not support the use of a 5Ha threshold for determining a revised development management policy whether prior extraction in the surface coal MSA needs to be assessed, is proposed based upon the BGS Guide there are numerous examples of prior extraction having been carried Mineral Safeguarding in England: Good out successfully, even within urban area and conurbations, on sites Practice Advice, (2011). Preferred Options much smaller than 5Ha in size. The approach is therefore likely to lead policy 58 sets out our approach to to the unnecessary sterilisation of surface coal mineral resources contrary safeguarding minerals resources. MSAs are to MPS1. The Coal Authority accepts that there needs to be guidelines set out in Appendix Q with detailed for development which not be viewed as sterilising development within boundaries shown on the Local Plan a MSA. The ability to successfully implement MSA policy is important, Proposals Map. and excluding householder development, change of use of existing buildings and advertisements as examples seem wholly proportionate. The Coal Authority's objection to the use of The Coal Authority does not however support the concept of removing 5ha threshold is noted. In this respect we note that the Coal Authority evidence

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Respondent Question 6 - Do you agree or disagree with our guidelines for Council Response development which would not be viewed as sterilising development within a Mineral Safeguarding Area? all development within urban areas under 5Ha in extent. Whilst The Coal identifies 48 examples of prior extraction of Authority is supportive of the overall approach in general, we must object coal in existing urban areas from 1995 to to one specific aspect of the implementation of the Policy. The Coal 2008. However only three of these sites were Authority is pleased to note that the Council are seeking to encourage in County Durham. We consider that these prior extraction of mineral resources to avoid their permanent sterilisation figures reinforce our view that such prior by non-mineral development proposals within MSAs, in line with MPS1. extraction of coal is a rare occurrence, but However, the selection of a 5ha threshold for non-mineral development nevertheless do consider that prior extraction proposals within urban areas appears to be arbitrary and is not of coal should be considered when evidence-led. The key factor counting against the inclusion of one generic regeneration and redevelopment occur. We site size threshold for consideration of prior extraction in urban areas is understand that other authorities in the region that the range of minerals listed for safeguarding are all very different. including South Tyneside and Gateshead and A "one size fits all" blanket approach cannot simply be applied, due to Newcastle are proposing a 1h a exemption the differing nature of mineral resources, the key differences in the and that the Coal Authority is in agreement manner with which they are extracted, and also the varying with this threshold. We are therefore circumstances of their economic viability at a small scale of extraction. intending to revise the 5ha exemption The Coal Authority therefore seeks removal of this threshold, to be threshold and reduce it to 1ha. replaced by a requirement for developers to prove to the Local Planning Authority as part of the planning application that prior extraction is not viable on smaller urban sites. As a matter of policy The Coal Authority is seeking the inclusion of a requirement for prior extraction in relation to all development proposals in the areas of surface coal resource without the use of thresholds or other sifting criteria. However, The Coal Authority recognises the practical difficulties the Local Planning Authority has to resolve in making this requirement feasible in the development management process. The Coal Authority have numerous examples of prior extraction of coal during regeneration schemes in the urban areas. The smallest of these examples in the heavily urbanised Black Country as an example was only 0.3ha in size, yet was deemed economically viable, and The Coal Authority has many other examples of viable prior extraction of surface coal resources on redevelopment sites in urban areas of less than 5ha. The prior extraction of any remnant surface coal resources as part of redevelopment or regeneration proposals in urban areas can be the most economically viable method of removing any

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Respondent Question 6 - Do you agree or disagree with our guidelines for Council Response development which would not be viewed as sterilising development within a Mineral Safeguarding Area? potential land instability problems caused by past mining activity at shallow depth. To apply an arbitrary threshold for consideration of prior extraction in urban areas without appropriate evidence in the Core Strategy is unnecessary and runs contrary to minerals safeguarding guidance set out in MPS1 and the BGS Guide to Mineral Safeguarding. Mr M Charis The BGS guidance was formulated in discussion with all major Following considerations of representations Mineral Planning Association stakeholders and agreed by the industry as a model approach. We would and consideration of new BGS guidance on need to be given very good reasons for departing from it. We see three mineral safeguarding published in 2011 the problems with your proposed approach. First, you specify that it needs Council has decided to modify its approach to be determined whether it is likely for mineral to be extracted in the a revised development management policy foreseeable future. With respect, that is not the objective of safeguarding is proposed based upon the BGS Guide mineral which is for the long term and future generations. If it adjudged Mineral Safeguarding in England: Good to be economically important now and therefore safeguarded as a Practice Advice, (2011). Preferred Options resource, it should be protected. policy 58 sets out our approach to safeguarding minerals resources. MSAs are Second, you specify that prior extraction should not impose abnormal set out in Appendix Q with detailed costs and delays in development. It will be easy for a developer to boundaries shown on the Local Plan circumvent the safeguarding intention using these words because he Proposals Map. can leave a development until the last minute and claim that he faces abnormal costs in getting the mineral out and preparing the land for The Coal Authority's objection to the use of development. 5ha threshold is noted. In this respect we note that the Coal Authority evidence Our comments above on the advisability of flagging up mineral interests identifies 48 examples of prior extraction of in LDPs should apply here. Third, your assumption that only coal needs coal in existing urban areas from 1995 to to be subject to the requirement for prior extraction is flawed and we will 2008. However only three of these sites were object if this approach is continued. Moreover, you should be aware that in County Durham. We consider that these South Tyneside Council has recently offered to amend its safeguarding figures reinforce our view that such prior criteria to reduce the exempt area from 5ha to 1ha following objections extraction of coal is a rare occurrence, but to its LDD. nevertheless do consider that prior extraction of coal should be considered when regeneration and redevelopment occur. We understand that other authorities in the region

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Respondent Question 6 - Do you agree or disagree with our guidelines for Council Response development which would not be viewed as sterilising development within a Mineral Safeguarding Area? including South Tyneside and Gateshead and Newcastle are proposing a 1h a exemption and that the Coal Authority is in agreement with this threshold. We are therefore intending to revise the 5ha exemption threshold and reduce it to 1ha.

Mr David Atkinson Lafarge support the proposed approach (i.e. Option 2) to the draft Support for option 2 and the draft guidelines Lafarge Aggregates Ltd Development Management Policy and agree with the guidelines for noted. Preferred Options policy 58 sets out development which would not be viewed as sterilising development our approach to safeguarding minerals within an MSA. resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr C Ball With regard to the proposed guidelines for development which would The proposed criteria 'Change of Use of UK Coal Mining Ltd not be viewed as sterilising development within an MSA, UK Coal feels Existing Buildings' is in line with the existing that Criteria 3 (" Change of Use of Existing Buildings ") should recognise approach of the County Durham Minerals that the change of use of some buildings (ie Barn Conversions) has the Local Plan which was adopted in December potential to create sensitive receptors that could potentially sterilise 2000 (Appendix 2, para A2.2.). No evidence development within MSAs, and considers that the wording of this criteria has been submitted to the Council to should be altered to reflect this. Other than this the criteria are considered demonstrate that the existing approach of the to be comprehensive and suitable. Council has led to any significant issues of mineral sterilisation since December 2000. The approach that the County Durham Plan takes to change of use of existing rural buildings is set out in policy 36 'Development in the Countryside' of Preferred Options and

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Respondent Question 6 - Do you agree or disagree with our guidelines for Council Response development which would not be viewed as sterilising development within a Mineral Safeguarding Area? takes into account the Government's new National Planning Policy Framework. Preferred Options policy 58 sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. G Gibson The guidelines seem well founded. Support noted. Preferred Options policy 58 CPRE sets out our approach to safeguarding minerals resources. MSAs are set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

Question 7 - Potential development management policy for safeguarding mineral related infrastructure

Potential development management policy for safeguarding mineral related infrastructure. We would welcome comments on this proposed policy.

Respondent Question 7 - Potential development Council Response management policy for safeguarding mineral related infrastructure Mr Bryan Huntley Agree with the Potential Safeguarding Mineral Support noted. Preferred Options policy 52 'Safeguarding minerals Darlington Borough Council Related Infrastructure Development Management related infrastructure and waste management sites' sets out our policy. approach to safeguarding minerals related infrastructure. Infrastructure safeguarded is set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr David Brewer CoalPro supports the proposed policy. Support noted. Preferred Options policy 52 'Safeguarding minerals related infrastructure and waste management sites' sets out our

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Respondent Question 7 - Potential development Council Response management policy for safeguarding mineral related infrastructure Confederation of UK Coal approach to safeguarding minerals related infrastructure. Producers (COALPRO) Infrastructure safeguarded is set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr Lee Weatherall ATH Resources support this suggested policy. Support noted. Preferred Options policy 52 'Safeguarding minerals ATH Resources related infrastructure and waste management sites' sets out our approach to safeguarding minerals related infrastructure. Infrastructure safeguarded is set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Miss Rachael Bust The Coal Authority supports the approach Support noted. Preferred Options policy 52 'Safeguarding minerals Coal Authority towards safeguarding mineral related related infrastructure and waste management sites' sets out our infrastructure. approach to safeguarding minerals related infrastructure. Infrastructure safeguarded is set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr M Charis We strongly support this policy and wish you to Support noted. Paragraph 3.12 of the consultation paper identified Mineral Planning Association go further by safeguarding potential infrastructure the Council's intention to safeguard mineral transportation such a rail sidings/lines and wharf sites. It should infrastructure i.e. Road to rail loading facilities and rail alignments be possible to identify such potential sites bearing (but only permanent facilities, footnote 7 stated "Where temporary in mind their limited occurrence. facilities have been given time limited planning permission they will not be safeguarded). Where suitable 'permanent' potential infrastructure is identified by the industry we will consider its safeguarding. In relation to wharfage paragraphs 2.48 to 2.51 of the consultation paper addressed the Port of Seaham. Preferred Options policy 52 'Safeguarding minerals related infrastructure and waste management sites' sets out our approach to safeguarding minerals related infrastructure. Infrastructure safeguarded is set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr David Atkinson Lafarge support the proposed policy to safeguard Support noted. Preferred Options policy 52 'Safeguarding minerals Lafarge Aggregates Ltd key mineral related infrastructure. related infrastructure and waste management sites' sets out our approach to safeguarding minerals related infrastructure.

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Respondent Question 7 - Potential development Council Response management policy for safeguarding mineral related infrastructure Infrastructure safeguarded is set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Mr C Ball UK Coal would be content for this safeguarding Support noted. Preferred Options policy 52 'Safeguarding minerals UK Coal Mining Ltd policy for protecting mineral related infrastructure related infrastructure and waste management sites' sets out our to be adopted. approach to safeguarding minerals related infrastructure. Infrastructure safeguarded is set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map. Ms G Gibson In the first paragraph non-minerals development Preferred Options policy 52 'Safeguarding minerals related CPRE will not be granted unless it can be demonstrated infrastructure and waste management sites' sets out our approach it no longer meets the industry needs. However, to safeguarding minerals related infrastructure. Infrastructure this is speaking of the present. We consider the safeguarded is set out in Appendix Q with detailed boundaries future should also be taken into account, despite shown on the Local Plan Proposals Map. being difficult to do so. Once lost it can be very difficult to recreate mineral related infrastructure. The difficulty of forecasting the future can perhaps be demonstrated by the current debate within the local geological community in which there are those who consider fluorspar will never be economic again, and others who see it only a matter of time before it will be rare enough worldwide for the North Pennines to become important again. The Council does need to consider its minerals policy on a timescale far longer than the period of "The County Durham Plan". Robin Beveridge As you are aware One North East has previously Support noted. Preferred Options policy 52 'Safeguarding minerals One North East responded in its statutory role to the Durham related infrastructure and waste management sites' sets out our Core Strategy Issues and Options Paper. The approach to safeguarding minerals related infrastructure. response made specific reference to our support Infrastructure safeguarded is set out in Appendix Q with detailed for the re-opening of the Leamside Line for boundaries shown on the Local Plan Proposals Map. passenger and freight services. The Line has

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Respondent Question 7 - Potential development Council Response management policy for safeguarding mineral related infrastructure significant potential for the provision of a freight service providing an important alternative to road based freight transport for businesses in the area. In this context, the Agency welcomes the Council's approach to ensuring the line and other infrastructure is safeguarded in order to help promote the sustainable movement of mineral by rail. Mr Michael Hodges In view of our comments re agricultural lime we The possibility of safeguarding Seaham Docks is addressed by Sherburn Stone Co Ltd would like to see Seaham docks safeguarded. paragraph 2.48 to 2.51 of the Technical Consultation Paper "Safeguarding Mineral Resources for the Future". Paragraph 2.49 stated "Six respondents replied to this question. Coal Pro indicated that while Coal has been shipped from Seaham Harbour in the past, future shipments from Seaham Harbour are extremely unlikely and there are probably better options. Similarly, Banks Developments indicated that it is unlikely that they would be interested in shipping any coal from the Port of Seaham. The Mineral Products Association however argued that while the Port of Seaham is not currently used for the bulk transport of minerals it may be needed in the future and should be safeguarded. The Council has also written to the operator of the Port of Seaham, the Seaham Harbour Dock Company and has not received any response." Paragraph 2.50 stated, "Having considered the views of the respondents it is clear that while some minerals have been transported from Seaham Harbour in the past, it is not currently being used for this purpose. While potentially, the Port could be used in the future, we are aware that their are other Ports and wharfage in the North East which are currently been used on a more regular basis for the transhipment of minerals. In particular marine dredged sand is imported into the region at sites in the Tees Valley (Cochranes Wharf in Middlesbrough, Able Wharf in Billingham) and the Tyne and Wear (Howdon Wharf in North Shields, Gateshead Wharf and Jarrow Wharf). In addition we

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Respondent Question 7 - Potential development Council Response management policy for safeguarding mineral related infrastructure are also believe that both Byth and Hartlepool are also/have been used in the past." Paragraph 2.51 stated, "While we could seek to safeguard the Port of Seaham, we do not wish to impose a safeguarding designation unless it is necessary and we do not have the information to make this determination. Our view is that we should not safeguard the Port of Seaham unless it is clear that the Port of Seaham is or has the potential to transport significant volumes of minerals in the future, and that a safeguarding designation is necessary to protect the Port. However, we do propose to safeguard the railhead at Seaham Harbour (see paragraph 2.47)." Preferred Options policy 52 'Safeguarding minerals related infrastructure and waste management sites' sets out our approach to safeguarding minerals related infrastructure. Infrastructure safeguarded is set out in Appendix Q with detailed boundaries shown on the Local Plan Proposals Map.

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E Responses to Technical Consultation Report 'Towards a Waste Delivery Strategy'

Question 1 - Approach to assessing existing and future capacity

Do you have any comments to make on the approach that we have taken to assessing existing and future capacity for: A. Municipal Solid Waste B. Commercial and Industrial Waste C. Construction and Demolition Waste D. Hazardous Waste E. Agricultural Waste F. Low level radioactive waste

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Respondent Question 1 - Do you have any comments to make on the approach that Council Response we have taken to assessing existing and future capacity for: A. Municipal Solid Waste B. Commercial and Industrial Waste C. Construction and Demolition Waste D. Hazardous Waste E. Agricultural Waste F. Low level radioactive waste apparel? By the completion of the E.P.A., which of course I completely The Preferred Options sets out the Council's understand is mandatory by virtue of the Equality Act 2010, will the Waste approach to climate change and the mitigation of Plan developed by the Council be proven not to discriminate against anyone its effects, in line with Government guidance, because all the Waste is mixed up together, and therefore no-one who could legislation and the National Planning Policy possibly state that discrimination existed have their complaint proven, and thus Framework. Planning has a vital role to play in lose out on compensation claimed? Would the County Council give, or in fact reducing greenhouse gas emissions and delivering be able to ascertain the cost of producing the Equality Impact Assessment, sustainable development. The Preferred Options so as to further discover if the application of this piece of legislation is really contains policies on Sustainable Development; in the best interests of the Council taxpayers, who are after all footing the bill Sustainable Design in the Built Environment; Flood for both the Plan, as well as the Equality Impact Assessment? As for the Plan Risk; Renewable Energy Development; Green itself, I have considered the whole scheme, and wish to comment only upon Infrastructure; and Wind Turbine Development. It Clause 2.1 of the Executive Summary, and especially the words which embrace also contains an 'Energy Hierarchy' showing how the whole concept of 'Climate Change' As I, along with many others whose we should reduce the need for energy in the first numbers increase daily, believe that the whole idea and 'science' of Climate instance. Change by virtue of Anthropogenic Global Warming has been categorically refuted, we as both citizens and taxpayers, should remove ourselves from any notion that, by virtue of endless 'recycling' and 'carbon footprint reduction' and all the other buzz-words so beloved of the Climate Change Brigade, we will be having any impact whatsoever upon the fact that the Earth's Climate is getting warmer. Apart from that proviso, the rest of the Plan seems perfectly acceptable to myself, as a man who has worked within the Water and Sewage Industries for some years. Mr Christopher The members of the County Durham Furniture Help Scheme want to be Comments noted. The County Council agrees that Palmer involved in the County Durham Plan, especially the ˜Towards a Waste Delivery as part of the Waste Hierarchy, re-use should be County Durham Strategy for County Durham'. The main policy of the County Durham Furniture provided for before any final disposal is considered. Furniture Help Scheme

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Respondent Question 1 - Do you have any comments to make on the approach that Council Response we have taken to assessing existing and future capacity for: A. Municipal Solid Waste B. Commercial and Industrial Waste C. Construction and Demolition Waste D. Hazardous Waste E. Agricultural Waste F. Low level radioactive waste Mr A Hunter 1. Introduction No comments. 2. Executive Summary key messages Support and comments noted. We have outlined English Heritage Paragraphs 2.4-2.5 indicate that new strategic and non-strategic waste facilities the location of existing waste facilities within the will be focused on the 12 larger towns. I note that for the purposes of this County on map 3 (page 34) and have also produced approach, Durham City is classed as a 'main town'. Paragraph 2.6 further maps of sites within each of the 5 different Delivery advises that waste management facilities will be based on the five new Delivery Areas. Areas identified in the latest Core Strategy consultation document. 3. Planning for Waste Management in County Durham Paragraph 3.2 advises that the Strategy needs to be consistent with others and, importantly, with the county's Sustainable Community Strategy. English Heritage welcomes this, as the Conservation policies join up with waste policies Vision for the future of County Durham found within it contains an explicit and we note the re-use of existing buildings can commitment to safeguarding and respecting the historic environment. indeed lead to a reduction in waste. Paragraph 3.6 refers to the wider policy framework for dealing with waste. English Heritage supports the waste hierarchy and the emphasis on waste minimisation, as it upholds the prudent use of existing built fabric in other words, seeking to make best use of existing buildings before conceding that The Preferred Options approach - and specifically demolition and rebuilding is the only feasible/practicable solution. (I have made policy 61 'Waste Management Provision' - uses the this point, now reflected in PPS5: Planning for the Historic Environment in Waste Hierarchy to provide waste management earlier consultation responses and at greater length.) It is worth noting that capacity through a criteria based approach. the Department for Communities and Local Government (DCLG), in issuing its definition of Sustainable Development for the purposes of drafting the National Planning Policy Framework and delivering the Localism agenda affirms our view by stating that ˜planning should help to deliver the prudent use of natural resources, thereby minimising the creation of waste. Paragraph 3.13 - I note that construction and demolition waste constitutes by far the largest of the various waste streams, and is consequently one where a shift in approach could produce significant reductions in arisings having to be transported to landfill. Paragraph 3.17 advises that there are 22 waste transfer stations throughout the county and paragraph 3.18 advises that there are 8 permitted

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Respondent Question 1 - Do you have any comments to make on the approach that Council Response we have taken to assessing existing and future capacity for: A. Municipal Solid Waste B. Commercial and Industrial Waste C. Construction and Demolition Waste D. Hazardous Waste E. Agricultural Waste F. Low level radioactive waste landfill sites in the County. It would be helpful to have a plan showing their distribution. Paragraph 3.8 - encouraging economic and social regeneration through the repair, conversion and extension of existing (often historic) properties is one way of helping to sever the link between economic growth and waste arisings. 4. How much waste needs to be managed to 2030 Paragraph 4.1 “ Sustainability Appraisal providing for management of future waste arisings". English Heritage supports Option A. This is the best way of reducing 'waste miles' and the environmental consequences of transporting waste through towns, villages and neighbourhoods where heritage assets may be susceptible to harm and where alternatives to road transport are limited. It would also help the community to better appreciate the direct linkage between its actions and the consequences. Paragraph 4.13 “ Sustainability Appraisal - Landfill Capacity ". English Heritage supports Option D. However, the extent to which additional capacity is needed could more helpfully be shown graphically. If the (intended) annual decrease in demand for landfill tracks closely the rate at which capacity reduces there may only be a need for limited ongoing capacity to handle future waste arisings. Sarah Jennings The following comments within this section relate to the technical content the Comments noted. Environment above paper. No comments have been included on issues of style, spelling or Agency grammar unless they lead to significant ambiguity. As the paper contains a Page 8 Para 3.5: Updates of the Waste Technical great deal of data we have not checked each item for accuracy but we have Paper will refer to the landfilling of biodegradable made observations when figures appear to be incorrect. Page 8 Para 3.5 It is waste as an emitter of methane. true that landfill is a major emitter of methane but the text does not acknowledge that it is the presence of biodegradable wastes that is responsible for methane Page 10 Para 3.13 Bullet 2: Updates of the Waste emissions. National strategy is to find alternatives to landfill and there are Technical Paper will contain notes on definitions indications that the government may consult on legislation to prevent the landfill of waste categories which address this point. of biodegradable waste. Page 10 Para 3.13 Bullet 2 This is factually correct

