Saint – Gobain PAM UK Ltd Stanton Regeneration – Gobain PAM UK Ltd Stanton Regeneration Preliminary Prior Coal Extraction Feasibility Review Project no. 301252 RSK GENERAL NOTES

OCTOBER 2014

Saint – Gobain PAM UK Ltd

Stanton RegenerationPreliminary Prior Coal Extraction Feasibility Review

Project no. 301252

RSK GENERAL NOTES

Project No.: 301252-1(01)

Title: Preliminary Prior Coal Extraction Feasibility Review: Stanton Regeneration

Client: Saint - Gobain PAM UK Limited

Date: October 2014

Office: RSK, Derby Tel: 01332 542740, contact: Melanie Rowley

Author Melanie Rowley Technical reviewer Paul Taunton

Signature Signature

Date: October 2014 Date: October 2014

Project manager Melanie Rowley

Signature

Date: October 2014

RSK Environment Limited (RSK) has prepared this report for the sole use of the client, showing reasonable skill and care, forthe intended purposes as stated in the agreement under which this work was completed. The report may not be relied upon byany other party without the express agreement of the client and RSK. No other warranty, expressed or implied, is made as tothe professional advice included in this report.

Where any data supplied by the client or from other sources have been used, it has been assumed that the information iscorrect. No responsibility can be accepted by RSK for inaccuracies in the data supplied by any other party. The conclusionsand recommendations in this report are based on the assumption that all relevant information has been supplied by thosebodies from whom it was requested.

No part of this report may be copied or duplicated without the express permission of RSK and the party for whom it wasprepared.

Where field investigations have been carried out, these have been restricted to a level of detail required to achieve the statedobjectives of the work.

This work has been undertaken in accordance with the quality management system of RSK Environment Ltd.

Status: Final

Saint – Gobain PAM UK Ltd iPreliminary prior coal extraction feasibility review: Stanton RegenerationReport no. 301252-1 (00)

CONTENTS

1 INTRODUCTION.............................................................................................................................. 11.1 Scope of works ........................................................................................................................ 11.2 Sources of information ............................................................................................................. 2

2 THE SITE ......................................................................................................................................... 32.1 Site location.............................................................................................................................. 32.2 Site description ........................................................................................................................ 32.3 Future development ................................................................................................................. 4

3 GEOLOGY ....................................................................................................................................... 53.1 Made ground............................................................................................................................ 53.2 Superficial geology................................................................................................................... 53.3 Solid geology............................................................................................................................ 53.4 Review of mining (including coal and ironstone) ..................................................................... 6

3.4.1 Previous investigation and review in relation to mining ............................................... 94 COAL RESERVES REVIEW ......................................................................................................... 11

4.1 Introduction ............................................................................................................................ 114.2 Planning position.................................................................................................................... 114.3 Mineral rights and prospecting............................................................................................... 124.4 Methodology........................................................................................................................... 124.5 Assumptions........................................................................................................................... 134.6 Estimate ................................................................................................................................. 14

5 CONCLUSIONS AND RECOMMENDATIONS ............................................................................. 15BIBLIOGRAPHY .................................................................................................................................. 17

TABLESTable 1: Summary of shaft records (Encia May 08) ............................................................................... 8

FIGURESFigure 1 Site location plan

Figure 2 Geological constraints plan

Figure 3 Schematic opencast extent

APPENDICESAppendix A Service constraints

Appendix B Potential extractable coal volume calculations

Saint – Gobain PAM UK Ltd 1Preliminary prior coal extraction feasibility review: Stanton RegenerationReport no. 301252-1 (01)

1 INTRODUCTION

RSK Environment Limited (RSK) was commissioned by MLA on behalf of Saint-GobainPAM UK Limited (Saint-Gobain) to carry out a preliminary assessment of the feasibilityof prior extraction of coal underlying the land at the former Stanton Ironworks, in supportof an outline planning application. Please refer to the attached Figure 1, Site LocationPlan.

RSK has undertaken a preliminary environmental and geotechnical assessment of theland at the former ironworks site. For ease of this assessment, the site was sub-dividedinto seven subject areas, which will be referred to throughout this assessment. Pleaserefer to the attached Figure 2.

This report is subject to the RSK service constraints given in Appendix A.

1.1 Scope of works

The purpose of the report is to determine, based on available preliminary data, whetherit is likely to be economically viable to remove any shallow in situ coal deposits as part ofthe ground works prior to the proposed development.

The following issues have been considered:

geological summary

planning situation and reserve ownership

quantification of coal beneath the Stanton site

quantification of coal sterilised by existing developments

quantification of coal sterilised if the proposed development at the Stanton site isundertaken.

For the purpose of this report the term ‘sterilised’, in relation to coal reserves, meanscoal that cannot reasonably be recovered due to existing or proposed surface or sub-surface development or due to the proximity of such developments, or through thepresence of environmental factors.

Information obtained by Gordons LLP from the Land Registry confirms the mines andminerals which exist under the land are owned by the Duke of Rutland of the BelvoirEstate. Therefore any revenue which would be generated by extraction would not be forthe benefit of our client.


