Support

Representation ID: 5022

Received: 02/01/2024

Respondent: Mrs Sara Glover

Any potential adverse issues should be highlighted to affected communities in advance of any decision on whether to proceed and mitigating actions approved by the communities involved.

Noted. This is dealt with at the planning application stage where proposals are required to assess potential adverse impacts and identify possible avoidance/mitigation measures. This information will be available during public consultation before a decision on the application is made.

Object

Representation ID: 5119

Received: 03/01/2024

Respondent: Natural England

Natural England would want to ensure that Habitats Sites, Sites of Special Scientific Interest, National Nature Reserves and irreplaceable habitats (including Ancient Woodland and veteran trees) will be safeguarded from inappropriate minerals and waste development. We consider that this policy does not specifically say this. A cross reference to Policy EN1: Protection of Sites, Habitats and Species should be made. It should also be ensured at the outset of any mineral development that appropriate Biodiversity Net Gain can be achieved.

The protection of habitats and environmental designations are recognised through the plan and its policies; however, it is not considered necessary to highlight particular habitats/designations over others. Such features will be taken into account on a site-by-site basis in line with the Local Plan policies and other relevant policies. A cross-reference to Policy EN1 is not necessary as the plan should be read as a whole.
Policy MIN9 - Restoration and aftercare, requires that restoration of minerals development provides at least 10% Biodiversity Net Gain (BNG), which is a mandatory requirement under the Environment Act (2021). A developer is required to submit proposals for restoration as part of the planning application.

Object

Representation ID: 5400

Received: 04/01/2024

Respondent: Heidelberg Materials UK

MIN4 (b.ii) refers to ‘adopted cement production rate’ but the Local Plan does not appear to define what that is with any clarity. NPPF 220 requires the planning authority to provide a steady and adequate supply of industrial minerals. NPPF footnote 78 notes only the minimum reserve levels to be provided and does not seek to limit what that might be. Reference to an adopted production rate does not therefore accord with national policy. MIN 4 should be amended to remove references to the ‘adopted cement production rate’.

Agreed. Remove reference to the ‘adopted cement production rate’ in the Local Plan. Amend text.

Object

Representation ID: 5837

Received: 06/01/2024

Respondent: Mary Cade

This needs to include quantitative risk assessments of potentially adverse effects on the local community, including health, and, as in CC8 state buffer distances etc. Also measures to ensure pedestrian safety on roads without footpaths, with respect to HGV load safety and deposition on the roads, not just Highway Safety. And to assess the cumulative effects of several quarries in close proximity on the amenity and health of nearby communities.
And to include an obligation on the operator to review the original risk assessments and mitigation measures within a time limit of a stated % increase in output being recorded.

Policy MIN4 addresses a broad range of potentially adverse impacts that may arise from minerals development including cumulative impacts. The need for quantitative risk assessments and the assessment of safety issues are matters to be addressed through the scoping and planning application process should a planning application come forward.

Object

Representation ID: 6385

Received: 08/01/2024

Respondent: Hughes Craven Ltd.

Within MIN4 b) iii, reference to ‘Rutland’ should be amended to ‘Rutland and the surrounding region’.
The preference for proposals at allocated sites risks prejudicing other applications, particularly if the sole proposed allocation is not brought forward. This may have a detrimental impact on material supply (particularly in relation to building stone), competition and the local economy. In order to support the continuation of existing operations, proposals for the extension/direct replacement of existing sites should be given equal importance to allocated sites.

Agreed in part. Amend MIN2 c) to: ‘support the supply of minerals where necessary for conservation purpose and / or maintaining the local distinctiveness of the built environment within Rutland and the surrounding sub-region’.
Amend Policy MIN4 a) to build in flexibility for non-allocated building stone sites to come forward: ‘Preference will be given to proposals for mineral extraction at allocated sites. Proposals on unallocated sites or outside of the areas identified in the spatial strategy will be considered where: a) the proposal relates to extraction of aggregates, building stone, or cement materials (limestone and clay) and cannot reasonably or would not otherwise be met from committed or allocated reserves, or from within the cement primary and secondary materials Area of Search; or

Support

Representation ID: 6462

Received: 08/01/2024

Respondent: Mrs Hilary Smith

Support BUT protection of adjacent populations needs to be considered in relation to Noise , Dust , and Traffic. Real time monitoring of particulate matter is essential

Noted. Policy MIN4 recognises the potentially adverse impacts of minerals development on human health and states that proposals must be expected to demonstrate how the proposal will protect local amenity, particularly in relation to dust, noise and vibration; secure safe and appropriate site access; and make provision to secure highway safety. Requirements for dust monitoring are addressed during the scoping and planning application stage, should a planning application come forward.

Object

Representation ID: 6519

Received: 08/01/2024

Respondent: BCH UK Ltd.