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Respondent Question 1 - Do you have any comments to make on the approach that Council Response we have taken to assessing existing and future capacity for: A. Municipal Solid Waste B. Commercial and Industrial Waste C. Construction and Demolition Waste D. Hazardous Waste E. Agricultural Waste F. Low level radioactive waste but could leave a lay-person confused as to how inert waste from industrial Page 10 Para 3.13: The figure quoted is from trends manufacturing processes would be categorised. Perhaps an additional clause data from EA website(a) could be included to explicitly acknowledge that inert manufacturing waste is also categorised as C&I. Page 10 Para 3.13 It is not clear from the text from Page 11 Para 3.18: Comment noted. 'Permit' and which sectors the hazardous waste arises and whether the tonnages of 'permitted' have been used in the Preferred Options. hazardous waste quoted in bullet point 4 are in addition to those quoted as Municipal, C&D, C&I, etc or whether they are a sub-set of the aggregated Regarding the significance of site types: It was felt tonnages of the first three bullet points (plus Agricultural and Mineral arisings). that the level of detail was suitable for the lay Page 11 Para 3.18 The first sentence uses the correct term 'permit' but reader, as including more detail may have added subsequent references use 'licence' which is an outdated term. 'Permit' and to the confusion or been unnecessary. It is unclear 'Permitted' should be used throughout. In addition, although factually correct, from your comment whether this refers to the the significance of the site types could be explained more fully as the lay reader landfill section only, or whether this is a general may not find it easy to understand from the text, as written, precisely what comment on site types. It was felt that the important wastes the permitted sites in Durham could accept. The description and, information (which sites can accept Municipal Solid therefore, significance of the four unaccounted for sites is left unexplained. Waste) was included in the section, but we will Page 12 Para 4.2 The authors are correct to promote self-sufficiency for waste consider the need to expand upon the text to management in the plan, whilst recognising that the actual pattern of waste distinguish what types of waste sites can accept treatment facilities provided by the private sector during the plans period will when producing future evidence base documents. primarily be dictated by economic drivers. These will include waste arisings and the availability of facilities in adjacent planning areas. Page 13 Item xiii Page 13 Item xiii 'Inert is assumed to be 100% 'Inert is assumed to be 100% recycled'. There is no basis given for that recycled': Whilst we accept that inert landfilling still assumption although it may well be accurate. About 50% of the waste landfilled occurs, for the purposes of capacity gap in the North East is C&D; are the authors satisfied that very little of this is from calculations it was considered appropriate to Transfer & Treatment Facilities? Page 16 Landfill and Residual Waste For consider that from transfer and treatment facilities clarity it is probably worth making clear in the header or subsequent text that all inert waste is recycled. This is discussed in this section is still considering only the municipal fraction of the total waste depth in the Waste Technical Paper. As stated in stream. Page 16 'Option D' It is not clear in the above text and following the Technical Paper, ad-hoc activity means that discussion whether the proposal is for the Council to purchase additional landfill whilst we know of activity that takes place on

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Respondent Question 1 - Do you have any comments to make on the approach that Council Response we have taken to assessing existing and future capacity for: A. Municipal Solid Waste B. Commercial and Industrial Waste C. Construction and Demolition Waste D. Hazardous Waste E. Agricultural Waste F. Low level radioactive waste capacity to add to its holdings at Joint Stocks or whether it is merely licensed sites, no reliable information is available acknowledging that will have to approve some subsequent planning applications on how much takes place on development sites. from private sector landfill operators. Page 17 Para 4.13 This sentence implies This assumption also ties in with targets to reduce that 100% of the waste must be recycled or recovered. The distinction between landfilling of inert waste and other drivers the recovery and the recycling percentages and the significance for the County's increasing recycling and diversion from landfill Waste Plan is not made explicit. Page 20 Capacity Gap: This meaning of this such as Site Waste Management Plans and the sentence is unclear. Page 21 Para 2 In the context of a planning document, Aggregates Levy. it is reasonable to compare the estimated landfill capacity with the estimated residual waste for disposal, as above. There is no discussion, however, of Page 16 Landfill and Residual Waste: Comments plans and policies to explore further reductions in the residual wastes tonnages noted. or to find alternatives to landfill, such as energy from waste. Page 26 Low Level Radioactive Waste To avoid confusion we recommend that the text Page 16 'Option D': The option merely gives a distinguishes between nuclear and non-nuclear sources. There are no nuclear choice which is to be consulted upon. The Strategy sites in Durham and no facilities for disposing of or treating radioactive waste. at this stage acknowledges that even with the policy We do not recognise the statement that, 'radioactive waste and controlled direction towards re-use, recycling and recovery waste are often mixed for disposal', unless it is a reference to the co-disposal and continued financial drivers, it will still be the of LLRW and potentially contaminated cleaning materials at the Drigg Site; in case that landfill capacity will need to be provided which case its inclusion here is misleading. Page 26 Para 4.39 (LLRW) We for some waste types which are not recyclable. As would be happy to discuss the information on LLRW available from our records discussed in the paper, the recommendation for to assist you in formulating your plan. No radioactive waste of any origin is this option is dependent on the outcome of the imported into Durham for treatment or disposal. Information on the specific procurement process for the management of the releases is held in the Durham Council public register and by the Environment County's MSW. Therefore it cannot be stated at this Agency. Information on the location of sealed sources for industrial, research stage (nor is it the intention to say) whether DCC and medical use is restricted on security grounds but aggregated information will procure landfill capacity from elsewhere. could be provided if required. Note, however, that these sources are returned to their suppliers for disposal rather than through the local waste sector. Page Page 17 Para 4.13: Comments acknowledged. 27 Para 4.41 It is unclear from the text whether the county is claiming that low

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Page 27 Question 1: Support noted.

The capacity gap is set out in the Preferred Options.

Ms G Gibson We consider the document to be a thorough analysis which will be a sound Comments and support noted. Transport impacts CPRE basis for future policy. Our only additional comment would be to emphasise and implications will be considered in the the importance of considering transport implications whenever applications assessment of any sites for allocation in the Plan, involving waste facilities are considered. We trust the above will be considered then at the time that these sites come forward at the appropriate time. through the planning process and will also be considered in the formulation of Development Management policies. The Preferred Options

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a. http://www.environment-agency.gov.uk/research/library/data/123744.aspx#North_East

Question 2 - Key Locational Principles

Do you have any comments on the key locational principles or any other matter in this section?

Respondent Question 2 - Do you have any comments on the key locational principles or any Council Response other matter in this section? Ms Wendy Hetherington Planning for waste management is recognised by One North East to offer significant Comments and support noted. One NorthEast challenges. As stated in the document, radical changes are required in outlook and CHP and district heating behaviour on the part of waste producers and waste managers. Furthermore, the link schemes are discussed in the between economic growth and the growth in waste must be broken, by pursuing a strategy document 'Towards a Strategy which foremost targets waste elimination and reduction. Overall, One North East is for Low Carbon Energy in encouraged to see that Durham County Council is developing a long term strategy in a County Durham'. We manner which incorporates flexibility in respect of developing and emerging technologies. acknowledge that there is

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Respondent Question 2 - Do you have any comments on the key locational principles or any Council Response other matter in this section? The Agency also welcomes Durham's intention to take a 'self-sufficient' approach, taking significant opportunity for into account sustainability and job creation benefits that will arise. This could potentially biomass CHP to contribute to be enhanced by fully recognising waste as a resource and therefore taking greater account renewable heat and electricity of its monetary and social value. The document states that there may be occasions where targets, viability permitting. it is more beneficial to export some of the waste to a neighbouring facility outside of the county. In adopting such an approach the Council should be clear about the advantages and dis-benefits that will result. In progressing the strategy, One North East would recommend that the overall methodology and approach for selecting the most appropriate technology is clearly demonstrated. Such a methodology should take account of a life-cycle assessment of green-house gas emissions. Finally, One North East welcomes the recognition of the co-location of treatment facilities with housing and industry growth areas and the reference to the need for consideration to be given for CHP schemes. The strategy could go further by looking at the options for linking CHP schemes to a district heating scheme. Mrs Christine Walton The Town Council would support the key locational principles. We would also like to state Support and comments noted. Great Aycliffe Town the importance of Aycliffe in this respect. Newton Aycliffe has great road and rail links, Policy 62 of the Preferred Council P.95 refers to the environmental effects of the transportation of waste over long distances Options sets out a criteria based this can be mitigated if this is achieved using rail rather than road transport. There is an approach to the location of new existing network of existing waste management facilities, (a waste transfer station on waste facilities. Aycliffe Business Park, Aycliffe Quarry and the potential of a biomass centre very nearby). Any new development or growth in this area can be accommodated by the existing and proposed facilities. However more use could be made of demolition materials for recycling such as bricks etc. this could be achieved at Aycliffe Quarry which has some facilities on site and is nearing the end of its life as a quarry. Although two large facilities exist near Durham City the emphasis on new housing and economic development in and around Durham City may cause problems dealing with any potential waste arisings without the need to transport to facilities further afield or invest large amounts in building new waste facilities nearby, which could be seen to go against the locational principles. Mr A Hunter 5. Where should waste be managed in the future Paragraph 5.5 in relation to Qu.43 of Comments noted. English Heritage the Core Strategy Issues and Options Paper consultation, I would restate English Heritage's preference for a variation on Option B, requiring the distribution of waste facilities to relate more closely to its point of origin, in order that waste does not travel

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Respondent Question 2 - Do you have any comments on the key locational principles or any Council Response other matter in this section? any further than it need. Waste that can be disposed of, or treated, recycled, or otherwise Policy 62 of the Preferred made use of locally should be. Paragraph 5.6 'Sustainability Appraisal' Developing an Options sets out a criteria based integrated network of waste management facilities. I note the acknowledgement that large approach to the location of new facilities and sites may bring with them the potential to cause harm to the historic waste facilities. Final environment and its heritage assets. Smaller, more localised facilities can assist with the distribution of waste facilities 'ownership' issue referred to in paragraph 4.1. In this respect I concur with the point made will to some extent be a in paragraph 5.25. Paragraph 5.12 purports to show on Map 2 the preferred spatial combination of small scale strategy for the location of housing and employment to 2030. The quantum of development facilities serving local areas, and in respect of a number of settlements in each Policy Delivery Area is represented by the larger scale facilities to deal with height of a column: so for example it can be seen that Newton Aycliffe will receive 1,500 the high end residual waste. The new houses in the Plan period. This is borne out by Table 2 of the Core Strategy Policy approach chosen aims to Directions consultation document. This being the case, I am puzzled as to the height of provide this flexibility. the column representing Durham City, which we are told in the above Core Strategy document would receive 4,750 houses. As depicted, Durham City would appear to be allocated fewer houses than Newton Aycliffe. Paragraph 5.15 contains Map 3 'Location of existing waste management facilities'. It would be helpful for the anticipated shortfall In relation to Paragraph 5.28, it in provision in relation to growth to be graphically illustrated. Paragraph 5.26 outlines the is accepted that non-designated environmental characteristics of the county. All listed buildings are assessed using national heritage assets are, or can be, a criteria and are therefore of national importance. Locally important heritage assets would material consideration in the include conservation areas and non-designated assets. Maps 4 and 5 do little to convey planning process, as can the the extent or complexity of environmental considerations. Paragraph 5.28 contains Table setting of heritage assets. 14 'Environmental constraints by type'. It should be noted that non-designated heritage Archaeological potential is also assets are, or can be, a material consideration in the planning process, as can the setting a material planning of heritage assets. Archaeological potential is also a material planning consideration. consideration. Policy 62 clarifies Paragraph 5.29 sets out the Key Locational Principles. English Heritage broadly supports environmental protection policy these principles. It is worth noting that as far as the safeguarding of the environmental and this will be informed in qualities of the county is concerned, the Principles remain silent as regards the historic Development Management component. Whilst I accept it is perhaps understood by informed observers that the 'built' decisions by the NPPF. Policy environment is taken to include the 'historic' element, I would prefer its inclusion to be 62 requires new waste facilities more overtly stated in line with the DCLG definition of sustainable development - The to be in accordance with other Government's clear expectation is that we move to a system where the default answer policies in the plan, including to development is 'yes', except where this would compromise the key sustainable policy 42 (Historic Environment). development principles set out in national planning policy. Planning should help to deliver: a strong, flexible and sustainable economy, by ensuring that sufficient land of the right

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Respondent Question 2 - Do you have any comments on the key locational principles or any Council Response other matter in this section? type, and in the right places, is available to allow growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure protection and enhancement of our natural, built and historic environment , prudent use of natural resources and actions to mitigate and adapt to climate change, including moving to a low carbon economy strong, vibrant and healthy communities, by providing an increased supply of housing to meet the needs of present and future generations; and by creating a good quality built environment, with accessible local services, that reflects community needs and supports well-being Sarah Jennings Page 36 Para 5.23 This paragraph is rather complex and difficult to comprehend. It may Comments and support noted. Environment Agency be worth noting that some novel biodegradable waste treatment technologies that could Policy 62 of the Preferred become more widely adopted during the plan period would be most appropriately Options sets out a criteria based co-located with farm waste treatment plant. Page 40 Question 2 The locational principles approach to the location of new set out in the preamble to Question 2 appear to be sound, flexible and able to deliver an waste facilities, which includes effective waste infrastructure within the county. I note, however, that the plan does not amenity. make any explicit provision for assessing the potential impacts of different waste management activities on surrounding business and residential properties. I suggest that an additional principle be included recognising that waste management developments will be only be permitted at locations where their activities are unlikely to have an adverse impact on their neighbours.

Question 3 - Safeguarding Waste Sites

Do you agree with our approach to safeguarding waste sites? (If you do not agree please explain why).

Respondent Question 3 - Do you agree with our approach to safeguarding Council Response waste sites? (If you do not agree please explain why). Mrs Christine Walton The Town council would agree with the approach outlined. Support noted. Policy 52 (Safeguarding minerals Great Aycliffe Town Council related infrastructure and waste management sites) of Preferred Options sets out the approach to safeguarding waste sites.

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Respondent Question 3 - Do you agree with our approach to safeguarding Council Response waste sites? (If you do not agree please explain why). Mr Martin Kerby The RSPB wishes to comment on the phrasing used in paragraph Comments noted. Further information has been RSPB Northern England 5.42 section 1. This confuses two separate aspects of the submitted by the applicant in support of a proposed region Habitats Regulations Assessment process ('likely significant allocation at Thrislington but does not allow an effect' and 'adverse effect on integrity'). If a likely significant effect adequate assessment in order to demonstrate that on the SAC is identified, either alone or in combination with other any potential impacts or emissions from proposed plans and projects, the Council must be able to ascertain that waste operations at the site would not cause the Core Strategy will not adversely affect the integrity of the significant damage and undermine the integrity of site. The HRA screening for the Council's Core Strategy identifies the SAC, either alone or in combination with other a number of potential ways that the Thrislington Special Area of plans and projects. It is not therefore considered Conservation could be affected by waste proposals on land possible to make an allocation for a strategic waste directly adjacent to it. Accordingly this will be a key issue for the site at Thrislington Quarry at this stage in the Plan. Habitats Regulations Assessment of the Core Strategy to The approach taken in Preferred Options policies 61 address. We stress the need for the Council to have a high (Waste Management Provision) and 62 (Location of degree of certainty that an adverse effect on integrity will be New Waste Facilities) provides a flexible approach avoided. Given the strategic nature of the proposed waste facility to providing for new capacity in the absence of a at Thrislington, failure to bring forward convincing evidence to strategic waste site. demonstrate no adverse effect on integrity would significantly undermine the soundness of the Core Strategy. Mr A Hunter Paragraph 5.30 some of the criticisms of the Core Strategy Comments noted. The approach taken in Preferred English Heritage Issues and Options Paper identified in this document by various Options policies 61 (Waste Management Provision) respondents could, I would argue, be resolved were the above and 62 (Location of New Waste Facilities) provides definition to be absorbed into both the Core Strategy and the a flexible approach to providing for new capacity. Waste Strategy. Paragraph 5.33 'Sustainability Appraisal' criteria Policy 52 (Safeguarding minerals related for strategic waste sites. English Heritage broadly concurs with infrastructure and waste management sites) of Option B. The detailed assessment of a waste site allocated in Preferred Options sets out the approach to the Core Strategy would normally follow in the form of an safeguarding waste sites. Legislation is clear that Environmental Impact Assessment, at which point, it should be waste planning is an issue for Local Plans, rather acknowledged, it may be found to be unacceptable. Sustainability than Neighbourhood Plans, to address. Appraisal criteria for making non-strategic waste site allocations. English Heritage broadly concurs with Option B. Given the expected changes to the planning system as a consequence of the Localism Bill, the relationship between strategic and local waste sites should be given careful consideration. It is not

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Respondent Question 3 - Do you agree with our approach to safeguarding Council Response waste sites? (If you do not agree please explain why). inconceivable that Neighbourhood Plans, which must adhere to strategic policies in Local Development Framework documents, may seek to deviate from the network of sites being advocated through this Waste Strategy. It may be necessary, therefore, to be 'strategic' about the distribution of local waste sites if the network is to maintain its integrity. Paragraph 5.31 we are advised that consideration of 'environmental acceptability' is 'implicit' in the assessment of sites. It ought to be explicit, and ought to be re-phrased. The use of the word 'acceptability' is somewhat prejudicial: assessment of environmental 'impacts' would be a more neutral term to use. Paragraph 5.47 given the time-frames for the production of other documents such as the Development Allocations DPD, is there a need to make interim provision for such safeguarding? Sarah Jennings Whilst, in principle there should be no need to ensure that 'all Comments noted. Policy 62 of Preferred Options Environment Agency existing waste management facilities, sites and proposed waste 'Location of New Waste Facilities' includes a criterion allocations should be protected from development that would on the use of waste as a fuel. Policy 52 (Safeguarding prejudice their use for waste management', the policy minerals related infrastructure and waste encompasses a pragmatic recognition that many current waste management sites) of Preferred Options sets out the management activities have a poor public perception and that approach to safeguarding waste sites. A recently this is unlikely to change in the short term. The application of the approved AD plant at Aycliffe Ind Estate is a good policy should recognise where the benefits of integration into a example of integration of waste facilities. wider commercial infrastructure outweigh any potential minor impacts. One example may be the co-location of bio-waste recovery technology in close proximity to manufacturing plants capable of using the products (for example bio-ethanol) as feedstock. Mr David Atkinson Lafarge The County Council's proposed approach to safeguarding Support and comments noted. Policy 52 Aggregates Ltd existing waste sites and allocations from development that would (Safeguarding minerals related infrastructure and prejudice their use for waste management is fully supported. It waste management sites) of Preferred Options sets Ms Claire Brown Amec out the approach to safeguarding waste and mineral Environment & Infrastructure sites. The further information submitted is not UK Ltd considered specific enough to make adequate

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Respondent Question 3 - Do you agree with our approach to safeguarding Council Response waste sites? (If you do not agree please explain why). is further noted that paragraphs 5.40 - 5.45 of the consultation assessment in order to demonstrate that any document refers specifically to a potential strategic waste site potential impacts or emissions from proposed waste at Thrislington, and that such an allocation has the potential to operations at the site would not cause significant accommodate significant capacity through a range of waste damage and undermine the integrity of the SAC, facilities and play an important role in managing future waste either alone or in combination with other plans and arisings in County Durham. The flexibility of the site and its projects. It is not therefore considered possible to current use support an allocation. It is acknowledged however, make an allocation for a strategic waste site at (as it is in paragraph 5.42) that a number of important issues Thrislington Quarry at this stage in the Plan. The need to be addressed and Lafarge responded in length as part approach taken in Preferred Options policies 61 of the previous consultation. A preliminary air quality assessment (Waste Management Provision) and 62 (Location of was completed for example which would be the norm at this New Waste Facilities) provides a flexible approach stage of the policy process. However, further information has to providing for new capacity in the absence of a also been requested and I attach this response. ( Air Quality strategic waste site. Assessment submitted and is available to view on request.) The key issues are summarised below: Thrislington SAC As noted in paragraph 1.2 above, to assist Durham County Council with their further evaluation of the potential continued allocation of Thrislington Quarry as a strategic waste management site, additional air quality assessment work has been carried out and is attached as Appendix A. This demonstrates that taking into account existing site traffic and the existing emissions from the Steetley lime kilns operations, a 220,000 tonne per annum facility (including energy from waste) could operate without resulting in unacceptable harm on the nearby Thrislington SAC. Effects on Groundwater As referenced in paragraph 5.44, non hazardous landfill is not being promoted by Lafarge at this time. With this in mind and considering the fact that any built waste infrastructure would have to include detailed surface water drainage proposals, it is unlikely that any proposed waste management allocation would have the potential to result in any significant impacts on groundwater. Of course, should the site be allocated, any subsequent planning application would be accompanied by a full Environmental Statement which would address groundwater issues in the context of ensuring that the usual operational

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Respondent Question 3 - Do you agree with our approach to safeguarding Council Response waste sites? (If you do not agree please explain why). mitigation measures were in place to ensure that no adverse groundwater effects would occur as a consequence of surface infiltration of potentially contaminated surface water run-off. Compatibilty with Existing Operations Lafarge is of the view that operationally, any strategic waste management facility would be entirely compatible with permitted and proposed operations at the site. It is fully appreciated however, that prior to formally allocating Thrislington Quarry, Durham County Council need to be satisfied that environmentally, a waste management operation would be compatible with the site's minerals activities. Issues relating to air quality have been dealt with above (and in previous submissions made by Lafarge). Furthermore, traffic is discussed below. However, other potential environmental effects relating to compatibility with existing operations (and which was raised by the Council in their letter of 20 April 2011), include the potential landscape and visual effects of having these two activities co-located at Thrislington Quarry. There are no firm proposals for waste development at this stage, but initial landscape and visual appraisal work has been carried out in support of this response, which seeks to assess the likely effects of co-locating a strategic waste facilty (including taller structures associated with energy from waste) with the existing site infrastructure at Thrislington. The results of this exercise, including a series of annotated photographs, are presented in Appendix B. Traffic Effects As noted above, the effects of any increased traffic associated with the location of a strategic waste facility at Thrislington Quarry have been built into the attached air quality assessment. Some basic assumptions have been made on traffic leaving Entrance 1 and of course in the longer run a new access is proposed for the Eastern Extension proposals. This preliminary assessment assumes that a 220,000 tonne facility incorporating energy from waste would generate 126 movements per day. Furthermore, it is assumed that all traffic generated by any waste management facility would access

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Respondent Question 3 - Do you agree with our approach to safeguarding Council Response waste sites? (If you do not agree please explain why). and leave the site from existing entrance 1. These movements would be in addition to the current movements from entrance 1, which is known to stand an average of 320 per day. It is not considered that additional traffic would have a significant impact on the local road network. Ms Janet Blackburn Bowburn & Parkhill Community Partnership thinks the Waste Support and comments noted. The further Bowburn & Parkhill Strategy is largely satisfactory. So far as Thrislington is information submitted in regard to Thrislington is Community Partnership concerned, it appears an application is being considered not considered specific enough to make adequate (perhaps not yet submitted) to make this a strategic site for assessment in order to demonstrate that any certain elements of waste disposal but at the moment not potential impacts or emissions from proposed waste including landfill. Is this correct? Regarding para 5.42 However operations at the site would not cause significant some critical issues remain to be addressed: The potential impact damage and undermine the integrity of the SAC, on the adjacent Thrislington Special Area of Conservation/Site either alone or in combination with other plans and of Special Scientific Interest and Thrislington Plantation National projects. It is not therefore considered possible to Nature Reserve, through Habitats Regulations Assessment make an allocation for a strategic waste site at (HRA) The HRA must be able to demonstrate that no significant Thrislington Quarry at this stage in the Plan. The impacts are likely, either alone or in combination with other plans Plan acknowledges that the need for a landfilling and projects. The potential impact on groundwater, particularly element in the proposal and its deliverability in this from any proposed landfill element of waste development. The location, especially in relation to the need to protect need for a landfilling element in the proposal and its deliverability groundwater, remain to be demonstrated. in this location remain to be demonstrated. The compatibility of proposed waste facilities with permitted and proposed minerals The approach taken in Preferred Options policies 61 operations at the Quarry. The potential impact of additional traffic (Waste Management Provision) and 62 (Location of generated as a result of the waste development proposal on the New Waste Facilities) provides a flexible approach strategic transport network. Proposed approach to waste to providing for new capacity in the absence of a development in the Central Durham Delivery Area: So far as the strategic waste site. 3rd bullet point is concerned, we are not sure where you may be considering. When would you know? The document correctly says that it cannot specify details - that would need to be considered in individual planning applications. But it does highlight traffic concerns and our comments re Bowburn (including reference to the relief road) is mentioned. However with reference to Para 6.13, Bowburn & Parkhill Community

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Respondent Question 3 - Do you agree with our approach to safeguarding Council Response waste sites? (If you do not agree please explain why). Partnership may well look at any planning applications that may have the potential to affect us, whether directly or indirectly e.g. by traffic problems.