1.2 Sources of information

The following sources of information have been used:

British Geological Survey, England and Wales Sheet 125, (Derby), Solid and DriftEdition (1972), 1:50,000 Scale

December 2007 ‘Geo-environmental Investigation of Land at Stanton Iron Works,Stanton-by-Dale’ Report ref. 9469/2. Prepared by Encia Consulting Ltd on behalf ofSpring Urban Regeneration Limited (Encia – Dec 2007)

April 2008 ‘Geo-environmental Assessment, Lows Lane, Stanton-by-Dale’, Reportref. 12170873-002. Prepared by WSP Environmental UK on behalf of PersimmonHomes (North Midlands) Ltd (WSP – Apr 2008)

May 2008 ‘Mining Desk Study Investigation of Land at Stanton Iron Works, Stanton-by-Dale’ Report ref. 9469/4. Prepared by Encia Consulting Ltd on behalf of SpringUrban Regeneration Limited (Encia – May 2008)

July 2008 ‘Geo-environmental Appraisal of Land at Stanton Stockpile Area’ Reportref. 9469/5. Prepared by Encia Consulting Ltd on behalf of Spring UR Residential(Encia – Jul 2008)

April 2010 ‘Minerals Core Strategy’ Derby and Derbyshire Minerals and WasteDevelopment Framework.


2 THE SITE

This section summarises the site location, description and proposed future development.This information has been taken from the Preliminary Risk Assessment report (PRA),dated April 2010, reference 131027-5 (01), by RSK, which should be consulted if furtherdetail is required.

2.1 Site location

The site lies in the area of New Stanton to the north and south of Lowes Lane, and itsapproximate centre is at National Grid reference SK 469390. The site is locatedapproximately 800m north of the village of Stanton-by-Dale and approximately 3.5km tothe south of Ilkeston town centre. The site is in a predominantly rural setting, with anarea of industry located to the north. A site location plan is presented as Figure 1.

2.2 Site description

The site occupies approximately 219ha and currently comprises an operational Saint-Gobain pipe manufacturing, storage and distribution facility, including areas leased forlight commercial/industrial use, a large concrete production and storage facility operatedby Stanton Bonna and the large Hallam plant (a former foundry, recently demolished).The site lies at an elevation of around 60m above Ordnance Datum (AOD) at itssouthern boundary, falling gently to the north, to around 45m AOD at the northernboundary.

The site was zoned by RSK during production of the PRA based on former land uses.The zones are:

Zone A – Grove farm tip and agricultural land

Zone B – Stanton Bonna concrete works, two substations, hardstanding and disusedland

Zone C – Former Stanhope plant (former foundry), reservoir, areas used for storageand auxiliary buildings including offices, a nursery and air raid shelters

Zone D – Hallam plant (former foundry)

Zone E – Open ground, Chadwicks pond and Nutbrook canal

Zone F – Flange plant, old tip and Nutbrook canal.

The zones are illustrated on Figure 2.


2.3 Future development

The master plan details the following proposed uses for each zone:

Zone A – Grove farm tip, to be closed under a separate planning application witha green space end use

Zone B – Green space end-use

Zone C – Majority residential end-use with private gardens and areas of publicopen space, an area of retail development within the north of Zone C and aprimary school

Zone D – Majority residential end-use with private gardens and areas of publicopen space, an area of retail development within the south of Zone D, a carehome and an area of green space in the north

Zone E – Residential end-use, with private gardens and areas of public openspace in the east and an area of green space in the north

Zone F – Mixed commercial/ light industrial in the south and green space end-usein the north.


3 GEOLOGY

Details of the site geological setting have been compiled from published data that coversthe site and surrounding area, including preliminary intrusive investigation undertaken byRSK. The geological details are presented with a greater emphasis on the solid geology,although a brief summary of the made ground and superficial geology is also presented.The shallowest material (made ground) is described first, followed by the superficialsediments and then the solid geology.

3.1 Made ground

Made ground was present across the majority of the site to depths varying between0.2m below ground level (bgl) and 9.0m bgl (both recorded in Zone C). The madeground was found to consist of varying amounts of foundry sand and slag with otherconstituents such as metal reinforcement bar, plastic, bituminous paving, timber ash,lino, broken electric cable, charcoal, drainpipe, railway sleepers, concrete lightingcolumns, glass, tyres, wiring, mineral wool insulation, fabric and redundant electricalcables.

3.2 Superficial geology

The published geological mapping indicates that superficial deposits are present withinthe north and east of the site. In the north superficial deposits comprise Alluvium andwithin the east the First River Terrace Deposits associated with the River Erewash.Superficial deposits are not recorded across the remainder of the site, which is directlyunderlain by the Pennine Lower Coal Measures Formation.

3.3 Solid geology

The Coal Measures which underlie the whole site are faulted with one fault in the north-eastern portion and one in the central eastern portion, both trending north–south anddown throwing to the north–north-east. Three coal seams are known to outcrop at thesurface across the site, with a fourth to the south of the site. The Coal Measuressequence is indicated to be dipping at 5 to 10 degrees to the north-north east,comprising the following seams (their approximate location is shown on Figure 2).

