Planning, Environment & Design

South Downs National Park - Soft Sand Study August 2012

Contents

1. Introduction & Terms of Reference ...... 1 Background ...... 1 Study Aim & Objectives ...... 1 The Scope of this Report ...... 2 2. Mineral Definitions ...... 3 Introduction ...... 3 Soft Sand ...... 3 Sharp Sand ...... 3 Silica Sand ...... 3 Sand & Gravel ...... 3 3. Distribution & Availability of Soft Sand Resources ...... 4 Soft Sand Distribution ...... 4 Availability of Soft Sand ...... 6 4. Minerals Planning Context ...... 7 Introduction ...... 7 The Managed Aggregates Supply System ...... 7 Minerals Planning for the South East Region ...... 7 Minerals Planning in the South Downs National Park ...... 8 Minerals Planning Policies of Surrounding MPAs ...... 9 Summary ...... 16 5. Trends in Demand & Permitted Reserves ...... 17 Regional Trends in Demand ...... 17 Local Trends in Demand ...... 17 Regional Permitted Reserve Trends ...... 18 Local Permitted Reserve Trends ...... 19 6. Permitted Soft Sand Sites, Markets & End Uses ...... 20 Permitted Soft Sand Sites ...... 20 Current Markets and End Uses for Soft Sand ...... 21 Discussion ...... 22 7. Provision of Soft Sand in the Current Plan Period ...... 23 Hampshire Allocations ...... 23 West Sussex „Long List‟ Sites ...... 25 East Sussex Site Allocations ...... 27 Summary ...... 27 8. Analysis of Reserves Information ...... 28 Reserve Calculation Tables ...... 28 Sand & Gravel Reserves ...... 30 Soft Sand Reserves ...... 30 Potential Influence of National Park Status on Soft Sand Provision ...... 31 Discussion ...... 31 9. Planning & Sustainability Implications of Altering the Traditional Supply Pattern ...... 33 Introduction ...... 33 Sustainability Issues ...... 33 Potential Alternatives ...... 34 Summary ...... 37 10. Conclusions ...... 38 Introduction ...... 38 Soft Sand End Uses & Markets ...... 38 Provision of Soft Sand in the Study Area...... 39 Alternatives to Future Extraction within the SDNP ...... 39 Apportionment in the SDNP ...... 40 Appendix A: Figures A.1 to A.3 (Resources and Constraints) ...... 44 Appendix B: Figures B.1 to B.3 (Permitted and Potential Sites) ...... 45 Appendix C: Figures C.1 to C.4 (Soft Sand Resources) ...... 46

South Downs National Park - Soft Sand Study March 2013 i 1. Introduction & Terms of Reference

1. Introduction & Terms of Reference Background

1.1 This report relates to the consultancy contract „Soft Sand Study‟ between the South Downs National Park Authority and Capita Symonds Limited. 1.2 Mineral Planning Authorities (MPAs) are required to plan for provision of aggregate minerals within their areas, including types of sand & gravel. Soft sand is a valuable mineral resource that, for certain end uses, cannot be substituted by other materials and a significant proportion of the resource in the South East is located within the National Park boundary and distributed across the National Park, and adjoining parts of Hampshire, West Sussex, East Sussex, Surrey and Kent. 1.3 The National Planning Policy Framework (NPPF) requires (paragraph 116) that applications for major development within National Parks should be refused planning permission except in exceptional circumstances, and where it can be demonstrated that they are in the public interest. This broadly echoes the stance taken, specifically in relation to mineral development, within the former Minerals Policy Statement 1 (MPS1: Planning and Minerals), Consideration of such applications is required to include an assessment of the need for the development; the cost of and scope for developing elsewhere, outside the designated area; and any detrimental effects on the environment, the landscape and recreational opportunities. 1.4 The South Downs National Park Authority (SDNPA) assumed its full powers in April 2011, including responsibilities as the Mineral Planning Authority (MPA) for the Park area. SDNPA has commissioned this work in partnership the adjoining MPAs represented by Hampshire County Council, West Sussex County Council and East Sussex County Council, in response to the cross-boundary nature of this planning issue. Study Aim & Objectives

1.5 The purpose of this study is to provide a better understanding of current soft sand reserves, uses and demands within the SDNP boundary and in the context of the wider South-East region. 1.6 Specifically, the study was required to provide information on:

 unconstrained, workable and viable soft sand resources and reserves within the study area that fall within the boundary of the SDNP (using GIS and building on existing evidence gathered by the MPAs)  how much soft sand is/has historically been extracted within the study area  the extent and nature of the market for soft sand arising from the study area  current and likely future uses and demand within the SDNP, including any emerging markets  assess the potential for alternative supplies of soft sand outside the SDNP and outside the study area, and whether they could fulfil current and future demand.  The availability, feasibility and sustainability of sourcing soft sand from alternative supplies outside the study area should also be assessed, including the social, economic and environmental impacts which would arise. 1.7 The study should “assist the South Downs National Park Authority and partner MPAs by providing a robust and sound evidence document which can be used by the Authority and partner MPAs in formulating a policy approach to soft sand in the future” (ITT for Soft Sand Study, SDNPA, December 2011).

South Downs National Park - Soft Sand Study August 2012 1 1. Introduction & Terms of Reference

The Scope of this Report

1.8 As required, the study primarily looks at land-won soft sand in the MPAs of the SDNP, Hampshire, West Sussex and East Sussex („the study area‟), however, Surrey and Kent are also included as the main source of soft sand in this area (the Folkestone Formation) is also found within their boundaries. 1.9 This report contains information on:

 the preparation of Minerals and Waste Plans within the SDNP, Hampshire, West Sussex and East Sussex (including Brighton and Hove) MPAs  key planning points in relation to the provision of soft sand for each MPA and the extent to which soft sand resources are safeguarded in those areas.  the distribution of soft sand resources in the SDNPA and neighbouring South East MPAs;  an overview of the availability of the soft sand given major environmental constraints;  regional and local (MPA-level) trends in permitted reserves of sand & gravel and soft sand.  current permitted reserves in terms of active sites and the potential future reserves represented by allocated or short listed soft sand extraction sites;  regional and local (MPA-level) trends in demand for soft sand, in terms of sales/production;  the general markets that the active soft sand sites serve and the end use of their products;  analysis of the potential shortfalls or surpluses over the current Plan period the study area; and  the broad (rather than site-specific) options available for the release of further reserves, where this may be needed to meet identified shortfalls  the location of potential alternative supply sources and provides a very broad analysis of the sustainability issues that will need to be addressed. 1.10 Plan production, including collection of aggregates data, is ongoing across the four study area MPAs. In order to assess the provision of soft sand, information (particularly the apportionment and reserve figures) has been used which relates to the former three MPA areas. 1.11 This report presents the results of research carried out at a particular point in time, prior to the publication of „Guidance on the Managed Aggregate Supply System‟ on 18 October 2012 (which supports the approach to planning for aggregate mineral extraction under the National Planning Policy Framework) and the proposed changes to the Hampshire Minerals and Waste Plan (October 2012) following the examination of the Submission Plan in June 2012. 1.12 For updates to the current planning situation for any of the MPAs in this report, please contact the relevant Local Authority or see their individual websites.

South Downs National Park - Soft Sand Study August 2012 2 2. Mineral Definitions

2. Mineral Definitions Introduction

2.1 This study is specifically concerned with soft sand and the text below describes the difference between this and other types of sand. While typical end uses have been identified below, those sands used for high-end products may be used in lower-end applications. Soft Sand

2.2 Soft sand is generally fine-grained sand in which the individual grains are well-rounded, imparting a relatively soft texture and free-flowing nature to the sand. Such sands are commonly deposited in marine environments, where constant movement by the sea results in the rounding, polishing and sorting of the grains. They therefore occur within strata, such as the Cretaceous Greensands, which originated in such environments. The characteristics of such sands lend themselves especially to products which are required to „flow‟ or be easily „workable‟ by hand when they are being used - particularly mortars, but also plaster, in the case of very fine grained sand. These are collectively known as „building sand‟. Soft sand may also be used in asphalt products where it is used to stiffen the bitumen binder, and in concrete products - although sharp sand (see below) is more commonly used for that purpose. Soft sands usually comprise a high proportion of silica (quartz), but also impurities such as iron oxide, which impart colour to the sand (mostly in shades of orange, brown and red). Similar sands but with fewer impurities are classed as „silica sands‟. These are generally lighter in colour and are used for a more specialist range of products (see below). Sharp Sand

2.3 In contrast to soft sand, sharp sand tends to be relatively coarse and the component grains are more angular. Such sands are typically deposited within river channels, rather than in oceans, and are generally found, as part of a sequence of mixed sand & gravel, within river floodplains, river terraces, and (in areas which have been glaciated) within other types of deposit. As the name implies they have a sharper texture than soft sands and, although they can be used as building sand, they are generally not preferred for that purpose because they produce less „workable‟ mortars, unless special additives are included in the mix, adding to the cost. They are better suited to use within concrete products, not least because they usually occur in conjunction with gravels which provide the coarse aggregate component of the concrete mix. Silica Sand

2.4 „Silica sand‟ is sand made up predominantly of silica grains and the content of other mineral impurities and silt is very small. Silica sand is used for non-aggregate purposes in a range of high value industrial applications such as glass manufacture, foundry sand, sands for brick facings, water filtration and, for very fine-grained sands, in resins, tile and brick facings and industrial filler applications. They are also used for specialist non-staining and neutral sports sand (including golf courses), play sand and for horticultural and rootzone products. Sand & Gravel

2.5 Where the term „sand & gravel‟ is used in this report it refers to aggregate that is not „crushed rock‟, i.e. it includes: soft sand, sharp sand and sand and gravel aggregate. Figures quoted for „sand & gravel‟ in this report may also include silica sand, although this is not normally classed as aggregate. In some cases, soft sand figures cannot be separately identified, and more generally the reporting herein of sand & gravel gives context to the situation as regards provision of soft sand.

South Downs National Park - Soft Sand Study August 2012 3 3. Distribution & Availability of Soft Sand Resources

3. Distribution & Availability of Soft Sand Resources 3.1 This section describes the distribution of soft sand in the SDNP MPA and the five nearby MPA areas of Hampshire, West Sussex, East Sussex, Surrey and Kent. Some measure of the practical „availability‟ of these resources is provided by way of constraints mapping that includes urban/infrastructure features and major environmental designations are provided to demonstrate the potential conflicts planning for extraction of these minerals may encounter. The way that provision of these reserves is managed is provided in the following Section 4 „Minerals Planning Context‟. Soft Sand Distribution

3.2 The extent of the bedrock sand resources in the South East can be seen in Figure 3.1 below. This image contains broad areas defined by the British Geological Survey (BGS) which “may be of current or potential economic interest”. 3.3 In the South East of England the primary source of soft sand is the Folkestone Formation of the Lower Greensand Group. The Folkestone Formation extends from north west of Lewes in East Sussex, across West Sussex and into Hampshire to Petersfield, where it swings around to the north east and then continues east across Surrey and Kent, meeting the coast at Folkestone. 3.4 Not all of the Folkestone Formation sands are suitable for use as building sand, as the Formation varies in both colour and grain size across the South East. Some parts of the resource are also sources of silica sand and/or sharp sand. Often, more than one type of sand is sourced from a single quarry site. 3.5 The BGS have defined the whole of the Folkestone Formation (in brown on the figure) as an area of potential bedrock sand and gravel mineral resource and have also identified specific areas of silica sand resources (identified in yellow). In total, the mapped Folkestone Formation resource covers an area of approximately 310 km2. 3.6 In the west of Hampshire, parts of the Bracklesham Group (including the Poole Formation, Branksome Sand Formation and Selsey Sand Formation) are defined by the BGS as an area of construction sand resource (these are shown in purple on Figure 3.1). These geological units contain sand & gravel. To the west of this mapped area, but still within Hampshire, are areas of Quaternary sands and gravels. In some locations, building sand is sourced from this material (e.g. Bleak Hill Quarry). 3.7 To the west of the SDNP is an area of identified resource associated with the Whitecliff Sand Member of the London Clay Formation. This is a „clean‟ fine to medium grained sand, worked for example in the former Fair Oak Quarry in Hampshire. 3.8 Over to the east of Kent, parts of the Thanet Sand Formation are sources of building sand and are identified as an area of mineral resource. There are also sand resources identified in the Sand Rock Formation on the Isle of Wight.

South Downs National Park - Soft Sand Study August 2012 4 3. Distribution & Availability of Soft Sand Resources

Figure 3.1 The Folkestone Formation and other soft sand resources in South East England.

South Downs National Park - Soft Sand Study August 2012 5 3. Distribution & Availability of Soft Sand Resources

Availability of Soft Sand

3.9 Potential constraints to the extraction of soft sand resource naturally include the South Downs National Park and Areas of Outstanding Natural Beauty (AONBs). They also include European designations such as Special Protection Areas (SPAs), Special Areas of Conservation (SACs), and nationally designated Sites of Special Scientific Interest (SSSIs) and Ancient Woodland. Urban areas and major infrastructure may also be a constraint (although prior extraction during redevelopment is a possibility). 3.10 The following sections describe the distribution of these particular constraints on the soft sand resource within the SDNP and the MPAs that adjoin the SDNP boundary, and also in the nearby MPA areas of Surrey and Kent. Figures A.1 to A.3 in Appendix A show the major environmental constraints in relation to soft sand resources. Not mapped, but also present, are areas of Green Belt, cultural constraints such as Scheduled Monuments; and locally designated sites such as Sites of Importance for Nature Conservation (SINCs) and Local Nature Reserves. Likewise, extraction may be precluded by hydrogeological, landscape character, highways, cumulative impacts and other unmapped constraints. 3.11 The following descriptive text is not an appraisal of local constraints (as would occur during the determination of applications for mineral extraction) but provides, at a high level appropriate for the purposes of this study, an idea of the extent of national and international designations with respect to the resource. Thus, where the terms „constrained‟ and „unconstrained‟ are used in the text below, this is only in the context of those that are mapped. The scale of these maps is small and so even small areas of unconstrained resource may still be economically viable. 3.12 Parts of the Folkestone Formation in Hampshire County are within the SDNP MPA, with the exception of an area to the north west of Haslemere. To the south of the SDNP, the Whitecliff Sand Member is somewhat covered by constraints, particularly built development. However, in the area west of Romsey there is an area of resource apparently free of mapped constraints1. Much of the mapped resource in the area that relates to the Branksome and Selsey Sand Formations falls within the New Forest National Park but in the area to the west of that, where sand is currently extracted at Blashford Quarry there are fewer mapped constraints. 3.13 In East Sussex County, there is very little of the Folkestone Formation and all of the soft sand resource is within the boundary of the SDNP MPA. The Formation continues as a low ridge in West Sussex and the majority of it is with the boundary of the Park. Notably, there is an area free of mapped constraints to the north of Upper Beeding and smaller areas around Storrington / Henfield, although local constraints may apply. 3.14 In the Surrey MPA, the Folkestone Formation also contains silica sands, and this is notable in the unconstrained areas mapped either side of Reigate (although silica sand is found elsewhere in the Formation). Areas without mapped constraints include those to east of Farnham, at Runfold. 3.15 In the Kent MPA there are some areas to the east of Sevenoaks that are not constrained by the AONB and resources areas picked out for silica sand are also largely unconstrained between Sevenoaks and Maidstone. The Folkestone Formation resource is shown to extend from Maidstone to Folkestone, running virtually parallel with the Kent Downs AONB. Within this section of the Formation, the mapped international and national designations are relatively few.