Question 4 - North Durham Delivery Area

Do you agree with the spatial approach for planning for future waste management facilities within the North Durham Delivery Area? (Please explain why you agree or disagree).

Respondent Question 4 - Do you agree with the spatial approach for planning for future Council Response waste management facilities within the North Durham Delivery Area? (Please explain why you agree or disagree). Mr A Hunter Paragraph 6.2 English Heritage supports the pragmatic view being taken with regard Support and comments noted. English Heritage to the location of waste sites. It is conceivable that strict self-containment based on The criteria based approach the Policy Delivery Areas could in fact conflict with the 'proximity' principle. I am taken in policies 61 and 62 of encouraged by the intention to have regard to those factors which give an area its Preferred Options is based on local distinctiveness in planning the network of facilities. North Durham Delivery Area the combination approach Paragraph 6.5 makes reference to the listed buildings, conservation areas, and historic preferred by respondents, parks & gardens in this delivery area and I am pleased to note that the proposed providing flexibility. approach seeks to protect 'recognised' environmental assets including heritage. It should be made clear, however, that this protection will extend to all heritage assets types. Sarah Jennings The spatial approach for planning for future waste management facilities within the Comments and support noted. Environment Agency North Durham Delivery Area appears to provide a sound basis for waste management The criteria based approach planning. I repeat my observation that some flexibility may be needed if future novel taken in policies 61 and 62 of technologies lend themselves to co-location with other non-waste industrial operations. Preferred Options is based on the combination approach preferred by respondents, providing flexibility.

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Question 5 - Central Durham Delivery Area

Do you agree with the spatial approach for planning for future waste management facilities within the Central Durham Delivery Area? (Please explain why you agree or disagree).

Respondents Question 5 Council Response Mr John Lowe Yes. Support noted. Mrs Margaret Forster Coxhoe Parish Council has no comments to make in general on the 'Towards Support noted. Coxhoe Parish Council a Waste Delivery Strategy for County Durham' Consultation Document other than to support the proposed approach to waste development. Mr A Hunter Paragraph 6.11 we welcome recognition of the extensive presence of high-status Support noted. The criteria English Heritage heritage assets within this area (containing as it does the city itself), as well as based approach taken in the overt reference to their protection in the plan approach. policies 61 and 62 of Preferred Options is based on the combination approach preferred by respondents, providing flexibility. Sarah Jennings The spatial approach for planning for future waste management facilities within Support and comments noted. Environment Agency the Central Durham Delivery Area appears to provide a sound basis for waste The criteria based approach management planning. I repeat my observation that some flexibility may be taken in policies 61 and 62 of needed if future novel technologies lend themselves to co-location with other Preferred Options is based on non-waste industrial operations. the combination approach preferred by respondents, providing flexibility. Ms Janet Blackburn Proposed approach to waste development in the Central Durham Delivery Area: Comments noted. The criteria Bowburn & Parkhill Community So far as the 3rd bullet point is concerned, we are not sure where you may be based approach taken in Partnership considering. When would you know? The document correctly says that it cannot policies 61 and 62 of Preferred specify details - that would need to be considered in individual planning Options is based on the applications. But it does highlight traffic concerns and our comments re Bowburn combination approach (including reference to the relief road) is mentioned. However with reference to preferred by respondents, providing flexibility. Any

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Respondents Question 5 Council Response Para 6.13, Bowburn & Parkhill Community Partnership may well look at any planning applications which planning applications that may have the potential to affect us, whether directly are submitted will be assessed or indirectly e.g. by traffic problems. having regard to these policies once the Plan is adopted and any comments from your organisation.

Question 6 - East Durham Delivery Area

Do you agree with the spatial approach for planning for future waste management facilities within the East Durham Delivery Area? (Please explain why you agree or disagree).

Respondent Question 6 Council Response

Mr Mark Welsh Yes, however the local Town/Parish Council and community should be consulted on Comments noted. The criteria based Seaham Town Council the location and type of any new waste management facilities. Any new facilities approach taken in policies 61 and 62 of should only be of a type and should only be sited so as to have no negative impact Preferred Options is based on the on the quality of life of the local community. combination approach preferred by respondents, providing flexibility. Any planning applications which are submitted will be assessed having regard to these policies once the Plan is adopted and any comments from your organisation.

Mr A Hunter Paragraph 6.16 acknowledges the presence of heritage assets such as conservation Comments noted. It is the Council's English Heritage areas and listed buildings, but unlike the previous two delivery areas, paragraph 6.17 intention to treat heritage assets contains no specific intention to protect them. I strongly believe that the heritage consistently. The criteria based assets of the county should be treated in a consistent way, and in some respects it approach taken in policies 61 and 62 of could be argued that there is an equally compelling need to protect those assets Preferred Options is based on the where they are fewer in number. Map 9 and others show the various Delivery Areas combination approach preferred by and their key features. In each there is a separate notation for 'conservation areas' respondents, providing flexibility. and 'heritage assets' which it would be helpful to explain or, better still, rationalise. Further maps have been produced and the Reasoned Justification explains the approach in each Delivery Area. Policy

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Respondent Question 6 Council Response

62 requires new waste facilities to be in accordance with other policies in the plan, including policy 42 (Historic Environment).

Sarah Jennings The spatial approach for planning for future waste management facilities within the Comments and support noted. The Environment Agency East Durham Delivery Area appears to provide a sound basis for waste management criteria based approach taken in policies planning. I repeat my observation that some flexibility may be needed if future novel 61 and 62 of Preferred Options is based technologies lend themselves to co-location with other non-waste industrial operations. on the combination approach preferred Page 59 Para 6.24 Should read 'end-of-life' by respondents, providing flexibility.

Question 7 - South Durham Delivery Area

Do you agree with the spatial approach for planning for future waste management facilities within the South Durham Delivery Area? (Please explain why you agree or disagree).

Respondent Question 7 Council Response Mrs Christine Walton Agree The Town Council feel the approach to waste development in the South Support and comments noted. The criteria Great Aycliffe Town Durham Delivery Area is correct. We would also like to state the importance based approach taken in policies 61 and 62 Council of Aycliffe in this respect. Newton Aycliffe has great road and rail links, although of Preferred Options is based on the the plan appears to gloss over the importance of the rail network. The combination approach preferred by environmental effects of the transportation of waste over long distances can respondents, providing flexibility. be mitigated if rail is used to transport waste rather than relying on road transport. There is an existing network of existing waste management facilities in and around Newton Aycliffe. (a waste transfer station on Aycliffe Business Park, Aycliffe Quarry and the potential of a biomass centre very nearby). More emphasis needs to be placed on reusing materials, reducing carbon emissions and improved waste management techniques. Protecting the natural environment whilst having the least impact on residents will be a key issue that may have longer consequences for County Durham to resolve. Utilising and expanding existing facilities would seem a common sense approach.

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Respondent Question 7 Council Response Mr A Hunter Paragraph 6.22 acknowledges the presence of heritage assets within this Support noted. The criteria based approach English Heritage delivery area. We welcome the approach set out in paragraph 6.24. taken in policies 61 and 62 of Preferred Options is based on the combination approach preferred by respondents, providing flexibility. Sarah Jennings The spatial approach for planning for future waste management facilities within Support and comments noted. The criteria Environment Agency the South Durham Delivery Area appears to provide a sound basis for waste based approach taken in policies 61 and 62 management planning. I repeat my observation that some flexibility may be of Preferred Options is based on the needed if future novel technologies lend themselves to co-location with other combination approach preferred by non-waste industrial operations. respondents, providing flexibility. Mr David Atkinson Whilst the general approach to identifying delivery areas is acceptable, Lafarge Comments noted. The Plan acknowledges Lafarge Aggregates Ltd particularly supports the acknowledgement in paragraph 6.2 that the delivery the potential of Thrislington in terms of its Ms Claire Brown Amec areas are not self-contained in waste management terms and that there are scale and central location within the County. Environment & wider, complex cross boundary flows of waste between Durham and the However, the information so far provided in Infrastructure UK Ltd surrounding area. Such acknowledgement is especially important in considering support of a proposed allocation at the allocation of Thrislington Quarry as a strategic waste management site. Thrislington does not allow an adequate This is because, such a facility would not be designed to simply serve the assessment in order to demonstrate that any needs of the South Durham Delivery area, but would also be a key piece of potential impacts or emissions from proposed infrastructure in meeting the wider waste management needs of the whole of waste operations at the site would not cause County Durham. Appendix A: Types of Facilities needed and Locational significant damage and undermine the Requirements Integrated Waste Management Facilities Lafarge agrees with integrity of the SAC, either alone or in the statement in paragraph A36 that permanent integrated waste management combination with other plans and projects. It facilities should not prejudice the agreed timescale at the site and would need is not therefore considered possible to make to accord with existing restoration proposals. Of course any built development an allocation for a strategic waste site at would, if permitted, lead to amendments in any agreed scheme for the area Thrislington Quarry at this stage in the Plan. west of the C69.

Question 8 - West Durham Delivery Area

Do you agree with the spatial approach for planning for future waste management facilities within the West Durham Delivery Area? (Please explain why you agree or disagree).

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Respondent Question 8 Council Response Mr A Hunter Paragraph 6.25 again acknowledges the presence of certain In formulating the approach for the different Delivery Areas, the English Heritage heritage asset types in this delivery area. However, and profile of each was taken into account. Whilst the Plan aims to perhaps more so relative to the others, there is a considerable have a common approach to all heritage assets, it is worth noting amount of important archaeology within this area which is not that the approach to the West Durham Delivery Area will be heavily mentioned in relation to this or any other delivery area. affected by the international and national environmental Paragraph 6.28 surprisingly, given the approach to the other designations there. As outlined, as a consequence of this and its four delivery areas, there is no reference at all to rural nature there are a limited number of facilities in the Delivery environmental protection of any kind, let alone the Area and it is not viewed as a key location for new facilities, as safeguarding of the historic environment and its heritage outlined in the Reasoned Justification in Preferred Options. It is assets. Appendix A what types of facilities are needed and therefore our intention to maintain the existing limited network what are their locational requirements No comments. of facilities and support new facilities on employment land in Appendix B Glossary of terms No comments. Appendix C locations well related to centres of population and certain small Capacity gap methodology Given the various references to scale recycling and recovery facilities which require a rural the historic environment and its heritage assets in the location. The point is noted that there is not explicit reference to document it would be useful to include their definitions within the protection of heritage assets, however this is now considered the glossary. These can be found in PPS5. to be covered by the reference to 'not give rise to significant adverse impacts on the environment or amenity of local communities in accordance with the other relevant policies of the Plan'. The criteria based approach taken in policies 61 and 62 of Preferred Options is based on the combination approach preferred by respondents, providing flexibility. Sarah Jennings The spatial approach for planning for future waste Support and comments noted. Page 66 paragraph A9 is a drafting Environment management facilities within the West Durham Delivery Area error. The criteria based approach taken in policies 61 and 62 of Agency appears to provide a sound basis for waste management Preferred Options is based on the combination approach preferred planning. Page 66 Para A.9 The second sentence is by respondents, providing flexibility. self-contradictory and needs clarifying. Page 69 Para A.23 Anaerobic digestion may develop as a option for clusters of industrial businesses producing similar biodegradable wastes, e.g. food manufacturing. In addition, there may be economies in rural food processors and clusters of farms forming co-operatives to operate such plants. This could be reflected in the text here or in Para A.29 (Farm Waste) Page 76 Autoclave As a glossary, this definition should be extended to make clear that the autoclaving process consists of

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Respondent Question 8 Council Response exposing waste to pressurised steam to sterilise it and change some chemical components. Page 76 Co-disposal I question the justification for including this term in the glossary when it does not appear in the text. In any event, the description is outdated as the term, 'special waste' is no longer recognised in waste management. Page 78 LATS Out of alphabetical order. Page 79 Leachate A duplicate entry.

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F Responses to Technical Consultation Report 'Towards a Strategy for Low Carbon Energy in County Durham'

Question 1 - An Energy Hierarchy

Should the Core Strategy adopt an Energy Hierarchy along the following lines as part of the overall policy of planning for future energy development in County Durham? 1) Reduce the need for energy. Account will be taken of landform, layout, building orientation, massing and landscaping to minimise energy consumption, including maximising cooling and avoiding excessive solar gain in the summer. 2) Use energy more efficiently. In construction, and through energy efficient appliances, lighting, fans and pumps. 3) Supply energy from renewable sources. An assessment of the feasibility of installing renewable or low carbon energy technologies should be included. This should include the expected energy outputs and CO2 reduction potential. 4) Any continuing use of fossil fuels to use clean technologies and to be efficient e.g. using Combined Heat and Power (CHP). The above assessment must include the potential for CHP and district heating.

Respondent Question 1 - Should the Core Strategy adopt an Energy Council Response Hierarchy along the following lines as part of the overall policy of planning for future energy development in County Durham? Mr John Lowe Yes, all should be part of the strategy but especially the reduction Support and comments noted. The Energy Hierarchy is of the need for energy in the first place. introduced by Preferred Options Policy 1 'Sustainable Development' and is also included in policy 17 'Sustainable Design in the Built Environment'. Mr Brian Burke Make maximum use of solar energy as it is the prime source of Comments noted. The Energy Hierarchy is introduced by British Motorcycling all energy on the planet. Obviously maximise efficiency so as to Preferred Options Policy 1 'Sustainable Development' and Federation reduce dependency on non-renewable energy forms. is also included in policy 17 'Sustainable Design in the Built Environment'. The efficiency of individual technologies is beyond the scope of the Plan. Miss Karen Johnson Darlington Borough Council supports the adoption of an energy Support noted. The Energy Hierarchy is introduced by Darlington Borough hierarchy as an efficient and effective approach to planning for Preferred Options Policy 1 'Sustainable Development' and Council long term sustainable development. is also included in policy 17 'Sustainable Design in the Built Environment'.

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Respondent Question 1 - Should the Core Strategy adopt an Energy Council Response Hierarchy along the following lines as part of the overall policy of planning for future energy development in County Durham? Mrs Susan Carmedy The Parish Council agrees with the principles of the document Support noted. The Energy Hierarchy is introduced by Brandon & Byshottles Preferred Options Policy 1 'Sustainable Development' and Parish Council is also included in policy 17 'Sustainable Design in the Built Environment'. Mr David Atkinson We have few comments to make on this consultation document. Support and comments noted. Lafarge Aggregates However, we do note the reference in paragraph 7.23 that key Ltd decisions relating to energy from waste need to be made in Energy from waste on different scales will need to form Durham and that this will be managed separately via the Council's part of the energy mix, but decisions on the County's own Ms Claire Brown Waste Strategy / procurement process. Whilst we welcome this Municipal Waste Management Strategy are the subject of Amec Environment & document's general recognition that renewable energy targets a separate procurement process and beyond the scope of Infrastructure UK Ltd have the potential to be achieved by energy from waste, this the County Durham Plan. statement does not sit well with paragraph 2.1 of the Executive Summary of 'Towards a Waste Delivery Strategy for County Durham', which states rather more definitely that: 'Energy from waste, in the form of electricity and renewable heat, will need to have formed an important part of the County's energy mix, displacing fossil fuels and playing a key part in the County's programme to address climate change' [Amec highlight] Ms C Straughan This Council broadly supports Durham County Council's approach Support noted. The Energy Hierarchy is introduced by Stockton on Tees of moving towards renewable forms of electricity and heat supply Preferred Options Policy 1 'Sustainable Development' and Borough Council within the area, in particular the principle of the energy hierarchy is also included in policy 17 'Sustainable Design in the set out in question 1. Built Environment'. Ms Wendy One North East recognises that providing a clean, secure and Support and comments noted. The Energy Hierarchy is Hetherington stable energy supply is a key challenge and a key opportunity for introduced by Preferred Options Policy 1 'Sustainable One NorthEast the region's economy. Efficient use of low carbon energy is the Development' and is also included in policy 17 'Sustainable key policy driver that the Agency has always promoted through Design in the Built Environment'. its plans and programmes, such as the Energy Pillar and Connectors and the RES Action Plan, to support businesses and other users to reduce the impacts of a presently volatile energy market and grasp the economic opportunities it represents. The Council's Low Carbon Strategy brings together the various issues

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Respondent Question 1 - Should the Core Strategy adopt an Energy Council Response Hierarchy along the following lines as part of the overall policy of planning for future energy development in County Durham? that need to be addressed to ensure that the Council meets its targets in achieving carbon emission reduction across the whole County by 2020, as agreed within the regional programme set out in the European Covenant of Mayors and required by the UK Renewable Strategy (The UK Renewable Energy Strategy (DECC 2009) sets a target for 15% of the UK's energy to come from renewable sources by 2020, which represents a seven fold increase from 2008.) Maximising energy efficiency measures and renewable energy generation will contribute to limiting carbon emissions and maintaining the North East's reputation as a leading player in the development of a low carbon economy. One North East welcomes and endorses the County Council's intention to provide this Low Carbon Strategy to ensure the County's opportunities to reach its renewable energy targets are satisfactorily achieved and, where possible, exceeded. The Agency notes the Strategy's proposal to achieve a target of 26% for provision of renewable electricity by 2020 with an aspiration to exceed that target. The draft Strategy also assesses future opportunities to generate energy from wind, biomass, waste, solar, landfill gas, and hydro sources and also sets out the approach to sustainable construction and embedding renewable energy in new development. This approach, involving the use of various technologies to achieve renewable energy targets, has always been highlighted and encouraged by the Agency in our responses to major planning applications (e.g. proposals for a biomass heat and power plant at Chilton by Dalkia Bio Energy Ltd.) and also to the Issues and Options stage of the County Council's emerging Core Strategy DPD (our letter dated 4 August 2010) and the Sustainable Design SPD (our letter dated 29 March 2010). One North East acknowledges the pivotal role played by wind energy schemes as a key electricity generating technology which is set to expand over the next ten years. One North East also recognises that Durham County is already acknowledged as one of the leading

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Respondent Question 1 - Should the Core Strategy adopt an Energy Council Response Hierarchy along the following lines as part of the overall policy of planning for future energy development in County Durham? local authorities in this respect. However, as the draft Strategy states, installing structures of such prominence inevitably involves significant landscape impact and wind energy proposals in the future will need to continue to ensure the County's landscapes and the amenity of its residents and businesses are not compromised by cumulative environmental impact. As you are aware, plans for the development of electric vehicles on a significant scale have been brought forward rapidly over the last 12 months. With the North East recognised as a low carbon economic area for ultra low carbon vehicles, there is major activity underway to ensure that the area remains at the forefront of this developing technology. One North East supports the Strategy's pro-active approach to the County Council's promotion of the use and expansion of electric vehicles within County Durham, including the development of charging infrastructure within new development. For further advice relating to electric vehicle charging infrastructure contact ONE's electric vehicle project team at: [email protected]. To conclude, One North East supports this proposed Strategy as set out in the draft document and based on the 5 delivery areas which will help to ensure the County Council's low carbon energy targets are achievable by 2030. The final approved Strategy should provide a sound reference point for setting carbon reduction targets in County Durham as well as informing the County's LDF process. Mr Martin Kerby The RSPB broadly supports the Energy Hierarchy proposed. Support and comments noted. The Energy Hierarchy is RSPB Northern Directing developments to sustainable sites with good public introduced by Preferred Options Policy 1 'Sustainable England region transport infrastructure that are well-connected to cyclepaths and Development' and is also included in policy 17 'Sustainable rights of way will also help reduce energy consumption by Design in the Built Environment'. The Preferred Options discouraging use of private cars. policy 17 also aims to promote the use of sustainable transport.

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Respondent Question 1 - Should the Core Strategy adopt an Energy Council Response Hierarchy along the following lines as part of the overall policy of planning for future energy development in County Durham? Mr Mark Welsh Yes. Support noted. The Energy Hierarchy is introduced by Seaham Town Preferred Options Policy 1 'Sustainable Development' and Council is also included in policy 17 'Sustainable Design in the Built Environment'. E.ON Climate and Yes, the proposed Energy Hierarchy very much reflects the ethos Support noted. The Energy Hierarchy is introduced by Renewables of both E.ON Climate & Renewables and E.ON UK. Preferred Options Policy 1 'Sustainable Development' and Mr Rod Hepplewhite is also included in policy 17 'Sustainable Design in the Prism Planning Built Environment'. Ronald Blain I am particularly interested in schemes which give benefit to the Support and comments noted. The Plan seeks to assess senior citizens of our communities, so that they, who have given a full range of viable renewable energy technologies and the greatest, should benefit in their 'Autumn Years'...... On the keep pace with the continuing evolution of technologies future of 'LOW CARBON' thinking, we should embrace the use of and their viability. The Preferred Options contains policies all possible sources of renewables, specifically both WIND and on both Renewable Energy Development (21) and Wind SOLAR power. WIND POWER could also generate HYDROGEN, Turbine Development (22). which could be used to power all the transport used by the COUNTY, reducing its budget, allowing funds to be used elsewhere within the Future Plan. If the roof of every senior citizen's house had a SOLAR Panel, or a small mini-WIND TURBINE located close by, which heated their water, not only would it reduce the household heating bill, but reduce the demand for electricity or gas, both of which are becoming, even now, an expensive commodity. The way it can be done, could be by grant-inducement or even socially procured for the poorer elements of our county society...... The main thought is to think long-term, with a constant evolving plan, updated yearly / two-yearly and constantly improving the environment and the plan. Mrs Christine Walton Yes. The Town council feel there is no one quick fix to reduce the Support and comments noted. The Preferred Options aims Great Aycliffe Town use of energy. Every individual needs to be seen to be doing their to give the reasons for the approach chosen. Council bit it is hoped that more detailed information will be provided in future documents.