Kilburn – located in the northern portion of the site, striking in a north-west to south-eastorientation. The coal seam underlies the alluvium in the northern portion of the site andis faulted beneath the reclamation area (zone F) in the east of the site, with the faultrunning north–south between the small valves and flange plant and reclamation area.British Geological Survey (BGS) records suggest that the coal varies in thickness from


0.7m to 1.8m, and comprises predominantly bright coal with subordinate bands and is ofgood quality with a low to moderate ash content.

Norton – this seam underlies the central portion of the site striking in a north-westerly–south-easterly direction. Underlying the Grove Farm Tip, Stanton Bonna and formerStanton Works (Zone A, B and C), the seam is reportedly typically less than 0.7m thickbut has been worked in the vicinity of the south-eastern part of the site.

Forty Yard - this seam outcrops approximately 100m south of the Norton Coal Seam,also underlying the Grove Farm Tip, Stanton Bonna and the former Stanton Works(zones A, B and C). It is reportedly typically less than 0.3m thick.

Alton – this seam outcrops very close to the southern boundary of the site, in an area offormer opencast mining, located immediately south of the southern boundary andencroaching onto the site itself. This was the Beal opencast mine that worked the Altonseam as shown on Figure 2.

3.4 Review of mining (including coal and ironstone)

The following sources of information have been reviewed in respect to the mining andironstone works at the site, together with previous investigation reports as detailed inSection 1.2:

BGS records

Coal Authority (CA) Mining Records Office.

The site has been subject to historical opencast working of coal and ironstone as well asunderground shallow mining of coal with some thirty-six mineshafts recorded within thesite.

The BGS maps and Coal Authority records show an area of former opencast miningimmediately south of the southern boundary; this was the Beal opencast mine workingthe Alton seam that encroaches onto the site. The approximate area of the opencastmine is also on shown Figure 2.

The CA report obtained by WSP (report ref: 00069081-07 dated 4 July 2007) and theCA report obtained by Encia (report ref: 00120586-07 December 2007) both stated thefollowing:

the property site is in the likely zone of influence from workings in two seams of coalat shallow to 60m depth that were last worked in 1855. This has been revised by theCA, and the site is considered to be underlain by workings in a single seam

the property is in the likely zone of influence from workings in two seams of ironstoneat shallow to 40m depth and last worked in 1900


the property is not in the likely zone of influence of any present or futureunderground or opencast coal workings. However, reserves of coal exist in the localarea which could be worked at some time in the future

no notice of the risk of land being affected by subsidence has been given underSection 46 of the Coal Mining Subsidence Act 1991

there are 19 mine entries (reported by WSP- May-2008), this relates to RSK Zone F.The CA report within the Encia July 2008 desk study, recorded 42 mine entries on orwithin 20m of the site, the Encia desk study covered the same area of site as theRSK assessments. There is no record of any steps that have been undertaken totreat mine entries

records may be incomplete. Consequently there may exist in the local area mineentries of which the Coal Authority has no knowledge

at the surface, there are no known faults or other lines of weakness due to coalmining that have made the property unstable

the property is within the boundary of an opencast site from which coal has beenremoved by opencast methods

there is no record of mine gas emission requiring action of the Coal Authority withinthe site

where development proposals are being considered, technical advice should beobtained before beginning the site

the site is within an area underlain by clay, sand and natural compressible depositsthat could potentially cause ground movements.

A review of the geological memoir detailed in the Encia May 08 Mining Investigation, the1:10,000 BGS map, together with the CA abandonment plans and borehole informationfrom the BGS indicates that the site is underlain at shallow depth by two workable coalseams (Norton and Kilburn) and three ironstone bands (known locally as “Rakes”:Honeycroft Rake, Civil Rake and Dale Moor Rake). These have been summarised inTable 1 below (Encia May 08) and are also shown on Figure 2.

Within the Encia May 08 Report, a BGS borehole record is reported from one of theshafts located at the site, the Stanton Sinking, showing the shaft having been sunkthrough the Kilburn Coal Seam. Table 1 presents a summary of the information from theBGS shaft and borehole records.


Table 1: Summary of shaft records (Encia May 08)

Seam Thickness (m) Depth to base (m)

Stanton Ironworks Sinking (from BGS memoirsheet 125 and BGS map sheet 125)

Kilburn (coal) 1.45 1.45

Norton (coal) 0.69 107.29

Forty Yard (upper) 0.30 115.82

Forty Yard (lower) 0.15 118.57

Alton 0.84 146.00

BGS borehole records - Record 1


Civil Rake (Ironstone) 8.74 106.40


Dale Moor Rake (Ironstone) 5.28 114.91



Alton (coal) 0.84 146.06



Civil Rake (Ironstone)


Dale Moor Rake (Ironstone)



Alton (coal) 0.84 145.63



Honeycroft Rake 3.76 14.08

Civil Rake (Ironstone) 6.68 96.13


Dale Moor Rake (Ironstone) 8.34 115.34



Alton (coal) 0.84 145.97


Based on the BGS memoir, the most significant seam locally was the Alton seamworked by the Beal opencast mine to the south of the site. In addition, the site has thepotential to be underlain by workings in Kilburn (0.75m) and the Norton (0.3m) seams.