Agent: Hughes Craven Ltd.

Within MIN4 b) iii, reference to ‘Rutland’ should be amended to ‘Rutland and the surrounding region’. The preference for proposals at allocated sites risks prejudicing other applications, particularly if the sole proposed allocation is not brought forward. This may have a detrimental impact on material supply, competition and the local economy. In order to support the continuation of existing operations, proposals for the extension/direct replacement of existing sites should be given equal importance to allocated sites.

Agreed in part. Amend Policy MIN4 iii ‘Supporting conservation of the historic environment or maintaining the local distinctiveness of the built environment within Rutland and the surrounding sub-region;’
Amend MIN2 c) to: ‘support the supply of minerals where necessary for conservation purpose and / or maintaining the local distinctiveness of the built environment within Rutland and the surrounding sub-region’
To build in flexibility for non-allocated building stone sites to come forward amend Policy MIN4: a) ‘Preference will be given to proposals for mineral extraction at allocated sites. Proposals on unallocated sites or outside of the areas identified in the spatial strategy will be considered where: a) the proposal relates to extraction of aggregates, building stone, or cement materials (limestone and clay) and cannot reasonably or would not otherwise be met from committed or allocated reserves, or from within the cement primary and secondary materials Area of Search; or’

Object

Representation ID: 6744

Received: 03/01/2024

Respondent: Rutland Quarry Forum

Agent: Rutland Quarry Forum

Representation suggest changes to the wording of policy MIN4 to reduce ambiguity and establish more rigorous criteria (such as replacing should with must) and adding the following final paragraph:
Should extraction rates at site exceed 110% of original consented rates the operator must, within 3 months of increased rates, review the risk assessments and mitigation measures supporting the original application to
determine the validity of assumptions used and whether the mitigation measures remain appropriate.

The word ‘must’ is used throughout Policy MIN4 however the word ‘should’ used in the policy supporting text can be replaced with ‘must’: ‘Any assessment of potential adverse impacts must also take into account cumulative effects’ and ‘The provision of suitable measures to protect and where appropriate enhance: trees, woodland and other landscape features within and adjoining the site; watercourses crossing the site; and groundwater abstractions present in the locality - unless the need for, and benefits of, the development in that location outweigh the likely loss or damage, in which case appropriate mitigation or compensation measure must be provided’. The need for impact risk assessment reviews (and any subsequent re-evaluation of mitigation measures), should extraction exceed consented rates, are more appropriate to be developed through the scoping and planning application stage on a site-by-site basis rather than included in the Local Plan.

Object

Representation ID: 6866

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

Policy is weak and does not correspond with Policy EN1: Protection of Sites, Habitats and Species to ensure that designated sites for nature conservation/irreplaceable habitats are appropriately protected. This should be extended to Priority Habitats as mineral extraction as
significantly contributed to losses historically.
Mineral developments must also align with Policy EN3 – Biodiversity Net Gain, ensuring that BNG can be achieved in principle and in perpetuity.

The protection of the environment from adverse impacts of minerals development is addressed by Policy MIN4; it is not necessary to list all the different types of environmental constraints that need to be considered. Such features will be taken into account on a site-by-site basis in line with the RLP policies (including Policy EN1) and other relevant policies.
Policy MIN9 - Restoration and aftercare, requires that restoration of minerals development provides at least 10% Biodiversity Net Gain (BNG), which is a mandatory requirement under the Environment Act (2021).

Object

Representation ID: 6952

Received: 04/01/2024

Respondent: Mr . Eatough

Agent: DLP Planning Ltd

Whilst we support the objective of this policy, in line with the national practice guidance, proposals should also be required to consider any impacts on landscape, heritage,
ecology, lighting impacts and flood risk and this should be included in the policy wording.

Our client made an objection to the forthcoming proposals at Grange Top Quarry during their
recent public consultation. In light of this, we strongly suggest that the set of requirements included within supporting text for Policy MIN4 is extended to include the
following:
• Landscape and Visual Impacts
• Ecology Impacts
• Heritage Impacts which considers heritage assets within close proximity to the site;
• Lighting Impacts

Noted. Impacts on landscape, ecology, heritage, visual/light and flood risk impacts are captured within the first paragraph of the supporting text for Policy MIN4 which refers to ‘impacts on the natural and historic environment and on human health’. It is not necessary to list all the potential impacts to make for a more succinct and reader friendly document.

Object

Representation ID: 7097

Received: 08/01/2024

Respondent: Mr David Wilkin

Re: The cement business at Ketton - Further excavation towards local housing does need to be carefully controlled.

Noted.

Object

Representation ID: 7300

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

We feel this policy should have more emphasis on restoration of mineral extraction areas for nature recovery within the county.