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Respondent Question 1 - Should the Core Strategy adopt an Energy Council Response Hierarchy along the following lines as part of the overall policy of planning for future energy development in County Durham? Mr Chris Bell I am writing on behalf of the Highways Agency regarding the Comment noted. Highways Agency "Towards a Strategy for Low Carbon Energy in County Durham" and "Core Strategy Interim Habitats Regulation Assessment" that contribute to Durham's Local Development Framework. Our prime concern is the safe and efficient operation of the Strategic Road Network. In this regard we have no comments to make on either of these documents. Mr Alan Myers The planning team deserves congratulations for the rigorous Support and comments noted. manner in which the research for the plan and clarity of the presentation of the report. I find most of the proposals are sound, Carbon capture and storage may well need to form an but raise two major concerns. integral role in a future carbon management strategy but the national policy direction on CCS is still developing. 1 No mention in the report is made of the potential of CCS The County Durham Plan will need to take account of future technologies in lowering CO 2 emissions. Peter Whitton, Managing developments and any spatial planning implications for Director of Progressive Energy, a company involved with two CCS County Durham. schemes in the region one at an old coal/biomass fired station at Lynemouth, the other a new coal-fired station on south bank of Tees. He is quoted thus in The Journal 7 March 2011: "It would be very difficult for the North East to have any kind of industrial The Plan aims to assess the potential and environmental base ...... without a CO 2 transport and storage network." The impacts of a wide range of viable renewables technologies, CO 2 from the Lynemouth and Teesside stations would be including wind energy. Infrastructure requirements to transported via a pipeline network and stored in depleted North support all technologies will also need to form part of the Sea oil fields. Carbon dioxide from other industrial sources could final strategy, but these will need to be developed in feed into this network. There seems to be general agreement consultation with key infrastructure providers. within the energy industry that CCS from fossil-fuel power stations and from manufacturing processes will be crucial to lowering CO 2 emissions.

2 In regard to wind developments: (a) I raise concern over the amount of land used up by wind turbines to generate a very modest amount of electricity relative to nuclear, coal and gas; (b) there is no mention in the report whether an increase in the number of pylons would be necessary in connecting the electricity generated

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Respondent Question 1 - Should the Core Strategy adopt an Energy Council Response Hierarchy along the following lines as part of the overall policy of planning for future energy development in County Durham? to the national grid. Points in relation to the above concerns are reiterated and explored further in my responses (below) to the questions asked in the strategy report. Question 1 All are more or less equally important. I would include reference to CCS in number 4 particularly in relation to developing industrial infrastructures in science/industrial parks that capture CO 2 and use it for other processes (e.g. plant/algal growth for food, biofuels and chemicals) or transport it to suitable storage facilities (being explored in the North Sea).

Mr Martin Wood Npower Renewables Ltd (NRL) is one of the country's leading Support and comments noted. Optimising the contribution RWE Npower developers and operators of renewable energy generating facilities, made within the County to renewable energy whilst at the Renewables Ltd operating throughout the UK but has a regional office in Barnard same time ensuring appropriate safeguards for the Castle. NRL supports in principle the Spatial Vision and Strategic County's landscapes and the amenity of local people, Objectives set out in the Core Strategy Policy Directions necessarily involves a detailed understanding of the consultation paper and welcome the proposed approach to environmental constraints to deployment of new capacity, renewable energy, which is to create a favourable context for within the context of national policy. private sector investment by pursuing policies to promote and facilitate renewable energy and associated infrastructure (Spatial Vision and Strategic Objective (6)). The challenge, as the Low Carbon Energy consultation paper rightly identifies, is to optimise Reducing energy demand through site-selection and the the contribution made within the County to renewable energy (and design of new development will need to be a thereby to combating climate change) whilst at the same time complimentary part of the approach to carbon reduction ensuring appropriate safeguards for the County's landscapes and alongside the deployment of renewable energy generating the amenity of local people. We are concerned that against the capacity. They are not competing objectives. background of a positively expressed Spatial Vision and a Strategic Objective to facilitate renewable energy deployment, the approach advocated in the consultation paper is by comparison backward looking, focusing upon the conclusions of studies produced before The Low Carbon Masterplan was adopted by the Council the most recent report of the Committee on Climate Change and in 2009/2010. This has been refreshed and renamed as the decision by central Government to adopt its recommendations the Climate Change Strategy, accompanied by an in pursuit of a 'step change' in the deployment of renewable energy Action/Delivery Plan.

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Respondent Question 1 - Should the Core Strategy adopt an Energy Council Response Hierarchy along the following lines as part of the overall policy of planning for future energy development in County Durham? throughout the country. The approach of the consultation paper appears to be heavily constraints-driven, rather than aligned with the permissive approach embodied in the Core Strategy that it is The Energy Hierarchy is introduced by Preferred Options intended to support. National planning policy is clear that it is Policy 1 'Sustainable Development' and is also included possible to accommodate renewable energy throughout the country in policy 17 'Sustainable Design in the Built Environment'. providing that the environmental and other effects are handled satisfactorily. That should be the approach followed in setting a renewable energy strategy for County Durham and it is against that background that our detail comments are offered. Section 3: The Preferred Options contains policies on both Renewable Low Carbon Energy: We broadly support the analysis set out in Energy Development (21) and Wind Turbine Development paragraphs 3.1 to 3.5. However, there is an unexplained reference (22). to 'the masterplan' in paragraph 3.3. The 'Masterplan' is said to be 'a central reference point for setting carbon reduction scenarios and detailing Council-based actions and specific targets to achieve them.' On the face of it therefore 'the Masterplan' is an important document. What is it? How does it relate to other evidence base documents? How does it relate to the County Plan? Question 1: The consultation paper is right to observe that reducing energy use can be an effective way of managing energy demand (paragraph 4.1) but as the proposed hierarchy set out within Question 1 makes clear, in the spatial/land use planning context this is relevant only in relation to new development, which even over the plan period would only account for a small proportion of the total building stock and so have little impact on total energy demand. By contrast, the displacement of carbon-based electricity generation by renewable technologies can have significant impact on emissions even if energy demand is unchanged. Reducing energy demand through site-selection and the design of new development is not a substitute for making progress on the deployment of renewable energy generating capacity: both are important components of a portfolio approach, as the national energy strategy acknowledges. The County Durham strategy should therefore draw a distinction between the factors to be taken

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Respondent Question 1 - Should the Core Strategy adopt an Energy Council Response Hierarchy along the following lines as part of the overall policy of planning for future energy development in County Durham? into account in selecting sites for development (for instance to meet the needs for housing, employment, etc) and in the design of new buildings on the one hand (which might include promoting on-site energy generation for example) ; and an overarching strategy to promote the increased deployment of commercial-scale renewable energy generating capacity on the other. Mr A Hunter Paragraph 4.1 “ Question 1 - English Heritage fully supports the Support noted. The Preferred Options aims to promote the English Heritage concept of an energy hierarchy “ one in which reducing the use re-use and conservation of historic buildings. of energy in the first place is given due prominence. The government urges, in PPS5: Planning for the Historic Environment (Policy HE3.1) the prudent use of existing built fabric - in other words, seeking to make best use of existing buildings before conceding that demolition and rebuilding is the only feasible/practicable solution. Project Genesis Ltd Whilst the suggested hierarchy may have merits in terms of the Comments noted. The Energy hierarchy would imply that Mr J P Haryley Gifford simplification of any planning decision-making process, as currently as a principle, energy conservation measures are preferred proposed it would fail to take account of any economic before renewable energy generation. However, it is not considerations to balance costs of energy saving against an intended to be applied rigidly if it can be demonstrated alternative generation of renewable energy. A policy as proposed that there are sound operational reasons, supported by could, potentially, mitigate against investment in renewables from evidence. The Energy Hierarchy is introduced by Preferred the private sector in a situation whereby achieving carbon reduction Options Policy 1 'Sustainable Development' and is also in a number of buildings may be prohibitively expensive in included in policy 17 'Sustainable Design in the Built comparison to development of a single renewable energy facility Environment'. to serve those buildings. The option to provide renewable energy in lieu of energy reduction measures within a development should be available to encourage appropriate investments. We would suggest that in any proposed hierarchy 'supply energy from renewable sources' should, in development terms, be given the same priority as 'reduce need for energy'.

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Respondent Question 1 - Should the Core Strategy adopt an Energy Council Response Hierarchy along the following lines as part of the overall policy of planning for future energy development in County Durham? Partner Construction In response to the questions set out within the Low Carbon Comments noted. The approach to sustainable buildings Ltd Strategy, it is considered that, on the whole, the requirements for through the County Durham Plan is based on an Mr Alastair Willis individual developments are appropriately dealt with through understanding of developing national standards and Signet Planning Building Regulations and the increase in Building Regulation Building Regulations requirements to avoid duplication. requirements, towards zero carbon in 2016. In this respect, Accordingly, the Preferred Options is clear that the paragraph 30 of PPS1: Delivering Sustainable Development states Building Regulations will set the minimum standards for that: 'Planning policies should not replicate, cut across, or energy efficiency in new buildings detrimentally affect matters within the scope of other legislative requirements, such as those set out in Building Regulations for energy efficiency'. Steven Whitfield I would like to know if the housing planned for the county will meet Comments noted. The Preferred Options contains an certain criteria such as the dwelling possessing a south facing overarching Sustainable Development policy, which could aspect to harvest as much energy as possible, many homes I provide an opportunity. An officer of the Council has been have seen built around Consett in the recent past face East/West. in contact regarding the solar housing proposals. As the Council and Government were developing their respective plans with a great emphasis on renewable energy I had reached a satisfactory position with regard to a solar house I wish to build. I have had contact with NAREC where the response was positive and am in contact with BeEnterprising, where the response has also been positive, with a view to produce a business plan. I am seeking partners with a view to producing a prototype and would like to talk to the council about integrating my design in the plan. Could I be put in touch with any member of the plan to discuss my proposal? DVRC In response to the questions set out within the Low Carbon Comments noted. Approach to sustainable buildings Mr Alastair Willis Strategy, it is considered that, on the whole, the requirements for through the County Durham Plan is based on an Signet Planning individual developments are appropriately dealt with through understanding of developing national standards and Building Regulations and the increase in Building Regulation Building Regulations requirements to avoid duplication. requirements, towards zero carbon in 2016. In this respect, paragraph 30 of PPS1: Delivering Sustainable Development states that:"Planning policies should not replicate, cut across, or detrimentally affect matters within the scope of other legislative

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Respondent Question 1 - Should the Core Strategy adopt an Energy Council Response Hierarchy along the following lines as part of the overall policy of planning for future energy development in County Durham? requirements, such as those set out in Building Regulations for energy efficiency". In the same respect, any percentage targets for renewable energy contributions from development proposals should consider the potential conflicts with other energy efficiency requirements set out in the Building Regulations. We trust the above representations are straight forward and will be afforded significant weight in the Council's consideration of its emerging Core Strategy. Furthermore, it is fundamental to the soundness of the emerging Core Strategy to ensure that the entire evidence base which informs the Core Strategy is available to consultees at the time of consultation.

Question 2 - Renewable electricity and heat targets

Do you agree with this approach and the suggested targets for renewable electricity and heat?

Respondent Question 2 - Do you agree with this approach and the Council Response suggested targets for renewable electricity and heat? Mr John Lowe The targets seem realistic but it is also important to strive to exceed Support and comments noted. The targets are not intended them and not just meet them. to be a limit to development. Mr Brian Burke I agree with the core strategy proposal. Support noted. British Motorcycling Federation Mr Alan Myers 1 It may be more appropriate to set targets to lower CO 2 emissions. Comments noted. After all, the level of atmospheric CO 2 is the "bottom line". These targets can be achieved through (i) renewable electricity and heat

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Respondent Question 2 - Do you agree with this approach and the Council Response suggested targets for renewable electricity and heat? generation and (ii) developing electricity generation and industrial It is acknowledged that expansion of renewable energy symbiotic infrastructures in which CO 2 -emitting processes are capacity to meet the proposed targets will have significant coupled to CO 2 -utilising processes (e.g. plant/algal growth) and environmental impacts but these will be assessed through any residual CO 2 is transported and stored as described above. 2 the Sustainability Appraisal process. Renewable energy Renewable energy targets (if specifically required by the development is seen as complementary rather than competing Government) could be set within a broader framework in which the with any development of carbon capture and storage essential goal is CO 2 emission reduction. infrastructure; each works towards wider carbon reduction objectives. As explained in the Preferred Options document, 3 The targets of 26% and 12% seem achievable from the way you although targets have been consulted upon here and earlier have presented the data. But for that target another 40 MW of wind on in the Plan process, it has been decided that the County development (20 turbines) or 20 MW biomass development or some Durham Climate Change Strategy 2012 target of a 40% carbon combination of these seem necessary. That is a considerable emissions reduction by 2020 is to be used as the overarching increase and its environmental impact and effect on energy supply target for the Local Plan. should be compared with approaches relating to 1(ii) above.

Mr Martin Kerby The RSPB supports the principle of developing renewable energy Support noted. Any environmental impacts will be assessed RSPB Northern sources in order to reduce the damaging impacts of climate change. through the Sustainability Appraisal process and through England region We therefore broadly support the approach and targets provided HRA. As explained in the Preferred Options document, that the aspirations referred to form part of the Core Strategy's policy although targets have been consulted upon here and earlier to ensure that targets are not interpreted as ceilings. These on in the Plan process, it has been decided that the County aspirations should be set in the context of ensuring that meeting or Durham Climate Change Strategy 2012 target of a 40% carbon exceeding renewable energy targets will not be allowed to result in emissions reduction by 2020 is to be used as the overarching significant environmental impacts. target for the Local Plan. Mr Mark Welsh Yes. Support noted. As explained in the Preferred Options Seaham Town document, although targets have been consulted upon here Council and earlier on in the Plan process, it has been decided that the County Durham Climate Change Strategy 2012 target of a 40% carbon emissions reduction by 2020 is to be used as the overarching target for the Local Plan.

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Respondent Question 2 - Do you agree with this approach and the Council Response suggested targets for renewable electricity and heat? E.ON Climate Agreed, Option B is the right approach. It also very much reflects Support noted. Originally, it was proposed that a target be and Renewables the comments submitted on behalf of E.On Climate & Renewables set for renewable heat and electricity, and this was consulted Mr Rod in respect of the 'Core Strategy Issues & Options Paper' 2010 on upon at Issues and Options and within the document Towards Hepplewhite this issue. a Strategy for Low Carbon Energy for County Durham. General Prism Planning consensus was that the 20% renewable electricity by 2020 target was not sufficiently ambitious and that a 30% target by 2020 (with 12% renewable heat) was already established through the UK Renewable Energy Strategy. The County Durham Climate Change Strategy 2012 target of a 40% carbon emissions reduction by 2020 is to be used as the overarching target for the Local Plan. Mrs Christine The Town Council feel that a target of 26% renewable electricity by Support and comments noted. Originally, it was proposed Walton 2020 and a 6% renewable heat target by 2020 would be realistic that a target be set for renewable heat and electricity, and Great Aycliffe and achievable. The County is expected to meet 21% of renewable this was consulted upon at Issues and Options and within Town Council electricity by 2011/12. However, this is in the main due to the wind the document Towards a Strategy for Low Carbon Energy for renewables and the plan acknowledges that the County is nearing County Durham. General consensus was that the 20% capacity. County Durham is far ahead of many areas in our renewable electricity by 2020 target was not sufficiently renewable targets and as such 26% will be difficult, although ambitious and that a 30% target by 2020 (with 12% renewable achievable, to meet. In addition this will allow time for new heat) was already established through the UK Renewable technologies to emerge which may help to exceed the target of Energy Strategy. The County Durham Climate Change 26%. District Heating Systems should be encouraged but the impact Strategy, 2012 target of a 40% carbon emissions reduction on the quality and landscape of the area must be kept to a minimum. by 2020 is to be used as the overarching target for the Local Plan. Mr Martin Wood We consider that the renewable electricity target is insufficiently Comments noted. RWE Npower ambitious, firstly because the timescale proposed (to 2020) is short Renewables Ltd in comparison with the plan period and with the lead-in times for Originally, it was proposed that a target be set for renewable commercial scale energy developments; and secondly because the heat and electricity, and this was consulted upon at Issues targets are inconsistent with the stated policies of both the Core and Options and within the document Towards a Strategy for Strategy and of the consultation paper itself, which has the objective Low Carbon Energy for County Durham. General consensus that the targets should be significantly exceeded. was that the 20% renewable electricity by 2020 target was not sufficiently ambitious and that a 30% target by 2020 (with 12% renewable heat) was already established through the UK

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Respondent Question 2 - Do you agree with this approach and the Council Response suggested targets for renewable electricity and heat? (a). Planning Period It is not clear why a shorter planning period is Renewable Energy Strategy. The County Durham Climate advocated for renewable energy by comparison with other Change Strategy 2012 target of a 40% carbon emissions development needs. The stated objective of the Core Strategy Policy reduction by 2020 is to be used as the overarching target for Directions paper is to create a favourable context for investment by the Local Plan. The overall policy direction is clear therefore the private sector in renewable energy and associated energy to establish the conditions for investor confidence. In the infrastructure. The lead-in time for renewable energy projects is at longer term, before 2020, we will review the carbon reduction least as long as for other forms of development: possibly longer targets and will establish 5 year carbon reduction budgets, given the potential for controversy that the consultation paper with the aim of meeting the national targets of reducing acknowledges. If proposals are to be brought forward in response carbon emissions by 80% by 2050. to the Core Strategy in accordance with a plan-led approach to sustainable development (as the Plan for Growth Written Ministerial Statement advocates) the strategic plan should adopt a longer planning horizon, consistent with that for housing, employment and other development needs. This should not imply stretching the targets but rather increasing them.

(b). Target The adoption of a comparatively low target whilst expressing an aspiration to exceed it is a manifestation of the constraint-led approach that is evident throughout the consultation paper. The only reason given for favouring a comparatively low target appears to be concern over the planning challenges that would present. That is not consistent with national energy and planning policy, which has developed since the consultation paper was prepared (and since all of the evidence base documents to which it refers were prepared) through the publication of the Committee on Climate Change's latest report and through the adoption of the Committee's recommended national targets by Government. The evidence base for the Core Strategy needs to be revisited to reflect the imperatives now embodied in national policy so that a better balance between the need for renewables deployment and environmental constraints can be reflected in the County Plan.

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Respondent Question 2 - Do you agree with this approach and the Council Response suggested targets for renewable electricity and heat? Mr A Hunter Paragraph 5.7 - English Heritage would urge the Council to Comments noted. The Plan's influence is limited to English Heritage campaign for the introduction of visually non-intrusive energy consideration through the Development Management process. conservation measures in existing properties improved insulation, Adaptation of existing buildings is acknowledged as an issue more efficient boilers and thermostatically controlled radiators before for the future, but requires wider policy interventions and contemplating intrusive energy generation methods such as solar financial support mechanisms. panels and wind turbines. Just as there is an energy hierarchy so should there be a sequential approach to energy conservation/generation. By this means there is more likelihood of safeguarding local distinctiveness and the character and appearance of important elements of the historic environment of the county. English Heritage welcomes recognition of this as an issue later in paragraph 6.5. Paragraph 6.5 Question 2 - see above. Project Genesis Para 6.2 Question 2 . We are concerned that any targets set for Comments noted. The targets are intended as a minimum to Ltd generation of renewable electricity and/ or heat should not include be achieved rather than a 'cap' on development. Whilst Mr J P Haryley any upper cap or limit. The Sustainability Appraisal provides environmental limits should be considered, the meeting of Gifford indicative development figures for meeting the County's minimum targets is not in itself a limit to development. This is evidenced proposed renewable electricity targets. The example given indicates by the current policy approach to renewables. that targets could be met by the development of a single, large scale Biomass CHP plant. Our concern would be that if, the minimum targets having been exceeded, there was subsequently a presumption against further development then a de-facto quota system would develop leading to significant disincentives to further renewable electricity generation development. This scenario has recently occurred with DECC's attempt to cap development of photovoltaic energy installations by threatening to introduce a planning cap, a move which has seen private sector investment in PV collapse. We would suggest that any policy on targets should be clear in a presumption of support for renewable electricity developments over and above the stated targets. nlp client We broadly agree with the strategy outlined under Paragraph 6.5. Support and comments noted. unknown The Sustainability Appraisal clearly demonstrates that adopting the current RS target of 20% renewable energy by 2020 and no heat

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Respondent Question 2 - Do you agree with this approach and the Council Response suggested targets for renewable electricity and heat? Ms Kate McGill target is not appropriate, given that the County is expected to meet Originally, it was proposed that a target be set for renewable Nathaniel around 21% of electricity requirements through renewable sources heat and electricity, and this was consulted upon at Issues Lichfield & before 2011/2012. In this context a higher, more ambitious target and Options and within the document Towards a Strategy for Partners should be set for renewable energy and a heat target is required. Low Carbon Energy for County Durham. General consensus We suggest that the UK Renewable Energy Strategy's target of was that the 20% renewable electricity by 2020 target was not 30% renewable electricity and 12% renewable heat by 2020, as sufficiently ambitious and that a 30% target by 2020 (with 12% suggested in the Core Strategy Key Issues Report, would be an renewable heat) was already established through the UK appropriate target for the Core Strategy. However, we understand Renewable Energy Strategy. The County Durham Climate that this target has been reduced to 25% and 6% respectively to Change Strategy 2012 target of a 40% carbon emissions reflect the constraints to development within County Durham. We reduction by 2020 is to be used as the overarching target for reserve the right to comment on the suitability of this target pending the Local Plan. The overall policy direction is clear therefore a review of the evidence base that supports it. Please could you to establish the conditions for investor confidence. The make available information that supports this specific target as soon targets adopted are intended as a minimum to be achieved as possible? We support the approach that the two targets are not but need to be set in the context of assessed constraints to considered to be limits to development and that there is an aspiration ensure that they are achievable. Progress will be monitored to significantly exceed the targets depending on new capacity from throughout the Plan period. energy from waste and commercial scale biomass. As noted later in the Consultation Paper, the potential to exceed these targets may also come from improvements in technology and performance. We support the aspiration to significantly exceed the 2020 targets by 2030. However, we suggest that actual targets for the period between 2020 and 2030 should be set or there should be a mechanism within the Core Strategy to allow targets to be set for the period up to 2030 later in the plan period. In terms of how the targets will be met, the approach agreed through the Sustainability Appraisal of using a combination of Options A, B and C is appropriate. In particular in relation to windfarm sites we agree that: sites proposed outside the 'areas of least constraint' are not discounted, but scrutinised on a case-by-case basis within the life of the County Durham Plan, there is likely to be some potential for renewable wind energy development outside the areas identified in the RS, as long as development decisions are taken with a

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Respondent Question 2 - Do you agree with this approach and the Council Response suggested targets for renewable electricity and heat? strategic view and potential impacts are fully considered. It is also likely that a more robust evidence-base will need to be developed to inform such decisions.