1 Hampshire County Council has identified that other issues affect this area, including highway safety constraints (comments on the draft version of this report, April 2012). Indeed these and other considerations (such as the cumulative impact on local communities) may apply to all areas where there are no mapped constraints. South Downs National Park - Soft Sand Study August 2012 6 4. Minerals Planning Context

4. Minerals Planning Context Introduction

4.1 This section outlines the national, regional and local minerals planning context for this study, including the responsibilities of the Mineral Planning Authorities (MPAs) to meet their authority‟s aggregate apportionments. It provides detail on what the situation is in each MPA in terms of planning for the supply of sand & gravel and soft sand resources (as defined in Section 2). The information given below reveals some important differences in Mineral Planning across the study area. The Managed Aggregates Supply System

4.2 The Managed Aggregate Supply System (MASS) is an informal name given to the „top-down‟ mechanism which has been used in England & Wales for many years to determine the levels of aggregate provision required in each Mineral Planning Authority (MPA), in order to contribute fairly to the overall expected level of demand. It is intended to help the planning system to address the spatial inequalities between the distribution of supply sources and the distribution of demand. 4.3 The system comprises:

 National-level econometric forecasting of overall and regional demand for construction aggregates, commissioned by the Department for Communities and Local Government (CLG) and based largely on projected investment in construction activity;  Regional-level „apportionments‟ published by CLG at periodic intervals in the form of National and Sub-National (formerly Regional) Guidelines for Aggregates Provision, each one covering a rolling sixteen-year period (e.g. 2005 - 2020);  Further (sub-regional) apportionment of each sub-national guideline figure by the (former) Regional Assemblies2 as supported by the Aggregates Working Parties, to give apportionment figures for each component MPA. These are expressed in million tonnes per year (mtpa) and in totals for the relevant 16-year period; and  Provision by each MPA for a „landbank‟ of sufficient permitted reserves to enable the indicated level of production to be sustained throughout the relevant period, and to maintain a landbank of at least seven years (for sand & gravel) throughout that period. 4.4 Under the recently published National Planning Policy Framework (NPPF, March 2012, paragraph 145), the emphasis is on the preparation of annual Local Aggregate Assessments by individual MPAs, or groups of MPAs. This theoretically allows greater scope for local minerals planning, but there is still a requirement for MPAs to participate in the operation of an Aggregate Working Party, and to take the advice of that Party into account when preparing their Local Aggregate Assessment. Moreover, there is also still a requirement for MPAs to take account of published National and Sub-National (previously regional) Guidelines as issued periodically by CLG. The Managed Aggregate Supply System therefore still has a very important role to play in determining the requirements for aggregates provision at the local scale. Minerals Planning for the South East Region

4.5 Formerly, the sub-regional apportionment of aggregates was set out in Regional Spatial Strategies (RSSs). In July 2010, a ministerial statement was published confirming the intention to revoke the RSSs. The High Court subsequently overturned the revocation of the RSS in

2 The South East England Regional Assembly‟s (SEERA) functions have now been assumed by the South East England Partnership Board (SEEPB) South Downs National Park - Soft Sand Study August 2012 7 4. Minerals Planning Context

November 2010, however a High Court judgment in February 2011 confirmed that the intended abolition of the RSS should be treated as a material consideration by decision makers. 4.6 Apportionments for the South East were issued under the regional system which prevailed at that time. The South East Plan states that for the Plan period 2010 to 2026 the Region should maintain a 7 year landbank that is sufficient to deliver 11.12 million tonnes per annum (mtpa). In the adopted South East Plan of May, 2009 (Government Office of the South East, 2009), this had been set at 13.25mtpa3. However the South East Regional Assembly challenged the regional apportionment. An Examination in Public (EiP) of the South East Plan took place in October 2009 and subsequently the Panel recommended the lower figure of 11.12mtpa. This was never formerly adopted. Despite the subsequent intended revocation of the RSS (see above), advice given to Chief Planning Officers (July 2010) was that MPAs in the South East should work from the Secretary of State's Proposed Changes to the Review of Policy M3 of the South East Plan (March 2010) unless there is local evidence which supports a different case. 4.7 Table 4.1 shows the breakdown of the required amount, per annum, by individual MPAs (or groupings of MPAs) within the SE Region. This table shows the total S&G for the SE MPAs. Where markets for sand & gravel aggregate are distinct enough, MPAs are encouraged by National Policy to provide separate apportionments for the different mineral types. For this study area, sand & gravel is variously divided for planning purposes according to the types described in Chapter 2 and some MPAs have specific policies for silica sand. Where separate silica sand apportionments exist in each MPA, they are mentioned briefly below. However the main focus of the following paragraphs is soft sand and sand & gravel.

Aggregate Apportionment in mtpa – Secretary of Mineral Planning Authority State’s ‘Proposed Changes, March 2010 (previous apportionment in brackets) Hampshire/Southampton/Portsmouth 2.05 (2.63) West Sussex 1.03 (0.91) East Sussex/Brighton& Hove 0.10 (0.01) Surrey 1.27 (2.62) Berkshire Unitaries 1.33 (1.57) Buckinghamshire 1.05 (0.99) Isle of Wight 0.10 (0.05) Kent 1.63 (2.53, joint with Medway) Medway 0.18 (see Kent) Milton Keynes 0.28 (0.12) Oxfordshire 2.10 (1.82) Table 4.1 Sub-regional apportionments for the period 2010 to 2026. 4.8 It was recognised in the regional guidance that a significant part of the soft sand resources in the region is within the South Downs National Park with a recommendation for Hampshire, West Sussex and East Sussex MPAs to first consider the potential for meeting requirements from outside the National Park and then from within. Minerals Planning in the South Downs National Park

4.9 The South Downs National Park Authority Local Development Scheme (September 2011) observes that until such time as Regional Spatial Strategies are finally revoked, and the SDNPA adopts its own or further joint LDF documents, the „Development Plan‟ for the SDNPA includes:

 The South East Plan (Proposed Changes)

3 On the basis of “the Government‟s National and Regional Guidelines for Aggregates Provision in England” (as reported in Government Office of the South East, May 2009) South Downs National Park - Soft Sand Study August 2012 8 4. Minerals Planning Context

 Hampshire Minerals and Waste Core Strategy (2007) – for Hampshire part of the National Park  East Sussex Minerals Local Plan (1999), East Sussex Waste Local Plan (2006) – for East Sussex, and Brighton and Hove part of the National Park,  West Sussex Minerals Local Plan (2003) – for West Sussex part of the National Park. 4.10 Other plans which are noted to be material considerations are:

 The emerging Joint Core Strategies for Waste and Minerals (with East Sussex and Brighton and Hove), Waste (with West Sussex) and Minerals and Waste (with Hampshire, New Forest NP, Southampton and Portsmouth), and  any emerging Development Plan Documents being prepared by the SDNPA 4.11 The SDNPA is working in partnership with Hampshire County Council (and Portsmouth City Council, Southampton City Council, and New Forest National Park Authority), West Sussex County Council and East Sussex County Council (and Brighton and Hove City Council) in the production of minerals and waste local plans. Minerals Planning Policies of Surrounding MPAs

Hampshire Plan Development 4.12 The Hampshire Minerals and Waste Core Strategy was adopted in 2007 by the partnering plan making authorities (Hampshire County Council, Portsmouth City Council, Southampton City Council and the New Forest National Park). Some policies of the previous Hampshire Minerals and Waste Local Plan (1998) were saved alongside the adoption of the Core Strategy. In line with the new Development Scheme, the Draft Hampshire Minerals and Waste Plan was submitted by the partners (now including the South Downs National Park Authority) for consideration by the Planning Inspectorate in February 2012. The plan will replace the adopted Core Strategy and the saved Local Plan policies. The Submission Plan was the relevant document at the time research was carried out for this report and was based on a number of evidence and assessment documents. Those reviewed for this study included:

 Minerals in Hampshire: Background Study (Version 5) (the Hampshire Authorities, 2012);  Minerals Proposal Study (Version 5) (the Hampshire Authorities, 2012);  Safeguarding Study (Version 4) (the Hampshire Authorities, 2012);  Soft Sand Topic Paper (Version 4) (the Hampshire Authorities, 2012); Provision of Soft Sand 4.13 The „proposed changes‟ apportionment for sand and gravel in Hampshire is 2.05 million tonnes per year. However, the Hampshire Authorities consider that this apportionment figure does not take into account local circumstances and supply. As such, in their Submission Plan (2012), a figure of 1.56 mtpa of land-won sand and gravel is put forward for the period 2011 to 2030. This is equivalent to 30mt over that period. Of this, 5.33 mt will be soft sand, equivalent to 0.28 mtpa4 (average sales of soft sand over the period 2001 to 2010). The authorities intend to meet this soft sand requirement through:

 existing reserves – 2.22 mt;  identified sites within the plan, including extensions and new sites – 4.03 mt.

4 Rounded figure South Downs National Park - Soft Sand Study August 2012 9 4. Minerals Planning Context

4.14 Policy 20 of the Submission Plan (2012) identifies that the supply of soft sand will be provided by maintaining a landbank of at least seven years from: “a) the extraction of remaining reserves [at existing sites]5; b) or extensions to [existing sites]6; c) or new sand and gravel sites at ...:  Forest Lodge Farm, Hythe (soft sand / sharp sand and gravel) (Inset Map 10) – 0.57 million tonnes  Purple Haze, Ringwood Forest (soft sand / sharp sand and gravel) (Inset Map 12) – 4.0 million tonnes”7 4.15 Extensions and new sites must also “address the development considerations outlined in Appendix A [of the Submission Plan]”. 4.16 Policy 208 also states that: “Proposals outside the areas identified in the Plan could be supported where: i. it can be demonstrated that the sites identified in the Plan are not deliverable; ii. there is a demonstrated need for the development; iii. the prior extraction of aggregate facilitates other development 4.17 Hampshire has identified a contingency sand and gravel reserve amount of 2.91mt in their plan to come from un-allocated sites. This has been guided by evidence that 4.76mt of sand and gravel has come from un-planned opportunities over the last 15 years. While Policy 20 applies to all types of sand and gravel, no contingency figure is provided in respect of soft sand. 4.18 Hampshire does not currently propose a silica sand apportionment. In the recent Examination in Public (EiP), discussion9 was had on whether the Tarmac site at Kingsley and the proposed extension to the site (which is within the SDNP), should be considered as a silica sand site and not as general construction sand. Hampshire produced a Silica Sand Topic Paper in May 2012. This paper identified that, although the sands from Kingsley had specialist end uses as a “high value non aggregate use namely for sports pitches”, they were not used for “„traditional‟ silica sand uses in the glass, ceramics and foundry industries” and that other aggregates including recycled aggregates could be used for the same end use as the Kingsley product. The Hampshire Authorities concluded that they did not consider that the specialist end uses constituted classification of the product as silica sand. 4.19 However, the Inspector agreed(8) that the site should be considered as silica sand and has asked for consideration of a modification to the Plan to this effect. The NPPF requires a silica sand landbank of at least 10 years for individual silica sand sites. This has implications for this study and these are discussed, where appropriate, in the remainder of this report. Minerals Safeguarding 4.20 Mineral Safeguarding Areas (MSAs) are defined within the 2012 Submitted Plan on a Proposals Map. The MSAs are based on the BGS resource mapping data and information “obtained from „local knowledge‟ of mineral reserves” (Safeguarding Study, 2012) and therefore they include

5 for soft sand these are listed as: Blashford Quarry (soft and sharp sand), Frith End Sand Quarry and Kingsley Quarry. 6 none are proposed that produce soft sand 7 Other sites are listed within this Policy 20 for sharp sand and gravel. 8 Since subject to modifications following the EiP. 9 Email from Peter Wilsdon, SDNPA, dated 13th June 2012. South Downs National Park - Soft Sand Study August 2012 10 4. Minerals Planning Context

most (but potentially not all) of the Folkestone Formation, Whitecliff Sand Member and the mineral resources identified within the Bracklesham Group. 4.21 The Folkestone Formation soft sand resources near Whitehill and Bordon are specifically identified for safeguarding as a prior extraction opportunity. Two potential sites identified at this location were ruled out as potential allocations following earlier stages of site appraisal as the deliverability of the sites is considered to be uncertain due to the development of the Whitehill- Bordon Eco-town. This is in turn dependant on the vacation of the site by the Ministry of Defence. This is documented in the Minerals Proposal Study. The Hampshire Minerals and Waste Plan Soft Sand Topic Paper notes that, at February 2012, the MoD are likely to have vacated the site by 2015 and that it is important that the soft sand reserves at Whitehill-Bordon are safeguarded with a view to ensuring that the reserves are not unnecessarily lost through the development of the proposed Eco-town. As such, these resources are afforded safeguarded status under Policy 15 of the Submission Plan. West Sussex Plan Development 4.22 The Minerals Local Plan (MLP), adopted in May 2003 (and covering the period between 1999 to 2006) is being replaced by the West Sussex Minerals Local Plan (to cover the period to 2031). 4.23 The new Plan is being prepared jointly with the South Downs National Park Authority. It will allocate „strategic sites‟ to meet the need for sand and gravel in West Sussex. The saved policies of the earlier Plan will continue to form part of the statutory 'development plan' and provide the local policy framework for development control decisions until they are replaced. 4.24 Preparation of the West Sussex Minerals and Waste Core Strategy was suspended October 2010. In May 2011, the Council decided to build on the work previously carried out (during the preparation of the Core Strategy) by commencing work on separate minerals and waste plans, with the waste plan to be begun first. Work that was completed for the Core Strategy for minerals is provided in a series of „living draft‟ background papers and these are to be used to inform the separate Waste and Minerals Plans. Provision of Soft Sand 4.25 The saved policies of the Minerals Local Plan, 2003 that pertain to the provision of sand include: “Policy 29: The Mineral Planning Authority will aim to grant planning permission for the supply of sand and gravel so that when added to permitted reserves, a total of 1.4 million tonnes per annum (812,000 tonnes of sand and 588,000 tonnes of gravel) can be provided in the period from 1.1.1997 to 31.12.2006. Thereafter the Mineral Planning Authority will aim to grant further permissions which when combined with reserves, will provide a landbank for the period 2006 to 2013 at a rate of 880,000 tonnes per annum (510,400 tonnes of sand and 369,600 tonnes of gravel).”

4.26 Separate amounts of sharp sand and soft sand were not identified in the 2003 plan as their occurrence within the same pits was identified to be irregular and unpredictable. However, the later „living draft‟ Background Paper10 3: Minerals (version 2, 2009, referred to here as BP3) provides options for a split in the apportionment of soft sand and sharp sand and gravel to guide the allocation of sites. The options given in BP3 are: no split in the apportionment; a split of 70:30, or; a split of 80:20 (both sets of split figures are rounded). These splits were put forward as options on the basis of comments raised by the minerals industry and the average split in production over the previous 8 years.

