Minerals Plan: Key Issues & Options

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Response Details

Response Details
From Andrew Barton - Peak District…
Date Started: 02 Aug 2010 11:57. Last modified: 02 Aug 2010 11:57
Status Complete
Response ID #76493

Vision (a)

Do you agree that this covers all the elements that a vision for mineral extraction in Derbyshire should cover?

  • Yes
  • No

Vision (b)

If not, please specify what you think should be added or removed.

The PDNPA welcomes and supports one of the components of the proposed vision for the Minerals Core Strategy, namely the recognition that the Derby and Derbyshire Core Strategy will assist in achieving the progressive reduction of minerals won in the Peak District National Park. This will aid the implementation of the overall strategy and aims of Policy 37 of the East Midlands Regional Plan and will ensure cross-boundary correlation with the emerging Peak District National Park Core Strategy. Care will need to be taken to ensure that this element of the vision is not undermined by the desire in the vision to see the potential reduction in aggregates landbank within Derbyshire. Such a reduction could result in an unexpected consequence of increasing pressure to release other new or extended sites within Derbyshire or surrounding areas including the Peak District if not properly managed.

Objectives (a)

Do you agree that this covers all the elements that the objectives for mineral extraction in Derbyshire should cover?

  • Yes
  • No

Objectives (b)

If not, please specify what you think should be added or removed

The PDNPA welcomes and supports the proposed plan objectives for the Minerals Core Strategy, particularly the recognition in Objective C that the plan will help achieve a progressive reduction of minerals won in the Peak District National Park. This will assist the implementation of Policy 37 of the East Midlands Regional Plan and will ensure cross-boundary correlation with the emerging Peak District National Park Core Strategy. The PDNPA also supports Objective D to protect the quality of the natural and built environment from the impact of minerals development, including the Peak District National Park.

Issue 1: Calculating the Provision for Aggregates Beyond 2020 (a)

What would be the best way of calculating the necessary provision we will need to make for aggregates in the period after 2020?

  • Option 1: Make an estimate of provision beyond 2020 based on a straight line projection of the current agreed apportionments (i.e. the annual apportionments for crushed rock and sand & gravel remain the same for the years from 2020 - 2030 as they are from 2005 - 2020).
  • Option 2: Use an average figure of recent annual production rates to calculate annual apportionment figures from 2020 - 2030.
  • Other (please specify)

Please type your answer here if you selected 'Other (please specify)' above
«No response»

Issue 1: Calculating the Provision for Aggregates Beyond 2020 (b)

Do you agree (for both options 1 & 2) that we should also allow for a reduced proportion of the Peak Park's displaced provision of crushed rock on the assumption that, after 2020, other authorities will take an element of this displaced provision?

  • Yes
  • No

Issue 1: Calculating the Provision for Aggregates Beyond 2020 (c)

Please explain how you came to your decision for (b), and if you disagreed, please suggest an alternative approach

«No response»

Issue 2: Identification of Sites for Sand & Gravel (a)

Taking all these considerations into account, one approach to meeting the necessary provision targets would be:

For the period up to 2020 - allocate specific extensions to existing sites rather than allocating new sites

For the period 2020-2030 - allocate broader Areas of Search

 

Do you agree with this approach?

  • Yes
  • No

Issue 2: Identification of Sites for Sand & Gravel (b)

Please explain why you came to that decision. If you disagreed, please suggest an alternative approach that we could take

«No response»

Issue 3: Criteria Based Policy for Industrial Limestone (a)

Do you agree that a criteria based policy is the best way of dealing with the issues outlined above?

  • Yes
  • No

Issue 3: Criteria Based Policy for Industrial Limestone (b)

Please explain why you came to that decision. If you disagreed, please suggest an alterntaive approach that we could take.

The PDNPA would support the inclusion in the Minerals Core Strategy of a policy on Industrial Limestone.

Issue 4: Identifying Future Working Areas for Coal Extraction (a)

Do you agree that a criteria based policy is the best way of dealing with the issues outlined above?

  • Yes
  • No

Issue 4: Identifying Future Working Areas for Coal Extraction (b)

Please explain why you came to your decision in (a). If you disagreed, please suggest an alternative approach that we could take.

«No response»

Issue 4: Identifying Future Working Areas for Coal Extraction (c)

What are the environmental constraints to the identification of future working areas that should be defined?