In particular, MIN 4 is very selective about the areas where it says damage should be avoided. It does not for instance mention Ketton Quarry Nature Reserve, which given its proximity to the new extraction areas still needs consideration. In addition, rather than purely looking at protection of, for instance, SSSIs, there should be adequate protection for general field and woodland biodiversity, particularly given the destructive nature of the mineral extraction process.

The restoration of mineral extraction sites is addressed in Policy MIN9 - Restoration and aftercare. It states that restoration should provide a net-gain in biodiversity and integrate where possible, into the forthcoming Nature Recovery Networks. Policy MIN4 requires proposals for mineral extraction to be environmentally acceptable and avoid and/or minimise potentially adverse impacts (including cumulative impacts) to acceptable levels. This includes consideration of all elements of the natural environment such as environmental designations and local landscape features. It is not necessary to list all the environmental constraints as such features will be taken into account on a site-by-site basis in line with the RLP policies and other relevant policies.

Object

Representation ID: 7462

Received: 07/01/2024

Respondent: Cottesmore Parish Council

Object to current policy – needs strengthening. Development Criteria for Mineral Extraction. - More specifically, we fully endorse the comments made by the Quarry Forum that this policy needs to be strengthened, in particular around proper quantitative risk assessments, demonstrating any adverse impacts and how operators will be forced to protect the local amenity, particularly of adjoining settlements. Where we share a more direct concern, to the quarries at Greetham for example, is to beef up the wording around highway safety, including the security of loads and safety of pedestrians.

Policy MIN4 states how proposals for minerals development are expected to demonstrate how the proposal will protect local amenity
particularly in relation to secure safe and appropriate site access; and make provision to secure highway safety. The need for quantitative risk assessments are more appropriate to be developed through the scoping and planning application stage for individual sites.

Support

Representation ID: 7594

Received: 08/01/2024

Respondent: Historic England

Criteria b) iii) is welcomed. The second paragraph is also
welcomed.

The last paragraph of the supporting text ‘Why is this
policy needed’ is also welcomed.

Unfortunately due to capacity (and the scale of the safeguarding areas proposed) it has not been possible to fully assess the proposed minerals and waste sites or the proposed safeguarding areas at this stage.

Noted.

Support

Representation ID: 7628

Received: 08/01/2024

Respondent: Environment Agency

Minerals and waste developments have the potential to pollute groundwater, these types of developments should therefore not be located in the most sensitive locations for groundwater. We recommend reference is made to this in policies MIN4 and WST2. See the Environment Agency’s approach to groundwater protection:
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/692989/Envirnment-Agency-approach-to-groundwater-protection.pdf

It is not appropriate to prohibit minerals and waste development in sensitive groundwater areas. Minerals in particular can only be worked where they are found and so location options for the economically viable and environmentally acceptable extraction of minerals may be limited. As outlined in Policies MIN4 and WST2, minerals and waste development will only be permitted where proposals avoid and/or minimise potentially adverse impacts to acceptable levels. Assessment of the impacts of minerals and waste development on groundwater will be undertaken on a site-by-site basis at the planning application stage.

Object

Representation ID: 7810

Received: 08/01/2024

Respondent: Edith Weston Parish Council

Policy WST2 clause (e) considers a range of impacts in terms of waste related development. We suggest that a similar clause is included for proposals in relation to future mineral extraction.

Including a clause similar to Policy WST2 clause (e) in Policy MIN4 is not considered necessary when a range of impacts from minerals development are already detailed throughout Policy MIN4 and the supporting text. These include impacts on the natural and historic environment and on human health, including from noise, dust, vibration, visual intrusion, traffic, tip and quarry slope stability, differential settlement of quarry backfill, mining subsidence, increased flood risk, impacts on the flow and quantity of surface and groundwater and migration of contamination from the site, together with cumulative impacts.

Support

Representation ID: 7960

Received: 08/01/2024

Respondent: Ryhall Parish Council

MIN4 Generally Support

Noted.

Object

Representation ID: 7993

Received: 07/01/2024

Respondent: Mr Harold Dermott

Ketton Cement works has detrimental impacts on pollution, creation of dangerous gases and carbon generation in Rutland. This cannot be ignored. Options for management include sequestration and offsetting. Please read accompanying report.

Noted. Government policy requires Mineral Planning Authorities to provide a stock of permitted reserves to support maintenance of cement production of at least 15 years for cement primary and secondary materials to maintain an existing plant, such as the Ketton Cement works. Until/if there is a change in national regulations/guidance in relation to cement production and decarbonisation, then the plan preparation will continue in line with the current national guidance.
Where possible recycled and secondary aggregates should be used in place of primary aggregates in order to conserve resources, minimise waste and contribute to the move to a low carbon economy. An increase in the consumption, and production, of recycled and secondary aggregates is supported through the emerging Local Plan.