10 Note that all background papers were produced by WSCC prior to SDNPA assuming full powers, thus they are subject to review by SDNPA prior to their information acting being relied for future Minerals Planning. South Downs National Park - Soft Sand Study August 2012 11 4. Minerals Planning Context

4.27 The paper identifies how much soft sand and sharp sand and gravel would be required to meet apportionment until the end of the plan period for these different splits. Based on this, the MPA has identified that there will be a total requirement for sand and gravel of between 9.35mt and 13.09mt, which equates to between 5.93mt and 10.47mt for soft sand. However, the total requirement referred to in BP3 was for the period 2009-2026 whereas the new Minerals Local Plan will cover the period to 2031. Therefore the requirement over the longer period is likely to be greater. 4.28 BP3 also presents options for maintaining the seven year landbank that include identifying separate landbanks for soft and sharp sand and gravel. These would be based on ratios identified for guiding site allocations. The landbank would be used as a tool for indicating when new permissions may be required and in this way the requirements for soft sand and sharp sand and gravel will be different according to the permitted reserve of each mineral type. 4.29 Saved policies from the 2003 Plan pertaining to specific site allocations, preferred areas or areas of search are: “Policy 32: The new sites identified for sand extraction pursuant to Policy 29 are:  Dunford Rough (Site No. 20) (Inset Map G)  West Heath (Site No. 26) (Inset Map H)” “Policy 33: Planning permission will only be granted for the extraction of sand and gravel from sites other than sites provided for, or proposed, in the Plan if there is no longer a seven year landbank available, or sterilisation of mineral resources would be avoided as a result, subject to environmental and other material considerations.” “Policy 34: Planning permission may be granted for minor extensions at existing workings subject to environmental and other material considerations, where sterilisation of mineral resources would be avoided as a result or where, on balance, and environmental benefit would occur.”

4.30 The anticipated total supply of sand from the two proposal sites was 2,920,800 tonnes at Dunford Rough and 352,300 tonnes at West Heath. With existing permitted reserves at the start of 2002 estimated at 6,806,000 tonnes, an over-provision of 1,735,100 tonnes of sand was anticipated. 4.31 In terms of emerging policy, BP3 gives details on the environmental, historical and ecological constraints that effectively define a search area for suitable future sand sites. Sites were brought forward from the Minerals Development Plan Document (DPD) (2005) and a call for sites exercise was undertaken. 4.32 Background Paper 5: Strategic Mineral Sites (version 2, 2009, referred to here as BP5) provides details on the assessment and selection process for deciding which specific minerals sites should go forward for consideration. Sites not considered acceptable „in principle‟ were rejected at this stage, those that were considered acceptable „in principle‟ are contained within a „long list‟ of sites11. The potential quantity of soft sand resources in the long list sites is 12.75 million tonnes. One of the long list sites (the extension to West Heath Quarry), has now been permitted giving a potential quantity of 12.35mt. Minerals Safeguarding 4.33 In terms of Mineral Safeguarding policy in West Sussex, the entire Folkestone Formation is considered a sub-regionally important resource and is included in the MSA (BP3, 2009). In West

11 The long-list of sites is only an indication of the sites that may be acceptable (as subject to approval by SDNPA). This is not a final shortlist as any shortlist would be linked to the number of sites required to meet the apportionment. South Downs National Park - Soft Sand Study August 2012 12 4. Minerals Planning Context

Sussex the MSA is identical to the Mineral Consultation Area (MCA) as no additional sites have been identified outside of the MSA. It is the intention of WSCC that the MSA identified in a BGS Study12 will be refined and will form the basis of a policy to safeguard mineral resources. Two options are presented for safeguarding of soft sand and sharp sand and gravel: one of which excludes only previously worked sites and one which excludes both worked sites and urban areas. East Sussex Plan Development 4.34 East Sussex MPA jointly prepare minerals local policy with Brighton and Hove Council and the SDNPA. The Waste and Minerals Plan for East Sussex, South Downs and Brighton & Hove has been submitted in June 2012 and until the new plan is adopted, the policies from the East Sussex, and Brighton and Hove Minerals Local Plan (1999) are saved. A Minerals Development Plan Document which will have details of sites for minerals extraction and processing, a Proposals Map showing area- and site-specific policies will be prepared following the adoption of the submitted Plan. Provision of Soft Sand 4.35 In the 1999 Plan, the MPA adopted a notional production figure of 0.3mt per annum (for sand and gravel) for the purposes of testing future allocations for land won aggregates and the plan seeks to supplement scarce land won supplies by planning for appropriate levels of imports and by encouraging greater use of secondary aggregates and recycled material. 4.36 Under the Submission Waste and Minerals Plan, the revised annual apportionment of 0.1mt (from the Proposed Changes to the South East Plan) is to be met through existing planning permissions. The annual allocation of 0.1mt of sand and gravel is to be met by the existing 7 year landbank of 0.8mt to 2017 or 1.7mt to 2026. 4.37 A separate soft sand apportionment is not proposed for the plan area as the soft sand resource in East Sussex is particularly limited and production has been intermittent. In East Sussex, the soft sand bed covers only 67 hectares of unsterilised mineral resource (outside the village of Ditchling). 4.38 In reference to the recommendation by the Secretary of State to consider provision of resources outside of the National Park first, the submission Plan (2012) outlines the approach of the SDNPA to work with East Sussex, West Sussex and Hampshire County Councils, to find an acceptable solution across the wider area. Parts b and c of Policy WMP 1 are relevant: “Policy WMP 1. Minerals and waste development affecting the South Downs National Park... b) Major minerals and waste development in the South Downs National Park should not take place except in exceptional circumstances, where it can be demonstrated to be in the public interest. In this respect, consideration will be given to:  the need for the development, including in terms of any national considerations; and  the impact of permitting or refusing the development upon the local economy; and  the cost of and scope for developing outside the designated area or meeting the need in another way; and  any detrimental effect on the environment, landscape and/or recreational opportunities and the extent to which it could be satisfactorily mitigated.

12 British Geological Survey (2007). Mineral Safeguarding Areas and Mineral Consultation Areas for West Sussex. South Downs National Park - Soft Sand Study August 2012 13 4. Minerals Planning Context

Development will only be in the public interest if the outcomes of i-iv above gives sufficient reason/s to override the potential damage to the natural beauty, cultural heritage, wildlife or quiet enjoyment of the National Park. c) Extensions to existing soft sand quarries or new quarry proposals in the National Park need to conform with (b) and additionally demonstrate that the need could not be practically achieved by extraction in adjoining Counties...”

4.39 In the East Sussex Minerals Local Plan (1999) Policy 3 identifies only one soft sand site as a preferred site – Stanton‟s Farm. The submission Plan (2012) identifies Stanton‟s Farm as the permitted soft sand reserves that will aid maintaining the seven year landbank and contribute to the combined sand and gravel apportionment for the Authority. This site has an annual production of up to 30,000 tpa (as reported by the operator), with an approximate 120,000t of remaining reserves). However, this site‟s permission is noted to expire in 2016 and therefore soft sand is only provisioned for in the early part of the plan period (to 2017)13. For the remainder of the period the total apportionment is met by sharp sand and gravel. 4.40 Work on a site allocations document is intended to commence within 12 months of the adoption of the Plan. Minerals Safeguarding 4.41 MCAs under the 1999 plan included all existing sites and the identified areas of search and preferred sites. Minerals safeguarding under the proposed submission Plan (2012) is through the application of MCAs around specific permitted sites. Thus, the MSA/MCA for soft sand is the Stanton‟s Farm site. The Plan states that other non-strategic mineral resources that might need protection will be identified through the Plan review process and in the Minerals Sites DPD. Surrey Plan Development 4.42 The Surrey Minerals Plan (SMP) was adopted in July 2011 and it plans for the period 2009 to 2026. The Minerals Core Strategy DPD and Primary Aggregates DPD were adopted in November 2010 and January 2011, respectively. The DPDs within this replaced the saved policies of the Surrey Minerals Local Plan, 1993. Provision of Soft Sand 4.43 Surrey supported the 2010 proposed changes to the apportionments which meant a reduction in their apportionment from 2.62mtpa to 1.27mtpa. Because the plan spans the changes in apportionment, the Primary Aggregates DPD (2011) assumes a requirement of 2.62mt for 2009. Thus, the equivalent total amount required over period is 22.94mt. By applying a sales based ratio between sand and gravel and soft sand, the proposed changes apportionment results in a split apportionment of 15.57mt and 7.33mt, respectively. This is identified as a „low‟ estimated resource requirement when compared to that which would result from use of the original apportionment figure (identified as a „high‟ estimate in the DPD). 4.44 The DPD identifies proposals in preferred areas that will be available over the plan period, it does not identify areas of search. The plan estimate is that these areas, plus the remaining existing reserves, would be sufficient to deliver 23.96mt. On this basis, Policy MA1 of the DPD states that provision will be made for 24mt of primary aggregate which comprises “15 million tonnes of concreting aggregate and 9 million tonnes of soft sand between 2009 and 2026”.

13 This is a provisional stance as there is a lack of evidence and deliverability. In reality there could be supply post 2016 if planning permission is renewed. South Downs National Park - Soft Sand Study August 2012 14 4. Minerals Planning Context

4.45 As for the apportionment estimates, the split between provision for concreting aggregate and soft sand was based on average sales figures.. Using the „low‟ estimate of the soft sand resources required, Surrey identify that 1.65mt needs to come from preferred areas and that this could be met by reserves at Mercers Farm, Nutfield Marsh (2.70mt). . 4.46 Surrey‟s Core Strategy states that there is a presumption against major new workings of soft sand within the Surrey Hills AONB as their requirement can (reportedly) be met from outside the designated area. However, the Core Strategy DPD notes a recognised national scarcity of silica sand “for which there is no suitable alternative”. There is, however, a silica sand preferred area (and area of search) at Pendell Farm (which adjoins existing works at North Park Quarry, Bletchingley) within the AONB and an application for silica sand extraction has since been approved. An additional silica sand area of search is at Chilmead Farm., outside the AONB. Consideration of Green Belt land also applies in this area. Minerals Safeguarding 4.47 Safeguarding of soft sand resources in Surrey is via Proposals Maps. There are six specific areas within the Folkestone Formation in which soft sand MSAs have been mapped. All of these areas fall within the Folkestone Formation resource. Kent Plan Development 4.48 Kent have begun development of their Minerals and Waste Core Strategy which will supported by a Minerals Sites Development Plan Document. The development of the Core Strategy and Minerals Sites DPD had reached options consultation stage at May 2011 and the 'Preferred Options' consultation for mineral sites is currently „live‟ (28 May to 23 July 2012). The publication and pre-submission consultation is scheduled for September 2013. Provision of Soft Sand 4.49 Kent‟s apportionment of land-won sand and gravel under the „proposed changes‟ is 1.63mtpa. The NPPF now requires MPAs to prepare an annual Local Aggregate Assessment (LAA) based on a rolling average of 10 years sales data and other relevant local information, assessing all aggregate supply options. Kent‟s draft LAA shows that the apportionment for land-won sand and gravel of 1.63mtpa closely reflects the average of the most recent ten years of available sales data and Kent therefore identify that this figure is still valid. 4.50 The preferred option is not to split the land-won aggregate landbank on the basis that the ratio of sharp sand and gravel to soft sand is thought likely to change over the plan period (“some of the traditional areas of gravel working in the County are being exhausted or reducing outputs considerably”, Core Strategy - Strategy and Policy Directions Consultation, 2011). The Preferred Options document notes that “the majority of sites promoted to the County Council for consideration were for soft sand leaving insufficient sharp sand & gravel sites to maintain a separate landbank for these two types of mineral for the plan period”. 4.51 There are 25 preferred option sites for mineral development 7 of which are specifically soft sand sites. Together, these soft sand sites represent a potential reserve amount of 17.06mt, and 23.53mt in total for sand & gravel. 4.52 One of the preferred option soft sand sites in Kent also has identified resources of silica sand (in a ratio of roughly 2:1 silica:soft sand) which would “provide an estimated reserve landbank of 10 years according to the current rates of consumption”.

South Downs National Park - Soft Sand Study August 2012 15 4. Minerals Planning Context

Minerals Safeguarding 4.53 The preferred option for mineral safeguarding is to apply this to scarce, high value minerals and this reported to include the Folkestone Formation soft sand and silica sand. MSAs will be included on a Core Strategy Key Proposals Map and in the Mineral Sites DPD. 4.54 Policy CSM4 in the Core Strategy states that safeguarding will be applied to areas of known soft sand and that MCAs will be identified adjacent to Specific Sites. 4.55 Kent County Council published „Minerals Topic Report 4: Mineral Safeguarding‟ in May 2011 which uses the BGS map „Un-sterilised Soft Sand Resources in Kent and Medway‟ to form the basis of their safeguarding policy. The map separates areas of resource on the basis of „no environmental constraints‟, „one constraint‟ and „two or more constraints‟. Subject to refinement, it is said that these areas will be safeguarded and likewise, areas of urban development will be refined and removed. Summary

4.56 There are some important differences between the approaches to Minerals Planning for the study area‟s MPAs and for those with nearby soft sand resources (Kent and Surrey). These are:

 the stage at which minerals planning has reached in each MPA (therefore for some MPAs there is more certainty for the next plan period and/or an advanced evidence base);  how the plans define where future resources will come from (i.e. using areas of search, preferred areas and/or allocated sites);  how the MSAs have been developed (i.e. whole outcrop approach, selective approach based on constraints and/or named areas);  the proposed apportionment figure (in some cases this is close to the „proposed changes‟ figure, in some it is not);  the identification of apportionments for specific mineral types (no split or a soft sand/sand and gravel split), and;  the need to plan for minerals extraction within the SDNP (and other landscape designations) in order to meet apportionments e.g. West Sussex has identified „acceptable in principal‟ sites within the SDNP, while Hampshire plan for sand resources outside of the SDNP (current consideration of the Kingsley extension site notwithstanding). 4.57 As a result of the recent Hampshire EiP, all or some of the reserves remaining at the Kingsley site do not now form part of the permitted soft sand landbank for Hampshire. Kingsley has been agreed as a silica sand site by the Inspector and as such Hampshire are drafting a plan modification to reflect this.

South Downs National Park - Soft Sand Study August 2012 16 5. Trends in Demand & Permitted Reserves

5. Trends in Demand & Permitted Reserves 5.1 This section looks at the regional and local trends in sales for sand and gravel and the portion of that which is soft sand. This section also deals with provides an overview of the past and current permitted reserves both regionally and for the study area. Regional Trends in Demand

5.2 Sales information is shown below in Table 5.1.Overall, sales of land-won sand and gravel over the period 2002 to 2009 inclusive have decreased. However, despite showing year on year changes, the soft sand sales do not show a comparable downward trend. 5.3 Published information regarding anticipated future trends in demand have not been identified, however, the Mineral Products Association has been able to provide more recent figures for the sales trends (reproduced in Table 5.2 below which includes both land-won and marine dredged sand and gravel: separate figures are not available). These figures (which are based on a reportedly large sample of the market) show that after 2009 sales have recovered, with a more marked recovery in the South East when compared to Great Britain as a whole. In terms of emerging or expected trends in demand, this correlates with reporting by one mineral industry representative of increased demand for sand and gravel in 2011, and the prediction by another representative that demand is expected to be greater in at least the next 2 to 3 years.

Sales (million tonnes) Year S&G Soft Sand 14 2000 12.63 0.32 12 2001 12.44 0.31 10 2002 11.48 3.06 2003 10.64 2.66 8

2004 10.41 2.62 6

2005 9.71 1.75 (Millions) Tonnes 4 2006 8.80 1.78 2007 8.50 1.91 2

2008 7.30 2.27 0 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2009 6.10 1.39 Sales - S&G Sales - Soft Sand

Table 5.1 Sales for the South East Region (source: collated from the South East Aggregates Monitoring Reports for 2000 to 2009).