A review of the BGS shaft record indicates both the Kilburn Seam and Norton Seam tobe locally of a greater thickness (1.45m and 0.69m respectively). Review of theabandonment plans (EM522 2 of 5) indicates recorded coal workings north of theoutcrop of the Kilburn seam to the west of the main fault line; this is referred to as theLadywood Seam on the abandonment plan. However there is no reference to this in theBGS records and it is therefore considered that these are likely to be workingsassociated with the Kilburn seam.

3.4.1 Previous investigation and review in relation to mining

The coal identified in the WSP investigation BH6 is believed to be the Forty Yard seamand was recorded as 0.30m thick. This was interpreted as the upper leaf of the spiltseam, which the BGS memoir state is not of economic importance.

Workings in the Kilburn seam are indicated east of the fault. Encia has undertaken rotarydrilling in this area, with fourteen holes drilled east of the fault. Four were located in therecorded worked area, varying in depth from 15m to 45m.

Based on the Encia mining investigation (May 2008), intact coal interpreted as theKilburn seam was encountered in three boreholes at a thickness of 0.7m dipping to thenorth as anticipated. However, none of the four probeholes drilled to the east of thesecond fault encountered the anticipated workings, or identified coal, voids/brokenground/ backfill or ironstone.

Where the Kilburn seam has been identified as intact in the minor fault block (locatedwithin RSK Zone F, as shown on Figure 3), there is sufficient cover to the seam if anyworkings were present, which have not been identified. It appears that insufficient coveris present east of the second fault, although workings have not been identified in thearea where they were anticipated.

Encia predicted that, based on the calculated combined throw of the two faults (approx.25m), it is possible that the Kilburn seam is present at a level below the drilling to date orthat workings have been incorrectly identified as coal and relate to ironstone.

During the Encia Stanton stockpile investigation of July 2008, nineteen rotary holes weredrilled to investigate the presence of shallow mine workings. Broken ground or packedwaste was encountered in five locations and was reported to be associated with theKilburn coal seam.

The WSP Investigation April 2008 encountered coal measures which generallycomprised weak and very weak mudstone. No evidence (such as loss of flush) ofpotential shallow workings was encountered within the rotary holes undertaken. Coalwas encountered at depths of 8.4m and 9.45m bgl (RSK zone E), 5.5m to 6m bgl (RSKzone E) and between 30m and 30.5m bgl (RSK zone E).


There is also potential for unrecorded workings in the Norton seam.

The Kilburn and Alton seams are not being considered within this assessment. Thelocation of the Kilburn seam close to the northern boundary of the site would not allowan adequate area of surface mining to be undertaken, furthermore this area of the site isnot proposed for surface development and will remain as an area of open space. TheAlton Seam outcrops to the south of the site and with the dip in a northerly directionresults in the seam being at depths in excess of the 30m at the southern boundary of thesite.


4 COAL RESERVES REVIEW

4.1 Introduction

A review of the potential for coal reserves suitable for opencast mining beneath theStanton Site is presented in relation to the amount of coal that is deemed economicallyviable to be extracted based on current market conditions and areas that may besterilised due to existing and proposed developments. The methodology adopted isbriefly described, along with the main assumptions that have been made in providing thereview.

4.2 Planning position

In accordance with the National Planning Policy Framework (NPPF) Local Authoritiesare required to define Minerals Safeguarding Areas (MSA) and adopt appropriatepolicies in order that known locations of specific mineral resources of local and nationalimportance are not sterilised by non-mineral development, whilst not creating apresumption that resources defined will be worked.

Local Authorities are further required to set out policies to encourage the prior extractionof minerals, where practicable and environmentally feasible.

The Derby and Derbyshire Minerals Local Plan (DDMLP), Policy MP27 (Coal Extractionand Colliery Spoil) and Policy MP17 (Safeguarding resources), both seek to safeguard amineral resource, the aim being to ensure that economically workable mineral depositsare extracted in advance of other development, unless this would give rise tounacceptable impacts or lead to excessive delays to the development.

Policy MP27 C (2) of the DDMLP states that:

‘When considering whether the unacceptable adverse environmental impact of aproposal is outweighed by the benefits that the development would provide, importancewill be given to those benefits that would be unlikely to be achieved by other means. Inparticular, the following will be taken into account, where relevant, either separately orcumulatively:

(2) Whether the proposed extraction is necessary in advance of other approvedpermanent development in order to avoid sterilisation of reserves of minerals, or toprovide sites for development which would provide local or community benefits;provided that ....the extraction will be completed and the land reclaimed in time and to astandard, to allow subsequent development to take place as planned withoutunreasonable delay’.


4.3 Mineral rights and prospecting

The Coal Authority manages the historic legacy of British Coal Corporation which waspassed to them by virtue of the Coal Industry Act 1994 by way of restructuring schemesafter the privatisation of British Coal. The Authority’s estates team also deal with furthercovenants formerly in favour of the National Coal Board and British Coal now passed tothe Coal Authority by virtue of the Coal Industry Act 1994. Any activity, which intersects,disturbs or enters any of the Authority's coal interests requires their prior writtenauthorisation. This authorisation can take the form of a Licence, an Agreement or aPermit, depending upon the activity to be carried out.