«No response»

Issue 5: Surface Mining Constraint Areas (a)

Should we designate surface mining constraint areas?

  • Yes
  • No

Issue 5: Surface Mining Constraint Areas (b)

If so, should we follow the approach taken in the Minerals Local Plan, of identifying areas with a sufficient concentration of conservation designations to justify special protection?

  • Yes
  • No

Issue 5: Surface Mining Constraint Areas (c)

What designations should they cover?

«No response»

Issue 5: Surface Mining Constraint Areas (d)

Or should we follow a different approach?

«No response»

Issue 6: Proper and Efficient Use of Building Stone (a)

Do you agree that we should include a policy which stipulates that building stone from new workings should be the principal product?

 

  • Yes
  • No

Issue 6: Proper and Efficient Use of Building Stone (b)

Please explain why you came to that decision. If you disagreed, please suggest an alternative approach

The PDNPA in its emerging Core Strategy will be looking to restrict future new building and roofing stone proposals to being only small-scale and restricted to meeting the heritage and conservation needs only of buildings within the National Park. The National Park Authority intends to secure this through suitable Planning Obligations as well as securing control of the use of the stone for building purposes and not aggregates. This will raise issues for neighbouring areas which may have secured their supply of building and roofing stone from the National Park in the past needing to secure supply from elsewhere instead. Consequently a policy that looks to protect building stone as a principal product from new workings in Derbyshire would help to meet future market need, taking account of cross-boundary issues with the National Park policy approach.

Issue 7: Strategy for Building Stone (a)

What approach do you think we should take for meeting the need for building stone?

  • Option 1: Identify specific quarries or extensions to existing quarries to provide sources of building and roofing stone for certain buildings or settlements.
  • Option 2: Devise a general policy, which allows for the extraction of building stone at sites where particular criteria are met.
  • A different option (please specify below)

Issue 7: Strategy for Building Stone (b)

Please explain why you came to that decision. If you chose 'a different option', please explain what that would be.

«No response»

Issue 8: Managing How We Make Provision for Clay (a)

Do you agree that we should include a policy for the development of clay working which sets out criteria similar to those in the existing Minerals Local Plan policy?

  • Yes
  • No

Issue 8: Managing How We Make Provision for Clay (b)

Please explain why you came to that decision, and if you chose 'no' please suggest an alternative approach that we could take

«No response»

Issue 9: Managing How We Make Provision for Vein Minerals (a)

Do you agree that we should include a policy for the development of vein working which sets out criteria similar to those in the existing Minerals Local Plan policy (MP33)?

  • Yes
  • No

Issue 9: Managing How We Make Provision for Vein Minerals (b)

Please explain why you came to that decision, and if you chose 'no' please suggest an alternative approach that we could take

The PDNPA agrees that the Core Strategy should set out a positive framework for the development of vein working because of the relative scarcity of some of these vein minerals such as fluorspar in the UK, and the economic importance of such minerals to the UK chemical industry. A positive framework in Derbyshire could also help to relieve the pressure within the National Park for such working, particularly given the view of the emerging PDNPA Core Strategy which identifies that the locations in the National Park where surface vein mineral working is likely to be environmentally acceptable are now largely exhausted and that future working will need to move to being from underground sources.

The PDNPA does not however accept the contention set out in paragraph 7.49 that a 'national need' for fluorspar exists, as no such intimation is set out in national minerals planning policy in MPS1 or any other document. Inclusion of such wording is unhelpful and illustrates the wrong perception in our view to the public.

Issue 10: Managing How We Make Provision for Conventional Oil & Gas (a)

Do you agree that we should include a policy for conventional oil and gas development which sets out criteria similar to those in the existing Minerals Local Plan (Policies MP13 & MP35)

  • Yes
  • No

Issue 10: Managing How We Make Provision for Conventional Oil & Gas (b)

Please explain why you came to that decision, and if you chose 'no' please suggest an alternative approach that we could take

«No response»

Issue 11: Managing How We Make Provision for New Coal Technologies (a)

Do you agree that we should include a policy for new coal exploitation technologies which sets out criteria similar to those for conventional oil and gas developments; as in the existing Minerals Local Plan policy MP35?