S&G1 Sales (% change on previous year) Year Great Britain South East of England 2009 -23% -18% 2010 No change +3% 2011 +5% +10% Table 5.2 Change in sand and gravel sales volumes for Great Britain and the South East Region (source: Mineral Products Association, 2012).1. includes both landed and primary sand and gravel, for which the relative proportions are expected to be broadly similar over the period. Local Trends in Demand

5.4 Table 5.3 below provides approximate sales figures for the MPAs over the period 2000 to 2010. The data within this table should be treated with caution as they are likely to be best estimates made by those who collated the original sources. 5.5 In West Sussex, overall sand and gravel sales were greater at the start of the period between 2000 and 2004, with a decline in sales observed thereafter to 2009. Soft sand sales (whilst the figures are not consistently available) were also greater at the start of the period (between 2000 South Downs National Park - Soft Sand Study August 2012 17 5. Trends in Demand & Permitted Reserves

and 2004) and show a sharp decrease between 2004 and 2005. A slight decrease in sales is shown thereafter to 2009. 5.6 For Hampshire overall sand and gravel sales decreased between 2000 and 2010 (with the exception of 2007) and each year remain the highest sales of the three MPA areas. Sales of soft sand also decreased between 2000 and 2009 (with the exception of 2008), 2010 shows a slight increase in sales. As such, the 10-year average of soft sand sales in Hampshire is 0.28 million tonnes per year (Soft Sand Topic Paper, 2012). 5.7 Figures for East Sussex cannot be obtained due to confidentiality reasons; annual figures would reflect individual sites.

Hampshire West Sussex East Sussex Year Total S&G Soft Sand Total S&G1 Soft Sand1 Total S&G Soft Sand 2000 2.41 0.71 0.8 0.6 C C 2001 2.29 0.50 1.0 0.7 C C 2002 2.19 0.38 0.9 0.7 C C 2003 1.81 0.31 0.9 0.7 C C 2004 1.67 0.36 0.8 0.6 C C 2005 1.58 0.31 0.6 0.5 C C 2006 1.24 0.19 0.5 0.5 C C 2007 1.49 0.18 0.5 0.5 C C 2008 1.27 0.29 0.4 0.4 C C 2009 1.05 0.11 0.3 0.3 C C 2010 0.98 0.14 0.3 0.3 C C Table 5.3 Sales in million tonnes (approximately end of year) by MPA. ?: figure not identified. C: confidential figure. (sources: where possible, the MPAs have verified or supplied the figures. In the case of West Sussex, these are estimates only. A portion of the sand and gravel reserves in East Sussex is confidential and so figures provided do not include this data. AMRs, SEERAWP reports and MWDF documents have also been used). Regional Permitted Reserve Trends

5.8 Between 2000 and 2009, the permitted reserves of sand and gravel within the whole of the South East fell from ~140mt to ~80mt. However, since the regional apportionment also decreased during this period, the declining reserves have been sufficient to reduce to, and then maintain, an approximate landbank of just under 7 years in the latter part of the period. Permitted soft sand reserves have also fallen, in a similar pattern to the overall totals for sand and gravel. In the absence of a separate apportionment figure for soft sand, this cannot be assessed in terms of a regional landbank.

Permitted Reserves (million tonnes) Year S&G Soft Sand 140 14 130 13

2000 139.56 60.09 Equivalent S&G Landbank 120 12 2001 129.67 54.43 110 11 100 10 2002 121.36 46.74 90 9 2003 97.09 28.41 80 8 70 7 2004 80.81 26.95 60 6

50 5 (Years) 2005 87.29 19.98 (Millions) Tonnes 40 4 2006 76.43 18.82 30 3 20 2 2007 78.13 24.30 10 1 2008 84.69 30.66 0 0 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

2009 79.05 21.30 S&G Soft Sand S&G Landbank Table 5.4 End of year permitted reserves for the South East Region (source: collated from the South East Aggregates Monitoring Reports for 2000 to 2009). South Downs National Park - Soft Sand Study August 2012 18 5. Trends in Demand & Permitted Reserves

Local Permitted Reserve Trends

5.9 The permitted reserves for West Sussex, East Sussex and Hampshire are shown in Table 5.5. The data within this table should be treated with caution as they are likely to be best estimates made by those who collated the original sources and because the reserves are subject to frequent reassessment by the mineral operators. 5.10 For Hampshire, there has been a general downward trend in permitted sand and gravel reserves until 2008 though reserves are estimated to have increased to 16.44mt by 2011. 5.11 In West Sussex, there has been a downward trend similar to that of Hampshire, and likewise the permitted reserves of soft sand have increased since 2007. 5.12 In East Sussex, the sand and gravel landbank has been consistently high at around 38 years, a result of large existing planning permissions. Most of the available resources are located close to the Kent border. Reserves of soft sand in the western part of the county are limited to a single small site (Stanton‟s Farm), which currently has a permission expiry date of 2016).

Hampshire West Sussex East Sussex Year S&G Soft Sand S&G Soft Sand S&G Soft Sand 2000 17.04 4.88 8.22 7.06 C C 2001 14.00 4.14 7.72 6.81 C C 2002 13.73 2.38 6.55 5.85 C C 2003 12.12 2.03 5.96 5.04 C C 2004 10.54 2.29 5.08 4.35 C C 2005 10.89 0.55 4.75 4.57 4.55 0.38 2006 9.80 1.87 4.21 4.11 4.55 0.38 2007 9.22 3.19 3.74 3.66 4.55 0.38 2008 7.63 2.94 4.84 4.79 4.55 0.38 2009 14.30 2.17 5.49 4.56 4.55 0.38 2010 14.00 2.22 5.37 4.44 4.10 0.12 2011 16.44 2.22 ? ? 4.10 0.12 Table 5.5 Permitted reserves in million tonnes by MPA (approximately end of year, rounded figures). ?: figure not identified. C: confidential figure. (sources: where possible, the MPAs have verified or supplied the figures. In the case of West Sussex, these are estimates only. A portion of the sand and gravel reserves in East Sussex is confidential and so figures provided do not include this data. AMRs, SEERAWP reports and MWDF documents have also been used,)

South Downs National Park - Soft Sand Study August 2012 19 6. Permitted Soft Sand Sites, Markets & End Uses

6. Permitted Soft Sand Sites, Markets & End Uses 6.1 This section provides information on existing soft sand quarry sites and the potential future sites, where they have been allocated in mineral plans. It also looks at the end uses of soft sand from particular quarries. In order to obtain this information, minerals industry representatives were contacted, along with reference to plan documents and directories. All sites identified in this section and in Section 7 are shown on the Figures B.1 to B.3 in Appendix B. Permitted Soft Sand Sites

6.2 Existing sites in the three MPAs that are adjacent to the SDNP (as identified for 2011) are shown in Table 6.1 below. All sites are marked on Figures B.1 to B.3, in Appendix B, in green.

County Site Status Within the SDNPA? Kingsley Quarry (Rookery Farm) Active No, but adjacent Hampshire Frith End Sand Quarry Active No, but adjacent Blashford Quarry (Plumley Wood / Nea Farm) Active No, ~40km away West Heath Quarry and extension1 Active Yes Minsted Sandpit Active Yes Sandgate Park Quarry Active No, but adjacent West Sussex Rock Common Sandpit Active No, but adjacent Heath End Quarry Inactive Yes Hampers Lane Sandpit Inactive No, but adjacent East Sussex Stanton’s Farm (Novington Sandpit) Active Yes Table 6.1 Existing quarry sites in the study area with permitted reserves of soft sand. 1. the extension was a long list site in 2009 (see Section 7) and was granted planning permission in 2010.

MPA Site Status Runfold South Quarry Area C Active Homefield Sandpit Active Reigate Road Quarry Active Surrey North Park Quarry (Sand and Silica Sand) Active Moorhouse Sandpits Active Farnham Quarry (Wrecclesham) Inactive Woodhill Sandpit Dormant Addington Sand Pit (Wrotham Quarry) Active Aylesford Quarry (Sand and Silica Sand) Active Borough Green Sandpits (Sand and Silica Sand) Active Charing Quarry (Swan Lane) Active Chilston Quarry Lenham Inactive Ham Hill Sandpit Inactive Ightham Sandpit Active Kent Joyce Green Quarry (also produces sand and gravel) Inactive Nepicar Sand Pit Active Ospringe Brickworks Inactive Sevenoaks Quarry Active Shepherd's Farm Quarry, Lenham Inactive Squerryes Court Quarry Inactive Winterbourne Quarry Active Table 6.2 Existing quarry sites in Surrey and Kent with permitted soft sand reserves. Sites as identified in Minerals and Waste Planning in Surrey - Annual Monitoring Report 2010-11 (Surrey County Council) and TRM1: Draft Local Aggregate Assessment (May 2012) (Kent County Council). 6.3 For the sites situated within the SDNP (as given in Table 6.1), there is an estimated total remaining permitted reserve of around 1.8mt of soft sand. This estimate is based on remaining

South Downs National Park - Soft Sand Study August 2012 20 6. Permitted Soft Sand Sites, Markets & End Uses

reserves reported in conversations with the mineral operators of the individual sites and on historical planning permission information; it includes some reserves that may be subject to obtaining time extensions for extraction and, as such, this figure should be treated with caution. 6.4 Sand quarries in Kent and Surrey, include those in Table 6.2 above (and these are marked on Figures B.2 and B.3 in green). The active/inactive status has been based on discussions, where these have been held, with mineral operators or identified within the most recent planning documentation available. Current Markets and End Uses for Soft Sand

6.5 For existing sites within the study area, Table 6.3 (below) provides detail on the end uses of soft sand and the demand in terms of main markets. Similar information is given for Kent and Surrey in Table 6.4. The location of these sites is shown in Figures B.1 to B.3.

County Site Uses & Markets Currently 75% of sand sales are for specialist end uses as the extracted sand is high in silica and matches the horticultural sand curve well. The sand is blended with imported soil and this „Kingsley Kingsley Quarry Mix‟ is used within playing pitches, especially football pitches and golf (Rookery Farm) courses, travelling as far as Birmingham, Bristol and Wales (up to around 200 miles). Another specialist sand end use is for filtration. The remaining 25% of sand sales is primarily for use as a building sand with a smaller proportion used in concrete. There are two main end uses of the sand: the majority is used as a mortar sand and the remainder is mixed with marine aggregates, Hampshire replacing the fines washed away by dredging so that the end mix can Frith End Sand Quarry be used in concrete. The sand travels to wharves at Portsmouth and Southampton and is then used within these local areas. Approx. 1/3 of the sand has specialist end use, and the operator considers the sand extracted to be similar to that at Kingsley. Both sites have sand and gravel (sharp sand) overlying soft sand. Blashford Quarry The soft sand is from the Poole Formation containing more silt than the soft sand making up the Folkestone Beds and does not meet (Plumley Wood / Nea specialist sand grading curves. (The sand is used mainly as a Farm) building sand, primarily for mortar and serves the local market (not travelling more than 30 miles). The sand is primarily used as building sand and much is transported to the operator‟s Kingsmead processing site, near Heathrow, where it is mixed with other quarry products to serve the West Heath Quarry and west London market. Sand also travels to nearby Petersfield and to extension (West builders merchants on south coast. Finer material is transported to Hampshire) wharves in Portsmouth and is mixed with marine aggregate to assist in lowering the chloride content for concrete end uses. A specialist sand end use includes bedding for cattle as micro-organisms grow very slowly within the clean sand. About 95% of the sand has a concrete products end use, predominantly roof tiles and serves a wider market of up to 45 miles. Minsted Sandpit The remaining 5% of the sand is use in specialist applications such West as for polo pitches and golf bunkers. Sussex About 75% of the sand is transported to the operators ready-mix plant Sandgate Park Quarry near Crawley, 40 miles away for use as a building sand. The remaining 25% is used within the onsite concrete plant.

About 80% of the sand is used as a building sand, with the remaining Rock Common Sandpit 20% of the sand having a specialist s end use within golf bunkers and for equestrian applications. The new operator has not yet commenced operations but anticipates Heath End Quarry a 50% building sand end use and a, 50% concrete products end use. Hampers Lane Sandpit Building sand / concreting sand East Stanton‟s Farm The sand is used entirely as a building sand, mainly within mortar. Sussex (Novington Sandpit) Table 6.3 Summary of reported end uses and markets for permitted soft sand sites in the study area.

South Downs National Park - Soft Sand Study August 2012 21 6. Permitted Soft Sand Sites, Markets & End Uses

MPA Site Uses & Markets Runfold South Quarry Building and construction Area C Building sand, as dug aggregate and construction sand1 Homefield Sandpit Construction sand3 Graded sand & gravel, construction sand and building sand1 Surrey Reigate Road Quarry Glass sand, dried sand, foundry sand, equestrian sand, leisure sand, industrial sand, bagged sand, sports sand.2 Glass sands, coloured glass sands, sodium silicate sands, foundry North Park Quarry sands, asphalt and mortar sands, rootzones, urban tree soil, mineral filler sands2. Sand for equestrian use3. Building sand and plasters1 Moorhouse Sandpits Construction sand, industrial, non construction3 Soft sand sales from here travel to the south coast for mixing with marine dredged sand and are primarily used in concrete rather than Sevenoaks as a building sand and have been used in high-profile projects including “the Gherkin, the Chelsea and Arsenal football stadiums, Wimbledon Centre Court and the Globe Theatre”4 Borough Green Building sand* Sandpits Construction aggregate (non construction aggregate)3

Charing Sandpit (Swan 3 Building sand* Building and asphalt Lane) Kent Lenham Quarry Concreting sand, building sand1

Snodland (Ham Hill 1 Building sand, construction sand Sandpit)

Squerryes Court 1 Sand for brick or tile manufacture Quarry

Winterbourne Quarry 5 Building sand West Ightham Sandpit Building sand5 Table 6.4 Summary of reported end uses and markets for soft sand in permitted sites in Kent and Surrey 1.Uses description from the Directory of Mines and Quarries, 2010, BGS. 2. http://www.samsa.org.uk/who_locations01.htm 3. GWP report, 2010 4. Minerals Planning Magazine, 01 June 2010 „Aggregates - Sevenoaks quarry wins consent for extension‟ 5. Kent Core Strategy consultations document Discussion

6.6 The radius of economic transportation of sand and gravel is often quoted as being generally less than 30 miles. However, it is clear from Table 6.4 that soft sand in the South East does in many instances travel over greater distances. There would appear to be a number of reasons:

 For national operators, such as CEMEX, the product is transported to the nearest ready- mix plant, such as that based at Kingsmead near Heathrow. This means the product travels up to 45 miles for processing with onward travel to more distant places, such as to the West London market.  One end use of the soft sand is to mix with marine aggregates to replace the finer material washed away by dredging and to assist in meeting the chloride content required for concreting purposes. In these instances, the product travels to the nearest wharves which again may be up to 45 miles distant.  For the smaller operators, the sand is often used more locally but manufactured products (such as roof tiles) will again travel up to 45 miles for longer term, larger demand contracts.  Finally, where the soft sand is being used for a specialist silica sand end use, such as in sports pitches, then distances travelled may be up to 200 miles.