The following activities require a Licence or Agreement and are dealt with by theAuthority's licensing department:

the mining of coal

exploration for coal or deep drilling through coal for other purposes (e.g. waterabstraction)

underground coal gasification

digging and carrying away of coal during non-coal mining related activities (incidentalcoal)

exploration and exploitation of coal methane.

Activities including initial site investigation boreholes and any subsequent treatment ofabandoned coal mine workings and coal mine entries for ground stability purposesrequire a Permit and are dealt with by the Authorities’ permissions department.

Information obtained from the Land Registry confirms the mines and minerals whichexist under the land are owned by the Duke of Rutland of the Belvoir Estate.

4.4 Methodology

The following methodology was adopted to assess the coal reserves beneath theproposed development at Stanton. The boundary of the area to be assessed for thepurpose of this estimation is shown on Figure 2.

The calculations for coal feasibility extraction have been made on the basis of certainassumptions that are further described below. The potential effect on coal estimates,caused by these assumptions are indicated where appropriate.


4.5 Assumptions

Calculations for coal reserve / sterilisation estimation has been made using the followingassumptions, following consultation with a number of contractors, and are based on thecurrent market conditions:

The coal seams being considered are the Norton and Forty Yard (upper and lower)beneath the proposed developable area within Zone C. The Kilburn and Alton seams arenot being considered within this assessment.

the maximum depth of extraction is approximately 30m bgl, therefore the lowest coalseam that could be mined is the Forty Yard Lower ( 0.15m thick) – if the thicknessof superficial deposits are greater than those anticipated, the viability of removingcoal from the Forty Yard seam may need to be reassessed

the seams are reported as dipping at between 5 and 10 degrees, with a distancebetween seam outcrops of circa 110m, which suggests that the dip locally is close to5 degrees

historic coal extraction is reportedly only from the Kilburn Seam, however there is thepotential for unrecorded shallow workings in the Norton and Forty Yard, which willrequire investigation. For the purpose of this assessment calculations have beenmade based on 100% of coal remaining intact, 70% and then 50%

coal seam thickness – Norton Seam (0.69m), Forty Yard Upper (0.30m) and FortyYard Lower (0.15m)

a reduction in seam thickness of 100mm has been allowed to account for some lossduring excavation, therefore an assumption has been made of recoverable coal asNorton Seam (0.59m) and Forty Yard Upper (0.20m)

the slope of the high wall has been assumed at 1:1

coal density is between 1.1t/m3 and 1.5t/m3 - 1.33t/m3 has been used for thecalculations

currently the sale price of coal varies between £20 and £50 per ton, depending onthe chemistry and hence the potential markets available. It is not clear where in thisrange, the coal beneath the site will lie

discussions with opencast contractors indicate that in current market conditions it iseconomically viable to extract coal at a ratio between overburden and coal ofbetween 20:1 and 23:1

there is no defined guidance for buffer zone distances alongside existing residential,commercial, agricultural or highways land uses, all of which are adjacent to the siteboundary being considered. This would be dependent on noise and dust assessmentin relation to adjacent neighbours and the structural integrity of the ground to be


excavated. Therefore a 50m buffer zone (sterilised zone) has been assumed forexisting residential, road infrastructure, industrial and agricultural to the north, eastand west.

4.6 Estimate

Estimates of coal reserves feasible for extraction prior to development, adopting theabove assumptions and methodology, have been calculated and included withinAppendix B and are presented on Figure 3 and are summarised below.

It should be recognised that these estimates are based on limited information regardingthe seam thickness, dip, and extent of previous mining local to the area of proposedextraction. A detailed borehole investigation would be required to confirm theparameters used in these estimates, and to produce more accurate data for design ofthe opencast mine.

The initial estimate has been based on 100% intact coal remaining in both seams, a dipof 5 degrees, and an extraction ratio of approximately 23:1. These assumptions indicatea maximum excavation length of 105m and depth of 8.5m would be feasible for the FortyYard upper leaf, and for the Norton seam a maximum excavation length of 310m anddepth of 25m. These dimensions suggest total recoverable coal of circa 175,000 tonnes.This number would only be achieved if all of the assumptions are proven to befavourable which is highly unlikely.

If the seam dip is steeper, or the seams have been worked, the excavation dimensionswould need to be very much smaller in order to maintain the same extraction ratio of23:1. A second calculation has been based on only 50% intact coal remaining in bothseams, and a steeper dip of 9 degrees, and the extent of the excavation reduced tomaintain the same extraction ratio of approximately 23:1. These revised assumptionsindicate a maximum excavation length of only 29m and depth of 4m would be feasiblefor the Forty Yard upper leaf. Shallow coal so close to the outcrop may be weatheredand of poor quality. For the Norton seam a maximum excavation length of 73m anddepth of 11.5m is calculated. These dimensions would result in a very much smaller totalrecoverable coal quantity of only about 22,000 tonne.

Further calculations are presented for different percentages of workings and dips.

The figures discussed above and presented in Appendix B, reflect the feasibility of prior-extraction of coal based on current market conditions and the data available; they do notreflect the potential profit in relation to this activity.