Question 3 - AONB wind energy policy

Should the County Durham Plan include a policy on wind energy development affecting the North Pennines Area of Outstanding Natural Beauty, which affords the AONB the highest level of protection?

Respondent Question 3 - Should the County Durham Plan include a policy on wind energy Council Response development affecting the North Pennines Area of Outstanding Natural Beauty, which affords the AONB the highest level of protection? Mr Brian Burke Seems to be a lot of emphasis on wind power. It is not just the visual impact and noise Comments noted. The Preferred Options British that needs to be considered. Taking too much energy from the wind could destabilise contains policies on both Renewable Motorcycling other areas with changes in related environments due to shifting wind patterns, resulting Energy Development (21) and Wind Federation modification to energy conversion in plant life. Turbine Development (22). Policy 37 of Preferred Options on the AONB is now necessary due to the revocation of the RSS. Mr Alan Myers Answer to both - undoubtedly - YES. 1 Clearly, the impact that the additional number Support and comments noted. The of wind turbines would have on the landscape is very important. Para 6.4 acknowledges Preferred Options contains policies on 40% of the area is AONB, settlements are dispersed and there might be objections to both Renewable Energy Development rapid growth of onshore wind farms as seen over the last decade. Crucially, the does (21) and Wind Turbine Development (22). not indicate whether a significant increase in the number of pylons will be necessary Policy 37 of Preferred Options on the for connection to the national grid. 2 Although it is estimated to be very expensive in AONB is now necessary due to the the short term, it is worth mentioning that it is technically possible and desirable to lay revocation of the RSS. cables underground. 3 The relatively large ratio for area of land per unit of electricity generated by wind is also concerning.

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Respondent Question 3 - Should the County Durham Plan include a policy on wind energy Council Response development affecting the North Pennines Area of Outstanding Natural Beauty, which affords the AONB the highest level of protection? Mr Martin Kerby Yes. As well as the AONB designation, the North Pennine Moors is designated as a Support and comments noted. Whilst the RSPB Northern Special Protection Area for breeding bird populations of European importance. Some Localism Act will abolish RSS, the NPPF England region of these bird populations make use of areas outwith the Special Protection Area, protects protected species and their particularly during spring but also during the breeding season and in autumn. Some habitats by order of importance and important undesignated areas for SPA species fall outside the AONB designation as protection for SSSIs is carried through well. Given the potentially significant risks of collision and displacement from wind energy into the NPPF. HRA assesses the impact developments in such areas, the Core Strategy should include policy that provides a of any developments on SPA species. high level of protection to this and other SPAs in County Durham. It should also identify The Preferred Options contains that SPA species may also be sensitive to developments that take place outside of the hierarchical policies on protection of designated site boundaries. designated wildlife sites; the AONB; the coast; and also contains policies on both Renewable Energy Development (21) and Wind Turbine Development (22). Mr Mark Welsh Yes, such a specific policy should also be implemented for the Durham Heritage Coast Support and comments noted. Whilst the Seaham Town to preserve this award winning landscape. Heritage Coast will be protected, it is a Council non-statutory landscape definition whereas the AONB is a statutory designation. NPPF requires the highest level of protection for AONBs and National Parks, but also adds protection of the coastline and improved access to it, as well as other special environmental areas which protect the character of our country's landscape, and preserve wildlife. Policy 37 of Preferred Options on the AONB is now necessary due to the revocation of the RSS. The proposed approach provides the necessary protection and enhancement highlighted by the Sustainability Appraisal. Policy 38 protects the Heritage Coast and coast.

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Respondent Question 3 - Should the County Durham Plan include a policy on wind energy Council Response development affecting the North Pennines Area of Outstanding Natural Beauty, which affords the AONB the highest level of protection? The Preferred Options contains policies on both Renewable Energy Development (21) and Wind Turbine Development (22). Mr Simon Owens Yes, most certainly. However, given the importance of Teesdale's attractive landscape Support and comments noted. The for visitors and the importance of the tourism sector in the local economy, protection appropriateness of the protection of from wind turbine developments should not just be provided to the AONB but also other classic views such as Raby Castle, and areas in Teesdale. Examples of beauty spots outside the AONB include (but are not the protection of the setting of these limited to) the following examples: Raby Castle, which is in the designated South Durham areas will be considered in the Upland coalfield area; the iconic vistas of Teesdale from the B6282 between Eggleston formulation of Development Management & Middleton in Teesdale; various other stretches along the River Tees including the policies. The environmental impact of Egglestone Abbey ruins right down to the parish of Gainford which is the gateway to any proposals will be assessed on a Teesdale - note that work is currently being developed to enhance this landscape through case-by-case basis through the the Heart of Teesdale Landscape project. Most visitors to Teesdale come by motor Development Management process. The vehicle and the vistas from a number of roads in Teesdale outside the AONB is effectively Preferred Options contains policies on the primary attraction for visitors who in turn create the various employment opportunities both Renewable Energy Development for local folk. (21) and Wind Turbine Development (22). Policy 37 of Preferred Options on the AONB is now necessary due to the revocation of the RSS. E.ON Climate and That would appear sensible. E.ON Climate & Renewables accepts that whilst Support and comments noted. The Plan Renewables Government Policy does not rule out wind farm developments in Areas of Outstanding seeks a balanced approach, optimising Mr Rod Natural Beauty in such locations commercial wind farm developments would normally the contribution of renewable energy Hepplewhite Prism only be permitted in exceptional circumstances. However, we would wish to reiterate whilst ensuring appropriate safeguards Planning E.ON Climate & Renewables' view that elsewhere, including locally designated for the County's landscapes and the landscapes, such as Areas of High Landscape Value and statutory Green Belts, there amenity of local people. This necessarily should not be any presumption against commercial wind energy developments. involves a detailed understanding of the environmental constraints to deployment of new capacity, within the context of national policy. The Preferred Options contains policies on both Renewable Energy Development (21) and Wind

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Respondent Question 3 - Should the County Durham Plan include a policy on wind energy Council Response development affecting the North Pennines Area of Outstanding Natural Beauty, which affords the AONB the highest level of protection? Turbine Development (22). These are complimented by Policy 37 of Preferred Options on the AONB. Mrs Christine Yes. As with many planning matters certain areas must always have specific policies Support and comments noted. The Walton to deal with their uniqueness. In this particular instance the intrusion of wind turbines Preferred Options contains policies on Great Aycliffe in an Area of Outstanding Natural Beauty must be given the highest level of protection. both Renewable Energy Development Town Council In addition other special sties should also have specific policies. (21) and Wind Turbine Development (22). Policy 37 of Preferred Options on the AONB is now necessary due to the revocation of the RSS. Mr Martin Wood Questions 3 and 4 need to be considered together. The Broad Areas of Least Constraint Comments noted. RWE Npower established through the Regional Plan are, axiomatically, regional-tier designations that Renewables Ltd reflect that the identified broad areas are those with least constraint to wind energy The Broad Areas of Least Constraint development at a regional level. However, as the consultation paper records, further identified in RSS were identified as investigations at a local level have suggested that in County Durham areas regionally relatively unconstrained but were not identified as relatively unconstrained, such as the South Durham Coalfield Upland (for rigorously assessed in terms of their example), are in practice so constrained that they are most unlikely to achieve their actual available capacity. Instead, all were regionally-assessed potential. There is a fundamental inconsistency between the identified as having capacity for medium translation of areas, which assessed on a regional basis, are relatively unconstrained scale development, broadly identified as for wind energy development into local policies that preclude the regionally identified up to 20-25 turbines. In reality, some of potential from being achieved. As the Energy White Paper and the most recent advice the identified areas do not have this scale for the Committee on Climate Change emphasise, onshore wind remains the most of capacity, whilst others have capacity deliverable of all of the renewables technologies in the short to medium term and in to exceed this. The purpose of the local developing a low carbon energy strategy as part of the County Durham Plan Core level assessments was to more fully Strategy these conflicts in the evidence base need to be resolved, otherwise it runs the understand actual capacity of each risk that any significant contribution from the most deliverable technology will effectively identified area. However, differential be precluded. In the light of the proposed Spatial Vision and Strategic Objectives of the levels of available capacity do Core Strategy Directions paper the conflicts should be resolved in a way that sets a necessarily remove the justification for context to encourage private investment in renewable energy and that promotes and identification of each area as strategic facilitates deployment. This means reassessing the capacity for onshore wind energy areas for new development. There is development in the light of up to date national energy and planning policy. Map 1 shows therefore no conflict in the evidence sites where early pre-application procedures (such as EIA screening/scoping) have base; merely a clarification of actual

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Respondent Question 3 - Should the County Durham Plan include a policy on wind energy Council Response development affecting the North Pennines Area of Outstanding Natural Beauty, which affords the AONB the highest level of protection? been undertaken. The supporting text at paragraph 7.4 suggests that the prospect of a achievable capacity in each area. Map 1 future planning application may be taken as an indication that development will eventually merely reflects the status of each proceed on those sites. It is presumably not the intention of the consultation paper either proposed scheme in the planning to suggest that those schemes are acceptable in planning terms (before the applications process. There is no intention or have been considered) or that permissions on those sites would preclude other proposals presumption implied that planning from coming forward. That should be made clear in any future consultation of a similar permission will be granted for those kind. schemes that are not yet approved. The Preferred Options contains policies on both Renewable Energy Development (21) and Wind Turbine Development (22). Policy 37 of Preferred Options on the AONB is now necessary due to the revocation of the RSS.

Mr A Hunter Paragraph 7.1 contains the Sustainability Appraisal of the options put forward. It advises Comments noted. English Heritage that there are various constraints on the location of renewable wind energy development, but I observe that none specifically mentioned concern the desirability of safeguarding County Durham Plan policy has been the historic environment or its heritage assets. Whilst I would argue that heritage is not drafted to address protection of the an inhibitor to the extent that many commentators would have one believe, there does historic environment. need to be an acknowledgement that its protection is a material planning consideration and on occasions wind energy development would be inappropriate in relation to it. Paragraph 7.9 identifies a number of national or international designations. They include Durham Cathedral and Castle World Heritage Site. It should be noted that there are Policy 37 of Preferred Options on the other heritage asset types that are of national importance, such as wreck sites. Some AONB is now necessary due to the non-scheduled archaeology is nevertheless of national importance. Although important, revocation of the RSS. The proposed conservation areas are a local designation. Paragraph 7.10 it could be argued that approach provides the necessary national guidance exists to inform decision-making in designated areas such as the protection and enhancement highlighted AONB. Unless there is a need to overlay this with locally specific policy I suspect it will by the Sustainability Appraisal. The be ruled unnecessary. Preferred Options contains policies on both Renewable Energy Development (21) and Wind Turbine Development (22).

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Respondent Question 3 - Should the County Durham Plan include a policy on wind energy Council Response development affecting the North Pennines Area of Outstanding Natural Beauty, which affords the AONB the highest level of protection? Mr & Mrs J Pagella We wish to register our views on the above issue - specifically, the building of industrial Comments noted. The County Durham wind factories in County Durham. To us it seems that County Durham is being swamped Plan seeks to develop a balanced with wind factories and is in danger of being over-whelmed by them. One of our main approach to new renewable energy concerns is that a 2 km. exclusion zone should be introduced so that wind turbines development, including wind energy, cannot be built close to residents' homes (this guidance is used in Scotland and within the context of national policy, Cambridgeshire County Council is currently consulting on this). There is a growing including on noise. Optimising the evidence of health-related problems concerning noise and residents in other parts of contribution made within the County to the country have had to leave their homes (the current Davis's High Court case which renewable energy whilst at the same time has a high profile). In addition, there are reputable Doctors and Scientists who have ensuring appropriate safeguards for the carried out research, such as Doctor Nina Pierpont ("wind turbine syndrome"), Dr van County's landscapes and the amenity of den Berg and Professor Ffowes Williams. ETSU-R-97, the method used to predict wind local people, necessarily involves a turbine noise is clearly outdated. Fourteen years later turbines can be in excess of 110 detailed understanding of the metres and many professional acousticians believe, therefore, that ETSU should be environmental constraints to deployment reviewed. Indeed, the Renewable Energy Foundation believes that ETSU '97 "is not fit of new capacity, within the context of for purpose". We also believe areas such as Teesdale that depend greatly on tourism national policy. However, it is clear from and have large areas on AONB, should be protected from the building of wind turbines. available evidence that opportunities for There is data available to support the fact that tourism is affected by industrial wind further substantial commercial wind turbines (should you require references we can supply this information). We strongly developments are limited and that believe that County Durham should move away from wind power and focus on alternative alternative renewables technologies will forms of renewable energy such as biomass, hydro, etc. We support a moratorium on need to play a more prominent role in building wind turbines in County Durham. We understand that there is a possibility of order to meet future targets. The an amendment to the Localism Bill that would allow more people control over the siting Preferred Options contains policies on of renewable energy developments. both Renewable Energy Development (21) and Wind Turbine Development (22), which are complimented by Policy 37 of Preferred Options on the AONB.

Preferred Options Policy 22 includes an approach to stand off distances, which is considered to be reasonable, effective in protecting amenity, and defendable based on evidence and within the context of national policy.

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Respondent Question 3 - Should the County Durham Plan include a policy on wind energy Council Response development affecting the North Pennines Area of Outstanding Natural Beauty, which affords the AONB the highest level of protection? nlp client unknown Paragraph 11 of PPS22: Renewable Energy states that: 'In sites with nationally Comments noted. The NPPF continues Ms Kate McGill recognised designations (e.g. Areas of Outstanding Natural Beauty [.]) planning this protection of nationally designated Nathaniel Lichfield permission for renewable energy projects should only be granted where it can be landscapes, but also adds protection of & Partners demonstrated that the objectives of designation of the area will not be compromised by the coastline and improved access to it, the development, and any significant adverse effects on the qualities for which the area as well as other special environmental has been designated are clearly outweighed by the environmental, social and economic areas which protect the character of our benefits'. We support the policy approach set out in PPS22 and note that there are country's landscape, and preserve examples from across the country where wind energy schemes have been sensitively wildlife. Policy 37 of Preferred Options accommodated within and adjacent to AONBs and other protected landscapes. It is on the AONB is now necessary due to therefore important to consider each case on its own merits and not to assume that all the revocation of the RSS. The proposed wind energy development is inappropriate within nationally designated landscapes. In approach provides the necessary terms of whether a policy should be included in the Core Strategy on the North Pennines protection and enhancement highlighted AONB, we note that paragraphs 4.30 - 4.32 of PPS12 clarify that 'The Core Strategy by the Sustainability Appraisal. The should not repeat or reformulate national or regional policy' unless there is sound Preferred Options contains policies on evidence which demonstrates that there are 'local reasons for having greater detail than both Renewable Energy Development national or regional policy provides for, local circumstances which suggest that a local (21) and Wind Turbine Development (22). interpretation of higher-level policy is appropriate'. No local evidence has been provided to demonstrate that the policy approach set out in PPS22 is not appropriate in relation to the North Pennines AONB. We therefore consider that unless this local evidence can be provided, a specific policy on wind energy development in the North Pennines AONB is not required. Should the Council disagree with the approach of relying on guidance in PPS22 and provide evidence to show that a local policy is required, we note that the wording 'highest level of protection' is unhelpful and has the risk of inferring that no wind energy development is appropriate in the AONB. Furthermore, we suggest that the RS approach, that one or more turbines or a turbine with a hub height of 25m is unlikely to be acceptable and is considered to be too prescriptive.

Question 4 - Broad Areas of Least Constraint

Should the County Durham Plan identify and re-confirm the Broad Areas of Least Constraint (from Regional Spatial Strategy Policy 41) to guide development and ensure that it does not exceed environmental constraints?

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Respondent Question 4 - Should the County Durham Plan identify and re-confirm the Council Response Broad Areas of Least Constraint (from Regional Spatial Strategy Policy 41) to guide development and ensure that it does not exceed environmental constraints?

Mr Brian Burke Unsure of this proposal. Certainly do not exceed environmental constraints. Comment noted. British Motorcycling Federation

Mr Alan Myers Answer to both - undoubtedly - YES. 1 Clearly, the impact that the additional Comments noted. The approach chosen in policy 22 aims number of wind turbines would have on the landscape is very important. Para to provide the necessary certainty for both developers and 6.4 acknowledges 40% of the area is AONB, settlements are dispersed and there communities, given the limited capacity remaining in many might be objections to rapid growth of onshore wind farms as seen over the last areas. decade. Crucially, the does not indicate whether a significant increase in the number of pylons will be necessary for connection to the national grid. 2 Although it is estimated to be very expensive in the short term, it is worth mentioning that it is technically possible and desirable to lay cables underground. 3 The relatively large ratio for area of land per unit of electricity generated by wind is also concerning.

Mr Martin Kerby This seems to be a sensible approach, provided that the findings of the capacity Support and comment noted. The approach chosen in policy RSPB Northern England study are fully reported. It would be useful to map the Broad Areas of Least 22 aims to provide the necessary certainty for both region Constraint and the Policy Delivery Areas: they have similar names but different developers and communities, given the limited capacity boundaries, which can lead to confusion. remaining in many areas.

Mr Mark Welsh Given capacity is acknowledged to have broadly been reached County Durham Comments noted. The Plan acknowledges that further Seaham Town Council should not allow any future onshore wind farm development and should encourage opportunities for commercial scale wind energy are limited. out of sight offshore wind farm development and alternative renewable energy However, they are not entirely exhausted and any further production technologies. proposals will need to be considered on their merits, in the context of national policy. The approach chosen in policy 22 aims to provide the necessary certainty for both developers and communities, given the limited capacity remaining in many areas.

Mr Simon Owens No. However, my comment is only with regard to the South Durham Upland Comments noted in relation to capacity in South West Coalfield which is the area I am most familiar with. Leaving aside the significant Durham. Capacity studies were necessarily strategic in local concern and divisiveness caused by recent wind-farm proposals in the nature and impacts from any individual development Bolam, Hamsterley and Woodland areas my concern has the same basis as my proposals will need to be assessed against a full range of response to question 3. Teesdale also markets its attractiveness to bicyclists and criteria, including potential impacts on tourism the mountain bike trails at Hamsterley Forest along with the Sustrans cycle routes development. The approach chosen in policy 22 aims to through Teesdale are part of that local tourism offer. I do not believe Ove Arup provide the necessary certainty for both developers and & Partners Ltd took sufficiently into account the importance of Teesdale's visual communities, given the limited capacity remaining in many landscape to the nature of the local tourism offer in their report. Even though they areas.

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concluded that "the potential for development is limited to a few small, well separated clusters" I believe that exaggerates the opportunity for even small scale (albeit not small size/height turbines) developments, certainly in Zones S19 & S20 + S9 & S10.

E.ON Climate and Yes, with qualifications. If, as would appear to be the case, there is a strong desire Comments noted. Renewables to direct wind energy developments to particular areas of the County and away Mr Rod Hepplewhite from others then re-confirming the "Broad Areas of Least Constraint" for wind All further development proposals will be considered on Prism Planning energy developments as identifed by Policy 41 of the RSS would be a sensible their merits. The approach chosen in policy 22 aims to starting point. E.ON Climate & Renewables would be concerned if these areas provide the necessary certainty for both developers and were to be further refined without careful consideration of all relevant planning communities, given the limited capacity remaining in many criteria and the Government's renewable energy strategy. Indeed, E.ON Climate areas. & Renewables has strong reservations with the "Wind Farm Development and Capacity Studies" that were undertaken by Ove Arup and Partners on behalf of Given their non-statutory status, the Arup reports have the North East Councils. Not only do the studies take a narrow perspective and always been viewed as informative, as an aid to decision omit to consider all relevant matters, they are also non-statutory advisory making, rather than definitive. Furthermore, it has always documents which should be treated with caution and not be allowed to unduly been clear from the outset and the definition of Broad Areas influence emerging planning policy on wind energy developments. Furthermore, of Least Constraint in RSS, that development in the BALCs there should not be a presumption against commercial wind energy developments did not imply a presumption against development outside outside of the Broad Areas. Rather, the presumption should be worded to indicate the identified areas. proposals within the Broad Areas will be considered favourably and that elsewhere they will be considered on their planning merits, taking into account all other relevant planning considerations. Additional Comment: It is acknowledged that local planning authorities often view potential impact upon the landscape and All further development proposals will be considered on landscape character as one of the key material considerations when determining their merits. The approach chosen in policy 22 aims to planning applications for wind farm developments. However, E.ON Climate & provide the necessary certainty for both developers and Renewables are firmly of the opinion that a predicted change in the landscape communities, given the limited capacity remaining in many character of an area should not necessarily lead to the refusal of planning areas. permission, particularly where the site is not within a nationally or internationally designated area (which would in any case usually indicate a presumption against prevent wind farm development). In other words, just because a landscape character is predicted to change as a consequence of the proposed wind farm development proceeding, this should not by itself be regarded as a "show-stopper" for wind farm development. Indeed, there is an acknowledged national need to increase renewable energy capacity by 2020 and 2050 and onshore wind will continue to have a big part to play in achieving this. Accordingly,landscape change is going to be inevitable in certain areas if the national need is to be met.

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Mrs Christine Walton Yes. It appears that many areas of County Durham are nearing capacity for wind Comments noted. The approach chosen in policy 22 aims Great Aycliffe Town energy development (turbines) the environmental constraints of each area should to provide the necessary certainty for both developers and Council be a key planning policy consideration. communities, given the limited capacity remaining in many areas.