South Downs National Park - Soft Sand Study August 2012 22 7. Provision of Soft Sand in the Current Plan Period

7. Provision of Soft Sand in the Current Plan Period 7.1 The Plans for East Sussex, West Sussex and Hampshire, which are all being prepared jointly with the SDNPA, are in various stages of development (see Section 4). Potential sites or areas for future working, and their success (or lack thereof) at Plan selection stages are provided in Tables 7.1 to 7.4 below. All sites identified in this section are shown on the Figures B.1 to B.3 in Appendix B (potential sites are identified by orange markers and rejected sites are marked in red). Hampshire Allocations

7.2 Information on the Hampshire sites that are potential future allocations comes from their work in preliminary assessment (documented in the Minerals Proposal Study) and for those sites put through the subsequent interim and draft Integrated Sustainability Appraisal (ISA). As Table 7.1 shows, only Forest Lodge Farm and Purple Haze were recommended for inclusion in the draft Plan following completion of the appraisal work. Two potential areas at Whitehill - Bordon were recommended for specific safeguarding, as a potential opportunity for prior extraction, due to the known development pressures in this location (the development of the Whitehill-Bordon Eco-town). The site identified within the Plan at Bleak Hill is allocated for sharp sand and gravel (0.5mt), but a small soft sand reserve is also likely to be found in this location. 7.3 Purple Haze may potentially be allocated as the best option for continuing a local supply for west Hampshire and, similarly, Forest Lodge Farm is considered the best option for continuing local supply in south Hampshire. 7.4 The potential site allocations in Hampshire for the period up to 2030 total 11.57mt for sand & gravel and the portion of that which is soft sand equates to 4.03mt. None of the potential reserves are within the area now covered by the SDNPA. However, the safeguarded sites at Whitehill-Bordon are approximately 500m from the SDNP boundary. 7.5 Note that Table 7.2 below includes the Kingsley site, as this was considered and rejected during the allocations process as it was considered that other soft sand sites would have less sustainability impacts. This site and the potential implications of its promotion as a silica sand site are discussed at the end of this section.

Within the Estimated Site Status (most recently reported) SDNPA? Reserve PROPOSED ALLOCATION: This site was considered at ISA to be appropriate for Forest Lodge No, ~20km inclusion within the Minerals and Waste Plan. The proposal would feed the South 400,000 Farm away Hampshire market area. The proposal is considered to be the most sustainable option for this type of extraction within this area. PROPOSED ALLOCATION: Recommended in 2011 for inclusion in the plan. The No, ~40km proposal would feed the west Hampshire and surrounding market areas. The 7,250,000 Purple Haze away proposal is considered to be the most sustainable option for this type of extraction (3,625,000)* within this area. PROPOSED SAFEGUARDED AREA: Recommended for safeguarding at ISA. The site is not considered to be suitable for allocation within the Minerals and Waste Whitehill Bordon No, <500m Plan, however, the soft sand reserves should be specifically safeguarded through Not known A away policies on the protection of mineral resources from sterilisation. Area is only suitable for specific safeguarding. Deliverability of the Eco-town is uncertain. Reserves only provide an opportunity for prior extraction PROPOSED SAFEGUARDED AREA: Recommended for safeguarding at ISA. The site is not considered to be suitable for allocation within the Minerals and Waste Whitehill Bordon No, <500m Plan, however, the soft sand reserves should be specifically safeguarded through Not known B away policies on the protection of mineral resources from sterilisation. Area is only suitable for specific safeguarding. Deliverability of the Eco-town is uncertain. Reserves only provide an opportunity for prior extraction Table 7.1 Site options proposed as potential allocations in Hampshire *A maximum of 4mt of sand and gravel will be available within the plan period, which includes up to 3.625mt of soft sand (Hampshire Minerals and Waste Plan (Submission). South Downs National Park - Soft Sand Study August 2012 23 7. Provision of Soft Sand in the Current Plan Period

Within the Estimated Site Status (most recently reported) SDNPA? Reserve At Integrated Sustainability Appraisal (ISA) the site was not considered to be suitable for allocation within the Minerals and Waste Plan. This is based on potential Dunwood No, ~20km impacts on communities, amenity, health and quality of life. The cumulative impacts 600,000 Nurseries away of this proposal working alongside other nearby minerals and waste developments is also considered to be potentially significant. There are other proposals considered to have less sustainability impacts. This potential extension was identified in the draft Hampshire Minerals Plan as Area Frith End Sand 4. It lies 0.6 miles south of the South Downs National Park Boundary. However, in No, <1km Quarry Extension July 2010 the potential mineral operator indicated that that the new landowners no 400,000 C away longer wanted to promote the site for mineral extraction. The site is considered to be undeliverable at this stage. Previously considered up to Regulation 26 for the draft Hampshire Minerals Frith End Sand No, <1km Consultation Plan, now considered to be undeliverable. In 2011, confirmation was Quarry Extension 1,000,000 received that the landowners of the site do not now support its nomination for D away mineral extraction. This site is therefore now considered undeliverable at this stage. Frith End Sand Not considered to be suitable for allocation at ISA, based on potential impacts on No, <1km Quarry Extension landscape and townscape, transportation, communities and amenity and health and 1,800,000 E away quality of life. Other proposals are considered to have less sustainability impacts. Considered unsuitable and ruled out at ISA stage. Extension of existing site 250,000 tonnes The site has not previously been considered 750 metres south of the South Frith End Sand Downs National Park boundary The proposal is for an extension to Frith End Quarry No, <1km Quarry Extension an existing, permitted and active mineral extraction site with a demonstrated 250,000 F away operating performance. There is not enough information to fully appraise this site at this stage. It is therefore not considered to be suitable for further appraisal at this stage. This possible new site is not considered to be suitable for allocation within the Minerals and Waste Plan, based on landscape and townscape, communities, No, ~20km amenity, health and quality of life. The cumulative impacts of this proposal working Glebe Farm 700,000 away alongside other nearby minerals and waste developments is considered to be potentially significant. Other proposals are considered to have less sustainability impacts. This possible extension site was rejected at ISA stage. The site is located within the South Downs National Park. Other opportunities for the extraction of soft sand which Kingsley Quarry Yes lie outside of designated areas. There may be impacts on prudent use of resources, 2,000,000 Extension communities and amenity and health and quality of life. Other proposals are considered to have less sustainability impacts. Rejected at ISA stage. This is based on potential impacts on landscape and Malthouse and No, ~700m townscape, communities and amenity and health and quality of life. There are other 1,800,000 Osbourne away proposals which are considered to have less sustainability impacts. Rejected at ISA stage. This is based on potential impacts on landscape and townscape, communities, amenity, health and quality of life. The cumulative impacts No, ~20km Post Hill Farm of this proposal working alongside other nearby minerals and waste developments is 965,000 away considered to be potentially significant. Other proposals are considered to have less sustainability impacts. Table 7.2 Site options rejected as potential allocations in Hampshire 7.6 The potential implications of classifying Kingsley Quarry as a silica sand site (in the recent Hampshire Minerals and Waste Plan EiP) and the subsequent requirement for Hampshire to plan for silica sand relate to: the defining and meeting of apportionments for soft sand/sand & gravel, and; the environmental criteria against which site allocations and planning applications are judged. The following discussion draws upon information from Sections 4 and 6. 7.7 If Kingsley is reclassified then the implications for aggregate apportionments, in particular soft sand apportionments, is not clear14. It may be assumed that part or all of the „soft sand reserves‟ at Kingsley that contribute to the current Hampshire landbank will be deducted and that there may a reduction in the soft sand apportionment. If there is no reduction in apportionment, there may need to be an increase in other allocations to cover this „deficit‟ unless the remaining reserves at Kingsley are very limited, and then the potential allocations at other sites may be sufficient for the coming plan period (an analysis of the soft sand provision situation across the study area is given in Section 8). 7.8 In terms of weighing up the environmental factors against the need for minerals extraction, the classification of the Kingsley site as silica sand may set an important precedent. For example

14 Legal opinions are awaited (Lisa Kirby, Hampshire County Council, pers. comm. July 2012). South Downs National Park - Soft Sand Study August 2012 24 7. Provision of Soft Sand in the Current Plan Period

there are reportedly other sites that may have similar specialist end uses for a portion of their product. Broadly speaking, these could be seen to include:

 Rock Common (a rejected site in West Sussex, adjacent to the SDNP: an existing site in this area has 20% specialist end use)  Minsted West (a long list site in West Sussex, inside the SDNP: an existing site in this area has 5% specialist end use)  Heath End (a currently inactive site in West Sussex, inside the SDNP: 50% specialist end use) 7.9 However, the implications of the successful argument by Tarmac may be that sites that would otherwise be put forward as soft sand sites could, in the future, be put forward for whole or partial classification as silica sand sites regardless of whether the end use of the material is „industrial‟ (as defined in the Technical Guidance to the NPPF) or „specialist‟. This clearly has implications for a site‟s strategic importance in the judgement between national need and national landscape protection. 7.10 A legal opinion is being sought on the issues raised by this classification of the Kingsley extension and Hampshire County Council are considering how they will respond. West Sussex ‘Long List’ Sites

7.11 For West Sussex, the sites in Tables 7.3 and 7.4 below are those identified through the long-list process, as documented in the „living draft‟ Background Paper 5: Strategic Mineral Sites (December 2009). Of the 20 sites, 8 were identified as „acceptable in principle‟ (Table 7.3) and 7 of these were within the SDNPA boundary. 7.12 The 0.565mt extension to West Heath Quarry was permitted in 2010 (included in active sites table above and in Table 7.3 below). Horncroft Quarry/ Coates Quarry was applied for but then withdrawn (at this time the SDNPA had raised an objection due to lack of exceptional circumstances and ambiguity over future level of supply from within the Park). 7.13 One previously allocated site (Dunford Rough, within the area now covered by the SDNPA) was rejected at the long list stage as a result of restrictive covenants and access difficulties. These long list sites may or may not be taken forward to allocation, depending on the next stages of West Sussex‟s Plan development, but those sites that fall within the SDNPA boundary have an identified potential soft sand reserve of 12.065mt (including West Heath Extension and Horncroft).

South Downs National Park - Soft Sand Study August 2012 25 7. Provision of Soft Sand in the Current Plan Period

Within the Estimated Site Status SDNPA? Reserve Long list site, 2009: Acceptable in principle subject to: assessment of impact on Chantry Lane landscape character; buffers to waterbodies; retention of hedgerows; protected Yes 350,000 Extension species assessment; mitigation of impacts on archaeological remains; flood risk assessment; new access from the A283. Long list site, 2009: Acceptable subject to: assessment of impact on landscape character; ecological assessment; buffers to SNCI, SSSI and ancient woodland; Duncton Common Yes 1,800,000 archaeological assessment; flood risk assessment; assessment of impact on nature conservation; diversion of PRoW. Long list site, 2009: Acceptable in principle subject to: protection/mitigation of East of West Yes PRoW; screening to protect views into the site; archaeological and 2,850,000 Heath Common geoarchaeological assessment; flood risk assessment. Long list site, 2009: Acceptable in principle subject to: buffers to hedgerows and No, but woodland; planting to screen and retain landscape character; mitigation of visual Ham Farm 850,000 adjacent impact upon listed building and buried archaeological remains; retention/protection of PRoW and mitigation of any impact on public amenity. Long list site, 2009: Acceptable in principle subject to the site being allocated as an extension to the existing Pendean sandpit utilising the same access and further Hawkhurst Farm Yes information about site deliverability; further assessment of the site boundary; 3,000,000 retention of Dunford Hollow and hedgerows; flood risk assessment, protection/mitigation for listed obelisk and archaeology. Long list site, 2009: Acceptable in principle subject to: mitigation of woodland features and hedgerows; reduction of site to south-west edge; mitigation of impacts Minsted West Yes 2,000,000 on buried archaeology; flood risk and hydrogeological assessment; assessment of impact on nature conservation; retention/mitigation/diversion of PRoW. West Heath Long list site, 2009. Acceptable in principle subject to: assessment of landscape 1 Yes 565,000 Quarry Extension impact; ecological assessment; archaeological assessment; flood risk assessment. Long list site, 2009, Acceptable in principle subject to: assessment of impact on Horncroft Quarry/ landscape character; retention of boundary hedgerows and stream valley with 2 Yes 1,500,000 Coates Quarry associated oaks; ecological assessment; archaeological investigation; flood risk assessment; protection of PRoW. Table 7.3 Site options that were successful during the long list process in West Sussex 1. permitted in July 2010. 2. subsequently applied for but then withdrawn, during Nov 2010. Within the Estimated Site Status SDNPA? Reserve Buncton Not considered for allocation unacceptable landscape character impact and Yes 1,000,000 Crossways uncertain deliverability. Yes Not considered for allocation unacceptable landscape character impact and Burton East 2,000,000 uncertain deliverability. Yes Not considered for allocation unacceptable landscape character impact and Burton West 3,000,000 uncertain deliverability. Coopers Moor Yes Not considered for allocation due to uncertain deliverability. 500,000 Yes Allocated in 2003, but not considered for allocation in recent plan due to Dunford Rough 3,400,000 restrictive covenants and access difficulties. Lower Chancton Yes Rejected in 2009 due to improvements to the A283 are needed before access can 7,500,000 Farm be achieved uncertain deliverability. Yes Rejected in 2009 due to Unacceptable impact on landscape character. The site Minsted East would have a detrimental visual impact along the extent of the valley floor. There is 2,500,000 also uncertainty about deliverability of the site. Yes Rejected in 2009 due to unacceptable impact on landscape character, visibility Ridlington Farm issues in National Park and wider foothills. Covenants on the land have also 5,700,000 restricted deliverability. Rejected in 2009 due to unacceptable impact on landscape character in context of Rock Common No, but the South Downs National Park. Adverse impact on public amenity as a result of 700,000 South adjacent cumulative impact. There is also uncertainty about deliverability. Improvements to the A283 are needed before access can be achieved. Rejected in 2009 due to unacceptable impact on landscape character. Removal of Rock Common No, but this section of land will open up views into existing extraction site. The proposal Not known West adjacent would have an adverse impact on public amenity as a result of cumulative impact. There is uncertainty about deliverability of the site. Yes Rejected in 2009 due to deliverability issues. The landowner has indicated that they Severals East Not known will not be bringing the site forward. Yes Rejected in 2009 due to deliverability issues. The landowner has indicated that they Severals West Not known will not be bringing the site forward. Yes Rejected in 2009 due to unacceptable impact on landscape character. The Wiggonholt proposal would have an adverse affect on landscape character and loss of 2,000,000 landscape features. There is also uncertainty about deliverability of the site. Table 7.4 Site options that were not successful during the long list process in West Sussex

South Downs National Park - Soft Sand Study August 2012 26 7. Provision of Soft Sand in the Current Plan Period

East Sussex Site Allocations

7.14 East Sussex intend to begin a site document within 12 months of the adoption of their Plan but there has been a lack of potential soft sand sites identified previously. Summary

7.15 At present, Hampshire has no potential sites now covered by the SDNPA, while the majority of reserves intended to meet West Sussex‟s apportionment are within or adjacent to the Park‟s boundary. In total, some 11.56mt was considered by WSCC, prior to the designation of the SDNP as potential allocations within the SDNP.