5 CONCLUSIONS AND RECOMMENDATIONS

Information obtained by Gordons LLP from the Land Registry confirms the mines andminerals which exist under the land are owned by the Duke of Rutland of the BelvoirEstate. Therefore any revenue which would be generated by extraction would not be forthe benefit of our client.

The complex nature of land ownership and mineral rights could prove to be problematicto any future extraction proposals. This aspect is outside of the scope of this report.

The Alton seam outcrops to the south of the proposed development area. At thepredicted dip beneath the Stanton development, opencast extraction would result in anoverburden to coal ratio of greater than 1:30 which would currently be uneconomic toextract, this has therefore not been considered any further.

The Killburn Seam which outcrops along the northern boundary is mostly within an areathat is not proposed for surface development. The proposal for this area is for it toremain as open space and it contains several surface water features that are to beretained including the Nutbrook Canal, the Nut Brook and Chadwicks pond. The onlyinfrastructure proposed to be developed in this area is the link road to the north, it maytherefore prove economic for limited extraction within this area.

The preliminary estimates therefore suggest that based on the limited available data andcurrent market conditions extraction of the coal (both the Norton and the upper leaf ofthe Forty Yard seam) would be feasible in favourable economic conditions. Howeverthere is likelihood of the seams having been significantly worked and therefore the totalcoal quantity recoverable may be low.

Opencast mining will create a high wall feature potentially restricting the flexibility of thefuture surface development and/or resulting in additional costs, i.e. additionalearthworks, and possibly more expensive foundation solutions. The removal of a largevolume of coal from the site will result in an impact to the proposed mass balancecalculations, which will also need consideration.

If future borehole investigations indicate that the seams have been worked at shallowdepth close to the outcrop, the removal of the Norton and Forty Yard seam would alsonegate the possible requirement for the treatment of shallow mine workings across aproportion of the development area within Zone C.

This preliminary feasibility review is based on limited available data and current marketconditions. A further detailed mining investigation would be required to verify theassumptions made, to confirm seam thicknesses, estimate the percentage of intact coaland carry out analyses to determine the quality of the coal.


We have not at this stage considered requirements for dust, noise and vehiclemovements in terms of planning. However, these assessments would also be required.


BIBLIOGRAPHY

British Geological Survey, England and Wales Sheet 125, (Derby), Solid and Drift Edition (1972),1:50,000 Scale.

December 2007 ‘Geo-environmental Investigation of Land at Stanton Iron Works, Stanton-by-Dale’ Report ref. 9469/2. Prepared by Encia Consulting Ltd on behalf of Spring UrbanRegeneration Limited (Encia – Dec 2007).

April 2008 ‘Geo-environmental Assessment, Lows Lane, Stanton-by-Dale’, Report ref. 12170873-002. Prepared by WSP Environmental UK on behalf of Persimmon Homes (North Midlands) Ltd(WSP – Apr 2008).

May 2008 ‘Mining Desk Study Investigation of Land at Stanton Iron Works, Stanton-by-Dale’Report ref. 9469/4. Prepared by Encia Consulting Ltd on behalf of Spring Urban RegenerationLimited (Encia – May 2008).

July 2008 ‘Geo-environmental Appraisal of Land at Stanton Stockpile Area’ Report ref. 9469/5.Prepared by Encia Consulting Ltd on behalf of Spring UR Residential (Encia – Jul 2008).

April 2010 ‘Minerals Core Strategy’ Derby and Derbyshire Minerals and Waste DevelopmentFramework.

FIGURES

Saint – Gobain PAM UK LtdPreliminary prior coal extraction feasibility review: Stanton RegenerationReport no. 301252-1 (01)

Reproduced from the 1992 Ordnance Survey 1:50,000 Scale Landranger Map 129, OSGR – SK 469 390 with the permission of the Controller of Her Majesty’s Stationery Office, Crown Copyright. Licence No. 100014807

RSK Group PLC, 18 Frogmore Road, Hemel Hempstead, Hertfordshire, HP3 9RT.

SITE LOCATION MAP

SITE LOCATION

SAINT-GOBAIN PAM UK LIMITED STANTON REGENERATION PRELIMINARY PRIOR COAL EXTRACTION FEASIBILITY REVIEW

301252-1(01) FIGURE 1


APPENDIX ASERVICE CONSTRAINTS1. This report and the preliminary risk assessment carried out in connection with the report (together the "Services") were compiled

and carried out by RSK Environment Limited (RSK) for Saint – Gobain PAM UK Ltd (the "client") in accordance with the terms of acontract between RSK and the "client", dated 4 November 2013. The Services were performed by RSK with the skill and careordinarily exercised by a reasonable environmental consultant at the time the Services were performed. Further, and in particular,the Services were performed by RSK taking into account the limits of the scope of works required by the client, the time scaleinvolved and the resources, including financial and manpower resources, agreed between RSK and the client.

2. Other than that expressly contained in paragraph 1 above, RSK provides no other representation or warranty whether express orimplied, in relation to the Services.

3. Unless otherwise agreed the Services were performed by RSK exclusively for the purposes of the client. RSK is not aware of anyinterest of or reliance by any party other than the client in or on the Services. Unless expressly provided in writing, RSK does notauthorise, consent or condone any party other than the client relying upon the Services. Should this report or any part of this report,or otherwise details of the Services or any part of the Services be made known to any such party, and such party relies thereon thatparty does so wholly at its own and sole risk and RSK disclaims any liability to such parties. Any such party would be welladvised to seek independent advice from a competent environmental consultant and/or lawyer.