Miss Karen Johnson Broad areas of least constraint are a useful tool to help ensure that the landscape Comments noted. The duty to co-operate and the views of Darlington Borough is able to accommodate an appropriate level of wind farm development. Given other Local Planning Authorities has informed the process. Council the extent of wind farm development that exists in Durham, the amount of The approach chosen in policy 22 aims to provide the proposed schemes, and the available land area in Durham where wind farms necessary certainty for both developers and communities, could potentially be accommodated we would welcome the inclusion of broad given the limited capacity remaining in many areas. The areas of least constraint or some similar delineation to ensure that wind farm Broad Areas of Least Constraint address cross boundary development does not exceed the capacity of the landscape particularly along issues, and any review of them would necessarily need to the boundary with Darlington. This would be consistent with the ARUP reports. take place on a collaborative, cross boundary basis, in line Consideration should be given in policy to the cumulative impact of wind farm with the duty to cooperate. We continue to work with other development, particularly cross boundary impact, to ensure that existing and LPAs as part of the duty to co-operate. proposed development in Durham together with Darlington does not exceed the capacity of the landscape.

Mr. Bob Stratford Having attended the consultation meeting in Sedgefield on the 15 th June 2011 Comments and objections noted. Mordon Parish Meeting re the above document I would like to state the position of the Mordon Parish Meeting on this document, in particular with reference to future wind energy development within our area of County Durham. We disagree with the council's approach for future wind energy development within our area as it has not been The Broad Areas of Least Constraint identified in RSS were demonstrated that sufficient weight is to be applied to the Arup studies or to Saved identified as relatively unconstrained but were not Policies, in particular Saved Policy E3. Saved Policy E3 states that:- "The council rigorously assessed in terms of of their actual available will seek to conserve the historic landscape character of the Bradbury, Mordon capacity. Instead, all were identified as having capacity for and Preston Carrs when approving proposals by ensuring that they do not damage medium scale development, broadly identified as up to the character or appearance of the area". The Parish Meeting is of the opinion 20-25 turbines. In reality, some of the identified areas do that this policy has been forgotten during the reorganization of the unitary not have this scale of capacity, whilst others have have boundaries resulting in the abolishment of Sedgefield Borough Council or that capacity to exceed this. The purpose of the local level there is no general knowledge of this, and other relevant policies, within Durham assessments, carried out by Arups, was to more fully County Council. Our concern, obviously, lies with the recent planning application understand actual capacity of each identified area. by EON, now withdrawn, relating to the A1 Wind Farm and the now pending Although not forming part of the statutory development application, again by EON, for a far larger wind farm (The Isles) covering the plan, these studies will continue to be material Carrs and the Isles which if submitted will be contrary to Saved Policy E3 and considerations in the assessment of any development will cover any area identified as a Conservation Area and, in parts, an area of proposals within the study areas. Special Scientific Interest. A situation that cannot be condoned. It should also be

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noted that the possible Isles development not only lies within the area protected by Saved Policy E3 but a very large scheme greater than 50MW's in the Carrs would not be consistent with the findings of the Arup Study as it would occupy Saved Policy E3 remains part of the statutory development an area largely identified as having a capacity of "None/ very limited", with a plan until the adoption of the County Durham Plan. maximum wind farm of less than 4 turbines. It is our understanding that until such time that a new plan is in force, both information from the Regional Spatial Strategy and Saved Policies will apply. We would seek assurances that these will be carried forward in some format in order that protection of this "unique area" is In terms of the submission of the Isles proposal, to the continued. Despite the Arup landscape capacity studies, the council are asking Planning Inspectorate (formerly IPC) as nationally if we agree with their approach to further develop "Broad Areas of Least significant infrastructure (>50MW), the County Council will Constraint". Our understanding of a Broad area of Least Constraint is that the have a statutory role in the process, as set out in the whole area is not of least constraint, and that the council should be mindful of Planning Act 2008. this. Indeed, is it not more important to protect those areas that are deemed important or special, in order that the whole area is not violated? We consider that the current situation of:-operational; approved; and planned submitted wind farms throughout the Tees Plain will exceed the landscape capacity of our The approach chosen in policy 22 aims to provide the immediate area. We also consider that the Local Authority seem to distance necessary certainty for both developers and communities, themselves from "THE ISLES" Project, when in fact according to the IPC "Local given the limited capacity remaining in many areas. Authorities play a pivotal role in the process." We would expect that strong representation be made at the very earliest stage to avoid any possibility of a "GENERATING STATION" being built on the protected unique Carrs. We trust that The Council will use our response to inform the further development of the Core Strategy and that the comments will help to decide which strategy and proposals would be best to pursue.

Mr Martin Wood Questions 3 and 4 need to be considered together. The Broad Areas of Least Comments noted. All further development proposals will RWE Npower Constraint established through the Regional Plan are, axiomatically, regional-tier be considered on their merits. The approach chosen in Renewables Ltd designations that reflect that the identified broad areas are those with least policy 22 aims to provide the necessary certainty for both constraint to wind energy development at a regional level. However, as the developers and communities, given the limited capacity consultation paper records, further investigations at a local level have suggested remaining in many areas. that in County Durham areas regionally identified as relatively unconstrained, such as the South Durham Coalfield Upland (for example), are in practice so constrained that they are most unlikely to achieve their regionally-assessed potential. There is a fundamental inconsistency between the translation of areas, which assessed on a regional basis, are relatively unconstrained for wind energy development into local policies that preclude the regionally identified potential from being achieved. As the Energy White Paper and the most recent advice for

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the Committee on Climate Change emphasise, onshore wind remains the most deliverable of all of the renewables technologies in the short to medium term and in developing a low carbon energy strategy as part of the County Durham Plan Core Strategy these conflicts in the evidence base need to be resolved, otherwise it runs the risk that any significant contribution from the most deliverable technology will effectively be precluded. In the light of the proposed Spatial Vision and Strategic Objectives of the Core Strategy Directions paper the conflicts should be resolved in a way that sets a context to encourage private investment in renewable energy and that promotes and facilitates deployment. This means reassessing the capacity for onshore wind energy development in the light of up to date national energy and planning policy. Map 1 shows sites where early pre-application procedures (such as EIA screening/scoping) have been undertaken. The supporting text at paragraph 7.4 suggests that the prospect of a future planning application may be taken as an indication that development will eventually proceed on those sites. It is presumably not the intention of the consultation paper either to suggest that those schemes are acceptable in planning terms (before the applications have been considered) or that permissions on those sites would preclude other proposals from coming forward. That should be made clear in any future consultation of a similar kind.

Ms C Straughan As you will be aware, questions 4, 9 and 11 refer to the Tees Plain broad area Comments noted. The approach chosen in policy 22 aims Stockton on Tees of least constraint for wind energy developments, which was identified in RSS to provide the necessary certainty for both developers and Borough Council Policy 41. As you have acknowledged in the document, the Tees Plain designation communities, given the limited capacity remaining in many crosses a number of administrative boundaries, including Stockton Borough areas. We continue to work with other LPAs as part of the Council's. The Council has the following comments regarding reaffirming the area duty to co-operate. The Broad Areas of Least Constraint of least constraint designation as advocated in the document. These can be address cross boundary issues, and any review of them summarised as follows: 1. As you will be aware the Localism Bill will abolish the would necessarily need to take place on a RSS, the original vehicle for this designation. It is also intended that the Localism collaborative,cross boundary basis, in line with the duty to Bill will introduce a duty to co-operate between Local Authorities to maintain cooperate. joined up planning between areas. Given the above, it is considered that this designation, which crosses a number of local authorities, should only be reaffirmed if the relevant Councils agree that it remains appropriate, in accordance with the duty to co-operate. 2. The Durham Core Strategy is a document, which is intended to plan for the County until 2030. In deciding whether to reaffirm the designation, Durham County Council should be satisfied that any areas designated as being of least constraint have the capacity to remain so for all or a significant part of the plan period. Stockton Borough Council anticipates that the area of land within

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the borough will begin to be constrained by wind farm planning permissions and development in the near future. Whilst planning applications will continue to be determined on a case-by-case basis against national policy, it is anticipated that designating the part of Stockton Borough that falls within the Tees Plain as an area of least constraint will be an unsound approach, taking in to account approved and operational wind turbines.

Mr A Hunter Paragraph 7.17 Question 4 - English Heritage considers it helpful to bring forward Support and comments noted. The approach chosen in English Heritage the concept of Broad Areas of Least Constraint used as the basis for Regional policy 22 aims to provide the necessary certainty for both Spatial Strategy policy. developers and communities, given the limited capacity remaining in many areas.

nlp client unknown We broadly support the approach outlined in Question 4, although it should be Support and comments noted. Each proposal will be judged Ms Kate McGill Nathaniel confirmed within the accompanying policy that development outside these areas upon its own merits. The approach chosen in policy 22 aims Lichfield & Partners is not inherently less appropriate, subject to site specific considerations. This is to provide the necessary certainty for both developers and acknowledged at Paragraph 7.1 of the Consultation Document. communities, given the limited capacity remaining in many areas.

Question 5 - District heating schemes

Should the Council require connection to an existing or approved district heating scheme, as a condition of planning permission for major development, where viable opportunities exist ?

Respondent Question 5 - Should the Council require connection to an existing or Council Response approved district heating scheme, as a condition of planning permission for major development, where viable opportunities exist ?

Mr John Lowe Yes, this is essential to promote energy efficiency. Comment noted. Policy 17 of Preferred Options on Sustainable Design in the Built Environment sets out our approach and requires major development to connect to an existing or approved district heating scheme, where viable opportunities exist.

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Mr Alan Myers Yes. Regarding paragraphs 7.27 and 7.28 and 7.29 on landfill and anaerobic Comment noted. Policy 17 of Preferred Options on digestion: The feasibility of using the CO 2 and heat from the combustion of Sustainable Design in the Built Environment sets out our methane to enhance the growth of crops in greenhouses located at sites could approach and requires major development to connect to an be explored. existing or approved district heating scheme, where viable opportunities exist.

Mr Mark Welsh Yes. Comment noted. Policy 17 of Preferred Options on Seaham Town Council Sustainable Design in the Built Environment sets out our approach and requires major development to connect to an existing or approved district heating scheme, where viable opportunities exist.

Mr Simon Owens What is meant by major development? How many opportunities for large Comment noted. Opportunities for major development will developments are there in the off gas network Durham Dales area? Few, if not be limited in the Durham Dales area. Policy 17 of Preferred none! DCC is demonstrating a lack of ambition with regards to developing biomass Options on Sustainable Design in the Built Environment sets (for which there is the opportunity of supply from local woodlands) as a credible out our approach and requires major development to connect alternative for the many existing dwellings in the dales currently dependent on to an existing or approved district heating scheme, where coal for heating. What are you planning to do to develop "the supply chain, viable opportunities exist. especially in rural areas (that) will help to relieve fuel poverty and reduce carbon emissions in sustainable way"??

Mrs Christine Walton Yes where such a development is being considered the merits of a district heating Comments noted. Impacts of any district heating projects Great Aycliffe Town scheme should be a planning condition. However it is recognised that this cannot would need to be fully assessed for their suitability. Policy Council be a blanket condition as the detrimental impact on some areas would far outweigh 17 of Preferred Options on Sustainable Design in the Built the value of a district heating scheme. Environment sets out our approach and requires major development to connect to an existing or approved district heating scheme, where viable opportunities exist.

Mr A Hunter Paragraph 7.22 Question 5 no observations. Noted. English Heritage

Project Genesis Ltd We are of the view that a proposal to require connection to an existing/ approved Comments and objections noted. Operational and financial Mr J P Haryley Gifford district heating scheme as a condition of planning is inappropriate. Unlike electrical issues raised have typically been addressed through the network connections the engineering required for connecting district heating formation of an Energy Services Company (ESCO) and this systems to heat generating facilities is much more complex. Operational efficiency would appear to be the most appropriate means of on both sides of the connection, i.e. the generating system and the district system, undertaking and managing district heating in the future. is significantly dependant on the connection itself and thus complex issues Policy 17 of Preferred Options on Sustainable Design in the

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regarding liability for system performance, on both sides of the connection, may Built Environment sets out our approach and requires major be created. A policy which forces a generating development to connect to a development to connect to an existing or approved district specified district system, the performance of which then adversely affects the heating scheme, where viable opportunities exist. performance of the generating facility, would create both legal and financial liability problems for any operators, investors and regulators. The need or desirability of connection to district systems should be determined by the operators of those systems only. In terms of planning, a caveat of viability would be of limited benefit because of issues relating to the definition of viability; on what criteria would viability be judged and by whom. The forthcoming European Renewable Heat Directive will inform national policy in this area and we would suggest that it would be more appropriate to formulate a more detailed policy in respect of this issue after the Directive has been published. We would recommend that at this stage the policy should be to ensure that reasonable provision is made in any generation development to allow for further connect to a district system. Para 7.23 From a sustainability perspective we would suggest that the future of energy from waste (EfW) schemes will be the development of small scale, local distributed (embedded) community schemes, relying less on collection and transport and therefore more sustainable. We are therefore of the view that it would be wrong to exclude EfW from the Plan at this stage and that the opportunity to bring forward appropriate EfW schemes must form part of any sensible Low Carbon Energy Strategy.

Mr Richard Pow Towards a Low Carbon Strategy Consultation Paper Comments noted. Policy 17 of Preferred Options on Sustainable Design in the Built Environment sets out our Forestry Commission - Para 7.19 -We are pleased to see the recognition given to smaller scale biomass approach and requires major development to connect to an North East England schemes supplied by domestic wood sources. This is consistent with the Wood existing or approved district heating scheme, where viable Fuel Implementation Plan published by the FC earlier this month. Small scale opportunities exist. Sustainability considerations such as schemes are able to make use of local wood supplies, avoiding long transport employment impacts and effects on wood-using industries distances. Developing the supply chain is an important factor. As well as relieving will be weighed up in the planning balance when determining fuel poverty and reducing carbon emissions, small scale wood fuel also helps to applications. bring neglected woodlands back into management, improving their biodiversity. A reference to the Renewable Heat Incentive (RHI) would be appropriate here (also mentioned under "solar" in para 7.24).

Para 7.20 "Any proposal based on wood pellet importation would also need to address sustainability considerations" add "including the impact on existing wood-using industries". There are sustainability issues if biomass plants suck in

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local timber which would otherwise go into long-lived timber products. There may also be employment impacts. These considerations apply equally to any other form of imported wood.

Question 6 - Local targets for decentralised energy

Should the County Durham Plan set local targets for decentralised energy? If so: A. should local requirements continue to develop the approach taken by the RSS to include a set amount of renewable energy generation in new development (e.g 10%, rising to 20% in line with national targets); or B. should local targets be set against nationally recognised criteria, such as the Code for Sustainable Homes (CSH) and/or BREEAM?

Respondent Question 6 - Should the County Durham Plan set local targets Council Response for decentralised energy? Mr Brian Burke Agree with Option B. Preference noted. Policy 17 'Sustainable Design in the British Motorcycling Built Environment' of Preferred Options sets out the Federation approach to decentralised energy. Mr Alan Myers Yes. Option B. Preference noted. Policy 17 'Sustainable Design in the Built Environment' of Preferred Options sets out the approach to decentralised energy. Mr Mark Welsh Yes - option B. Preference noted. Policy 17 'Sustainable Design in the Seaham Town Council Built Environment' of Preferred Options sets out the approach to decentralised energy. Mr Simon Owens B is preferable. However greater thought needs to be given to Preference and comments noted. Policy 17 linking building regs and energy efficiency requirements for new 'Sustainable Design in the Built Environment' of build with the locally available energy supply. In other words higher Preferred Options sets out the approach to energy efficiency requirements for areas off the gas network and decentralised energy. planning on utilising coal or oil as the heating energy source.

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Respondent Question 6 - Should the County Durham Plan set local targets Council Response for decentralised energy? Mr A Hunter Paragraph 8.1 helpfully acknowledges the 'significant' opportunities Comments noted. Policy 17 'Sustainable Design in the English Heritage to reduce the carbon emissions of the existing building stock, Built Environment' of Preferred Options sets out the whilst accepting that the Core Strategy necessarily focuses on approach to decentralised energy. new development. Opportunities do exist, however, in relation to Section 10 below. Paragraph 8.7 “ Question 6 “ it would be consistent with this government's approach were the Council to set for itself local, yet challenging, targets. Project Genesis Ltd Question 6 and para 8.7 Local targets for decentralised energy Preference and comments noted. Policy 17 Mr J P Haryley Gifford should be set in conjunction with targets for carbon etc, set against 'Sustainable Design in the Built Environment' of nationally recognised criteria. I.e. a combination of A & B. The Preferred Options sets out the approach to nationally recognised criteria referred in to question 6 relate decentralised energy. specifically, to individual developments/ development of individual buildings or facilities and as such may, on their own, be too restrictive in achieving optimum, economically viable carbon reductions in relation to wider scale estate development. I.e. overall site considerations, viability etc, may dictate that a global, off-site renewable energy solution may provide a better carbon outcome than meeting specific, and possibly excessively expensive, carbon requirements for specific buildings. Our suggestion would be that a mix of renewable electricity generation targets in conjunction with nationally recognised criteria (e.g. CSH, BREEAM etc) would provide better flexibility to ensure commercial viability, from a development perspective, whilst still achieving an optimum carbon reduction solution. Partner Construction Ltd In the same respect, any percentage targets for renewable energy Comments noted. Policy 17 'Sustainable Design in the Mr Alastair Willis Signet contributions from development proposals should consider the Built Environment' of Preferred Options sets out the Planning potential conflicts with other energy efficiency requirements set approach to decentralised energy. The approach to out in the Building Regulations. We trust the above representations sustainable buildings through the County Durham are straight forward and will be afforded significant weight in the Plan is based on an understanding of developing Council's consideration of its emerging Core Strategy. It is national standards and Building Regulations fundamental to the soundness of the emerging Core Strategy to requirements to avoid duplication. Accordingly, the ensure that the entire evidence base which informs the Core Strategy is available to consultees at the time of consultation.

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Respondent Question 6 - Should the County Durham Plan set local targets Council Response for decentralised energy? Preferred Options is clear that the Building Regulations will set the minimum standards for energy efficiency in new buildings Keepmoat Homes In response to the questions set out within the Low Carbon Comments noted. Policy 17 'Sustainable Design in the Mr John Wyatt Signet Strategy, it is considered that, on the whole, the requirements for Built Environment' of Preferred Options sets out the Planning individual developments are appropriately dealt with through approach to decentralised energy. The approach to Building Regulations and the increase in Building Regulation sustainable buildings through the County Durham requirements, towards zero carbon in 2016. In this respect, Plan is based on an understanding of developing paragraph 30 of PPS1: Delivering Sustainable Development states national standards and Building Regulations that: 'Planning policies should not replicate, cut across, or requirements to avoid duplication. Accordingly, the detrimentally affect matters within the scope of other legislative Preferred Options is clear that the Building requirements, such as those set out in Building Regulations for Regulations will set the minimum standards for energy energy efficiency'. In the same respect, any percentage targets efficiency in new buildings for renewable energy contributions from development proposals should consider the potential conflicts with other energy efficiency requirements set out in the Building Regulations.

Question 7 - A Carbon Offset Fund

Do you support the proposal for a Carbon Offset Fund for County Durham? If so, what types of projects should the Fund support? Examples could include: A. Peatland restoration B. Woodland and forestry creation C. Energy efficiency grants D. Renewable energy grants

Respondent Question 7 Council Response Mr John Lowe I do support the creation of this fund which should be used Comments and preference noted. Policy 17 'Sustainable Design to combat fuel poverty. in the Built Environment' of Preferred Options sets out the approach to carbon offsetting with the creation of the 'Allowable Solutions Fund' from 2016.

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Respondent Question 7 Council Response Mr Brian Burke I support energy efficiency grants to improve current housing Comments and preference noted. Policy 17 'Sustainable Design British Motorcycling stock and commercial operations. in the Built Environment' of Preferred Options sets out the Federation approach to carbon offsetting with the creation of the 'Allowable Solutions Fund' from 2016. Mr Alan Myers YES; but how will the price of a unit of C be set? The Comments and preference noted. The national carbon price examples given are worthy of support. In addition the following would be used as the indicator for the price per unit of carbon should be considered: CCS, e.g. pipe network to link CO 2 in County Durham. However there remains the option of setting from manufacturing sites such as the proposed Hitachi plant a different rate for the County before the national rate takes to Teesside network. CCS projects at DEI and Newcastle effect in 2016. Policy 17 'Sustainable Design in the Built University. Environment' of Preferred Options sets out the approach to carbon offsetting with the creation of the 'Allowable Solutions Fund' from 2016. Mr Mark Welsh Yes with a primary focus on energy efficiency and renewable Comments and preference noted. Policy 17 'Sustainable Design Seaham Town energy grants to improve current housing stock. New in the Built Environment' of Preferred Options sets out the Council developments should have explicit conditions in order to approach to carbon offsetting with the creation of the 'Allowable achieve planning consent to ensure developers construct the Solutions Fund' from 2016. most energy efficient buildings they can, with renewable energy technologies such as solar panels stipulated. Mr Simon Owens Yes (energy efficiency grants) but with a caveat. The objective Comments and preference noted. Policy 17 'Sustainable Design should be to get the best carbon reduction possible and low in the Built Environment' of Preferred Options sets out the energy costs for occupants. The danger could be that approach to carbon offsetting with the creation of the 'Allowable affordable housing hardly ever meets the prescribed targets Solutions Fund' from 2016. in order to minimise construction costs with a consequent higher energy costs for the resident than would be the case if requirements were met. That does not help the fuel poverty agenda. A local authority could be enticed into building up the Fund to finance other development, which is currently a temptation with section 106. Mrs Christine Walton The Town Council fully supports and welcomes the proposals Comments and preference noted. Policy 17 'Sustainable Design Great Aycliffe Town for a carbon offset fund for County Durham. However it would in the Built Environment' of Preferred Options sets out the Council be difficult to limit the fund to only one of the options given. approach to carbon offsetting with the creation of the 'Allowable Area specific funds may be a more suitable approach to Solutions Fund' from 2016.

