MINERALS LOCAL PLAN ARGUMENTS FIRST SPEAKER: CLLR BRUCE LAUGHTON History: Involved in the work leading up to the 2005 Minerals Local Plan which involved sites in my own county division; None of the sites I’m talking about today are in my own division, but I have visited them, along with other Members of this Committee; Concern is to ensure this Council does NOT make a decision which is flawed, and blight particular areas of this County unnecessarily. Key points of my amendment: To recommend specifically that the Shelford West and Averham Flash Farm sites be REMOVED from the Nottinghamshire Minerals Local Plan Submission Draft document; They represent tonnes of sand and gravel that isn’t needed, because Demand for the period 2012 – 2030 inclusive has been over-estimated; The Submission Draft document uses demonstrably out-of-date and therefore inaccurate and misleading data; Amendment calls on Members to agree that these sites must be removed, and the data calculations reviewed, otherwise Conservative Members will feel obliged to vote against the whole document. Let me explain why the estimates are unreliable, referring to evidence I have circulated to Members as background papers: On page 46 of the Council’s Submission Draft document (which I have extracted and marked ‘A’ in the background papers for Members’ attention), the Estimated Total Aggregate Demand for 2012-2030 is calculated using Annual Aggregate Production figures from 2002 to 2011, based on data from the Nottinghamshire Local Aggregates Assessment, published in July 2013; These figures four years are out-of-date! As recently as April 2015, Nottinghamshire County Council and Nottingham City Council published a Local Aggregates Assessment (Marked ‘B’ in the circulated papers), showing on page 7 more up-to-date sand and gravel production data from 2004 to 2013; ; The figures show that sand and gravel production tonnage has dropped dramatically over recent years (decline over past 20 years anyway); The drop in sand and gravel requirements has been highlighted by the need for developers to apply for time extensions on current extraction sites, because they haven’t quarried as much aggregate as they anticipated in the original timeframe, and the number of sites that are still mothballed; 1 The fall in aggregate usage, shown here from at least 2004, pre-dates any effect the recession may have had since it took hold from 2008; Indeed, by not using the latest data, and drawing in higher figures from 2002 and 2003 which are no longer representative of the current trend, the Submission Draft calculation is a MUCH LESS reliable estimate of future sand and gravel usage; Other local authorities have already recognised national expert guidance that the most up-to-date data should be used for these estimates; For example, the Warwickshire Local Aggregate Assessment (marked ‘C’ in the papers I have circulated) clearly states that the calculation “should be based on the latest available 10-year sales” according to Good Practice Guidelines set out by the Planning Officers’ Society and the Mineral Products Association; They have used the most recent, 2004-2013 data; Likewise (in the document marked ‘D’), Lincolnshire County Council decided to MODIFY its Pre-Submission Draft to use the latest sand and gravel figures from 2004-2013, as a direct response to “issues raised by the Planning Inspector” at Hearing Sessions in October 2015; In document ‘D’ I have highlighted the text from Lincolnshire’s Schedule of Proposed Modifications to the Pre-Submission Draft, which states:“Since the Sub-Regional Apportionment (SRA) was agreed, sales of sand and gravel and limestone in the county have been significantly lower than the annual averages set by the SRA. Indeed, for the 10-year period 2004-2013, sales of sand and gravel averaged only 2.37 million tonnes per annum, which is 0.91 million tonnes (28%) less than the SRA annual average. As a result, the County Council considers the SRA no longer provides a reliable forecast of aggregate demand and that it would be more appropriate to base the level of future provision on average sales over the period 2004-2013” So why would Nottinghamshire County Council not learn from the experience of other Councils, including Lincolnshire who are 6 months ahead of us in the process, and base our future estimates on the latest, most reliable data? Document E in my pack illustrates that Derbyshire have also based their calculations on data from 2004 – 2013; Document F in my pack illustrates why this is so crucial to the demand estimation process:- i) Using outdated figures between 2002 and 2011, the average sand and gravel requirement per year over 10 years is 2.58 million tonnes which, multiplied by 19 years up to 2030, estimates demand at 49.02 mill tonnes; ii) Using the most current data between 2004 and 2013, average sand and gravel requirement per year over 10 years is 2.24 million tonnes which, multiplied by 19 years, estimates demand of 42.6 million tonnes; 2 iii) So, the most current figures produce an estimated demand 6.42 million tonnes LOWER than Nottinghamshire’s proposed plan suggests; iv) And Nottinghamshire’s over-estimate of demand currently stands at around 13%, but could be even greater, given the overall trend of a falling market for sand and gravel over many years, and an increase in recycling mainly driven by Landfill Tax. This undermines the case in relation to ALL of the proposed sites, but most immediately Shelford West and Averham Flash Farm, because their operational period is set to commence as early as 2016; It’s worth noting that the National Planning Policy Framework (shown as Document G in my papers) requires local authorities to make only SEVEN years provision for sand and gravel, so Councils are erring on the side of caution anyway; Members would be foolhardy to “endorse” or recommend this to Full Council in the light of this evidence and experience from local authorities elsewhere, because the Inspector is likely to find the document “unsound”; Aside from the technical arguments, think also of the impact on those we represent: more worry and distress to residents for no good reason! To expand on my point that the forecasts in the document under-estimate likely recycling levels in Nottinghamshire: There has been a complete change in culture as far as developers are concerned; They frequently recycle and re-use old concrete on site (e.g. for base aggregates on roads and footpaths) rather than sourcing new aggregate; Much cheaper and more convenient for them to use recycled material; Developer recycling not even measured by the County Council within their recycling rates, which already show a steady increase; Landfill Tax is currently running at £82.60 per tonne and increasing to £84.40 per tonne from April 2016, so the incentives for developers to recycle rather than dispose of existing aggregate is only going to increase, and the decrease in demand for newly quarried aggregate will continue. 