4. It is RSK's understanding that this report is to be used for the purpose described in the introduction to the report. That purpose wasa significant factor in determining the scope and level of the Services. Should the purpose for which the report is used, or theproposed use of the site change, this report may no longer be valid and any further use of or reliance upon the report in thosecircumstances by the client without RSK 's review and advice shall be at the client's sole and own risk. Should RSK be requested toreview the report after the date hereof, RSK shall be entitled to additional payment at the then existing rates or such other terms asagreed between RSK and the client.

5. The passage of time may result in changes in site conditions, regulatory or other legal provisions, technology or economicconditions which could render the report inaccurate or unreliable. The information and conclusions contained in this report shouldnot be relied upon in the future without the written advice of RSK. In the absence of such written advice of RSK, reliance on thereport in the future shall be at the client's own and sole risk. Should RSK be requested to review the report in the future, RSK shallbe entitled to additional payment at the then existing rate or such other terms as may be agreed between RSK and the client.

6. The observations and conclusions described in this report are based solely upon the Services which were provided pursuant to theagreement between the client and RSK. RSK has not performed any observations, investigations, studies or testing not specificallyset out or required by the contract between the client and RSK. RSK is not liable for the existence of any condition, the discovery ofwhich would require performance of services not otherwise contained in the Services. For the avoidance of doubt, unless otherwiseexpressly referred to in the introduction to this report, RSK did not seek to evaluate the presence on or off the site of asbestos,electromagnetic fields, lead paint, heavy metals, radon gas or other radioactive or hazardous materials.

7. The Services are based upon RSK's observations of existing physical conditions at the Site gained from a walk-over survey of thesite together with RSK's interpretation of information including documentation, obtained from third parties and from the client on thehistory and usage of the site. The Services are also based on information and/or analysis provided by independent testing andinformation services or laboratories upon which RSK was reasonably entitled to rely. The Services clearly are limited by theaccuracy of the information, including documentation, reviewed by RSK and the observations possible at the time of the walk-oversurvey. Further RSK was not authorised and did not attempt to independently verify the accuracy or completeness of information,documentation or materials received from the client or third parties, including laboratories and information services, during theperformance of the Services. RSK is not liable for any inaccurate information or conclusions, the discovery of which inaccuraciesrequired the doing of any act including the gathering of any information which was not reasonably available to RSK and includingthe doing of any independent investigation of the information provided to RSK save as otherwise provided in the terms of thecontract between the client and RSK.

8. The phase II or intrusive environmental site investigation aspects of the Services is a limited sampling of the site at pre-determinedborehole and soil vapour locations based on the operational configuration of the site. The conclusions given in this report are basedon information gathered at the specific test locations and can only be extrapolated to an undefined limited area around thoselocations. The extent of the limited area depends on the soil and groundwater conditions, together with the position of any currentstructures and underground facilities and natural and other activities on site. In addition chemical analysis was carried out for alimited number of parameters [as stipulated in the contract between the client and RSK] [based on an understanding of theavailable operational and historical information,] and it should not be inferred that other chemical species are not present.

Any site drawing(s) provided in this report is (are) not meant to be an accurate base plan, but is (are) used to present the general relativelocations of features on, and surrounding, the site.


APPENDIX BPOTENTIAL EXTRACTABLE COAL VOLUMECALCULATIONS

Stanton Volume Calculations

Upper level of site 60 mLower level of site 45 m

Site width 1000 m Approximate estimated site dimensionTan of slope 0.015

Calculated site slope 0.015 radianCalculated site slope 0.859 degrees Ground slope likely to make little difference?

Checking the above:Level at NE boundary 59 m Level at SE boundary 50 m

Width of Zone C 575 m Distance measured from Google EarthTan of slope 0.016

Calculated site slope 0.016 radianCalculated site slope 0.897 degrees Confirms calculation above is reasonable

Note: assuming the site to be flat is a conservative assumption. The fact that the site slopes down in the directionof dip at about 1 degree means that less overburden will need to be removed than is calculated for a flat site.

Seam vertical separation 10.0 m Average (8.4m to upper leaf, 11.2m to lower leaf)Seam dip 10.0 degrees From report text

Levels as stated in report text

Levels taken from Google Earth at boundaries of Zone C

Seam dip 10.0 degrees From report textSeam dip 0.17 radian

Calculated outcrop separation 57 m Based on dip and separation statedExpected outcrop separation 110 m approx. Shown on geological map

Note: there is an inconsistency in the data. If two seams are separated by 10m vertically and both dip at 10 degreesthe outcrops should be approximately 57m apart, but the mappping shows an outcrop separation of about 100m?Need to assess 2 cases, 110m between outcrops (based on map) and 57m (based on vertical separation and dip)

EXAMPLE CALCULATIONSeam dip 5.0 degreesSeam dip 0.09 radian

Distance between outcrops 110 mFORTY YARD SEAM (UPPER LEAF ONLY)