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Respondent Question 7 Council Response consider and in many instances more than one type of project could be considered when a development fails to meet the carbon reduction requirements. Mr Nicholas We would support this proposal in the context of a wider Comments and preference noted, in relation to opportunities for Sandford strategy to reduce, as well as offset, carbon emissions and small scale biomass. Policy 17 'Sustainable Design in the Built The Woodland Trust also measures to enable adaptation to climate change. We Environment' of Preferred Options sets out the approach to particularly would like to see some emphasis given to option carbon offsetting with the creation of the 'Allowable Solutions B, use of woodland and forestry creation. We would like to Fund' from 2016. see more use of wood as a fuel providing that harvesting is carried out sensitively and respects the biodiversity, scale and cultural importance of the site especially ancient woods. We believe that woodland owners can benefit from the developing markets for wood fuel and that income streams generated would help owners deliver environmental and social benefits from their woods to society. Developing a market for low-grade timber through wood fuel projects could also make other woodland management operations with a high biodiversity benefit more economically viable, for example the restoration of planted ancient woodland sites currently under non-native conifers. Harvesting methods must, however, be undertaken sensitively. It is vital that management of ancient woodland, long established plantations and coppice woodland for the production of wood fuel should be grounded in high standards of management for protection and enhancement of biodiversity. In ancient woodland it is important that plenty of dead wood remains, that veteran trees are protected and that coppicing is only undertaken after expert advice. Adherence to certification standards under the Forest Stewardship Scheme or UK Woodland Assurance Scheme would help to prevent inappropriate harvesting operations. This should be regulated through the Woodland Grant Scheme and the felling licence system to ensure that these woods are restored and managed in a sensitive way. Use of timber from existing woodland can

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Respondent Question 7 Council Response play an important role in sustaining rural communities, providing employment opportunities in timber harvesting and transport and supply chains. Government estimates that a medium scale 20MW wood-fired power plant (supplying energy for around 20,000 homes) would provide full-time employment for 48 permanent staff and significant short-term employment opportunities. We favour development of smaller plants serving around 5,000 homes which would still provide significant economic benefits to local communities. This would help to support the forestry sector and would offer valuable diversification opportunities for farmers. Mr A Hunter Paragraph 10.3 “ Question 7 “ a Carbon Offset Fund could Comments and preference noted. Policy 17 'Sustainable Design English Heritage legitimately be used to help finance (C) energy saving in the Built Environment' of Preferred Options sets out the measures in the existing building stock. English Heritage approach to carbon offsetting with the creation of the 'Allowable would support such an arrangement Solutions Fund' from 2016. Project Genesis Ltd Para 10 & Question 7 In principle we would support a proposal Comments and preference noted. Policy 17 'Sustainable Design Mr J P Haryley for a carbon offset fund. However, we would suggest that in the Built Environment' of Preferred Options sets out the Gifford policies in connection with such a fund are co-ordinated with approach to carbon offsetting with the creation of the 'Allowable current national support systems. The award of central, Solutions Fund' from 2016. Renewable Energy Grants, designed to support renewable energy projects with capital grants or on-going revenue support (such as tariff support), can preclude renewable energy developments from accessing other funding support, such as the Renewable Obligation Credit (ROCs). Subsidiaries, such as ROCs, are frequently the deciding factor in determining the viability of renewable energy projects, and any fund providing grants should be properly coordinated with other national support mechanisms to ensure that there is no conflict which may act as a disincentive to renewable development/ investment. Para 11.6 and 7.13.1 Para 11.6 appears to directly contradict para 7.13.1. The latter states that the level of wind development in the North Durham Coalfield Upland exceeds the scale of development envisaged in the RSS, whilst the former states that for the North Durham

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Respondent Question 7 Council Response Coalfield Upland: . . . . . despite some minor scale wind energy schemes, the only operational commercial wind energy scheme is a size 220KW turbine facility generating at Green Croft Industrial Estate. We are of the view that there remains significant opportunity for appropriate scale on-shore wind development in the North Durham Delivery area and would expect the Plan to further encourage such development. Sarah Jennings Should a Carbon offset fund be set up, we would agree that Comments and preference noted. Policy 17 'Sustainable Design Environment Agency peatland restoration should be included in the potential in the Built Environment' of Preferred Options sets out the projects that could be funded. We also considered whether approach to carbon offsetting with the creation of the 'Allowable funds could be directed towards additional upgrades to Solutions Fund' from 2016. sewage treatment works, which is a carbon intensive process. We are aware that NWL are moving in this direction through the AMP programme and through other funding, so perhaps this additional funding stream would not be appropriate. However as capacity is an issue in some areas of County Durham, it may be worth considering this as a possibility as it has the potential to address two issues simultaneously. Hydropower - This section refers to a study done by babyHydro for RENEW. We have also carried out some 'opportunity mapping' for hydro development which assesses and maps opportunities for hydropower similar to the RENEW study, however using different criteria in defining feasibility. Our study emphasized using existing structures that could be developed to incorporate a hydropower scheme, and other environmental constraints rather than considering areas where new obstructions would be required. In our study we found that County Durham had some of the highest hydropower potential in the country, but also with the greatest environmental sensitivity. We identified 490 barriers that could be suitable, although many of these sites will not be viable due to environmental or physical constraints. Both studies are a broad assessment of capacity and do not replace the need for a site assessment. A summary of this report is

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Respondent Question 7 Council Response available on our website.(a) We would strongly suggest that we come to an agreement on appropriate methodology for identifying potential hydropower sites which can then be used to support this and future documents. Paragraph 7.30 is somewhat misleading; reference to low flow head, should refer to low flow or low head. Recommend redrafting as below. ˜Hydro power is a relatively under utilised resource in County Durham. Although the region's rivers do not offer large scale hydro power resources, the potential still exists for small scale domestic and community use which should be further encouraged and developed where appropriate.'

a. http://publications.environment-agency.gov.uk/PDF/GEHO0310BRYF-E-E.pdf

Question 8 - North Durham Delivery Area approach

Do you agree with the approach for future energy development in the North Durham Delivery Area? (Please explain why you agree or disagree).

Respondent Question 8 - Do you agree with the approach for future energy Council Response development in the North Durham Delivery Area? (Please explain why you agree or disagree). Mr Brian Burke I would like to see more effort given to improving photo-voltaic cell Comment Noted. However efficiency of particular British Motorcycling efficiency. technologies is beyond the scope of the Plan. The Federation criteria based approach taken in policies 21 (Renewable Energy Development) and 22 (Wind Turbine Development) of Preferred Options is based on the combination approach preferred by respondents. Mr Alan Myers I would consider changing the title for Section 11 to accommodate Comments noted. Many of the suggestions put forward CCS development and modifying para 11.2 thus: Other renewable would need to be instigated by commercial decisions energy technologies will need to come on stream throughout the Plan by private companies, within the context of national

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Respondent Question 8 - Do you agree with the approach for future energy Council Response development in the North Durham Delivery Area? (Please explain why you agree or disagree). period to enable the County to meet challenging new renewable policy, (particularly support for carbon capture and energy targets, and longer term aspirations. In addition, the storage) and are therefore beyond the scope of the Plan. development of technologies involved in CCS and of industrial The Plan can, however, map out opportunities for a infrastructures that enable CO 2 emitted from certain processes to range of renewable technologies and environmental feed into other processes that use it up (e.g. plant and algal growth and technical constraints in the County, and can assess for food and biofuels). Such advances should contribute to wider alternative site options through sustainability appraisal. carbon reduction commitments that have already been set nationally. The criteria based approach taken in policies 21 The following points also relate to section 11 and questions 8-11 (Renewable Energy Development) and 22 (Wind Turbine generally. Unqualified support for the wind developments mentioned Development) of Preferred Options is based on the for each area (including in areas of least constraint) should not be combination approach preferred by respondents. given without consideration of the following. Comparing the potential carbon footprints, increase in generating capacity and environmental impacts (including numbers of pylons) for the whole NE region resulting from the following alternatives: 1 No onshore wind developments, but instead construction of one or more power stations fuelled by biomass or coal (with CCS) located within one or more industrial parks e.g. Consett in the northern area or Aycliffe or Shildon (Hitachi plant) in South Durham (say 0.25 GW, i.e. about half the size of Lynemouth and equivalent to at least 150 - 2 MW wind turbines). These power stations ideally should be integrated with CO 2 capture from manufacturing processes in the industrial parks and storage or use of the CO 2 in enhancing plant or algal growth. I appreciate there may be problems with getting raw materials to such stations. Para 6.4 suggests that a coastal port is necessary for import of biomass; similarly coal might need to be imported. Nevertheless, the avenue should be explored. 2 A strategy that involves no further onshore wind developments but recognises that the regional generation (low carbon) will increase with one or more of the following: (i) the offshore wind developments in the North Sea; (ii) possible development of CCS at Lynemouth power station to be fuelled with biomass and coal and the coal-fired new power station with CCS proposed at Teesside (south bank of Tees); (iii) new nuclear station at Hartlepool in 2020s (likely to generate 2-3 times more than the present one of 1200MW).

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Respondent Question 8 - Do you agree with the approach for future energy Council Response development in the North Durham Delivery Area? (Please explain why you agree or disagree). The amount of land used up per unit of electricity generated is much greater for wind than for coal, gas or nuclear. Science magazine (Aug 2010) estimates the ratios for wind/coal, wind/gas, wind/nuclear in terms of land area per unit of electricity generated are 14, 180 and 13 respectively. This makes onshore wind generation unfavourable. Question 8 YES, broadly. But see above comments on reservations concerning wind developments and possible developments at Consett. Mr Martin Kerby The North Pennine Moors SPA falls within the western portion of the Comments noted. The Plan's proposed approach as set RSPB Northern North Durham Delivery Area, and some adjacent undesignated areas out in the Preferred Options includes protection of the England region are likely to have value for SPA species. To prevent adverse effects SPA and any planning proposal would need to be on the integrity of the SPA, we recommend that the proposed assessed through the Habitats Regulations. The criteria approach for this Delivery Area includes strong policy protecting the based approach taken in policies 21 (Renewable Energy SPA from inappropriate wind energy developments and clarifying Development) and 22 (Wind Turbine Development) of that potential impacts on the SPA could occur outside as well as Preferred Options is based on the combination approach inside the designated site. preferred by respondents. E.ON Climate and Agree. Much of the NDDA lies within the North Durham Upland Comments noted. The Plan aims to support the Renewables Coalfield area, identified as an area for medium scale wind energy contribution made from renewable energy within the Mr Rod Hepplewhite development in the Broad Areas of Least Constraint under Policy 41 NDDA whilst ensuring appropriate safeguards for the Prism Planning of the RSS, where the presumption in favour of commercial wind County's landscapes and the amenity of local people. energy development should be reaffirmed. Only the westernmost This necessarily involves understanding the part of the NDDA (outside of the NDUC) lies within the North Pennines environmental constraints to deployment of new AONB, where it is accepted that commercial wind energy capacity, within the context of national policy. The developments are likely only to be accepted in exceptional criteria based approach taken in policies 21 (Renewable circumstances. Elsewhere, the County Council should acknowledge Energy Development) and 22 (Wind Turbine the in-principle potential of accommodating commercial wind energy Development) of Preferred Options is based on the developments, subject to the usual consideration of all material combination approach preferred by respondents. planning criteria. Mr Martin Wood To the extent that the delivery strategies in each of the delivery areas Comments noted. The Plan aims to support the RWE Npower advocated realising the potential of the area for onshore wind energy contribution from renewable energy whilst at the same Renewables Ltd we support them. However, the introductory text in paragraph 11.2 time ensuring appropriate safeguards for the County's significantly qualifies what is intended, suggesting that wind energy landscapes and the amenity of local people. This

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Respondent Question 8 - Do you agree with the approach for future energy Council Response development in the North Durham Delivery Area? (Please explain why you agree or disagree). is likely to be constrained and only likely to make a limited contribution necessarily involves understanding the environmental to the overall energy target. We have already commented on why constraints to deployment of new capacity, within the that is an inappropriate assumption and on the need for the evidence context of national policy. The criteria based approach base to be refreshed in order to enable the Spatial Vision and taken in policies 21 (Renewable Energy Development) Strategic Objectives of the Core Strategy Directions paper and these and 22 (Wind Turbine Development) of Preferred Options proposed delivery strategies (to realise the potential of the delivery is based on the combination approach preferred by areas) to be achieved. respondents. Mr A Hunter This section deals with the situation in each of the five newly formed Comments noted, especially need to reflect historic English Heritage Policy Delivery Areas. English Heritage welcomes the stated approach interest in South and West Durham, and supporting in each which is to protect recognised environmental assets guidance. The criteria based approach taken in policies especially, but not to the exclusion of others, those identified in 21 (Renewable Energy Development) and 22 (Wind paragraph 7.9. The commentary accompanying, and setting the scene Turbine Development) of Preferred Options is based on for the approach in each Delivery Area, varies in the extent to which the combination approach preferred by respondents. reference is made to the existence of important cultural and historic assets; so for example they warrant a mention in respect of North, East, and Central Durham, but not in respect of South or West Durham. I would contend that there is enough historic interest in the latter to justify the same level of appreciation. Glossary of Terms Given the various references to the historic environment and its heritage assets in the document it would be useful to include their definitions within the glossary. These can be found in PPS5. Finally, I should like to draw your attention to a number of guidance documents to be found on the HELM website www.helm.org.uk . English Heritage has recently updated its guidance on Energy Efficiency and Historic Buildings “ http://www.helm.org.uk/upload/pdf/EH_Part_L_FA-web_(3).pdf?1308890805 Also on the HELM website the following guidance can be found“ Advice for Domestic Energy Assessors Climate Change and the Historic Environment Draughtproofing and secondary glazing Micro wind generation and traditional buildings Microgeneration in the Historic Environment Small scale solar thermal energy and traditional buildings Wind Energy and the Historic Environment

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Respondent Question 8 - Do you agree with the approach for future energy Council Response development in the North Durham Delivery Area? (Please explain why you agree or disagree). UK Coal Plc UK Coal We are generally in support of the proposed approach to future energy Comments noted. The report was framed in the context Mining Ltd development in the North Durham Delivery Area, which supports of national policy, particularly PPS22 and PPS1. The Miss Louise Oakley remaining opportunities for commercial wind energy. However, we approach in the Preferred Options is informed by BHP would suggest that a greater emphasis is placed in acknowledging national policy, now contained in NPPF. Policy 22 of other suitable locations for new small scale wind energy development Preferred Options aims to provide certainty to both outside of the Durham Coalfield Upland Area. Government guidance communities and developers. on renewable energy development, set out in Planning Policy Statement (PPS) 22: Renewable Energy, encourages the planning system to make positive provision for renewable energy developments. In addition to PPS22, PPS1 has a published supplement 'Planning and Climate Change' that provides guidance to planning authorities and developers regarding the ways in which planning should contribute to reducing emissions and stabilising climate change. PPS1: Planning and Climate Change states that Planning Authorities should: 'Alongside any criteria - based policy development in line with PPS22, consider identifying suitable areas for renewable and low carbon energy sources and supporting infrastructure, where this would help to secure the development of such sources, but in doing to, take care to avoid stifling innovation including by rejecting proposals solely because they are outside areas identified for energy generation'. It is considered that a suitable location for small scale wind energy development outside of the Durham Coalfield Upland Area would be the wider Marley Hill and Byermoor areas. The regeneration of derelict areas at Byermoor and Marley Hill provides an excellent opportunity for renewable energy production including wind energy, geothermal energy and solar energy (referred to enclosed plan). A small scale wind farm scheme at the site could really be connected to the national grid system given its close proximity to the nearby settlements of Marley Hill and Byermoor, enabling renewable energy generated to be fed back into the grid. It is considered that a small scale wind farm at this locality could generate a capacity of up to 5MW. We consider that the site is situated in a suitable location for renewable energy sources and supporting

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Respondent Question 8 - Do you agree with the approach for future energy Council Response development in the North Durham Delivery Area? (Please explain why you agree or disagree). infrastructure and would help to secure the development of such sources in accordance with national government policy and the aim of the Council's Low Carbon Energy Strategy to support remaining opportunities for commercial wind energy. We are in support of the Council's aim to continue to encourage the development of all renewable and low carbon energy generation on a micro scale on existing buildings and in new development wherever suitable opportunities arise. We envisage that there is a potential for such opportunities to be incorporated into new development that is located on derelict brownfield sites and which are in exposed areas. The derelict areas at Byermoor and Marley Hill would have the potential to generate solar energy through a combination of both, or either, the solar thermal method or photovoltaics (PV). The solar energy generated by either the solar thermal or PV could be suitably connected to the National Grid System to allow the energy to be fed back into the grid. It is acknowledged that, although geothermal energy has not been included as a potential energy source in the Council's Delivery Strategy, this form of renewable energy could be exploited within County Durham. The Marley Hill / Byermoor area offers an exciting opportunity to utilise geothermal energy. Based on gravity data investigations in the 1960's and the Rowlands Gill borehole in the 1980's, it is now known that the Weardale Granite is only some 1000 metres or so beneath the surface at Marley Hill and Byermoor due to the presence of what is known as the 'Rowlands Gill Cupola' which brings the granite much nearer to the surface than in adjacent areas, for example, the granite is approximately 9km below the surface at Blaydon. The Weardale granite is associated with a high heat-flow anomaly, caused by its relatively high content of uranium and thorium. It is estimated that temperatures around 230 centigrade would be met at a depth of 7km beneath the surface at Marley Hill. Projects to tap geothermal energy from hot rock deposits have demonstrated that this is now a viable form of energy. Discussions with experts at Newcastle University, which is at the

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Respondent Question 8 - Do you agree with the approach for future energy Council Response development in the North Durham Delivery Area? (Please explain why you agree or disagree). forefront of the development of geothermal energy, have indicated that a geothermal energy project at Marley Hill / Byermoor could be a realistic prospect. Geothermal energy could be used not only to provide heat and power to new development in the area but also to existing houses, schools etc. In light of the above, it is suggested that geothermal energy is identified as a potential renewable energy source with the Council's Delivery Strategy for Renewable Energy. nlp client unknown Questions 8 to 12 seek to establish whether consultees agree with Comments and support noted. Each proposal will be Ms Kate McGill the approach for future energy development in the Durham Delivery assessed on its merits. The approach chosen in policy Nathaniel Lichfield & Areas. We broadly support the approach to 'support remaining 22 aims to provide the necessary certainty for both Partners opportunities for commercial wind energy in the BALC where they developers and communities, given the limited capacity can take place without significant environmental impact, either alone, remaining in many areas. or cumulatively with other development'. However, as noted in relation to Question 4 there is no requirement to specifically refer to the BALC and this element of the policy should be removed. In terms of references to the North Pennines Area of Outstanding Natural Beauty we refer you to our comments set out above in relation to Question 3.

Question 9 - East Durham Delivery Area approach

Do you agree with the approach of the East Durham Delivery Area to the delivery of future energy development? (Please explain why you agree or disagree).

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Respondent Question 9 Council Response Mr Brian Burke Agree with the proposals for all the areas. Support noted. The criteria based approach taken in British Motorcycling policies 21 (Renewable Energy Development) and 22 Federation (Wind Turbine Development) of Preferred Options is based on the combination approach preferred by respondents. Mr Alan Myers Yes, though with reservation on wind developments as above. Comments noted. The criteria based approach taken in The exploration of the potential for a biomass scheme as part of policies 21 (Renewable Energy Development) and 22 a heat network at Seaham is welcome. (Wind Turbine Development) of Preferred Options is based on the combination approach preferred by respondents. Mr Martin Kerby We welcome the statement that the recognised Environmental Comments noted, including need to have regard to RSPB Northern Assets will be protected. Given the multiple designations at the coastal designations. The criteria based approach taken England region coast (SPA, Special Area of Conservation, SSSI, Durham Heritage in policies 21 (Renewable Energy Development) and 22 Coast), it would be worth including specific policy that discourages (Wind Turbine Development) of Preferred Options is wind energy developments within the coastal belt. This would based on the combination approach preferred by provide strong protection for the range of environmental assets respondents. present in this area. Mr Mark Welsh No - County Durham has enough onshore wind farms and Comments and preference noted, including issues about Seaham Town Council therefore alternative technologies should be utilised. The Town any potential coastal biomass project at Seaham. The Council and local community should be extensively consulted on criteria based approach taken in policies 21 (Renewable any proposed development of a commercial biomass scheme at Energy Development) and 22 (Wind Turbine Development) Seaham. However, given the excellent transport links from the of Preferred Options is based on the combination port to the A19 there is no reason that such a scheme could not approach preferred by respondents. be located at a location which is a reasonable distance from the Town and would therefore still present an energy efficient option while having no impact on the quality of life of the residents of the Town. Seaham is the only coastal Town in the County on the Durham Heritage Coast, it is steadily becoming a key tourism destination in County Durham and eventually it will be the location of the Centre of Creative Excellence. If any proposed biomass facility is considered it must be located and must operate using

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Respondent Question 9 Council Response technologies which have zero detrimental impact on the local area and must not in any way present a risk to the drinking water aquifer. E.ON Climate and Generally agree, although E.ON Climate & Renewables considers Comments noted. The Plan aims to support the Renewables that there are still opportunities within the East Durham Limestone contribution made within the County to renewable energy Mr Rod Hepplewhite Area for further wind energy developments and reference to this whilst at the same time ensuring appropriate safeguards Prism Planning should be included within the proposed approach. Furthermore, for the County's landscapes and the amenity of local acknowledging that no part of the EDDA lies within an AONB then people. This necessarily involves understanding the the County Council should accept in principle the potential of environmental constraints to deployment of new capacity, accommodating commercial wind energy developments, subject within the context of national policy. The criteria based to the usual consideration of all material planning criteria. approach taken in policies 21 (Renewable Energy Development) and 22 (Wind Turbine Development) of Preferred Options is based on the combination approach preferred by respondents. Mr Martin Wood To the extent that the delivery strategies in each of the delivery Comments noted. The Plan aims to support the RWE Npower areas advocated realising the potential of the area for onshore contribution made within the County to renewable energy Renewables Ltd wind energy we support them. However, the introductory text in whilst at the same time ensuring appropriate safeguards paragraph 11.2 significantly qualifies what is intended, suggesting for the County's landscapes and the amenity of local that wind energy is likely to be constrained and only likely to make people. This necessarily involves understanding the a limited contribution to the overall energy target. We have already environmental constraints to deployment of new capacity, commented on why that is an inappropriate assumption and on within the context of national policy. The criteria based the need for the evidence base to be refreshed in order to enable approach taken in policies 21 (Renewable Energy the Spatial Vision and Strategic Objectives of the Core Strategy Development) and 22 (Wind Turbine Development) of Directions paper and these proposed delivery strategies (to realise Preferred Options is based on the combination approach the potential of the delivery areas) to be achieved. preferred by respondents. Ms C Straughan As you will be aware, questions 4, 9 and 11 refer to the Tees Plain Comments noted. The approach chosen in policy 22 aims Stockton on Tees broad area of least constraint for wind energy developments, which to provide the necessary certainty for both developers Borough Council was identified in RSS Policy 41. As you have acknowledged in and communities, given the limited capacity remaining the document, the Tees Plain designation crosses a number of in many areas. We continue to work with other LPAs as administrative boundaries, including Stockton Borough Council's. part of the duty to cooperate. The Council has the following comments regarding reaffirming the

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Respondent Question 9 Council Response area of least constraint designation as advocated in the document. The Broad Areas of Least Constraint address cross These can be summarised as follows: 1. As you will be aware the boundary issues, and any review of them would Localism Bill will abolish the RSS, the original vehicle for this necessarily need to take place on a collaborative,cross designation. It is also intended that the Localism Bill will introduce boundary basis, in line with the duty to cooperate. a duty to co-operate between Local Authorities to maintain joined up planning between areas. Given the above, it is considered that this designation, which crosses a number of local authorities, should only be reaffirmed if the relevant Councils agree that it remains appropriate, in accordance with the duty to co-operate. 2. The Durham Core Strategy is a document, which is intended to plan for the County until 2030. In deciding whether to reaffirm the designation, Durham County Council should be satisfied that any areas designated as being of least constraint have the capacity to remain so for all or a significant part of the plan period. Stockton Borough Council anticipates that the area of land within the borough will begin to be constrained by wind farm planning permissions and development in the near future. Whilst planning applications will continue to be determined on a case-by-case basis against national policy, it is anticipated that designating the part of Stockton Borough that falls within the Tees Plain as an area of least constraint will be an unsound approach, taking in to account approved and operational wind turbines. nlp client unknown Questions 8 to 12 seek to establish whether consultees agree with Comments noted. The approach chosen in policy 22 aims Ms Kate McGill the approach for future energy development in the Durham to provide the necessary certainty for both developers Nathaniel Lichfield & Delivery Areas. We broadly support the approach to 'support and communities, given the limited capacity remaining Partners remaining opportunities for commercial wind energy in the BALC in many areas. where they can take place without significant environmental impact, either alone, or cumulatively with other development.' However, as noted in relation to Question 4 there is no requirement to specifically refer to the BALC and this element of the policy should be removed. In terms of references to the North Pennines Area of Outstanding Natural Beauty we refer you to our comments set out above in relation to Question 3.

