Minerals Plan: Key Issues & Options

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Answers to Derby & Derbyshire Minerals Core Strategy: Key Issues & Options Questionnaire

COMPLETE RESPONSE

Response ID #76529. Submitted on 02 Aug 2010 13:32 by Planning - Cemex

Vision (a)

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

  • Not Selected
    Yes
  • Not Selected
    No

Vision (b)

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

«No response»

Objectives (a)

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

  • Not Selected
    Yes
  • Not Selected
    No

Objectives (b)

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

«No response»

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?

  • Selected
    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).
  • Not Selected
    Option 2: Use an average figure of recent annual production rates to calculate annual apportionment figures from 2020 - 2030.
  • Not Selected
    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?

  • Not Selected
    Yes
  • Selected
    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

It is crucial that the means of calculating aggregate provision be consistent throughout the Framework period. As the apportionment approach has been adopted for the period up to 2020 then this approach should continue to be adopted for the extended period up to 2030. There seems to be little logic behind the suggestion that Derbyshire should seek to reduce its contribution to the shortfall caused by the Peak Park running down its permitted reserves. It seems to be based on an anticipation that other MPAs will step in, but no evidence is provided to support this. Rather than unilaterally assuming that other MPAs will 'take up the baton' post 2020 this issue is one that should be resolved at a RAWP or inter RAWP level. Therefore option 1 would be more appropriate at this time. There is a general presumption to the decrease of mineral operation in the Peak District but this should not lead to the omission of mineral extraction in the Peak District.

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?

  • Not Selected
    Yes
  • Not Selected
    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

Preferred Areas are always superior from the perspective of identifying resources as they minimise the element of uncertainty that accompanies any designation. It is recognised, however, that insufficient suitable sites can be identified for the whole of the Framework period. It is suggested that the MPA identify sufficient Preferred Areas to fulfil its apportionment until 2030. If the MPA is unable to identify sufficient reserves in this way for the full Framework period then any shortfall should be made up with Areas of Search which, to the best of the MPA's knowledge, have the potential to release reserves to eliminate any identified shortfall.

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?

  • Selected
    Yes
  • Not Selected
    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.

It is agreed that a criteria based policy for industrial limestone would be appropriate. The core strategy should not aim to resolve all concerns as certain matters should be addressed in detail at the application stage

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?

  • Selected
    Yes
  • Not Selected
    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.

Again a criteria based policy would be appropriate. With regard to constraint these should be included on the proposals map so it is clearly identified what issues should be considered and then determine if they could be mitigated. Constraints should include, flooding, SSSI, SPA, SAC, Ramsar etc. It should be clarified if constraints mean presumption against development as this would not be an appropriate policy approach.

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?

With regard to constraint these should be included on the proposals map so it is clearly identified what issues should be considered and then determine if they could be mitigated. Constraints should include, flooding, SSSI, SPA, SAC, Ramsar etc. It should be clarified if constraints mean presumption against development as this would not be an appropriate policy approach.

Issue 5: Surface Mining Constraint Areas (a)

Should we designate surface mining constraint areas?

  • Not Selected
    Yes
  • Not Selected
    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?

  • Not Selected
    Yes
  • Not Selected
    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?

It is unclear the benefit of surface mining constraint areas as key environmental, social and economic issues should be considered similar to aggregate permissions.
Advice from the coal authority should be sought and protection and safeguarding of potential reserves should be undertaken with economically, environmentally and socially acceptable sites identified.

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?

 

  • Not Selected
    Yes
  • Not Selected
    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

It may be necessary to control the primary use of a building stone operation as the material may be of national importance and preserved and efficiently utilised.

Issue 7: Strategy for Building Stone (a)

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

  • Selected
    Option 1: Identify specific quarries or extensions to existing quarries to provide sources of building and roofing stone for certain buildings or settlements.
  • Not Selected
    Option 2: Devise a general policy, which allows for the extraction of building stone at sites where particular criteria are met.
  • Not Selected
    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.

Option 1, unless there is an overriding need or market demand then an application should be considered against certain criteria to assist determination.

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?

  • Not Selected
    Yes
  • Not Selected
    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

As the clay resource in Derbyshire is limited in volume it may be appropriate to continue with similar planning policies if they enable efficient and sustainable production.