South Downs National Park - Soft Sand Study August 2012 27 8. Analysis of Reserves Information

8. Analysis of Reserves Information 8.1 This section brings together information relating to available permitted reserves, apportionments and estimated reserves within allocated/long-list sites, to provide an analysis of the potential shortfall or surplus over the current Plan period for each MPA in the study area, with consideration of reserves in Kent and Surrey. Note that, although this sections uses some very precise figures, the results of the calculations applied to them should be viewed as providing a general picture of soft sand provision (particularly given the differing stages achieved in planning for minerals across the MPAs and the availability of data to support the analysis). Reserve Calculation Tables

8.2 Tables 8.1 and 8.2 below, summarise the overall position with regard to sand & gravel and soft sand provision, respectively, within each MPA. The tables set out information relevant to the current Plan period (the one for which minerals and waste local plans are currently being developed), and refer to the whole of the MPAs concerned. The sand & gravel figures in Table 8.1 provide a starting point and context for the analysis of soft sand provision in Table 8.2, which accounts for only a portion of the total sand & gravel values. 8.3 Column A in each table describes each MPA‟s approach to adoption of an apportionment figure. In some cases the MPAs have worked towards meeting the apportionment as set out in the „Proposed changes‟ to the South East Plan. In other MPAs, an alternative figure has been proposed based on assessment of local issues. In the case of soft sand, not all MPAs have or propose to identify a separate apportionment. Where a separate apportionment is proposed, the method for identifying the amount of soft sand the MPA will plan for is noted. 8.4 Column B identifies the number of years covered within the calculations. The start date for the period of years is that defined in Adopted, Submission or Proposed Submission plans and likewise, the end date is based on the end of each MPA‟s Plan Period (defined within the relevant submitted Plan or other supporting, but earlier stage, planning documents). For West Sussex, minerals planning has not yet reached the stage of having prepared a proposed submission plan and therefore the start date is based on a point in time for which „current‟ permitted reserves (Column E) could be identified and could be separated from „potential future reserves‟ (Column G, those being planned for). The end date for West Sussex calculations is 203115. 8.5 Column C gives the annual apportionment that each MPA is working towards meeting16, with additional rows provided where this differs from the „proposed changes‟ apportionment. Column D identifies the total apportionment for the number of years used identified as roughly equivalent to „plan period‟. 8.6 In Column E, the permitted reserves figures are those given for the start of the plan period in the planning documents. For West Sussex and Kent, these figures have been obtained for the relevant point in time from the Annual Monitoring Reports for those MPAs. Both Table 8.1 and 8.2 include the Kingsley site within the permitted reserves figure. 8.7 Column F shows the result of subtracting the apportionment for each MPA from the permitted reserves and, in effect, identifies the amount of mineral that would need to be identified in order to meet the apportionment.

15 As identified in the West Sussex Minerals and Waste Development Scheme 2011-2015. 16 West Sussex do not yet have a defined apportionment but it may be based on the figure identified - Table 8.1, footnote 6. South Downs National Park - Soft Sand Study August 2012 28 8. Analysis of Reserves Information

S&G A B C D E F G H Permitted Shortfall or Allocated or Apportionment Annual Total Residual Reserves at Surplus over Potentially MPA type used in Years Apportion- Apportion- Shortfall Start of Plan Plan Period Allocated calculations ment (mtpa) ment (mt) or Surplus Period (mt) (mt) Reserves (mt) 1 2 3 4 Locally derived 19.25 1.56 30.00 16.44 -13.56 11.57 -1.99 Hampshire 1 3 4 'Proposed Changes' 19.25 2.05 39.46 16.44 -23.02 11.57 -11.45 5 6 7 8 Locally derived 22 0.64 14.12 5.34 -8.78 25.03 16.25 West Sussex 5 7 8 'Proposed Changes' 22 1.03 22.66 5.34 -17.32 25.03 7.71 9 10 11 12 East Sussex 'Proposed Changes' 17 0.10 1.70 4.10 2.40 0.00 2.40 Total residual S&G shortfall or surplus against locally proposed apportionments 16.66 Total residual S&G shortfall or surplus against proposed changes apportionments -1.33 13 14 15 16 Surrey 'Proposed Changes' 18 1.27 22.94 8.00 -14.94 16.00 1.06 17 18 19 Kent & Medway 'Proposed Changes' 19 1.63 30.97 20.62 -10.35 23.53 13.18 Total residual S&G shortfall or surplus against locally proposed apportionments 30.90 Total Residual S&G Shortfall or Surplus against Proposed Changes apportionments 12.90 Table 8.1 Sand & gravel provision in the study area NB: figures are rounded. Source notes: 1. 2011-2030 (based on Submission Plan, 2012). 2. Submission Plan, 2012 3. Submission Plan, 2012 . 4. Allocated sites. 5. 2009-2031 - CSL defined based on contemporary figures available for potential allocations and existing reserves for 2009. 6. Locally derived figure is based on 10 year average production figures as reported in the AMR and suggested by the MPA as likely to inform their apportionment figure. 7. West Sussex AMR, Dec 2011. Table 3: Sand and Gravel Landbank - 2005/06 to 2010/11. 8. Acceptable 'in principle sites' in long list 2009, incl. West Heath, permitted July 2010 (165,000t more than anticipated) and Horncroft (later applied for then withdrawn). Only the minimum number of sites to meet the apportionment would be allocated in the final plan. 9. 2012-2026 (Submission Plan 2012). 10. the 'Proposed Changes' apportionment has been locally adopted. 11. Table 11, (Plan, 2012). Excl. confidential reserves. 12. Plan, 2012. 13. 2009-2026 (Adopted Core Strategy, 2011). 14. 'Proposed Changes' apportionment used for 2010 onwards, previous apportionment applies to 2009, para 6.2 in Primary Aggregates DPD, 2011. 15. Primary Aggregates DPD, 2011. Total permitted is 10.28mt but only 8mt will be available in plan period. 16. Tables 3&4 in Primary Aggregates DPD, 2011, plus a modest adjustment to the production at Preferred Area E of +0.53mt. 17. 2012- 2030 (Core Strategy - Strategy & Policy Directions Consultation, May 2011), however permitted reserves figure is for year beginning 2011. 18. Kent AMR 2010/11, Dec 2011. 19. Preferred Options Allocations total. Soft Sand A B C D E F G H Permitted Shortfall or Allocated/ Residual Apportionment Annual Total Reserves at Surplus over Potentially Shortfall MPA type used in Years Apportion- Apportion- Start of Plan Plan Period Allocated or calculations ment (mtpa) ment (mt) Period (mt) (mt) Reserves (mt) Surplus Sales based 1 2 3 4 Hampshire 0.92 apportionment 19.25 0.28 5.33 2.22 -3.11 4.03 Sales based ratio on 5 6 7 8 6.75 locally derived 22 0.51 11.30 5.13 -6.17 12.92 West Sussex Sales based ratio 5 6 7 8 22 0.82 18.13 5.13 -13.00 12.92 -0.08 'Proposed Changes' No separate 9 10 11 12 East Sussex 0.00 apportionment 17 0.00 0.00 0.12 0.00 0.00 Total residual soft sand shortfall or surplus against locally proposed apportionments 7.67 Total residual soft sand shortfall or surplus against proposed changes apportionment 0.84 Sales based 13 14 15 16 Surrey 1.05 apportionment 18 0.41 7.33 5.68 -1.65 2.70 No separate 17 18 19 20 Kent & Medway 0.00 apportionment 19 0.00 0.00 9.85 0.00 17.06 Total residual soft sand shortfall or surplus against locally proposed apportionments 8.72 Total residual soft sand shortfall or surplus against proposed changes apportionment 1.89 Table 8.2 Soft sand provision in the study area. NB: figures are rounded. Source notes: 1. 2011-2030 Hampshire Submission Plan, 2012. 2. Hampshire Submission Plan, 2012. Table 5.3. Based on average sales, however 0.28 x 19.25 years is 5.39mt, while 5.33mt is given in Plan. 3. Hampshire Submission Plan, 2012. Table 5.3. 4. More reserves are available for allocation at Purple Haze, only that which is to be available in this plan period is included (3.625mt of soft sand)). 5. 2009-2031 CSL defined, based on contemporary figures available for potential allocations and existing reserves for 2009 and revised end of Plan period by WSCC. 6. Both apportionments are based on a 80:20 split applied (soft:S&G). Options presented in Background Paper 3: Minerals, Version 2, December 2009. 7. RAWP Report 2009: figure for end of year 2008.Table 6. 8. Acceptable 'in principle sites' in long list 2009, incl. West Heath, permitted July 2010 (at 65,000t more than anticipated). Only the minimum number of sites to meet the apportionment would be allocated. 9. 2012-2026 East Sussex Submission Plan 2012. Operator has suggested a higher figure (400,000) but that is approximately the same as the total for this site when first permitted in 2003 (380,000) and does not seem plausible. 10. No apportionment figure is provided however the approximate current level of production, as advised by operator is 25,000 to 30,000 tpa. 11. Table 11, (East Sussex Plan, 2012). 12. East Sussex Plan, 2012 states that no separate soft sand landbank will be used. 13. 2009-2026 Adopted Core Strategy, 2011. 14. Calculated: Surrey's low estimate requirement gives a total apportionment for the period of 7.33mt. 15. Primary Aggregates DPD, 2011. Total permitted is 7.96mt but only 5.68mt will be available in plan period. 16. Tables 3&4 in PA DPD, 2011. NB. although the result is a shortfall in reserves likely to 'come online' in the plan period, the current permitted reserve is actually greater. 17. 2012-2030 Core Strategy - Strategy & Policy Directions Consultation, May 2011. No separate soft sand apportionment is proposed. 19. Kent AMR 2009. 20. Approximate total of soft sand sites in Preferred Options Allocations.

South Downs National Park - Soft Sand Study August 2012 29 8. Analysis of Reserves Information

8.9 The values in Column G represent the amount of reserves specifically identified at sites or areas within the submission plans or, in the case of West Sussex and Kent those identified at the most recent planning stage („long list‟ sites and Preferred Options Allocations, respectively) and contain therefore greater amounts than are likely to be put forward in submission documents. 8.10 Finally, Column H shows the resulting surplus or shortfall of sand & gravel or soft sand that each plan (or early stage of plan) represents. A total is given across the study area MPAs, and for the study area plus Surrey and Kent. 8.11 The figures in Tables 8.1 and 8.2 incorporate a number of important points / assumptions for which there are notes given beneath the tables and in the following text. Sand & Gravel Reserves

8.12 Table 8.1 shows that for sand and gravel provision it is likely that, despite showing slight shortfall17, Hampshire will have sufficient resources available for their plan period (however, the existing reserves at Kingsley are included in the calculation). The surplus figure for West Sussex is large as it contains the reserve amount for all long-list sites. In reality this figure will be reduced during subsequent stages of the minerals plan development process. However, the outlook is positive given that so much reserve has been put forward and found to be „acceptable in principle‟. In East Sussex the current permitted reserves are deemed to be sufficient for the coming plan period and a surplus is also forecast, although it has been noted18 that the market for approximately half of the output of soft sand in East Sussex is in Kent. 8.13 Also shown in Table 8.1 are similar data for Kent and Surrey. Both MPAs have a surplus: for Surrey, this is because the MPA is planning for slightly more mineral than apportioned (24mt against 22.94mt „proposed changes‟ requirement) and; for Kent, this surplus figure could be slightly less due „current‟ permitted reserves only being found for the beginning of 2011 (i.e. the existing reserves and planned reserves may need to viewed over 20 years, not 19). Soft Sand Reserves

8.14 Hampshire have developed a sales based apportionment based on the 10 year average of 0.28mt. Table 8.2 shows that there is a 0.92mt surplus of soft sand over the required apportionment plan period which may or may not help cover any reduction in soft sand reserves, as a result of silica sand issue at Kingsley. The amounts required from unallocated opportunities, as detailed in Table 8.1, relate only to sharp sand and gravel, not soft sand.. 8.15 The apportionment figure for soft sand in West Sussex is based on 80% of the total sand & gravel reserves in the County, this being the highest of three sales-based ratio options considered in BP3. The table shows that, if they are all allocated, the „acceptable in principle‟ long list sites would represent a surplus of around 6.75mt, however, in practice, only enough soft sand to meet the apportionment will be allocated. If the „proposed changes‟ to the SE Plan apportionment were to be adopted in West Sussex, rather than the „Locally Derived‟ apportionment there would be a shortfall. 8.16 There is no apportionment for soft sand proposed in East Sussex but the permitted reserves have been included for completeness. These reserves relate to a single site and are taken from the 2012 Plan. This amounts to just 3% of the total sand & gravel reserves in the County, 19. If this percent is applied to the potential surplus, soft sand represents around 0.072mt of the surplus.

17 Based on the historical contribution from non-allocated opportunities. 18 Pers. comm. East Sussex County Council, August 2012 19 although a higher (confidential) figure has been reported to this study‟s authors by the operator. Pers. comm. S. Dudman, March 2012 South Downs National Park - Soft Sand Study August 2012 30 8. Analysis of Reserves Information

8.17 Outside of the study area, Surrey has a projected surplus for soft sand and this is because the MPA plan to enable production of 9mt20 (Policy MA1) against the „proposed changes‟ requirement of 7.33mt. Given that only 8.38mt is identified in their Plan (5.68mt in permitted reserves and 2.7mt in the single soft sand Preferred Area) it could be considered that Surrey have a small shortfall against Plan. However, only 5.68mt of a total permitted 7.96mt is used to meet the apportionment within this plan period and it may be that any shortfall could be remedied by upping the production at sites with reserves permitted beyond end of the plan period. 8.18 In Kent, there are permitted and potential soft sand reserves of 26.9mt but no separate apportionment is proposed. The soft sand figures represent 48% of the permitted reserve and 73% of the Preferred Options Allocations. Together, they represent 61% of the reserves potentially available in the next plan period and theoretically therefore also represents 61% of the potential surplus – some 8mt. Potential Influence of National Park Status on Soft Sand Provision

8.19 Only the West Sussex County area has the potential for allocated sites within the National Park (excluding the Kingsley Quarry extension site in Hampshire). Table 8.3 below shows the potential effect on sand & gravel and soft sand provision if these sites are excluded from the calculations. The table indicates that there would not be a shortfall in all sand & gravel, however, this would depend entirely on almost all of the long list sites outside the SDNP being included in the submission plan (and subsequent approval/adoption of this Plan). 8.20 However, the effect of removing the estimated 12.065mt of soft sand in sites within the SDNP is a shortfall of 4.4mt. In the longer term (beyond the current Plan period), as existing permitted reserves within the National Park become exhausted, the shortfall would increase significantly.

Shortfall / surplus1 Potential allocations inside Remaining shortfall County Area (mt, see tables 8.1 & 8.2) the Park (mt) / surplus (mt) Hampshire 0.920 0 0.920 West Sussex 16.249 14.9652 1.284 East Sussex 2.400 0 2.400 Total S&G 4.604 Hampshire 0.920 0 0.920 West Sussex 6.750 12.065 -5.315 East Sussex 0 0 0 Total Soft Sand -4.395 Table 8.3 Shortfall or surplus result for Sand & Gravel and Soft Sand if potential future reserves in the SDNPA are excluded from the calculations. 1. Against locally derived apportionments. 2. All long list sites except Ham Farm plus the two sand & gravel sites in the long list (2009) that sit within the SDNP: „Land adjacent to Valdoe Quarry‟ and „Land at Redvins‟.