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Question 10 - Central Durham Delivery Area approach

Do you agree with the approach for future energy development in the Central Durham Delivery Area? (Please explain why you agree or disagree).

Respondent Question 10 Council Response Mr Brian Burke Agree with the proposals for all the areas. Support noted. The criteria based approach taken in policies British Motorcycling 21 (Renewable Energy Development) and 22 (Wind Turbine Federation Development) of Preferred Options is based on the combination approach preferred by respondents. Mr Alan Myers Yes to all except the first on wind. The above general Comments noted. The criteria based approach taken in comments regarding integration of power policies 21 (Renewable Energy Development) and 22 (Wind generation/carbon capture and use or storage apply to the Turbine Development) of Preferred Options is based on the science parks and industrial estates referred to in para combination approach preferred by respondents. 11.19. Mrs Susan Carmedy Brandon & Byshottles Parish Council agrees with the Support noted. The criteria based approach taken in policies Brandon & Byshottles approach 21 (Renewable Energy Development) and 22 (Wind Turbine Parish Council Development) of Preferred Options is based on the combination approach preferred by respondents. E.ON Climate and Generally agree. However, E.ON Climate & Renewables Comments noted. The Plan aims to support the contribution Renewables considers that there are still opportunities within the East made within the County to renewable energy whilst at the Mr Rod Hepplewhite Prism Durham Limestone Area for further wind energy same time ensuring appropriate safeguards for the County's Planning developments and reference to this should be included landscapes and the amenity of local people. This necessarily within the proposed approach as well as the reference to involves understanding the environmental constraints to the North Durham Upland Coalfield area still having deployment of new capacity, within the context of national potential for wind energy developments. Elsewhere, policy. The criteria based approach taken in policies 21 outside of the North Pennines AONB, the County Council (Renewable Energy Development) and 22 (Wind Turbine should acknowledge the in-principle potential of Development) of Preferred Options is based on the accommodating commercial wind energy developments, combination approach preferred by respondents. subject to the usual consideration of all material planning criteria.

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Respondent Question 10 Council Response Mr Martin Wood To the extent that the delivery strategies in each of the Comments noted. The Plan promotes opportunities for RWE Npower Renewables delivery areas advocated realising the potential of the area renewable energy whilst at the same time ensuring Ltd for onshore wind energy we support them. However, the appropriate safeguards for the County's landscapes and the introductory text in paragraph 11.2 significantly qualifies amenity of local people. This necessarily involves what is intended, suggesting that wind energy is likely to understanding the environmental constraints to deployment be constrained and only likely to make a limited of new capacity, within the context of national policy. The contribution to the overall energy target. We have already criteria based approach taken in policies 21 (Renewable commented on why that is an inappropriate assumption Energy Development) and 22 (Wind Turbine Development) of and on the need for the evidence base to be refreshed in Preferred Options is based on the combination approach order to enable the Spatial Vision and Strategic Objectives preferred by respondents. of the Core Strategy Directions paper and these proposed delivery strategies (to realise the potential of the delivery areas) to be achieved. mlp client unknown Questions 8 to 12 seek to establish whether consultees Comments and support noted. The approach chosen in policy Ms Kate McGill Nathaniel agree with the approach for future energy development in 22 aims to provide the necessary certainty for both developers Lichfield & Partners the Durham Delivery Areas. We broadly support the and communities, given the limited capacity remaining in approach to 'support remaining opportunities for many areas. The criteria based approach taken in policies 21 commercial wind energy in the BALC where they can take (Renewable Energy Development) and 22 (Wind Turbine place without significant environmental impact, either Development) of Preferred Options is based on the alone, or cumulatively with other development'. However, combination approach preferred by respondents. as noted in relation to Question 4 there is no requirement to specifically refer to the BALC and this element of the policy should be removed. In terms of references to the North Pennines Area of Outstanding Natural Beauty we refer you to our comments set out above in relation to Question 3.

Question 11 - South Durham Delivery Area approach

Do you agree with the approach for future energy development in the South Durham Delivery Area? (Please explain why you agree or disagree).

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Respondent Question 11 Council Response Mr Brian Burke Agree with the proposals for all the areas. Support noted. The criteria based approach taken in policies British Motorcycling 21 (Renewable Energy Development) and 22 (Wind Turbine Federation Development) of Preferred Options is based on the combination approach preferred by respondents. Mr Martin Kerby The North East Biodiversity Forum has identified several Comments noted. The approach chosen in policy 22 aims RSPB Northern England sites in the North East with potential for wetland habitat to provide the necessary certainty for both developers and region restoration on a scale that could make a significant communities, given the limited capacity remaining in many contribution to national UK Biodiversity Action Plan targets. areas. One of these - Morden and Bradbury Carrs - falls within this Delivery Area. This area was identified as a Habitat Creation and Enhancement Area in the Regional Spatial Strategy. Therefore we believe the policy for this Delivery Area should ensure that significant habitat restoration opportunities are not sterilised by inappropriately-sited wind energy developments. E.ON Climate and Agree. Furthermore, since no part of the SDDA lies within Comments noted. The approach chosen in policy 22 aims Renewables the North Pennines AONB, the County Council should to provide the necessary certainty for both developers and Mr Rod Hepplewhite Prism accept the in-principle potential of accommodating communities, given the limited capacity remaining in many Planning commercial wind energy developments outside of the South areas. Durham Upland Coalfield and Tees Plain areas, subject to the usual consideration of all material planning criteria. Mrs Christine Walton In principle the Town Council would agree with this Comments noted. The approach chosen in policy 22 aims Great Aycliffe Town approach. However the environmental impact and the impact to provide the necessary certainty for both developers and Council on the living conditions of residents should be given communities, given the limited capacity remaining in many extremely high levels of consideration. Although South areas. Durham is one of the broad areas of least constraint for wind energy that should not mean that it is flooded with wind turbines to make up for areas where it is considered they are nearing capacity. Para 11.34 comments that the area is not capable of accommodating the level of wind turbine development that was envisaged in the RSS without a significant change in the landscape character of the area. In this current economic climate it is hoped that the lure of

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Respondent Question 11 Council Response large cash investment does not override all other considerations. The South Durham delivery area is well placed to assist with the targets for carbon reduction, renewable energy and renewable heat targets. Mr Alan Myers Yes. Particularly welcome is the encouragement of district Comments noted. The approach chosen in policies 21 and heating schemes. Regarding Aycliffe Industrial Park, CO 2 22 aims to provide the necessary certainty for both capture from manufacturing units integrated with CO 2 developers and communities, given the limited capacity capture from biomass/biogas combustion in the power plants remaining in many areas. at Chilton and Aycliffe should be explored. The CO 2 could be used for plant/algal growth enhancement and/or fed into a pipe network for CCS. Miss Karen Johnson The approach to delivery is supported in principle although Comments noted. The approach chosen in policies 21 and Darlington Borough we would welcome a reference to the cross boundary 22 aims to provide the necessary certainty for both Council cumulative impact of commercial wind energy development developers and communities, given the limited capacity with Darlington particularly in landscape terms. The wider remaining in many areas. We continue to work with landscape that crosses into Darlington together with its neighbouring authorities as part of the duty to co-operate. infrastructure should be a key consideration when assessing the potential for wind energy in Durham. Mr Martin Wood To the extent that the delivery strategies in each of the Comments noted. The approach chosen in policies 21 and RWE Npower Renewables delivery areas advocated realising the potential of the area 22 aims to provide the necessary certainty for both Ltd for onshore wind energy we support them. However, the developers and communities, given the limited capacity introductory text in paragraph 11.2 significantly qualifies remaining in many areas. what is intended, suggesting that wind energy is likely to be constrained and only likely to make a limited contribution to the overall energy target. We have already commented on why that is an inappropriate assumption and on the need for the evidence base to be refreshed in order to enable the Spatial Vision and Strategic Objectives of the Core Strategy Directions paper and these proposed delivery strategies (to realise the potential of the delivery areas) to be achieved.

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Respondent Question 11 Council Response Ms C Straughan As you will be aware, questions 4, 9 and 11 refer to the Tees Comments noted. Comments noted. The approach chosen Stockton on Tees Borough Plain broad area of least constraint for wind energy in policy 22 aims to provide the necessary certainty for both Council developments, which was identified in RSS Policy 41. As developers and communities, given the limited capacity you have acknowledged in the document, the Tees Plain remaining in many areas. We continue to work with other designation crosses a number of administrative boundaries, LPAs as part of the duty to cooperate. including Stockton Borough Council's. The Council has the following comments regarding reaffirming the area of least The Broad Areas of Least Constraint address cross constraint designation as advocated in the document. These boundary issues, and any review of them would necessarily can be summarised as follows: 1. As you will be aware the need to take place on a collaborative, cross boundary basis, Localism Bill will abolish the RSS, the original vehicle for in line with the duty to cooperate. this designation. It is also intended that the Localism Bill will introduce a duty to co-operate between Local Authorities to maintain joined up planning between areas. Given the above, it is considered that this designation, which crosses a number of local authorities, should only be reaffirmed if the relevant Councils agree that it remains appropriate, in accordance with the duty to co-operate. 2. The Durham Core Strategy is a document, which is intended to plan for the County until 2030. In deciding whether to reaffirm the designation, Durham County Council should be satisfied that any areas designated as being of least constraint have the capacity to remain so for all or a significant part of the plan period. Stockton Borough Council anticipates that the area of land within the borough will begin to be constrained by wind farm planning permissions and development in the near future. Whilst planning applications will continue to be determined on a case-by-case basis against national policy, it is anticipated that designating the part of Stockton Borough that falls within the Tees Plain as an area of least constraint will be an unsound approach, taking in to account approved and operational wind turbines. Mrs Jean Gillespie Following a resident having attended the consultation Comments noted. The Broad Areas of Least Constraint Bradbury Parish Meeting meeting in Sedgefield on the 15 th June 2011 re the above identified in RSS were identified as relatively unconstrained document I would like to state the position of Bradbury but were not rigorously assessed in terms of of their actual

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Respondent Question 11 Council Response Parish Meeting on this document, in particular with reference available capacity. Instead, all were identified as having to future wind energy development within our area of County capacity for medium scale development, broadly identified Durham. We disagree most strongly with the Council's as up to 20-25 turbines. In reality, some of the identified approach for future wind energy development within our areas do not have this scale of capacity, whilst others have area as it has not been demonstrated that sufficient weight have capacity to exceed this. The purpose of the local level is to be appied to the Arup studies or to Saved Policies, in assessments, carried out by Arups, was to more fully particular Saved Policy E3. Saved Policy E3 states that:- understand actual capacity of each identified area. Although 'The council will seek to conserve the historic landscape not forming part of the statutory development plan, these character of the Bradbury, Mordon and Preston Carrs when studies will continue to be material considerations in the approving proposals by ensuring that they do not damage assessment of any development proposals within the study the character or appearance of the area'. Our Parish Meeting areas. is of the opinion that this policy has been forgotten during the reorganisation of the unitary boundaries resulting in the Saved Policy E3 remains part of the statutory development abolishment of Sedgefield Borough Council or that there is plan until the adoption of the County Durham Plan. no general knowledge of this, and other relevant policies, within Durham County Council. Our concern, obviously, lies In terms of the submission of the Isles proposal, to the with the recent planning application by EON, now withdrawn, Planning Inspectorate (formerly IPC) as nationally significant relating to the A1 windfarm and the now pending application, infrastructure (>50MW), the County Council will have a again by EON, for a far larger wind farm (The Isles) covering statutory role in the process, as set out in the Planning Act the Carrs and the Isles which is contrary to Saved Policy 2008. E3 and will cover any area identified as a Conservation Area and, in parts, an area of Special Scientific Interest. A The approach chosen in policy 22 aims to provide the situation that cannot be condoned. It should also be noted necessary certainty for both developers and communities, that the possible Isles development not only lies within the given the limited capacity remaining in many areas. area protected by Saved Policy E3 but a very large scheme greater than 50MWs in the Carrs would not be consistent with the findings of the Arup study as it would occupy an area largely identified as having a capacity on None / very limited, with a maximum wind farm of less than 4 turbines. It is our understanding that until such time that a new plan is in force, both information from the Regional Spatial Strategy and Saved Policies will apply. We would seek assurances that these will be carried forward in some format in order that protection of this unique area is continued. Despite the Arup landscape capacity studies, the council

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Respondent Question 11 Council Response are asking if we agree with their approach to further develop Broad Areas of Least Constraint. Our understanding of a Broad area of Least Constraint is that the whole area is not of least constraint, and that the whole area is not of least constraint, and that the council should be mindful of this. Indeed, is it not more important to protect those areas that are deemed important or special, in order that the whole area is not violated? We consider that the current situation of: operational, approved, and planned submitted wind farms throughout the Tees Plain will exceed the landscape capacity of our immediate area. We also consider that the Local Authority seem to distance themselves from THE ISLES Project, when in fact according to the IPC Local Authorities play a pivotal role in the process. We would expect that strong representation be made at the veryearliest stage to avoid any possibility of a GENERATING STATION being built in the protected unique Carrs. We trust that The Council will use our response to inform the further development of the Core Strategy and that the comments will help to decide which strategy and proposals would be best to pursue. mlp client unknown Questions 8 to 12 seek to establish whether consultees Comments and support noted. The approach chosen in Ms Kate McGill Nathaniel agree with the approach for future energy development in policy 22 aims to provide the necessary certainty for both Lichfield & Partners the Durham Delivery Areas. We broadly support the developers and communities, given the limited capacity approach to 'support remaining opportunities for commercial remaining in many areas. The criteria based approach taken wind energy in the BALC where they can take place without in policies 21 (Renewable Energy Development) and 22 (Wind significant environmental impact, either alone, or Turbine Development) of Preferred Options is based on the cumulatively with other development'. However, as noted combination approach preferred by respondents. in relation to Question 4 there is no requirement to specifically refer to the BALC and this element of the policy should be removed. In terms of references to the North Pennines Area of Outstanding Natural Beauty we refer you to our comments set out above in relation to Question 3.

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Question 12 - West Durham Delivery Area approach

Do you agree with the approach for future energy development in the West Durham Delivery Area? (Please explain why you agree or disagree).

Respondent Question 12 - Do you agree with the approach for future energy Council Response development in the West Durham Delivery Area? (Please explain why you agree or disagree).

Mr Brian Burke Agree with the proposals for all the areas. Support noted. The criteria based approach taken in policies 21 British Motorcycling (Renewable Energy Development) and 22 (Wind Turbine Federation Development) of Preferred Options is based on the combination approach preferred by respondents.

Mr Martin Kerby The North Pennine Moors SPA covers a significant portion of the West Comments noted. Any potential impacts on SPA must RSPB Northern England Durham Delivery Area, and some adjacent undesignated areas are necessarily form a key part of the assessment of development region likely to have value for SPA species, for example in the Woodland proposals through the Development Management process and area. To prevent adverse effects on the integrity of the SPA, we HRA. The proposed approach in the Plan includes protection recommend that the proposed approach for this Delivery Area includes for the SPA. See previous responses. strong policy protecting the SPA from inappropriate wind energy developments and clarifying that potential impacts on the SPA could occur outside as well as inside the designated site.

Mr Simon Owens No. Please see my earlier comments regarding wind farm developments Comments and objections noted. in part of the South Durham Coalfield Upland area. More landscape beyond that in the AONB needs protecting in the Durham Dales to Issues raised are important but to some extent are beyond the ensure that tourism remains a growth sector for the local economy. scope of the County Durham Plan to affect, given that they are There is no attempt to deal with conversion of houses obliged to principally issues about upgrading existing housing rather than continue utilising coal for domestic heating. This has health implications, new development. The Council's Fuel Poverty Action Plan aims particularly for those in fuel poverty. No recognition of the higher costs to address many of the issues faced by households in older involved with providing effective insulation in old stone built houses or housing off the gas network. Government's proposed Green any plans to assist. No recognition of the extent of private rented homes Deal may also offer opportunities to address some of the issues in Teesdale and the impact that has on the energy efficiency measures raised. The criteria based approach taken in policies 21 being undertaken. I support development of commercial scale hydro (Renewable Energy Development) and 22 (Wind Turbine developments at existing reservoirs but not elsewhere. It would seem Development) of Preferred Options is based on the combination that people in rural areas will be more reliant on the national approach preferred by respondents. government than their local council for any concrete help to deal with their energy concerns.

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Respondent Question 12 - Do you agree with the approach for future energy Council Response development in the West Durham Delivery Area? (Please explain why you agree or disagree).

E.ON Climate and Agree. E.ON Climate & Renewables acknowledges that within the Support and comments noted. The policy approach in the Plan Renewables North Pennines AONB commercial wind energy developments are will be to support the development of wind energy within the Mr Rod Hepplewhite Prism likely only to be accepted in exceptional circumstances. However, capacity of the environment and protecting the best of the Planning whilst welcoming the fact that in-principle support will be given for County's landscapes. The criteria based approach taken in commercial wind energy developments proposed within the South policies 21 (Renewable Energy Development) and 22 (Wind Durham Upland Coalfield area, it is considered that the County Council Turbine Development) of Preferred Options is based on the should accept the in-principle potential of accommodating commercial combination approach preferred by respondents. wind energy developments elsewhere within the WDDA outside of the AONB, subject to the usual consideration of all material planning criteria.

Mr Alan Myers The importance attributed to the protection of the North Pennines AONB Support and comments noted. As noted in the document, in the last point is welcomed. I would also be wary of any wind geothermal could make a small but valuable contribution. It is developments in the South Durham Coalfield because of arguments not referred to specifically in the proposed approach due to the expressed elsewhere relating to area of land required to generate a uncertainty of development of geothermal schemes. The criteria modest quantity of electricity. Specific reference in the proposed based approach taken in policies 21 (Renewable Energy approach could be made to geothermal potential (as mentioned in para Development) and 22 (Wind Turbine Development) of Preferred 11.43. Collaboration with geothermal research teams at Newcastle Options is based on the combination approach preferred by and Durham Universities is relevant in this particular respect. respondents.

Mr Martin Wood To the extent that the delivery strategies in each of the delivery areas Comments and support noted. It is considered that the RWE Npower Renewables Ltd advocated realising the potential of the area for onshore wind energy appropriate approach is to continue to support wind we support them. However, the introductory text in paragraph 11.2 development which respects the capacity of the environment significantly qualifies what is intended, suggesting that wind energy is and protects the best of the County's landscapes. The criteria likely to be constrained and only likely to make a limited contribution based approach taken in policies 21 (Renewable Energy to the overall energy target. We have already commented on why that Development) and 22 (Wind Turbine Development) of Preferred is an inappropriate assumption and on the need for the evidence base Options is based on the combination approach preferred by to be refreshed in order to enable the Spatial Vision and Strategic respondents. Objectives of the Core Strategy Directions paper and these proposed delivery strategies (to realise the potential of the delivery areas) to be achieved.

Mr J Hodgson At its meeting on 21 July 2011, the Parish Council considered the Support and comments noted. The criteria based approach taken Staindrop Parish Council present state of play on the County Durham Plan, and took the in policies 21 (Renewable Energy Development) and 22 (Wind opportunity to discuss the documents you are presently consulting on. Turbine Development) of Preferred Options is based on the Given the high level strategy content of the Papers at this stage, our combination approach preferred by respondents. only comments are as follows: On the Carbon Energy strategy, assuming the targets set out in 6.5 are realistic and attainable (on

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Respondent Question 12 - Do you agree with the approach for future energy Council Response development in the West Durham Delivery Area? (Please explain why you agree or disagree).

which we did not feel qualified to comment), the Parish Council broadly agrees with the proposed approach for the West Durham Delivery Area as set out on page 42. nlp client unknown Questions 8 to 12 seek to establish whether consultees agree with the Support and comments noted. Each proposal will be assessed Ms Kate McGill Nathaniel approach for future energy development in the Durham Delivery Areas. on its merits. The criteria based approach taken in policies 21 Lichfield & Partners We broadly support the approach to support remaining opportunities (Renewable Energy Development) and 22 (Wind Turbine for commercial wind energy in the BALC where they can take place Development) of Preferred Options is based on the combination without significant environmental impact, either alone, or cumulatively approach preferred by respondents. with other development. However, as noted in relation to Question 4 there is no requirement to specifically refer to the BALC and this element of the policy should be removed. In terms of references to the North Pennines Area of Outstanding Natural Beauty we refer you to our comments set out above in relation to Question 3.

Statement of Consultation Minerals, Waste and Low Carbon Technical Consultation Reports 353 To find out more about the new County Durham Plan: Spatial Policy Team, Write to: Durham County Council County Hall Durham DH1 5UQ

03000 026 0000 Telephone: [email protected] Email: www.durham.gov.uk/cdp Visit: Interactive http://durhamcc-consult.limehouse.co.uk/portal/planning/ Website:

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