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)?

  • Not Selected
    Yes
  • Not Selected
    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

Concern is raised with regard to flooding the limestone market.

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)

  • Not Selected
    Yes
  • Not Selected
    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

If oil and gas are a proven resource within the county, a policy could be devised or general development control policies could be applied to ensure appropriate development is permitted.

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?

  • Not Selected
    Yes
  • Not Selected
    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

New coal exploration technologies should not be dismissed and if necessary a policy devised giving clear guidance and direction. No policy should hinder new technologies

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?

  • Selected
    Yes
  • Not Selected
    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

Derbyshire should continue to compensate for the reduced contribution to aggregate demand from the Peak Park. How this issue is accommodated post 2020 should be a matter for resolution via the RAWP. Simply Derbyshire to determine unilaterally that it is unsustainable for it to continue in this role after 2020 cannot be acceptable as this is not the correct test - it may be that continued supply from Derbyshire is the most sustainable option when viewed in the context of all other options. The Issues & Options paper does not contain sufficient evidence to arrive at a robust view as to Derbyshire continuing role in compensating for the reduced contribution of the Park. As acknowledged by the Issues and Options paper itself a debate on this issue is largely academic given the size of the aggregate landbank and the MPA's inability to regulate where this material is sold geographically.

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?

  • Not Selected
    Yes
  • Not Selected
    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

The issues of recycling, reprocessing and transfer waste should be mentioned within the MDF and highlight that mineral operations may provide a temporary location to assist these operations and markets.

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?

  • Selected
    Criteria based policy
  • Not Selected
    Specific sites

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

Please explain why you came to that decision

Criteria based policy most appropriate as industry is best placed to identify potentially economically viable sources of spoil.

Issue 15: Defining Mineral Safeguarding Areas (a)

What will be the most appropriate way of defining MSAs?

Safeguarding zones should include mineral resource areas that could be worked (exclude existing urban areas, industrial and major road systems). Advice should be sought from BGS. The process should be kept simple with clear criteria and enable detailed assessment to be undertaken at the planning application stage. The support of District/ Borough & Unitary authorities within the county is essential.

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? 

«No response»

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?

 

  • Selected
    Yes
  • Not Selected
    No

Issue 16: Sterilisation of Mineral Resources (b)

Please explain why you came to that decision

Yes, this approach should be considered through the core strategy.

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?

  • Not Selected
    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.
  • Not Selected
    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
  • Selected
    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. 

There should be no policy to reduce the landbank. The landbank will natural decrease as reserves deplete. New permissions which provide a nationally significant resource should not be refused on a landbank policy only. If the MPA feel sufficiently strongly that certain planning permissions should be revoked to reduce an inappropriately large landbank then it should use the appropriate mechanism provided by the legislation - the Revocation Notice. Whilst the approach of relinquishing permissions is valid this isn't something that should be enshrined in policy, certainly not at a site specific level. Relinquishing permissions is an issue to be determined between applicant and MPA at the application stage. To attempt to develop a site specific policy could be interpreted as stifling competition as it would favour those operators with more extensive interests within the County.

Issue 18: Restoration Scheme for Trent Valley (a)

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

  • Not Selected
    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.
  • Selected
    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
  • Not Selected
    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.

Option 2 seems the most appropriate and sustainable approach.

Issue 19: Restoration Scheme for A515 Corridor (a)

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

  • Selected
    Option 1: Prepare a comprehensive long term landscape strategy for the restoration of limestone quarries along the A515 Corridor.
  • Not Selected
    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.
  • Not Selected
    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.

Option 1 would make a comprehensive restoration to the corridor more likely to take place, but this would require MPA intervention along the lines of an old style Subject Plan, in today's parlance it would probably be an SPD. In principle we would wish to contribute to such a document, but it would have to rest with the MPA to produce it and all operators subject to its content would have to sign up to it.

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.

  • Not Selected
    Yes
  • Not Selected
    No

21

This is the first time we have used a totally electronic consultation document and questionnaire. Your ideas will help us, improve the way we seek people's views in this way, in the future.

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;

  • how we have asked you to register;
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•·         or anything else

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

«No response»