Assumed max. dig depth 8.5 mLength of Forty Yard seam exposed 97.2 m

High wall dig length (at 1:1 slope) 8.5 mExcavation length 105.7 m

Cross sectional area of dig 449 m2

Excavation width 700.0 mExcavation volume 314,325 m3

Forty Yard thickness (recoverable) 0.2 mForty Yard thickness (recoverable) 0.2 mForty Yard volume 13,602 m3

RATIO assuming unworked 23.1 :1RATIO assuming 70% remains 33.0 :1RATIO assuming 50% remains 46.2 :1

Do excavations overlap? noNORTON SEAM

Assumed max. dig depth 25.0 mLength of Norton seam exposed 285.8 m

High wall dig length (at 1:1 slope) 25.0 mExcavation length 310.8 m

Cross sectional area of dig 3884 m2

Excavation width 700.0 mExcavation volume 2,719,074 m3

Forty Yard thickness (recoverable) 0.59 mForty Yard volume 118,015 m3

RATIO assuming unworked 23.0 :1RATIO assuming 70% remains 32.9 :1RATIO assuming 50% remains 46.1 :1

CALCULATED EXTRACTION RATIOS AND TONNAGES FOR VARYING SEAM DIP AND DEPTH OF DIG

Depths have been selected to give a ratio of approx 23 in unworked or partially worked seams.

Seam dip degrees 5.0 5.0 5.0 9.0 9.0 9.0Distance between outcrops m 110 110 110 110 110 110

FORTY YARD SEAM (UPPER LEAF ONLY)Assumed max. dig depth m 8.5 5.5 4.0 8.0 5.5 4.0

Length of Forty Yard seam exposed m 97.2 62.9 45.7 50.5 34.7 25.3High wall dig length (at 1:1 slope) m 8.5 5.5 4.0 8.0 5.5 4.0

Excavation length m 105.7 68.4 49.7 58.5 40.2 29.3Cross sectional area of dig m

2449 188 99 234 111 59

Excavation width m 700.0 700.0 700.0 700.0 700.0 700.0Excavation volume m3 314,325 131,603 69,608 163,828 77,434 40,957

Forty Yard thickness (recoverable) m 0.2 0.2 0.2 0.2 0.2 0.2Forty Yard volume m3 13,602 8,801 6,401 7,071 4,862 3,536

RATIO assuming unworked :1 23.1 15.0 10.9 23.2 15.9 11.6RATIO assuming 70% remains :1 33.0 21.4 15.5 33.1 22.8 16.5RATIO assuming 50% remains :1 46.2 29.9 21.7 46.3 31.9 23.2

Do excavations overlap? no no no no no no

NORTON SEAMAssumed max. dig depth m 25.0 17.5 12.5 23.5 16.5 11.5

Length of Norton seam exposed m 285.8 200.0 142.9 148.4 104.2 72.6High wall dig length (at 1:1 slope) m 25.0 17.5 12.5 23.5 16.5 11.5

Excavation length m 310.8 217.5 155.4 171.9 120.7 84.1Cross sectional area of dig m

23884 1903 971 2020 996 484

Excavation width m 700.0 700.0 700.0 700.0 700.0 700.0Excavation volume m3 2,719,074 1,332,346 679,768 1,413,657 696,909 338,535

Forty Yard thickness (recoverable) m 0.59 0.59 0.59 0.59 0.59 0.59Forty Yard volume m3 118,015 82,611 59,008 61,278 43,025 29,987

RATIO assuming unworked :1 23.0 16.1 11.5 23.1 16.2 11.3RATIO assuming 70% remains :1 32.9 23.0 16.5 33.0 23.1 16.1RATIO assuming 50% remains :1 46.1 32.3 23.0 46.1 32.4 22.6

TOTAL RECOVERABLE COALassumed density T/m3 1.33

assuming unworked T 175,051 90,905assuming 70% remains T 85,104 44,582assuming 50% remains T 43,497 22,293

SeamThickness

(m)Depth tobase (m)

Separation(m)

Stanton Ironworks Sinking(from BGS memoir sheet 125and BGS map sheet 125)Norton (coal) 0.69 107.29Forty Yard (upper) 0.3 115.82 8.53Forty Yard (lower) 0.15 118.57 11.28 2.75BGS borehole records - Record 1Norton (coal) 0.69 107.34Forty Yard (upper) 0.3 115.72 8.38Forty Yard (lower) 0.15 118.54 11.2 2.82BGS borehole records - Record 2Norton (coal) 0.69 106.91Forty Yard (upper) 0.3 115.06 8.15Forty Yard (lower) 0.15 117.88 10.97 2.82BGS borehole records - Record 4Norton (coal) 0.69 107Forty Yard (upper) 0.3 115.65 8.65Forty Yard (lower) 0.15 118.47 11.47 2.82

Average Norton/Upper 8.4Average Norton/Upper 8.4Average Norton/Lower 11.2Overall Average Separation 9.8

This Table based on Table 1 in report

Documents

Saint – Gobain PAM UK Ltd Stanton Regeneration – Gobain PAM UK Ltd Stanton Regeneration Preliminary Prior Coal Extraction Feasibility Review Project no. 301252 RSK GENERAL NOTES