Discussion

8.21 The foregoing analysis has demonstrated that the existing / emerging Plans for East and West Sussex county areas, and for the MPA of Hampshire are likely to be able to make sufficient provision for soft sand for most of the relevant Plan periods (assuming that the potential sites identified are brought through to the adopted plans). 8.22 The majority of the existing sites and potential allocated or safeguarded future sites for the working of soft sand within West and East Sussex Counties are located within or immediately

20 South Downs National Park - Soft Sand Study August 2012 31 8. Analysis of Reserves Information

adjacent to the National Park. This is largely a reflection of the distribution of soft sand resources (as described in Section 3). 8.23 It follows that, as joint local mineral plans are developed with the South Downs National Park, these will either need to reflect the importance of traditional supply areas and sites within the Park in maintaining the necessary supplies of soft sand for use in adjoining areas, or there will have to be a change in future supply patterns, with a requirement for output from additional sites outside of the SDNP in West Sussex MPA and Hampshire MPA, and perhaps from further afield. 8.24 Whilst mineral extraction is not altogether precluded from National Parks, any new applications are required by the NPPF to be, as far as is practical from outside National Park other than in exceptional circumstances, and where it can be demonstrated that they are in the public interest. Consideration of such applications is required to include an assessment of the need for the development; the cost of and scope for developing elsewhere, outside the designated area; and any detrimental effects on the environment, the landscape and recreational opportunities. Whilst similar restrictions applied to the former South Downs AONB21, the existing permissions for mineral extraction were nevertheless granted. This contrasts with the neighbouring Surrey Hills AONB, where future soft sand sites will be resisted22,23. This may or may not set a precedent for continued mineral extraction within the SDNP, depending on the extent to which the differences in approach resulted from clear differences in demand, public interest and environmental impacts. 8.25 Thus, although the need for soft sand can be demonstrated by reference to existing demand, as discussed briefly in Section 6, and although the acceptability or otherwise of potential allocations has begun to be tested through the local plan process, consideration must also be given to the options available for meeting this demand from other sources outside the National Park. This is discussed in the next Section.

21 As with the current NPPF, previous National Policy for minerals, as set out in Minerals Policy Statement 1 (2006) and before that in Minerals Planning Guidance Note 6 (1994) has always been the same for both National Parks and AONBs, in each case requiring that major developments should not take place other than in exceptional circumstances, and that they should be subject to the most rigorous examination, and demonstrated to be in the public interest. 22 There are no allocations for soft sand in the Surrey Hills AONB, but there is however an allocation for silica sand. 23 Policy MC2, Surrey Core Strategy DPD, 2011 and para 3.7 “There is a presumption against major new workings of soft sand within the Surrey Hills Area of Outstanding Natural Beauty, because it is not so scarce as to justify sufficient need” South Downs National Park - Soft Sand Study August 2012 32 9. Planning & Sustainability Implications of Altering the Traditional Supply Pattern

9. Planning & Sustainability Implications of Altering the Traditional Supply Pattern

Introduction

9.1 In recognition of National Policy regarding future planning applications for mineral extraction within National Parks, there is a need to consider potential alternative resources of soft sand which may need to be called upon to maintain future supplies, and to consider the broad sustainability implications of placing increased reliance on such sources in the years ahead. Although the potential need for such supplies has been shown to be limited during the Plan periods covered by existing and emerging Local Plans, this will increase significantly in the longer term as existing permitted reserves within the SDNP are exhausted. Consideration of alternatives does not imply that they will necessarily be required, but it is a step towards reaching a balanced and informed decision regarding future supply patterns. 9.2 Therefore, the potential policy responses of the SDNPA to extraction of soft sand within the Park will depend on the sustainability implications of changing patterns of supply and may be an all or nothing approach, or somewhere in-between. Options include: a) Continue the current style of extraction by allowing future supplies of soft sand from sources within the SDNP; b) Restrict the amount of extraction within the SDNP to a level lower than the current one; c) Do not allow any future supplies of soft sand to come from the within the SDNP, once current permissions have run their course. 9.3 In options b) and c) alternative terrestrial sources of soft sand will need to be found outside the SDNP. Generally, and insofar as the availability of unconstrained resources will allow, alternative sources most likely to be proposed in future will be those located close to existing sites, since these will generally be best placed to provide comparable materials and to serve the same market areas. 9.4 In the sub-sections below, the type of potential sustainability implications arising from alternative sources of land-won soft sand are briefly described, subsequent text discusses the practicality and sustainability aspects of the potential alternatives for provision of soft sand outside of the SDNP. Sustainability Issues

9.5 Sustainability issues which would need to be considered in relation to any of these potential alternative supply sources will comprise a mixture of local environmental and employment issues, and wider transport-related or product-related issues. None of these can be addressed in detail without being able to construct specific scenarios for comparison, since they will all be influenced by site-specific details regarding environmental constraints, mitigation options, employment factors, transport distances and routes, and product types. Some indications can, however, be given, regarding the nature of the issues which would need to be considered in any future detailed analysis. The broad groups of sustainability implications considered in this Section are: 1. Local environmental and economic impacts 2. Transport-related impacts; and 3. Product-related impacts 9.6 Local sustainability issues relate primarily to the wide range of factors that are normally considered within a site-specific Environmental Impact Assessment. Although the constraint

South Downs National Park - Soft Sand Study August 2012 33 9. Planning & Sustainability Implications of Altering the Traditional Supply Pattern

maps presented in Appendix A provide some indication of the likely sensitivity of the various potential source areas, they deal only with a limited number of major constraints and do not provide any information regarding local priorities. Additional issues to be considered include the site-specific impacts relating to all ecosystem services, including the scope for mitigation and enhancement. This goes far beyond any impression that could be gained from an analysis of mapped environmental constraints. 9.7 Transport issues are primarily relevant where existing sites within the SDNP are to be substituted by other sites located in very different resource areas (e.g. West Hampshire, Surrey or Kent). More generally, potential substitute resources that are located reasonably close to existing sites would probably have limited relative sustainability implications in terms of transportation. This would also probably apply in terms of employment. 9.8 Whilst these issues cannot be assessed in any detail without more precise knowledge of locations and specific substitutions, the more general observation can be made that, with increasing distance there are increased fuel and associated carbon emissions. Depending on the routing of the vehicles there might also be increased traffic impacts associated with heavy lorries on minor roads. Equally, however, those impacts might actually be reduced by virtue of travelling along major highways (or by other means e.g. rail or water) to the market destinations (e.g. along the south coast) rather than along country roads through the SDNP. This highlights the importance of needing to compare specific alternative scenarios. 9.9 One further aspect of sustainability to be taken into account is that relating to the suitability or otherwise of the alternative materials for the intended end uses involved. Soft sand can sometimes be replaced with sharp sand in mortar, but this will generally require increased quantities of water and cement to achieve a comparable degree of workability and performance, and might also give rise to the need for artificial additives such as plasticisers. These again

have cost implications and may also give rise to increased levels of embodied CO2 within the construction materials. Potential Alternatives

9.10 The following alternatives for supply of soft sand are grouped under headings that relate to the meeting or amending current apportionment. „Current‟ means those apportionments so far defined in planning policy. Marine Sources 9.11 Although it is not part of the scope of this work to look at marine-based alternatives for the supply of soft sand, they are mentioned briefly here for completeness. 9.12 Marine sands are often formed by the same processes that have created terrestrial sand deposits and therefore, comparable sands could be anticipated in an offshore situation. Marine sands are used in the production of mortar24 and the Crown Estate25 indicate that there are areas of the sea bed in the south east that could provide suitable raw materials. 9.13 Although they identify some issues that would need to be resolved, the Crown Estate “believe there is potential for marine sources to provide a viable “soft” sand as an alternative to land based quarrying”. They have identified the following issues as relevant: being able to meet colour and grading expectations26; the logistics of onshore handling and/or processing; retention of the bottom end of the sand grading as material is dredged (particularly to meet building sand grading specification) and customer product acceptance. Options put forward for providing the

24 Indeed British Marine Aggregate Producers Association (2002) 25 Dr I Selby, pers. comm., August 2012. 26 potentially, there may be appropriate resource areas already within some consented licences on the south coast. South Downs National Park - Soft Sand Study August 2012 34 9. Planning & Sustainability Implications of Altering the Traditional Supply Pattern

desired products are: targeting particular sandbanks for the appropriate grades; screening for the appropriate grade at sea; or, screening on land. 9.14 Brief research27 indicates that, in order for marine sands to offer a suitable alternative to the current land-won pattern of soft sand supply, wharf and fleet capacity could be key. Phased long-term investment to enable permanent working above the current capacity might be required, or the marine materials that might otherwise be exported could be sold into the south east. Either way, a reliable UK market could be needed as justification. Land-won sources: Meeting Current Apportionments 9.15 A) Do not have a separate soft sand apportionment in West Sussex: The total sand & gravel requirement may well be met from sites outside the SDNP (subject to refinement of the „long list‟ of sites) and if no soft sand apportionment is identified for West Sussex, then the issue of extraction within the Park may be „solved‟ in this way. However, the duty of MPAs to provision for those minerals which have distinct markets (as required by the NPPF) may not then be seen to be fulfilled. 9.16 B) Look for sources outside of the SDNP but within West Sussex for allocations: In West Sussex, the only resources outside the SDNP are those located close to the Park boundary, between Storrington, Henfield and Keymer. Currently active pits and those which are being considered as site allocations in these areas are all located in the western part of this outcrop, close to Storrington (see Figure C.1 in Appendix C). The remainder of the outcrop, further east, is narrower, implying a reduced thickness of mineral, though it may be feasible to develop small- scale sandpits within these areas, subject to more detailed geological investigations and, of course, to acceptability in planning and environmental terms. No soft sand sites have been worked in the eastern outcrop in at least the last four decades. 9.17 As shown on Figure C.1, the resource is generally free from mapped major environmental constraints however, the River Adur cuts through this low lying area and it may be that the reserves underlie floodplain in this location. In addition, part of the outcrop is sterilised by the town of Henfield and various major roads. It is considered unlikely that any sites within that area would be able to accommodate much, if any of the soft sand component of sand & gravel apportionment currently ascribed to West Sussex. In practice, any future development of the resources within this area might be able to substitute for West Sussex sites within the eastern part of the National Park, but for those further west, substitution would be more likely to involve the resources around Bordon or north east of Southampton and Fareham, in neighbouring Hampshire (see below). Land-won sources: Reducing the Soft Sand Requirement in West Sussex 9.18 The following four alternatives involve a reduction in the apportionment of soft sand for West Sussex. 9.19 C) Within the study area, recognise the reserves in East Sussex as an „apportionment‟ thereby offsetting some of the cross-boundary shortfall: This „apportionment‟ could reflect the remaining life of the permitted soft sand reserves in East Sussex because, if no extraction is to take place within the SDNP in the future, this “apportionment” could not continue beyond the existing permitted reserves. There would be no sustainability issues with this alternative to the current planning situation. However, due to the very small amount of „surplus‟ permitted reserve (0.072mt), it is not a full substitution solution. 9.20 D) Within the study area, reduce the apportionment in West Sussex and plan for greater soft sand reserves above the current Hampshire apportionment: The safeguarded resource at

27 including Mankelow (2008) and Highley (2007) (see references section). South Downs National Park - Soft Sand Study August 2012 35 9. Planning & Sustainability Implications of Altering the Traditional Supply Pattern

Whitehill-Bordon offers potential for utilisation within the Plan period and perhaps beyond but being able to make use of these minerals prior to development is vital. This is potentially a key alternative to quarrying in the SDNP, depending on the quality, quantity and workability of the reserves as prior extraction is generally a sustainable practice. This area is also close to current sites of production. 9.21 If the resources at Whitehill-Bordon cannot be utilised, finding alternatives could entail re- assessing the rejected Hampshire sites in light of the increased requirement for soft sand (for example in the areas already permitted around Kingsley and Frith End, see Figure C.2). Major potential constraints within the area around Frith End (their coverage shown on Figure C.2), include proximity to the SDNPA and Surrey Hills AONB, a SSSI and proximity to a SPA. Other factors reported as part of the draft sustainability appraisal on submitted sites in this area (Interim Report on Sites, dated February 2011) include potential negative impacts on communities and amenity, health and quality of life and the potential for cumulative impacts. 9.22 Alternatively there may need to be a call for additional sites to come forward for assessment and in terms of finding new sites the Whitecliff Sand Member (see Figure C.3) may be suitable but this would depend on the availability of that land for extraction. This is an area not currently exploited for soft sand (although historically there have been sand sites within the formation) and so there may be sustainability issues surrounding the setting up of new sites. This area is however, in close proximity of the M27 and rail lines and depots at Eastleigh, Botley and Fareham (which have been used for imported crushed rock supplies28). These depots have been proposed as safeguarded under the 2012 Submission Plan and if of sufficient quality, it would be prudent to investigate the practicality and cost of distributing soft sand from here to West Sussex markets. 9.23 In Hampshire there is also the option of utilising soft sand resources in the west of the County, within the Bracklesham Group, near to the safeguarded site at Purple Haze. All of these lie outside the SDNPA, although parts of the Bracklesham Group extend into the New Forest National Park. Other potential constraints include the River Avon SAC and Avon Valley SAC/Ramsar/SSSI and the distance from markets currently served by West Sussex and East Sussex quarries. 9.24 E) Outside the study area, reduce the apportionment in West Sussex and plan for greater soft sand reserves above the amount currently provisioned for in Surrey: There are potentially areas of soft sand resource within Surrey, along the northern outcrop of the Folkestone Formation. Most of those resources fall within AONB designations, however, and are thus subject to the same level of protection as those within the National Park. Of those which are not, the outcrop around Farnham would seem to offer similar potential to that around Bordon in Hampshire (see above and Figure C.2), and the area around Reigate, though more distant from the West Sussex sites, offers specific potential for the future extraction of silica sand. However, one or two potential sites in this area have been assessed as part of the development of Surrey‟s Plan29 and have been found to have their own sustainability implications30. Even if these sites (or other, as yet unidentified sites in this area), were found to be appropriate locations for extraction in the future, this alternative relies on the ability and willingness of Surrey MPA to co- operate. It appears that there may not be sufficient surplus of soft sand in Surrey in the short term and increasingly so in the long term.

28 Aggregate Mineral Resources Map South East England and London Region, BGS, 2008, & Need Assessment for Wharves and Rail Depots, Land & Mineral Management Ltd (February 2011) 29 Draft Appendix Four to the Environmental & Sustainability Report for the Surrey Minerals Development Framework 2004 to 2016 – February 2006 30 For example, being situated within principal aquifer, risk of cumulative impacts, local level Area of Great Landscape Value designations and proximity to residences South Downs National Park - Soft Sand Study August 2012 36 9. Planning & Sustainability Implications of Altering the Traditional Supply Pattern

9.25 F) Outside the Study Area, Reduce the apportionment in West Sussex and plan for greater soft sand reserves above the current Kent apportionment: There are potentially areas of soft sand resource within Kent that may not yet have been subject to assessment for inclusion in a minerals plan and it is possible that some of these could be identified as appropriate for mineral extraction (determining of individual applications pending). However, although much of these resources lie outside (but close to) AONB designations, they are more distant from the relevant markets. In practice this might restrict the extent to which resources in Kent would be likely to substitute for those in West Sussex or Hampshire, though in detail this would depend on individual market relationships between suppliers and consumers, and cannot be ruled out as a possibility, especially in the long term. 9.26 Notably, much of the soft sand resource in Kent is located adjacent to the M20 between Maidstone and Ashford (see Figure C.4). Generally, sites situated in this location that were not successful at sustainability appraisal had few potential adverse impacts on the environment despite being located near to the Kent Downs AONB. Rather, the potential adverse impacts related to residential amenity and communities (due to use of local roads) and unsuitable access via (or impacts along) local roads. Further to the south east, between Ashford and Folkestone there are additional mapped areas of unconstrained resource for which no sites have been put forward during production of the Kent Minerals Plan. Thus, it does appear that there may be largely unconstrained soft sand resource in this area of Kent, close to major transport routes, providing that sites could be identified for which local transport impacts are less. 9.27 As with Surrey, this potential alternative relies on the ability and willingness of Kent MPA to co- operate in planning for additional soft sand reserves but it may be that this is a long term alternative to extraction within the South Downs National Park becoming comparatively more sustainable despite the impacts of transport over longer distances. Summary

9.28 A combination of the alternatives outlined above may be appropriate in the long term. In the short term it appears that there may be some un-investigated reserves in West Sussex but investigation would be required as to the potential for that area to support extraction, particularly in relation hydrological and hydrogeological constraints associated with proximity to the River Adur. To a greater extent, there are apparent un-investigated reserves within the Whitecliff Sand Member in Hampshire. By exploring these two alternatives initially, it may be possible to alleviate some of the requirement for reserves to come from within the Park and without the need to seek cooperation of MPAs outside of the study area.