  • Yes
  • No

Issue 11: Managing How We Make Provision for New Coal Technologies (b)

Please explain why you came to that decision, and if you chose 'no' please suggest an alternative approach that we could take

«No response»

Issue 12: Consequences of Reducing Aggregate Extraction in Peak Park (a)

Do you agree that Derbyshire should continue to contribute to the aim of reducing aggregates from the National Park through agreed increases in our apportionment, based on the markets that Derbyshire is best placed to supply sustainably?

  • Yes
  • No

Issue 12: Consequences of Reducing Aggregate Extraction in Peak Park (b)

Please explain why you came to that decision, and if you chose 'no' please suggest an alternative approach that we could take

The PDNPA obviously supports the principle that the amount and proportion of aggregates supplied from the National Park should reduce as this is in accord with the requirements of Policy 37 of the East Midlands Regional Plan. The East Midlands Regional Aggregates Working Party has taken on board the thrust of the principle in its revised apportionment for 2005 to 2020, however the methodology utilised continues to penalise the National Park for historically over-providing against its apportionment figure and reward other MPAs including Derbyshire for historically under-providing against their apportionment figures. Therefore the 'readjustment' from the Peak District into Derbyshire for the 2005 to 2020 period is largely an academic exercise, and as highlighted earlier whilst the overall total for the Peak District has reduced from 66.9 million tonnes in the last apportionment period down to 65.0 million tonnes now, because the regional total has also reduced the percentage of regional proportion has actually increased from 12.8% in the last apportionment period to 13.0% now for the Peak District.

As highlighted earlier this increase in proportion is considered to be contrary to regional policy and as such the PDNPA considers that a further reduction in the Peak District apportionment is actually required with a further consequential adjustment to other MPAs in the region including Derbyshire.

Derbyshire as a neighbouring MPA has had its figure theoretically increased to compensate for the reduction in the Peak District figure. However when the figures are examined, in fact the latest 2005 to 2020 apportionment figures has actually seen the Derbyshire amount reduced from 153.8 million tonnes to 139.9 million tonnes and the proportion of the regional total reduced from 29.4% to 28% for Derbyshire. Therefore whilst an adjustment has been made from the baseline figures for the 2005 to 2020 apportionment, because Derbyshire had only met some 77% of its previous apportionment figure from 2001 to 2007 it has still effectively been rewarded for this under-provision in the revised apportionment figures.

Consequently whilst the PDNPA welcomes the adjustment made to increase the Derbyshire figure and reduction in the Peak District figure, we do not consider that the adjustment is sufficient, nor has it really achieved the policy objective of Policy 37 of the East Midlands Regional Plan either in spirit or in real terms. Therefore the PDNPA had intended to challenge the revised apportionment figure in the Partial Review of the Regional Strategy when it was published for consultation in due course. However as this is now likely to be abandoned following the change of Government, the PDNPA now intends to test the reasonableness of the apportionment figure through the forthcoming public examination for the Peak District Core Strategy in line with the questions that the Planning Inspectorate set out for assessing the soundness of minerals policies.

As indicated above under issue 1 there is at present no mechanism for inter-regional trading of aggregates apportionment, nor does the PDNPA consider that there is likely to be any realistic potential for such trading with the abolition of regional governance mechanisms. The regional aggregates apportionment exercise is currently predicated on the basis that any shortfall within any region must be made up within that same region, this is likely to continue as practice in the future as well. Despite the PDNPA raising this issue in response to consultation on the West Midlands Regional Plan and the LDFs of neighbouring MPAs, there has not yet been any success in persuading the neighbouring regions or authorities to increase their apportionment figures to take account of the policy requirement to reduce the Peak District apportionment figure. The premise on which Derbyshire has only agreed to take some 77% of the amount ceasing from the five quarries in the National Park over the next few years, i.e. for market and sustainability reasons remains untested and is considered by the PDNPA to potentially be at odds with current national planning policy set out in MPS1 as it is reliant upon a foundation of inter-regional trading.

Issue 13: Safeguarding Sites for Recycled Aggregates (a)

Do you agree that the most appropriate place to consider the safeguarding of individual sites suitable for the recycling, reprocessing and transfer of materials including construction and demolition wastes is the Waste Core Strategy?

  • Yes
  • No

Issue 13: Safeguarding Sites for Recycled Aggregates (b)

Please explain why you came to that decision, and if you chose 'no' please suggest an alternative approach that we could take

«No response»

Issue 14: Reworking Spoil Tips for Secondary Aggregates (a)

Should we have a criteria-based policy relating to reworking of spoil tips for secondary aggregates or seek to identify specific sites where these products can be worked?

