5 January 2017

While the Cotswold Green Party agreed with the overall vision for the plan, we objected to the assumption in favour of fracking, mineral extraction in Flood Zone 3bs, quarrying in nature conservation areas of various designations and also wanted assurance on keeping public footpaths open.

The Cotswold Green Party fully supports your Vision Statement:

A Vision for Gloucestershire – 2033

At the start of 2033, Gloucestershire will be a cleaner, greener, more healthy and safer place in which to live, work and visit. It will be a leading county in managing its mineral resources and a successful contributor towards the achievement of sustainable development promoting the re-use

of building and other construction materials; assisting the increased and diversified use of recycled construction & demolition wastes and alternative secondary aggregate, particularly from local sources.

 However, various policies conflict with this vision and we would like to make the following comments:

 1. Objective ENV proposes ‘To protect, and where opportunity exists, enhance, the quality of landscapes, habitats, heritage and other environmental assets, having full regard to their international, national or local importance and value’

BUT Policy DM06 Biodiversity and Geo-diversity CONFLICTS with this by allowing mineral abstraction in SSSIs, National Nature Reserves  and Gloucestershire key wildlife sites  ‘Where the benefits of minerals development clearly outweigh the potential adverse impacts upon the key features of any designation.’

 We therefore OBJECT to Policy DM06

 2. A cleaner, greener, safer Gloucestershire cannot beachieved if there is fossil fuel extraction in any form, whether it be coal, gas or oil. It would be wonderful if Gloucestershire County Council could come forward with a strong stance on this by banning fossil fuel extraction.

The Cotswold Green Party OBJECTS to Sections 5: Strategy and Section 8: Policy MW06 (Oil and Gas) and Policy MW05 Coal because they are contrary to:

  • the Government's committed objectives on Climate Change as detailed in the Climate Change Act 2008 and the COP21 Paris Agreement 2015
  •  the 3 Government-agreed tests set out by the Committee on Climate Change
  •  core principles of environmental, habitat and heritage protection in the National Planning Policy Framework and in the Minerals Local Plan itself

 If GCC cannot impose a complete ban on the extraction of coal, oil and gas, then the policies should be amended so that any development:

  • must demonstrate it will have a net zero impact on climate change from emissions including methane
  • must show that there will be no harm to the environment, groundwater, protected species and local communities. Mitigation or off-setting should not come into the equation as often they do not work
  • must take into account cumulative harmful effects from the earliest stage of application.

This would then be in line with your Vision Statement.

3. The Draft Minerals Plan has commendable aims for maximising the use of secondary and recycled aggregates and we agree with Policy SR01 except for the inclusion of Coal as a Mineral Safeguarded Area.

 We also OBJECT to point 82 where incinerator bottom ash from Javelin Park is envisaged as a secondary aggregate source.  There is clear evidence that this ash is toxic and that much of it should be treated as hazardous waste.  It can potentially cause irreversible environmental harm, both raw and when "weathered" (the weathering process also creates toxic leachate).  Research shows that when IBA is used in road construction, a toxic impact on surroundings can result due to high concentrations of chloride emitted.

4. Policy DM01 Amenity is laudable ‘Minerals development proposals will be permitted only where it can be demonstrated that unacceptable adverse impacts on the amenity of local communities within Gloucestershire and those of neighbouring administrative areas by means of noise, air pollution, vibration and visual intrusion, can be avoided and / or satisfactorily mitigated.

BUT this must be ENFORCED by GCC. Too often infractions are let off or simply ignored.

5. The same applies to Policy DM03 Transport. Too often Public Rights of Way are closed and not reinstated. There should always be diversions. It has been proven that access to and enjoyment of the countryside improves human health and well-being.  Residents in the Cotswold Water Park have seen massive curtailment of their access to the countryside.  Remaining PROWs are often blighted by the close proximity of buildings or intimidating fences.

Gravel lorries must not be allowed to drive through villages and place like Fairford and Lechlade with narrow roads.  The Transport policy restrictions MUST BE ENFORCED

6. The Cotswold Green Party OBJECTS to Policy DM04 Flood Risk

Gravel allows water to travel underground.  Many years of gravel extraction has seen an increase in flooding as water is forced to travel over ground instead of underground. There should be no mineral extraction in Flood Zone 3b (the functional floodplain).

Sustainable Urban Drainage Systems does not work in areas of high water table. Also, flash floods will become more frequent because of climate change