South Downs National Park - Soft Sand Study August 2012 37 10. Conclusions

10. Conclusions

Introduction

10.1 This report has considered the current and planned situation regarding soft sand provision in the study area. Land-won soft sand is specifically considered, although silica sand has been included to a limited extent and where it has particular implications for the planning of soft sand supply. The majority of the existing reserves and potential allocated or safeguarded sites for the future working of soft sand, especially within West Sussex, are located within the Cretaceous Folkestone Sand Formation, which, in the study area, is found within or immediately adjacent to the SDNP. Additional resources are found in the MPAs surrounding the SDNP in other geological formations however, soft sand extraction has historically been (and is currently) focussed within the Folkestone Formation. 10.2 Key conclusions of this study are given below and these concern the end use and markets for soft sand, the ability of the study area to provision for soft sand supply and the potential alternatives and suitability implications of reducing or curtailing future permissions for extraction within the SDNPA. Some discussion is also given to the potential for setting an apportionment for soft sand for the SDNP. Soft Sand End Uses & Markets

10.3 In most cases, the majority of output from existing soft sand quarries is used as building sand, taking advantage of its natural ability to produce „workable‟ mortar, based on grain size and shape characteristics. Alternative sources of sand which did not have the same physical characteristics (e.g. the „sharp‟ sands derived from Quaternary river deposits) would provide a relatively poor substitute, requiring additional quantities of water, cement and chemical additives in order to achieve similar workability and quality, which in turn would have both cost and sustainability implications (see below). The radius of transportation for building sand is generally within around 30 miles to distribution depots and other areas of demand along the south coast, and in parts of south west London. Greater distances (up to 45 miles) may be involved, particularly where the mineral operator is part of a vertically-integrated supply chain and thus has long term steady demand for its products from specific distribution depots in urban areas. Distance travelled also increases as minerals become more scarce locally. 10.4 As demonstrated in Section 6, above, soft sand resources are also utilised in places for concreting aggregate and elsewhere for more specialist sand products. In the case of concreting aggregate, soft sand is often blended with imports of marine-dredged sand. This is because it complements the „gap-graded‟ particle size distribution of the marine sand, and also helps to reduce the overall chloride content, resulting in a better overall product. In such cases, any replacement of the soft sand from a given location would need to come from other similar sources, and not from different types of material such as „sharp‟ river sands or additional dredged sand. 10.5 In the case of specialist „silica‟ sand, the specification requirements (though generally rather vague) are more exacting in terms of limiting the opportunities for substitution. The primary use of these specialist sands is for horticultural and sports (particularly equestrian) applications, where the primary qualities are the high silica content, rounded grains and pale colour. It is therefore unlikely that the existing source of silica sand within the study area (at and around Kingsley in Hampshire) could be substituted by sands from elsewhere in the study area, although more detailed analysis of soft sands from other sources would be needed to confirm this. It is also the case that specialist sands command higher prices and thus tend to travel greater distances to areas of demand. For this reason, and notwithstanding the relative scarcity

South Downs National Park - Soft Sand Study August 2012 38 10. Conclusions

of these materials, alternative supply sources further afield may well be able to substitute for those produced within the study area. Provision of Soft Sand in the Study Area

10.6 In terms of the emerging mineral plans for the neighbouring MPAs of National Park, the study has found that there are sufficient permitted and allocated or potentially allocated reserves to make adequate provision for soft sand for most of the relevant Plan periods (based on the use of MPA‟s locally-derived rather than sub-national apportionments and on the assumption that the allocations identified in local mineral plans are all granted planning permission in due course). However, should the pattern of supply from the SDNP be reduced or curtailed in future planning there is the potential for the apportionment formerly relating to the area defined by the county of West Sussex to be short by approximately 5.315mt. This is an equivalent potential shortfall of 4.4mt across the study area (and possibly could be larger, as the figure assumes that all sites outside of the SDNP are allocated). Alternatives to Future Extraction within the SDNP

10.7 In identifying alternative sources of supply, consideration must be given to the end uses for which the sand has traditionally been used; the suitability or otherwise of the alternative sources for meeting those specification requirements; and the locations of the markets that are being served. Soft sand can be replaced with sharp sand in mortar, but this will generally require increased quantities of water and cement to achieve a comparable degree of workability and performance, and might also give rise to the need for artificial additives such as plasticisers.

These again have cost implications and may also give rise to increased levels of embodied CO2 within the construction materials. 10.8 In terms of locating the alternative supplies, consideration will first need to be given to the immediately adjoining MPAs of East and West Sussex and Hampshire. In the case of East Sussex, there are no resources of soft sand outside the National Park. In West Sussex, the only resources outside the National Park are located very close to the Park boundary, between Storrington, Henfield and Keymer and could be subject to environmental constraints outside of those mapped (potentially, the reserves sit within the floodplain of the River Adur). In Hampshire, the safeguarded resource at Whitehill-Bordon offers potential for utilisation within the Plan period and perhaps beyond. There may also be possibilities of finding further reserves in the areas already permitted around Kingsley and Frith End (in areas outside the Park). Significant parts of the resource outcrop within these areas lies outside the National Park boundary and there may thus be scope for this area substituting for existing sources in both this part of Hampshire and neighbouring parts of West Sussex. Subject to more detailed analysis, some of these areas might be suitable for providing specialist silica sand as well as more general building sand. The Whitecliff Sand Member to the north east of Southampton and Fareham may offer the best alternative to resources within the National Park in the more immediate future, particularly given the proximity to the rail network which might be looked at for its potential to supply the resources from here to parts of West Sussex. 10.9 There are further soft sand resources in Surrey, though most of these fall within AONB designations and are thus subject to the same level of protection as those within the National Park. Therefore, Surrey itself may have increasing difficulty in meeting apportionments beyond the current plan period. There are also alternative resources of soft sand within Kent. These generally lie outside (but close to) AONB designations, but are more distant from the relevant markets. In practice this might restrict the extent to which resources in Kent would be able to substitute for those in West Sussex or Hampshire, though in detail this would depend on individual market relationships between suppliers and consumers, and cannot be ruled out as a possibility.

South Downs National Park - Soft Sand Study August 2012 39 10. Conclusions

10.10 With regard to transport-related issues, these cannot be assessed in detail without precise knowledge of locations and specific substitutions and further work on this would be needed. However, the more general observation can be made that, with increasing distance (for example, the resources in Kent) there are inevitably increased fuel and associated carbon emissions, and increased costs. Depending on the routing of the vehicles there might also be increased traffic impacts associated with heavy lorries on minor roads. However, those particular traffic impacts may actually be reduced by virtue of travelling along major highways to the market destinations (e.g. along the south coast) rather than along country roads through the SDNP. 10.11 While alternatives have been provided, these cannot be addressed adequately without being able to construct specific scenarios for comparison, since they will all be influenced by site- specific details regarding environmental constraints, mitigation options, employment factors, transport distances and routes, and product types. Local environmental issues include the site- specific impacts relating to all ecosystem services, including the extent of national and local designations relating to environmental protection but also the local scope for mitigation and enhancement. Apportionment in the SDNP

10.12 In the absence of a formal apportionment figure for the SDNP in the South East Plan, and in view of the fact that the neighbouring MPAs are basing their requirements on Local Aggregate Assessments, rather than reflecting any kind of „top-down‟ approach, it will be for the SDNPA to decide how it wishes to make provision for future aggregate production, including soft sand. Taking account of the observations outlined above, regarding alternatives and sustainability factors, and of the considerable difficulties in unravelling the complexities of market demand for soft sand in different areas, it would be very difficult to arrive at a sensible, justified apportionment figure for future soft sand production within the area. An apportionment could be based on past sales figures for sites within the national park but this would not take account of the need for Nationals Park MPAs to give consideration to alternatives outside of the Park31. Equally, however, it is clear that well defined alternatives are limited and that continued production of soft sand from within the National Park would help to avoid the adverse effects of longer-distance transportation from alternative sites and those associated with the use of less suitable alternative materials. More detailed surveys would be useful to establish the quality of the potential alternatives outside of the Park, including a better understanding of the potential for marine sands to substitute for land-won resources. 10.13 It would therefore seem prudent for the SDNPA to develop policies which allow for the continued production of soft sand from resources within the National Park, whilst also continuing to co-operate with its neighbouring MPAs to encourage the production of material from unconstrained resources in those areas. Subject to there being adequate site-specific controls on environmental impacts, this would encourage the continued operation of a free market in which material is delivered efficiently to the markets according to actual demand. This would reflect the general ethos of „Plan, Monitor and Manage‟, rather than perpetuating the outdated concept of „predict and provide‟.

31 Note: this report was written prior to the publication of the new MASS guidance which should be consulted in any further consideration of these issues. South Downs National Park - Soft Sand Study August 2012 40

References

National Department for Communities and Local Government. National Planning Policy Framework. March 2012. Department for Communities and Local Government. Technical Guidance to the National Planning Policy Framework. March 2012. Department for Communities and Local Government. National and regional guidelines for aggregates provision in England 2005-2020. June 2009 British Geological Survey. Collation of the results of the 2005 Aggregate Minerals Survey for England and Wales. May 2007. British Geological Survey. Collation of the results of the 2009 Aggregate Minerals Survey for England and Wales. October 2011. Department for Communities and Local Government. Letter to Chief Planning Officers: Revocation of Regional Strategies. 6 July 2010 Selby, I. (The Crown Estate). Marine Sand and Gravel Supply Looking 50 Years Ahead – The Challenge for Planning, unknown date.

Regional The South East Plan, Regional Spatial Strategy for the South East of England. May 2009 The South East Plan, Examination in Public November 2006 – March 2007, Report of the Panel, August 2007.

South Downs National Park Agenda Item 11, Report PC 11/11. Horncroft Quarry. 14 February 2011. Assessment of need for soft sand and alternative potential sites. Proposed sandpit at Horncroft Common, Coates Quarry. Washbourne Greenwood Development Planning Ltd. November 2010. South Downs National Park Authority Local Development Framework, Local Development Scheme. September 2011.

East Sussex East Sussex and Brighton & Hove Local Minerals Plan, Adopted November 1999. Published April 2000. East Sussex Annual Monitoring Report 2004/5. Minerals and Waste. December 2005. East Sussex Annual Monitoring Report 2005/6. Minerals and Waste. December 2006. East Sussex Annual Monitoring Report 2006/7. Minerals and Waste. December 2007. East Sussex Annual Monitoring Report 2007/8. Minerals and Waste. December 2008. East Sussex Annual Monitoring Report 2008/9. Waste and Minerals. December 2009. East Sussex Annual Monitoring Report 2009/10. Waste and Minerals. December 2010. East Sussex, South Downs and Brighton & Hove Waste and Minerals Development Framework. Analysis of Comments on the Preferred Strategy(Information Document). 2009, updated October 2011. East Sussex, South Downs and Brighton & Hove, Draft Waste and Minerals Plan, October 2011. East Sussex, South Downs and Brighton & Hove Waste and Minerals Development Framework. Information Paper 2, The Future Need for Minerals Production and Management. (Draft Consultation Document).October 2011. East Sussex Annual Monitoring Report 2010/11. Waste and Minerals December 2011. East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan. Proposed Submission Plan. (Proposed Submission Document). February 2012.

West Sussex West Sussex Minerals Local Plan, July 2003. West Sussex Minerals and Waste Development Framework, Annual Monitoring Report. December 2005. West Sussex Minerals and Waste Development Framework, Annual Monitoring Report. December 2006.

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SD Hannis, EJ Steadman, KA Linley, R Newsham. 2007. Minerals Safeguarding Areas and Mineral Consultation Areas for West Sussex. British Geological Survey Open Report, OR/07/026. 39pp. West Sussex Minerals and Waste Development Framework (MWDF), Annual Monitoring Report (AMR) 2006/7. December 2007. West Sussex Minerals and Waste Development Framework, West Sussex Wharves & Railheads Study. (Land & Mineral Management Ltd.). February 2008. West Sussex Minerals and Waste Development Framework (MWDF), Annual Monitoring Report (AMR) 2007/08. December 2008. West Sussex Minerals and Waste Development Framework Background Paper 1: Spatial Portrait, Issues, Vision and Objectives. Version 2. December 2009 West Sussex Minerals and Waste Development Framework. Background Paper 3: Minerals. Version 2. December 2009 West Sussex Minerals and Waste Development Framework. Background Paper 5: Strategic Mineral Sites. Version 2. December 2009. West Sussex Minerals and Waste Development Framework (MWDF), Annual Monitoring Report 2008/09. December 2009. West Sussex Minerals and Waste Development Framework Annual Monitoring Report 2009/10. December 2010. Draft West Sussex Minerals and Waste Development Scheme 2011-2015. April 2011. West Sussex Minerals and Waste Development Framework, Annual Monitoring Report 2010/11. December 2011.

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Other GWP, March 2010. A Study of Silica Sand Quality and End Uses in Surrey and Kent, ,. Lusty, P. A. J., Bee, E. J., Bate, R., Thompson, A., Bide, T., Morigi, A., Harris K., 2011. An evidence based approach to predicting the future supply of aggregate resources in England. British Geological Survey Open Report. OR/11/008. British Marine Aggregate Producers Association, 2002. Marine sands in mortars and screeds (downloadable pdf document. http://www.bmapa.org/documents/marine_building.pdf accessed August 2012). Mankelow, J M; Bate, D; Bide, T; Linley, K; Hannis, S; Cameron, D; Mitchell, C. 2008 Aggregate resource alternatives : options for future aggregate minerals supply in England. Nottingham, UK, British Geological Survey, 79pp. (OR/08/025) Highley, D.E.; Hetherington, L.E.; Brown, T.J.; Harrison, D.J.; Jenkins, G.O.. 2007 The strategic importance of the marine aggregate industry to the UK. Nottingham, UK, British Geological Survey, 44pp. (OR/07/019)

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Appendix A: Figures A.1 to A.3 (Resources and Constraints)

South Downs National Park - Soft Sand Study August 2012

Appendix B: Figures B.1 to B.3 (Permitted and Potential Sites)

South Downs National Park - Soft Sand Study August 2012

Appendix C: Figures C.1 to C.4 (Soft Sand Resources)

South Downs National Park - Soft Sand Study August 2012

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