  • Criteria based policy
  • Specific sites

Issue 14: Reworking Spoil Tips for Secondary Aggregates (b)

Please explain why you came to that decision

«No response»

Issue 15: Defining Mineral Safeguarding Areas (a)

What will be the most appropriate way of defining MSAs?

The PDNPA supports in principle the safeguarding of economically proven minerals resources through the LDF process by the use of Mineral Safeguarding Areas (MSA) and Mineral Consultation Areas (MCA) in the two-tier part of the Derby and Derbyshire plan area.

It is for the local circumstances present within Derbyshire to determine what mineral resources should be safeguarded, the PDNPA has no particular view to express on which minerals should be safeguarded, however the definition of any MSAs should be undertaken in accordance with the advice set out in the BGS Guide to Mineral Safeguarding in England to ensure consistency in the methodology and approach between all MPAs.

In relation to cross-boundary issues the emerging Peak District Core Strategy is looking to only safeguard certain defined mineral resources, namely: limestone (of 98% calcium carbonate); fluorspar (two proven deposits in Milldam and Watersaw Mines); and sites/areas of local building and roofing stone for heritage/conservation purposes (once we have the necessary evidence base produced). Whilst the PDNPA recognise that there are other mineral resources on our shared boundary with Derbyshire (coal, limestone and building stone) which the Derbyshire Minerals Core Strategy is likely to look to safeguard, the PDNPA has previously considered whether to safeguard these mineral resources, but has concluded not to do so. This is for reasoning explained in the Peak District emerging Core Strategy and follows the lead set in the other National Park Core Strategies that have been adopted, where in general no minerals have been safeguarded at all but have still been deemed sound at public examination.

The PDNPA acknowledges that Derbyshire intend to safeguard Carboniferous Limestone; Permian Limestone; alluvial sand and gravel; Sherwood Sandstone and surface coal. Of these minerals there are cross boundary commonalities between Derbyshire and the National Park in relation to surface coal and Carboniferous Limestone. The PDNPA will not be safeguarding all of the Carboniferous Limestone as Derbyshire proposes but only the extensive part of it which is of 98% calcium carbonate in purity. On the western Park boundary around Buxton, the majority (about 90%) of the cross-boundary limestone resource is the very high purity limestone (98% calcium carbonate), so there is likely to be a strong degree of co-ordination here between our two MSAs. On the eastern Park boundary around half of the cross-boundary limestone is the very high purity resource, so again there will be some degree of co-ordination between our MSAs. The PDNPA does not propose to safeguard surface coal, so there will be no cross-boundary co-ordination with regard to this resource; however the coal resource in the Peak District only represents the very periphery of this resource that is not considered viable for surface extraction in the future, consequently no practical issues are likely to arise from a difference in approach.

Issue 15: Defining Mineral Safeguarding Areas (b)

It is likely to be inappropriate and unworkable to define all resources, so what criteria do you think we should use to ensure that sufficient minerals are safeguarded for the future? 

Those mineral resources which the PDNPA is proposing to safeguard will be defined by MSAs which for the limestone (98% calcium carbonate) will cover the entire resource, not excluding any urban areas or any environmental constraints. The PDNPA believes that MSAs should be defined on the basis of the geological resource without excluding areas for other planning reasoning. The practical implementation of the MSA should then occur through a relevant criteria based policy which makes the principle of safeguarding workable. The fluorspar MSA will be based upon two defined mines as these are considered to be the only areas where a proven as opposed to an inferred resource exists. The MSA covering sites/area of local building and roofing stone will be based upon the results of the evidence base currently being undertaken by the National Stone Centre, these will actually then be incorporated into the later Peak District Development Management Policies DPD and not the emerging Core Strategy.

The PDNPA welcomes the recognition that a further evidence base is required within Derbyshire (section 13 of the evidence base paper) on sources of local building and roofing stone, the work being undertaken by the National Stone Centre and English Heritage in Derbyshire will complement and support the evidence being produced for the PDNPA by the National Stone Centre.