3 SECOND SPEAKER Many specific local reasons why the proposed new sites at Shelford West and Averham Flash are unsound. Shelford should be removed because of: The difficulty of removing material from the site; Inadequacies of the conveyor belt system (which would stretch for a mile & a quarter); The additional number of lorries entering onto the A6097, considering that according to 2014 data shown at Document H there are currently 19,400 vehicles per day using the A6097 between the A612 Lowdham and Trent Lane, East Bridgford, of which 5.3% of lorries; the 19,400 figure represents a rise of around 1,000 vehicles in four years; The access down to the Wharf on the Colwick side of the Trent is unsuitable; Colwick Loop Road into the City is already extremely congested; Knock-on logjam potential for surrounding road networks; Bulcote/Gunthorpe application was withdrawn in 2006 amid concerns that the extraction may well re-route the Trent due to the width of the Trent catchment at that point, but similar issues have not been identified for any other site. Averham Flash Farm should be removed because of: The A617 running through three rural villages which would be negatively affected by heavy traffic; As shown in Document I in my background papers, Road Traffic Noise on the A617 at Kirklington & Hockerton has already been measured by Newark & Sherwood District Council officers and found to be in excess of the Control of Road Traffic Noice (CRTN) and World Health Organisation (WHO) standards; The entrance to Newark, particularly on Fridays, on the A617 and A616 is already being regularly gridlocked; Kelham Bridge – a photograph of which is shown in Document J - has inadequate width to allow two lorries to pass at once in opposite directions; Document K shows that traffic follows on the A617 on the Kelham Loop North East of Averham are in excess of 85,000 vehicles a week already, 15% of which are heavy goods; 4 Many of the properties backing up to the side of the A617 through Averham and Hockerton are already affected by vibration from lorries (Document L); Nowhere in today’s document does it state the developer’s that Flash Farm has been allocated for infill of inert waste; The Averham Flash Farm proposal is to replace the void created by the extraction of 200,000 tonnes of sand and gravel void per annum, with inert waste which equates to some 86.9% of the county inert waste production on this one site, based upon 2010 figures adopted in our Waste Core Strategy. Nottinghamshire County Council’s Waste Core Strategy (Document M) states:- “Disposal of inert construction and demolition waste has fallen dramatically over the last 10 years from more than 500,000 tonnes a year to around 230,000 tonnes in 2010. Typically this waste is used to restore old mineral voids or similar sites although some is also used as daily cover and engineering material at non-hazardous landfill sites.” This question doesn’t just apply to Averham Flash. There are other identified quarry sites listed within the Plan which also intend to restore their voids to agricultural land. Where are they going to source the amounts of inert waste required? Overall points applying to both sites: Should encourage recycling to take place at sites that are already extracting gravel e.g. Cromwell Already there are sites allocated with planning permission (e.g. Sturton) Cemex have 2.5 million tonnes allocated north of Cromwell; Large allocation also recently allocated at Swinderby; Recent approval by the Planning committee of the Besthorpe site adding an extra 800,000 tonnes to the extraction over the next six years; Sites should be allocated as close to need as possible i.e. the main market areas of South Yorkshire, South Nottinghamshire and the A1 corridor. Recognise that development can take place quite close to communities as long as long as it has direct access to a main road e.g. Cromwell Some of the sites to be considered have more potential for road improvements than others; Number of developers own interests in preferred sites at better locations than Shelford and Averham, and should be encouraged to develop those sites. 5 THIRD SPEAKER Barton-in-Fabis site: Barton-in-Fabis appeared to be removed by officers behind closed doors supposedly for “ecology” reasons, without any convincing explanation in this paper; Where was this decision initially made and by whom? How is this transparent? The cases for and against ALL sites should be heard in public committee, as per my presentations on Shelford and Averham Flash Farm today; Concerns about democratic procedure: Serious questions over the publication of these papers on 18 th December 2015 for a meeting on 4th January 2016: meaning no opportunity over Christmas to properly inform or consult residents; Impression is of a planning authority acting in a manner which is anything but open, transparent, democratic and fair; Council appears to be seeking to rush through a decision and bury bad news while public and Member attention is distracted during the Christmas & New Year holiday season; The Conservative Group Leader already has made written complaint to the Chief Executive to this effect; Intend to take this to the Local Government Ombudsman if the timing and contents of this paper are not reconsidered; Also believe the Constitutional limit of 10 minutes per speaker in relation to Council committees should be re-examined in relation to complex papers such as this, where Members may wish to raise a large number of points. 6