Issue 16: Sterilisation of Mineral Resources (a)

Existing MLP Policy MP17 states proposals for development which would sterilise the future working of economically workable mineral deposits will be resisted, except where there is an overriding need for the development and prior extraction cannot be undertaken.  Where the development is considered essential and proven mineral deposits would be sterilised, permission will be granted provided it would not lead to adverse environmental impacts.

 

Do you agree that we should continue this approach in the Minerals Core Strategy?

 

  • Yes
  • No

Issue 16: Sterilisation of Mineral Resources (b)

Please explain why you came to that decision

«No response»

Issue 17: Reducing the Landbank of Crushed Rock in Derbyshire (a)

What would be the best way of reducing the landbank for crushed rock in Derbyshire?

  • Option 1: Grant limited new permissions for aggregate crushed rock if operators agree to relinquish reserves of a greater amount in Derbyshire as a condition of the permission.
  • Option 2: Grant limited new permissions for aggregate crushed rock if operators agree to relinquish reserves of a greater amount in Derbyshire or the Peak District National Park as a condition of the permission
  • A different option (please specify below)

Issue 17: Reducing the Landbank of Crushed Rock in Derbyshire (b)

Please explain why you came to that decision. If you chose 'a different option', please explain what that would be. 

The PDNPA would support any proactive action undertaken by Derbyshire County Council that included the potential giving-up of permissions within the National Park in return for new aggregates proposals in Derbyshire. As you indicate this would help to achieve the desired reduction in the amount and proportion of aggregates production within the National Park, the objective of Policy 37 of the East Midlands Regional Plan and enshrined in the emerging PDNPA Core Strategy. As indicated under our Representation No.1 above on the vision however, any proposal to reduce the aggregates landbank within Derbyshire itself will need to be carefully considered and managed to ensure that no unintended adverse consequences arise from the displacement of market pressure then into neighbouring areas which could undermine the overall Core Strategy approach.

Issue 18: Restoration Scheme for Trent Valley (a)

What approach should we take to the restoration of mineral workings in the Trent Valley?

  • Option 1: Prepare a comprehensive long term landscape strategy for the restoration of sand and gravel workings in the Trent Valley, accepting that this may guide the allocation of new sites.
  • Option 2: Continue to apply a criterion based approach to the restoration of sand and gravel workings, based on local circumstances, devising restoration schemes for quarries as they arise, guided by local circumstances only
  • A different option (please specify below)

Issue 18: Restoration Scheme for Trent Valley (b)

Please explain why you came to that decision. If you chose 'a different option', please explain what that would be.

«No response»

Issue 19: Restoration Scheme for A515 Corridor (a)

What approach should we take to the restoration of mineral workings along the A515 Corridor, Buxton?

  • Option 1: Prepare a comprehensive long term landscape strategy for the restoration of limestone quarries along the A515 Corridor.
  • Option 2: Continue to apply a criteria based approach to the restoration of these quarries, based on local circumstances, devising restoration schemes for quarries as they arise, guided by circumstances specific to the particular quarry only.
  • A different option (please specify below)

Issue 19: Restoration Scheme for A515 Corridor (b)

Please explain why you came to that decision. If you chose 'a different option', please explain what that would be.

The PDNPA would support efforts to look at the strategic restoration of the four mineral sites to the west of Buxton along the A515 through the preparation of a long-term landscape strategy for Dowlow, Brierlow, Hillhead and Hindlow to be implemented as the current and potential future reserves become exhausted. There may also be merit in also looking at the quarries at Doveholes and Tunstead in the same strategy for greater co-ordination. The National Park boundary skirts around the network of these quarries and any proactive efforts to look at restoration comprehensively in this area will not only potentially enhance the A515 corridor in the longer-term but will also positively enhance the setting of the National Park in line with the statutory duty imposed on all public bodies. Any strategy being considered in the A515 corridor has again got to consider whether it may generate any unexpected consequences, the PDNPA would want the County Council to ensure that its actions here does not increase pressure for Tunstead/Old Moor and/or Doveholes to extend further into the National Park.

Issue 20: Site Suggestions

Would you like to propose a site for possible inclusion within the Minerals Core Strategy?

If you tick yes we will contact you to discuss the necessary next steps.

  • Yes
  • No

21

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Please could you tell us in the box below, if there is anything you think we ought to change in the way such consultation documents are designed?

For instance;

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•·         or anything else

I think the e consultation could be improved by.......

«No response»